Environmental Resources Management, Inc.855 Springdale Drive • Exton, Pennsylvania 19341 • (215) 524-3500 • Fax One: 524-7335 • Fax Two: 524-7798

16 March 1990

Mr. James FeeneyProject OfficerSE Pennsylvania Section (3HW21)U.S. EPA . i841 Chestnut Street fPhiladelphia, PA 19107 File No.: 751f02-00-01

Re: Response to EPA Comments - Transicoil Draft RIFSWork Plan

Dear Jim:By this letter ERM and Transicoil, Inc. acknowledge receipt pfcomments by EPA on December 1,1989 and February 22, 1990 for theabove referenced matter. We met on January 25 to discuss yourcomments and since then have spoken by telephone on severaloccasions. This letter is intended to serve three functions: 1) !tosummarize all of our discussions; 2) to formalize the agreed uponconcepts; and 3) to present revised language for your approval tofinalize the Work Plan. |We have not yet received any written or verbal comments regardingthe revised Section 5, Risk Assessment. During our telephoneconversation of March 1 you'stated your preference of discussingSection 5 when you and I discuss these revisions. I

!If the language submitted herein meets with your approval, there areseveral alternative courses of action we could take with regarjd tofinal approval of the Work Plan. Two of these alternatives ar6 listedbelow: !1) Approve the Work Plan with the exception of SectionS. Approval

of Section 5 will follow; or ii •

2) Withhold approval of the Work Plan until we have discussed andrevised Section 5. j

With regard to EPA comments #14 and 18, ERM and the respondentsdo not agree with EPA's technical approach on these issues. jWedisagree with your use of the 20 foot open interval. Based upon our

The

An affiliate of the Environmental Resources Management Group with offices worldwideAR000222

Mr. James FeeneyUSEPA16 March 1990Page 2

experience, we feel that longer open intervals are appropriate in thisenvironmental setting. Our objection to unfiltered samples(Comment #18) has been expressed to you on numerous occasions.We believe that acidification of unfiltered samples may result in theexpression of artificially high levels of metals in the chemicalanalysis. In the spirit of moving forward with this work, we haveconceded to EPA's requests on these points, however, we retain theright to challenge any additional work which may result fromanalyzing unfiltered samples and limiting the open interval of thewells.

I would like to take this opportunity to thank you for your opennessand availability to discuss this project by telephone and by meeting.The result has been beneficial to the project in that significantprogress in field work, e.g., the first round of geophysical testing, hasalready taken place. Data from these studies is currently underreview. We expect field work to begin soon after final approval of theWork Plan has been given. If you have any questions, please do nothesitate to call me.

Sincerely,

Mary LetzkusSenior Project Manager

ML:jlAttachmentcc: P. Harper

M. JohnsonM. HewittS. Sayko

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AR000223

COMMENTS AND REVISIONS TO THE SEPTEMBER] 1989DRAFT WORK PLAN TRANSICOIL SITE

Title PageComment1. Include an approval line for the U.S. - EPA Project Manager.Response |1. As agreed, an approval line for the U.S. EPA Project Manager

has been added to the title page.

SECTION 1

Comment2. The Statement of Purpose must include provisions to

expand the 1/2 mile radius for the domestic wateir supplyinvestigation consequent to any findings that indicatecontamination may extend further. Also include nearbyupgradient wells as the prevailing ground water flow may bechanged locally due to hydraulic loading at the septic drainfield and pumping of local production wells as discussed insub-section 2.3 of the work plan.

Response2. As agreed during our 25 January meeting we agree to the

change EPA has proposed. We offer the following proposedlanguage to be added to page 1-1 of the Work Plan: j

i i

"...This study will include both on-site source airea andhydrogeologic investigations, and an investigation ofdomestic water wells within a one-half mile radius of thesite boundary. If the results of this study show that groundwater contamination extends beyond the one-half mileboundary specified by this study, EPA will be notified.Notification will afford EPA and the respondents theopportunity to discuss extending the radius of the stjudy areabeyond the one-half mile boundary. In the event..."

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SECTION 2

Comment3. Include a site location map on a smaller scale to better

depict the geographic location of the site (see enclosedexample taken from aerial photo survey).

Response3. As agreed, ERM has included a site location map. This map

is nearly identical to the one you sent to us for use as anexample on 19 December. In addition, a second locationmap at 1:24000 scale has also been added. Because a newmap was added to Section 2 the list of figures are now onenumber higher e.g., old Figure 2-3 is now Figure 2-4, oldFigure 2-4 is now Figure 2-5, etc.

Comment4. In the current Figure 2-1, identify the Transicoil buildings

and structures including the main building, building #2, theparking lot, the drum storage areas, and the septic drainfield. Reference is made to all of these structures insections 2 and 3.

Response4. As we have agreed, the Transicoil buildings and structures

illustrated on new Figure 2-2 have been identified. Theseinclude the main building, building #2, parking lot, drumstorage areas and septic drain field as requested.

