£1160

UNITED STATES ENVIRONMENTAL PROTECTION AGENCYREGION Hi

841 Chestnut BuildingPhiladelphia, Pennsylvania 19107

Mr. Bonald PuttCryoChem, Inc.E.D. *2, Box 74-ARTE 562Boyeriown, PA 13M2

JAN 181990

Dear Mr. Putt:

The Environmental Protection Agency (EPA) has completed itsreview of the Draft Bemedial Investigation (PI) Report for theCryoChem Superfund Site, The documents were prepared by JACACorporation and are dated November 22, 1989. Based upon a numberof deficiencies and a general lack of justification for many ofthe Report's conclusions, SPA has decided to disapprove the RIReport. EPA's comments and rationale are itemised in theattachment to this letter.

Although the number of comments is large, EPA believes thatsufficient environmental data was collected during the RI toenable JACA to adequately evaluate potential remedialalternatives for the site during the FS stage. Thus, additionalfield effort to fully define the extent and magnitude ofcontamination at the site may not be needed at this time, eventhough the plume in the ground water or the magnitude of soilcontamination arc not fully defined. However, EPA believes thatsome of the conclusions made in the El Report are not wellsubstantiated by. information collected during the RI. As aresult, the majority of EPA's comments request clarification,justification or substantiation of specific issues. EPA alsobelieves that, the information and assessments provided within theRI Report may rrot be sufficient to fully support the design ofcertain remedial options which may be applicable to the site.Thus, additional design-related studies may be needed.

Ronald Putt^ * a

One of the major deficiencies identified in the RI Reportconcerns the lack of an adequate risk assessment. The riskassessment does not include an estimate or calculation of therisk posed by the site to various receptors. Without a full riskassessment, EPA can not evaluate the need for remedial action forspecific contaminated media at the CryoChem site.

One of the RI Report's biggest shortcomings relates to anobvious lack of technical review before submission to EPA. TheReport contains a significant number of inconsistencies anddiscrepancies. The reader is continually double checking numbersand figures to reassure themself that what they are reviewing isindeed accurately stated. The entire RI Report must be proofreadand reviewed for consistency and quality before resubmission toEPA. The attached comments identify several of the problemareas,

JACA should begin immediately to revise the RI Report and toaddress the issues raised in the attached package of comments.The comments are intended to assist JACA in their revision of theRI Report. I will be available for consultation on specificissues. If needed, a meeting may be arranged between EPA andPFPs.

Sincerely,

Michael Towle,Remedial Project Manager

cc: A. GrayE. Nishitani

AR301570

ATTACHMKNT

GENERAL COMMKNTS ON CRYOCHKM RI REPORT

1. Include a list of APPENDICES in the Table of Contents.

2. The HSL has changed to the "TCL/TAL". Include and define HSLin the glossary.

3. Conclusory statements must be supported by data collectedduring the Remedial Investigation. Several of the conclusorystatements in the RI Report are not substantiated by datacollected during the RI.

4. Many of the risks potentially posed by the site and many ofthe site features are described as "significant" or"insignificant" without adequate justification. These statementsas they appear throughout the document need to be substantiated.Please e.l aborate . Examples include :

A. (1-3, par 3) "significant" health risk.B. (5-17, par 1 and 2) "significant" and "insignificant"

levels, sources and concentrations.

5, Portions of the text are not properly referenced on thefigures and vice versa. Some features are not identified on anyfigure. Review document and revise appropriate text. Examplesiunclude:

A. (3-1, par 2) The fish pond and dam should be referencedby numbers.

B. The "small borrow pit" discussed in Section 3.2.3 shouldbe identified on a figure.

C. The "dump" along the eastern edge of the C.S. Garberproperty discussed in Section^3.2.3 should be identifiedon a figure.

6. On January 31 and February 1, 1989, PRC and JACA observed aniron pipe slowly discharging liquid into the on-site creek.Provide EPA with information concerning the origin of this pipeand the nature of the liquid(s) which discharge from it. Includea discussion a id depiction of this pipe in the RI Report.

7. Include colored pages between APPENDICES for easy location.Volume II. of the RI Report should contain a^list of APPENDICESand their contents.

8. Detection or quantitation limits should be included in alltables of analytical data in the RI Report.- **

AR301571

- !'?••- j'\-- R'i>*» ":K lV.:i,r 1 *• in=»':-?ii r^t^l y de^orIb^d as- a "closed-•'--'Sin w^pT^- f -ir--; ] i t.y. " This implies that, it was once an approvedsoJid wsst.e f'":•!] j fy . Plec-fc** revise text.

2. This section states on page (1-3) that "ground water is theenvironmental medium of concern" and "no other environmentalmedia or exposure pathways were found to represent a significanthealth risk." These conclusions are apparently based on thequalitative risk assessment and may be premature since the soilcontamination was not evaluated and risk numbers were notgenerated for any media. See comments on Risk Assessment.

3. This section states on page (1-2) that pertinent recordsconcerning the Heimbach Dump have been lost. However, A copy ofthe PADER results of sampling at the Heimbach Dump wereapparently sent to a local citizen. The citizen has indicatedthat the following organic compounds were detected: 2-propanone,2-butanone, 2-butane1, 4-methyl 2-pentenone, and 4-methyl 2-pentanol, This suggests that the Heimbach Dump is notcontributing to local ground water contamination.

4. ARARs or TBCs may also include health-based risk levelsderived from a quantitative risk assessment. Revise thediscussion as needed.

5, The Risk Assessment does not contain public health risksassociated with the contamination. Revise page 1-1.

6. The range of TCE detected in upgradient wells is incorrectlystated on page 1-3 according to data in Table 5-19.

COMMENTS ON SECTION 2 - IKTRODOGTTON

SECTION 2.1 - BACKGROUND

1. What other compounds, besides TCA, comprise the organicsolvent Chlorothene ? The text indicates that TCA is the maincomponent. Please elaborate.

