NORTH PENN AREA 5 RI/FS WORK PLAN Lansdale, Montgomery County

\J-

NORTH PENN AREA 5 RI/FS WORK PLAN Lansdale, Montgomery County,

FINAL

Submitted to: ENVIRONMENTAL PROTECTION AGENCY Region III 841 Chestnut Building Philadelphia. PA 19107

Prepared Fon BLANK, ROME, COMISKY AND McCAULEY Four Penn Center Plaza Philadelphia. Pennsylvania 19103

Prepared By: THE EARTH TECHNOLOGY CORPORATION 53 Haddonfleld Road. Suite 316 Cherry Hill. New Jersey 08002 - Telephone: (609)482-5553/Fax: (609)482-6514 -PROJECT NO. 691546 SEPTEMBER 1993

AR3006I I TABLE OF CONTENTS .'"-.. . :'" •'. '••- :' -.- . • SECTION DESCRIPTION PAGE 1.0 INTRODUCTION 1 1.1 Background . 1 1.2 Project Objective 5 • 2.0 SUMMARY OF AVAILABLE INFORMATION 7 2.1 AEL , 7 2.2 Stabiius 9 2.3 KEMA/Powertest/Webcrafl/ABB 10 2.4 Byers Choice/Lindberg 10 2.5 R&B/FMC Corporation . 14 2.6 New Yorker Steel Boiler Company, Inc. 14 2.7 Neotech 17 2.8 Lumber Yard 17 3.0 ENVIRONMENTAL SETTING 18 3.1 Regional Site Setting 18 3.1.1 Regional Topography 18 3.1.2 Regional Soils " 18 3.1.3 Regional Geology 18 3.2 Site Setting 20 3.2.1 Site Topography 24 3.2.2 Site Soils 24 3.2.3 Site Geology 24 3.3 Regional Climate 24 3.4 Hydrology 26 3.4.1 Surface Water 26 3.4.2 Groundwater 26 3.4.2.1 Shallow (Perched) Aquifer 26 3.4.2,2 Bedrock Aquifer 26 i ' " . ' • ' 3.4.3 Monitor Wells 28

AR3006I2 TABLE OF CONTENTS (Continued)

SECTION DESCRIPTION PAGE 4.0 SUMMARY OF PAST ENVIRONMENTAL INVESTIGATIONS 33 . 4.1 AEL 33 4,2 R& B/FMC 36 4.3 Stabiius 39 4.4 KEMA/Powertest/Webcraft/ABB 39 . . .4.5 Existing Analytical Data QA/QC 43 4.6 Aerial Photograph Interpretation • 43 5.0 SUMMARY OF PAST REMEDIAL ACTIONS 45 6.0 CONCEPTUAL SITE MODEL 48 6.1 Sources of Contamination 48 6.2 Contaminant Migration Pathways 48 6.3 Receptors 52 7.0 PRELIMINARY RISK ASSESSMENT 53 / - • • . . • . . • ' - ' ' - . . 8.0 DEVELOPMENT OF POTENTIAL REMEDIAL ACTIONS 54 8.1 Preliminary Remedial Action Objectives 54 8.2 Identification of Potential Applicable or Relevant . and Appropriate Requirements (ARARs) , 55 8.3 Potential Remedial Actions 59 8.3.1 Air 59 8.3.1.1 No Action 59 8.3.1.2 Source Removal 59 .8.3.1.3 Source Control ' 59 • . • . • • 8.3.2 Groundwater 60 • . ' • , 8.3.2.1 No Action 60 8.3.2.2 Institutional Actions 60 8.3.2.3 Containment 6X) 8.3.2.4 Collection, Treatment, and Discharge 61

AR300613 TABLE OF CONTENTS (Continued)

SECTION DESCRIPTION PAGE 8.3.3 SoU 61 8.3.3.1 No Action $! .8.3.3.2 Access Restrictions 6i 8.3.3.3 Capping 61 8.3.3.4 Excavation, Treatment, and Disposal 62 8.3.3.5 In Situ Treatment .63 8.3.4 Surface Water -63 , 8.3.4.1 No Action \ 64 8.3.4.2 Runoff Diversion 64 8.3.4.3 In Situ Aeration ' 64 8.3.5 Sediment •'-. 64 8.3.5.1 No Action 64 8.3.5.2 Excavation, Treatment, and Disposal 65 i . ' • . ' • - . 9.0 DATA GAPS REQUIRING RI/FS TASKS 66 ...... * • 9.1 Soil Contamination , 66 : . " , * • 9.1.1 AEL 66 9.1.2 Stabiius 66 9.1.3 R&B/FMC 66 , 9.1.4 Powertest ' 66 9.1.5 Webcraft 67 9.1.6 New Yorker Steel Boiler , 67 9.2 Groundwater Contamination 67. . . 9.3 Hydraulic Characteristics of Aquifers , 67 9.4 Soil Physical Characteristics 68 9.5 Surface Water, Sediments, and Stormwater Characteristics 63 •. - 9.6 Treatability of Groundwater 68 9.7 TreatabiUty Studies 68 9.8 Data Quality Objectives 68

AR3006IU TABLE OF CONTENTS (Continued)

SECTION DESCRIPTION fii PAGE 10.0 RI/FS SCOPE OF WORK 71 10.1 Project Planning 71 , 10.1.1 Sampling and Analysis Plan . 73 10.1.2 Quality Control 73 10.1.3 Project Management 73 10.1.4 Meeting Attendance 74 10.2 Community Relations - 74 10.2.1 Community Relations Plan 74 10.2.2 Community Relations Implementation 74 10.3 Field Investigation 75 10.3.1 Site Mobilization , 75 10.3.1.1 Subcontractor Procurement 75 10.3.1.2 Equipment Procurement and Site Setup 75 . 10.3.2 Surveying 75 10.3.3 Well Inventory 76 10.3.4 Soil Gas Survey 76 10.3.5 Soil Investigations 83 10.3.6 Groundwater Investigations . 91 10.3.6.1 Phase 1 - Groundwater Investigations 91 10.3.6.2 Phase 2 - Groundwater Investigations 94 10.3.6.3 Phase 3 - Groundwater Investigations 99 10.3.7 Surface Water and Sediment Investigations 103 10.3.7.1 Surface Water Runoff Flow Paths and Surface Water Bodies 103 10.3.7-2 Surface Water and Sediment Sampling 104 10.3.8 Quality Assurance/Quality Control 104 103.9 Data Validation 107 10.3.10 Assessment of Risk 107 10.3.11 RI Derived Waste Disposal 107 10.4 Remedial Investigation Report 109 , 10.5 Feasibility Study 109

ftR3006l5 •TABLE OF CONTENTS (Continued)

SECTION DESCRIPTION PAGE 10.5.1 Remedial Action Alternative Screening . 110 10.5.2 Development of Alternatives 110 10.5.3 Detailed Analysis of Alternatives 111 . 10.5.3.1 Compliance with ARARs . Ill 10.5.3.2 Short-Term Effectiveness HI , 10.5.3.3 Long-Term Effectiveness and Permanence 111 10.5.3.4 Overall Protection of Human Health and the Environment • , • ill 10.5.3.5 Reduction of Toxicity, Mobility, and Volume of Contaminants 112 10.5.3.6 Implementability 112 10.5.3.7 Cost 112 10.5.4 Summary Comparisons and Recommendation. of Remedial Alternatives 112 10.5.5 Feasibility Study Report 113 11.0 SCHEDULE 114 12.0 REFERENCES 116

AR300&16 LIST OF FIGURES

SECTION DESCRIPTION 1-1 Site Location Map 2 1-2 North Perm Area 5 Site Plan 3 2 - 1 Site Plan -American Electronic Laboratories 8 2-2 Site Plan/Areas of Environmental Investigation - Stabiius 11 2. - 3 Site Plan - Powertest 12 2-4 Site Ban - Webcraft 13 2-5 Site Plan - R&B/FMC 15 2-6 Site Plan - New Yorker Steel Boiler 16 3-1 Regional Topographic Map V - 19 3-2 Regional Geologic Map . 23 3-3 Monitor Well Locations - American Electronic Laboratories 29 4-1 Areas of Environmental Investigation American Electronic Laboratories 34 4-2 Areas of Environmental Investigation - R&B/FMC 38 4-3 Site Plan/Monitor Well Locations - Powertest Facility 41 6-1 Groundwater Contours Deep Aquifer March 30, 1989 American Electronic Laboratories 50 10-1 Soil Investigation Areas-American Electronic Laboratories 77 10-2 Soil Investigation Areas-R&B/FMC 78 10-3 Soil Investigation Areas-Stabflus 79 10-4 Soil Investigation Area-Powertest Facility 80 10-5 Soil Investigation Area-Webcraft Facilities 81 10-6 Soil Investigation Areas-New Yorker Steel Boiler 82 10-7 Proposed Monitor Well Locations - North Perm Area 5 Site Plan 97 10-8 Surface Water and Sediment Sample Location Map 105 11-1 Schedule 115

AR30Q617 LIST OF TABLES

SECTION DESCRIPTION PAGE 1-1 Site Chronology 4 3-1 Geologic Section for Montgomery County, Pennsylvania 21 3-2 Soil Series Found in Regional Area 25 3-3 AEL Well Construction and Water-Level Data 30 4-1 Groundwater Monitoring Well Sampling Analytical Results TCE Concentration in UG/L 37 4-2 R&B/FMC Groundwater Analytical Results 16 September 1987 40 8-1 Potential Chemical Specific Groundwater and Surface Water ARARs and TBCs for Organics 56 8-2 Potential Federal and State Action-Specific ARARs 58 9-1 Data Needs for the Area 5 Site , 70 10- 1 RI/FS Tasks 72 10-2 Soil Boring Program ! 85 10-3 Compounds to be Analyzed by the Field GCJ ,86 10-4 Target Compound List (VOCs Only) Target Analyte List and selected indicator Parameters 87 10-5 Groundwater investigations-Rationale for Proposed Monitor Well Locations 96 10 - 6 Phase 2 Groundwater Sampling Program 98 10-7 : . Groundwater Investigations-Proposed Monitor Well Construction Details 100 10-8 Phase 3 Groundwater Sampling Program . 102 10-9 Surface Water, Sediment and Sewer Sampling Program 106 10 - 10 Summary of QA/QC Program . 108

AR3006 I ft LIST OF ABBREVIATIONS

RI/FS Remedial Investigation and Feasibility Study NPL National Priorities List NPWA North Perm Water Authority PADER Pennsylvania Department of Environmental Resources VOCs Volatile Organic Compounds TCE Trichloroethene PCE Tetrachloroethene NUS NUS Corporation TCA 1,1,1-trichloroethahe PRP's Potentially responsible parties AEL American Electronic Laboratory R&B R&B, Inc. CERCLA Comprehensive Environmental Response, Compensation, and Liability Act of 1980 BCM Betz. Converse & Murdoch MEK Methyl Ethyl Ketone FMC FMC Corporation MSL Mean sea level GPM Gallons per minute TSD TSD Environmental Services . USGS United States Geological Survey , . NWWA North Wales Water Authority UST Underground Storage Tank MCL Maximum Contaminant Level DCA Dichloroethane DCE Dichloroethene ARARs Applicable and Relevant or Appropriate Requirements EPA Environmental Protection Agency RFD Risk Reference Dose TBC To-Be-Considered NCP • National Contingency Plan NPDES National Pollutant Discharge Elimination System POTW Publicly Owned Treatment Works RCRA Resource Conservation and Recovery Act DQOs Data Quality Objectives SAP Sampling and Analysis Plan . QA/QC Quality Assurance/Quality Control CLP Contract Laboratory Program SAS Special Analytical Services QAPP Quality Assurance Project Plan FSP Field Sampling Plan CRP Community Relations Plan PID - Photoionization detector GC Gas Chrornatograph

AR3006I9 LIST OF ABBREVIATIONS (Continued)

-• • v • HSP Health and Safety Plan TCL Target Compound List x RPM Regional Project Manager SARA Superfund Amendments and Reauthorization Act PHE " Public Health Evaluation

AR300620 SECTION 1 INTRODUCTION

This work plan presents the technical approach and methodologies developed to complete the Remedial Investigation and Feasibility Study (RI/FS) for the North Penn Area 5, National Priorities List (NPL) site. The site is one of five NPL listings made final in March 1989 within the North Perm Water Authority (NPWA) service district in Montgomery County, Pennsylvania. A sixth site was made final in September 1989. Previous investigations by the NPWA, the Pennsylvania Department of Environmental Resources (PADER), and U.S. EPA, Region HI detected levels of volatile organic compounds (VOCs) in groundwater samples from wells at each of the sites. The primary contaminants identified to date have been trichloroethene (TCE), tetrachloroethene (PCE) and 1,1,1 trichloroethane (TCA). This work plan was prepared to address specifically the study area known as North Penn Area 5. Figure 1-1 presents a site location map of North Penn Area 5. 1.1 Background North Penn Area 5 is located within Montgomery and Hatfield Townships in Montgomery County, Pennsylvania. A preliminary boundary was defined based on existing groundwater quality data by NUS, as shown in Figure 1-2. Initially, EPA's contractor CH2M HILL prepared a wo± plan to conduct the RI/FS for North Penn Area 5 (Area 5). Subsequently a committee was formed of four (4) potentially • > responsible parties facility to develop the final work plan for implementation. The facilities >—' committee is comprised of AEL, R&B^Stabflus (formerly Gas Spring) and FMC. The Earth Technology Corporation (Earth Technology) was retained to conduct an evaluation of existing data and develop a revised RI/FS work plan for submittal to EPA. This work plan includes additional data collected beyond the CHjM HILL work plan. Table 1-1 provides a chronology of activities associated with the site. Groundwater sampling was initiated in 1980 after the NPWA discovered TCE, 1,1,1-trichloroethane (TCA), and tetrachloroethene (PCE) contamination in NPWA Well NP-21 in 1979; pumping of well NP- 21 was discontinued at that time. In July 1986, NUS Corporation completed a site discovery for the EPA. The site was scored using the Hazard Ranking System in Octbber 1986 and was proposed for the NPL in January 1987. , ' . ' ' . *•,'.' . • ' In February 1989, CH,M Hill collected residential well samples and on March 31, 1989, the NPL listing became final. .

AR30062I SCALE: 1:24000

1000 2000 3000 4000 5000 9000 7000 FEET 11 1/2* III 0*07* 204 MILS Ml 2MIL3 1 KILOMETER

' UTM GRID AND 1983 MAGNETIC CONTOU/*ntiT/MiRn INTERVAikiTentfiiL 2*A0 eee-FEETr ______CENNORTHT DECLINATIO EH OP SHEENT AT The Earth Technology NORTH PENN Corporation AREAS TELFORO AND DOYLESTOWN. PA. QUADRANGLES U.S.G.S. 7.5 MN.TOPOGRAPHIC MAP SITE LOCATION MAP 8 '______PROJECT NO. 591346_____FIGURE 1-1 BREWER ASSOCIATES w TABLE 1-1

SITE CHRONOLOGY August 1979 The'NPWA discovers TCE contamination in well NP-21, which is subsequently shut down. • January 1980 TCE spill from Baron Blakesiee truck on Stabiius property. AEL and the NPWA sign a consent agreement regarding groundwater quality testing. Sixteen monitoring wells are installed on the AEL property. March 1980 BCM submits a program for installation of recovery wells at AEL to PADER. . April 1980 Twenty-one additional wells installed on the AEL property. June 1980 An underground solvent storage tank is removed from AEL. December 1980 Buried drums are discovered on AEL property. January 1981 AEL investigated and remediated buried drums found on the property to the satisfaction of PADER. . April 1981 Consent Order and Agreement between AEL and PADER is signed. August 1982 Excavation of AEL's solvent storage pad area is completed. '.-•'. " ' • ' ' •••''• June 1986 EPA Region III requests information from facilities under CERCLA Section 104(e), ' .'• July 1986 104 (e) information is provided by Lindberg Industries. NUS completes the Site Discovery of Groundwater Contamination in •, the North Penn Area. August 1986 104(e) information is, provided by Stabiius and AEL. October 1986 The site is scored using the Hazard Ranking System. November 1987 . Techlaw completes the Final Facility Report; North Penn Area, . American Electronics Laboratory. Inc. Site. May 1988 . ATSDR releases the Preliminary Health Assessment. September 1988 Versar completes the Technical Evaluation of Zone of Contamination 5, American Electronics Laboratories, Inc. Site, Montgomery County, Pennsylvania. February 1989 CHjM Hill, under contract to EPA Region III, samples residential wells. , V • . ^ ' ' ' "'".••'•-_•• March 1989 The NPL listing becomes final. / . June 1989. EPA, in a letter to the file, identified the need for 5 follow- up and 10 new 104 (e) letters to be sent to facilities. August 1990 Draft Work Plan completed by CHjM HILL. , July 1991 Facility committee formed and retains Earth Technology to prepare revised RI/FS Work Plan. . •'

AR30062U This Work Plan outlines the technical approach and associated activities to conduct the RI/FS for Area 5. It is the culmination of data gathering and analysis activities to identify data gaps < '~s to be addressed by the RI/FS. Initially the existing data was collected, compiled and analyzed / to develop a conceptual site model, identify additional data needs, and determine required ^-^ RI/FS activities. Subsequent sections of this Work Plan review existing data for the site, available from previous investigations; the environmental setting; past remedial actions; and presents a preliminaryrisk assessment. In addition, preliminary potential remedial actions are developed for use during completion of the 'RI/FS. The RI/FS tasks are presented and include a . discussion of the data needs, defined as a result of the evaluation of existing data; development of the conceptual site model; and performance of the preliminary risk assessment. In this Work Plan the terms "area" and "site" are used interchangeably to refer to Area 5 as shown in Figure 1-2. The terms "facility" and "property" are used hi reference to the plant and property, respectively, of an individual facility. / 1.2 Project Objective The overall objective of this project is to conduct an RI/FS to accomplish the following: o Characterize the hydrogeology of the site, particularly with respect to the locations and orientations of water-bearing fractures and the directions of groundwater flow. o Define the nature and extent of contamination in soil and groundwater, and A J define the site boundaries based on the extent of groundwater contamination. o Identify sources of contamination, including contaminated soil, storage tanks, and sewer lines at the Area 5 facilities, and identify the nature and concentration of contaminants present at these sources. . ./ , o Identify the nature of contaminant migration at the site. o Perform a risk assessment to evaluate potential threats to human health arid the environment. • o Develop and evaluate a range of final remedial action alternatives to control any identified human health or environmental threats. The RI/FS will be conducted in accordance with the October 1988 version of the Guidance for Conducting Remedial Investigations and Feasibility Studies Under CERCLA.

AR300625 The Area 5 site is characterized by considerable complexity of hydrogeology and contamination history. The hydrogeologic complexity includes a fractured-bedrock aquifer with strongly developed preferred directions of groundwater flow, potential groundwater discharge boundaries within the area, variability of recharge to the water table due to paving and other development, and multiple groundwater pumping centers with complicated and uncertain discharge histories. The contamination history includes many industries occupying several facilities, many different potential contaminants and several known and probably many unknown incidents of release of contaminants to the environment. When the factors of hydrogeologic complexity are combined with the uncertainty in the past use of potential contaminants at the site, the result is a system that is very difficult to characterize. ~ \ Therefore, the principal objectives of this RI/FS include: (1) defining the site hydrogeology, the nature and extent of contamination in the environment, the location of the site boundaries, and the potential pathways of contaminant migration; and (2) developing remedial action alternatives suitable, for protecting human health and the environment. The RI/FS tasks proposed in this Work Plan are based on the present conceptual model of contaminant distribution and migration at the site, which is a product of appropriate information presently available, and are designed to meet the overall and principal project objectives. The groundwater portion of the investigation is focused on providing information to support the design and implementation of remedial measures over the entire site. Insofar as possible, RI/FS tasks are proposed for selected facilities that have potential for soil and groundwater contamination based upon past operations, chemical use and existing environmental data. This work plan has been developed to ensure the RI data gathering process is designed to provide relevant data for the subsequent feasibility study. In order to accomplish this objective, preliminary feasibility study activities will be conducted using existing data. Using this approach will allow the characterization data to be intelligently collected to fill the data gaps and minimize excessive data collection. In addition, the work plan has been designed for the feasibility study to be conducted in concert with the RI studies.

AR300626 SECTION 2 SUMMARY OF AVAILABLE INFORMATION

This section presents a summary of the available information for each facility in Area 5. This information was derived from various documents obtained from EPA, PADER, visits to these facilities and information made available by the Area 5 facilities. In subsequent sections, the available information was analyzed and evaluated to develop a conceptual site model for Area 5. Each facility was evaluated for potential contribution to site contamination. It should be noted that limited information was available for the majority of the facilities. Therefore, the data analysis and evaluation was limited to those facilities with available information. The conceptual site model, preliminary responsibility search and preliminary risk assessment provide the basis for determining the scope of the RI/FS activities. Earth Technology evaluated data from EPA and other agencies and available data from the participating facilities. The following, sections provide summaries of available information for each facility. The information relative to hazardous material handling was obtained from various sources and covers activities as recent as 1991. '2.1 AEL ' •••••'. '-'.,_ •- • ' ••••_,••<;'••'•• AEL is an electronics manufacturing and testing facility that began operating in 1953. The facility is located on approximately 60 acres, of which 48 acres are used for industrial activities (Figure 2-1). The operations at the plant include degreasing, anodizing, and nickel, copper, tin, and lead plating. The structures at the facility include the main manufacturing plant, a plating shop (Building No. 2), a chemical storage pad, an antenna building, and a product testing building (Building No. 5). Building No. 2 also contains the waste treatment facilities for the plating effluent. An unnamed tributary of die West Branch of Neshaminy Creek flows north through the western part of the property. Most of the chemicals used and wastes generated at the AEL facility were the result of a plating and anodizing process that uses nickel, copper, tin, and lead. Halogenated organics were also used for degreasing. Water rinse Ikes from the plating operations in Building 2 were separate from the sanitary lines. High-strength wastes from Building 2 at the AEL facility, were segregated for offsite disposal, while low-strength rinse waters were sent to an equalization basin where heavy solids were removed for offsite disposal.