Comment5. Table 2-1 should include the depth of the well casings to

indicate the extent of the open interval (screened or hole).Response5. Table 2-1 has been changed to add detail regarding depth of

well casings to indicate the extent of the open interval(screened or hole).

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Comment6. Reports of the previous investigations performed at! the site

that are summarized in this section should be included asattachments to the Work Plan for clarification.

Response6. As agreed during our 25 January meeting, we will include

the BCM Report of 1980 and the SMC Martin Report of1988 as Appendices C and D respectively.The ERM study of 1988 is incorporated into the text ofsections 2 and 3, however, since it was produced for agroup of PRPs and therefore, not in the public dpmain orowned by Transicoil or Eagle-Picher, we cannot include thisstudy as ah appendix. Language has been added tj) page 2-5 which reads as follows: j

!"During the summer of 1988, Environmental ResourcesManagement, Inc. (ERM) conducted a hydrogeologicinvestigation at the Worcester Site. While trie results of thisstudy were never published, information learned from thatstudy is incorporated into this Work Plan; Thatinvestigation..." |

: - !Comment j .7. In sub-section 2.3.5 it is stated, "At this time there | does not

appear to be any sensitive environmental area within one-half mile of this site." This statement needs to besupported; how was this determination made. Seej also thefollowing comment and the comments covering section 5.

Response jt7. We have added narrative to sub-section 2.3.5 and section 5.5

to describe how we determined that no sensitiveenvironmental areas exist within 1/2 mile of the site.Please also see our response to Comments #8 and |29 belowfor additional detail. Language added to sub-section 2.3.5 isas follows: !I •

"Our review of the files and conversations withknowledgeable state, local and federal officials suggest thatno sensitive environmental areas exist within the one-halfmile range." I

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Comment8. Under sub-section 2.4, Identification of Data Gaps, there

should be a paragraph indicating the determination of thepresence (or absence) of the following areas which may beassociated with or impacted by the site: wetlands,floodplains, recreational areas, farmlands, historic buildingsor areas, archaeological sites, etc. The Fish and WildlifeService should be contacted to determine the occurrence(or absence) of threatened and endangered species in thisarea and the impact this site may have on those species.

Response8. As requested, and as noted above in the response to

comment #7, we have added narrative to sub-sections 2.3.5and 5.5 to describe how we determined that no sensitiveenvironmental areas exist in the vicinity of the site. As perour telephone conversation of March 1 we did not addadditional language to section 2.4 as EPA's concerns werehandled in sections 2.3.5 and 5.5. Narrative added to sub-section 5.5 page 5-8 reads as follows:"Initial data review with knowledgeable state, local andfederal officials (e.g., U.S. Fish and Wildlife Service,Pennsylvania Fish Commission, Pennsylvania GameCommission Bureau of Forestry, Montgomery CountyPlanning Commission, etc., indicate that no sensitive areasare present within a one-half mile range of the site.However, if any natural resources (e.g., wetlands) areidentified in the immediate site vicinity the need for anecological risk assessment would be evaluated."

SECTION 3

Comment9. In sub-section 3.1.2.1, evaluations of aerial photography and

a site area walk-over are indicated to determine soil gassampling locations, however, the criteria to be used in theseevaluations are not presented.

Th«L _/""

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Response9. As agreed, narrative has been added to sub-section! 3.1.2.1.

on page 3-2 as follows:"...for additional soil gas studies. Criteria to bechoose potential areas for sampling include, but

used toare not

limited to the following: areas of soil discoloratiob; drumstorage areas; suspect debris piles, and employee interviewsetc.In addition, some samples will be randomly selected. Thisapproach is useful to avoid bias by errors in sample( locationselection. Large areas, such as the septic field, will besampled using a grid so that they can be systematicallysampled."

Commenti

10. Since the development of general response sectioili of thiswork plan includes the evaluation pf soilexcavation/treatment, an air impact analysis should beincluded to estimate potential ambient air impacts Resultingfrom VOCs in the soil during remediation. This j analysisshould be detailed in sub-section 3.1.2, Source AreaInvestigation. I

'• i'Response10. As agreed, narrative has been added to sub-sectipn 3.1.2,

page 3-2 to describe modeling of emissions for! the noaction alternative during the RI. We propose the followinglanguage: j"Information collected during this task will be evaluated todetermine whether health risks exist due to jphysicalcontact with the soil and whether these soils could be acontinuing source of contamination into the ground' water orair for the Transicoil Site. We will model emissions for theno action alternative during the RI. Emission modeling forsoil excavation and/or air stripping will be performedduring the FS. Emission modeling will be accomplished bydeveloping an engineering plan which sequentiallydescribes the work to be accomplished. Potential missionpoints for each step will be identified and emission rateswill be developed for each emission point based upon, but

AR000228 Group

not limited to, the following: work performed; rates, ofagitation; surface areas exposed; and estimated or knowncontaminant levels."

Comment11. In sub-section 3.1.2.3, evaluation of the soil gas survey will

be used to determine the sampling locations for soilanalyses, however, the criteria to be used in theseevaluations are not presented. Soil samples should beanalyzed for TOG in anticipation of evaluating potentialcontaminant loading to ground water.