2, The RI Report suggests that the use of Chlorothene between1970 and 1 82 "varied". How were welds checked prior to 19YO andhow did Chlorothene use vary ? This section should detail thisinformation. -

3. On page (2-3) change "the REM II team" to "EPAfe REM IIcontractors".

AR3Q1572

SKOTTON 2.2 - OHJKCTIVKS

1 . /JAGA rtT.flt.ft* that, one of the objectives of th«=? RI is torjetermj ne horizontal Had vertical extent of contamination in thesoils that needs to be remediated. Since the RI does notquantitatively determine risk posed by contaminated soil, thisobjective is not met. How much contamination in the soils canremain without requiring remediation ? Will existingconcentrations in soil continue to contaminate the ground water

2. The RI Report does not discuss vertical ground water flow asdetailed in the fourth bulleted objective.

COMMENTS OK SECTION 3 - BACKGROUND INFORMATION

SECTION 3.1.1 - GENERAL

1. Figure 3-1 and related text need to be revised.

A. Please depict springhouse on adjacent C.S. Garberproperty which feeds the fish pond and is referenced on page 3-1.

B. Text should reference the small dam as feature #6 and thefish pond as feature #7 on figure 3-1.

C. The stream should be identified in the legend. • " '"

D. The locations of the on-lot septic systems and productionwells should be included on a figure in this section andreferenced on the figure since they are discussed in the text.

E. The restaurant should be shown .on the figure.

F. The, 1/4 mile radius discussed in the report should be '.shown on the figure. . - ~"\v;-V ;..•'"

•- -' ' ,,.2. This section should mention that many of the homes with -- _- -,contaminated water supplies are located in Douglass Township. _.:.,

3. The RI should discuss further the on-lot septic systems. \ \;Have thesec~"systems been connected to the fabrication areas ? <s.Were they usecUfor residual waste disposal ? Were they -.- ..'"-T;7-- _.-considered or'investigated as contributing sources to the ground-,water contamination ? - - •• •'•:

ftR30i573

J1KCTION :* \ .?. - WKTi.ANVJS

1., 'TM^ $--*••-:-t, i on *h->u'M intr-lodi- ft figure del i n^at i neT wetland

2, The PI report should state who conducted the survey and theguidance that was followed.

SECTION 3.1.4 - CLIMATOLOGY

1. A reference should be given for the source of theclimatological data.

SECTION 3.1.5 - GROUND WATER CONSUMPTION

1. Page 3-3 states that the site is located in Earl Township,but page 3-5 discusses the residents of Worman. The RI Reportneeds to clearly and consistently identify villages, towns, etc

2. A reference is needed for household and business waterconsumption. Or, the Report should discuss how the consumptionnumbers were generated.

3. This section discusses production wells which are not clearlyidentified on a figure. Depict all wells discussed on a figure.

4. This section should discuss ground water consumption and us<at the mobil station.

SECTION 3.2.1 - PREVIOUS LAND USE

1, The junkyards near the site should be discussed in Section3.2.1 Previous Land Uses. The various -pits and "dumps" near oron "the site should also be discussed,

SECTION 3.2.2 - PREVIOUS INVESTIGATIONS ^

1. This section should summarise previous sampling locationsresults of sampling. Summary tables and figures would be useful. /;]jj3Sj:»_-,

PiZzf S."

SECTION 3,2.3 - POTENTIAL SOURCE AREAS (PEPS)

1. The terms "PRP" and "Potential Source Area" are notinterchangeable. This section should be revised.

2. The discussion of CryoChem Inc. should not be included insection 3.2,3 since it has been shown to be a source area and nota potential source area. *" >---

B. A copy of the "lost.11 analytical results are in thepossession of a local resident. The chemicals reportedlydiscovered by PAPER at the Heimbach Dump do not include TCA, DCA,TOE, DCE or FOE. This section should state this.

C. This section should state or infer the source ofinformation suggesting that the dump is filled with auto partsfrom a previous repair shop,

4. BOYERTQWN SCRAP

A. The contents of some of the drums removed from theBoyertown Scrap location were analysed by EPA. The resultsindicate that the drums contained at leaet the following:

Ethyl benzeneTolueneMethylene ChlorideIsophoroneNapthaleneXyleneAJkyl benzenescomplex hydrocarbons

B. According to EPA records, soil beneath the drums removedfrom the Boyertown Scrap locations was stained and contaminated.

C. During the removal of drums from-the Boyertown Scraplocation, EPA learned that an estimated 100 additional drums mayhave been buried at the site. According to a local resident whoobtained information from a former employee of the scrapoperation, the suspected location of drum burial was beneath atire pile which existed on the site in 1984. The tire pile waslocated on property adjacent to the Boyertown Scrap propertynorth of the .-current ISG building. In 1984, EPA investigated thearea of the-tire pile and determined that the area may have beenthe site of'buried material since the area was slightlydepressed. '

D. In 1984, ground water samples were collected from nearbywells. The results do not suggest that the drums contaminatedthe ground water.

, C1

E. The source of information indicating that Kowecki ChemicalCompany contracted Boyertown Scrap to dispose chemicals needs tpbe referenced or inferred. ' "

AR30I575

A. Thi* section should indicate whr> suspects that C.S. Garberproperty has contributed to ground water contamination andprovide background information to support this.

R, The "dump" located along the east side of the propertyohou1d be located on a figure.

6. TFEXLKF PROPERTY

A. Please make it clear that, this property is referred to as"Former Refinisher" on Figure 3-1.

7, FANCYVALK MOBIL

A. The gasoline station discussed on page 3-11 was at thecorner of Route 562 and Sunrise Lane prior to 1970. The buildingexists on June 27, 1964 aerial photography. Bevise the text,

8. The location of the former furniture manufacturer on the ,CryoChem property should also be identified on Figure 3-1. ..

AR30I576

r>K<T.n cm/,. (> .-..PHYSICAL .CJHAKA.CTKSJ^TICH QK THK .STUDY

SECTION 4.1 - TOPOGRAPHY

1. According to the U3GS 7.b minute map, and RI Figure 2-2,Fancy Hill is not located northeast of CryoChem as stated in thissection.