AR300627 s i 0>

ro CO ' A 1979 chemical survey performed by BCM revealed that AEL used TCA, TCE, and dichlorodifiuoromethane for degreasing. Smaller quantities of other organic compounds were i identified in that survey as well, including acetone, carbon tetracliloride, chloroethanes, methyl ^—/ ethyl ketone .(MEK), and styrene. Some spent solvents were kept in a 400-gallon underground storage tank located in the chemical storage area, between Buildings 2 and 5, while others were kept in 55-gallon drums prior to removal. Inorganic chemicals identified in the 1979 survey, were antimony, nickel, tin/copper, lead, aluminum, silver, cadmium, chromium, cyanides, acid, and caustic. - The solvent storage tank was excavated and disposed of in June 1980. The surrounding soils were excavated, treated by shredding (aeration), and replaced in the excavated area. In December 1980, BCM conducted a reconnaissance survey to locate and recover several buried drums that were suspected to be on the property. Visual and magnetometer inspections revealed the presence of several buried drums. Six 55-gallon,drums and two 1-gallon containers were identified and removed. The majority of the drums were still competent with one (1) drum partially crushed and several rusted through in a few areas. Two (2) of the , drums contained liquids and three (3) contained sludges. The sixth drum was empty. Five (5) soil samples were collected from soil located immediately beneath the drums. These samples were analyzed for metals and purgeable halocarbons and PCBs. The results of the analysis indicated minimal contamination associated with the drum contents. Based upon discussions with PADER, no further remedial action was deemed necessary. The location of the .buried drums was the wooded western portion of the property. In 1979, investigations were conducted in an area on AEL's property described as a pond. , j This pond iy currently not present on the property. The results of this investigation could not • ^-—^ establish the source of contamination. Based upon aerial photograph review, the pond may have been located in the wooded western portion of the property. At least two sanitary sewer lines exist on the AEL property. One line serves AEL and runs approximately northwest from the Main Building. The other line serves Stabiius and runs southwest along AEL's northwest property line. The two lines reportedly join northwest of the AEL facility. ^ There is one onsite production well at AEL. It is located on the southwest side of the Main Building and is 300 to 350 feet deep. 2.2 Stabiius The current Stabiius facility was formerly known as Gas Spring Co. The name Change became effective on January 1, 1991 ,at the direction of Stabiius. Stabiius began operations adjacent to the AEL facility in May 1979. Stabiius records indicate that a TCE conveyor degreaser was used for cleaning steel parts at the facility. Records indicate that TCE was supplied to Stabiius by Baron-Blakeslee, Inc. from May 1979 through January 1986. Prior to 1985, TCE was delivered by tank truck and stored in a 1,000-gallon bulk tank (owned by Baron-Blakeslee, Inc.) inside the Stabiius facility.

AR300629 This bulk tank was returned to Baron-Blakeslee, Inc. in 1985 and TCE was then delivered and stored in 55-gallon drums inside the facility. TCE usage as high as 500 gallons per month in 1982 and as low as 100 gallons per month in 1985 was documented by the Stabiius in its hazardous waste manifests and invoices from Baron-Blakeslee, Inc. Spent TCE was pumped into 55-gallon drums and stored inside the facility until it was reclaimed by Baron-Blakeslee Inc. for distillation. Figure 2-2 presents a site plan of the Stabiius facility. In 1980, representatives from the NPWA and BCM observed liquid leaking from a Baron- Blakeslee truck that was pumping TCE into the storage tank at Stabiius. Most of the leaking TCE was captured in 5-gallon buckets placed beneath the truck, but small amounts leaked onto Stabiius parking lot. This parking lot. is drained by a storm drain that, enters a stormwater drainage ditch that is located south of the Stabiius Plant in the area of die Byers Choice/Lindberg facility. . There is no production well onsite at the facility. A sanitary sewer line that is used exclusively by Stabiius passes through the AEL property to connect to a municipal sewer line. 2.3 KEMA/PowertestAVebcraft/ABB Brown Boveri owned the current Powertest and Webcraft facilities until 1987; the locations of these facilities are presented in Figures 2-3 and 2-4. The smaller facility became Powertest (a subsidiary that tested electrical circuit breakers) and the larger facility became Webcraft (a subsidiary that manufactured electrical circuit breakers). Webcraft is now an independent company that prints and distributes bulk mailing, and uses TCE in some of its process materials. According to a Brown Boveri official, chlorinated solvents have never been used at what is now the Powertest facility. Reportedly, TCA was used at the Webtraft facility during Brown Boveri's ownership. Both facilities are located just north of the Montgomery County line in Bucks County, Pennsylvania. An unnamed tributary of the West Branch of Neshaminy Creek flows north between the two facilities. 2.4 Bvers Choice/Lindberg Liridberg manufactured industrial heat-treating furnaces until 1985. The Lindberg facility was purchased by Byer's Choice Ltd. (Figure 1-2). This company manufactures dolls. The date Lindberg began operations is not presently known. The process involved a vapor degieaser which used TCA and other chlorinated solvents; detailed information on the composition of the other solvents has hot been reported, but it is known that PCE was also used. After the facility closed, the degreaser was drained and the resulting 55 gallons of spent TCA were disposed of offsite. There is no well at the facility.

AR300630

S i GrvO>

In 1980, three drums of waste TCA were observed inside the facility during an EPA inspection. One drum was reported to be in a crushed condition. 2.5 R&B/FMC Corporation FMC Corporation formerly owned and operated a manufacturing facility at the currently owned and operated R&B, Inc. facility. The facility was originally built in 1952 by Link-Belt : Company and was acquired by FMC in the mid-1970's. The main activity at the plant was the manufacture of material handling systems for the coal, iron ore, wood pulp, steel and other industries. Various industrial processes performed on-site included shot blasting, sand blasting, machining, welding, grinding and metal cleaning. . FMC utilized limited quantities of TCE in the metal cleaning process. These limited quantities of TCE were stored in 55 gallon drums inside the manufacturing facility. Wastes consisted of solvent rags that were stored in 55 gallon drums and disposed of offsite. A wastewater treatment plant was present on the property and was reportedly only used for sanitary wastewater treatment. The treatment plant effluent was discharged to Neshaminy Creek. The treatment plant was removed in the early 1970's when the sanitary sewer lines were connected to the municipal sewer. In 1980, EPA conducted a site inspection and indicated that no TCE or PCE was observed being used at the FMC facility. There are three production wells present on the former FMC property usedlto supply potable i . water to the site. R&B now occupies the facility formerly occupied by FMC Corporation. In 1987, R&B purchased the facility from FMC Corporation. R&B designs and packages automobile products. There is no documented use of chlorinated solvents at the R&B facility. Figure 2- 5 presents a site plan of the former FMC facility and current R&B facility. 2.6 New Yorker Steel Boiler Company. Inc. New Yorker Steel Boiler Company, Inc. is located at the southern boundary of North Penn Area 5. This facility manufactures heating equipment, fabricated plate work, and household .appliances. There is documented use of TCA at this facility and review of historical aerial photographs suggest landfill may have been present on adjacent properties. During an EPA site inspection a leaking drum of TCA was observed inside the facility. The facility has an onsite well. Groundwater analytical results from this wellhave revealed concentrations of I.I- DCA, TCA and TCE. Figure 2-6 presents a site plan of the New Yorker Steel Boiler facility.

N 14

AR30063U in i?

e a Wv' 3D J • «. 3 ••> Z> « E^ ** SO oGO o o^ Cc3n t

SR300636 2.7 Neotech The Neotech facility is located southeast of the Byers Choice facility on the adjacent property. Neotech manufacturer electro-mechanical .components. No additional information is available concerning this facility. " 2.8 Lumber Yard The Mayse Lumber Yard is located immediately north of the AEL facility. The lumber yard conducts typical lumber yard activities. No additional information is available concerning past activities at this facility.

AR300637 SECTION 3 ENVIRONMENTAL .SETTING The environmental setting of North Penn 5 is discussed in this section. The data provided in this section illustrates potential migration pathways and receptors of contaminants. 3.1 Regional Site Setting The following subsections describe the regional site setting in terms of topography, soils and geology. 3,1.1 Regional Topography . The work area is situated in the Triassic Lowlands portion of the Piedmont Physiographic Province. The Triassic Lowlands are a downfaulted portion of the Piedmont composed of sedimentary rocks and diabase intrusions. The resulting topography is flat to gently rolling, with ridges underlain by igneous intrusive rocks. Hills are typically the surface expression of either metamorphism or more resistant sedimentary rocks. Sorter, less resistant sedimentary rocks underlie the long, relatively flat valleys. . The region is part of what is known as the Delaware River basin. The area is drained by the Neshaminy Creek and its tributaries. Surface runoff generally flows northwest towards tributaries of the Neshaminy Creek. The Neshaminy Creek flows easterly, then southerly towards the Delaware River. The Neshaminy Creek enters the Delaware River near Bristol, Pennsylvania. The region gently slopes to the southeast, with surface elevations ranging from 250 to 670 feet above mean sea level (msl). Figure 3-1 presents a topographic map of North. Perm Area 5. . 3.1.2 Regional Soils The regional soils are primarily deep in depth with poor to moderately good internal drainage. Regional soils are typically derived from the underlying bedrock, chiefly shale and siltstone, or from alluvial deposits. 3.1.3 Regional Geology The rocks underlying the region are primarily composed of Triassic deposits that comprise the Newark Group. Newark Group rocks form a series of discontinuous basins from Nova Scotia to North Carolina along the Atlantic coast of the United States and Canada. All of the basins share similar lithology, commonly interbedded sandstone and arkosic sandstone near the base and red shales and sandstones near the top. Diabase intrusions are common throughout Newark Basin rocks. •/

AS 3-00.6 38 •v-/ The Triassic rocks of Montgomery and Bucks counties form part of the Newark Basin. The sedimentary formations, from oldest to youngest, are the Stockton, the Lockatong and the Brunswick Formations. A generalized geologic section is presented in Table 3-1. Figure 3- 2 illustrates the regional geology in the area of North Penn Area 5. The Brunswick Formation is present beneath most of the region. This formation consists of thin beds of reddish-brown shale, mudstone and siltstone. Joints are not uncommon. The joints are typically filled with calcite or quartz. The base of the Brunswick is composed of red argillite which may be interbedded with dark gray argillite of the Lockatong Formation. The maximum thickness of the Brunswick Formation in Montgomery County is 16,000 feet near Pottstown. However, the Brunswick thins to zero thickness where the Lockatong and Brunswick interfinger. The top of the Lockatong Formation often interfingers with the overlying Brunswick Formation. The Lockatong is composed of massive beds Of medium to dark gray argillite interbedded with thin beds of gray to black shale and siltstone. The maximum thickness of the Lockatong Formation is 4,000 feet near the Montgomery/Bucks County line. The Lockatong Formation conformably overlies the Stockton Formation. The Stockton is comprised of three members. The upper member is composed of red and gray shale and siltstone. The middle member consists primarily of arkosic sandstone. The lower member consists of conglomerate and arkosic sandstone. The maximum thickness of the Stockton in the region is 5,000 to 6,000 feet Diabase sills and dikes occur in the subsurface and are exposed at the surface in portions of Montgomery and Bucks counties. These intrusions are composed of dense diabase rich in the minerals labradorite and augite. The dikes range in thickness from 5 to 100 feet. The sills are greater than 1,000 feet thick in some areas. The diabase exposure Closest to the study area is approximately 2.5 miles to the northeast. Diabase intrusives altered the surrounding country rock in areas where the two rock types came into contact. Typically, Brunswick shales are metamorphosed into dark hornfels that can visually resemble Lockatong argillites. The edge of the metamorphic zone is gradational. Near dikes this zone may be 40 to 100 feet wide. Near sills this zone may be as much as 1 mile wide. The average dip of the Brunswick and Lockatong beds is towards the northwest at approximately 20 degrees and strikes N42E. Several broad synclines and anticlines are superimposed on this homocline. Well-developed vertical joint systems are common in Brunswick beds. The strike of the joints is apparently independent of the strike of the beds. Triassic rocks unconfqrmably overlie lower Paleozoic, limestones and/or Precambrian basement rock. ~ 3.2 Site Setting The following subsections describe the site setting in terms of topography, soils, and geology, using site-specific information when available.' ,

AR3006l*0 TABLE 3-1 GEOLOGIC SECTION FOR MONTGOMERY COUNTY, PENNSYLVANIA

Era System and Epoch Formation Thickness Character - (feet) Cenozoic • ' • " t •' ' V r Quaternary ——— ————— Soil, sand, and clay. Holocene Alluvium 0 to 10 Deposits in stream valleys. Pleistocene Pennsauken 0 to 10 Sand, gravel, clay, yellowish- brown; small area! extent. Tertiary Pliocene Bryn Mawr 0 to 10 Sand and gravel; small area! Gravel . extent. Mesbzoic . '• . Cretaceous Patapsco 0 to 10 Clay and sand, highly colored; Formation small area! extent. . •' '••' . •' •'- •'• , : ••'•- . • " •• .; . ' ••' - •'• ' Triassic Diabase 1 to 5,800 Medium to coarse grained , igneous rock, dark gray, occurs as dikes and sills. Brunswick 0 to 16,000 . Shale, mudstone, sandstone, Formation and conglomerate beds; reddish-brown. - - • •' •• '.'"•-. ^ Lockatong 0 to 2,000 ; Argillite, mudstone, and shale; . Formation dark gray to black; thick . - bedded, Stockton 1,000 to 6,000 Shale and siltstone in upper Formation . , member, sandstone, fine-to 7 : coarse-grained, arkosic, middle member, conglomerate lower '.-'-. - member.

21 TABLE 3-1 (Continued) GEOLOGIC SECTION FOR MONTGOMERY COUNTY, PENNSYLVANIA

Era System and Epoch Formation Thickness Character (feet) Paleozic Ordovician . Conestoga 500 to 800 Limestone, impure, .thin- bedded ...'•.- Limestone . upper part; middle dark graphitic phyllite, lower . limestone, granular thick- bedded, dark gray. Cambrian Elbrook 800 Limestone, fine-grained, light Formation , gray to cream-colored, thin . - . . ' ' ••••. . .-. - . . . •; . bedded. . .: Ledger 1,000 Dolomite, granular, gray to Dolomite bluish gray. Harpers 500 to 800 Phyllite, fine-grained, greenish Formation gray, some beds of quartzite and schist. Chickies 500 to 1,000 Quartzite, vitreous, light Quartzite colored, thick-bedded, conglomerate at base. Precambrian Wissahickon —— — - —— Schist (albite-chlorite and Formation / oligoclase-mica); includes hornblende gneiss and phyllite. ••••.''. , -. • . : - . ' Granite — •——— — Composed chiefly of quartz, Gneiss feldspar, biotite, and hornblende. j • • ^ . . • • Hornblende -——— — -— - Composed of quartz, feldspar Gneiss and hornblende. Serpentine -—— — — - Soft, fine-grained, green.

Derived from Newport, 1971.

^ •-.••'•. '-•-' 22 ' . . ' ''-• ..' • -

AR3006l*2

3.2.1 Site Topography V> North Penn Area 5 is situated on flat to gently sloping land. .Local groundwater elevations range from 260 to 325 feet above sea level. The area slopes west towards the West Branch of Neshaminy Creek. Tributaries of the West Branch of Neshaminy Creek run through the • • • ' •-• site. '"•'.'',-•• . - . * '.'. • •-' ' ' - • \ 3.2.2 Site Soils . : . ' • ' . . > . ' • ' • The predominant North Penn Area 5 soil type is the Abbotstown silt loam. This soil type is deep, poorly drained, and located on uplands with gentle slopes. Less extensive soil types found on or near the site include Readington and Reaville silt loams located on uplands and the Bowmahsville and Rowland silt loams found in flood plains. The Readington and Reaville silt loams are moderately well drained. The Bowmansville and the Rowland are both poorly drained. At depth, all of these soil types become shaly. A description of the soil series found in the region of the North Penn site is presented in Table 3-2. ' 3.23 Site Geology ;••• Regional geologic maps indicate that Area 5 is underlain by the Brunswick Formation and the Lockatong Formation, with a northeast-southwest trending contact located west of the AEL facility. The Brunswick Formation interfingers with the Lockatong Formation. The Brunswick and Lockatong formations dip to the northwest at an angle of approximately 20°. BCM identified the contact \^_ J between the Brunswick and Lockatong Formations in the vicinity of Well NP-21. . According to the NP-21 well log, bedrock, specifically red, brown and gray shales, was encountered 4 feet below the ground surface. Brown and gray "rock" was encountered from 30 to 131 feet below ground surface. This was underlain by Brunswick shale from 131 to 237 feet below ground surface. The Brunswick was identified again at the 284 to 293 foot interval. The rest of the well cuttings , . from 237 to 284 feet and from 293 feet to the bottom of the boring at 500 feet, consisted of a mixture of brown and gray "rock". No information concerning fractures was provided on the borelog. However, depth and yield information indicate significant jumps in yield from depths of 75 to 130 feet and from 324 to 338 feet. These zones are presumably heavily fractured. BCM installed a series of monitor wells on the AEL facility, which provided information concerning the depth to bedrock. The depth to bedrock ranges from 4 to 24 feet on and near the AEL property. 3.3 Regional Climate The regional climate is described as moderate and moist. Weather systems generally are derived from the continental interior, with the Atlantic Ocean providing both moisture and a moderating effect to the temperature. 24

.AR30.0.6M* TABLE 3-2 SOIL SERIES FOUND IN REGIONAL AREA

Series Description , . Abbbttstowh Deep and moderately deep. Somewhat poorly drained. Formed in material weathered from red and brown shale and sandstone. Have a low permeability subsoil that impedes the downward movement of water. . Bowmansville Deep, poorly drained, gray or grayish-brown silt loams or silty clay loams. Formed, in material washed from uplands underlain by shale, sandstone, and diabase. Nearly level or gently sloping. Occur along streams and waterways. Croton Deep, poorly drained, nearly level or gently sloping. Formed on shale and sandstone. Thick and low permeability subsoil impedes the downward movement of water. • Doylestown Deep, poorly drained, gray soils. Nearly level or gently sloping and silty. Formed in .windblown silt on low-lying flats. • in depressions, and. on smooth, broad uplands. Have a thick layer of low permeability subsoil that impedes the downward -. ' • • movement of water. • • , Made Land Results from the altering or mixing, by construction activity, of soils formed in material weathered from shale and sandstone. Consists of study silt loam, and many areas consist entirely of pieces of shale. Readington Deep, moderately well-drained silt loams. Nearly level to moderately sloping. Formed in materials weathered from shale. siltstone, and sandstone; Located on smooth to rolling uplands. Contain a firm subsoil that has grayish mottles in the lower part. • . • • Reaville Deep, moderately well-drained to somewhat poorly drained, reddish shaly silt loam. Have a thin subsoil of low permeability that restricts the downward movement of water. Formed in materials .weathered from shale and siltstone on level to rolling uplands. ' Rowland ' Deep, moderately well-drained or somewhat poorly drained, nearly level -silt loams on. flood plains. Formed in material washed from uplands underlain by. red shale and sandstone. - ,

Derived from Soil Conservation Service. 1986.

'25

AR3006'I»5 The annual average temperature is approximately 54*F. July is typically the hottest month, with an average temperature of 77"F. January is typically the coldest month, with an average temperature of \s_ J- 31"F. Usually, less than 100 days per year have minimum temperatures below freezing. Summers are hot and humid, with an average of 21 days per year with maximum temperatures above 90°F. The annual precipitation is approximately 40-45 inches. Precipitation is fairly evenly distributed throughout the year, with no clearly defined "dry" season. August is often the wettest month due to common thunderstorms while February is typically the driest month. Yearly annual snowfall is approximately 20 to 30 inches. 3.4 Hydrology The following subsections discuss the surface water and the groundwater found in the vicinity of the study area. ' 3.4.1 Surface Water A detailed description of the local surface water hydrology is not available. Approximately 15 to 21 inches of precipitation enters the surface-water drainage system as surface runoff. In the vicinity of the study area, the eastern and western tributaries of the West Branch of Neshaminy Creek drain the area around the facilities, and each flows north for less then one-half mile before joining the Creek. 3.4.2 Groundwater BCM identified two (2) separate aquifers beneath the AEL facility. One is a shallow aquifer perched \^_J' above the bedrock surface. The other is a bedrock aquifer under water table conditions. 3.4.2.1 Shallow (Perched) Aquifer A shallow water-bearing unit periodically occurs in the soil overburden. Groundwater in this shallow unit may perch upon the bedrock surface, or on top of a lower-permeability horizon in the soils. Some of the shallow wells are seasonally dry. The configuration of the wells makes the construction of meaningful contour maps difficult. BCM concluded that the groundwater flow is towards the northwest. 3.4.2.2 Bedrock Aquifer Available information indicates that the Brunswick Formation is a reliable source of small to moderate supplies of groundwater. An analysis of almost 200 wells in Montgomery and Berks counties . indicated that wells should be installed to a depth -of at least 200 feet if yields in excess of 100 gallons per minute (gpm) are desired. Typically, wells drilled to between 200 feet and 550 feet in this formation provided maximum yields. Below that, the fractures tend to be closed; above that, they are commonly made less permeable by the presence of highly weathered rocks near the surface. A 104-foot-deep recovery well installed at AEL in the Brunswick was estimated by the driller to yield 30 gpm.

AR3006U6 , . '. ' : :- • ' • '.''', • f The underlying Lockatong Formation yields groundwater at an average rate of only about 7 gpm. In the areas where the Lockatong and Brunswick Interfinger and fractures are wider and more closely spaced, yields from the Lockatong are typically greater. . ' \^ J The Stockton Formation is the most productive of the three formations that may underlie the site. Although the Stockton does not form outcrops or subcrops in the study area, this formation may be 'encountered at depth. A previous study reported that the arkosic sandstone middle member and the conglomerate lower member are prolific, yielding an average of 131 and 106 gpm, respectively. The upper Stockton member, composed of shale and siltstone, yields only 19 gpm. Studies by BCM and TSD indicate ttiat groundwater flow is generally to the northwest. There are also vertical components to groundwater flow. Vertical flow components are controlled by infiltration rates, well pumping, and hydraulic connections caused by fractures. It has been reported that NP- 21 occasionally flows under natural conditions. A caliper log performed on NP-21 in 1983 indicates that there are numerous fractures in the upper part of the well between the depths of 60 and 124 feet. There are other indications of fracturing and enlargements in the borehole from 155 to 170 feet and from 214 to 224 feet. From the well log a significant water entry point appears to be present between 75 and 130 feet, with well yields increasing from 25 to 100 gallons per minute, respectively. This correlates rather well with the shallow fracture zone identified during caliper logging. An aquifer test was conducted in 1968 by F.L. Bollinger & Sons in NP-21. The test was conducted at a constant pumping rate of 602 gpm for 74 hours. During the test, drawdown was measured in NP-21 and'three (3) observation wells. One of these observation wells was North Wales supply wel1 No. 16 located northeast of AEL and 2,600 feet northeast of NP-21. The maximum drawdowi / observed in this well was 4.75 feet and indicates that NP-21 may exert an influence north of County""^^ Line Road. One explanation for the significant drawdown observed in NW-16, is that in the Brunswick and Lockatong formations it is not uncommon for wells located on a line parallel to strike to exhibit greater drawdowns man wells perpendicular to strike. The reason for this is that wells parallel to strike generally penetrate the same strata, while those perpendicular to strike only penetrate a portion. Hydrogeologic information for the interfingered zone of the Brunswick and Lockatong formations indicate transmissivity ranges from 7,000 to 14,000 gpd/ft with a storage coefficient of approximately 0.00095. The United States Geological Survey (USGS) collected continuous water-level data for approximately a six week period from NPWA well NP-75. During water level monitoring the stable water level with NP-75 pumping at a constant rate was approximately 15.5 feet Every 4 to 8 days however, the water level would rise 2 to 3 feet and then drop to approximately 15.5 feet, indicating that NP-75 is strongly influenced by a nearby pumping well. The direction of groundwater flow is quite variable as a result of the number of high volume pumping centers in the area.

