RECORD OF DECISION DUBLIN TCE SITEThe Dublin TCE Site is located at 120 Mill Street in Dublin Borough, Bucks County, Pennsylvania (Figure 1) approximately 400 feet west of State Route

RECORD OF DECISIONDUBLIN TCE SITE

DECLARATION

SITE NAME AND LOCATION

Dublin TCE Site, Alternate Water Supply Operable UnitDublin Borough, Bucks County, Pennsylvania

STATEMENT OF BASIS AND PURPOSE

This decision document presents the selected remedial actionfor Operable Unit 1 (OU 1) of the Dublin TCE Site, in Dublin,Pennsylvania, which was chosen in accordance with ComprehensiveEnvironmental Response, Compensation, and Liability Act of 1980(CERCLA), as amended by the Superfund Amendments andReauthorization Act of 1986 (SARA), and, to the extentpracticable, the National Oil and Hazardous Substances PollutionContingency Plan (NCP). This decision document explains thefactual and legal basis for selecting the remedy for OperableUnit 1 of this Site.

The Commonwealth of Pennsylvania concurs with the selectedremedy. This unofficial concurrence is documented in a letterfrom PADER to EPA, dated' September 12, 1991. The informationsupporting this remedial action decision is contained in theAdministrative Record for this Site.

ASSESSMENT OF THE SITE

Actual or threatened releases of hazardous substances fromthis Site, if not addressed by implementing the response actionselected in this Record of Decision (ROD), may present animminent and substantial endangerment to public health, welfare,or the environment.

DESCRIPTION OF THE REMEDY

This Operable Unit is the first operable unit of at leasttwo operable units planned for the Site. This Operable Unit willprovide a permanent clean drinking water supply for theresidences and businesses whose ground water has been or maybecome contaminated by the Site. This early action remedy willbe incorporated into the final action taken at the Site toremediate the groundwater, soil, and surface water at the Site.Operable Unit Two (OU 2) will address the investigation andremediation of the groundwater, surface water, and soil at theSite.

The major components of the selected remedy include:

1. Development, construction, and operation of a new watersupply well within the plume of contamination oroperation of an existing well within the plume ofcontamination. Preference will be given to use of anexisting well so that this remedy can be implemented asquickly as possible, however, the decision on use of agroundwater well will be made based on a review of allrelevant factors.

2. Construction and operation of an air stripping andvapor phase carbon adsorption system (or similartreatment technology which is acceptable to EPA afterconsultation with PADER) for treatment of the waterextracted from the well described above. Treatedwater, which does not exceed the Maximum ContaminantLevels (MCLs) for the contaminants of concern, shall besupplied to the public water supply.

3. Expansion of the existing Dublin Borough public waterdistribution system with use of the well and treatmentsystem described above to provide clean water,according to the requirements of the Federal SafeDrinking Water Regulations and the State CommunityEnvironmental Control Regulations, through the publicwater supply, to the affected and potentially affectedresidences and businesses.

4. Monitoring of residential and commercial wells at homesnot addressed by the public water supply but which havethe potential for contamination until a finalgroundwater remedy is implemented at the Site.

5. Operation and maintenance of the selected remedy.

DECLARATION OF STATUTORY DETERMINATIONS

The selected remedy is protective of human health and theenvironment, complies with Federal and State requirements thatare legally applicable or relevant and appropriate to theremedial action, and is cost-effective. Although this interimaction is not intended to fully address the statutory mandate forpermanence and treatment to the maximum extent practicable, thisaction utilizes treatment and thus is in furtherance of thatstatutory mandate. Because this action does not constitute thefinal remedy for the Site, the statutory preference for remediesthat employ treatment that reduces toxicity, mobility, or volumeas a principal element, although partially addressed in thisremedy, will be more fully addressed by the final responseaction. Subsequent actions are planned to address fully thethreats posed by the conditions at this Site.

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Because this remedy will result in hazardous substancesremaining on-site above health-based levels, a review will beconducted within five years after commencement of remedial actionto ensure that the remedy continues to provide adequateprotection of human health and the environment.

, 'VX' : . DECbu k;,' " "

Edwin B. Erickson DateRegional AdministratorRegion III

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DUBLIN TCE SITERECORD OF DECISION

TABLE OF CONTENTS

I. Site Name, Location, and Description . . . . . . . . . . . 1

II. Site History and Enforcement Activity . . . . . . . . . . l

III. Highlights of Community Participation . . . . . . . . . 5

IV. Scope and Role of Operable Unit 1 . . . . . . . . . . . . 5

V. Summary of Site Characteristics . . . . . . . . . . . . . 6

VI. Summary of Site Risks . . . . . . . . . . . . . . . . . . 7

VIII. Alternatives . . . . . . . . . . . . . . . . . . . . . 8Alternative 1: NO ACTION . . . . . . . . . . . . . . . . 9Alternative 2: CONNECTION TO THE EXISTING DUBLIN

BOROUGH MUNICIPAL WATER SUPPLY . . . . . . . . . . 9Alternative 3: INSTALLATION OF A NEW WELL OR USE OF AN

EXISTING WELL OUTSIDE OF THE PLUME OFCONTAMINATION . . . . . . . . . . . . . . . . . . . 12

Alternative 4: TREATMENT OF WATER FROM RESIDENTIAL ANDBUSINESS WELLS WITH CARBON ADSORPTION SYSTEMS . . 15

Alternative 5: TREATMENT OF WATER FROM A NEW WELL OR ANEXISTING WELL WITHIN THE PLUME WITH A CARBONADSORPTION SYSTEM . . . . . . . . . . . . . . . . 17

Alternative 6: TREATMENT OF WATER FROM A NEW WELL OR ANEXISTING WELL WITHIN THE PLUME WITH AIR STRIPPINGAND VAPOR PHASE CARBON ADSORPTION . . . . . . . . . 20

Alternative 7: TREATMENT OF WATER FROM A NEW WELL OR ANEXISTING WELL WITHIN THE PLUME WITH ULTRAVIOLET(UV) OXIDATION .................. 24

IX. Summary of the Comparative Analysis of Alternatives ... 28A. Overall Protection . . . . . ............ 28B. Compliance with Applicable or Relevant and

Appropriate Requirements (ARARs) ........ ,29C. Long-Term Effectiveness and Permanence:....... 30D. Reduction of toxicity, mobility, or volume of the

contaminants through treatment: .......... 31E. Short Term Effectiveness: .............. 32F. Implementability .................. 33G. Cost . . . . . . . . . . . . . . . . . . . . . . . . 34H. State Acceptance: . . . . . . . . . . . . . . . . . . 34I.Community Acceptance: . . . . . . . . . . . . . . . . 34

X. Selected Remedy ..................... 34

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XI. Statutory Determinations . . . . . . . . . . . . . . . . 40A. Protection of Human Health and the Environment ... 40B. Compliance with ARARs . . . . . . . . . . . . . . . . 41

1. Chemical-Specific ARARs . . . . . . . . . . . . 412. Location-Specific ARARs . . . . . . . . . . . . 423. Action-Specific ARARs . . . . . . . . . . . . . 42

C. Cost-Effectiveness . . . . . . . . . . . . . . . . . 43D. Utilization of Permanent Solutions and Alternative

Treatment Technologies or Resource RecoveryTechnologies to the Maximum Extent Practicable . . 44

E. Preference for Treatment as a Principle Element ... 44

APPENDIX A- RESPONSIVENESS SUMMARYAPPENDIX B- ADMINISTRATIVE RECORD INDEXAPPENDIX C- ANALYTICAL RESULTS FROM REMOVAL ACTION

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I. Site Name, Location, and Description

The Dublin TCE Site is located at 120 Mill Street in DublinBorough, Bucks County, Pennsylvania (Figure 1) approximately 400feet west of State Route 313. The Site is located onapproximately 4 1/2 acres in size and is surrounded by residencesand businesses to the east, west and south. A fruit orchardborders the Site to the north and-west. The Site consists of oneone-story brick building surrounded by a parking lot. A firetower is located at the northern boundary of the property (Figure2).

The regional water supply primarily consists of private andpublic wells. The aquifer is classified as Class IIA, a currentsource of drinking water. Based on available information, theground water flows from southeast to northwest beneath the Siteand is controlled predominantly by fractures. Ground waterbeneath the Site flows towards residential and commercial wellsin Dublin Borough.

Site surface water drainage is expected to flow in anorthwestward direction via street drainage because the majorityof the property is currently paved with asphalt. Drainage notabsorbed by the fruit orchard located directly northwest of theSite, is collected by a drainage ditch situated on the northerncorner of the property near the fire tower. The ditch isbelieved to discharge into the headwaters of an unnamed perennialtributary of Morris Run, located approximately 1/2 mile northwestof the Site.

Specific information concerning groundwater and surfacewater flow will be confirmed during the Remedial Investigation/Feasibility Study (RI/FS) which is currently being performed byone potentially responsible party.

II. Site History and Enforcement Activity

The Site operated as a hosiery mill from the 1930s until1956. Dublin Hosiery Mills operated the Site from 1945 to 1956.Home Window Company of Pennsylvania, Incorporated manufacturedaluminum doors and windows at the property from 1956 to 1959.

Kollsman Motor Corporation (KMC) owned and operated the Sitefrom 1959 to 1971 and used it to manufacture miniature precisionmotors, gear trains, clutches, brakes and related electro-mechanical components which were used in manned aircraft andmissiles. Trichloroethylene (TCE) was used as a degreasingsolvent in this operation. Between 1959 and 1971, KMC used TCEat the rate of approximately 15 gallons per week. Spent TCE wasdisposed of at the Site in "chip" drums (i.e. drums used to storewaste metal parts from the manufacturing process) located behind

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the building. These drums had drainage holes on the bottom sothat the TCE drained out of the drums and onto the ground. TCEwas also poured on the ground behind the building. KMC sold theproperty to Kollsman Instrument Corporation (KIC) in 1971.

Athlone Industries, Incorporated (Athlone) purchased theproperty from KIC in 1973 and operated the Site from 1973 to1986. Athlone used the property to clean, stamp, package andstore baseballs and softballs. Safety Solvent No. 2, a solventcontaining approximately 10% trichloroethylene was used in 1982by Athlone as a degreasing solvent for the assembly of threestamping machines. A partially full 30-gallon drum of thissolvent was left on the premises after Athlone sold the propertyin 1986.

John H. Thompson purchased the property in 1986 and is thecurrent owner and operator of the Site. Mr. Thompson uses aportion of the Site to restore antique race cars and leases aportion of the Site to Laboratory Testing, Incorporated. LTIuses the property for metallurgical testing.

During a routine drinking water survey in the summer of1986, the Bucks County Health Department (BCHD) discovered levelsof TCE up to 1000 parts per billion (ppb) in 23 tap watersamples. Approximately 170 homes, apartments and businesses inDublin Borough were affected. BCHD issued advisories to thepublic on the best approach to curtail water usage and preventfurther exposure to TCE. For residences with TCE levels greaterthan 5 ppb, BCHD recommended the installation of carbon filters.For TCE levels above 500 ppb, the County cautioned residents notto use their tap water for bathing.

The EPA Region III Emergency Response Section received arequest from the BCHD to evaluate the Site on September 3, 1986.A preliminary assessment, conducted by EPA, determined thecurrent water usage status of all residential and commercialwells which were found to be contaminated with TCE.

On June 29, 1987, EPA entered into a CERCLA Section 106Consent Agreement and Order with John H. Thompson. Mr. Thompsonagreed to: (1) take action to assure that all residents andcommercial employees exposed to TCE levels greater than 5 ppbwould have an adequate treatment system in place or would besupplied with bottled water (as specified in the Work Planattached to the Consent Agreement and Order), (2) conductperiodic monitoring of all carbon filters and air strippers beingused by the residences and businesses to assure that the unitswere functioning properly, and (3) conduct periodic groundwatermonitoring of wells for all residences and businesses at risk inaccordance with the Work Plan.