Response11. As per your request and our discussion on 25 January, we

have reconsidered your request for performing TOG analysisand we agree to perform this test during the RemedialInvestigation. This will eliminate the need to return to thesite at a later time to perform TOG analysis. We suggest thefollowing language to be substituted in sub-section 3.1;2.3page 3-3:"As described above, soil gas studies will be performed aton-site areas which have not previously been studied.Information gathered during the soil gas study will be usedto determine areas for additional investigation. Criteria forselection of additional areas of investigation are as follows:

1) The trigger level for additional studies is any area whichshows OVA or field GC readings equal to, or exceeding 5times the background level.All site locations meeting this test will require thecollection of soil samples which will be submitted forlaboratory analysis in accordance with the QAPP. Allsamples will be collected using a hand-driven bucket auger.a For contaminated areas where field soil gas analyses are

5 times background and equal to or greater than 100ppm, 3 soil samples will be collect from the area. Oneof these samples will be taken from the location withinthe area of the highest OVA or field GC reading. Onesample will be collected from an area demonstrating amedian field measurement. One sample location will bechosen from an area showing a low end (but above

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background) reading. Wherever possible each soilsample taken for laboratory analysis will be collectedfrom within 6 to 12 inches of the soil gas measurementpoint.

b. For contaminated areas with field soil gas readingsequal to 5 times background but less than 100 ppm, 2soil samples will be collected. Highest and lowestlocations will be selected from within the contaminatedarea. Each sample will be collected from within 6 to 12inches of the soil gas sampling point wherever possible.

c. If in the unlikely event free product is encountered inthe soil the field geologist will call title ERM projectmanager to request guidance concerning theappropriate next course of action. The EPA projectmanager will also be notified in the event of thisoccurrence. j

In addition to the samples taken from contaminated areas(e.g., those in excess of 5 times background), threebackground samples will also be collected for laboratoryanalysis. These samples will be collected from a |depth ofapproximately three feet using a hand-driven auger. Forthe purpose of determining background, sample locationswill be chosen from areas believed to be unaffected by pastor present plant operations. Background samplejs will beseparated from each other by a minimum of 200 feet.Based upon our present understanding of the site, ERManticipates that approximately 20 soil samples; will becollected from areas of investigation plus the 3 additionalbackground soil samples. Background samples, will beanalyzed for the full Target Analyte List (TAL) and 'for TotalOrganic Carbon (TOG). Approximately 80% of theinvestigation samples will be analyzed for VOCs using eitherEPA approved methods 8010 (plus Freon 113) or 8020.Approximately 20% of the samples will be tested for the fullTarget Compound List (TCL) and TAL. Sampling protocolsand the QA/QC samples to be submitted to the laboratory aredescribed in the QAPP (Appendix B)." |

7AR000230

Comment12. Sub-section 3.1.3.2 indicates that geophysical logging of the

open intervals will be conducted in wells MW-1 throughMW-5 and in T-6. This proposed plan does not include thewells T-3 or T-5 which are positioned between thesuspected freon source and the fracture trace which trendsapproximately north/south at the southeast side of the site.

Response12. As per your suggestion, narrative has been added to sub-

section 3.1.3.2 describing why wells MW-1 through MW-5and T-6 were chosen for the. first round of geophysicallogging."T-6 was chosen for geophysical logging due to its depthand the fact that VOCs have previously been detectedtherein. T-6 had previously been used for supplying coolingwater to the plant but is out of service since early December1989 when the first round of geophysical logging wasconducted. The main objective of the geophysical logging isto evaluate bedding-related permeability and to determinewhich water bearing zones carry contamination at the site.T-6, being the deepest well, will give the best information.Wells T-3 and T-5 were not proposed for geophysicallogging because analysis of bedrock strike and dip indicatethat these wells will not intersect the same geologic beds asencountered in the other monitoring wells and well T-6.» Inaddition, both T-3 and T-5 are used for plant process water.Simultaneous disruption of service at all three wells wouldseverely limit manufacturing processes. However, ifnecessary to complete definition of site conditions,geophysical logging will be performed in T-3 and T-5 whenthe new RI monitoring wells are logged or after the facilityhas closed. Transicoil expects to move its manufacturingoperation from this site in mid-1990."

Comment13. In sub-section 3.1.3.3 it is indicated that "selected" intervals

will be field tested for VOCs. It is the opinion of EPA thatevery packed interval should be sampled and field analyzedfor VOCs. A complete vertical profile of contaminationentering or exiting the borehole will preclude any futureneed for interpretation and subsequent resampling.