A R3 0061*7 3.43 Monitor Wells ; AEL installed 34 monitor wells and 4 recovery wells on and adjacent to their property between 1980 and 1983. Of the monitor wells, 18 (the A-series) were constructed in the overburden and 16 (the W-series) were completed in bedrock. All of the recovery wells were installed in bedrock. Well locations are shown in Figure 3-3. Well construction and water level data from March 1988 are provided in Table 3-3. .''.', Four (4) monitor wells are currently located on the Powertest property. Based on water level readings obtained on 1 May 1990, it appears groundwater flow is in a north direction toward the West Branch Neshaminy Creek.

AR3Q06U8

'•-.,' '- '• ••-•,"• TA81E 3-3 -/' .^

• • AEL WELL CCKSTRUCUOK AND VATCR'lEVEl CATA : ' - . • . , /..' / . • '•;. . ••/• •••..'. .

WELL Touv Depth.to well screened er Reference Water level . Destn gedroc* Diameter Open Interval Elevation Keren 1988 (feet).- (fett) (inches) tft. below turfeee) (ft. ibove tal) (ft. above ssi)

OVERBURDEH . ' A-t 9.5 9.5 6 0-9.5 31T.I7 .' 308.54 A-2 9.5 9.5 6 0-9.5 3t7.7T 309.01 A-J 11 11 A 0-11 316.97- 310.26

A-« 10 * 10 6 0-10 * 317.U 308.14

A-5 12 12 6 0-12 316.47 305.56

A-* 12 12 6 0-12 316.23 305.13

A-7 12 >12 6 0-12 317.02 304.57 A-8 12 >« 6 0-12 317.76 305.96

A-9 IS >« 6 0-13 317.60 . DRY

A-W 11 >11 6 0-11 316.55 A-11 22 22 6 0-22 314;86 302.32

A«12 24 . 24 4 0-24 516.11' , 302.21

A-13 19 19 6 0-19 314.23 302.16 . • - / • . • A-H 19 19 6 0-19 315.77 302;56

A-15 11 11 6 0-11 — 0*T

A-16 9-5 9.5 6 0-9.5 311.56 ———

A-17 11.5 11.5 6 0-11.5 316.06 ORT A-18 12 >12 4 0-12 315.69 D«

«...» indicates data not available.

30 AR300650 •TABLE 3-3 - ' ..', . -

AEL VEIL OBSTRUCTION AMD VAIER-LEVEL DATA

WELL Totil Depth to veil Screened or leferenet ««er level oeotn • seorocK uianwcDieter v>^.Open. ,..,...Int.™— ..limit. * , •«« 19S8 '(feet) (feet) (inches) (ft. belo* surface) (ft. above ml) (ft. soove rat)

. BEDROCK' '- '....' •'.,-.'• ' . - ' •• W-1 S2 9 2 9-52 314.49 306.04

W-3 28 . 12 2 ,. 12-28 303.29 296.64

y-4 33 . 16 2 16-33 . i 293.13 256.31

V»-5 44 . 9 2' ' - ' ' 9-46 296.71 284.44

W-6 ^ 10 2 10"3* 300.65 29^.'* ', M-7 SJ 22 2 22-52 300.63 — W-8 33 13 2 15-33 301.42 ',''"' • W-9 52 13 2 13-52 290.13 '••• W10 34 12 2 12-34 290.45 289.33 W-12 47 7 2 7-47 299.41 292.08

U-1J . 16 10 2 10-46 - 268.80 2E3.96 W-14 47 6 2 6-47 303.29' 291.12

V-15 47 8 I 8-47 311.61 297.62 '-•-••• ' - - . > ' tf-16 52 9 2 9-52 319.80 *•• VM7 47 62 6-47 . 293.44 224.94 - . . , ' - , • ' • . "\ ' ' • • . W-18 47 6 2 6-47 313.54 . 300.19

»..-• Indicates

31 AR300651 TABLE 3-3

AEL hill CONSTRUCTION AMD WATER-LEVEL JATA

WELL Total Depth to ' well Screened or Reference Water level Depth .Bedrock Stameter Open Interval Elevation Harch 1988 (feet) (feet) (inches) {ft. below surface) (ft. above nsl) (ft. toove isi)

BEDROCK . : . ' .'."'.. ' RW-1 70 22 6 23-70 3W«M ,296.86

w.2 ISO 22 6 80-150 ' 315.20 299.97

RU.J 210 20 6 150-210 315.36 304.78

Recovery 104 — 6 • —• 316.55 Well _ ;'' '; • •• " . ' - ' ..'-•-" ' ' Main 300-350 ————— 6 ——— 313.50 Well ' " . ' ' ' . . ' • ' _ - • .

\. l~ . H...K (ndicates data not available.

AR300652 ... • • '. SECTION 4 . ( • • - SUMMARY 01* PAST ENVIRONMENTAL INVESTIGATIONS

There have been environmental investigations conducted at facilities within North Penn Area 5. This section discusses the past investigations conducted relative to soil, surface water, sediments and groundwater. These data provide the basis for the conceptual model of existing data and development of the Rl/FS data needs. The past environmental investigations conducted in North Perm Area 5 include environmental site assessments, remedial actions, and sampling and analysis of groundwater by NPWA and NWWA. Upon identification of the environmental investigations and discussion of the results, the laboratory analysis will be evaluated for acceptance as valid data for development of the conceptual model. 4.1 AEL ... - .-. ' • - •' ' ' ' • ''•"." • • .'. ' Several environmental investigations have been conducted at the AEL facility in response to areas of environmental concern at the facility. Soil, surface water and sediment investigations have been conducted at AEL. Figure 4-1 presents the areas of environmental investigations conducted on the AEL property. In 1979, BCM conducted investigations relative to the TCE content of the AEL industrial wastewater effluent. This investigation included collection of wastewater effluent and receiving surface water samples and subsequent laboratory analysis for TCE and PCE. In conjunction with this investigatio a pond located in the western portion of the property was sampled for surface water and sedim Also, the sanitary sewer that flows from the Stabiius facility through AEL's property was sampled during this investigation. During a one (1) week period wastewater effluent samples were collected on a daily basis and analysis revealed TCE and PCE concentrations were present. The effluent TCE concentrations ranged from non-detect (<0.1 ug/L) to 165.5 ug/L and PCE concentrations ranged from non-detect (<0.1 ug/L) to 38.4 ug/L. No concentrations of TCE or PCE were identified above the method detection limit (0.1 ug/L) in the stream samples collected. The pond samples revealed TCE concentrations ranging from 100 ug/L to 600 ug/L. the sanitary sewer line that flows from Stabiius through AEL's property has revealed concentrations of TCE ranging as high as 93.4 ug/L and concentrations of PCE as high as 9.0 ug/L. In response to the identified concentrations of TCE in the public drinking water supply wells in the area, AEL initiated investigations to attempt to identify potential sources on the AEL property. In June 1980, the TCE waste underground storage tank on the property was removed and disposed of properly. No leakage was confirmed during removal. A soil boring program was conducted from 1980 - 1982 prior to and following removal of the UST in an attempt to identify potential TCE contaminated soils. The soil boring program was also conducted in the area of/the chemical storage pad which was the area where raw and waste chemicals were managed.

AR300653

The results of the soil boring program indicated maximum concentrations of TCE contamination ranging to one part per million. Soil samples were collected from two (2) depth intervals (3 to 5 feet (1 and 10 to 14 feet below ground surface). The significant TCE contamination appeared to be limited to the shallow soil zone. The general pattern of contamination exhibited in the samples reflected a residual TCE concentration centered around the former location of the storage tank and the chemical storage pad area. . In 1980, BCM conducted a buried drum investigation to attempt to identify reported buried drums on the AEL property. The results of the geophysical investigation revealed six (6) 55 gallon drums and two (2) one (1) gallon containers buried on the property. The drums were found at depths of two to five feet below ground surface. Most of the drums were still competent and withstood lifting out of the ground. One drum was partially crushed and several were rusted in a few spots. All of the drums identified were removed from me ground, recontainerized when necessary, and shipped to an appropriate disposal facility. Soil samples in the immediate area of the drums were collected and analyzed for metals, volatile organics and PCB's. The contents of several of the drums resembled paint residues. The results of the soil sample analysis indicated that minimal contamination associated with the drum contents was realized. Based upon discussions with PADER, no further remedial action was deemed necessary. In 1980, BCM also initiated a groundwater investigation of the AEL facility. Thirty-eight (38) wells were installed on and adjacent to AEL's property. The wells were drilled in three sets and labeled A-series (18 wells), W-series (16 wells) and RW-series (4 wells). The locations of the well were illustrated in Figure 3-3. V > The A-series .wells are shallow monitor wells ranging in depth from 9 to 24 feet. These wells are grouped together in an area surrounding the chemical storage pad. Installed in April and May of 1980, these wells were drilled to the top of solid bedrock and were designed to be used to sample groundwater and determine water levels in the shallow soil zone. The A-series wells are cased with 6-inch PVC casing. The W-series wells (installed in January 1980) are deeper than the A-series, extending down into bedrock to depths ranging from 28 to 52 feet. These wells arc widely dispersed over the AEL property and the area between AEL and Well NP-21. These wells, cased with 2-inch PVC casing, were designed for sampling water and determining water levels in the bedrock aquifers. '''{'•.. ' . -• ' - • : .. •'-..•; . '.-.'.'- • '•. - • The RW-Series wells (installed in May 1980) were designed to. be used as recovery wells, from which TCE-laden water could be removed and treated. They are cased with 6-inch steel casing and are located within 200 feet of the chemical storage pad. The depths of RW-1, RW-2, and RW-3 are 70, 150. and 210 feet, respectively, . Groundwater samples were collected from the wells at various times during the past ten years. Over 125 groundwater samples were collected from the monitor wells over a 16-month period and analyzed by BCM's laboratory using gas chromatography for TCE. In addition, water samples from AEL's main production well are collected and analyzed monthly for TCE and PCE. .

AR300655 Groundwater monitoring of selected monitor wells has continued over the past decade. In 1987. TSD Environmental Service, Inc. was retained to conduct the groundwater monitoring at the AEL facility Table 4-1 presents a summary of the ranges of TCE detected in each of the AEL wells over monitoring periods. Based on these data, TSD made the following conclusions: o Consistent seasonal TCE concentration fluctuations in A-3, A-ll, A-14, and W-l, with levels in A-3 and W-l peaking in March and A-ll and A-14 peaking in September were identified. o There was a general decline in TCE concentrations in all A-series wells sampled. o There was a general increase in TCE concentration in W-4. o Generally steady TCE levels were reported for W-5, W-6, and RW-1 above the EPA Maximum Contaminant Level (MCL) of 5 ug/L

\ . . .'''"'' ; . . . •" ' ' - o Levels consistently below the MCL were found in W-10, W-12, RW-2, and RW-3. o Two distinct plumes of TCE contamination in the bedrock- aquifer occur on the AEL property. . o The TCE plume located west of Building 5 appears to be of limited area! extent. o The plume of contamination located near the north corner of the property does hot appear to be related to TCE contamination near Building 5 and may be due to offsit sources. Based upon the findings of these groundwater investigations a groundwater remediation program for the shallow aquifer is being implemented at by AEL. The overall decrease in TCE levels through time is most likely due to the removal of the source of TCE and the implementation of a pump and treat groundwater remediation system. , '• . -: 4^2 R&B/FMG - In 1987 R&B retained American Resource Consultants to conduct an environmental assessment of the FMC Corporation facility. A soil sampling program was conducted at three (3) areas of environmental concern identified on the property. Test pits were excavated and soil samples collected and analyzed at a former petroleum underground storage tank area, a trench drain area located in an open field behind the warehouse (Building #2) and an inactive paint storage building formerly used for oil drum storage. Figure 4-2 presents the locations of the investigated areas and test pits. Soil samples were collected from the test pits and analyzed for VOCs, naphtha, total chromium, total lead, EP Toxicity metals and oil and grease. The soil samples collected from the test pits revealed non-detectable concentrations of all VOCs.

AR30065& TABLE 4-1 •

GROUNDWATER MONITOR HELL SAMPLING - ANALYTICAL RESULTS AEL, INCi TCE CONCENTRATIONS ug/1 .

May/July March September March September March Well 1986 1987 1987 1988 1988 1989

A-3 19?5 .26.5 0.8 12 ND 12 A-9 433.5 DRY DRY DRY DRY DRY

A-ll 288 95.7 218.5 75.9 190 4.1 A-14 267 55.3 246 117 190 40"'

A-18 NO DRY DRY DRY DRY DRY W-l 180 168 0.3 112 84 120 ; W-3 2.2 ND 9.6' 1.05 2 NO W-4 235 596 240 1545 1500 1600 W-5 93.4 57.3 * 107.5 120 45

W-6 1.5 2.3 V 6 4 6 ND

W-10 v 1 ND 0.6 • ND ND , ND

W-12 ND . ND 0.6 ND ND ND

W-13 * • i 5.3 5 5.4 RW-1 292 265 240 292 260 220

RW-2 4.9 ND 0.2 0.9 2 ND ,.."•• i ! - ' - - • RW-3 ND ND ND ND . ND ND

'Notes: "*" denotes no sample collected. "ND" denotes not detected at Laboratory Minimum Detection Limit.

37 AR300657

In addition to the soil sampling program, groundwater samples were collected from the three (3) onsite wells and analyzed for total lead, total chromium and VOCs. Figure 4-2 also includes the locations of these wells (pump house no. 1, pump house no. 2 and pump house no. 3). The results of the groundwater analysis are presented in Table 4-2. The groundwater analytical results revealed detectable concentrations of aromatic compounds, dichlorobromethane, TCA and DCA. Also, lead and chromium concentrations were detected in the groundwater samples. The TCA concentrations detected were well below the EPA Drinking Water MCL. It should be noted that these metals' samples were not filtered as required for groundwater analysis and do not represent soluble metals' concentrations. No TCE was detected in any soil or groundwater samples collected and analyzed during this investigation. 4.3 Stabiius The Stabiius facility has limited information relative to environmental investigations. In 1980, a reported spill of TCE was identified during transfer operations by Baron-Blakeslee, Inc. to the TCE storage tanks present on the Stabiius property. Figure 2-2 presented a site plan of Stabiius and the location of the former storage tank. No sampling and analysis activities were known to have been conducted to investigate the potential impact of this spill. In 1979, the sanitary sewer that flows from the Stabiius facility through AEL's property was sampled on AEL's property. The concentrations of TCE ranged as high as 93.4 ug/L, while concentrations of PCE ranged as high as 9.0 ug/L. In June 1980, Stabiius retained Weldon C. Harris & Associates to conduct television and pressure testing of the sanitary sewer line on the Stabiius property to determine its integrity. The results of the survey determined that no infiltration or exiiltration of the tested portion of the line was observed. Stabiius terminated use of TCE at the facility in 1986. In June 1990, AEL contracted Pipe Maintenance Services, Inc. (PMS) to conduct a video survey of the sewer line from Stabiius that passes through the AEL property. The results of the investigation identified several areas of the pipe that had observed root infiltration and an area in which the pipe was observed to be sagging. 4.4 KEMA-Powertest/Webcraft/ABB In April 1990, an environmental site assessment was conducted at the Powertest facility formerly owned by BBC Brown Boveri, Inc. Four monitor wells were installed .and groundwater samples analyzed. The monitor wells were installed to depths ranging from 19-25 feet below ground surface (bgs). The wells were constructed in the shallow groundwater zone encountered at depths to groundwater of less than 12 feet bgs. Groundwater elevations recorded from the monitor wells indicate that shallow groundwater flow direction on the property is to the north. Figure 4-3 presents the locations of the monitor wells on the Powertest facility.

AR300659 • , TABLE 4-2 . R&B/FMC FACILITY GROUNDWATER ANALYTICAL RESULTS (16 September 1987)

Parameter (units) Well #1 Well #2 Well #3 Lead (mg/1) 0.30 0.29 0.32 Chromium (mg/1) . 0.02 0.03 0.06 Benzene (ppb) 0.01 0.01 0.01 Chlorobenzene (ppb)' 0.02 0.02 0.02 Toluene (ppb) . 0.07 0.07 0.06 Methylene Chloride (ppb) 7.8 83.5 V. . 19.1 Dichlorobromomethane ND 0.6 0.1 (ppb1,1,1) Trichloroethane ND 18.,4 1.9 1,1 Dichloroethane (ppb) ND 2.0 0.4

ND - Not detected at EPA detection limit method 625 Only compounds detected above the method detection limit are presented.

AR300660 Kl 1 I? I !i Groundwater samples were analyzed using EPA Method 601/602. The analytical results revealed concentrations of TCA (11,149 ug/L), DCA (187 ug/L) and DCE (6,763 ug/L) in monitor well MW- 2 and a TCA concentration in MW-3 of 25.9 ug/L. The elevated concentrations of TCA and DCE in MW-2 indicate groundwater contamination in the area of MW-2. MW-2 is located in the immediate area of the railroad line that crosses County Line Road. These results indicate the potential for a source of TCA in this area. Limited information is available concerning potential past solvent usage at this facility. , - ' r • i An environmental survey was conducted at the current Webcraft facility in 1985 as a requirement for the agreement of sale between BBC Brown Boveri and Chalfont Direct Response Corp. The environmental survey was conducted by Merritt/Osbom, Inc. of Newtown, Pennsylvania. The survey consisted of a review of available records relative to the environmental condition of the property; interviews with representatives and employees on the premises; a visual inspection of the premises; and collection of environmental samples from areas identified as possible sources of contamination. Several areas of potential environmental contamination were identified including an electroplating line, epoxy resin coating line, electrostatic paint line, transformers, wastewater treatment system, materials storage pad, waste chemicals located in tanks and drums, a drainage field and paint storage area. . '. . ; •' . :'' t '•''•'•••'. . '•'.-••• Soil samples were collected from the identified drainage field and the wastewater treatment area. The soil samples were analyzed for heavy metals and total and amenable cyanides and selected samples were analyzed for EP Toxicity metals. The results of the analysis revealed "elevated levels of zinc, copper and silver". The elevated metals' concentrations ranged from 127 mg/Kg to 476 mg/Kg. In addition, sediment samples were collected and analyzed for EP Toxicity metals and pesticides/PCBs. The results of the EP Toxicity analysis revealed leachate concentrations below the allowable toxicity levels. Soil samples were also collected from the identified runoff area adjacent to the materials storage pad and analyzed for total metals and cyanides and EP Toxicity. Elevated levels of zinc, copper and lead were identified in these areas. Based upon the results of the samples collected and a meeting with the Pennsylvania Department of Environmental Resources (PADER), a limited volume of soil was excavated from the drainage ditch located in the area of the wastewater drainage field and disposed of offsite due to metal's concentrations. Also, 39'drums of packaged waste materials were identified as being present on 'a materials storage pad requiring removal and disposal. The contents of these waste materials were not identified in the survey report. In addition, the report referred to a site evaluation and closure plan for sludge settling and dewatering sumps located on the property. This closure plan was implemented in 1985 under the jurisdiction of PADER. On 3 May 1985, PADER provided conditional approval for the closure plan; however, no certification of completion was provided. The available information provided concerning the Webcraft facility did not indicate the use of chlorinated solvents nor were samples analyzed for volatile organics.

AR300662 4.5 Existing Analytical Data QA/QC "••...... :.,-. Environmental investigations and remedial actions conducted in North Perm Area 5 have resulted collection of sampling data. This data was utilized to develop the conceptual site model and to determine existing environmental conditions. The accuracy of the site model is limited by the accuracy and precision of the data collected and evaluated. Various consultants and commercial analytical laboratories nave conducted sampling and analysis of samples from North Perm Area 5. The majority of sampling activities conducted used standard field sampling QA/QC procedures; however, these methods were not documented in a QAPP. The majority of the laboratory analysis did not included documented QA/QC procedures. Several EPA contractors have collected and analyzed samples from the area which were subjected to a QA/QC review. Data validation procedures and reports were developed for these data. For the purpose of developing the conceptual site model and RI/FS planning activities,, all data reported by the laboratories was utilized with the known limitations associated with the generated data. This conclusion was based on the standard operating procedures and test methods referenced by the laboratories and the consistency and reproducibility of the data. , Data obtained from the EPA contractors, sampling and analysis programs were successfully validated and can be used for both RI/FS task planning, preliminary risk assessment and the formal risk assessment that will be conducted based on validated RI data. •••-•' '• ' ' . :..•'- . •• •- . • • ; '• '.'•--•.-•• 4.6 Aerial Photograph Interpretation An aerial photograph interpretation was conducted of available stereoscopic pairs for the North Area 5 site. Mr. Dave Nale of Aerial Data Reduction reviewed the stereoscopic photographs for several of the North Perm Area 5 facilities. The aerial photographs were dated from 1958-1985. Review of the AEL facility was conducted in an attempt to confirm former locations of remediated areas. Review of the photographs was inconclusive relative to the former pond with documented sampling and analysis. No visible pond was identified from review of the available photographs. The R&B/FMC facility was reviewed to identify any waste storage areas that may have been present on the property. The aerial review identified exclusively raw material storage in the rear of the facility. This storage was identified as being organized and well kept. No significant waste storage areas were identified at the R&B/FMC facility in .the aerials reviewed. Review of the New Yorker Steel Boiler facility identified two areas that were used as fill areas. Excavation and filling operations were identified in two areas adjacent to the property between 1975 and 1985. A large area was identified south of the facility in 1975 through 1979 while a smaller area was identified north of the facility in 1985. A dirt road was observed leading to this fill area in 1985.

A R 3.00.66.3 The Powertest facility was reviewed to attempt to identify potential source areas for the documented TCA concentrations found in onsite monitor wells. The aerial photograph review identified waste materials and debris in the area of currently existing monitor well MW-2 in 1979 and 1985. In the 1979 photograph there appeared to be drainage ditches excavated in this area toward the railroad tracks north of the facility. The aerial photograph review was used to assist in identifying source investigation areas for the RI field investigations. The results of the aerial photograph review will be used in developing the overall RI field activities.