This Consent Order and Agreement was amended in April 1991HR3QI562

to provide point-of-entry carbon filtration systems i.e.,treatment systems installed on the water source entering thehousehold, to all residential dwellings with groundwatercontamination greater than 5 ppb TCE. At businesses, eitherbottled water or point-of-use carbon filtration systems areprovided. This amendment addressed the risk posed by inhalationof TCE vapors released from the groundwater. Residences thatwere previously supplied with only point-of-use treatment systems(i.e. treatment systems located at the kitchen tap) are now beingsupplied with the point-of-entry systems. Residential welltesting conducted under this order indicated that groundwater iscontaminated with several volatile organic compounds (VOCs),including trichloroethylene (TCE), tetrachloroethylene (PCE) andvinyl chloride.

On June 4, 1990, the Commonwealth of Pennsylvania,Department of Environmental Resources (PADER) and SequaCorporation (successor in ownership to Kollsman Motor Corporationand Kollsman Instrument Corporation) entered into a Consent Orderand Agreement under the Commonwealths' Clean Streams Act. SequaCorporation agreed to investigate and abate the groundwatercontamination problems at or near the Site in accordance with theWork Plan attached to the Consent Order and Agreement. Under theConsent Order and Agreement executed by Sequa and PADER, Sequaalso agreed to submit a Recommended Remedial Action Plan whichwill address the contaminated groundwater and provide for a waterdistribution system.

John H. Thompson, at the request of PADER, installed twomonitoring wells at the Site in 1988. Eight additionalmonitoring wells were installed off of the 120 Mill Streetproperty under a separate study by Geraghty & Miller. Themonitoring wells installed both on-site as well as off-site showcontamination by volatile organic compounds, including TCE andvinyl chloride. Three municipal supply wells located in theBorough were tested for VOCs in 1991 by Dublin Borough for VOCs.No contamination was detected in these wells.

Soil and soil gas at the 120 Mill Street property weresampled during studies performed by John H. Thompson in 1988 andSequa Corporation in 1990 on behalf of PADER. Results indicatedthat the soil and soil gas on the property are contaminated withvolatile organic compounds, including TCE and vinyl chloride.

The Site scored a 28.9 under EPA's hazard ranking system.It was proposed for inclusion on the CERCLA National PrioritiesList (NPL) on October 26, 1989. The Site was finalized on theNPL on August 30, 1990.

In 1991, EPA conducted a Focused Feasibility Study (FFS) forOperable Unit 1 at the Site to evaluate remedial alternatives forproviding an alternate clean drinking water supply to the

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affected and potentially affected residences and businesses(referred to collectively as "affected parties") . The FFSincluded the supply of an alternate water source to 69 homes andbusinesses whose well water exceeded or had the potential, due togroundwater flow, to exceed the Maximum Contaminant Levels (MCL)set by EPA, or pose an excess cancer risk level of IxlO"06 orgreater for volatile organic compounds, including TCE, PCE andvinyl chloride. The MCL is an enforceable drinking waterstandard established within the Safe Drinking Water Act. If achemical did not have an MCL, EPA developed a IxlO"06 level whichmay result in one excess cancer among one million people exposedto the contaminant. Table 1 identifies the residences andbusinesses where remedial action levels, i.e. , MCLs or IxlO"06cancer risk levels, were exceeded or have the potential to beexceeded. The FFS also identified residences and businesseswhose well may be contaminated by VOCs from the Site if agroundwater remedial action is not implemented by 1995.

EPA issued a proposed plan on August 8, 1991 which describedthe remedy EPA preferred to implement for OU 1, as well as 6other alternatives. The remedy EPA preferred to implement was aconnection to the existing Dublin Borough water system, expansionof the system to include a water supply well within the plume ofcontamination, and treatment of this water with air stripping andvapor phase carbon adsorption prior to distribution to theaffected parties. A request for an extension of an additional 30days to the public comment period was made on August 13, 1991.The public comment period was extended to October 9, 1991. Afterthe 60-day public comment period closed, EPA reevaluated the 7alternatives within the proposed plan based upon commentsreceived. This record of decision (ROD) selects the remedialalternative for Operable Unit One which was preferred in theproposed plan.

EPA entered into a Consent Order and Agreement with SequaCorporation on August 15, 1991. This Consent Order and Agreementrequires Sequa Corporation to conduct a Remedial Investigation(RI) and Comprehensive Feasibility Study (FS) at the Site. TheRI/FS is expected to be completed in 1993. This RI/FS willaddress the groundwater, surface water and soils at the Site.

EPA conducted potentially responsible party searches in 1987and in 1990 and identified the following PRPs: Sequa Corporation(successor in ownership of KMC and KIC), Athlone Industries,Incorporated, and John H. Thompson. Sequa Corporation and JohnH. Thompson were sent "special notice" letters on August 22,1991. The letters indicated that EPA would not begin theremedial investigation or feasibility study for the Site until 90days from the date of the special notice letter provided that thepotentially responsible parties agreed to implement the RI/FS. Ageneral notice letter was sent to Athlone Industries,Incorporated on November 21, 1990 requesting participation in the

on-going negotiations between Sequa Corporation, John H. Thompsonand EPA for implementation of a RI/FS.

At least two federal lawsuits have been filed at the Site.These include Whistlewood Commons Associates v. Sun ChemicalCorporation, Athlone Industries. Incorporated, and John H.Thompson. United States District Court for the Eastern Districtof Pennsylvania, Civil Action No. 87-6407, and Susan Coburn,etal. v. Sun Chemical Corporation, Athlone Industries,Incorporated, and John H. Thompson, United States District Courtfor the Eastern District of Pennsylvania, Civil Action No. 88-0120.

III. Highlights of Community Participation

In accordance with CERCLA Section 117, the Proposed Plan andthe FFS for OU 1 were released to the public on August 8, 1991.These two documents were made available to the public in theAdministrative Record for this Site and the informationrepository maintained at the Dublin Borough Hall located at 119Maple Avenue in Dublin, PA and the EPA Docket Room in Region III,Philadelphia, PA. The notice of availability of these documentswas published in The Daily Intelligencer. The News Herald, TheMorning Call, and The Philadelphia Inquirer on August 8, 1991.In addition, a copy of the Proposed Plan was mailed toapproximately 100 people who requested information concerning theSite.

Due to a request for an extension to the comment period, the30-day public comment period was expanded to 60 days. Thecomment period began on August 8, 1991 and was concluded onOctober 9, 1991. The public was given additional opportunity tocomment on the Proposed Plan and Focused Feasibility Study at apublic meeting held at the Dublin Fire Hall on August 26, 1991.At this meeting, representatives from EPA and PADER answeredquestions and received comments about the Site, the remedialalternatives under consideration and the proposed remedy. Astenographic report of the public meeting was prepared by EPA. Aresponse to the comments received during the 60-day commentperiod is included as part of this ROD in the ResponsivenessSummary (APPENDIX A).

The index for the Administrative Record, upon which thisdecision document is based, is contained within APPENDIX B. Thisdecision document is also based upon comments contained withinthe stenographic report of the public meeting on August 26, 1991and other comments received by EPA, which are also included inthe Site file.

IV. Scope and Role of OU 1

This record of decision addresses the first operable unit at

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the Site. The ROD for this operable unit addresses drinkingwater. This remedial action provides an alternate water supplyfor approximately seventy (70) residences and businesses affectedor potentially affected by the Dublin TCE Site contamination.Table 1 lists the residences and businesses who will be suppliedby an alternate water source. The provision of an alternatewater supply will prevent the ingestion of and dermal contactwith contaminated groundwater and the inhalation of vapors fromcontaminated groundwater. This remedial action also provides formonitoring for VOCs of approximately (50) residential andcommercial wells which may be potentially impacted by thegroundwater contamination if a final groundwater remedy is notimplemented by 1995. Table 2 lists the residences and businesseswhose wells will be monitored.

The primary objective of this response is to supply cleanwater to residences and businesses whose wells are currently orpotentially affected by the Dublin TCE Site groundwatercontamination. The aquifer being used by the residences andbusinesses at or near the Dublin TCE Site is classified as ClassIIA, a current source of drinking water, in accordance with theEPA document "Guidelines for Groundwater Classification"( FinalDraft, December 1986). The primary risk to human health and theenvironment is from ingestion of, and contact with, groundwaterfrom wells that contain contaminants above the MCLs establishedunder the Safe Drinking Water Act, 42 U.S.C. Sections 300f to300j-26. The water supply must meet all federal and stateapplicable or relevant and appropriate standards. The responsewill address distribution of clean water to residences andbusinesses whose water supply is affected or potentially affectedby contamination from the Site.

The remedy described in this ROD is only part of the totalremedy for the Site. The remainder of the Site is beinginvestigated as part of a remedial investigation and feasibilitystudy, the results of which will be presented at a later date andused to select a remedy for the entire Site. The remedialalternative selected in this ROD will be consistent with theremedy selected for the entire Site.

V. Summary of Site Characteristics

All characteristics of the Dublin TCE Site will be fullydescribed and discussed after the Remedial Investigation andFeasibility Study have been completed and a report of theinvestigation and study are approved by EPA.

During former operations at the Dublin TCE Site, chemicalsolvents were used to degrease machined metal parts andequipment. The amount of solvent used between 1959 and 1971amounted to approximately 15 gallons per week. A 30-gallon drumof a solvent containing TCE was purchased for use during 1982 and

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the partially full drum was left at the 120 Mill Street propertyat the time of the sale of the property to John H. Thompson.

The amount of solvent spilled or otherwise released into theenvironment at the Dublin TCE Site is unknown. However, some ofthe chemical solvent has migrated through the soil column and hasentered the ground water system beneath the facility. Chemicalsampling of ground water from wells on the Dublin TCE Site andfrom wells near the Dublin TCE Site indicate that volatileorganic chemicals, including TCE, PCE and vinyl chloride, existin the ground water at levels of up to 10,000 ppb, 13 ppb and 28ppb, respectively. TCE and PCE are probable human carcinogensand vinyl chloride is a confirmed human carcinogen. These VOCsare mobile and soluble in groundwater.

The bedrock beneath the Site is fractured. Ground watermoves predominantly through the fracture system. Therefore,residential or other wells penetrating the same fractures orfracture systems containing contaminated ground water from theSite may become contaminated. Some residential and commercialwells are now contaminated by volatile organic compounds similarto those found at the Dublin TCE Site, including TCE. JohnThompson has, under a Consent Order with EPA, installed activatedcarbon units or supplied bottled water to homes and businesseswith TCE levels above 5 ppb to reduce these levels to safelevels. EPA has decided to develop and screen remedialalternatives to provide a permanent supply of clean water toresidences and businesses near the Site and to select a remedialalternative for an alternate water supply of drinking water inthis Record of Decision.

Between 1987 and 1990, a series of field investigations andresidential well monitoring at the Site confirmed the presence ofTCE in the soil and groundwater at and surrounding the Site.These investigations were conducted by John H. Thompson, SequaCorporation and Roy F. Weston for PADER, EPA and the WhistlewoodApartment Complex.

VI. Summary of Site Risks

Well sampling conducted under the Consent Order between Mr.Thompson and EPA indicates that the untreated groundwater atcertain residences and businesses is contaminated with VOCsincluding TCE, PCE and vinyl chloride at levels which exceed theMaximum Contaminant Levels (MCLs) for these chemicals.Residential and commercial well sampling has indicated TCE levelsup to 10,000 ppb, PCE levels up to 13 ppb and vinyl chloridelevels up to 28 ppb in the untreated groundwater. Degradationproducts of TCE and PCE in addition to vinyl chloride have beenidentified in the residential and commercial wells. Thesechemicals include cis- and trans- 1,2- dichloroethylene, 1,1-dichloroethylene, and 1,1- dichlorethane. 1,1,1 trichloroethane

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has also been identified.