The

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Response j13. The word "selected" has been removed from sub-section

3.1.3.3 to indicate ERM and Transicoil's intent to sampleeach water bearing interval during the field test for VOCs.As discussed during our 25 January meeting; we propose thefollowing paragraph to replace the old paragraph #3,subsection 3.1.3.3 found on page 3-5: j"Based on the results of the geophysical logging of well T-6,a number of potential water-bearing intervals: will beidentified for testing. A number of likely lowryieldingintervals will also be identified and tested. T|he totalnumber of intervals tested is expected to be 20 to 30intervals. The testing will generally follow theseprocedures: i• Lower the packer into the borehole, once fully

submerged wait for full recovery of the water [to staticlevel; iii

• Inflate packers at intervals identified for testing andallow interval potentiometric head level to stabilize.The rate that readings stabilize is proportional to thepermeability of the interval. This procedure will berepeated moving from the top to the bottom of j the well.No pumping will occur during this testing. i

• Starting at the bottom of the well, pumping of the testintervals will proceed. At each interval t\|/o watersamples will be collected, one partially filling j a 1 literjar, and a second in a 40 ml VOA vial. The head spacein the 1 liter jar will be evaluated for VOCs; using aCentury 128 OVA. Samples showing levels of VOCs andfrom high yielding zones will have the 40 ml VOA vialsubmitted for VOCs analysis.

All VOC analyses will be performed by EPA method 601(plus Freon 113) and method 602. Should any'unusualconditions be encountered during the test, ERM fieldpersonnel may test additional intervals and' submitadditional samples for VOC analysis." i

9AR000232

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Comment14. Sub-section 3.1.3.4 indicates that up to seven (7) new

monitoring wells will be installed, however, there is notadequate rationale provided in the work plan to support theselection of this maximum number and no detail on whatcriteria was used to determine their proposed location.Specifically, the following comments must be addressed:a It is indicated that there are several water producing

zones, however, the proposed new wells seem toindicate a focus on two zones, shallow and deep.

b. The proposed construction details for well depths andopen hole intervals are not appropriate. Theconstruction of monitoring wells should not be a meansof interconnecting fracture intervals and providing apotential source of cross contamination. Thepreliminary number and location of the new wellsshould be determined based on the results of thegeophysical logging and packer testing of the existingwells as currently specified in the work plan, but thefinal well designs should be refined according to thespecific local conditions described by coring, boreholegeophysical testing, or additional packer and chemicaltesting of the new boreholes. Only fracture intervalswith similar head and chemical concentrations shouldbe transversed by the open hole completion.

c. A fracture trace identified in Figure 3-2 is not the siteof a proposed well. The rationale for this decision mustbe presented in the Work Plan.

Response14. Narrative has been added in sub-section 3.1.3.4 to support

the selection and placement of up to seven new wells. Also,criteria used to support selection of these locations hasbeen added. We offer the following to replace the oldbullets on pages 3-5 and 3-6 and paragraphs 2 and 3 ofsubsection 3.1.3.4:"• One shallow bedrock well will be installed in the

vicinity of the highest chloroflurohydrocarbon (CFG)concentration (the highest CFG is near T-5). Thepurpose of this well is to further evaluate the CFG levels

10AR000233

in ground water in the area in which CFC has previouslybeen observed. The exact location will be determinedafter the following tasks are completed: reviewingaerial photography; performing Transicoil employeeinterviews; and completing the soil gas investigation.

• One nest, a shallow arid a deep well, will be installedapproximately 500 to 1000 feet west of well MW-2.These wells will be located on a fracture trace! strikingnorthwest from the site. Several domestic wellsnorthwest of the site are known to be contaminated.These wells may demonstrate the feasibility! of VOCmigration in this direction form the site. [

• One nest, a shallow and deep well, will be| locatedapproximately 200 feet north of MW-1. The purpose ofthis nest is two-fold. First to monitor VOC migration ina direction which is downgradient and downdrp of themost contaminated well on-site. Second, the deep wellwill be installed at a depth consistent with MW-1 interms of stratigraphic dip. Its depth |will bedetermined from evaluation of the geophysicalinvestigation. Its open interval will be limited to 20feet. Past experience in this geologic setting has shownthat enhanced bedding parallel permeability can be acritical factor in ground water flow and VOC transport.

• One shallow monitoring well will be installed on thecrest of the ridge between well T-6 and the WprchesterNike Park. This well will provide additional control onthe potentiometric surface and the VOC distribution.

• One well will be installed on the southeastern flank ofthe septic drainfield. This well will provide additionalcontrol on the potentiometric surface. VOC distributionand may provide insight on the influence of th : dippinggeologic bedding on VOC transport. I

The criteria for construction of shallow and deep wells isdefined below. One exception to these criteria wiil be thedeep well north of MW-1. This is necessary as thecompletion depth of this well is critically tiecji to theinterpretation of the geophysical investigation. For j all otherwells: !