AR30066l» SECTION 5 SUMMARY OF PAST REMEDIAL ACTIONS

, • • ' • . Remedial actions have been documented at the AEL facility. AEL has implemented remedial actions to address a process discharge to surface water, sanitary sewer that passes through the property, buried drums, solvent storage tank, chemical storage pad and associated contaminated soil and groundwater. In 1979, an internal source of TCE was discovered and eliminated from a surface water discharge from AEL's plating operation. '

1 - 1 "..''.; ' " '• In September 1979, BCM conducted a lithium chloride tracer study in a sanitary sewer located northwest of the AEL facility. The sewer carried effluent from the Stabiius facility to a junction with AEL's sewer west of the AEL facility, passing underneath AEL's property along its northwest boundary. TCE had been identified in the Stabiius sewer from an earlier investigation, and the purpose of this tracer test was to determine if the sewer could be the source of the TCE contamination in the AEL pond. Lithium chloride was injected into the sewer on AEL's property and then water and sediment samples collected from the pond and analyzed for lithium. No lithium was detected in either the pond water or sediment. / In December 1980, BCM excavated buried drums discovered during a magnetometer survey. Six 55- gallon drums and two 1-gallon containers were recovered from 2 to 5 feet below the surface. BCM reported that most Of the drums were intact, although at least one was partially crushed and several had rusted through in a few spots. Soil samples were collected from the area surrounding th excavations and were analyzed for cadmium, chromium, lead, and PCBs, as well as 29 halocarbons. The only heavy metal that was detected was chromium. Only four of the halocarbons were detected, and the maximum concentration was 28.8 ug/Kg of TCA. BCM concluded that very little contamination was attributed to the buried drums and, based upon conversation with PADER no additional actions were taken in this area. > The solvent underground storage tank was excavated and disposed of in June 1980. After the tank 'was excavated, the surrounding soils were tested for contamination. Only those samples collected in the immediate vicinity of the excavated tank revealed significant concentrations of. TCE (150 to 4950 ug/Kg). In addition, the contamination appears to have been limited to just below the soil surface, with the samples taken at greater than 9 feet having less than 100 ug/Kg TCE. PADER and AEL then agreed that AEL should excavate the soils with greater than 100 ug/Kg TCE. The soil was excavated by backhoe in November 1981. Following excavation, additional samples were collected from the walls and floor of the excavation. Since these samples were found to contain TCE in concentrations greater than 100 ug/Kg, the area of excavation was expanded. This procedure of excavation and sample collection/analysis continued until 110 to 120 cubic yards of soil were removed.

AR300665 Soil shredding and aeration proceeded concurrently with the excavation and laboratory analyses. Weather conditions, however, were less than ideal for proper aeration (i.e., low temperatures). Therefore, after the excavated soil had been shredded and aerated three times, the soil was placed back into the excavated area and further action was delayed Until the following year, when the temperatures and humidity were more favorable. It was believed by BCM that because the treatment program had removed the majority of the contamination (final average concentration was approximately 400 ug/Kg, with concentrations from five samples ranging from 241 to 734 ug/Kg), groundwater quality would not be adversely affected by placing the partially treated soil back in the excavation until treatment could be resumed. The treatment process was resumed in early August 1982. The soil originally excavated was re- excavated, along with an additional 85 cubic yards of soil in the directions of the paved parking lot, Building No. 5, and the chemical storage pad. After this excavation soil samples, from the base and side-walls .of the excavation revealed concentrations near or below the 100 ug/Kg action level. Almost all of the excavated soil was then shredded three times. This reduced the mean concentration of TCE in the soil to approximately 100 ug/Kg, with concentrations from 10 samples ranging from 30 to 200 ug/Kg. v In April 1981, AEL and PADER signed a consent agreement requiring AEL to perform several tasks directed at remediating and preventing contamination at the facility. With respect to remediation, AEL was to immediately initiate a DER approved groundwater recovery operation to remove TCE contamination. AEL was also to submit monthly progress reports on the recovery program to PADER. In addition, AEL was required to implement a Pollution Incident Prevention Plan, continue to monitor TCE levels in its process wastewater discharge into an unnamed tributary of Neshaminy Creek's West Branch, and submit an application and construction schedule for industrial waste treatment facilities. In compliance with this consent order and agreement, AEL has been conducting a groundwater remediation program at their facility. Based on the initial groundwater sampling data, BCM first proposed a groundwater retrieval program for the AEL facility in 1980. The plan consisted of pumping the contaminated groundwater from the A- and RW-series wells to a batch aeration/carbon adsorption unit. A feasibility study was completed on the aeration unit and was found to be applicable to the TCE-contaminated water. When the program was implemented early in 1981, however, it was found that the shallow A-series wells did not have enough groundwater yield to support the process and the deeper RW-series wells were not contaminated enough to justify treatment. PADER then suggested that BCM modify their plan to include artificial recharge. This was also found to be infeasible when an injection test of Wells A-12 and A-13 revealed that the wells were not adequately sealed to withstand even low pressure injection. A subsequent slug test analysis on Well A-12 yielded a hydraulic conductivity of 0.1 feet per day in the overburden zone. From this parameter it was estimated that it would require more than 3 weeks for water injected in Well A-12 to reach A-13. In June 1983, another groundwater recovery well was installed, to a depth of 104 feet, in the Brunswick Formation. The well was drilled in the vicinity of Wells W-l and A-10 to provide an onsite source of TCE-contaminated water for the aeration tower.

AR300666 Data from a pumping test of the recovery well indicated that the well could sustain a pumping rate of 15 gpm and would deliver approximately 750 ug/l TCE. Based on the design calculations of thr air stripper, the effluent stream would then contain less than 4.5 ug/l TCE. AEL also developed a "Preparedness, Prevention and Contingency Plan" for the facility. This plan outlines the steps taken to prevent and control the accidental discharge of polluting material to surface water and groundwater and to minimize and abate hazard to human health and the environment from fires, explosions, or release of hazardous materials and waste to air, soil or surface water. This plan was finalized in 1982 arid updated in 1985, 1986, 1987, 1989 and 1991 and is currently followed as part of the AEL operations. The recovery well/aeration, tower system was brought online in April 1986. .Although there appears to be a seasonal fluctuation in the TCE concentration of the air stripper influent water, there has been a general decline in the concentration during the 6 years of operation. This indicates an overall improvement in groundwater quality in the vicinity of the recovery well. Although there is no clearly defined cone of depression in either the shallow or deep aquifers around the recovery well, the TCE • concentrations in the vicinity of the recovery well appear to be influenced by the daily groundwater withdrawals. It was also concluded that vertical migration downward is not occurring based on the TCE levels in RW-2 and RW-3. : Li 1992 AEL expanded their facilities into the area identified as the former buried drum area. Prior to construction, three (3) soil samples were, collected and laboratory analyzed for Volatile Organic Compounds plus fifteen peaks (VO-f 15). The results of the analyses indicated that the targeted VOC concentrations were near or below the method detection limit. Remedial actions have been conducted at the R&B/FMC facility with respect to removal underground storage tanks. No remedial actions are known to have occurred at any facilities besides AEL within North Perm Area 5 with respect to potential hazardous wastes or substances.

AR300667 SECTION 6 CONCEPTUAL SITE MODEL

This section describes the conceptual site model developed based upon the evaluation of available information presented in previous sections. This model evaluates potential risks to human health and the environment and identifies suspected sources of contamination, types of contaminants and effected media, known and potential routes of migration and known or potential human and environmental receptors. 6.1 Sources of Contamination . The main contaminants of concern identified at North Penn Area 5 are chlorinated solvents including TCE,TCA, PCE, DCE and their derivatives. It is documented that AEL, Stabiius, R&B/FMC KEMA/Powertest/Webcraft/ABB New Yorker Boiler and Lindberg used cleaning agents consisting of TCE, PCE, TCA, and possibly other VOCs. Soil and groundwater samples from AEL's property indicate that TCE contamination may have resulted from the presence of the underground solvent storage tank, wastewater effluent from their plating operations, and the chemical and drum storage areas. In addition, a sanitary sewer line crosses AEL's property carrying effluent from Stabiius which was found to contain TCE and could be a potential source of past contamination. The-documented TCE spill incident that occurred from Baron- Blakeslee operations at Stabiius may also represent a source of contamination. The underground solvent storage tank at AEL has been removed and contaminated soil excavated and treated to levels acceptable to PADER. Also, discharge of wastewater effluent to surface drainages under NJPDES Permit #PA0050601 at AEL has been stopped. In addition, drums were removed and remediated from an area in the western portion of the AEL property.. Little is known about the former pond in the western portion of the AEL property.. ' . ' • ' ' ' ; ' '' " '/•'-• :-..'"...:, 6.2 Contaminant Migration Pathways ' The following contaminant migration pathways may be present in the study area: . o transport of contaminants from unsaturated to saturated soil; o transport of contaminants from unsaturated or saturated soil to the fractured bedrock; o transport of contaminants in soil via surface runoff to surface water bodies; o discharge of contaminated liquids from storm drains or sewers directly into surface , water or groundwater;. o transport of contaminants in moving groundwater, o discharge of contaminated groundwater into surface water from pumping wells; " '.' '•'•' ' '. ,. ' ' " 48 ''•'••• :. < ''" ' :

AR300668 o transport of airborne contaminants as volatilized chemicals or dust; and • ' . -' - * ' • o transport of contaminarits by biota. • Based on existing data, the primary contaminant migration pathways of concern are those related with transport of contaminants to the affected groundwater aquifer. \ , Two distinct groundwater environments are present in Area 5: the saturated portion of the soil overburden and the underlying fractured-rock aquifer. Currently, the available information characterizing the soil overburden groundwater system at the site is limited. Current knowledge is based primarily on .information from the shallow (A-series) monitoring wells at AEL and Powertest. The A-series wells are located in a relatively narrow zone along the facility's southwestern property line (Figure 3-3). Based on the depth of these wells and associated water-level data, groundwater conditions in the unconsolidated material appear to vary both spatially and temporally. The depths, of the A-series and Powertest wells indicate that the thickness of the unconsolidated material ranges from 9.5 to 24 feet along the AEL property line. Water-level data from the A- series wells indicate that the unconsolidated material is frequently dry. When groundwater is present in the shallow wells it is typically at least 10 feet below the ground surface, and most likely flows to the northwest; this flow direction is consistent with the site topography. It is likely that groundwater in the soil overburden flows toward nearby surface-water bodies. These include the West Branch of Neshaminy Creek (to the northwest) and its western tributary (to the west and southwest). Samples of soil and shallow groundwater in the soil overburden from AEL indicate that VOCs present in these media, particularly in the vicinity of the former site of the solvent storage tank, an the sewer line from Stabiius. Contaminated groundwater in the unconsolidated material may move laterally and discharge to surface water if saturated conditions are continuous in this material- Based on a limited number of surface water and sediment samples collected during investigations relative to potential TCE in AEL's wastewater, these environments have not been adversely effected to date. At least two sewer pipelines cross AEL's property, one serving AEL and the other serving Stabiius. TCE contamination his been identified in the Stabiius sewer, indicating the potential of these sewers as contaminant migration pathways. A pressure test and a lithium chloride tracer test performed of the sewer serving Stabiius suggested that no leakage occurs from this facility; however, a video survey of this line in 1990 indicated root infiltration. Groundwater movement in the bedrock aquifer occurs primarily in the fractures in the sandstone and shale under water-table conditions. At present, a water-table map is not available for all of the study area; the hydrogeological component of the conceptual site model is based on the distribution of the site topography investigations performed at the AEL facility. A groundwater contour map for the deep aquifer of the AEL property is presented in Figure 6-1.

AR300669

Under natural conditions, groundwater flow in the shallow aquifer most likely is toward the northwest to discharge into the West Branch of Neshaminy Creek. Pumping from wells in the area diverts groundwater radially toward them, causing local deviations from the natural flow conditions. NPWA well NP-21 when in use produces a significant impact on flow, directions; however, this well is no longer in operation. Other known pumping influences are AEL's main well, NWWA well NW-16 which is currently pumping, and potentially, the wells at the R&B/FMC facility northwest of AEL. Minor influences may be imposed by the AEL recovery well and nearby private wells. The details of groundwater flow in the bedrock aquifer are also unknown for Area 5. Piezometric maps have been developed for the vicinity of AEL. Maps from 1988 and 1989 indicate bedrock groundwater flow is generally toward the west and northwest. For the purposes of the conceptual site model, it is assumed that the flow directions indicated by the 1988 and 1989 piezonietric maps are generally representative of bedrock groundwater conditions. Unusually high water levels are typically measured in wells W-l and W-3. It is not known if these apparent anomalies are due to perching of groundwater in the soil overburden, mounding of the bedrock aquifer water table (perhaps due to recharge from process pipe leaks or other causes), inadequately sealed surface casings, errors in surveying the elevations of well measuring points, or. some other conditions. These discrepancies must be evaluated to allow accurate estimation of groundwater flow direction. Based on water-level measurements in the RW-series wells, bedrock groundwater typically has an upward component in this vicinity. This may be a result of pumping of the recovery well and may contribute to the lack of contamination detected recently in the deepest RW well (RW-3). At present, it is unknown how much of the groundwater in the bedrock aquifer beneath the study area is derived from recharge from the surface in the area. The low-permeability layer in the soils covering much of the area may be directing infiltration to local streams rather than allowing it to continue vertically into the bedrock aquifer. If this is the case, most groundwater beneath the area enters due to regional flow and pumping-induced conditions. - ^ According to existing information,, contaminants entering the groundwater system at the AEL facility or other locations either move laterally in the shallow system toward the nearby streams or migrate vertically into the bedrock aquifer. The contaminants may reach the bedrock aquifer by infiltration down from the soil, along improperly constructed wells, along building foundations, or via other pathways. Once in the bedrock aquifer, they may move into the cone of depression beneath the property induced by pumping centers and are removed from the groundwater system through the pumping wells. If no pumping influences are present, contaminants may move to the northwest with the regional flow and be discharged into the West Branch of Neshaminy Creek. If the shallow groundwater in the soil overburden is a really extensive, groundwater and associated contaminants may move laterally through the soil toward surface water bodies. Under these conditions, contaminant migration would occur southwest or west toward the western tributary of the West Branch of Neshaminy Creek.

AR30067I The groundwater data indicates a variability in time trends for contamination in AEL monitor wells. Some seasonal variability is seen in both the A-series and W-series wells. In general. TCE- ^ concentrations have gradually declined in the A-series wells, increased in W-4, and remained generally j steady in the others. ^-^ ~i. i • .' '''._' .. i '.'-'••. . Based on the data evaluated the lateral and vertical limits of the contaminant plum* are not well defined. Groundwater remediation'at AEL has been successful, with gradual reductions over time in TCE concentrations in monitor wells in the vicinity of the plume. The southern limit of this plume has not been defined. The TCE concentrations identified on the northern portion of the AEL property may be due to offsite sources. The lateral and vertical limits of contamination in this area have not been defined. If elevated concentrations of the chlorinated solvents identified in North Penn Area 5 are found in shallow groundwater, the potential for the presence of Dense Non-Aqueous Phase Liquids (DNAPL) to be present in groundwater exists. DNAPLS will sink within the aquifer and result in potential vertical migration of contaminants. . Surface-water samples taken at AEL in 1979 were analyzed for VOCs only and none were detected. Effluent from the air stripping tower is discharged to the small stream bordering the southwest side of AEL's property and has consistently had TCE concentrations less than the detection limit of 1 ug/l. At the AEL facility, the western tributary of the West Branch of Neshaminy Creek is the nearest surface-water body to locations of known contamination. At Stabiius, Brown Boveri, and Lindberg, the eastern tributary is nearest. Contaminants reaching either tributary will be carried downstream toward the West Branch, then to Neshaminy Creek itself, .-,'..'. ,' v j- Air monitoring has not been conducted at Area 5. Volatile emissions and dust could have been generated at AEL, particularly during their soil remediation and air stripping programs, but there is insufficient information to evaluate this pathway at this time. 6.3 Receptors , , Potential receptors to contaminants in the study area include both human and environmental species. Site residents, employees, and visitors to the study area could come into contact with contaminated groundwater from wells through ingestion. If the presence of municipal drinking water supply wells in the area increase, the potential for human receptors. These human receptors could come into contact with contaminants in air through inhalation, with contaminated vegetation in surface water and sediments through direct contact, and with contaminated biota by ingestion. Human receptors could also have dermal contact with contaminated soil, and dermal and inhalation contact through bathing and showering with contaminated water. Similarly, environmental species could come into contact with contaminants in air through inhalation, and with contaminants in surface water, sediments, and soil through ingestion, inhalation, and dermal contact.

AR300672 SECTION 7 PRELIMINARY RISK ASSESSMENT

The human health and environmental risk assessment process is intended to collect and evaluate the physical, chemical, biological and population information required to determine what risk, if any, a site presents to human health and the environment. Risk assessment can serve several purposes in the remedial process, including: _- characterization of risks related to site contamination under existing conditions; - identification of major contributors to site-related risk; - development of information to justify action or the no-action remedial alternative at a site; and - development of risk-based cleanup criteria which will be protective of human health and the environment for site-related contaminants in various environmental media. EPA's current policy concerning risk assessments is that EPA will conduct the risk assessment for this RI/FS. Communication will be maintained with EPA during collection of RI data and as the risk assessment is conducted to ensure appropriate risk analysis and models are incorporated to result in a reasonable characterization and assessment of risk for North Perm Area 5. The data collected during RI. activities will meet the required validation and be summarized and provided to EPA as required to conduct the risk assessment. EPA-performed risk assessments are required to be submitted for public comment in two (2) stages; the exposure assessment, and the resulting risk assessment. EPA has recognized the exposure assessment portion of the risk assessment process as the step most often having the highest level of uncertainty. Site-specific information can significantly reduce this uncertainty, because it generally concerns exposure-type. The data,to be presented to EPA for the purpose of conducting the risk assessment will be compiled to provide the site specific information in a form that will be readily usable for input into the risk assessment process. This will include proper identification of the level of data quality.

Afi300673 , ••' • .-.". -.'.-•• SECTIO•• N-.-' 8• • • •• • • . .• DEVELOPMENT OF POTENTIAL REMEDIAL ACTIONS

The primary objective of this portion of the RI/FS is to develop an appropriate range of waste management options or remedial action alternatives utilizing existing data. The development of potential remedial action alternatives will provide a mechanism to identify gaps in existing data. Therefore, through the identification of additional data requirements the focus of the RI investigations can be better defined. Remedial action alternatives are developed by assembling combinations of technologies, and the media to which they would be applied, that address contamination on a site wide basis or for a specific operable unit. The criteria used to develop remedial action alternatives will be discussed in this section and potential remedial action alternatives identified. , '•••''•• ' .. ' ' i - . • ' 8.1 Preliminary Remedial Action Objectives Remedial action objectives specify the contaminants and media of interest, exposure pathways, and preliminary remediation goals that permit a range of treatment and containment alternatives to be developed for protecting human health, and the environment. Therefore, remedial action objectives will address control of three specific factors: the source of contamination; migration of contamination, and exposure pathways. The preliminary remedial action objectives developed for this site are presented for each medium of interest. •AIR o Protect existing and future residents, workers, visitors, and terrestrial biota from exposure to volatile organic compounds emissions and dust containing concentrations , of hazardous substances that exceed ARARs or that may endanger human health or the environment. GROUNDWATER

. ' • • ' ' ' l • • . •• • v . o Protect existing and future users of groundwater from ingestion, inhalation, and dermal absorption of groundwater containing concentrations of hazardous substances that exceed ARARs or that may endanger human health or the environment through actual or potential risks. - . o Prevent migration of contaminants to unaffected portions of the aquifer. SOIL o Protect existing and future residents, workers, visitors, arid terrestrial biota from ingestion and dermal absorption of soil containing concentrations of hazardous 1 substances that exceed ARARs or that may endanger human health or the environment.

AR 300671* o Eliminate contaminated soil as a source of contamination. - f . " ' ' ' '' ' ' •"•'.. • _ SURFACE WATER o Protect existing and future residents, workers, and visitors from dermal absorption, ingestion, and inhalation of contaminants in surface water and from ingestion of aquatic biota containing concentrations of hazardous substances that exceed ARARs or that may endanger human health or the environment. o Protect aquatic and terrestrial biota by restoring surface water to ambient water quality criteria. ' SEDIMENT o Protect existing and future residents, workers, visitors, and terrestrial and aquatic biota from ingestion and dermal absorption of sediments containing concentrations of hazardous substances that exceed ARARs or that may endanger human health or the environment. 8.2 Identification of Potential Applicable or Relevant and Appropriate Requirements (ARARs) The identification of potential ARARs and To-Be-Considered (TBC) Information is useful in developing the scope of work for the RI, identifying data requirements, and planning field investigations. ARARs may be categorized as chemical-specific requirements that may define acceptable exposure levels that may be used in establishing potential remediation goals; as location- specific requirements that may set restrictions on activities within specific locations (i.e. fioodplains); and as action-specific, which may set controls or restrictions for particular treatment and disposal activities related to hazardous substances or wastes. The following is a general, preliminary list of potential ARARs, inclusion or lack of inclusion of an ARAR in this discussion does not preclude inclusion or exclusion of any ARAR in the FS, or in the final remedy selection. , Potential chemical and location-specific ARARs are identified on the basis of an evaluation of existing site data while action-specific ARARs are identified on the basis of the potential remedial actions. In addition to ARARs, other Federal and state criteria, advisories, guidance and local ordinances should be considered. A list^of the potential Federal and State chemical-specific ARAR's and TBC information relative to Organic compounds detected in groundwater and surface water are presented in Table 8-1. A list of the potential Federal and State action-specific ARAR's and TBC information relative to the site is presented in Table 8-2. A comment relative to the type of action that would require. consideration of the ARAR or TBC information is provided along with each item.

AR300675 Iss s g-a-.g a :i U •a •: 35 g 5 ill 3! - O J-S, «3* 5 •

* «v • 3 3 •:! "lo1 ^••t i« M*» • a— j 9? 9a •i 113ft- "1

JiK* I S I S P I I I |

5.5 32«xS3 ««i^^*««^.«w<^.tfvw9:K 8 8 •* I w C 3 3^ 8 i3 XX w • ^ S ^ • «• w« s& : a .. ; :• ____ L . . ...«••s • 553 -:^ - - XujPi S i3;« -

• «J1 .3 13 1a 1a i 111 1 11 s1 - • a a ~ t u i < • • • i M w i »••• I •• M • • : l

56 AR300676 s:s 2 s g s si • a o • * *•" *• «••£ .•S _ ?" *.r ^« * •X 1 ***** *i * •» " fc 57 AR300677 TABLE 8-2 ^ POTENTIAL FEDERAL AND STATE ACTION-SPECIFIC ARARs

Requirement • Comment ' ' RCRA-40CFR Parts 260-161 General requirements: for handling hazardous waste Part 262 . _ ' Requirements for generators Part 263 • . .. Requirements for transport Part 264 Requirements for treatment, storage.and disposal Part 268 Land ban regulations sbWA-Maximum Contaminant Levels Provision of alternate water supply; discharge to distribution system CWA-Pretreatment-Section 307,402 ' . Discharge to POTW . CWA-Effluent Limitations-Section 301, Discharge to surface water 302; Water Quality Standards-Sections 303. 304 CAA-National Ambient Air Quality Standards Air emissions- from air stripping, soil vapor extraction, and other treatment, (40 CFR Part 50): prevention of significant deterioration of air quality for criteria pollutants • • '•..'•• (40 CFR Part 60); new source performance standards OSHA—Requirements for Workers Engaged in _ Any action . • Response or Other Hazardous Waste Operations DOT-Rules for Transportation of Hazardous , Offsite disposal Materials (49 CFR Parts 107, 171.1-172.558) PADER—Clean Stream Law, Public Law • Discharge to surface water 1987, Chapter 92-State NPDES PADER-Clean Stream Law, Public Law Discharge to surface water 1987, Chapter 93-Water Quality Criteria and Stream Use . • ' PADER-Clean Stream Law. Public Law , Discharge to POTW 1987, Chapter 94-Pretreatment Requirements . , PADER-Air Pollution Control Act, Air emissions from air stripping, soil vapor extraction, and other Chapter 127-New sources treatment PADER-Air Pollution Control Act, Public Law 2119 . Air emissions from air stripping, soil vapor extraction, and other Chapter 139—Sampling and Analysis treatment . '" PADER—Solid Waste Management Act, .. Regulations dealing with identification and listing, generation. Public Law 380. Chnptef 7V • transportation, storage, treatment, and disposal of hazardous • • ' . . : ' - .-'... waste . '•.'.' ' -•',-• ' . . ' RCRA - Resource Conservation and Recovery Act SDWA - Safe Drinking Water Act . CWA - Qean Water Act . . CAA - Clean Air Act '•' OSHA - Occupational Safety and Health Act DOT - Department of Transportation • PADER - Pennsylvania Department of Environmental Resources ,

58-

AR300678 8.3 Potential Remedial Actions V_y Potential remedial actions were developed for potentially contaminated media identified in the preliminary risk assessment. The potential remedial actions presented were selected based upon the actions ability to satisfy the remedial action objectives. As required by the National Contingency Plan (NCP) the no action alternative will be included for each media and will be utilized as a baseline for comparing potential remedial actions. Also included with each potential remedial action is a statement regarding anticipated data required during the RI to evaluate these remedial actions. 8.3.1 Air The preliminary remedial action objective for air at this site is to protect human health and the environment from existing and future exposures to volatile organic compound emissions and dust containing hazardous substances. Three potential remedial actions were developed to address potential air contamination and satisfy the remedial action objectives. The three potential remedial actions developed are no action, source removal, and source control. 8.3.1.1 No Action The no action alternative would involve no remedial action with respect to potential air emissions. However, this alternative would consist of periodic air monitoring to document the presence or absence of volatile organic compounds or hazardous substance containing particulates (dust). The air monitoring would be utilized to evaluate ambient air quality and the potential for exposure to contaminants identified, if any. The no action alternative would provide baseline ambient air quality , data for use in comparison to ARARs and TBC information. A risk assessment is required to V_y evaluate the viability'of this alternative. 8.3.1.2 Source Removal The source removal alternative would involve the removal or elimination Of the air contamination source. The source may be surface soil contamination that through erosion generates dust containing hazardous substances. By removing the surface soil contamination (excavation) the source or potential source of air contamination can be reduced below ARARs or TBC information or completely eliminated. Potential sources of air contamination will require evaluation through field screening and , sampling during the RL 8.3.1.3 Source Control The source control alternative involves implementation of control techniques. Control techniques are typically applied to a specific emission source for the purpose of reducing or eliminating hazardous substance emissions. The source control alternative will most likely apply to treatment equipment that may be used onsite. The source control alternative will be used to evaluate potential remedial actions selected for other potentially contaminated media.