2. Fancy Hill should be labelled on a figure in this section orthe reader should be referred to figure 2-2.

SECTION 4.2.2 - SITE GEOLOGY

1. (Figure 4-1) LEGEND:

A. The legend contains a symbol for the orientation ofvertical joints, but the RI Report states that joints dip 60 to75 degrees, The symbol is incorrect,

B. The symbol for a thrust fault is not the same as thedelineation used in the figure. The symbol is incorrect.

C. Fracture traces should be "inferred".

2. The configuration of the streams near the fish hatchery isnot the same as the configuration depicted on figure 5-3 (Streamand Sediment Sampling Locations). One of the figures isincorrect. This applies to earlier figures as well.

3, The first full paragraph on page 4-4 needs to be revised.The thrust contact between the Hardyston and LeithsvilleFormations occurs both north and south of the CryoChemmanufacturing building. The Leithsville Formation is not coveredby the Hardyston Formation on the southern and northern portionsof the CryoChem property. Please clarify this discussion.

4. On page 4-6, a small depression within a stream near the siteis discussed,- This feature should be located on figure 4-1.

5. A geologic cross section would be helpful.

SECTION 4.2.2.2 - SOIL

1. The terms soil and overburden are incorrectly interchangedwithin this section especially in the discussion of residentialwelJ casing on page 4 - 8 , '

A R 3 Q I 5 7 7

A, Well location #5 (5S and 5D) should be depicted on the"Monitor Wel 3 Location" figure .

B. Well 4S is incorrectly labelled 45 .

3. Well QH-1 is not defined in this section. The well log, ifavailable, should be provided. When was this well installed ?why ? who ?

SKCTION 4.3.1 - HYDROLOGY INTRODUCTION

1 . The RI h'r-fp rt states that the connection between the soil andbedrock ground water is sporadic and semi-confining. JACA needsto desribe how it made this conclusion and provide supportingevidence.

2. This section states that once ground water enters the bedrockaquifer, the flow is controlled by fractures predominantlyoriented in s northwest-southeast direction. However, the HIreport states that very little evidence of fracture traces couldbe determined from site information. JACA must substantiate thisconclusion with site information.

SECTION 4.3.2.1 - NATURAL DRAINAGE

3. JACA should state how and when stream discharge measurementswere made. The results should be reported in a table.

SKCTION 4.3.2.2 - MA8MADE DRAINAGE PATHS

1. The HI Report states that 2 comparisons of flow rates wereconducted on the pipe which reportedly conducted TCA to thenearby stream. JACA should describe how the tests wereconducted,-how the flow rates into and out of the pipe weremeasured, and how the comparisons were made. - .:

SECTION 4,3.3 UNCONSQLIDATED GROUND WATER

1. Change the section heading since ground water can not beconsolidated or unconsolidated.

2. Please rewrite the first paragraph.* It is confusing.

RR301578

p i - " ri-"l!f-. ' s..tf,: '-•'.•i.'liti'V]:; , pl'-^t^ el:ib^r^t^ and justify withdate* I *' the :• t '-t t'. n n -^- *re r.'erier-rl oi1 theoretical, do not inferthat tht>y r^p'res^nt site conditions. Revi se as necessary.

4. This section interchanges *the terms "soil" and "unconsolidatedmaterial". These terms are not interchangeable at this site.Revise as necessary.

5, A shallow ground water flow diagram is needed. Thedistribution of shallow wells should not nullify JACA's abilityto construct such a diagram. At minimum, a diagram is neededwhich plots shallow ground water levels at locations where it wasmeasured. The statement that accurate contour maps could not beconstructed front water-level data due to the extensive aerialspread of the wells indicates that additional wells are needed toadequately define the extent of the problem at the site.

6. The fact that shallow wells which contained ground water inApril were dry in September suggests that the water table mayhave dropped more than 9.43 feet as indicated on page 4-21.

7. How was the "average gradient of the water table" determined ?An "average gradient" can not be determined using data obtainedin September from only 3 wells. The procedure for determiningthe gradient should be described and calculations provided in theRI Report.

8. Topography, soil thickness, hydraulic conductivity andbedrock surface are not variable from April to September andtherefore should not cause differences in ground water gradients.Revise statements discussing the change in gradient from April toSeptember.

9. The following statement is not justified: "Hence, the watertable gradient is greatest in the northern portion of the sitewhere the topography is steepest and the soil depth is lowest".The PI Report contains no map or supporting data. If site datado not substantiate this statement, revise accordingly.

10. Discuss .-well 5S. •

11. The following statement is not justified: "The soil/bedrockinterface appears to be a semi-confining zone which permitsground water movement between the two aquifers in some areas, butprecludes movement in other areas". This statement must eitherbe substantiated by site data or removed from the RI Report.

12. Table 4-3 and 4-4 need to contain water-level informationfrom wells which are not listed in the table (e.g. dry, notavailable, not measured, etc.)

^

AR301579

4.3 '1 - iJKOUMf) WATKR KhOW IN BKDHOCK

1. The pAt.t.ern of the temperature logs for we lift CC-2., QH-1 andHI-3D is markedly different than the pattern for wells RI-1D, RI-2D and RJ-4D. The first set of logs is rounded and the secondset of logs is stepped. Please explain. Submit raw data to EPAfor analysis.

2. The increase in temperature with depth in well CC-2 isextreme. This log requires explanation.

3. Please explain the following statement: "The ground wateryielding fracture in RI-4D at 40 feet creates a gradualtemperature increase probably due to its low yielding capacity.

PIEZOMETR1G SLOPE

1. The RI Report states that the average slopes of thepiezomet.ric surface through the CryoChem site for June andSeptember may be considered to be the minimum and maximum slopesfor the purposes of the RI, JACA should explain how it has madethis assumption.

2. The plezometric slope in the northern portion of the site issteeper than that in the southern portion of the site inSeptember only,

HYDRAULIC CONDUCTIVITY '. - ijj-

1. Table 4-7 should contain results from all zones tested. iD'-t 5

2. The RI Report should contain the pump rate for the pumpingcycles.

SECTION 4.3,4.2 - GROUND WATER FLOW - OPERATING CONDITIONS

1. The text in this section does not adequately describe the j;water level information. The graphs for each well should be ,;:'_' ",-annotated. The* text should be clarified. __.'__

2, It appears from the water level record of well CP-2 that therecovery perlqd is less than 30 minutes. It appears that thewater level has returned to pre-pumping level before the nextpumping cycle begins, thus, the well returns to static conditionsin less than 25 minutes.