The MCL is an enforceable drinking water standardestablished within the Safe Drinking Water Act. EPA willinitiate a remedial action if groundwater contains a particularchemical above the standard, or MCL, for that chemical. If a MCLhas not been developed for a chemical, EPA will use othercriteria when considering the need for remedial action. For thisremedial action, EPA has used the established MCLs or the "excesscancer risk level of IxlO""06", i.e. one excess cancer among onemillion people, to determine if remedial action is necessary.The criteria, i.e. remedial action level, used by EPA which wouldtrigger the need for remedial action for this operable unit andthe maximum levels identified at the Site are described in Table3. The MCL has been exceeded for vinyl chloride,trichoroethyene, tetrachloroethylene, and 1,l-dichloroethylene atthe affected residences and businesses near the Site. Therefore,a remedial action is justified.

A summary of the most recent analytical data fromresidential wells is contained within APPENDIX C. Average TCEconcentrations in the residential wells from 1986 to March 1991are indicated in Figure 3.

VIII. Alternatives

This section of the ROD describes the process of screeningand developing remedial alternatives and discusses in detail eachof the seven alternatives evaluated in the proposed plan.

The FFS studied and evaluated several options to determineif they could be applicable for use in providing an alternatewater supply. The NCP requires that the "No Action" alternativebe evaluated. The technologies determined to be most applicableto this action were developed into remedial alternatives. Thesealternatives, presented and discussed below, are:

• Alternative 1: No Action• Alternative 2: Connection to the Existing Dublin Borough

Municipal Water Supply• Alternative 3: Installation of a New Well or Use of an

Existing Well Outside of the Plume ofContamination

• Alternative 4: Treatment of Water from Residential andBusiness wells with Carbon AdsorptionSystems

• Alternative 5: Treatment of Water from a New Well orExisting Well within the Plume witha Carbon Adsorption System

• Alternative 6: Treatment of Water from a New Well orExisting Well within the Plume with AirStripping and Vapor-Phase Carbon Adsorption

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• Alternative 7: Treatment of Water from a New Well orExisting Well within the Plume with UVOxidation

Applicable or relevant and appropriate requirements (ARARs)which are identified for this remedial action are listed in Table4. Major ARARs pertaining to each alternative are identified inthe alternative description sections below.

Alternative 1: NO ACTION

The NCP requires that the "No Action" alternative beevaluated at every site to establish a baseline for comparisonwith the other alternatives. Under this alternative, EPA woulddiscontinue the monitoring program and discontinue the supply ofbottled water or carbon adsorption units to the affected parties.As a result, residences and businesses would use watercontaminated with volatile organic compounds. Because VOCs existat levels above the MCL and/or the cancer risk level of IxlO"06,public health would not be protected under the "No Action "alternative. Alternative 1 does not satisfy the primaryobjective of this ROD.

Alternative 2: CONNECTION TO THE EXISTING DUBLIN BOROUGHMUNICIPAL WATER SUPPLY

The general components of this alternative are:

A. Connecting affected parties into an extension of theDublin Borough municipal water system.

B. Removing existing carbon units or discontinuing bottledwater service for the affected residences andbusinesses and disposing of the carbon units inaccordance with all Federal and State regulations.

C. Abandoning affected and potentially affected wellswithin the plume of contamination and/or implementinginstitutional controls on the development and use ofprivate wells within the plume of contamination.

D. Conducting periodic sampling and monitoring at certainresidences and businesses not connected into the Dublinsystem to ensure that these homes do not becomeaffected by contamination from the Site.

E. Conducting periodic monitoring of the Dublin Boroughsupply wells for volatile organic compounds to ensurethat these wells do not become affected bycontamination from the Site.

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The Borough of Dublin operates a municipal water supply andpublic water distribution system. This alternative involvesexpanding the existing public water distribution system andsupplying the affected parties with uncontaminated water from theexisting water supply. The affected parties currently obtainwater from private wells. The existing municipal water supply issupplied by three wells, Well #1, Well #2, and Well #3 (Figure3). The capacity of the existing water supply system would needto be increased by approximately 50 gallons per minute (gpm) tosupply the affected parties. The existing water supply ispermitted by the Pennsylvania Department of EnvironmentalResources (PADER) and the Delaware River Basin Commission (DRBC)for this additional capacity.

The water would be distributed to the affected partiesthrough water mains constructed along North Main Street, MillStreet and a portion of Elephant Road (see Figure 3). Aconnection could be made to the Dublin water distribution systemat the intersection of Elephant Road and Deep Run Road. Watermains would be extended from this point south along Elephant Roadto Main Street, and then north along North Main Street toRickerts Road. A main would also be installed along Mill Streetfrom North Main Street to Cherry Lane to supply residences alongMill Street and on the northside of Maple Avenue to Cherry Lane.Each affected party would be connected to the water main and thewater use would be metered.

Dublin Borough Ordinance No. 164, requires that privatewells be abandoned, as a general rule, when a borough water lineexists to service a home or business. The Borough Ordinancedoes, however, exclude those residents and business owners andoperators, who have utilized private wells prior to theconstruction of the borough water line.

Under this alternative, the existing residential wells wouldbe abandoned and the existing in-house carbon filters would beremoved unless an agreement is reached between the property ownerand the Borough for continued use of the private well. If theproperty owner reached such an agreement, the property ownerwould maintain the in-house treatment system. These carbonfilters would be disposed of in accordance with the FederalResource Conservation Recovery Act (RCRA) and Pennsylvania'sSolid Waste regulations with preference given to recycling orregenerating this filters, if possible. These regulations areconsidered applicable. The spent carbon filters would beconsidered a RCRA characteristic waste if the toxiccharacteristic leaching procedure (TCLP) analysis performed onthis waste resulted in a VOC concentration greater that 0.5 partsper million. Otherwise, the waste would be disposed of inaccordance with RCRA Subtitle D regulations.

Under this alternative, the water mains and associated

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equipment would be transferred to the Dublin Borough WaterDepartment for its use. The affected parties would be billed forwater usage by the Borough at the standard rate, which wouldprovide sufficient revenue to finance the O&M for the water lineextension.

This alternative does not include provisions for additionalsystem capacity to serve new development in the area not affectedor potentially affected by the Site. This option does notprovide for additional fire protection, i.e., more protectionthan residences currently have.

Under the Federal Safe Drinking Water Act (SDWA) andPennsylvania's Safe Drinking Water Regulations (PASDWR), whichare applicable requirements, the Borough would be required tosample the wells which supply the water distribution systemperiodically to ensure that all criteria identified within theseregulations are met.

In addition, because these wells are outside the plume ofcontamination and the plume has not been fully defined,monitoring for VOCs on a quarterly basis would be necessary toensure that the contamination from the Site does not spread tothese wells. This monitoring will be required at least until afinal ground water remedy is implemented at the Site.

Because Well #3 is downgradient of the Site and is a wellopen to many bedrock fractures, there is a possibility that thiswell may become affected by the contamination from the Site.Also, even though the other wells (Wells #1 and #2) are locatedupgradient of the Site, increased pumping from these wells mayspread the contamination by redirecting the natural groundwaterflow. If contamination did spread to Well #1, Well #2, or Well#3, a treatment system would be required so that water dischargedfrom these wells meets all of the requirements of SDWA andPASDWR.

This alternative would provide the residences and businesseswith a permanent, regulated water supply. This would ensure thatthe residences and businesses are supplied with a safe, cleandrinking water source that meets all Federal and State drinkingwater regulations.

The estimated costs for this alternative are presentedbelow. Detailed cost information is provided in the FocusedFeasibility Study. The costs assume that each of the residencesand businesses listed in Table 1 would be connected to the watermain and that the wells at the residences and businesses listedin Table 2 would be monitored on a quarterly basis for volatileorganic compounds until a final groundwater remedy is implementedat the Site. The present worth costs are based on a 30 year lifeand a 10% discount rate. The estimated time for implementation

12

of this alternative is 6 to 12 months.

• Capital Costs: $2,200,000• Annual O & M Costs: $138,000• Present Worth: $2,600,000

Alternative 3: INSTALLATION OF A NEW WELL OR USE OF ANEXISTING WELL OUTSIDE OF THE PLUME OFCONTAMINATION


A. Constructing a new water supply well or using anexisting water supply well outside of the plume ofcontamination and incorporating this well into theexisting Dublin Borough municipal water distributionsystem.

B. Connecting the affected parties into an extension ofthe Dublin Borough municipal water system andsupplementing the current capacity of the existingBorough supply system with enough water from the welldescribed in A to supply the these residences andbusinesses.

C. Removing existing carbon units or discontinuing bottledwater service for the affected residences andbusinesses and disposing of the carbon in accordancewith all Federal and State regulations.

D. Abandoning affected and potentially affected wellswithin the plume of contamination and/or implementinginstitutional controls on the development and use ofprivate wells within the plume of contamination.

D. Conducting periodic sampling and monitoring at certainresidences and businesses not connected into the Dublinsystem to ensure that these homes do not becomeaffected by contamination from the Site.

E. Conducting periodic sampling and monitoring of the newwater supply well to ensure that this well does notbecome affected by contamination from the Site.

This option involves construction of a new water supply wellor use of an existing private well outside the plume ofcontamination. Water from this well would be pumped into anexpanded Dublin Borough water distribution system. A submersiblepump capable of delivering approximately 50 gallons per minute(gpm) at the required system pressure would be installed in the

flR30!572

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well. This well pump would be operated at a rate necessary tosupply only the affected parties and would supplement theexisting system with the required additional water. A water linewould be installed from the well to the borough's storage tankfacility located on South Main Street or another storage facilityspecifically constructed for the water discharged from this well.The well water would supplement the water currently beingsupplied to the borough's storage tank facility by the threeexisting municipal wells (Figure 3).

The water would be distributed to the affected partiesthrough water mains constructed along North Main Street, MillStreet and a portion of Elephant Road. A connection could bemade to the Dublin water distribution system at the intersectionof Elephant Road and Deep Run Road. Water mains would beextended from this point south along Elephant Road to MainStreet, and then north along North Main Street to Rickerts Road.A main would also be installed along Mill Street from North MainStreet to Cherry Lane to supply residences along Mill Street andthe northside of Maple Avenue to Cherry Lane. Each affectedparty would be connected to the water main and the water usewould be metered.


Under this alternative, the existing residential wellswould be abandoned and the existing in-house carbon filters wouldbe removed unless an agreement is reached between the propertyowner and the Borough for continued use of the private well. Ifthe property owner reached such an agreement, the property ownerwould maintain the in-house treatment system. These carbonfilters would be disposed of in accordance with the FederalResource Conservation Recovery Act and Pennsylvania's Solid Wasteregulations with preference given to recycling or regeneratingthis filters, if possible. These regulations are consideredapplicable because the spent carbon filters would be considered aRCRA characteristic waste if the toxic characteristic leachingprocedure (TCLP) analysis performed on this waste resulted in aVOC concentration greater that 0.5 parts per million. Otherwise,the waste would be disposed of in accordance with RCRA Subtitle Dregulations.

Under this alternative, the well, water mains and associatedequipment would be transferred to the Dublin Borough WaterDepartment for its use. The affected parties would be billed for

flR3GI573

14

water usage by the Borough at the standard rate, which wouldprovide sufficient revenues to finance the O&M for the supplywell and the water line extension.

This alternative does not include provisions for additionalsystem capacity to serve new development in the area not affectedor potentially affected by the Site. This option does notprovide for additional fire protection, i.e., more protectionthan residents currently have.

Under the Federal Safe Drinking Water Act and Pennsylvania'sSafe Drinking Water Regulations, which are applicablerequirements, the Borough would be required to sample the wellswhich supply their system, including the new well, to ensure thatall criteria identified within these regulations are met.