AR300679 8.3.2 Groundwater The remedial action objectives for groundwater at this site are to protect human health and environment from existing and future exposure to groundwater containing hazardous substances and to prevent migration of contaminants. Four remedial actions were developed to address potential groundwater contamination and satisfy the remedial action objectives. The four potential remedial actions developed are no action; institutional actions; containment; and collection, treatment and discharge, . ! 8.3.2.1 No Action The no action alternative would involve no remedial action with respect to potential groundwater contamination. The no action alternative would include periodic sampling and laboratory analysis of residential wells as well as new and existing monitor wells for the presence of contaminants of concern. The monitoring data would be utilized to establish groundwater quality and will provide a mechanism for evaluating, the need to provide an alternate water supply or initiate groundwater treatment. Groundwater quality data and hydraulic .characteristics will be required to evaluate) this alternative. 8.3.2.2 Institutional Actions The institutional action alternative would involve implementation of institutional controls rather than an actual remedial action. Several institutional actions considered for this site are access or deed restrictions providing an alternate water supply, and groundwater quality monitoring. Access restrictions would involve maintaining security with regard to monitor well usage to limit prevent access to contaminated groundwater. In addition, deed restrictions would eliminate installation of wells on properties in the area of the site and thereby; reduce the potential for access to contaminated groundwater. i Providing an alternative water supply would eliminate potential exposure to contaminated groundwater. The alternative water supply could come from new wells operated by the water authority or through the supply of bottled water to affected residents. A comprehensive well inventory,, sampling and analytical data for these wells, and water utilization rates are required to evaluate these alternatives. 8.3.2.3 Containment The containment alternative would involve minimizing the spread of contaminants through hydraulic control. The, hydraulic control can be passive (Le. slurry walls) or active (i.e. extraction wells or interceptor trenches). These alternative rely on the prevention of exposure for protection of human health or fthe environment. . Several conditions that favor the use of containment are groundwater that is naturally unsuitable for consumption (i.e. Class m aquifers), low mobility contaminants, low aquifer transmissivity, low concentrations of contaminants, low potential for exposure, and usage of the groundwater. These factors or characteristics are required in order to fully evaluate the containment alternative.

AR300680 8.3.2.4 Collection, Treatment, and Discharge • This alternative involves the recovery, treatment, and discharge of contaminated groundwater. The collection or recovery of groundwater can be achieved by using pumping wells, interceptor trenches or French drains. Treatment could involve air stripping, carbon adsorption, biological treatment, or other treatment technologies. During the RI subsurface conditions, aquifer characteristics, and a contamination assessment must be completed to provide sufficient data to evaluate this alternative. i ;.-',• ' . . . , Effluent or discharge from the treatment system could be handled in one of several ways. Discharge could be directed to the local streams which would require NPDES permits. Because the streams appear to have low flow rates, its hydraulic loading capacity would heed to be evaluated. Alternatively, the discharge could be directed to the local POTW which would require a local permit and appropriate ARARs would need to be considered. In either case, the contaminant concentrations of the effluent and hydraulic loading capacities of both systems would be evaluated. 8.3.3 Soil The remedial action objectives for soil at this site are to protect human health and the environment from existing and future exposure to soil containing hazardous substances and to eliminate contaminated soil as a source of contamination. Five remedial actions were developed to address potential soil contamination and satisfy the remedial action objectives. The five potential remedial actions developed are no action; access restrictions; capping; excavation, treatment, and disposal; and in situ treatment. 8.3.3.1 No Action . • ' ' - •'. .... ' . ' / •• :'•• •-. -.. .' ::.: .-• ' .. - . -. . • The no action alternative involves no further action with respect to the contaminated soil. The no action alternative will provide a baseline for existing soil conditions and will be used for comparison to ARARs, TBC information, and other remedial action alternatives. A risk assessment would be required to evaluate the viability of this alternative. 8.33.2 Access Restrictions -'''.,'• • ; The access restrictions alternative involves constructing a fence,around all areas of contaminated soil and debris considered part of the site. The security fence would be equipped with locks and would be marked with warning signs to limit public access. Data on the type and concentration of contaminants present in all media would be required to fully evaluate this alternative. 8.3.3.3 Capping , The capping alternative would involve capping areas of soil contamination for the purpose of limiting infiltration (protecting groundwater) and surface run-off (protecting surface water). This alternative would limit direct contact with contaminated soil. Generally, the purpose of the cap controls the material of construction.

AR30068I For example, if the purpose of the cap were to prevent migration of the contaminant to the groundwater through elimination of infiltration, then the cap Would need to be constructed of f material with low permeability (i.e., clay or synthetic material). In order to fully evaluate thi; capping, alternative contaminant type and concentration, geotechnical characteristics of the subsurface, and ARARs and TBC information must be reviewed. 8.3.3.4 Excavation, Treatment, and Disposal This alternative involves the excavation, treatment and/or disposal of contaminated soil. The excavation will be completed using conventional construction equipment (i.e. backhoe). Treatment and/or disposal of the soil after excavation will be evaluated based upon the volume of contaminated soil as well as the type and concentration of contaminants. Treatment technologies exist that allow treatment of the excavated soil onsite and offsite. Potential onsite treatment technologies are mobile incineration, bioremediation, soil aeration, soil washing (extraction), and solidification. Potential offsite treatment technologies) are limited to incineration. Disposal of excavated soil could occur onsite or offsite. The characteristics of the contaminants and the excavated soil will control the available disposal alternatives. The Resource Conservation and Recovery Act (RCRA) criteria for characterizing a waste as hazardous or non-hazardous are generally utilized to assist in identification of a disposal alternative. Depending on whether the waste is a "listed" or "characteristic" hazardous waste will determine if the residue from treatment requires management as a hazardous waste. The terms "listed" and "characteristic" are defined: Listed • ^ A material listed in the RCRA as a hazardous waste must be treated to levels of contamination in accordance with the land disposal restrictions; the treatment residue is then considered a hazardous waste eligible for land disposal at a hazardous waste landfill or an onsite landfill that conforms to the RCRA . minimum technology requirements (double-lined with leachate collection and removal system between liners, etc.). Characteristic - A material is a characteristic hazardous waste according to the RCRA, if it is corrosive, ignitable, reactive, or flammable. Therefore, if the characteristic that considers a material hazardous is removed, the treatment residue is no longer a hazardous waste and may be disposed of in an industrial waste landfill or a sanitary landfill depending on contaminant concentrations. If contaminated soil is simply removed as part of other cleanup operations (such as removal of an underground storage tank), kept within the area of contamination, and replaced in the original location, the land disposal restrictions do not apply. If at any time the soil is removed from the area of contaniination and replaced with new fill material, the restrictions apply.

AR300682 8.3.3.5 In Situ Treatment The in situ treatment alternative involves the implementation of a. treatment technology in place for the reduction or elimination of risk posed by the contaminants. In situ treatment implies that the waste materials are treated without being physically removed from the ground. There are presently several commercially available in situ treatment.technologies. Some examples are soil flushing, vitrification, biodegradation, and soil vapor extraction. Soil flushing is the washing of contaminants from the soil with suitable solvent such as water or other aqueous or nonaqueous solutions. The method is potentially applicable to all types of soil contaminants. Several bench and pilot-scale studies have been completed on the effectiveness of soil flushing. Soil flushing enables permanent removal of contaminants from the soil and is most effective in permeable soils. The technology can introduce potential toxins into the soil system and an effective collection system is required to prevent contaminant migration. In situ vitrification is a thermal treatment process by which contaminated soils are convened into chemically inert and stable glass and crystalline materials. Large electrodes are inserted into contaminated soils, and heat (up to 3600°C) is generated by passing electric current through the electrodes. Typically, vapor recovery hoods are used in combination with the electrodes to recover and treat, if required, organics emitted during treatment. Biodegradation refers to the breakdown of organic compounds in soils by the action of microorganisms such as bacteria, actinomycetes, and fungi. Treatment generally consists of optimizing , conditions of pH, temperature, soil moisture content, soil oxygen content, and nutrient concentration to stimulate the growth of microorganisms that will feed on the particular contaminants present. Alternatively genetically engineered organisms may be added to the soil system and conditions established within the soil to optimize the growth. Concentrations of volatile materials Can be reduced by the use of a vapor extraction system. Vapor extraction systems involve the recovery of volatile contaminants by injecting air or steam into the soil and extracting the air (in which volatile chemicals have partitioned) in a vapor-recovery well. These alternatives would limit further contamination of the groundwater, protect against direct contact with the soil, and protect against contamination of the surface water through runoff. -Data on soil properties, depth and extent of contamination, and the presence of suitable microorganisms would need to be collected during the RI. The extent of soil contamination (i.e., volume of soil to be treated) is a major consideration in evaluating the suitability of these alternatives. Potential exposures through inhalation or dermal contact during remediation would be considered and necessary actions taken. 8.3.4 Surface Water ' • . .,'.''•' ' ' . . The remedial action objectives for surface water at this site are to protect human health and the environment from existing and future exposure to surface water containing hazardous substances and to restore surface water to ambient water quality criteria. Three remedial actions were developed to address potential surface water contamination and satisfy the remedial action objectives. The remedial actions developed are no action; runoff diversion; and in situ aeration.

AR300683 8.3.4.1 No Action The no action alternative would involve no remedial action. This alternative would serve as a baseline for use in comparing other alternatives. A risk assessment would be requked to evaluate the viability of this alternative. 8.3.4.2 Runoff Diversion • The runoff diversion alternative would involve controlling runoff from areas of contaminated soil in order to prevent migration to surface water bodies onsite. A mechanism to capture and contain diverted runoff may be required. In the event that the captured runoff contains contaminants in excess of allowable concentrations, treatment may be required. The treatment of runoff would most likely be included with treatment of groundwater (Subsection 9.3.2.4) Data would be requked on the surface water and sediment such as the concentration of contaminants. Also, surface water drainage and flow patterns would be requked to evaluate locations for diversion. 8.3.4.3 In Situ Aeration The in situ aeration alternative would involve aerating the streams or ponds onsite to remove volatile contaminants. The aeration would most. likely be accomplished by mechanical equipment located within the stream or pond. The mechanical equipment would provide a means of increasing the air to water surface area through mixing and thereby promote volatilization or mass transfer of volatile organics. Data requked for full evaluation of this alternative includes stream ecology, stream hydraulics patterns), stream characteristics (dissolved oxygen content), and geomorphology. Impacts on the stream or pond ecology and effects of increased ak emissions would need to be considered. 8.3.5 Sediment The remedial action objective for sediment at this site is to protect human health and the environment from existing and future exposure to sediment containing hazardous substances. Two remedial actions were developed to address potential sediment contamination and satisfy the remedial action objectives. The remedial actions developed are no action and excavation, treatment, and disposal. 8.3.5.1 No Action The no action alternative would involve no further action with respect to the contaminated sediments. The no action alternative will provide a baseline for existing sediments and will be used for comparison to ARARs, TBC information, and other remedial alternatives. A risk assessment would be requked to evaluate the viability of this alternative. ' " ...

'64

AR3QQ681* 8.3.5.2 Excavation, Treatment and Disposal This alternative would involve the excavation, treatment, and/or disposal of contaminated sediments. Based upon the fact that small streams and ponds are located onsite, the excavation will be completed using conventional construction equipment (i.e. backhoe). As with contaminated soil, subsequent treatment and /or disposal of contaminated sediment will be evaluated based upon the volume of sediment as well as the type and concentration of contaminants. The potential onsite and offsite treatment technologies identified in subsection 9.3.3.4 will be applicable to contaminated sediments. Additional data requirements include stream or pond biota impact studies and dewatering requirements for excavated sediments.

AR300685 SECTION 9 • ' • ...... ' • •} • .'..•'•.•' f DATA GAPS REQUIRING RI/FS TASKS \

The overall objective of this work assignment is to conduct an RI/FS on the North Perm Area 5 site. To accomplish this objective, the work assignment has been divided into standard tasks and subtasks as described in the RI/FS Guidance document. The data needs and technical approach for the RI/FS are based on the preliminary risk assessment, summary of available information, existing conceptual site model and on the preliminary potential remedial actions. The level of effort proposed for the site in this Work Plan will fulfill these data gaps to the extent requked in order to select appropriate remedial measures. ' 9.1 Soil Contamination . Data concerning the type and quantity of potential soil contamination are needed to evaluate the effectiveness of past remedial actions and potential existing contaminant sources. 9.1.1 AEL The field investigations proposed for the AEL facility will be designed to confirm the adequacy of soil remediation activities and investigate potential contaminant sources in other areas on the AEL property. Soil gas surveys, soil borings and soil sampling and analysis at selected areas of concern will be conducted. ., ' ' V - .-'• ' . . ' ' ' . :'• ' 9.1.2 Stabiius The field investigations proposed for the Stabiius facility will be designed to investigate the areas Of TCE product use and storage and solvent waste storage. A soil gas survey, soil borings and soil sampling and analysis at the southwestern portion of the facility will be conducted to identify potential soil contamination. The specific area of the documented spill during unloading of TCE by Baron Blakeslee will be a targeted investigation area. 9.L3 R&B/FMC The field investigations proposed for the R&B/FMC facility will be designed to characterize subsurface soils in the areas of the former french drain discharge and paint storage area. 9.1,4 Powertest Due to documented groundwater contamination with chlorinated solvents (TCA) at this facility, a soil gas survey, soil borings and soil sampling and analysis will be conducted in the area of identified shallow groundwater contamination.

AR300686 9.1.5 Webcraft A soil gas survey and soil boring program will be conducted in two (2) areas on the main facility to assess past solvent handling activities at this facility. One of these areas was used as a drum storage area while the other was a drainage field for wastewater treatment discharges. 9.1.6 New Yorker Steel Boiler A soil gas survey and soil boring program is proposed for two fill areas identified adjacent to the property during aerial photograph interpretation and near the facility where materials storage areas were identified. These investigations will be conducted to assess potential contaminant sources in these areas. . 9.2 Groundwater Contamination This information will be needed to assess health risks to receptors and to plan necessary remedial measures. This information will be obtained by sampling wells at the site and analyzing the samples for selected contaminants. Monitor wells will be installed to define the lateral extent of the contaminant plumes and to assess the interconnection of contamination identified in different wells. These wells will also be used to assess the effectiveness of remediation, if implemented. Municipal, industrial, and residential wells will also be sampled. . 9.3 Hydraulic Characteristics of the Aquifers . The hydraulic characteristics of site groundwater aquifers will be needed to define distribution, migration pathways and potential groundwater flow directions. Since groundwater flow in the area is primarily controlled by the geologic structure (strike and dip of the bedding planes) it is important that the hydraulic characteristics be well defined. An aquifer test previously conducted in NP-21 indicated that under high volume pumping conditions a strike parallel cone of depression greater than 2,600 feet can be expected. This cone of depression would therefore extend south of New Yorker Steel Boiler and north of Powertest. - ' • The data requked to define aquifer characteristics will be obtained from monitor well installation; a surface fracture study of the site and vicinity; borehole television surveys; geophysical logging; and straddle packer tests in existing and new monitor wells. . In addition to these studies, water level data will be collected during the RI in existing and new wells installed as part of the RI and in isolated intervals of wells during straddle packer tests. In order to define groundwater flow rates and yield, aquifer tests will be performed on selected wells. This information will also provide requked groundwater remediation design data.

AR300687 9.4 Soil Physical Characteristics . - ' • . • - • • • ,/' *"• The physical characteristics of contaminated soil will need to be defined in order to develop so , remedial measures and to better understand potential migration pathways from the unsaturated zone-—' • to groundwater. Samples for physical characterization will be obtained in areas where significant soil contamination is identified. 9.5. Surface Water, Sediments, and Storrmvater Characteristics The potential affects of site contamination on surface water, sediments and stormwater in the area will be assessed. There is no documented contamination of these media and only limited sampling will be conducted. 9.6 Treatabilitv of Groundwater Since there has been effective groundwater treatment conducted at the AEL facility, existing operating data will be evaluated to provide information that can be used in assessing full-scale groundwater remediation of North Perm Area 5. 9.7 Treatabilitv Studies -' "* ' ' • - . • Treatability studies have not been formally planned in this Work Plan. In the case of soil, there is presently no information indicating the location or verifying the presence of soil contamination at the facilities; hence, the need for soil remediation is uncertain. RI/FS tasks proposed in this Work Plan are dkected toward assessing the possible presence of soil contamination, and treatability studie* will be proposed as needed during the RI effort , > The appropriate time to consider soil treatability studies would be upon completion of the soil investigation, at which time extensive data obtained from field analyses of soil samples will be available and drilling equipment will still be present at the site. Studies could include bench tests for biodegradation and low-temperature thermal desorption, or a prototype soil vapor extraction system set up in a promising location at the site. In the case of groundwater contamination, treatment system technology is sufficiently developed that information on influent and effluent concentrations as well as on the flow rate, of the system are all that are needed for design, and treatability studies should not specifically be needed. 9.8 Data Quality Objectives In order to generate data during the RT/FS that can support the decision making process to determine site remediation, a clear definition of the RI/FS objectives and procedures for collecting data are requked. This goal is facilitated through the development of data quality objectives (DQOs). DQOs provide an objective means of relating the end use of the data to the extent and quality of the data to be gathered in the remedial investigation components of the RI/FS. Specifically, DQOs are defined with respect to the types, numbers, and locations of samples that will be collected, and the QA levels associated with the analysis. DQOs are developed during project planning and are detailed in the sampling and analysis plan (SAP), with summary information imparted here in the Work Plan. : ' '^ . ' ' ' "• •••'.' . • - ' ' /" '•••••• . •'• '•..-. 68 .••-...- ' ,. - ,

A '83 0068 8 Data quality objectives for chemical analytical data can be measured qualitatively and quantitatively hy precision, accuracy, reproducibiliry, comparability, and completeness, which are specified for each i data set. DQOs are set such that the level of uncertainty associated with measurement of the data ^—' is compatible with the level of uncertainty that can be acceptable in the decisions or conclusions that are derived from interpretation of the data. , One component of DQOs is the QA levels associated with the analyses being conducted. The QA levels arc generally described as follows: . o Screening (Level I), which provides the lowest data quality but the most rapid results and is used for purposes of comparison to ARARs, initial site characterization to define areas for further study, and engineering screening of alternatives (bench-scale tests). Screening analyses include on-site measurements and mobile lab-generated data. . o Field Analysis (Level II), which provides rapid results and better quality data. Analysis may include mobile laboratory generated data. o Engineering (Level III), which provides an intermediate level of data quality and which is used for site characterization. Engineering analyses may include mobile laboratory generated data and Contract Laboratory Program (CLP) analytical laboratory methods usually without the validation or documentation requked by CLP Level IV analysis. o Conformational (Level IV), which provides the highest level of data quality and which is used for purpose of risk assessment, engineering design, and cost recovery documentation. Confirmation analyses require full CLP analytical and data validation procedures. >—^ o Analysis by Non-Standard Methods (Level V), which is all analysis performed in an offsite analytical laboratory which may or may not be a CLP laboratory. Method development or method modification may be requked for specific constituents or detection limits. CLP special analytical services (SAS) are Level V. . Other DQO elements such as detection limits and QA/QC methods will be detailed in the project SAP. The DQOs will be refined further during the preparation of the SAP. Table 9-1 presents the data needs and DQOs for the RI/FS.

AR300689 •S-J. ItH-I! A1$ nl^ -5 ill S - i 3^ !*!s. is

§ ini.2i.i*Ji»| f--i

>U-l M s .. i as I--!a «5i.f s 3s ' • 1«2; 5^i . 2=:- "* i.-* »• I !5L3 oi« IP 1

3 . .' . : is i |s|i*|l i p«t 1I i i 3*"eg Ifl «• fi * 1 li*!!![]i P! -lilh]U sb ! III! I! ill! Ti

AR300690 SECTION 10 RI/FS SCOPE OF WORK

The RI/FS scope of work for the North Penn Area 5 site has been developed based upon the data gaps identified following review and evaluation of existing data for the site. This evaluation and review was presented in previous sections. - ' ' ' - - . . ' Initial RI/FS tasks will investigate potential contamination sources to groundwater by conducting soil gas surveys in specific areas -of environmental concern identified previously. The soil gas survey information will be utilized to select specific areas to advance soil borings to collect soil samples for laboratory analysis. The objective of the source identification program will be to confirm past remediation of contaminated soils and to identify potential current soil contamination that may be an ongoing source of contamination to groundwater.