Trig11 RR00023U

Group

Shallow wells will be completed with an open interval of 20feet. The well will be drilled to 15 feet below the first waterbearing zone encountered. The maximum depth drilled willbe to 50 feet below the potentiometric surface, determinedfrom nearby existing wells. An OVA will be used duringdrilling as a screening tool. Should any obviously elevatedlevels of VOCs be detected at a unique depth, drilling will behalted until the ERM project or task manager has beenconsulted to evaluate the situation, and potentially modifythe aforementioned construction. Well construction mayalso be modified after consultation with the ERM project ortask manager if more than one "significant" water bearingzone (10 gpm or greater) is encountered, or if any otherunexpected conditions are encountered. In no case willmore than one "significant" water bearing zone beencompassed by a single open interval..Steel well casing will be installed into competent bedrockto 5 feet above the first water bearing interval. Should therock encountered be unstable such that an open intervalmay not remain open, then a 4-inch PVC well screen andcasing will be installed. Casing in both the deep and shallowwells will be grouted in place with a 95/5 cement/bentonitemixture in the annular space between the well casing andthe bore hole. The grouting process will be: 1) install awooden of cement plug into the bottom of the well casing,2) fill the bore hole with sufficient grout to fill the annularspace, and 3) lower the casing into place, displacing thegrout and filling the annular space. The grout will beallowed to set for 24 hours before additional drilling isinitiated.Deep wells, only one exists in the present plan to which thefollowing applies, will be cased and grouted at 70 feet belowthe potentiometric surface. Drilling of the deep openinterval will commence 24 hours after grouting the wellcasing in place. The deep open interval will be 20 feet.Should a significant water yielding zone be encounteredbetween the bottom of the shallow well and 70 feet belowthat potentiometric surface (to be cased off between theshallow and the deep well), the well construction will bereevaluated by the field geologist and the project managerbefore installing well casing.

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Comment15. Sub-section 3.1.3.4 indicates that drill cuttirjigs and

development water will be discharged to the ground in thevicinity of the wells. This discharge is subject to verbalapproval of the discharge from the PA DER Bureau ;of WaterQuality. To receive such approval, a letter rnust besubmitted to: j

i •Lew LuchieRegional Water Quality ManagerPennsylvania Department of Environmental Resources1875 New Hope StreetNorristown, PA 19401In the letter, summarize the pertinent background theexpected contaminants and the level of contaniination,describe why the discharge is proposed, exactly wpere thedischarge will occur and when. This information can beculled from the work plan. This comment also applies tothe proposed discharge of the water generated during theaquifer pump test in sub-section 3.1.3.7.

Response15. Thank you for this information. As you suggest, ERM will

discuss this matter with Lew Luchie. EPA will be |apprisedof the outcome of this discussion. iI

Comment !16. In sub-section 3.1.3.4, in a description of the locajtion of a

proposed well, the suspected Freon source is mentioned.This Work Plan must include a description of this suspectedFreon source detailing where it is located and how it wasdetermined to be a suspect source. This should! also beindicated in one of the site maps. j

Response |16. As we discussed at our 25 January meeting, the reference

on page 3-5 regarding the suspected freon source: was anerror. Per your request, the reference to the tra<jle nameFreon has been changed to chloroflurohydrocarbon (CRF).The alternative language is presented under the response tocomment #14 above. i

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Comment17. Sub-section 3.1.3.5 states that ground water samples from

three of the thirteen existing wells will be analyzed for thefull TCL/TAL. The existing rationale or criteria for the threewells subject to this analysis should be presented.

Response17. We propose the following language addition to page 3-7 to

address your comment:"...and the full Target Compound List and Target Analyte List(TCL/TAL) on samples of the three remaining wells.Twenty-five percent of the samples from the three wellswill be analyzed for the total compound list (TCL). Wellstentatively chosen for TCL testing are identified as: MW-1because it has shown the highest levels of VOCcontamination; MW-5 because no VOC contamination hasbeen detected here; and the newly proposed well directlynorth of MW-1. . The respondents reserve the right tosubstitute other wells should field observations merit such achange in plans. EPA will be notified in advance of such achange and the reasons supporting it. Samples..."

Comment18. Sub-section 3.1.3.5 states that ground water samples from

on-site wells will be filtered in the field for TAL Analysis. Itis Regional policy that both filtered and unfiltered samplesbe analyzed for the assessment of ground water quality.

Response18. In your written comments of December 1 and February 22

and during our meeting on January 25 you stated that it isRegional policy to require analysis of both filtered andunfiltered samples. As we explained during our 25 Januarymeeting and during subsequent telephone conversations,ERM strongly believes that such an approach can lead to thedevelopment of a misleading data base. Preservation byacidification of unfiltered samples will desorb naturallyoccurring metals from suspended sediment particulates,and thus may give elevated false positive readings for metals.We also offered, as a compromise, to provide split samplesfor your laboratory to analyze; however, we would be likely to

14Group

&ROQQ237

challenge any additional expense resulting from this work.While we still reserve the right to make all of the abovearguments, in the interest of expeditiously beginning thiswork we will agree to take filtered and unfiltered samples.If, in the event that these analyses show elevated metallevels significantly above normal background levels; and itcannot be shown that Transicoil is responsible for theirpresence in the ground water, we may challenge anyadditional work resulting from this anomalous information.Revised language is as follows: "...Samples submitted [for TALwill be filtered and unfiltered in the field j beforeacidification..."