AR30I580

r.KCTioN 4.;j.i ;-.

2. There is no supporting evidence for the elliptical shape ofthe radius of influence. The number, location and type ofobservation wells makes it nearly impossible to determine theshape of the radius of influence. Please justify.

3. Although the concentration of certain compounds increased at60 minutes. The concentrations of the compounds decreased after120 minutes, This information requires evaluation.

AR301581

COMHKNTS f'N r,Kt;TM)N ?* . 0 , NATURK ANI> KXTKNT OK..(1OHTAHT NATION

!>, I MAONKTOMKTHY

1. A^^oroin? to availsbJfr information it appears that JACA'sTN*£Ttetrimeter survey was performed on land adjacent to thesusp'-cte.d location of buried drums. The suspected location ofdrum burial is beneath and in the vicinity of a tire pile behindthe ISC building, JACA's magnetometer survey was conductedprimarily on property owned by R.R Garber, The survey may notmeet RI objectives stated in Section 2.3.2. Please discuss.

2, It is difficult for EPA to determine if the grid shown onfigure 5-1 extends to the suspected location of drum burial. Itappears that it does not. Expand figure 5-1, or create a newfigure, to show the entire ISC building and the property behindthe ISC building, formerly adjacent to Boyertown Scrap property,on which the existing tire pile is located. Indicate where themagnetometer survey was conducted during the RI. Indicate wherethe east edge of the R.R. Garber property is located. A figureshowing the location of the magnetometer survey relative to thesite would be useful. The scale on figure 5-1 is so large thatIt is difficult to visualise the location of the survey.

3. Text on page 5-1 states.,, "Magnetic anamolies, which aredifferences in the ambient magnetic field, can be delineated ongraphs and contour maps of measured magnetic intensities." Yet,the HI Report does not contain a contour map. The data should bepresented on a map.

4. Correlation between the data in Appendix M and the grid onfigure 5-1 is difficult. It is not clear which of the lines inAppendix M traverse the areas with steel well casings and drillrods. This is crucial for interpretation purposes. A contourmap of the data, a key to location of lines, and a description ofthe data in areas of casing and rods is needed.

5. The narrative describing the magnetometer survey is poorlydocumented. Thus, it is not clear whether the survey andinterpretation were performed correctly. The description shouldclearly indicate the orientation of the lines with respect tomagnetic north "as well as describe typical anamolies produced bysteel drums.

6, Contrary t=o conclusions drawn in this section, the data inAppendix H clearly indicates anamolies on the order of hundredsto thousands of gammas (e.g. Line 0+75: 4752 gammas) This Ischaracteristic of ferrous iron, but it is not clear where theselines are on the map. An explanation of the anamolies is needed.A contour map of the data would be useful.

7. It is unclear how the aerial photograph analysis relates tothe ma^netom^try survey. Please explain.

RR301582

!::. Tf"i-"- .r "'••-:• "i -"'I' ''ri^< r b^-r -'%::;i.'?t&.K , fl *' stated or'! pct, 1 5- 3 , is notde f i ','i'~} '--•-;• I •-><-."s ted on ^ny fi sure , F'lear;e del i neat.e thisproper* y . Kow i;:? t.h'i:;; ^r^p different th-vn "C . S . Garber" .

5.2.1 SOIL, GAS SURVEY

1, Exhibits ] and 2 need north arrows.

2. Table 5-1 does not contain background data for the Trexlerproperty. Provide this data or discuss its absence from the RIReport,,

3. This section should include a discussion of how the data were"corrected".

4, This section should discuss why signifiacnt VOCs were notdetected in some locations which exhibited high soil gasreadings.

SUMMARY OF EPA SURFACE SOIL SPLIT SAMPLING - ORGANICS

SAMPLE IDENTIFICATIONJACAEPA

COMPOUND

ACETONETOLUENE2-BUTANONE1,1,1 TCA1,1 DCATOTAL XYLENES2-METHYLNAPTH.PCB 12604,4' DDTUNKNOWN #UNKNOWN* #HYDROCARBON- 4tAROMATIC #

#4SS-1

164( J )

.

- 3127

*-*•

#4 #17SS-1D SS-2

CONCENTRATION

3124

3400(B)820040001800013000(J)160(J)

3 101181

#11 #5SS-3 SS-4

(UG/KG)

17 5900CB)

16 3400(B)

36

* unknown compounds determined after extractiontt totaJ. number of compounds detected

&R3Q1583

i-UfMMAUY OK KVA iUJRKAfK £OI}> SPMT SAMPMN<3 - I NOW5AN

SAHHKK JDKNTJ&'ICATIONJACA iM #4 #17 #11 #f>KPA S3S-1 SS-ID SS2 SS3 SS4

ANALYTK"~"~ CONCENTRATIONALUMINUMARSENICBARIUMBERYLLIUMCADMIUMCALCIUMCHROMIUMCOBALTCOPPERIRONLEADMAGNESIUMMANGANESEMERCURYNICKELPOTASSIUMSELENIUMSODIUMVANADIUMZINC

2190036.61863.4

268020(K)

12.6(B)20.42010040.7446(B)2720(K)0.922.31020(B)

163032.282.1(J)

1170029.51032.1

194015(K)8.3(B)7.9(B)

1310042.9273(B)1450(K)0.912.9618(B)

128017.850.1(J)

80209.37061 . 2(B)2.49310164(K)

11 .2(B)42.81230011626901130CK)0.71071120(B)

163011.5(B)1990CJ)

18700481511 . 2(B)

332024.8(K)22.623

2040021.73730860(K)1.218.91310(B)

180036.757.8(J)

3330024.61351.43.9320043(K)

13.721.53410033.73350640(K)0.920.1752(B)KB)

121065123(J)

SECTION 5.2.2 - SURFACE SOIL

1. Table 5-2 lists parameters analysed in residential wells.This table does not belong in Section 5.2.2 since surface soilsamples were not analysed for semivolatile organic compounds.Table 5-2 is therefore misleading. Remove this table and itsreference from Section 5.2.2. Replace as needed.