' - ' .'''"'. : ^ Groundwater investigations will be conducted using a phased-approach. Initially, investigations will be conducted on existing production and monitor wells to generate as, much useful data as possible from existing sources and to allow intelligent investigations in the subsequent phases including the majority of new monitor well installations. Surface water investigations will be limited to define if surface water contamination exists and potential sources of contamination. Based upon the findings of this limited sampling program, additional investigations to further define sources, if identified, will be conducted. " ' • " v .,''"• - - ' ' - The RI/FS scope of work being proposed includes flexibility to allow modifications to the scope of work based upon the findings of each phase Of work. This flexibility will ensure relevant data is collected and will allow for more focused investigations. Concurrent FS tasks will be conducted as data is generated to ensure data requkements for feasibility tasks are satisfied. Table 10-1 presents the RI/FS tasks identified to fill the data gaps identified and evaluate remedial alternatives for North Penn Area 5. T . • - • . . i .. - : 1 ' - • 10.1 Project Planning ' . • . . i This task includes planning activities for implementing this work assignment, including initial planning and those activities to be conducted during implementation to control the cost, schedule, and quality of work.

AR30069I TABLE 10-1 ' - RI/FS TASKS

Task 1.0- Project Planning Sampling and Analysis Plan (SAP) , Quality Control Project Management - Meeting Attendance • Task 2.0 - Community Relations Community Relations Plan .Community Relations Implementation Task 3.0 - Field Investigation Site Mobilization Subcontractor Procurement •'.'•'' Equipment Procurement and Site Setup Surveying . , Well Inventory Soil Gas Survey < Soil Investigations Groundwater Investigations Surface Water and Sediment Investigations Quality Assurance/Quality Control • Data Validation Assessment of Risk RI Derived Waste Disposal Task 4.0 - Remedial Investigation Report Task 5.0 - Feasibility Study Remedial Action Alternatives Screening Development of Alternatives Detailed Analysis of Alternatives Summary Comparison and Recommendation of Remedial Alternatives Feasibility Study Report .

AR300692 10.1.1 Sampling and Analysis Plan The Sampling and Analysis Plan (SAP) will contain the following discrete elements: the Quality Assurance Project Plan (QAPP), the Field Sampling Plan. (FSP), and the Health and Safety Plan (HSP). The SAP will be developed to conform to the latest version of the Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA and with the QAPP Workshop Participant Workbook. The QAPP will specify the analytical procedures; the choice of analytical methods and data reduction; data validation requirements; and reporting methods. Statistical sampling design will be performed during this task to provide guidance for the soil gas survey and soil boring and sampling activities to be -performed. At present, the soil gas surveys assume certain spacings of sampling points. Existing information on facility waste handling activities and any soil contamination will be reviewed to devise a sampling plan with a sound statistical basis. Insofar as possible, the number of samples and sampling points will conform to those specified in the Work Plan. The procedures outlined in the Compendium of Superfund Field Operations Methods and the Users Guide to the Contract Laboratory Program will be used to develop the FSP. Sample custody procedures, including those related to chain of custody, will be delineated in the FSP and will conform to the procedures detailed in the National Enforcement Investigation Center's Policies and Procedures for Sample Control. A site-specific HSP will be developed for use with each of the field activities associated with this work assignment. The HSP will include a health and safety assessment to identify problem areas where exposure to hazardous substances in water, air, or soil may occur. The assessment will also address safe working procedures, restrictions that will apply to the fieldwork, potential human exposure to hazardous substances, and the lexicological effects of these substances. An ak quality monitoring plan will be developed as pan of the HSP because of the concern for releases of VOCs into the ak. 10:1.2 Quality Control The QC aspects of the project will include a procedures review of in project activities. Deliverables will be independently reviewed by a QC review team. The QC review team will consist of qualified experienced personnel capable of presenting an objective review of project deliverables. The QC program will be designed to ensure all project activities meet the requked technical standards. 10.1.3 Project Management • -Th e ' sit• e "manage r is responsible for completin."""''g the work assignmen. t within the establishe• . (d schedule and budget and for assuring the quality of the work products. Specific project management responsibilities for the RI/FS include: 1 •, • ' ' / o arranging for staff and other resources heeded to execute the work, establishing clear lines of communication and organizing, directing, and controlling personnel and resources; 73

AR300693 o maintaining communication with the facility committee and EPA; and1 • o overseeing the project budget and schedule by regularly reviewing the Work Plan and projecv progress. • Project management of all RI/FS tasks, is included in this subtask. 10.1.4 Meeting Attendance Throughout the course of the RI/FS, project personnel will hold several meetings with EPA Region m and PADER. A kickoff meeting will include a visit to the site to familiarize the SM and task leaders with the site and to interview facility representatives to update facility information and to clarify any issue which may impact the RI/FS activities. During this site visit, initial visits will be made to any new facilities defined by EPA; modifications may be made to the Work Plan at this time if additional RI activities appear to be warranted at any of these facilities. At critical junctures of the project, it will also be necessary to conduct meetings between EPA Region m and the facility committee, to discuss project deliverables and the schedule and to evaluate the need for and scope of additional studies. 10.2 Community Relations ' - • , This task includes preparation and implementation of the Community Relations Plan (CRP). - .' 10.2.1 Community Relations Plan • A CRP will be developed from previous work conducted at the site and interviews conducted federal, state, and local officials and residents, as appropriate. The CRP will include a site description and an area map; a site .history; a community background including key environmental concerns of the community; a mailing list of affected residents, interested groups, and local, state, and national elected officials; and a description of community relations activities. This Plan will also include a schedule of community relations activities for the site. ' 10.2.2 Community Relations Implementation Implementation of the CRP will include the following activities: o preparing a "pre-RI/FS" kickoff fact sheet; o preparing a "post-RI/FS" summary fact sheets o preparing the proposed plan fact sheet; o providing public meeting support; o providing technical support for community relations; and o securing meeting rooms and supplying visual aids for public meetings.

74 ' . * : ^ :

AR30069I* 10.3 Field Investigation All efforts for the preparation and implementation of site characterization work are included in this task. The field investigation task will involve the interaction of several subtasks, each of which addresses a different element of RI field effort. -.'.';' 10.3.1 Site Mobilization Site Mobilization involves the activities that are necessary before the field activities can be implemented. This subtask includes subcontractor procurement, equipment procurement, and site setup. 10.3.1.1 Subcontractor Procurement Several of the investigations to be conducted during the course of the RI will requke the services of outside contractors. Services expected to be subcontracted are: o surveying; '."...'' o overflight for aerial photography; , o drilling and monitoring well installation; o pump pulling and setting; o borehole television and geophysical surveys and temperature logging; o soil gas survey; o geotechnical laboratory analyses; o straddle-packer testing; : o fence construction; and o i Rl-derived waste removal. Time expended in preparing .and evaluating subcontractor bid documents and in subcontract administration will be covered under this subtask. 10.3.1.2 Equipment Procurement and Site Setup. This element involves acquiring the equipment that will be used during the field investigation activities and setting up onsite facilities, including an onsite field office. Decontamination facilities for-the heavy equipment that will be used onsite will be included in the drilling subcontract. A secured area for storage of contaminated materials and equipment will be constructed during the RI. Wastes mat may be generated include disposable protective clothing and drill cuttings. It is assumed that permission will be obtained to locate the onsite field office, equipment storage and purge waters facility, and waste storage area on the property of a facility. 10.3.2 Surveying The purpose of this task is to develop a base map of Area 5 and accurately survey pertinent features. The topographic "contours and additional features will be digitized from aerial photographs obtained from a subcontracted site overflight. The map will have a horizontal scale of 1 inch equals 200 feet and a topographic contour interval of 2 feet. .. , . • • • • •.•• . . ,' 75 ' '"•'••. • / '..

AR300695 The map will include an area of about 4 square miles and will show roads, buildings, streams, .etc. The area of the site characterized by paving and surface covers will be defined using the aerial photographs. 'A licensed surveyor will measure the horizontal and vertical locations of pertinents^ features at the site. Pertinent features will include wells, facility property boundary points,.and, .facility structure points (e.g., building comers, drain locations). Horizontal locations will be measured to the nearest 1 foot; elevations of well casing measuring points will be surveyed to the nearest 0.01 foot, while other elevations will be surveyed to the nearest 1 foot. These features will be plotted on the site map. - ' Detailed maps of the AEL, Stabiius, Webcraft, Powertest, R&B/FMC and New Yorker Steel Boiler facilities will be developed as part of this subtask. The maps will include the locations of property boundaries, buildings, wells, and other pertinent features. The horizontal scale will be 1 inch equals 100 feet. . . , .. . ; 10.33 Well Inventory Although much information is currently available on existing wells within North Penn Area 5, a well inventory will be conducted to locate as many public and private wells as possible (including residential, commercial, and industrial wells) in order to identify potential receptors and to identify potential vertical migration routes for contaminants within wells. The well inventory subtask will include a search for significant groundwater pumping centers, both in the area and its periphery, which may be influencing the dkections of groundwater flow and contaminant migration. Also, additional wells may be identified for logging and testing (including large-scale aquifer testing) to provide more subsurface information, while some may be identified that should be abandoned by grouting in order to prevent vertical cross contamination. A survey of residential wells within Area 5 was performed by CDM personnel in August 1987. It is known from that study that many of the residents have private domestic wells despite the availability of public water. Information on some other wells in the vicinity has been obtained from PADER, facilities, the U.S. Geological Survey, the Pennsylvania Geological Survey, and the Delaware RiVer Basin Commission. • 10.3.4 Soil Gas Survey The objective of this subtask is to perform soil gas surveys at 'the facilities with documented chlorinated solvent usage to determine the extent of possible VOC soil contamination. These surveys will be used to guide the surface and subsurface soil sampling programs. Soil gas surveys will be performed at specific areas of concern at AEL, Webcraft, Powertest, Stabiius R & B/FMC and New Yorker Steel Boiler In general, soil gas measurements will be made on grids ranging from 10-feet centers to 50-feet centers, depending upon the area being surveyed. The proposed locations of the soil gas surveys for each facility are presented in Figures 10-1,10-2, 10-3, 10-4, 10-5 and 10-6, respectively. The actual locations of the soil gas survey measuring points may vary from .a prescribed grid, depending upon the results of statistical sampling design.

AR300696

in Di I?I

* nj ••« P

AR300698 J=L (—n

Soil gas survey measurements will be made by pushing a stainless steel probe into the soil to prescribed depths below the surface and extracting a sample of the ak present in the soil pore spaces. Soil gas samples will be obtained at two depths at each location. One sample will be obtained at a depth of 5 feet, a depth sufficient to avoid the effects of possible short-ckcuiting. While the other sample will be obtained at the soil-rock interface. If the soil depth is less than 5 feet, a sample will only be obtained at the soil-rock interface. If the subsurface soils are not amenable to ak extraction, a core sample will be collected from the appropriate depth and headspace analysis conducted. At all locations where volatile organics are detected in the soil gas, additional samples will be obtained one-half the. grid distance away from the positive reading in four directions oriented with the grid, thus refining the grid in the vicinity of the positive reading. A mobile field GC will be used to support the soil gas survey since quick turnaround of sample analyses will be requked. Use of the field GC will entail several activities. These activities include validating analytical methods, preparing standard operating procedures, mobilizing to the site, operating the field GC on a day-to-day basis, demobilizing from the site, and preparing reports and data .summaries. QC samples (duplicates and field blank) will be analyzed by the field GC to ensure the representativeness of the analytical results. Details of these activities will be discussed in the SAP, along with field procedures associated with sample collecting and handling and. a discussion of detection limits associated with the equipment to be used. All soil gas samples will be analyzed by the field GC for TCE, PCE, TCA, 1,2 - DCA DCE, and cis-l,2-DCE. Additional samples will be collected and analyzed as requked for QA/QC purposes. Details on the sampling method, analytical method, and detection limits will be discussed in the SAP. 10.3.5 Soil Investigations The objectives of this subtask are the following: o to collect surface and subsurface soil samples for chemical analysis in order to determine the nature and extent of soil contamination at each facility; and • / . . . . ••.'•'•'. o to collect samples to determine the physical characteristics of soil for evaluation of possible remedial alternatives. Surface and subsurface soil samples will be collected at most facilities. The locations of the soil sampling will also be in similar areas as the soil gas survey areas presented in Figures 10-1, 10-2, 10-3, 10-4, 10-5 and 10-6. ; The soil boring program will be guided by the soil gas surveys at the facilities where such surveys are performed. The soil gas measurements will be made at the locations defined by the statistical sampling design prepared for the SAP. At locations where volatile organics are detected at significant concentrations in the soil gas, soil borings will be performed; in addition, soil borings will be performed at some locations .where volatile organics were not detected. For estimating purposes, it is assumed that soil borings will be advanced at 20 percent of the locations where soil gas survey measurements are collected. '

'83

AR300703 Initially, soil samples will be collected by continuous split-spoon sampling of the soil to bedrock. A drill rig will be used for this effort; if access is difficult, a tripod rig or hand auger sampling may/' > be used.--- . • .'..--• '.•.-'.••'•'.' •'..'•• r ..... •';. .: ''.- . ', ; The number of soil borings and number of soil samples to be collected are summarized in Table 10- 2. It is assumed that all soil borings will be advanced to bedrock at a depth of 10 feet. Samples will be collected from the shallow zone, middle zone and soil/rock interface of each boring resulting in collection of three (3) soil samples per boring. These soil samples will provide delineation of the vertical extent of contamination. In order to provide sufficient sample volume, 3.5-inch diameter split , spoon samples will be used. All samples will be visually described and classified according to the Unified Soil Classification System. Based upon the initial continuous split-spoon sampling activities, split-spoon samples may be revised to be collected at five foot intervals. . Soil borings will be advanced dependent upon the results of the soil gas. survey. For estimating purposes, assumptions have been made as to the requked soil borings at each facility as presented in Table 10-2. Any soils brought to the surface but not retained as samples will be returned to the boring in 2- foot lifts and compacted using the drill rig. Any open holes remaining will be backfilled with grout, and the surface will'be returned to its original conditions. All samples will be initially surveyed with an HNU photoionization detector (PID) or similar instrument; samples will then be submitted for analysis by the field GC. It is estimated that all of the soil samples collected will be analyzed using the field GC. It is also assumed mat 20 percent of the soil samples analyzed by the field GC will also be submitted to the CLP to confirm the fielf* GC laboratory results and to provide information on a wider array of constituents. Different method.) (with different detection limits) will be used between the field GC and CLP to compare resultsr*"\ However, the field GC is expected to be the primary analytical tool for the laboratory soil investigation. Table 10-2 also contains a summary of the chemical analyses to be performed on the soil samples. All soil samples submitted to the field GC will be analyzed for the volatile organic constituents listed in Table 10-3. All samples submitted to the CLP laboratory will be analyzed for the volatile organics listed in Table 10-4 and TOC. Selected samples will be CLP laboratory analyzed for semi-volatiles and metals. Background soil samples will be obtained for each facility. An attempt will be made to obtain samples from each soil type present in the area. Based on existing information, there are only two soil types that cover significant portions of the area: Abbotstown, which covers the major percentage, and Readington. Insofar as possible. Subsurface samples will be obtained upgradient from any operations involving potential transport to contamination while surface soil samples will be collected up slope and up wind from any operations.

AR3007QI* TABLE 10-2 . SOIL BORING PROGRAM .

Facility General Location Nunber of Sample Total Number of Chemical Analysis Locations Samples AEL ' .' '" -'••'•'•'. '. -';•'' • ' .•••...''• k ' . , ' •"'.•,"• '' • ' • '"'-'• ; Southwest of facility 2 6 Table 11-3 VOCs 2 ; Table 11-* VOCs 1 Former solvent storage tank 2 6 Table 11-3 VOCs 2 , Table 11-* VOCs * SVOCs Former pond . 2 6 Table 11-3 VOCs '„-;..;'. . 2 Table 11-A VOCs Former buried drun area - 2 6 Table 11-3 VOCs . . 2 Table 11-* VOCs * Metals Northern portion of property 15 AS Table .11-3 VOCs 9 Table 11-* VOCs . RiB/FMC ' . ' • French Drain Area : 5 15 Table 11-i VOCs 3 Table 11-* VOCs Paint Storage Area 3 . , 9 Table 11-3 VOCs 2 Table 11-* VOCs + Metals . STABILUS v •',-'.. TCE Storage Tank 3 9 Table 11-3 VOCs 3 Table 11-* VOCs + SVOCs Waste Storage Area 3 9 Table 11-3 VOCs ,3 Table 11-* VOCs POWERTEST ./ V j Northwestern portion of property 10 " '. 30 ." Table 11-3,VOCs ^—^ 6 Table 11-* VOCs 2 Table 11-* SVOCs ; ' UEBCRAFT ; . - ' . • '.: ..'/-' :' ' ' Rear of Facility 3 9 Table 11-3 VOCs 3 Table 11-* VOCs Drainage Field 3 9 Table 11-3 VOCs 3 Table 11-* VOCs t SVOCs NEW YORKER STEEL BOILER South Fill Area . 15 *5 Table 11-3 VOCs , 9 Table 11-* VOCs North Fill Area 5 15 Table 11-3 VOCs 3 Table 11-* VOCs Rear of Facility 3 9 • Table 11-3 VOCs 3 Table 11-* VOCs + SVOCs

BACKGROUND . 3 ^6 Table 11-* VOCs Z Table 11-* SVOCs + Metals TOTAL 79 . 228 Table 11-3 VOCs 61 Table 11-* VOCs . 15 Table 11-A SVOCs 6 Table 11-* Metals

85 •. >' AR300705 TABLE 10-3 \ ' - ( • ' ' . • ' COMPOUNDS TO BE ANALYZED BY THE FIELD GC

Volatile Organic Compounds

1,1-Dichloroethene Trichloroethene Tetrachloroethene 1,1,1-Trichloroethane cis-1,2-Dichlorethene 1,2 - Dichloroethane

AR300706 TABLE 10-4 TARGET COMPOUND LIST, TARGET ANALYTE LIST, AND SELECTED INDICATOR PARAMETERS

TARGET COMPOUNDS

Volatile Organic Compounds Acetone Benzene Bromodichloromethane Bromoform Bromomethane Carbon disulfide Carbon tetrachloride Chlprobenzene Chloroethane Chloroform Chloromethane Cis-l,2-dichloroethene Dibromochloromethane 1,1 -Dichloroethane 1,2-Dichloroethane 1,1-Dichloroethane 1,2-Dichlorpethane (total) trans-1,2-Dichloroethane 1,1-Dichloroethene 1,2-Dichloroethene (total) Trans-1,2-Dichloroethene 1,2-Dichloropropene cis-1,3-Dichloropropene trans-1,3-Dichloropropene Ethylbenzene 2-Hexanone Methyl ethyl ketOne (2-Butanone) 4-Methyl-2-pentanone Methylene chloride Styrene 1,1,2,2-Tetrachloroethane Tetrachloroethene 1,1,1-Trichloroethane 1,1,2-Trichloroethane

AR300707 ' TABLE 10-4 (Continued) TARGET COMPOUND LIST, TARGET ANALYTE LIST, AND SELECTED INDICATOR PARAMETERS

TARGET COMPOUNDS

Trichloroethene . Toluene Vinyl acetate. Vinyl chloride Xylene (total) Semi- Volatile Compounds Acenaphthehe • Acenaphthylene Anthracene Benzo (a) Anthracene Benzo (a) Pyrene Benzo (b) Fluoranthene Benzo (ghi) Perylene Benzo (k) Fluoranthene Benzo Acid ' Benzyl Alcohol \, ..." - Bis (2-chloroethoxy) methane Bis (2-chloroethyl) ether . Bis (2-chloroisopropyl) ether Bis (2-Ethylhexyl) phthalate 4-Bromophenyl Phenyl ether Butyl Benzyl Phthalate 4-Chloro-3-Methylphenol (P-Chloro-M-Cresol) 4-Chloroaniline 2-Chloronapthalene 2-Chlorophenol 4-Chlorophenyl Phenyl ether Chrysene Di-n-Butylphthalat^ Di-n-Octyl Phthalate Dibenz (a^) Anthracene Dibenzofuran 1,2-Dichlorobenzene \ 1,3-Dichlorobenzene 1 ,4-Dichlorobenzene

ftR300708 • TABLE 10-4 (Continued) TARGET COMPOUND LIST, TARGET ANALYTE LIST, AND SELECTED INDICATOR PARAMETERS TARGET COMPOUNDS

3,3-Dichlorobenzidine 2,4-Dichlorophenol Diethyl Phthalate Dimethyl Phthalate 2,4-Dimethylphenol 4,6-Dinitro-2-Methylphenol 2,4-Dinitrophenol 2,4-Dinitrotolune 2,6-Dinitrotolune Fluoranthene Semi- Volatile Compounds ,--»'• .Fluorene Hexachlorobenzene Hexachlorobutadiene Hexachlorocyclopentadiene Hexachloroethane Indeno (1,23, -cd)Pyrene Isophorone 2-Methylnaphthalene 2-MethyIphenol 4-Methylphenol N-Nitroso-Dipropylamine N-Nitrosodiphenylamine Naphthalene 2-Nitroaniline 3-Nitroaniline , 4-Nicroaniline Nitrobenzene 2-Nitrophenol 4-N5trophenol Pentachlorophenol Phenanthrene Phenol Pyrene 1 ,2,4-Trichlorobenzene 2,4,5-Trichlorophenol 2,4,6-Trichlorophenol

AR300709 TARGET .COMPOUND LIST, TARGET ANALYTE LIST, AND SELECTED INDICATOR PARAMETERS

TARGET ANALYTES

Metals Aluminum Antimony Arsenic Barium Beryllium Cadmium Calcium Chromium Colbalt Copper Iron Lead Magnesium Manganese Mercury Nickel Potassium Selenium Silver Sodium Thallium Vanadium Zinc

SELECTED INDICATOR PARAMETERS TOC Hardness

AR3007IO Geotechnical samples will be obtained to provide information in the event that soil remediation is needed. Based upon the laboratory results, 24-inch Shelby tube samples Of undisturbed soil will be \J obtained from contaminated areas and submitted to a geotechnical laboratory for physical characterization. "The physical characterization will include the following: o Atterberg limits; o particle size distribution; o water content; . o specific gravity; < o porosity (total); o bulk density; and V o permeability. It is estimated that a total of six geotechnical samples will be submitted for analysis from Area 5. During soil boring activities, the ak quality in the vicinity of the drilling will be monitored as part of implementing the HSP. This monitoring will provide information on volatilization of organics from the soil, during disturbance. Based on the ak quality data collected, the need for more extensive ak monitoring will be addressed. Upon completion of the soil sampling and field GC analysis, the suitability of the sites as interim action operable units will be evaluated. More detailed information on DQO elements for the soil sampling such as sample collection, handling, and analysis (including the need for duplicates and QC samples) and analytical methods and detection limits will be supplied in the SAP. 10.3*6 Groundwater Investigations * ._ The groundwater investigations for the RI/FS have been designed to collect the requked data in an efficient and effective manner. A phased-approach will be used to optimize existing available resources of data at the site. Three (3) phases will be implemented to characterize the hydrogeological characteristics. '••--•• ' ' ' v 10.3.6.1 Phase 1 •Groundwater Investigation The initial phase will involve data gathering and evaluation tasks, groundwater elevation recording, downhole geophysics on existing monitor wells, straddle-packer testing, and aquifer testing. The objective of the Phase 1 investigations will be to fill data gaps concerning site hydrogeological conditions using existing monitor wells and available data. ; Data Evaluation Existing monitor well logs, aquifer test data and well construction details will be obtained and reviewed to determine monitor and production wells in the North Perm Area S with previous downhole geophysics and aquifer tests conducted.