The location of a new well or use of an existing well wouldbe determined during the remedial design phase of remedyimplementation. Because this new well would be outside the plumeof contamination, a potential exists for the contamination fromthe Site to spread to this well. This potential will be reducedby properly locating and designing the well during the remedialdesign phase. Monitoring of this well for VOCs on a quarterlybasis would be necessary to ensure that the contamination fromthe Site does not spread to this well. This monitoring will berequired at least until a final ground water remedy isimplemented at the Site.


The estimated costs for this alternative are presentedbelow. Detailed cost information is provided in the FocusedFeasibility Study. The costs assume that each of the residencesand businesses listed in Table 1 would be connected to the watermain and supplied with water from the new well and that the wellsat the residences and businesses listed in Table 2 would bemonitored on a quarterly basis for volatile organic compoundsuntil a final groundwater remedy is implemented at the Site. Thepresent worth costs are based on a 30 year life and a 10%discount rate. The project would be technically feasible andimplementable. The estimated time for implementation of thisalternative is 9 to 12 months.

• Capital Costs: $2,600,000• Annual O&M Costs: $169,000• Present Worth: $3,300,000

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Alternative 4: TREATMENT OF WATER FROM RESIDENTIAL ANDCOMMERCIAL WELLS WITH CARBON ADSORPTIONSYSTEMS


A. Providing the affected and potentially affectedresidences with point-of-entry individual granularactivated carbon (GAC) treatment units and providingaffected and potentially affected businesses witheither point-of-use carbon treatment systems or bottledwater.

B. Maintaining the treatment systems by periodicallymonitoring the influent and effluent from thesystems and replacing the spent carbon, as necessary.

C. Removing or installing a bypass system around theexisting GAC units or discontinuing bottled waterservice for the affected parties and disposing of thecarbon in accordance with all Federal and Stateregulations once the groundwater is completelyremediated.

D. Conducting periodic sampling and monitoring at selectedresidences and businesses not connected into the Dublinsystem until a final groundwater remedy is implementedto ensure that these residences do not become affectedby contamination from the Site.

In this alternative, continued individual GAC unit orbottled water service would be provided to the residential andcommercial wells currently monitored under the Order between JohnH. Thompson and EPA in addition to the additional homes andbusinesses identified as potentially affected by thecontamination (see Table 1). The treatment system for privateresidences with 5 ppb or greater of TCE would include a point-of-entry system. The untreated and treated water would be sampledperiodically. Businesses would be supplied with either bottledwater or a point-of-use carbon treatment system and would bemonitored periodically. Treated water would meet all Federal andState drinking water quality standards for the VOCs identified atthe Site.

The GAC adsorption system would include two beds of carbonoperating in series. The GAC adsorption process involvescontacting the contaminated groundwater with activated carbon.The organic molecules contacting the activated carbon particlesurface would be held there by physical or chemical forces. Oncethe carbon is saturated with organics, the spent carbon must be

flR30!575

16

either removed and replaced with virgin or off-site-regeneratedcarbon or the spent carbon must be regenerated on-site. It wasassumed that the spent carbon would be removed and replaced witheither virgin or off-site-regenerated carbon. Spent carbon wouldbe disposed of or treated in accordance with Federal ResourceConservation Recovery Act and Pennsylvania's Solid Wasteregulations. These regulations are considered applicable becausethe spent carbon filters may be considered a RCRA characteristicwaste if the TCLP analysis performed on this waste resulted in aVOC concentration greater than 0.5 parts per million. Otherwise,the waste would be disposed of in accordance with RCRA Subtitle Dregulations.

Operation and maintenance of the in-house carbon systemswould be required until the final ground water remediation iscomplete. At that time, the units could be removed or bypassed.These carbon filters would be disposed of in accordance with allFederal and State regulations. The operation and maintenance(O&M) of the system must be the responsibility of some agreed-upon authority. This authority must be able to gain access tothe homes to complete O&M and sampling. This authority would beresponsible for routinely sampling the water effluent from thetreatment systems at the individual residences and businesses toensure that all criteria related to the contamination at the Siteare met. Because this alternative would require treatment ofwater prior to discharge to the individual residence or business,periodic monitoring of the effluent from the treatment systemwould be necessary to ensure that the treatment equipment isfunctioning properly.

Because this is not a public distribution system, monitoringand treatment would be provided only for contaminants related tothe Site.

The estimated costs for this alternative are presentedbelow. Detailed cost information is provided in the FocusedFeasibility Study. The costs assume that each of the residencesand businesses listed in Table 1 would be supplied with aindividual GAC treatment systems or bottled water, asappropriate, and residences and businesses listed in Table 2would be monitored on a quarterly basis for volatile organiccompounds until a final groundwater remedy is implemented at theSite. The present worth costs are based on a 30 year life and a10% discount rate. This remedy would be technically feasible andimplementable. The estimated time for implementation of thisalternative is 1 to 2 months.

• Capital Costs: $100,000• Annual O&M Costs: $390,000• Present Worth: $2,800,000

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Alternative 5: TREATMENT AND SUPPLY OF WATER FROM A NEW WELL ORAN EXISTING WELL WITHIN THE PLUME WITHA CARBON ADSORPTION SYSTEM


A. Developing, constructing, and operating a newwater supply well within the plume of contamination oroperation of an existing well within the plume ofcontamination and incorporating this well into theexisting Dublin Borough municipal water distributionsystem.

B. Constructing and operating of liquid-phase GAC carbonadsorption system for treatment of the water extractedfrom the well described above.

C. Connecting the affected parties into an extension ofthe DuMin Borough municipal water system andsupplementing the current capacity of the existingBorough supply system with enough treated water fromthe well described in A to supply the these residencesand businesses.

D. Removing existing carbon units or discontinuing bottledwater service for the affected residences andbusinesses and disposing of the carbon in accordancewith all Federal and State regulations.

E. Abandoning affected and potentially affected wellswithin the plume of contamination and/or implementinginstitutional controls on the development and use ofthe wells within the plume of contamination.

F. Monitoring of residential and commercial wells at homesnot addressed by the public water supply but which havethe potential for contamination.

This option involves construction of a new water supply wellor use of an existing private well inside the plume ofcontamination, treating the groundwater by removing the volatileorganic compounds.

A submersible pump capable of delivering approximately 50gallons per minute (gpm) at the required system pressure would beinstalled in the well. The well water would be pumped to angranular activated carbon (GAC) adsorption system located at theground surface. This well pump would be operated at a ratenecessary to supply the affected parties and would supplement theexisting system with the required additional water. A water line

18

would be installed from the discharge of the GAC adsorptionsystem to the borough's storage tank facility located on SouthMain Street or another storage facility specifically constructedfor the water discharged from this well.

The GAC adsorption system would include two beds of carbonoperating in series. The GAC adsorption process involvescontacting the contaminated groundwater with activated carbon.The organic molecules contacting the activated carbon particlesurface would be held there by physical or chemical forces. Oncethe carbon is saturated with organics, the spent carbon must beeither removed and replaced with virgin or off-site-regeneratedcarbon or the spent carbon must be regenerated on-site. It wasassumed, for costing purposes, that the spent carbon would beremoved and replaced with either virgin or off-site-regeneratedcarbon. A final design cost may provide information indicatingthat on-site regeneration of carbon is more economical. Thecarbon filtration system would treat the water to comply withFederal and State drinking water quality standards. Spent carbonwould be disposed of or treated in accordance with all Federaland State regulations.

One limitation in using GAC treatment involves theadsorption of vinyl chloride. Vinyl chloride is a degradationproduct of TCE and has been identified in the groundwater at theSite. Large quantities of GAC are necessary for the adsorptionof vinyl chloride. Therefore, as the concentration of vinylchloride in the groundwater increases with increased degradationof TCE, an increase in the quantity of GAC necessary fortreatment of the contaminants would be required.

The treated water, initially pumped to the Borough'sstorage facility or similar facility, would be distributed to theaffected parties through water mains constructed along North MainStreet, Mill Street and a portion of Elephant Road. A connectioncould be made to the Dublin water distribution system at theintersection of Elephant Road and Deep Run Road. Water mainswould be extended from this point south along Elephant Road toMain Street, and then north along North Main Street to RickertsRoad. A main would also be installed along Mill Street fromNorth Main Street to Cherry Lane to supply residences along MillStreet and properties on the northside of Maple Avenue to CherryLane. Each affected party would be connected to the water mainand the water use would be metered.

The location of a new well or use of an existing well wouldbe determined during the remedial design phase of remedyimplementation.

Dublin Borough Ordinance No. 164, requires that private

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19

wells be abandoned, as a general rule, when a borough water lineexists to service a home or business. The Borough Ordinancedoes, however, exclude those residents and business owners andoperators, who have utilized private wells prior to theconstruction of the borough water line.

Under this alternative, the existing residential wells wouldbe abandoned and the existing in-house carbon filters would beremoved unless an agreement is reached between the property ownerand the Borough for continued use of the private well. If theproperty owner reached such an agreement, the property ownerwould maintain the in-house treatment system. These carbonfilters would be disposed of in accordance with the FederalResource Conservation Recovery Act and Pennsylvania's Solid Wasteregulations with preference given to recycling or regeneratingthis filters, if possible. These regulations are consideredapplicable because the spent carbon filters may be considered aRCRA characteristic waste if the TCLP analysis performed on thiswaste resulted in a VOC concentration greater than 0.5 parts permillion. Otherwise, the waste would be disposed of in accordancewith RCRA Subtitle D regulations.

Under this alternative, the water mains and associatedequipment would be transferred to the Dublin Borough WaterDepartment for its use. The party implementing the remedy(either the PRPs or the Commonwealth of Pennsylvania under aState Superfund Contract) will assure that the remedy is properlyoperated and maintained. Operation and maintenance of the welland carbon system would be required until the final groundwaterremediation is complete. Once remediation is complete, thecarbon filtration system could be bypassed or removed and thewell could continue to be used to supply the residents.Agreements would be necessary between Dublin Borough, the partyimplementing the remedy and the well or property owner for accessto the well. The affected parties would be billed for waterusage by the Borough at the standard rate, which would providesufficient revenues to finance the O&M for the supply well andthe water line extension.


Under the Federal Safe Drinking Water Act and Pennsylvania'sSafe Drinking Water Regulations, which are applicablerequirements, the Borough would be required to sample the wellswhich supply their system, including the new well, to ensure thatall criteria identified within these regulations are met.

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20

Because this alternative would require treatment of waterprior to discharge to the water storage facilities, periodicmonitoring of the effluent from the treatment system would benecessary to ensure that treatment equipment is functioningproperly.


The estimated costs for this alternative are presentedbelow. Detailed cost information is provided in the FocusedFeasibility Study. The costs assume that each of the residencesand businesses listed in Table 1 would be connected to the watermain and that the wells at the residences and businesses listedin Table 2 would be monitored on a quarterly basis for volatileorganic compounds until a final groundwater remedy is implementedat the Site. The present worth costs are based on a 30 year lifeand a 10% discount rate. This alternative is technicallyfeasible and implementable. The estimated time for implementationof this alternative is 12 to 15 months.

• Capital Costs: $3,000,000• Annual Operation and Maintenance (O & M) Costs: $250,000• Present Worth: $4,500,000

Alternative 6: TREATMENT OF WATER FROM A NEW WELL OR ANEXISTING WELL WITHIN THE PLUME WITH AIRSTRIPPING AND VAPOR-PHASE CARBONADSORPTION


A. Developing, constructing, and operating of a new watersupply well within the plume of contamination oroperation of an existing well within the plume ofcontamination and incorporating this well into theexisting Dublin Borough municipal water supplysystem.

B. Constructing and operating an air stripping andvapor-phase carbon adsorption system for treatment ofthe water extracted from the well described above.

C. Connecting the affected parties into an extension ofthe Dublin Borough municipal water system andsupplementing the current capacity of the existing

fiR30!580

Borough supply system with enough water from the welldescribed in paragraph A, above, to supply theresidences and businesses.