2. Ethylbensene (920 ug/kg) and total xylenes (11000 (B) ug/kg)are not repprted for surface soil sample #17 in Table 5-3, Thisdata is contained in Appendix P. In addition xylene and ethylbenzene were detected in EPA's split sample. Discuss thepotential source of xylene and ethylbenaene at location #17.

3, Samples beneath the CryoChem building were collected from adepth of approximately 16 inches. The depth of the sump whichcollected spilled TCA is approximately^ feet. Will thisdiscrepancy affect site remediation or interpretation of theextent, of contamination? Please discuss.

of its or i £in and

5. Toluene was observed in most of the samples at levels belowthe MDL3 but the contaminant was not detected in any of the fieldor trip blanks. EPA detected 24 ug/kg in a split of location #4.Thus, JACA's conclusion that toluene is a probable laboratorycontaminant should be justified. Table 5-3 indicates thattoluene concentrations are flagged by "B" indicating that thecompound was detected in the laboratory blank. Please providesupporting documentation.

This comment also applies to the detection of 2-butanone atlocation #6.

6. Pesticide > PCB analytical data for sample locations 9, 13 and16 is not within Appendix P. Revise Appendix P,

7. The footnote on Table 5-4 indicates that the symbol (-) meansthat the metal was not detected. According to the text, andlaboratory data, the metals were not analyzed. Revise Table 5-4.

8. EPA's split sample results indicate elevated levels ofarsenic at surface soil sample locations #4 (36.6 ug/kg) and #11(48 ug/kg). Review arsenic data and discuss potential sources ofelevated arsenic,

9. EPA's split sample results indicate possible elevated sine atsurface sojl sample location #17 (199Q(J) ug/kg). Review zincdata and discuss potential sources of elevated zinc.

10. Inorganic data in Appendix P is stamped "PRELIMINARY DATA".The RI Report should contain data which is properly reviewed forquality assurance and quality control. Revise Appendix P orprovide justification.

11. It is not clear from the discussion in section 5.2.2 andfrom the title of Exhibits 1 and 2 that soil sample locations areplotted on Exhibits 1 and 2. Please clarify.

12. The RI Report should briefly discuss the rationale foranalysing t>nly 8 of the metals included on the TAL except In Boilsample #2. . _..- • . •- -

AR30I585

'; '}"-•,:. *'=,:' ,w^..+ ... T _-. ._r .A.,- -,.- i.^rr.i ;-, .r' r^/j. t i r,:. H .ii s-i f ica i i on ."Tlit* oompounttn ohru-rv^<i ,int not pert} neri t to thit; study rmd t.hei rtviriot-tn.t.r.tf Ions ^c^ i ns igo j f .1 'i/int.. " AJ .1. <-''">rfifii">undfv d^tect.ed inr f.. jr.*[ w T ! i^-" . .sii r rr" ,';i w.it.(-:T .ri:!.1 ?:-:ii j on the s if e are pertinent toth'- Hi /FS R*vi.K'-> t.hJK statement . The term?; "significant" and"insignificant," must, be defined. How does JACA know that theamount of ehJordane observed in soil is insignificant. JACAneeds to demonstrate that the amount of a chemical present in thesoil will not be a threat to ground water or a risk foraccidental contact ingestion or inhalation. This applies toorganics and inorganics.

14. When discussing levels of metals in soil, JACA shouldcompare analytical results to background values. A table ofbackground values or ranges would be helpful.

15. Surface soil samples collected by JACA were not analysed forsemi volatile compounds. EPA sp3it samples were analyzed forthese compounds with no significant detections.

16. SPA detected 36(J) ug/kg of 4,4'~DDT in a split of samplelocation £5. EPA detected 160(J) ug/kg of PCB-1260 in a splitsample of location #17. Evaluate these results.

SECTION 5.2.3 - SUBSURFACE SOIL

1. Section 5.2.3 needs a figure depicting sample locations.

2. It is not clear from Table 5-5 where soil samples arelocated. For example, soil sample CC-HS-1 was collected frommonitoring well location RI-1. A reference table would behelpful. The analyses performed should be included.

3. The terms "significant", "insignificant", and "elevated" arepoorly defined for use in this section. Why is 48 UG/KG of TCAin soil the most significant.

4. This section states that phthalate detected in soil samplesoould result from plastic field and laboratory equipment. JACAshould indicate which equipment could cause this contamination.

A R 3 C I 5 8 6

RY OK K'PA "THKAH AND HKHINKNT HPMT SAMPLING

AQOKOUr, rtAMl-'LK i UKNT I K 1 GAT I ONKl-'A i',W-:> MW-2L) SW-1

ANALYTK

ALUMINUMCALCIUMCHROMIUMCOFFERIRONLEADMAGNESIUMMANGANESEMERCURYPOTASSIUMSODIUMZINC

COMPOUND1,1,1 TCA

CONCENTRATION

17034600

52.2(B)3636.3(B)

167003f>.71 .4(B)2900(B)66508i> . 4

7(J)

34600

66.7(B)1395.6(B)

1720021.61 . 2(B)2700(B)747055,4

6(J)

1369210(B)39.646.31804.6(B)2510(B)

2.8(B)1900(B)4490(B)21.4

SEDIMENT SAMPLE IDENTIFICATIONEPA SE-2 SE-2D SE-1JACA #5

ANALYTE CONCENTRATION

ALUMINUMARSENICBARIUMBERYLLIUMCADMIUMCALCIUMCHROMIUMCOBALTCOPPERIRONLEADMAGNESIUMMANGANESEMERCURYNICKELPOTASSIUMSILVERSODIUMVANADIUMZINC

52003.1114

3980064.5(K)7.540

104-0056.2

"- 8620" J253CK)0.8660345

148016.814&(J)

83903.51521.12.1

61300338(K)13.881.71540051.414700301(K)1.530710603.6(L)197023'. 6166(J)

1250

20.6

24604.7(K)1.612.6(B)26707.245390(K)

0.93

426

1460 _

26.6(J)

AR301587

SKOTION .*> a.! STHKAH KAMPUNG AWKOUK

1- Ar<u] y H-:.'-i J i - i ! - , i ?• tab]** i r T^bJe b-1] is compared to theMt'T. '['hi? •'!'i r # -:-h •>.! in b-^ ^.orupare^ t.o applicable freshwatererxt^ri s H^ we! J .