Comment19. Sub-section 3.1.3.6 indicates that electronic water level

recorders will be installed in three wells; the criteria forthe selection of the wells should be presented. j

Responsei

19. Narrative has been added to section 3.1.3.6 to o^escribecriteria for installation of electronic water level recorders tobe installed in the three wells. ii •"Electronic water level recorders will be installed 0 1 threewells so that the greatest areal coverage can be achieved.Wells selected to receive water level recorders are! MW-5,the new well nest west of MW-1 and MW-2, and at Tn3. T-3is proposed for water level tests if it is not in use for plantoperations and if it has been off-line for at least <jme fullweek. If these conditions cannot be met then T-6 will bemonitored in lieu of T-3. Criteria used for the selection ofwells for this test are well depth and distribution.; Othernon-critical criteria include the installation of instrumentsin clean wells, and at locations where multiple we|l nestscan be monitored with one water level recorder. The wellsselected for such tests include: MW-5, the new nestMW-1 and MW-2; and well T-3."

Comment

west of

20. Sub-section 3.1.3.7, proposed discharge from aquifeir pumptest, see above comment for sub-section 3.1.3..4. !

15AR000238 Jl

_:oup

Response20. The response to comment 15 applies to this comment.Comment21. Sub-section 3.1.4 proposes a soil percolation rate using a

standardized method. The specific method should bereported either in the final work plan or in the RI Report.

Response21. As per our conversations we propose to replace sub-section

3.14 found on page 3-8 with the following:"The development of a Feasibility Study for this site isexpected to evaluate ground water remediation via a pumpand treat scenario. As an option for disposal of the treatedwater, surface application/spray irrigation would beconsidered. In order to evaluate this option in the FS,infiltration rates for site soils must be determined. Thepurpose of the infiltration tests is to collect the datanecessary to provide a conceptual level of evaluation ofsurface application in the FS.Infiltration testing will be performed using a basin floodingtechnique. This method has been selected over percolationtesting as it is more appropriate for surface application oftreated water. This method was selected over double ringinfiltrometer methods as it is simpler to perform, and usesa greater surface area for testing thereby minimizing errordue to spatial variability and minimizing edge effects at thering perimeter. Should surface application of treated waterbe selected in the final remedial design, additionalinfiltration testing will be necessary.Three basin flooding tests will be performed. Theprocedures followed will be in accordance with thosepresented in the EPA Manual for Land Treatment ofMunicipal Waste. One exception will be that notensiometers will be used. Instead, basin flooding willcontinue until infiltration rates approach a stabilized value.This generally takes longer than using tensiometers but isequally reliable.

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An 8-foot diameter basin will be created by Inserting a 6 to8 inch wide metal band into the soil to a depth ofapproximately 3 inches and sealed with a bentonite slurry.Following installation, preliminary flooding of the basin willbe performed to achieve saturation of the upper soijl profile.Once saturation is achieved final basin flooding! will beperformed and the infiltration rate monitored.

i

Infiltration data will be plotted on a log/log graph. Thestabilized infiltration rate will be chosen as the valuereached at equilibrium, i.e. the asymptote of theinfiltration/time plot.In addition to the infiltration testing, a 6 to 8-foot deep testpit will be dug in the area of each basin flooding t st. Thesoil profile will be evaluated by a soil scientist. Adescription of the soil profiles and an interpretation of thecapacity of the site soils for surface application of treatedwater will be prepared by the soil scientist. "

Comment22. Sub-section 3.2 indicates that one of the purposes of the off-

site characterization is to provide potable water "at i the tap"for affected residents whose water exceeds EPAJ interimremedial action level for TCE. This section should bepresented so as to include action levels for any sit relatedcontaminant, and to provide uncontaminated water at thepoint of entry to the affected residences. This provisionwould protect against inhalation exposure to VOCjs duringhousehold water usage.

Response22. We agreed during our meeting that "at the tap," is not

limited to faucets where residents obtain drinking water,but rather should include shower heads, laundry, toilets,etc. We therefore propose the following adoption tolanguage on page 3-9, sub-section 3.2: j"...if so, to provide potable water for all normal householduses including but not limited to, bathing, laundry,! drinkingwater, etc., for those residences;"

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Comment23. Sub-section 3.2.1, see comment to section 1 concerning

expanding the off-site investigation if necessary.Response23. Comment on section 1 applies to comment 23.Comment24. In sub-section 3.2.3 it is stated that samples from private

wells will be analyzed for VOCs. Approximately 10% ofthese samples should also be analyzed for the TAL. Also seecomment to section 1 concerning expanding the off-siteinvestigation if necessary.

Response24. As per our discussions on January 25 and 29 we have agreed

that if the TAL analyses on the three on-site wells showelevated semi-volatiles or inorganics, we will test some ofthe off-site samples for TAL. We therefore propose thefollowing word change to the Work Plan document:"Samples will be analyzed for VOCs by EPA methods 601(plus Freon 113) and 602. In the event that the on-sitesamples tested for TAL show elevated inorganic or semi-volatile contaminant levels, five percent of the off-site watersamples, or approximately 20, will also be tested for TAL...."