D. Removing existing carbon units or discontinuing bottledwater service for the affected residences andbusinesses and disposing of the carbon in accordancewith all Federal and State regulations.

E. Abandoning affected and potentially affected wellswithin the plume of contamination and/or implementinginstitutional controls on the development and use ofthe wells within the plume of contamination.

F. Monitoring of residential and commercial wells at homesnot addressed by the public water supply but which havethe potential for contamination until a finalgroundwater remedy is implemented.

This option involves construction of a new water supply wellor use of an existing private well inside the plume ofcontamination.

A submersible pump capable of delivering approximately 50gallons per minute (gpm) at the required system pressure would beinstalled in the well. The well water would be pumped to an airstripper located at the ground surface. This well pump would beoperated at a rate necessary to supply the affected parties andwould supplement the existing system with the required additionalwater. A water line would be installed from the discharge of theair stripper to the borough's storage tank facility located onSouth Main Street or another storage facility specificallyconstructed for the water discharged from this well.

A packed tower air stripper with countercurrent flow wouldbe used to treat the contaminated groundwater. The contaminatedgroundwater would be pumped to the top of the tower and fed downby gravity through the loosely packed fill material in the tower.As the water moves through the packing, air would be forcedthrough the packing from the base of the tower, and VOCs would betransferred from the water to the air. The air stripping systemwould treat the^water to comply with Federal and State drinkingwater quality standards. This alternative assumes that liquid-phase GAC adsorption would not be necessary to further treat theeffluent from the air stripper.

The contaminated air stream discharged from the air stripperwould be treated in a vapor-phase GAC adsorption system prior todischarge to the atmosphere. The discharged air would meet theapplicable requirements under the RCRA and Pennsylvania's Air

BR30I58I

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Quality Control Regulations. The GAC adsorption system wouldinclude two beds of carbon operating in series. The vapor-phaseGAC adsorption process is identical to the process described forliquid-phase GAC described in Alternative 5 except a gas (air) ispassed through the carbon beds instead of a liquid (water). Itwas assumed, for costing purposes, the spent carbon would beremoved and replaced with either virgin or off-site regeneratedcarbon. A final design cost may provide information indicatingthat on-site regeneration of carbon is more economical. Spentcarbon would be disposed of or treated in accordance with theapplicable Federal RCRA and State Solid Waste Managementregulations.

The water, once pumped to the Borough's storage facility orsimilar storage facility, would be distributed to the affectedparties through water mains constructed along North Main Street,Mill Street and a portion of Elephant Road. A connection couldbe made to the Dublin water distribution system at theintersection of Elephant Road and Deep Run Road. Water mainswould be extended from this point south along Elephant Road toMain Street, and then north along North Main Street to RickertsRoad. A main would also be installed along Mill Street from NorthMain Street to Cherry Lane to supply residences along Mill Streetand properties on the northside of Maple Avenue to Cherry Lane.Each affected party would be connected to the water main and thewater use would be metered.



Under this alternative, the existing residential wells wouldbe abandoned and the existing in-house carbon filters would beremoved unless an agreement is reached between the property ownerand the Borough for continued use of the private well. If theproperty owner reached such an agreement, the property ownerwould maintain the in-house treatment system. These carbonfilters would be disposed of in accordance with the FederalResource Conservation Recovery Act and Pennsylvania's Solid Wasteregulations with preference given to recycling or regeneratingthis filters, if possible. These regulations are consideredapplicable because the spent carbon filters may be considered aRCRA characteristic waste if the TCLP analysis performed on this

AR30I582

23

waste results in a VOC concentration greater than 0.5 ppm.Otherwise, the waste would be disposed of in accordance with RCRASubtitle D regulations.

Under this alternative, the water mains and associatedequipment would be transferred to the Dublin Borough WaterDepartment for its use. The party implementing the remedy (eitherthe PRPs'or the Commonwealth of Pennsylvania under a StateSuperfund Contract) will assure that the remedy is properlyoperated and maintained. Operation and maintenance of the well,air stripper and vapor-phase GAC adsorption system would berequired until the final groundwater remediation is complete.Once remediation is complete, the air stripper and GAC adsorptionsystem could be bypassed or removed and the well could continueto be used to supply the residents. An agreement would benecessary between Dublin Borough, the party implementing theremedy and the well or property owner for access to the well.The affected parties would be billed for water usage by theBorough at the standard rate, which would provide sufficientrevenues to finance the O&M for the supply well and the waterline extension.

This alternative does not include provisions for additionalsystem capacity to serve new development in the area not affectedor potentially affected by the Site. This option does notprovide for additional fire protection, i.e., more protectionthat residents currently have.

Under the Federal Safe Drinking Water Act and Pennsylvania'sSafe Drinking Water Regulations, which are applicablerequirements, the Borough would be required to sample the wellswhich supply their system, including the treated water from thenew well, to ensure that all criteria identified within theseregulations are met.

Because this alternative would require treatment of waterprior to discharge to the water storage facilities, periodicmonitoring of the effluent from the treatment system would benecessary to ensure that treatment equipment is functioningproperty.


The estimated costs for this alternative are presentedbelow. Detailed cost information is provided in the FocusedFeasibility Study. The costs assume that each of the residences

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24

and businesses affected or potentially listed in Table 1 would beconnected to the water main and that the wells at the residencesand businesses listed in Table 2 would be monitored on aquarterly basis for volatile organic compounds until a finalgroundwater remedy is implemented at the Site. The present worthcosts are based on a 30 year life and a 10% discount rate. Thisalternative is technically feasible and implementable. Theestimated time for implementation of this alternative is 12 to 15months.


Alternative 7: TREATMENT OF WATER FROM A NEW WELL OR ANEXISTING WELL WITHIN THE PLUME WITHULTRAVIOLET (UV) OXIDATION


A. Developing, constructing, and operating of a newwater supply well within the plume of contaminationor operation of an existing well within the plume ofcontamination and incorporating this well into theexisting Dublin Borough municipal water distributionsystem.

B. Demonstration of UV oxidation technology during atreatability study to be conducted at the Site.

C. Constructing and operating an UV oxidation system,based on information obtained during the treatabilitystudy, for treatment of the water extracted from thewell described above.

D. Connecting the affected parties into an extension ofthe Dublin Borough municipal water system andsupplementing the current capacity of the existingBorough supply system with enough treated water fromthe well described in paragraph A, above, to supply thethese residences and businesses.

E. Removing existing carbon units or discontinuing bottledwater service for the affected residences andbusinesses and disposing of the carbon in accordancewith all Federal and State regulations.

F. Abandoning affected and potentially affected wellswithin the plume of contamination and/or implementinginstitutional controls on the development and use of

A D o n i c- «

25i

private wells within the plume of contamination.

G. Monitoring of residential and commercial wells at homesnot addressed by the public water supply but which havethe potential for contamination until a finalgroundwater remedy is implemented.

This option involves construction of a new water supply wellor use of an existing private well inside the plume ofcontamination and treating the groundwater by destroying thevolatile organic compounds. A submersible pump capable ofdelivering approximately 50 gallons per minute (gpm) at therequired system pressure would be installed in the well. Thewell water would be pumped to an ultraviolet oxidation systemlocated at the ground surface. This well pump would be operatedat a rate necessary to supply the affected parties and wouldsupplement the existing system with the required additionalwater. A water line would be installed from the discharge of theUV oxidation system to the borough's storage tank facilitylocated on South Main Street or another storage facilityspecifically constructed for the water discharged from this well.

UV oxidation would destroy the VOCs present in thecontaminated groundwater. This technology uses UV radiationalone or in tandem with ozone and/or hydrogen peroxide to oxidizeorganics. The contaminated groundwater is fed from the well intothe reactor, which contains the UV lamps. In the reactor,hydrogen peroxide and ozone may be injected, if required. Theozone is generated through the ozone generator using air orliquid oxygen as the source. Under the influence of ultravioletlight, the ozone and hydrogen peroxide are converted intohydroxyl radicals (OH~) . The hydroxyl radicals generated or theozone, hydrogen peroxide, or UV radiation would oxidize theorganics to carbon dioxide, water and salts. Ozone which is nottransferred to the reaction would be destroyed in an ozonedecomposition unit. This alternative assumes that additionaltreatment such as liquid-phase GAC adsorption would not benecessary to further treat the effluent from the UV oxidationunit.

The discharged air from the decomposition unit would meetthe applicable Federal Clean Air Act, RCRA and the PennsylvaniaAir Quality Control Regulations.

Because UV oxidation technology is a. relatively newtechnology and it has not been demonstrated at the Site, atreatability study would be required prior to full-scaleimplementation. This treatability study would provideinformation on design criteria and costs necessary for full-scaleimplementation. It is estimated that the treatability study

AR30I585

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would take six months to complete.

The water, once pumped to either the Borough's storagefacility or similar facility, would be distributed to theaffected parties through water mains constructed along North MainStreet, Mill Street and a portion of Elephant Road. A connectioncould be made to the Dublin water distribution system at theintersection of Elephant Road and Deep Run Road. Water mainswould be extended from this point south along Elephant Road toMain Street, and then north along North Main Street to RickertsRoad. A main would also be installed along Mill Street fromNorth Main Street to Cherry Lane to supply residences along MillStreet and properties on the northside of Maple Avenue to CherryLane. Each affected party would be connected to the water mainand the water use would be metered.



Under this alternative, the existing residential wells wouldbe abandoned and the existing in-house carbon filters would beremoved unless an agreement is reached between the property ownerand the Borough for continued use of the private well. If theproperty owner reached such an agreement, the property ownerwould maintain the in-house treatment system. These carbonfilters would be disposed of in accordance with the FederalResource Conservation Recovery Act and Pennsylvania's Solid Wasteregulations with preference given to recycling or regeneratingthis filters, if possible. These regulations are consideredapplicable because the spent carbon filters may be considered aRCRA characteristic waste if the TCLP analysis performed on thiswaste resulted in VOC concentrations greater than 0.5 ppm.Otherwise, the waste would be disposed of in accordance with RCRASubtitle D regulations.

Under this alternative, the water mains and associatedequipment would be transferred to the Dublin Borough WaterDepartment for its use. The party implementing the remedy(either the PRPs or the Commonwealth of Pennsylvania under aState Superfund Contract) will assure that the remedy is properlyoperated and maintained. Operation and maintenance of thewell and the UV oxidation system would be required until the

flR30J586

27

final groundwater remediation is complete. Once remediation iscomplete, the UV oxidation system could be bypassed or removedand the well could continue to be used to supply the residents.An agreement would be necessary between Dublin Borough, theparty implementing the remedy, and the well or property owner foraccess to the well. The affected parties would be billed forwater usage by the Borough at the standard rate, which wouldprovide sufficient revenues to finance the O&M for the supplywell and the water line extension.


Under the Federal Safe Drinking Water Act and Pennsylvania'sSafe Drinking Water Regulations, which are applicablerequirements, the Borough would be required to sample the wellswhich supply their system to ensure that all criteria identifiedwithin these regulations are met.

Because this alternative would require treatment of waterprior to discharge to the water storage facilities, periodicmonitoring of the effluent from the treatment system would benecessary to ensure that treatment equipment is functioningproperty.


The estimated costs for this alternative are presentedbelow. Detailed cost information is provided in the FocusedFeasibility Study. The costs assume that each of the residencesand businesses listed in Table 1 would be connected to the watermain and that the wells at the residences and businesses listedin Table 2 would be monitored on a quarterly basis for volatileorganic compounds until a final groundwater remedy is implementedat the Site. The present worth costs are based on a 30 year lifeand a 10% discount rate. This alternative is technicallyfeasible and implementable. The estimated time forimplementation of this alternative is 18 to 21 months. Thisincludes 6 months for a treatability study.