2. Stream sampling locations depicted on figures 5-3 and 5-4 arenot the same. Revise these figures to show correct and similarsampling locations.

3, Cadmium was not detected in samples submitted by JACA or EPAfor TAL analysis. Cd was detected in significant levels only insamples submitted for limited analysis. EPA's oversight samples,which are properly QA/QC'd, contained no cadmium. The detectionof cadmium in significant levels in the stream is questionableand must be explained. Review analytical data and discuss in RIReport.

4. The inorganic analytical data in Appendix R is stamped"PRELIMINARY DATA", The RI Report should contain only data whichhas been thoroughly reviewed for quality assurance and qualitycontrol. Please revise or explain.

5. The RI Report states that 2 of the 12 samples were analyzedfor the HSL. The Report should also state for which compoundsthe remaining samples were analyzed.

6. The narrative section discusses 12 samples, but the datatables provide analytical results for 13 samples. Please :clarify.

7. The location of sample CCSW3Q is not shown on figure 5-3.

8. The instrument detection limit for analytical results shownin Table 5-11 should be indicated and the table should indicatewhether the sample results were above or below the detectionlimit. This applies to all data tables.

9. The data qualifier "E" should be defined in Table 5-12 andwherever it appears.

10, Table 5-8 indicates that sample CCSH004 had a TGAconcentration- of 24 ppb, but the text of the report states thatthe concentration was 8 ppb. This discrepancy should beclarified." '

11. The following statement, which appears on page 5-24, requiresjustification and substantiation by site data: "Transportationof these contaminants appears to be affected by shallow groundwater fluctuations."

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b a c k g r o \ in c! v; 11 i i e s

5.3,2 STREAM SAMPLING - SEDIMENT

1. Inorganic analytical data contained within Appendix S isstamped "PRELIMINARY DATA". The RI Report should contain onlydata which has been thouroughly checked for quality assurance andquality control. Please revise or explain.

2, Comparing Figure 5-3 to Table 5-13 indicates that there is adiscrepancy in sediment sampling locations. The figure indicatesthat a sediment sample was collected at SW6 and the tableindicates that a sample was collected at SW8, Please clarify.

SECTION 5.4,1 - RESIDENTIAL WELL SAMPLING HOUND 1

1. the HI Report states that 25 homes were sampled during round1. Only 23 of the 25 wells listed in the analytical tablesappear on figure 5-5. Wells #444 and #439 were sampled,according to Tables 5-18 through 5-22, but do not appear onfigure 5-5. Figure 5-5 depicts well #438, but this well was notsampled. Well 74-A is labelled as CP-2. Well 474 is labelled asTF-1. Revise as necessary. Figure and text should beconsistent.

Section 5.4.1 states that well #444 was the only well where PCSwas detected, but this well is not located on any figures withinthe section.

2. The narrative should be revised to indicate that well 74-A isthe CryoChem Production well #2 (CP-2) and well #474 is the TroutFarm well (TF-1). These wells are not necessarily residentialwells.

3. Analytical data for sample cross reference numbers 11, 55,66-A and 86, a.e~ indicated on tables in Section 5.4.1, is notcontained within Appendix T. Appendix T contains analytical datafor sample numbers 10, 54 and 65 which are not in the analyticaltables. Please revise or clarify as needed.

4. The text (page 5-46) incorrectly states that TGA. not TCE,was detected in wells 331, 330 and 343 in concentrations of 18,77 and 56 ppb.

AR3015S9

During round i , DCS was detected in we 1 1 451 at 3( J) ppb,but the data is not shown on figure 5-6, TCE was also detectedin well 74-A at 2(J) ppb. Revise the figure to include allpos i t i ve res u Its, Check all results.

6. The graphic representation of results on figures 5-6 through5-15 is somewhat confusing. Ideally, each indicator compoundshould have its own map, which should include all measuredconcentrations during both phases plus the contour lines.

Alternatively, the text should clearly state and justify that theTCK-DCK plumes aro the same (same source) and the TCA-DCA plumesare the

7. Section 5.4.1 incorrectly states that APPENDIX D (not T)contains results of all parameters included in the residentialwell water analyses.

8. The Report states that well 76 had a pH value less than 6.5,while Table 5-18 indicates that well 63, and not 76, had a pHvalue less than 6.5. There appears to be confusion between the"B£P Garber well" (63) and the "Garber" well (76). Pleaseclarify. All other references to these wells should be checked.

9. Table 5-22 incorrectly reports results in ppm. the correctunit is ppb according to the APPENDICES.

10. The Garber well apparently contained 270 ppm of total organiccarbon, but no detectable VOCs or BNAs. The RI Report shouldexplain this incongruity. Was the TOC analysis incorrect ? Ifnot, how could the GC and GC/MS analyses have failed to identifyany specific compounds,

11. A1J results should be plotted on figure 5-7 for homes whichwere sampled and appear on the figure. For example, informationfor well #76 is not depicted on this figure although this wellwas sampled. The data flagged by "J" should also be shown onthis figure. 'Some wells (e.g. 82) should not be labelled onfigure 5-7 because they were not sampled. Make Figure 5-8 and 5-7 consistent .t Please revise this figure.

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12. Figures 5-8 and 5-9 have problems similar to those statedabove for 5-6 and 5-7. Well #76 appears on figure 5-9, but isnot labelled.