AR3007H These data will be reviewed and information accumulated to aid in determination of wells that can be used for field investigations to develop the data required to evaluate subsurface hydrogeology'' During development of the conceptual model, existing information was obtained relative to the NF, 21 and North Wales municipal supply wells. Aquifer tests were conducted on these wells and this information will be reviewed and evaluated to aid in designing the subsequent groundwater investigations. Groundwater Elevations In order to better define groundwater flow dkection and gradient prior to monitor well installation, continuous, water level recorders will be installed at strategically selected monitor wells. These recorders will provide information relative to groundwater flow dkection under various pumping conditions. Area production well operations will be coordinated to allow definition of the pumping center effects on groundwater flow dkection. Continuous water level readings will be collected over a thirty (30) day period inclusive of production well activities. Downhole Geophysics The distribution of subsurface fractures will be investigated during this phase using borehole television and geophysical methods. In a borehole television survey, a television camera is, lowered, through the open borehole of the well and the image is recorded on video tape. This approach provides immediate identification of fracture zone locations. The geologic Setting at North Penn is aptly suited for this technique and the method was successfully used in NP-21 and NP-87. The existing video tapes will be reviewed and compared to determine depths of fractures zones in these two (2) wells. Based on our findings one (1) additional well will be selected for downhole logging to provide af initial understanding of the fracture system so that subsequent monitor well depths can be determined. In addition to televiewer analysis, temperature, caliper and flow meter logging will be performed during Phase 1 activities. Since inflow and outflow within various fracture zones cannot be determined conclusively by televiewer and/or geophysics alone, brine testing will also be conducted. Straddle-Packer Testing The subsurface hydrogeology of North Penn Area S consists of groundwater moving through discrete fractures in the bedrock. In order to define the hydraulic characteristics of the hydrogeological system, individual fracture zones will be isolated to conduct tests on these zones. ' Straddle-Packer testing involves lowering inflatable packers into the borehole or well to depths above and below the zone of interest. When the packers are inflated, the borehole interval is sealed off preventing interaction of the other water-bearing zones. In the zones isolated using straddle-packers, several tests will be performed. The specific capacity of the interval will be estimated by pumping the interval at a constant rate and observing the decline in hydraulic head in the interval with a pressure transducer. The interval will be pumped until a steady-state water level, or at least significant drawdown, is achieved. The specific capacity test will indicate the relative permeability of the packed interval.

AR300712 Pressure transducers will also be installed above and below the packed interval to assess the degree of vertical interaction between the packed interval and the other water-bearing zones. Water levels measured in each packed interval prior to pumping will determine whether vertical hydraulic head gradients exist at the borehole location. • ' • . • •> - The Phase 1 investigation will include straddle-packer testing of NP-87, which is a well located in the immediate area of NP-21 with 5 intervals being tested. Test intervals will be selected based on the findings of the television review of NP-21 and NP-87, an existing caliperlog of NP-21, the additional televiewer survey, temperature logs and brine tests. . Straddle-Packer Groundwater Sampling Groundwater sample's will be obtaine. " d from the packe.•:'''.d interval to determine the vertical distributio' n of potential contaminants. The samples will be collected after completion of the pumping period for the specific capacity test in order to ensure that the packed interval has been sufficiently purged. The samples will be laboratory analyzed for volatile organics listed in Table 10-4. In one packed interval in each well, two replicates (i.e., three samples) of groundwater samples will be obtained for analysis because the results of the analyses from the packed intervals will be used to make decisions on depths at which future monitor wells will be installed, these special replicates will provide greater assurance that there is a chemical difference between zones. Details of the sampling methods, analytical' methods, detection limits, and other relevant topics will be presented in the SAP. Aquifer Test ;'.- In order to determine aquifer hydraulic characteristics and to assess the amenability of the groundwater aquifers to pump and treat technology, an aquifer test will be conducted on NP-87. Since groundwater flow is primarily controlled by the strike and dip of bedding and pumping in NP- 21 can influence wells parallel to strike greater then 2,600 feet to the north, it is crucial that a firm understanding of the groundwater flow dynamics be developed. NP-87 is located approximately thirty (30) feet from NP-21 and is currently not in use.

• • • f ! •". ' ' • ' The aquifer test will be performed using a 72-hour drawdown period and a sufficient recovery period. Several monitoring wells at various depths will be monitored to assess resultant drawdown from the aquifer test. In addition, groundwater samples will be collected and analyzed from the pump discharge for specific parameters of concern for groundwater treatment including VOC's, pH, SPCD, hardness and iron. The aquifer test purge waters will be discharged to the local POTW, predicated upon receipt of approval from the municipal utility authority. These tests will provide valuable design data for evaluating alternative groundwater treatment units for application to the site. In addition, the data can be used to develop conceptual design of a groundwater recovery and treatment system if selected for implementation at the site. The Phase 1 groundwater investigations will provide vital information as to the migration pathways of groundwater contamination. This information will be analyzed and evaluated to determine monitor well locations and construction details for future Phase 2 and 3 investigations.

AR3Q07I3 10.3.6,2 Phase 2-Groundwater Investigations The Phase 2 groundwater investigations will be designed based upon the results of the Phase investigations. These tasks will be developed to fill data gaps identified during the previous investigations. Phase 2 Monitor Well Installation ' •". . ' •> : .-'.•• i " • • - ' _ . • • • Selected additional monitor wells will be installed within the North Penn Area 5 to provide data concerning the extent of contamination and groundwater flow dkection. In addition, this information will be utilized to make decisions concerning future Phase 3 investigations. The results of the Phase 1 investigations will determine the need and location of additional monitor wells. For purposes of developing a definitive scope of work at this time, assumptions have been made based upon existing data to identify monitor well locations and depths. During the actual RI, monitor well installations may be adjusted or eliminated, based upon Phase 1 findings. Six (6) monitor wells are estimated to be installed during Phase 2 investigations including three (3) in the area, of AEL, one (1) in the area of Powertest and Webcraft property, one (1) on the New Yorker Steel Boiler property and one (1) in the vicinity of the Byers Choice facility. Three (3) shallow bedrock monitor wells will be installed on adjacent properties to AEL. One monitor well will be installed north of existing well W-4 in the area of Whistlestop Park. This well will aid in identifying potential offsite sources of contamination contributing to monitor well W-4 and defining groundwater flow in this area. A Second monitor well will be installed west of the AEL facility near the western tributary of Neshaminy Creek. This well will provide important data concerning potential migration of contaminants to the west of the AEL facility as well as definin shallow zone groundwater flow in this area. A thkd monitor well will be installed up dip gradient to the AEL facility. This well will provide information relative to potential upgradient sources of TCE. This is important since TCE was identified in a domestic well southeast of Richardson Road. A fourth deep bedrock (MW-2D) monitor well will be installed as a cluster with monitor well W- 12 and will be constructed between NP-21 and the AEL facility. The depth will be determined based on the aquifer test, straddle-packer testing/sampling and geophysical logging of NP-87. Also, the fracture zone identified during the downhole logging of NP-21 was at 60-124.feet; this deep monitor well will be critical for identifying potential migration pathways in the identified fractured zone in this area. If Phase 1 data collection proves to be incomplete for placement of this well it will then be installed during Phase 3 activities. The well will be drilled to a depth of approximately 350 feet to perform packer testing, borehole geophysical and an aquifer test. . Once these activities are completed the well will be sealed to a depth based on our findings. Based on previous findings we estimate this depth to be 130 feet.

One (1) shallow bedrock monitor well will be installed in the area between the Powertest and Webcraft facilities. This well will assess the potential contribution of these facilities to the identified groundwater contamination in North Penn Area 5.

AR3007II* One (1) shallow bedrock monitor well will be installed on the New Yorker Steel Boiler property located at the southern portion of North Penn Area 5. This monitor well will evaluate potential groundwater contamination south of NP-21. There has been'np. documented investigations to confirm lack of contaminant sources in this area. This well will also provide data as to the horizontal extent of groundwater contamination to the south. One (1) shallow bedrock monitor well will be installed on the northern border of the Byers Choice facility. This well will aid in assessing groundwater quality in the area of Stabiius and Byers Choice. This well will also evaluate the potential effects of the documented spill of TCE and reported runoff patterns onto the Byers Choice facility. Table 10-5 presents the rationale for proposed monitor well locations and Figure 10-7 presents the locations of monitor wells proposed for the Phase 2 and Phase 3 groundwater investigations at North Penn Area 5. -'./.' The.Phase 2 monitor well installations will provide data requked to initially confirm the extent and characteristics of groundwater contamination and will provide data relative to potential additional sources of contamination in Area 5. These monitor well locations have been designed to provide the overall groundwater data required to fully evaluate and delineate the extent of contamination, if requked, during the thkd phase of investigations. Phase 2 Groundwater Sampling . • ' ••.•'•'' . •' During the Phase 2 investigations selected existing and new monitor and production wells will be sampled to generate as much reliable data as possible. This would include facilities'onsite production and monitor wells including AEL, R&B, New Yorker-Steel Boiler, Powertest, NP-21 and NW-16. The groundwater sampling activities will be conducted following Phase 2 monitor well installation. Table 10-6 presents the wells to be sampled and analyzed during the Phase 2 investigations. All NPWA, NWWA, and production wells will be sampled using pumps already present in these wells. The monitor wells will be sampled using appropriate sampling equipment. All groundwater samples from Phase 2 will be analyzed .for the Table 10-4 VOC Compounds. Selected monitor wells will also be analyzed for. metals as a screening for potential metals concentrations present in the groundwater. Groundwater samples analyzed for metals will be analyzed as soluble metals.

AR3007I5 x"

s %% 388 111§§ 0 ?

ug c4 «S< . 1 51 v 1 •q » * , 5 « 3 « 5 8 .« a. o O 9 u O ' S 2 :g U 3 Q **, H S B -rf - 3 a I rt M

.1. ' •'•••-• '• •' :- ',. '••*».••H« / WO• w o vr * eo • ui • O•'•'.Q Q ' o «HM no '«r-«}B ,-««ill«. •:';"•>±1 I «".« '.iM*«:. 'OJi' 0»«-« •<•

98 AR3007I6 AR3007I7 TABLE 10-6 Phaee 2 Groundwater Sampling Program

Total Number Chemical Analysis** Sample Location Number of wells of Samples

' ,a 29 Table 11-4 VOCs Konitor Wells* 2| 5 Table 11-4 Ketals + SVOCs -'.••' -M s 4 Table 11-4 VOCs AEL Recovery Wells 1 1 Table 11-4 Ketals + SVOCs , • '.. , 1 Table 11-4 VOCs AEL Production Well l R&B Production Wells 3 \ Table 11-4 Ketals + SVOCs New Yorker Steel Boiler \ \ Table 11-4 Ketals + SVOCs Production Well l NWWA Well NW-16 1 1 Table 11-4 Ketals +SVQC8 Y , ' 1 Table 11-4 VOCs NPWA Well NP-21 J J Table 11-4 Ketals + SVOCs

Totals 10 10 Table 11-4 Ketals + SVOCs

* 4-AEL "A Series" wellsi 14-AEL "W Series" wells) 4-Fowertest wells; and 7 newly installed wells. •* Table 11-4 compounds analyzed by CLP methodology.

68 ; AR3007I8 10.3.6.3 Phase 3 - Groundwater Investigations The Phase 3 groundwater investigations will be designed based upon the results of the Phases. 1 ani/ 2 investigations. These activities will be developed to fill the data gaps remaining following the initial phases of work, if any. Phase 3 Straddle Packer Testing Upon completion of the Phase 1 and 2 activities the collected data and information will be analyzed to determine additional straddle packer tests, temperature logging and brine test that win be requked to be conducted, if any, to develop a full understanding of aquifer characteristics and contaminant migration pathways. The additional packer tests and downhole geophysics surveys will be conducted on a newly installed monitor well which will be strategically located to provide the maximum amount of information. For purposes of this work plan, it is assumed one (1) additional straddle packer test and downhole geophysics survey will be conducted in MW-2D. Phase 3 Monitor Well Installation The number of monitor wells to be installed during Phase 3 will be dependent upon the results of the Phase 1 and Phase 2 investigations. Based upon review of these data; additional, monitor wells will be installed to complete the groundwater assessment, if requked. These wells will be strategically placed to further delineate groundwater contamination and provide additional data relative to potential additional sources of contamination identified during Phase 1 source identification activities. ~v ' ' • . '.'.'• . ''.•.': Earth Technology has developed proposed wells based upon current information and assumed findin The number and locations of these monitor wells will be adjusted based upon actual results previous tasks. Ten (10) additional monitor wells are estimated to be requked to complete contamination delineation. Figure 10-7 also presents the Phase 3 monitor wells to be installed in Area 5 and the proposed construction features of each well are presented in Table 10-7. Two (2) additional monitor wells are proposed on the AEL facility including one deep well in the area East of the facility near W-6 and one cluster deep well adjacent to monitor well W-4. The addition of these two (2) wells will complement the existing wells forming two (2) clusters. Two (2) monitor wells are proposed for the R&B facility to assess groundwater quality on this site. These wells are requked assuming the current industrial wells onsite will not be suitable for monitoring groundwater zones effectively. Two (2) monitor wells are proposed on the Stabiius property during Phase 3 to assess potential groundwater contamination at this facility. One (1) additional monitor well is proposed for the Powertest facility to assess potential vertical migration of contamination at this facility. A monitor well cluster will be developed at existing monitor well MW-2 at this facility. x

AR3007I9 ll • ."' • ' - ' ' ' 0 o mC-O o o C «C Ca eC -cO TJTaic^ceftiaieJ -0 CC CC Ci -o* TJ«o^ ooacpo ,o oo .o p .c f t c oe cec oco aooo, ftoo . &« c CX C V 0)00 « SeW o h o fataV'0U o o • 14 o M W WW W W

O"-

»-ei -- ~4 4c* •oCioc l 'JM'OOO * <•*• c*>£ tIn Hl iIn iInI in I in H l rlrIl l H l I iniI n IiIn inI «n g«HOhe i •,

» a * I 5 < I

WD«n '** rHtxWQ«n «.o. ^. <«.•.«0 » • ' £S g -*? ' 11il1l '1 * * 1' 1* 11 S

«S. AR30072J} One (1) additional monitor well is proposed on the New Yorker Steel Boiler facility as a cluster with . Phase 2 monitor well MW-8. This well will assess potential cteep migration of contamination -gouth' southwest of NP-21. . : ^^ One (1) monitor well will be installed north of the intersection of Walnut Street and County Line Road to assess potential groundwater contamination in the dkection of the West Branch of Neshaminy Creek. This well will also be used to assess potential groundwater contamination migration from the Powertest and R&B/FMC facilities. . . •• • Y • • • . . • •.•• • • • One (.1) monitor well will be installed adjacent to Richardson Road between .AEL--ahd NW-16 to provide information relative to potential strike-parallel sources of contamination and to assess upgradient sources of TCE identified in the Regan domestic well. Phase 3 Groundwater Sampling Upon completion of the monitor well installations site monitor wells, production wells and residential wells, will be sampled as presented in Table 10-8. This sampling activity will constitute a second round of groundwater sampling to provide follow up groundwater quality data from the Phase 2 sampling round and provide additional groundwater quality data for the newly installed Phase 3 monitor wells and residential wells. Details of the sampling procedures, analytical methods and detection limits will be presented in the SAP. Monitor Well Depths ' - . • . r • ' '-'.''. ' • The borehole logging, Straddle-Packer testing, aquifer test and sampling will be used to determine tf depths at which monitor wells will be installed. Four (4) of the wells are to be installed in parts of the bedrock aquifer. The purpose of these wells is to provide facilities to measure the vertical hydraulic gradient and to sample for the vertical distribution of contaminants. Therefore, the deepest well will be installed below the deepest extent of the contaminant plume. In order to provide additional information on the vertical distribution of contaminants, borehole television and temperature surveys, and straddle-packer tests and sampling will be performed in selected wells in the area. In these wells, the borehole television and temperature survey will provide information on the distributionof the water-yielding fractures. This information will then be used to located the fracture intervals to be isolated with packers. The specific capacity tests, and groundwater sampling will then be performed in the packed intervals. It is assumed that five intervals will be packed off in the wells to be tested. For the purpose of this Work Plan* it is assumed that the deepest monitor well will be installed to a depth of 150 feet. In the event that contamination is anticipated to be found below this depth during testing and sampling of the existing wells, deeper monitor wells may be needed to adequately define the vertical contaminant distribution.

101

AR30Q72I TABLE 10-8 ;; Phase 3 Groundwater Sampling Program

Total Number Chemical Analysis** Sample Location Number of wells of Samples

Konitor Wells* 3? 3* Table 11-4 VOCs

AEL Recovery Wells 4 4 Table 11-4 VOCs AEL Production Well 1 1 Table 11-4 VOCs R C B Production Wells 3 3 Table 11-4 VOCs New Yorker Steel Boiler 1 1 Table 11-4 VOCs ' Production Well . . • NWWA Well NW-16 1 1 Table 11-4 VOCs NPWA Well NP-21 . 1 1 Table 11-4 VOCs Private Wells 20 20 Table 11-4 VOCs .» ' '.'"''"••' •' ' ' ' , •* 68 68 Table 11-4 VOCs Totals ,

* 4-AEL "A Series" wells; 14-AEL "W Series* wellst 4-Fowertest wells; 6-Phase 2 wells; and 9-Phaee 3 newly installed wells. ** Table 11-4 compounds analyzed by CLP methodology.

AR300722 The depths of the wells proposed in Table 10-7 are estimates based on available data on depth to groundwater in Area 5. Existing data indicates considerable variability in water levels irt wells ? "" AEL, with wells W-6 (total depth 36 feet) and W-13 (total depth 47 feet) periodically reportedly going dry. As a result, the well depths are proposed to be adequate to account for these fluctuations. Monitor Well Construction At the locations of deep bedrock wells, a 10-inch diameter bore hole will be drilled to a depth of 5 feet into bedrock (to an estimated depth of 15 feet) and a 6-inch steel surface casing will be grouted into the depth of the hole. This casing will be pressure grouted into place and allowed to set for 24 hours prior to additional . drilling. A 6 inch diameter borehole will then be drilled to the specified depth; using air rotary drilling methods to niinirnize the introduction of fluids with possible contaminants into the boring during drilling. If is determined that straddle packer testing and/or bore hole geophysics are warranted" they will be performed at this time. Each well will be completed with 30 feet of 2-inch diameter PVC screen and sufficient PVC casing to the surface, Centralizers will be used to center the well in the borehole. , A sand pack will be placed to a height of 2 feet of bentonite placed on top of the sand. The remainder of the annulus will be tremie grouted with a cement-bentonite mix. The well will be finished at the surface with a steel security casing and locking cap. , At the locations of the shallow bedrock wells a 10-inch diameter borehole will be drilled to a depth of 5 feet into competent bedrock. The remainder of the borehole will consist of a 6 inch open borehole to a depth of approximately 40 feet. Each well will be completed with 6 inch locking steel casing grouted from competent rock to the ground surface. - "','•••:.•'••.••••"' • • . . '"' 10.3.7 Surface-Water and Sediment Investigations r .•'•':'••.,'• ''.'-. ' . i '; Limited information is currently available concerning the potential effects the presence of contamination at North Penn Area 5 has had on area surface water bodies. During this task the surface water runoff flow paths and potential groundwater discharge zones will be identified for the area. Upon identification of potential receptors, a limited surface water and sediment sampling program will be conducted. The purpose of this investigation is to determine if any Area 5 sources of contamination have adversely affected area surface water bodies. •''.".'• • ~. '• .. i •'••'.••'. .. • 10.3.7.1 Surface-Water Runoff Flow Paths and Surface Water Bodies Local municipalities and current facility owners will be contacted to obtain stormwater drainage patterns, stormwater and sanitary sewer plans. This information will be supplemented by a visual inspection of area sewer line and observed runoff patterns. The majority of the area is drained by stormwater sewers that discharge to local natural drainage ways. Most surface runoff appears to be directed to the West Branch of Neshaminy Creek and its tributaries. The locations of surface runoff and potential groundwater discharge to the base flow of the creek will be identified to develop the surface water and sediment sampling program.

103

AR300723 10.3.7.2 Surface-Water and Sediment Sampling The objective of the sampling program will be to define background surface water and sediment conditions and to determine if the contaminants present in North Penn Area 5 have affected local surface water and sediments. Figure 10-8 presents the proposed locations for surface water and sediment sampling in Area 5. The proposed locations are .estimated based upon existing data and estimated runoff drainage patterns. These locations will be adjusted as necessary based upon the findings of the previous task. A total of 11 sample locations are presented in Figure 10-8. An additional 4 sample locations are included in the proposed sampling program for individual, runoff drainage locations expected to be identified at additional Area 5 facilities. Table 10-9 summarizes the proposed sampling program to be conducted for the surface water and sediments characterization. One round of sampling is proposed. If the results of the first round indicate surface water of sediment contamination, additional selected surface water and sediment samples will be collected from * the specific areas effected during a second round of sampling. ' • . Samples from the Stabiius and AEL sewers will also be obtained to assess the potential for TCE contamination from these sources. It is assumed that, between the two facilities, four samples will be obtained. Samples will be analyzed for the TCL, VOCs utilizing CLP Methods. Surface-water and sediment sampling locations will be co-locations. If the stream is found to be dry during a scheduled sampling visit, the visit will be postponed until the requked samples can be obtained. A number of analyses will be performed to provide information for the Envkonmental Assessment. These analyses include both chemical and physical parameters. Table 10-9 summarizes the analyses to be performed on surface water and sediment samples. Temperature, dissolved oxygen, SPCD, pH, and specific conductance will be measured in the field during sampling. More detailed information on DQO elements for the surface water and sediment sampling such as sample collection, handling, and analysis, including the need for duplicate and QC samples and analytical methods and detection limits, will be supplied in the SAP.. 10.3.8 Quality Assurance/Quality Control In order to produce reliable and valid data, a Quality Assurance/Quality Control program (QA/QC) will be instituted during all sampling activities. The QA/QC guidelines will conform with the level of data validation being instituted for sample analysis. The field sampling program will include decontamination procedures, custody seals and collection of QA/QC samples. The analytical QA/QC program will include collection of trip blanks, equipment rinse blanks, field duplicates and matrix spikes and duplicates. Precision refers to the reproducibility of a method when it is repeated on a duplicate sample under controlled conditions. Equipment rinse blanks evaluate the potential for cross contamination of sample collection due to residual contamination not removed during decontamination procedures. The trip blank evaluates the potential for contamination due to contaminants encountered during transport of the sample containers to and from the site.