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28

IX. Summary of the Comparative Analysis of Alternatives

Each of the remedial alternatives for this operable unit arecompared and evaluated against nine criteria to determine whichremedial alternative and combination of technologies andmanagement or process options will best meet the primaryobjective of this ROD. These nine criteria are:

Threshold Criteria

-Overall protection of human health and the environment-Compliance with applicable or relevant and appropriaterequirements

Primary Balancing Criteria

-Reduction of toxicity, mobility, or volume-Implementability-Short-term effectiveness-Long-term effectiveness-Cost

Modifying Criteria

-Community Acceptance-State Acceptance

A. Overall Protection of Human Health^ and the Environment:

A primary requirement of CERCLA is that the selectedremedial action be protective of human health and theenvironment. A remedy is protective if it eliminates, reduces,or controls current and potential risks posed through eachexposure pathway to acceptable levels through treatment,engineering controls, or institutional controls.

When properly designed and sufficiently tested, alternatives2 through 7 would protect human health by providing a cleandrinking water source to the affected parties and by monitoringadditional residences which may be potentially affected by theVOC contamination. The water which would ultimately bedistributed to the affected parties would meet or exceed allfederal and state drinking water standards. Drinking waterstandards are established within the Federal Safe Drinking WaterAct and Pennsylvania's Safe Drinking Water Regulations. Periodicwater sampling would be employed as part of these alternatives toensure the protection of human health.

Alternatives 4, 5, 6 and 7 would be the most protective of

AR30I588

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human health and the environment by not only supplying a cleandrinking water source to the affected parties but by alsoreducing and controlling the risk through treatment of thegroundwater and preventing of the spread of contamination.

Alternatives 2 and 3 would not reduce the risk posed by thespread of the plume of contamination.

Alternative 1 would not be protective of human health andthe environment because the affected parties would be exposed toVOCs via ingestion or dermal contact of groundwater, orinhalation of VOC vapors from the groundwater.

B. Compliance with Applicable _pr_R_eleyant__and AppropriateRegu i rements (ARARs)

Section 121(d) of CERCLA requires that remedial actions atCERCLA sites at least attain legally applicable or relevant andappropriate federal and State standards, requirements, criteria,and limitations which are collectively referred to as "ARARs",unless such ARARs are waived under CERCLA Section 121(d)(4).Applicable requirements are those substantive environmentalprotection requirements, criteria, or limitations promulgatedunder federal or State law that specifically address hazardoussubstances found at the Site, the remedial action to beimplemented at the Site, the location of the Site, or othercircumstances present at the Site. Relevant and appropriaterequirements are those substantive environmental protectionrequirements, criteria, or limitations promulgated under federalor State law which, while not applicable to the hazardousmaterials found at the Site, the remedial action itself, the Sitelocation or other circumstances at the Site, nevertheless addressproblems or situations sufficiently similar to those encounteredat the Site that their use is well suited to the Site. ARARs mayrelate to the substances addressed by the remedial action(chemical-specific), to the location (location-specific), or themanner in which the remedial action is implemented (action-specific) .

Table 4 identifies Applicable and Relevant or AppropriateRequirements for the alternatives developed in this ROD.

Alternatives 2 through 7 would meet the respective ARARs forthe Federal and State environmental laws for this action.

Once the remedy is implemented, the water supply provided inAlternatives 2 and 3 would need to be periodically checked toensure that the water supply does not become degraded shouldvolatile organic compounds from the Site migrate into the wellsused in these alternatives.

Once the remedy is implemented, the water supply provided inAlternatives 4, 5, 6, and 7 would need to be periodically

AR30I589

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monitored to ensure that the treatment processes used areperforming effectively. In addition, the air stream effluentfrom the treatment processes used in Alternatives 6 and 7 wouldneed to be monitored periodically to ensure compliance with theFederal Clean Air Act, RCRA and Pennsylvania's Air ResourceRegulations. The carbon used in Alternatives 4, 5, and 6 wouldneed to comply with guidelines for treatment and disposalcontained within the Resource Conservation and Recovery Act.

Alternative 1 would not meet the respective ARARs for theFederal and State environmental laws for this action.

C. Lgng-Term Effectiveness and Permanence:

Long-term effectiveness and permanence refers to the abilityof a remedy to maintain reliable protection of human health andthe environment over time. This criteria evaluation includesconsideration of residual risk and the adequacy and reliabilityof controls.

Alternatives 2, 3, 5, 6, and 7 provide a permanent cleandrinking water supply which would be regulated under the SDWA andPennsylvania'a Safe Drinking Water regulations. The water supplywould not only be monitored routinely for VOCs but for othercontaminants as set forth in the Federal and State regulations.Operation and maintenance of the water supply system would beturned over to the Dublin Borough Water Department.

Alternatives 2 through 7 all require long-term maintenanceand monitoring. Monitoring of the wells used in Alternative 2and 3 would be required to determine if the plume ofcontamination has spread to these wells. Monitoring andmaintenance of the treatment systems used in Alternatives 4through 7 would be critical because the breakdown of thetreatment systems would result in the distribution ofcontaminated water to residents. Operation of two GAC adsorptionunits in series in Alternative 4, 5, and 6 will reduce the riskof exposure to volatile organic compounds through the groundwateror air caused by saturation of the carbon bed. Treatment ordisposal of the spent carbon generated during the operation ofAlternatives 4, 5 and 6 would be required until the groundwateris remediated to an acceptable level. On-site and off-siteequipment for the regeneration of spent GAC is readily available.

The treatment technologies employed in Alternatives 4, 5,and 6 are well established, reliable technologies which have beenproven effective at the site and at similar Superfund sites.These treatment technologies are capable of reducing theconcentration of volatile organic compounds in the groundwater,and the air discharge in Alternative 6, to acceptable levels.The treatment technology employed in Alternative 7 has beenproven effective in destroying volatile organic compounds from

AR30I590

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groundwater at sites similar to the Dublin TCE Site, but atreatability study would have to be performed prior to full-scaleoperation at the Site to confirm the technology's effectiveness.

Alternatives 5, 6, and 7 are the most consistent with thelong-term remediation of the Dublin TCE Site. The treatmentoptions which are part of these alternatives would help reducethe amount of volatile organic chemicals in the environment.Sampling and monitoring required in Alternatives 5, 6 and 7 couldbe integrated into the final groundwater remedy employed for theentire Site.

Alternative 4 is not considered a permanent remedy.Monitoring would be required at approximately 70 residences andbusinesses until the groundwater is remediated to an acceptablelevel. Because this is not considered a public water supply,routine monitoring would only be required for identification ofhazardous substances found at the Site. An authority would needto be established to perform the operation and maintenance ofthis alternative.

Alternative 1 is not considered a permanent remedy becausean unacceptable level of risk would be associated with using thecontaminated groundwater as a drinking water supply.

Because all alternatives would result in hazardoussubstances remaining at the Site above levels for unlimited useand unrestricted exposure, a five year review will be conducted.

D. Reduction of toxicitv, mobility, or volume of the contaminantsthrough treatment;

This evaluation criteria addresses the degree to which atechnology or remedial alternative reduces toxicity, mobility, orvolume of hazardous substances.

Alternatives 4, 5, 6 and 7 are the only alternatives whichwould result in a reduction of volatile organic chemicals in theaquifer. Alternative 7 completely destroys the contaminants inthe immediate environment and, therefore, no residual waste isgenerated. Alternatives 4, 5 and 6 would remove contaminantsfrom the immediate environment, although treatment or disposal ofthe residual (spent carbon) in a safe and effective manner wouldbe required.

Alternatives 4, 5, 6, and 7 are the only alternatives whichwould help to inhibit further migration of the contaminants inthe aquifer. Mobility and volume of the contaminants would bereduced. In addition, these four alternatives would reduce thetoxicity of the contaminants in the aquifer via carbon treatment,air stripping or UV oxidation.

flR30!59l

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Alternatives 1, 2, and 3 would not act to reduce the volume,toxicity, or mobility of contaminants in the aquifer.

E. Short Term Effectiveness:

Short-terra effectiveness addresses the period of time neededto achieve protection of human health and the environment and anyadverse impacts that may be posed during the construction andoperation period until remediation goals are achieved.

Alternative 4 would take the shortest amount of time toimplement requiring approximately 1 to 2 months to implement.Alternative 4 would be the alternative least likely to impact theenvironment during construction and implementation.

Alternatives 2 and 3 would take approximately 4 to 11 monthslonger to implement than Alternative 4 because installation ofwater lines, and, possibly, installation of a well, would benecessary.

Alternative 5 and 6 could take approximately 9 to 14 monthslonger to implement than Alternative 4 because installation ofwater lines, possibly a well, and a treatment system would benecessary. Alternative 7 would take the longest time toimplement because a treatability study would be required prior toremedy implementation.

Installation of a well within the plume of contamination andthe treatment system, as described in Alternatives 5, 6, and 7,would pose the greatest risk to workers during implementation ofthe remedy. Possible exposure to volatile organic compoundsduring these installation processes could occur.

Installation of the wells, water lines, and treatmentsystems as described in Alternatives 2 through 7 would not posea significant risk to workers or the community as long as safetyprocedures are properly followed.

Alternatives 2 and 3 potentially may cause the contaminationto spread. Since one of the Dublin Borough municipal supplywells (Well #3) is downgradient of the plume of contamination andbecause a final groundwater remediation system and contaminantcontainment system is not in place at the Site, an increase inpumping from this well may decrease the time which it takes forthe TCE and other contaminants to reach this well. AlthoughPublic Supply Wells #1 and #2 are located upgradient of the Site,testing would be necessary during the design phase of remedyimplementation to determine if increased pumping from these wellswould spread the contamination. This testing would also berequired for the wells used in Alternative 3. As long as use ofthe well in Alternative 3 would not spread the contamination,this alternative would not pose an environmental risk.

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F. Implementabilitv

Implementability refers to the technical and administrativefeasibility of a remedy, from design through construction,operation, and maintenance. It also includes coordination offederal, State, and local governments to cleanup the Site.

Alternatives 4, 5, 6, and 7 would require initialoperational treatment system testing and periodic sampling toensure efficient operation of the treatment system. Thetreatment technologies used in Alternatives 4, 5, and 6 are wellestablished and have been proven reliable at the Site as well asat other sites. Maintenance and monitoring of Alternatives 5, 6,and 7 would be performed much more easily than the maintenance ofAlternative 4 because only one treatment system would be requiredinstead of approximately 70 individual treatment systems.

Because vinyl chloride is a degradation product of TCE, itspresence in the aquifer may increase with time. Significantlymore GAC is necessary to treat vinyl chloride as compared to TCE.Therefore, Alternatives 4 and 5, which use GAC treatment, mayrequire significantly more carbon to meet the Drinking WaterStandards for vinyl chloride than originally estimated. Thisincrease in carbon usage will impact the operation andmaintenance of these alternatives because more frequentreplacement of the spent carbon will be necessary.

Alternatives 3, 5, 6, and 7 would require the identificationand, possibly, the installation of a well prior toimplementation. This would involve additional investigations,although data generated to date at the Site under PADER andothers should help to identify a well quickly.

Alternative 7 incorporates a relatively new technology whichdoes not have the established reputation as a treatmenttechnology for VOC-contaminated groundwater as compared toAlternatives 4, 5, and 6. A treatability study would benecessary for this alternative.

Alternative 4 accommodates new homes to the system moreeasily than any other alternative. Accommodation of new homes tothe systems described by Alternatives 5, 6, and 7 may requireadditional treatment equipment and additional wells or theexpansion of the existing wells. Alternative 2 and 3 also mayrequire additional wells or the expansion of the existing wellsif new homes require an alternate water supply. In addition,Alternatives 2 and 3 may require treatment equipment if the wellsused in these alternatives become contaminated.

Services and materials are readily available for allalternatives.

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G. Cost:

This criteria examines the estimated costs for each remedialalternative. For comparison, capital, annual O&M, and presentworth costs are shown in Table 5.