13. Estimated results for Benzene as reported in APPENDIX Tshould be reported in a table in Section 5.4,1,

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r *•-• 1 ':i ?'."; v *-.r 'V h 1 P' i. !': o n ci s t c t i v j t. v•;:*- IT .:-< .1 n we i i B ,

15. Analytical resu Its should be compared to MCLs or other AKARs.

SECTION 5.4.2 - RESIDENTIAL WELL SAMPLING ROUND 2

1. A value of 3(J) TCE is incorrectly reported as 3(J) TCA onpage 5-60, according to Table 5-23.

2. The assertion that "the only significant level of 1,1-DCE wasfound jn the MobJ3 station well" is incorrect. In fact,unacceptable levels of 1,1-DCE were found in home wells, CryoChemproduction wells and monitoring wells,

3. Table 5-23 does not contain data for sample Sill as reportedin Appendix T.

SECTION 5.4.3 - EPA CARBON FILTER DATA

1. In the discussion of general trends, the FI Report statesthat the pump test conducted on the site indicated that a welldeveloped set of fractures trended southeast from the vicinity ofthe site. Section 5.4.3 states further that this fracture setmay allow the contaminants to move quickly through the area ofhomes to the southeast of the site.

Section 4.3.4.3 does not adequately support this hypothesis.Please substantiate,

2. Well 107 (Benjo) is listed as having a carbon filter, butSection 5.4.2 indicates that this well does not have a carbonfilter since it was sampled during round 2. Please clarify.Benjo is written as Benyo on Table 5-23, Please clarify.

3. This section should contain a figure showing the distance ofeach group of homes, i.e. 1, 2 and 3, from the CryoChem site.

4. JACA sHould carefully review precipitation records andcontaminant concentrations. It appears that contaminant levelsare highest in summer and fall months and lowest in the wintermonths, thus suggesting a trend in the data. Evaluate seasonaltrends in rainfall and contaminant levels.

5. The location of the NpAA rain gauge^ station must beidentified.

RR301591

8. The Report needs to be more clear about whether the VOCconcentr&tjonfi in Table 5-25 were measured before or after GACtreatment.

8, The concentration of chemicals after GAC treatment is needed.

10. Some of the data reported in figures in this section isoverprinted on the home number. Please revise the figures sothat a33 data Is 3egible.

SECTION 5.5.1 - MONITOR WKLL SAMPLING AND ANALYSIS ROUND i

1. The RI Report states that the highest concentration of KN wasdetected in well HI-ID, however, Table 5-29 indicates that HI-5Shas a higher concentration.

2, APPENDIX V does not contain analytical data for metal samplescollected during round 1.

3. According to Table 5-28, TCA exceeded 100 ppb in 3 wells, not4 as stated on page 5-76.

4, Many of the samples contained very low estimatedconcentrations of toluene. All results should be listed on atable. Alternatively the results should be discussed.

5. Results from the Trout Farm well are not presented on Table5-28

6. Sample numbers in the APPENDICES have been changed so that -"--.they are not consistent with numbers reported in Table 5-28.Other sample numbers are not consistent between APPENDIX V andTable 5-28. Please revise or clarify,

t- -7. Results of semivolatile sampling must be reported and - ., .evaluated. --"' ' .

8. According'to data in Table 5-29, metals are a concern inground water since levels are above acceptable standards.

' *< MONITOR WKI.l, HAMPi.W; AND ANALYSTS ROUND ?f

2. Table 5-31 indicates that PCE was not detected in wells Rl-4S, RI-6 and QH-1, while other analytical data indicate that thewells were not even sampled. Please clarify.

3. The discussion of dilution on page 5-80 suggests that sampleswith values under 300, but above 200 were further diluted toimprove analytical detection. In sample CP-1, the undilutedvalue was 310(E). The diluted value was 150(D). Does thissuggests that saome of the VOCs were lost during dilution ?Please disc-use .

4. TCA detected in sample CCRI001D is not reported in Table 5-31.

SECTION 5.6 - DATA VALIDATION

1. This section must discuss the fact that several samples wereanalysed after the holding times were exceeded.

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RR30\593

SKCTION fi U HiTK KVAbUATJON

B.I fiOUKOKS OK nONTAMTNATJON

1. Conclusions related t.o the Heimbach Dump are notsubstantiated by data.

2. TCE and breakdown products are the most toxic found in groundwater during the RI .

3. This section discusses a steep ground water gradient from thearea of the upgradient TCE-contaminated wells to the CryoChemsite, but the RO Report does not dpeict nor discuss this gradientpreviously. Water level data from well location £5 should bereferenced in a discussion of water level gradients.

6,2 SOU, CONTAMINATION

1 . The HI Report does not contain the data or justification toconclude that the soil on the CryoChem property is not acontinuing source of contamination to the ground water. In fact,this statement contradicts a conclusion made on page 5-17 whichstated that "the TCA concentration of 22,000 in soil sample #17indicates that this area is a significant source ofcontamination". Metals were also detected at high concentrationsin some samples. Justify the conclusion.

2. According to EPA's oversight reports, soil near the base of >:'*'the sump into which the Chlorothene spilled could not be sampled,Thus, the soil which is probably the most contaminated could notbe sampled. Since the most probable area with highconcentrations of contaminants was not sampled, JACA can notconclude that the soil is not a source of contamination.

3. Soil near the CryoChem manufacturing building (JACA #17)contained elevated levels of TCA (22J000(E) UG/KG). The RIReport needs to demonstrate, by calculation, that this amount of TCA in soil wil] not leach into the ground water system in orderto conclude that it is not a continuing source of contamination. ""Similar determinations should be made for other contaminants thatwere identified" in the soil at the site. -^ ,

4. The most contaminated soil sample (#17) was collected near,": 7soil vapor pro>e location #14. The corrected soil gas reading atprobe location #14 was 262, The corrected soil gas reading was , ;higher at other probe locations suggesting that additional areasof soil may be contaminated with elevated levels of TCA, PCE,DCA, TCE, PCE or other chemicals. This must be addressed beforeJACA can conclude that the soil is not $ continuing source ofcontamination or that location #17 is tvhe most contaminated.

RR3Q159U

6.3 SORKACK WATER

1. This section should summarise the sediment results.

2, The fact that off-site springs are contaminated near the fishhatchery raises the question of possible contamination of otheroff-site springs which may not have been sampled. JACA mustdiscuss off-site contamination of surface water in light of theepr.ings discussed in section 4.3.2. and the use of springs bylocal residents.

3, ThjB section should discuss.impoacts, if any, to wetlandareas.