Comment25. Table 3-1, Residential Well Data Sheet, section 3 should

include the following questions:Is the well open hole?To what depth is it cased? (open hole)What is the depth of the screened interval? (casedwell)

Response25. We have added the three questions you requested to the

Residential Well Data Sheet.

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SECTION 4

Comment26. In this section it is stated that the goal is to determine if

potable water wells within one-half mile of the site exceedthe EPA action level for TCE. This section should state, "exceed the U.S. EPA action levels for any site relatedcontaminant thus requiring interim remedial measures.This section should indicate that alternate water supplies, ifnecessary, will be installed at the entrance to the homes.See also the comment concerning sub-section 3.2.

Response26. As per our discussions on 25 January and 5 February we

propose to add the following language change to page 3-9,section 3.2: •!"The purpose of the off-site characterization study isthreefold: . . . . - •

i• to determine whether any of the residents j living in

the vicinity and downgradient of the site are usingwater in excess of the USEPA action levels.Because this action is an interim remedial measurethe action level for TCE will be 128 ug/1 which isprotective to the 10'5 risk. Homes with TCEconcentrations equal to or in excess of 128 ug/1will be supplied with water filtration systems by therespondents."

27. Also in this section, the following language should beincluded: I"Provisions for installation and the disposal of spent carbon

filters will be subject to EPA approval."Response27. Since it has not yet been demonstrated that carbon jfiltration

units are necessary, the recommended wording ispremature. As an alternative, we suggest the following:"If TCE levels in the homes is equal to or exceeds] the EPAremoval action levels, Transicoil will supply potable water

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for those residents. .If the system chosen involvesinstallation of new carbon filters and/or disposal of spentcarbon filters, removal and disposal of spent filters will be inaccordance with all Federal, state and local regulations."

SECTION 5 - A RESTRUCTURED SECTION 5 WAS SENT TOMR. FEENEY ON 5 JANUARY 1990. WE HAVE NOT YETRECEIVED COMMENTS ON THIS WORK FROM EPA. TH ERESTRUCTURED VERSION ALSO INCLUDED COMMENTSRESPONSIVE TO EPA COMMENTS 28 THROUGH 3 3INCLUSIVE.

General Comments:A new Section header, 5.1 Introduction, was added to thetext of Section 5. This necessitated the subsequentrenumbering of listing section titles e.g., old 5.1 "Purpose ofthe RA" is now 5.2. Other minor word changes which makefor smoother reading have been made throughout Section 5.These changes do not alter the meaning of the various sub-sections.

Comment28. Language should be added to the Risk Assessment Work

Plan section to show that air monitoring will be taking placeas is reported in the Health and Safety Plan, Section 5.Provisions should be included so that if significant levels ofcontaminants are demonstrated during monitoring, air willbe evaluated in the Risk Assessment as a migration pathing.

Response28. Language describing air monitoring detailed in the Health

and Safety Plan has been incorporated into sub-section5.4.2.2 (old 5.3.3.1) Section 5 of the Work Plan. We havealso committed to evaluating air as a migration pathway inthe Risk Assessment if significant levels of contaminants arefound in air during the field studies. Language added is asfollows:"During the conduct of field activities at the site, airbornevapors will be monitored to detect any release of chemicalsof concern to the air. This monitoring will be performedusing an Organic Vapor Analyzer (OVA). If concentrations

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above background are discovered, the air pathway will beevaluated as a potential migration pathway. Monitoring ofair is further described in the Health and Safety Plan,Appendix A, of this Work Plan."

i

Comment29. Sub-section 5.5 states that if potential impacts to the

environment are found, an environmental assessment willbe conducted, however, no methodology to be used todetermine an environmental impact is detailed hejre. Seealso the comments on sections 2.3.5 and 2.4. [

Response29. Three pages of descriptive language has been added to sub-

section 5-5, detailing methodologies to be used in the eventthat a potential impact to the environment is found. Due tothe length of this discussion it is not reproduced here.Please refer to the copy provided to you on 5 January.

Comment i-30. In sub-section 5.3.2 (now 5.4.1) the Superfurid Public Health

Evaluation Manual is referenced as the proposed source fortoxicological information on the contaminants of concern atthe site. However, since much of that information isoutdated, the Integrated Risk Information System (IRIS)database should be relied upon as the primary source ofcurrent toxicological data. In the absence of IRIS, theHealth Assessment Summary Tables printed by EPA on aquarterly basis, may serve as a secondary source oftoxicological information. j

Response i30. IRIS and the new "Risk Assessment Guidance for Siiperfund,

Parts A and B" have been added to Section 5.3 knd sub-section 5.4.3. Reference to the outdated "Superfurid PublicHealth Handbook" has been deleted from both parts;.

Commenti

31. In sub-section 5.3.3.1 the third sentence should be j modifiedto read, "they volatilize readily from surface water andsurface soil and thus are commonly not significant risk

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problems in those media, but may potentially be a risk inthe air."