The costs assume that 69 connections into a new water linewould be made and that 56 residences and businesses would bemonitored for four years until a final groundwater remedy isimplemented. The lowest cost alternative is Alternative 2 at$2,600,000. The most expensive alternative is alternative 6 witha present worth cost of $5,000,000.

H. State Acceptance:

The Commonwealth of Pennsylvania has reviewed the Record ofDecision and has concurred with the selected remedy. Thisunofficial concurrence is documented in a letter from PADER toEPA, dated September 12, 1991.

I.Community Acceptance;

Comments received from the Borough of Dublin and communitymembers indicated general support for EPA's proposed alternative,Alternative 6. The Borough of Dublin believed that Alternative 2would be the most easily implemented alternative but stated thatthey would be willing to work with EPA and the PRPs inimplementing Alternative 6. The Borough of Dublin expressedconcern over the costs and implementation time associated withAlternative 6.

One potentially responsible party indicated that this EarlyAction should be implemented in stages. Theses stages wouldinclude immediate connection of the affected parties to theexisting public distribution system (as described in Alternative2) and, then, once the RI/FS is complete, installing groundwaterwells within the plume of contamination for both treatment andsupply of groundwater. Use of the existing public distributionsystem would be modified to include the installation of an airstripper in case the existing supply wells became contaminated.One potentially responsible party indicated that other treatmenttechnologies should be considered for vapor-phase treatment ofthe air discharged from the air stripper described in Alternative6.

X. selected Remedy and Performance Standards

The Selected Remedy is Alternative 6. This operable unitaddresses the provision of clean water to affected parties nearthe Dublin TCE Site. After the RI/FS is completed, a remedy forthe entire Site will be developed. To the extent practicable,the remedy selected for future operable units will be consistent

35

with Operable Unit One. The selected remedy consists of thefollowing components:

Installation and operation of a new or existing watersupply well.

- Construction and operation of a system for thetreatment of the water extracted from the welldescribed above.

Expansion of the existing Dublin Borough publicdistribution system with use of the well and treatmentsystem described above to provide clean water to theaffected parties.

Monitoring of the residential and commercial wells athomes not serviced by the public distribution system.

- Operation and maintenance of the selected remedy.

Each component of the remedy and its design and performancestandard(s) will be described in turn.

1. Installation and operation of a well

A. Description of the Component of the Remedy

This component will include development, construction, andoperation of a new water supply well within the plume ofcontamination or operation of an existing well within theplume of contamination. The plume of contamination isdefined as the portion of the drinking water aquifer at ornear the Dublin TCE Site which contains levels of thecontaminants of concern above the detection level of EPAAnalytical Method 524.2, as described at 40 CFR Part 141.The chemicals of concern include but are not limited to:tetrachloroethene, trichloroethene, vinyl chloride, cis-1,2-dichloroethylene,trans-l,2-dichloroethylene, 1,1-dichloroethylene, and 1,1,1-trichloroethane. The list ofthe chemical of concern may be expanded by EPA based oninformation gathered during the Remedial Investigation/Feasibility Study (RI/FS).

The location and construction details of the new or existingwater supply well will be finalized and approved by EPAduring the design stage of the selected remedialalternative. Use of an existing well will be investigatedfirst so that this early action can be implemented asquickly as possible , however, the decision on use of agroundwater well will be made by EPA based on a review ofall relevant factors.

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This well shall be capable of supplying water to theaffected parties identified in Table 1, and to any partiesthat become affected or may become affected by thecontamination in the future, as determined by EPA.

B. Performance Standards

Implementation of the component of the remedy described inl.A., above, is a performance standard.

The performance standard for disposal of the welldevelopment wastes (i.e. soil boring cuttings, pump-testwater, etc.), shall be the requirements of the ResourceConservation and Recovery Act (RCRA) Regulations and thePennsylvania Solid Waste Regulations including: 40 CFR Part261 Subpart A Section 261.3, Subpart C Section 261.24, andSubpart D Section 261.31 (regarding the listing andidentification of characteristic hazardous waste); 40 CFRPart 262 Subparts A-E (regarding standards applicable togenerators) and the substantive requirements for thetreatment, storage, and disposal of hazardous wastes setforth in 40 CFR Part 263 (regarding transporters ofhazardous wastes) and 40 CFR Part 264 Subparts B-H(regarding general requirements for Treatment, Storage andDisposal facilities); 40 CFR 268 Subparts C Section 268.30and Subpart E (regarding restriction of hazardous waste landdisposal and storage of hazardous waste); 25 PA CodeSections 75.259 through 75.270.42 which establish Staterequirements for the generation, transportation, storage andtreatment of hazardous wastes (specifically, 25 PA Code75.262 requirements for generators of hazardous wastes, 25AP Code Section 75.263 requirements for the transportationof hazardous wastes, and 25 PA Code Section 75.264requirements for the treatment, storage and disposal ofhazardous wastes; 25 PA Code 261.24 and 273.421 (regardingthe handling of residual and other waste and thedetermination of hazardous waste by the Toxic CharacteristicLeaching Procedure).

2. Construction and operation of a crroundwater treatmentsystem


Construction and operation of an air stripping andvapor-phase carbon adsorption (or thermal destructionunit) for treatment of the water extracted from thewell described in paragraph l, above.

If necessary, based upon results of chemical sampling,a liquid-phase carbon adsorption unit(s) will bedesigned and installed on the water discharge of the

AR30I596

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air stripper to ensure that the water delivered to theresidences and businesses meets the MCLs describedbelow.


Implementation of the component of the remedy describedin 2.A., above, is a performance standard.

The performance standard for each contaminant ofconcern in the effluent water from the air stripper,which is supplied to public water system that willserve the affected parties, shall be the MCL for thatcontaminant as promulgated under the Safe DrinkingWater Act, 42 U.S.C. § 300f to 300J-26, and set forthat 40 CFR § 141.61(a). The MCLs for the chemicals ofconcern are:

Substance MCLfug/1)

Tetrachloroethene 5Trichloroethene 5Vinyl Chloride 2cis-l,2-dichloroethylene 70trans-l,2-dichloroethylene 1001,i-dichloroethylene 71,1,1-trichloroethane 200

The performance standard for the air emissions from thestripping unit shall be the requirements of the RCRAregulations set forth at 40 CFR 264 Subpart AA- AirEmission Standards for Process Vents. The totalorganic emissions from all affected process vents atthe facility are required to be below 1.4 kg/hr and 2.8mg/yr under this regulation. Because the Site lieswithin an ozone non-attainment area, the air emissionsfrom the treatment unit shall comply with the NationalAmbient Air Quality Standards (NAAQS) under the CleanAir Act (40 CFR Part 50.1-3, 50.9, Appendix D, AppendixH) for the release of volatile organic emissions. Thevinyl chloride air emissions will also comply withSection 112 of the Clean Air Act, 42 U.S.C § 7412National Emission Standard for Hazardous Air Pollutants(NESHAPs). The relevant and appropriate NESHAP forvinyl chloride is set forth at 40 CFR Part 61, SubpartF. The air emissions will also comply with the Stateregulations set forth in 25 PA Code S127.l2(a)(5).This regulation requires that emissions be reduced tothe minimum obtainable levels through the use of bestavailable technology, as defined in 25 PA Code §121.1.

The performance standard for disposal of spent carbon

AR3QI597

38

filters from the liquid- and vapor-phase carbontreatment systems and any other hazardous wastegenerated during treatment system installation shall bethe requirements of the Resource Conservation andRecovery Act (RCRA) Regulations and the PennsylvaniaSolid Waste Regulations including: 40 CFR Part 261Subpart A Section 261.3, Subpart C Section 261.24, andSubpart D Section 261.31 (regarding the listing andidentification of characteristic hazardous waste); 40CFR Part 262 Subparts A-E (regarding standardsapplicable to generators) and the substantiverequirements for the treatment, storage, and disposalof hazardous wastes set forth in 40 CFR Part 263(regarding transporters of hazardous wastes) and 40 CFRPart 264 Subparts B-H (regarding general requirementsfor Treatment, Storage and Disposal facilities); 40 CFR268 Subparts C Section 268.30 and Subpart E (regardingrestriction of hazardous waste land disposal andstorage of hazardous waste); 25 PA Code Sections 75.259through 75.270.42 which establish State requirementsfor the generation, transportation, storage andtreatment of hazardous wastes (specifically, 25 PA Code75.262 requirements for generators of hazardous wastes,25 AP Code Section 75.263 requirements for thetransportation of hazardous wastes, and 25 PA CodeSection 75.264 requirements for the treatment, storageand disposal of hazardous wastes; 25 PA Code 261.24 and273.421 (regarding the handling of residual and otherwaste and the determination of hazardous waste by theToxic Characteristic Leaching Procedure).

3. Expansion of the Dublin Public Water DistributionSystem


The water extracted from the well described inparagraph 1, above, and treated with the treatmentsystem described in paragraph 2, above, shall bedelivered to the existing Dublin Borough water supplysystem either through the currently existing storagefacility or through a storage facility constructedspecifically for the new well.

The existing Dublin Borough public water distributionsystem shall be expanded by the installation of watermains along North Main Street, Mill Street and aportion of Elephant Road.

Connections shall be made from these newly constructedwater mains to the affected or potentially affectedparties with the installation of water meters at each

AR3QI598

39i ' ' ~ -

residence and business.

All areas impacted by the construction activitiesduring remedy implementation and operation andmaintenance shall be graded, restored and revegetated,as necessary.

The existing residential wells shall be abandoned, ifappropriate, and the existing in-house carbon filtersshall be removed and disposed of.



The performance standard for disposal of the in-housecarbon filters shall be the requirements of theResource Conservation and Recovery Act (RCRA)Regulations and the Pennsylvania Solid WasteRegulations including: 40 CFR Part 261 Subpart ASection 261.3, Subpart C Section 261.24, and Subpart DSection 261.31 (regarding the listing andidentification of characteristic hazardous waste); 40CFR Part 262 Subparts A-E (regarding standardsapplicable to generators) and the substantiverequirements for the treatment, storage, and disposalof hazardous wastes set forth in 40 CFR Part 263(regarding transporters of hazardous wastes) and 40 CFRPart 264 Subparts B-H (regarding general requirementsfor Treatment, Storage and Disposal facilities); 40 CFR268 Subparts C Section 268.30 and Subpart E (regardingrestriction of hazardous waste land disposal andstorage of hazardous waste); 25 PA Code Sections 75.259through 75.270.42 which establish State requirementsfor the generation, transportation, storage andtreatment of hazardous wastes (specifically, 25 PA Code75.262 requirements for generators of hazardous wastes,25 AP Code Section 75.263 requirements for thetransportation of hazardous wastes, and 25 PA CodeSection 75.264 requirements for the treatment, storageand disposal of hazardous wastes; 25 PA Code 261.24 and273.421 (regarding the handling of residual and otherwaste and the determination of hazardous waste by theToxic Characteristic Leaching Procedure).

4. Monitoring of Residential and Commercial Wells


Residential and commercial wells at certain residencesand businesses not addressed by the public water supply

&R301599

40

but which have the potential for contamination shall bemonitored on a quarterly basis for the chemicals ofconcern using EPA Analytical Method 524.2 until EPAdeems that it is no longer necessary. The initial listof these residences and businesses is given in Table 2.This list may be expanded by EPA based on the resultsof design of this remedy and information gatheredduring the RI/FS.



5. Operation and Maintenance of the Selected Remedy

A. Description of Remedy

Operation and maintenance of the newly installed well,and treatment system shall continue until theconcentrations of contaminants of concern in the waterextracted from the new production well, located withinthe plume of contamination, have been reduced to theMCLs indicated in paragraph 2, above. The well will besampled on a quarterly basis for at least 30 years. Ifsampling confirms that the MCLs have been attained atthe well (prior to treatment) and remain at therequired levels for twelve consecutive quarters,operation of the treatment system can be suspended.The groundwater pumped from the well shall bypass thetreatment system and be distributed to the affectedresidences. If, subsequent to the treatment systemshutdown, quarterly monitoring shows the groundwaterconcentration of any contaminant of concern to be abovethe MCLs, the treatment system shall be restarted andcontinued until the MCLs have once more attained fortwelve consecutive quarters.