104

AR30072U AR300725 TABLE 10-0 $urf«ce Water. Sediment and Sewer Sairpllng Prog-aa

Kmtoer Location Kedls of Samples Cheated Analysis

Western tributary Surface water 4 Table 11-4 VOCt, TOC, TSS, and AEL drainage alkalinity, and hardness ditch ' 1 . ' • Table 11-4 metals « SVOCi •'••''. Sedinent 4 Table 11-* VOCt and TOC x 1 Table 11-4 Betals , eastern Tributary Surface water 2 . Table 11-A VOCs, TOC, TSS, and Vebcfaft . . alkalinity, and hardness drainage ditch 1 Table 11-* metals * SVOCs . sedloent Z Table 11-* VOC* and TOC 1 Table 11-4 metals fastern Tributary Surface water 3 Table 11-4 VOCs, TOC, TSS, •and Eyers Choice alkalinity, and hardness drainage ditch 1 Table 11*4 metals » SVOCs Sediment S Table 11-4 VOCs and TOC 1 Table 11-4 metal* Vest Branch of Surface water 6 Table 11-4 VOCs, TOC, TSS, Keshaminy Creek alkalinity, and hardness 1 Table 11-4 MtaU « SVOCt Sedlnent 6 lable 11-4 VOCs and TOC 1 Table 11*4 netals ' . . ' • ; . • " - \ Sewers Water . 4 Table 11-4 VOCs, TOC, TSS, alkalinity, and hardness 1 Table 11-4 Ktals « SVOCS

Additional locations Water 4 .alkalinityTable 11-4 ,VOCs and, hardnes TOC, TSSs , 1 Table 11-4 netals * SVOCs Totals Surface water and 23 Table 11-4 VOCs, TOC, TSS, water alkalinity, and hardness 6 Table 11-4 netals « SVOCs Sedloent IS Table 11-4 VOCs and TOC 4 Table 11-4 tetaU .

AR300726 Table 10-10 presents the typical QA/QC program to be instituted during collection of various media samples. A complete description of the sampling methods and QA/QC procedures will be presented in the SAP and QAPP. ' In addition, 10% of the samples collected are anticipated to be collected as split samples with EPA for analysis. 10.3.9 Data Validation The data collected during field investigations will be validated and summarized in accordance with the EPA Functional Guidelines before they are interpreted by project staff. During validation, any data that should be qualified will be flagged with the appropriate symbol. Results for field blanks and field duplicates will be reviewed and the data will be further qualified if necessary. Finally, the data set as a whole will be examined for consistency, anomalous results, and reasonableness. A data validation report will be submitted to the CRL and the RPM. 10.3.10 Assessment of Risk EPA will conduct an assessment to estimate the risk or potential threat to public health, welfare, and the environment under the no-action alternative. The information on land use, demography, and natural resources needed to perform this assessment will also be collected. It is anticipated that the risk assessment will be consistent with EPA methods for estimating the health risks of envkonmental contaminants, the most recent available version of the Risk Assessment Guidance for Superfund, (U.S. EPA, 1939d) and Guidelines for Exposure Assessment, (1991). Offir of Emergency Remedial Response guidelines for Superfund public health evaluations, and Office Waste Programs Enforcement guidelines for endangerment assessments. The results of the assessment will be included as a chapter in the RI Report. The approach to conducting the risk assessment was discussed fully in Section 7. The risk assessment will be conducted by EPA utilizing the validated data generated during the RI and concurrent with FS activities: 10.3.11 RI Derived Waste Disposal Wastes derived from the RI field tasks will include: drill cuttings from monitoring well installation; water produced from equipment decontamination, well development, groundwater sampling, and aquifer testing.

107

AR30Q727 TABLE 10-10 SUMMARY OF Q.A/QC PROGRAM '

Chemical Analysis Sample Type Frequency . Table 11-3 VOCs Duplicates 1/10 samples Equipment blank 1 pec day Field blank 1 per day

'*''.- ' ' • i '•

Table 11-4 VOCe DuplicateEquipments blan k 1/11 pe0r dasampley s Ffelef blank 1 per day . - KS/KSTrip DBlan k 1/21 pe0r samplecoolers per week

• • .1 ' ' Y • • • ; ' '....'./ . ' . . • . • ' Table 11-4 SVOCs EquipmenDuplicatet blans k 1 1/1per0 da sampley s Flela blank 1 per day KS/KSD 1/20 samples per week

Table 11-4 Ketals Duplicates 1/10 samples and inorganics EquipmenField blant blank k 1 per day , KS/KSD 1/20 samples per week

IDS AR300728 Significant quantities of cuttings will be generated as the monitoring, wells are installed. All cuttings will be monitored with an HNU. If reading above background are measured, those cuttings will drummed and stored in a secure storage, area to await removal by a subcontractor; storage of s material must comply with RCRA requkements. One sample from each drum will be tested for RCRA Characteristics to evaluate the waste disposal requkements of the material. Most of the cuttings will be derived from solid rock that has not been exposed to any potential contamination and; as a result, are unlikely to be contaminated. All water generated during equipment decontamination, well development, and aquifer testing will be disposed at a sanitary sewer inlet for treatment at the local publicly owned treatment works (POTW). The permission of the POTW operator will be requked for this discharge. .'•.,. ' ' , ' Y' ' . . .V • •'.'.-. • ' The driller will be responsible for transporting to the sewer inlet all water associated with drilling. All water pumped during groundwater sampling of monitoring wells will be contained in a small tanker truck and transported to a sanitary sewer. All groundwater .pumped during sampling of NPWA, NWWA, and private wells will be disposed of either on the ground or at other routinely used locations, such as a sanitary sewer or storage tank. Handling of purge water from NPWA and private wells in this manner is justified as this is the normal handling routine. Drilling equipment decontamination will typically consist of high-pressure steam cleaning. An area will be designated at the site for this purpose and suitable runoff control measures will be implemented. 10.4 Remedial Investigation Report Upon completion of the RI, a report will be prepared describing the investigation activities and presenting the data obtained. This report will be prepared in accordance with the Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA (U.S. EPA, 1988a) and in accordance with the provisions of me administrative order for performance of the RI/FS. The report will be submitted to EPA Region UJ for approval in accordance with the provisions of the administrative order. This RI report will be based upon data obtained during the field program as well as data from previous investigations. The report will contain all chemical and geotechnical data generated during me RI program. 10.5 Feasibility Study Concurrent with the RI, Earth Technology will conduct a comprehensive feasibility study (FS) at North Penn Area 5 in accordance with the current Superfund Amendments and Reauthorization Act (SARA) guidelines. The FS will utilize background information and the data generated during the . RI to evaluate various remedial alternatives and identify those that provide the most appropriate, cost- effective solutions for site remediation. In accordance with SARA, remedial alternatives that reduce the toxicity, mobility, or volume of wastes and contaminated materials will be emphasized. The FS will be conducted in accordance with "Guidance of Conducting RI and FS under CERCLA October 1988 and the Natural Contingency Plan (1988)". The following provides a description of the basic tasks involved with conducting the FS.

109

.A R 3 00 7 2.9 10.5.1 Remedial Action Alternatives Screening The initial stages of the FS process will involve identification of the remedial technologies best suited for further consideration in developing remedial alternatives for the North,Penn Area 5 site. The focus of the screening process is to eliminate technologies that are not feasible, based on information obtained in the RI, because they may prove difficult to implement or have severe limitations that would prevent achievement of remedial objectives. The technologies will be evaluated according to thek effectiveness and implementability in relation to site and waste characteristics. The effectiveness evaluation will focus on the technology's stage of development and performance. The implementability evaluation will focus on technical and institutional concerns. Finally, in the screening'process, the costs of implementing a particular technology will be discussed on a relative basis. Based on these considerations, a recommendation will be made to retain or eliminate the technology from further consideration. 10.5.2 Development of Alternatives Technologies retained for further consideration in the screening stage will be combined to form a range Of Site-wide remedial alternatives for the North Penn Area S site. According to SARA, the following alternatives should be developed to the extent possible: o a number of treatment alternatives ranging from one that would eliminate or minimize to the extent feasible the need for long-term management (including monitoring) at a site to one that would use treatment as a primary component of an alternative to address the principal threats at the site; ' o one or more alternatives that involve containment of waste with little or no treatment but protect human health and the envkonment by preventing potential exposure and/or reducing mobility of contaminants; and o a no action alternative. If a full range of alternatives is not developed, the specific reason for doing so will be briefly discussed in the FS. Depending on the number of alternatives developed, additional screening may or may not take place. For instance, if a large number of alternatives are developed, they may be screened on the basis of effectiveness, implementability, and relative cost considerations to reduce the number of alternatives that will be analyzed in detail. If the number of developed alternatives is not large/this screening effort may be eliminated and all the developed alternatives will be subjected to a detailed evaluation.

110

AR300730 10.5.3 Detailed Analysis of Alternatives '•• . • • ' . Y •. • ' • •. • • -, . Alternatives developed for •detailed evaluation will be analyzed based on the following criteria: o compliance with ARARs; .o short-term effectiveness; o long-term effectiveness and permanence; o overall protection of human health and the environment; o reduction of toxicity, mobility, and volume of contaminants; o implementability; and o cost. 10.5.3.1 Compliance With ARARs This criteria is used to determine how each alternative complies with applicable regulations and the action levels determined in the Public Health Evaluation (PHE). The chemical, location, and action- specific requkements will be discussed along with any other appropriate criteria, advisories, and guidances as they apply to each alternative. 10.5.3.2 Short-Term Effectiveness This evaluation criterion involves investigation of the effects of the alternative during construction and implementation;. Items of concern are the protection of the community and the workers during implementation of remedial measures, potential envkonmental impacts, and the time requked to achieve remedial response objectives. , .. 10.5.3.3 Long-Term Effectiveness and Permanence This' evaluation criterion involves consideration of the risks that remain after the site has been cleaned up to acceptable levels as indicated in the remedial response objectives. Items of concern are the presence of any receptors near the site, the magnitude of the remaining risk from untreated waste or treatment residuals, the adequacy of controls that are used to manage treatment residuals or untreated waste, and the reliability of these controls. 10.5.3.4 Overall Protection of Human Health and the Environment This evaluation criterion provides a final check to assess whether each alternative provides adequate protection of human health and the envkonment. The overall assessment of protection draws on the assessments conducted under other evaluation criteria, especially long-term effectiveness and permanence, short-term effectiveness, and compliance with ARARs. The evaluation of the overall protectiveness of an alternative will focus on whether a specific ' alternative achieves adequate protection and will describe how site risks posed through each pathway addressed by the FS are eliminated, reduced, or controlled through treatment, engineering, or institutional controls.

Ill

AR30073I 10.5.3.5 Reduction of Toxicity, Mobility, and Volume of Contaminants Consideration of this evaluation criterion is a result of recent statutory preference for selecting remedial actions that permanently and significantly reduce the toxicity, mobility, and volume of the contaminants and associated media, The following factors will be considered in this evaluation: • o the treatment process and materials they will treat; o the amount of hazardous materials that will be treated; . o the degree of reduction in toxicity, mobility, or volume expected; o the degree to which treatment will be irreversible; and o the type and quantity of materials that remain after remediation. 10.5.3.6 Implementability . . •' - . . ' ''.' •''.'; . ' i . V " This criterion establishes the technical and administrative feasibility of implementing an alternative. Technical aspects evaluated for each alternative include construction and operation activities, reliability of the technologies involved, ease of undertaking additional remedial action, , and monitoring requkements after completion of activities. Administrative concerns include establishing contact with appropriate agencies to implement remedial actions (e.g., obtaining permits for construction and operation of a treatment unit). Availability of materials and equipment needed is another factor that will be considered when evaluating the implementability of an alternative. 10.5.3.• 7 ' Cost . - - - --.- ••-•:•-. •-.- . ••• • : : /• .- . :, . :-. . A remedial cleanup program must be implemented and operated in a cost-effective manner and must mitigate environmental and human health concerns at the site. In considering the cost effectiveness of the various alternatives, the following categories are evaluated: capital costs, operating and maintenance costs, and monitoring costs. The present worth value will be used as the method to evaluate total costs of the remedial alternatives, using an appropriate discount factor. The cost effectiveness of the various alternatives will be compared on a total present worth cost basis. 10.5.4 Summary Comparison and Recommendation of Remedial Alternatives : •• • • • ' ' - i Once the developed alternatives have been subjected to a detailed analysis, they will be summarized and compared with respect to the evaluation criteria. From this comparison, an alternative will be chosen as the recommended alternative for implementation at the North Perm Area 5 site.

112

AR300732 10.5.5 Feasibility Study Report : ' ' ••• Y .."•'• '•-•'','• . ••'.'• ' •..•;."• .'•'''.-. .'. . This task will include the preparation of a draft, a draft final, and a final FS document, including recommendation of the alternative for implementation. The draft report will be prepared for review by the facilities. A draft final report will be prepared incorporating the facility comments for review by the appropriate federal, state, and local regulatory agencies. The findings of the draft final FS report will be presented at one public meeting held during the three-week period of public review and comment. Following the public meeting, the final FS report will be prepared to incorporate comments from the facilities and involved federal, state, and local regulatory agencies in addition to items discussed at the public meeting. The FS report will include an executive summary, introduction, identification and screening of alternatives, development,. and screening of alternatives, detailed analysis of alternatives, and recommended alternative.

AR3Q0733 Section 11 SCHEDULE

The estimated schedule for completion of the RI/FS as presented in this work plan is illustrated on the Gantt Chart included as Figure 11-1. The schedule presented does not account for document review time periods by EPA. An assumed analytical laboratory turnaround time of four (4) weeks is included for all laboratory analysis. This schedule also assumes the groundwater investigations will be limited to three (3) phases. The overall schedule for completion of the RI/FS is estimated at fifteen months.

114

AR300731* o 1 . . .'• : ; : - Y ;•••"•• a •&> '•'..•"•' ' Y: ^4 - m-* H .' ' ' ' " •' ' ' ' ,1 2 ; /'. : ;. ;: ; . ;•' I eo • O px-| • :-x Kf s .-• : • 1 • ' ' • • •'.-." 1 1 Y £ ;• 3 Y' ; '•••-.-' .;.-••' ,' .-•'.•; I <\ . o • , w1 • • ' § ^ l $ - 'i& JT5J CO g fe 0> I\ "^ s - yi 62 ^5 s C °o ;; |B- O ~ . 10 S f* • ^ f? < CO N 2 | gm ; :. "•-. |;;. .;':•;• -...- / .-» 1 1 : • , • ' ••' « •;.;.;• ;- •(;-. H / . .• ;; . : - • §lf % ® i ' • • ^_ N III.'' ' ' :. . •• A£*• 585 . .«; 1! •.-.-:, ." '-.•- "--;•• ;.;. • • . 2

E '' A. . • • •'•..' ' • ' '>..'. • 1

o •'" o -ft! : •••''.". . a o a3.. • £ • . «^ Cl CO 7» @ &4 ,- ' i • J

- CO CU CU CU -g 2 ft* ' JS O S S2 5 '' ' §-S S3 3§ 1E S< 9« H gl'Sir i Hi 1 1 g "' •• 1 J § g i & i III «•-« i S § 2§r INCLUD E D I" S^iHliitilliliHi f' £ 3 s " » 1 -Sr AR300735 Section 12 REFERENCES

BCM. 1980a Plan for the Installation and Operation of Groundwater Retrieval Wells in the Vicinity of North Penn Well No. 21. Prepared by Betz-Converse-Murdoch, Inc. March 24, 1980. BCM. 1980b. Interim Report-Investigation and Removal of Trichloroethylene from Groundwater at American Electronic Laboratories, Inc., Montgomeryville, Pennsylvania. Prepared by Betz-Converse- Murdoch, Inc. April 1980. . BCM•' . 1980c: . Letter from Anthon• y G. Bove, Sectio' ' n Manager, Wate' r and Wastewater, Betz-Converse- Murdoch, Inc., to Jon Carter, Manager, American Electronics Laboratories, Inc. June 25, 1980. BCM. 1980d. Progress Report, Investigation of TCE in Groundwater for AEL, Inc. July 29, 1980. BCM. 1981a. Buried Drum Investigation Report, Letter from Terrance McManus, Betz-Converse- Murdoch, Inc. to Jon Carter, Facilities Manager, American- Electronic Laboratories, Inc. January 28, 1981. ; BCM. 198 Ib. TCE Recovery Program-Progress Report No. 4. Prepared by Betz-Converse-Murdoch, Inc., for American Electronic Laboratories, Inc. April 9, 1981. BCM. 198 Ic. Hydrogeologic Investigation of TCE in Groundwater for AEL, Inc. June. ' ' ' ' • ' •-• - . ".' • - • ' • .' : BCM. 1982a. Preparedness, Prevention, and Contingency Plan for American Electronic Laboratories, Inc., Montgomeryville, Pennsylvania. August 1982. . BCM. I982b Report on Soil Decontamination for AEL. December 1982. BCM. 1985 Letter to David Everitt, Delaware River Basin Commission, from Mark A. Stevens, BCM Eastern Inc. October 15, 1985. Bionetics Corporation. 1989. Site Analysis, AEL, Colmar, Montgomery County, Pennsylvania. Prepared for U,S. EPA, Environmental Monitoring Systems Laboratory. May. CH2M HILL. 1988. Sampling and Analysis Plan, North Perm Phase I RI/FS. December 1988. CH2M HILL. 1989a. Region HI ARCS Management Plan. February 1989. CH2M HILL. 1989b. North Perm site visits. May 1989. CH2M HILL, 1989c. North Penn Site visits. February 1990.

116

AR300736 Longwill, Stanley M. and Charles^ R. Wood. 1965. Groundwater Resources of the Brunswick Formation in Montgomery and Bucks Counties, Pennsylvania. Pennsylvania Geol. Surv. Water Resources Report 22. ' • Musheno, Michael. 1980a. Letter to file on the U.S. EPA Lansdale Groundwater Contamination Investigation. March 10, 1980. Musheno, Michael. 1980b. Letter to file on the U.S. EPA Lansdale Groundwater Contamination Investigation. March 10, 1980. * . / Musheno, Michael. 1980c. Letter to file on the U.S. EPA Lansdale Groundwater Contamination Investigation. March 10, 1980. , , Newport, Thomas G. 1971. Groundwater Resources of Montgomery County, Pennsylvania. Pennsylvania Geol Surv. Water Resources Report 29. Y NPWA. 1985. Quality Assurance Manual. North Penn Water Authority. NUS. 1986a. Site Discovery of Groundwater Contamination in the North Perm Area. NUS Corporation. July 7, 1986 NUS. 1986b. A Hazard Ranking System for AEL, Inc. October 10, 1986. PADER.. 1981. Press release on the Consent Agreement between AEL and the Pennsylvania Department of Erivkonmental Resources. April 13, 1981. Rima, D.R., Harold Meisher, and S.M. Longwill. 1962. Geology and Hydrology of the Stockton Formation in Southeastern Pennsylvania. Pennsylvania Geol. Surv., 4th Series, Bull. W-14, 111 p. SCS. 1986. Condensed Soil Survey, Montgomery County, Pennsylvania. U.S. Soil Conservation Service/June. ' SMC-Martin, 1983. A Hydrogeologic Evaluation of North Penn Water Authority Well No. 61. Prepared for NorthYPenn Water Authority. December 1983. TechLaw, Inc. 1987. Final Facility Report, North Penn Area, AEL, Inc. November 12, 1987. TSD. 1988. Report of Groundwater Monitoring and Remediation of AEL, Inc., 24-Month Progress Report. March 1988. . , TSD. 1989. Groundwater Monitoring and Remediation: 36- Month Progress Report. v TSD Environmental Services, Inc. May 1989. '•'••:"' U.S. EPA. 1980. Interim Guidelines and Specifications for Preparing Quality Assurance Project Plans. U.S. EPA. 1986. Guidelines for Estimating Exposures. 51 Federal Register 34042. September 24, 1986.

AR300737 U.S. EPA. 1987a. Data Quality Objectives for Remedial Response Activities. OSWER Dkective 9335.0-7B. March 1987. ' - •' ' - :'Y. Y - - •' ' -' '- U.S. EPA. 1987b. Health Advisories for 25 Organics. March 1987. U.S. EPA. 1987c. Compendium of Superfund Field Operations Methods. OSWER Dkective 9335.0- 14. September 1987. • • ; • U.S. EPA. 1988a. Guidance of Conducting Remedial Investigations and Feasibility Studies Under CERCLA. October. U.S. EPA. 1988b. Laboratory Data Validation Functional Guidelines for Evaluating Organics Analyses. U.S. EPA. 1988c. Region m Modifications to the Organic Functional Guidelines. U.S. EPA.. 1988d. Laboratory Data Validation.Functional Guidelines. U.S. EPA. 1988e. Region in Modifications to the Organic Functional Guidelines. U.S. EPA. 1988f. Users Guide to the Contract Laboratory Program. U.S. EPA. 1988g. National Contingency Plan. U.S. EPA. 1989a. Integrated Risk Information System.June 1, 1989. U.S. EPA. 1989b. Review of Facility Search of Zone of Contamination 5. June 15, 1989. U.S. EPA. 1989c. QAPJP Workshop Participant Handbook. , U.S. EPA. 1989d. Interim Final, Risk Assessment Guidance for Superfund, Volume 1, Human Health Evaluation Manual, Part A. OERR, EPA/5401/1-90/002. December 1989. \ • " • - . , . U.S. EPA. 1990. Personal telephone communication with Ray Schrock, U.S. EPA. August 7, 1990.

--'. ' ' - ' •«..•'- Versar, Inc. 1988. Technical Evaluation of Zone of Contamination 5. Prepared for U.S. EPA, Office of Waste Programs Enforcement. September 14, 1988. Berg, TM et al. Geologic Map of Pennsylvania. Pennsylvania Topographic and Geological Survey Map 1, 1980. . Longwill, Stanley M and Charles R. Wood. Ground-Water Resources of the Brunswick Formation in Montgomery and Berks County, Pennsylvania. Pennsylvania Topographic and Geological Survey Ground Water Report W-22,1965. SMC Martin Inc. A Hydrogeologic Evaluation of North Perm Water Authority Well #61,1982.

118 •'

AR300738 Soil Conservation Service. Condensed Soil Survey Montgomery County Pennsylvania. United States Department of Agriculture, 1986. • " •'•••" Y . ' ' ' •',••.•" '--. ' ---- . •''.'.' '• ' '•• ' •'• :' •' • ' ' " Soil Conservation Service. Soil Survey of Bucks and Philadelphia Counties, Pennsylvania. United States Department of Agriculture, 1975. Van Diver, Bradford B. Roadside Geology of Pennsylvania. Mountain Press Publishing Company, 1990. Willard at al. Geology and Mineral Resources of Bucks County, Pennsylvania. Pennsylvania, Topographic, and Geological Survey County Report C9, 1959. -..'.-••• »- • - . • • . • CH2M HILL. North Penn Area 5 Draft Phase n RI/FS Work Plan, Work Assignment No. 01- 3LW6,0, Contract No. 68-W8-0090, August 1990. Merritt/Osboum, Inc. Envkonmental Survey, BBC Brown Boveri, Inc. Chalfont Switchgear Plant, July 29, 1985. Melick-Tully Environmental, Inc., Report Environmental Testing Services, Proposed Building Addition, AEL Defense Corporation, March 26, 1992.

. • ' • . ' . ... ' r 119

AR300739