Response31. Sub-section 5.3.3.1 has been modified to read, "Chlorinated

contaminants such as TCE readily volatilize from surfacewater and surface soil into the air. If there is a continuingrelease from these media there may be a risk to the airpathway. Subsurface soil is not a concern to the air pathwayas contaminants in this media cannot volatilize to a greatextent. Subsurface contamination may migrate into andwithin ground water from systems........"

Comment32. It is stated in sub-section 5.4.2.1 that no ARARs exist for

contaminants in soils in Pennsylvania or in the Federalregulations. While it is true that there are no legallyenforceable standards for contaminants in soil, applicableand relevant requirements can be determined, if necessary,based upon the best available science. The referencedstatement should be clarified accordingly.

Response32. Your comment is addressed to the old sub-section 5.4.2.1

which has been changed to 5.4.4.1 on the new page 5-7.During our meeting of 25 January you indicated that asentence on air modeling would suffice to satisfy yourcomment. We, therefore, propose to add the followinglanguage:"It is anticipated that the ARARs for the Transicoil site mayinclude Federal and State ground water and drinking waterregulations, (e.g., Federal Safe Drinking Water MCLs) andclean air regulations. The modeling efforts described insub-section 3.1.2 on page 3-2 will demonstrate whether anypotential health risks exist at the site. Modelinginformation will be used in the application of ARARs to thesite."

Comment33. Sub-section 5.5 indicates that if any environmental impacts

are found, an environmental assessment will be conducted.

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The methodology to be used to determine the impactsneeds to be presented. A description of the potentiallyimpacted biotic communities should be presented! here orin sub-section 2.3.5, Site Description. See also thecomments directed to sub-sections 2.3.5 and 2.4. I

Response i33. The revised Chapter 5 contains Section 5.5 which is a

detailed discussion of how an Environmental assessmentwill be conducted, if necessary, at the site. As noted aboveunder comment #29, due to the length of this new materialit is not reproduced here. Please advise if this revisedsection requires additional detail.

Section 6Comment34. In sub-section 6.1.2 1, the list of Remedial Action Objectives

should include, "to eliminate or mitigate the site's impacton identified environmental receptors. ji

Response ~ I34. Sub-section 6.1.2.1 has been changed to the following: "or

mitigate the site's impact on identified environmentalreceptors." ;

COMMENT

35. Sub-section 6.1.6 mentions table 6-1 which TJvas notincluded in the draft work plan. i|

Response i35. Reference to Table 6-1 has been deleted from the final

Work Plan. We propose to delete this item because it refersto a sample outline for the FS which is, in effect the FSTable of Contents. We feel it is premature to present a tableof contents now for the FS. , i

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Section 7Comment36. Figure 7-1 should include the appropriate addresses and

phone numbers for the named contacts.Response36. A new Table, 7-1, has been added listing names, addresses,

and telephone numbers of contacts for EPA, Transicoil,Eagle-Picher, and ERM.

Comment37. Sub-section 7.2 refers to Appendix C which was not

included in the draft work plan. Also stated in this sectionis that the duration of the project is expected to be 52•weeks, however, Figure 7-2 indicates 18 months.

Response37. Appendix C was not included in the draft Work Plan because

it is redundant to Figure 7-2. Reference to Appendix C isdeleted from the final Work Plan. The duration of theproject is 18 months as reflected in Figure 7-2. Languagesuggesting 52 weeks has been deleted.

APPENDIX B - QUALITY ASSURANCE PROJECT PLAN

Comment38. The Table of Contents does not list sections 15 and 16.Response38. Sections 15 and 16 do not exist in the QAPP.Comment39. In Section 4, Table 4-1, there are no duplicate samples

designated. However in Section 9, duplicate samples arespecified for every 20 samples. The table needs to beadjusted accordingly. A duplicate needs to be taken even ifthere are less than 20 samples per media/sampling event.

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Response39. The error in Table 4-1 has been corrected to reflect the

collection of duplicate samples described in Section! 9.Comment iI40. Table 4-1 has field blanks as a header, however, these are

"rinsates" according to the description presented in Section9. t

Response |40. The heading in Table 4-1 and the text in SectioA 9 have

been modified to consistently reflect the use of!rinsatesblanks. i

Comment41. Section 5 should include provisions for documenting the

source of reagents and supplies such as preservatives andpH buffers for field activities. !. I -

Response !41. Provisions for documenting the source of reagents and

supplies such as pH buffers and preservatives is included inSection 5. !

MISCELLANEOUS

Comment42. See attached sheets for the typographical errors that were

found in the work plan.Response j• i42. Each typo has been corrected in the final Wiark Plan

Product. |Typo Section 6; missing Table 6-1. We have deletedreferences to this table. It is, in effect, the table of; contentsfor the FS. See comment #35 above. Inclusion 6f the FSTable of Contents is irrelevant in the RI/FS Work Plan.

iWe have tried to consistently use trichloroethylene fortrichloroethene, however, they are both the same

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compound. There is no Section 8 to the Work Plan and nomention of trichloroethylene or trichloroethene in Section7.

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