6.4 GROUND WATEH

1. This section concludes that observed fractures and solutioncavities are probably the primary avenues for ground watermigration. This conclusion must be justified in light ofstatements made earlier in the RI Report including:

A. (4-4) "In some cases the joints may represent faultdisplacement although no significant faulting was noticed inoutcrops or rock cores."

B. (4-4) "The secondary joint set generally trends N 55-90 Wand dips 60 S. It is generally poorly developed..."

C. (4-4) "Limited outcrops in the area prevented verificationof the fracture sone." This statement refers to a potentialnorth-south trace behind the fabrication building determined byaerial photograph analysis.

D. (4-5) '.'-No" outcrops of the Leithsville were observed in thestudy area. . . " ;.

E. (4-5) "Np fracture traces were observed in the area onaerial photographs..." This statement refers to the areaunderlain by the Leithsville Formation.

F. (4-6) " Sinkholes, characteristic of carbonate terrain,were not obvious in the area." A statement is made which infersthat some depressions in the area may bve sinkholes.

AR301595

n at ion inTab)- v~K- w i i - . * » . s-.Kt'K'. f.n M^if. n^ uAnkhoJe «as obts^rverf in thejfi.t '- fi n«-;-s..r ;- .!im f:t RHrnpl^- J '."';at ion tf&. Since the location ofthe puH^ibJe airikljole was rKit on figure 4-1, EPA assumes that itift supposediy near Redjment sample location tf9,

2. This section statevS that ground water discharges to thestreams in the study area which in part causes the contaminantplumes to be narrow. The RI Report provides no information tosubstantiate this conclusion. The RI Report needs tosubstantiate this conclusion in order to define the western andsouthern ]imjts of the plume.

3. This ^action discusses "north-south" fractures. Othersections discuss "northwest-southeast" fractures. Please makethe RI Report consistent.

4. This section implies that EPA greed that inorganiccontamination should be eliminated from consideration. Thissection shouJd state that EPA agreed to eliminate inorganics fromsampling round 2, Even though metals were not sampled in PhaseII, they still may represent a risk posed by the site.

COMMKNTS; ON i^KCTJON. 7,0..-.. KJ OK

SKCTION Y.I -• LNTHOUOOTJON

1. Tliis section should clearly state that all homes affected bycontamination do not have carbon filters.

SECTION 7.2 - CONTAMINANT IDENTIFICATION

1. The objectives of this section should be to screen theinformation available on all contaminants, not just organiccontaminants,

SKCTION 7.2.1 - SITE CONTAMINANTS

1. Information in Table 7-1 is inconsistent with information insection 7.2.1,

A. PCS results are not in Table 7-1B, Methylene Chloride results form ground, water are not shown

in Table 7-1C. Chlorobensene results from ground water are not shown in

Table 7-1

2. Table 7-1 does not contain results of all sampling (e.g.compounds flagged by "J"). Please discuss the exclusion ofsampling results form Table 7-1.

3. Table 7-1 does not contain results of inorganic sampling.Please justify. Since Table 7-1 summarizes results of HIsampling, all results should be included.

4. Please explain why metals results are not considered in theassessment of risk.

5, Table 7-1 does not include results of EPA sampling atresidential wells. This data should be included or justificationfor exclusion must be provided. • ;, ' r

6. Table 7-1 needs to identify the units of concentration. ...

7. Table 7-1 should identify the frequency of detection of eachcontaminant/". . - ./' _'

flR30i597

SKOTION Y ?,,*' CHmnA?, OOMTAMi

w*"> i >? *v -T.i-u lr> b"-th ; h* vri."3nJ H.tt^v ^u*: nrfac^ water, only theK.' '|>JJ'J w,?i t~*r r! v."t .: u W-*P> ufed . this- approach f'~*r water waevt.ak^n bevv-auve po'.ahle w=tt.er in the study area is obtained fromground water. " This statement must be justified in light of thefact that some of the residents obtain potable water from springsaccording to JACA's Phase I Heport .

2, This section discusses the rationale for excluding chemicalsfrom further consideration. However, some of the chemicalsdiscussed do not appear in tables anywhere within the riskassessment (see above comment). Revise Table 7-1.

3, The HI Report should describe exactly how the "representative"concentrations in each medium were calculated. This descriptionshould include: (1) which samples were averaged, (2) whether non-detects averaged as zero (which may be incorrect), and (3)whether the average was arithmetic, geometric or something else.

The HI Report states that representative concentrations weredeveloped by averaging concentrations from samples . in which acompound was detected. This may not be very meaningful for media.in which a low frequency of detection was observed or media, suchas surface soil > that were sampled at random locations .

4. Please cite sources for toxicity constants.

5 . Several compounds , including toluene , chlorobenaene , ethylbensene, and xylene, are leiminated due to their lowconcentrations and frequency of detection. However, the presenceof all these chemicals in one sample (CCSS005) may be significantsince these componds are components of gasoline and hte samplewas colected at the end of a leaking pipe observed by PHC onFebruary 14, 1889. Is the pipe a source.

SECTION 7.3.1 - EXPOSURE SCENARIOS

1. The soil exposure scenario is eliminated because "the area ofsoil contaminaiton is small and exposures due to contaminated _./soils are mos*t likely insignificant compared to exposuresassociated with ground water." The conclusion that the area ofsoil contamination is small can not be supported by the RI since rit is not fully delineated (if it is, please delineate). Sincethe exposed populations for the ground water and soil scenariosare different, the risks from each scenario should be quantified^

2. A fifth exposure scenario, involving recreational use of thestreams, should be added. This scenario should include (1)incidental ingest ion of surface water, (2) dermal contact withcontaminated water and sediment, and (3) inhalation of compoundsvolatilised from surface water by a child.

SKOT70N Y.rJ

The IV] Report ends by eat i mating, concentrations at tHe point ofexposure, arid comparing these to ARARs. No lifetime doses,cancer risks, or hazard indexes are calculated, nor does thedocument include information on toxic effects or dose-response ofthe indicator chemicals. The document lacks a risk estimate.For example, how many people in a million may contract cancerafter exposure to the risks posed by the site ?

/5R30I599

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