XI. statutory Determinations

A. Protection of Human Health and the Environment

The selected alternative is protective of human health.This remedy will reduce the risk posed by ingestion of, dermalcontact with and inhalation of vapors from TCE in the groundwaterused as a water supply for the affected parties throughtreatment. The drinking water supplied to the residences and

AR301600

41

businesses will meet the MCLs listed in Table 3. The ail-discharged from the air stripper will meet all Federal and Stateair quality regulations. The selected remedy will also help tocontain the plume of contamination.

No unacceptable short-term or cross-media risks will becaused by implementation of this remedy. The remedialtechnologies employed in the selected remedy are proven to reducethe concentrations of volatile organic chemicals to acceptablelevels.

B. Compliance with ARARs

The Selected Remedy will comply with all applicable orrelevant and appropriate chemical-, location -, and action-specific ARARs. Those ARARs are:

1. Chemical-Specific ARARs

a. Applicable Maximum Contaminant Levels (MCLs)promulgated under the Safe Drinking Water Act, 42U.S.C. § 300f to 300J-26, and set forth at 40CFR § 141.61 (a) are:

Substance MCLfug/1)

Tetrachloroethene 5Trichloroethene 5Vinyl Chloride 2cis-1,2-dichloroethylene 70trans-l,2-dichloroethylene 1001,1-dichloroethylene 71,1,1-trichloroethane 200

b. PA 25 Code Sections 109.202(1), and 109.201(2),109.203 and 109.503 which set forth drinking waterquality standards at least as stringent as federalstandards (MCLs) and additional State requirements(secondary maximum contaminant levels) for publicwater systems including permit design andconstruction, source quality and sitingrequirements, are applicable.

c. EPA Directive 9355.0-28, which sets forth riskassociated with emissions from Superfund airstrippers at Superfund groundwater sites, is to beconsidered.

d. The air discharge from the treatment system willbe implemented consistent with the requirementsof the Resource Conservation and Recovery Act(RCRA) regulations 40 CFR 264 Subpart AA- Air

RR301601

42

Emission Standards for Process Vents. Theseregulations are applicable. The total organicemissions from all affected process vents at thefacility are required to be below 1.4 kg/hr (3Ib/hr) and 2.8 mg/yr (3.1 tons/yr) underthis regulation.

e. The vinyl chloride emissions from the treatmentsystem will comply with Section 112 of the CleanAir Act, 42 U.S.C. § 7412 National EmissionStandard for Hazardous Air Pollutants (NESHAPs).The relevant and appropriate NESHAP for vinylchloride is set forth at 40 CFR Part 61, SubpartF.

f. The air emissions from the treatment system shallcomply with the National Ambient Air QualityStandards (NAAQS) under the Clean Air Act (40 CFRPart 50 Sections 50.1-3,50.9, Appendix D, AppendixH) for the release of volatile organic emissionsfrom the air strippers (the Site lies within anozone non-attainment area).

2. Location-Specific ARARs

a. The substantive requirements of the Delaware RiverBasin Commission (18 CFR Part 430)regulations are applicable. These regulationsestablish requirements for the extraction ofgroundwater within the Delaware River Basin.

3. Action-Specific ARARs

a. 25 PA Code §123.31 is applicable to the remedialalternative and prohibits malodors detectablebeyond the property line.

b. 25 PA Code §127.12(a)(5) will apply to the newpoint source air emission, if it is not exemptunder 25 PA Code §127.14, that result from theimplementation of the remedial alternative,requiring that emissions be reduced to the minimumobtainable levels through the use of bestavailable technology (BAT).

c. The groundwater treatment will be implementedconsistently with the requirements of the ResourceConservation and Recovery Act (RCRA) Regulations,including: 40 CFR Part 261 Subpart A Section261.3, Subpart C Section 261.24, and Subpart DSection 261.31 (regarding the listing andidentification of characteristic hazardous waste);

43, i-

40 CFR Part 262 Subparts A-E (regarding standardsapplicable to generators) and the substantiverequirements for the treatment, storage, anddisposal of hazardous wastes set forth in 40 CFRPart 263 (regarding transporters of hazardouswastes) and 40 CFR Part 264 Subparts B-H(regarding general requirements for Treatment,Storage and Disposal facilities); 40 CFR 268Subparts C Section 268.30 and Subpart E (regardingrestriction of hazardous waste land disposal andstorage of hazardous waste). These regulationsare applicable.

d. 25 PA Code §§ 75.259 through 75.270.42 whichestablish State requirements for the generation,transportation, storage and treatment of hazardouswastes (specifically, 25 PA Code § 75.262requirements for generators of hazardous wastes,25 PA Code § 75.263 requirements for thetransportation of hazardous wastes, and 25 PA Code§ 75.264 requirements for the treatment, storageand disposal of hazardous wastes) are applicablerequirements.

e. The Occupational Safety and Health Act (OSHA)regulations (29 CFR 1910) are applicable for allactivities conducted during this remedial action.

f. 25 PA Code §§261.24 and 273.421 are applicableregulations for the handling of residual and otherwaste and for the determination of hazardous wasteby the Toxic Characteristic Leaching Procedure.

C. Cost-Effectiveness

The selected remedy is cost-effective in providing overallprotection in proportion to cost, and meets all otherrequirements of CERCLA. The NCP, 40 CFR Section300.340(f)(ii)(D), requires EPA to evaluate cost-effectiveness bycomparing all the alternatives which meet the thresholdcriteria - protection of human health and the environment andcompliance with ARARs - against three additional balancingcriteria: long-term effectiveness and permanence; reduction oftoxicity, mobility, or volume through treatment; and short-termeffectiveness. The selected remedy meets these criteria andprovides for overall effectiveness in proportion to its cost.The estimated present worth cost for the selected remedy is$5,000,000.

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D. Utilization of Permanent Solutions and Alternative TreatmentTechnologies or Resource Recovery Technologies to the MaximumExtent Practicable

Because of the limited scope of this operable unit, apermanent remediation of the ground water was not considered.However, a permanent source of clean drinking water to residencesand businesses affected or potentially affected by the Site willbe developed. Secondary objectives of this operable unit are toreduce the migration of contaminants and to prevent current orfuture exposure to the contaminated ground water in the aquifer,through treatment and containment. Extraction and treatment ofcontaminants in the aquifer will achieve some reduction in thecontamination at the Site, and will enhance the attainment of apermanent remedy at the Site. Subsequent actions will addressfully the principal threats posed by the conditions at the Site.The remedy(ies) selected in future operable units will employpermanent solutions to the maximum extent practicable.

E. Preference for Treatment as a Principle Element

The selected remedy employs a treatment process which hasbeen demonstrated to effectively reduce VOC contamination atother Superfund sites. Therefore, the statutory preference forremedies that employ treatment as a principal element issatisfied.

FIGURES 1 THROUGH 3

DUBLIN TCE EARLY ACTION ROD

AR30I605

IIIIIIIIIIIIIIII

ORIGINAL

SOUffCC: (7.9 MIMUTC SCfflf S) U.S.O.S. SfOMMSTiJ* 4 OOYliSTOWN, FA, QUAD.

SITg LOCATION MAPDUBLIN WATER SUPPLY

-SCAtt i: 24000Fiaur<* -i

IXIUSCOHPGRATTQN

I—I RoickiuiaiWeUs(tvenfe TCE resultsfrom 19S6-1990) ppb

BaraafhWeUs(TCE not detected)DUBLIN TCE SITE MAP

DvbUn Boroughy PA

1 APPENDIX A

DUBLIN TCE SUPERFUND SITE

RESPONSIVENESS SUMMARYFOR THE

PROPOSED PLAN FOR EARLY ACTION

TABLE OF CONTENTS

I. Overview . . . . . . . . . . . . . . . . . . . . . . . 1

II. Background . . . . . . . . . . . . . . . . . . . . . . 2

III.Summary of Responses toIssues and Concerns . . . . . . . . . . . . . . . . . . 3

A. Remedial Alternative Preferences . . . . . . . . . . . 4B. Questions/Concerns on EPA's Proposed Alternative ... 7C. General Cost/Funding Issues ............. 12D. Potentially Responsible Parties ........... 15E. Risk of Contaminants and Other Health Concerns .... 16F. Technical Questions/Concerns on Remedial Alternatives 17G. Questions/Concerns on FFS and Proposed Plan ..... 25

1. Structure/Format of Reports . . . . . . . . . . . . 252. Background and Assumption Information ....... 28

H.. Coordination with State and Local Agencies . . .... 30I.. Superfund Enforcement Process ............ 3 3

RESPONSIVENESS SUMMARYDUBLIN TCE SUPERFUND SITE

This community relations responsiveness summary is dividedinto the following sections:

Overviev; This section discusses EPA's preferred alternativefor early response action.

Background; This section provides a brief history of communityinterest levels and concerns raised during earlyaction planning at the Dublin TCE Superfund Site.

This section provides a summary of technical andnon-technical issues and concerns raised by thelocal community on the proposed plan for earlyaction and EPA's responses to those issues. "Localcommunity" may include local homeowners, businesspeople, municipal officials, and potentially

AR3QI6Q9

2

responsible parties (PRPs).

I. OVERVIEW

In August 1991, EPA completed a Focused Feasibility Study(FFS) of the drinking water for the community surrounding the Site.EPA chose to address the drinking water contamination separatelyfrom the overall ground water contamination because the levels oftrichloroethylene (TCE) and other hazardous substances in thedrinking water supply were then and continue to be sufficientlyhigh to require an expedited response.

On August 8, 1991, EPA prepared a Proposed Plan for earlyaction and requested public comment on its preferred responseaction alternative. EPA accepted oral comments on the ProposedPlan at a meeting held in Dublin on August 26, 1991 and writtencomments postmarked before October 9, 1991.

EPA's preferred early action alternative for the alternatewater supply is Alternative Number 6. This Alternative wasreferred to as Alternative 5 in the FFS. EPA's preferredalternative includes installation of a well within the plume andtreatment of the contaminated water by air stripping prior todischarge to the Dublin Borough Public Distribution System. Watermains would be installed along North Main Street, Mill Street, anda portion of Elephant Road, and approximately 70 residences andbusinesses would be connected to the expanded public distributionsystem. The contaminated air released from the air stripper wouldbe treated in a carbon adsorption system (or similar treatmenttechnology) to remove the contaminants prior to discharge to theatmosphere. This remedy would also include monitoring ofapproximately 50 residential and commercial wells until a finalground water remedy is implemented.

II. BACKGROUND

Community interest and concern about the Dublin TCE SuperfundSite has been relatively high. A removal action, which providesaffected residences and businesses with either bottled water orindividual carbon treatment systems, went into effect in 1987. Theresidents became particularly interested in the Site in 1988, whena class action suit led by an attorney against the PRP stirredhealth-related concerns. In response to the removal action andlawsuit, EPA held an informational meeting in Dublin in May 1988.

After the placement of the Site on the National PrioritiesList in August 1990, the Site received considerable attention fromlocal and metropolitan newspapers. To inform the community of theSite status and explain the Superfund process in layman's terms,EPA issued its first fact sheet on the Dublin TCE Superfund Site inMay 1991. Based on comments received from Dublin citizens during

A R 3 0 I 6 I O

interviews, EPA also prepared a draft community relations plan.Dublin Borough officials commented on the draft community relationsplan at a meeting held by EPA in May 1991. EPA considered thesecomments in preparing the final community relations plan in June1991.

EPA held an informal public meeting in July 1991 to discussthe alternatives being evaluated in the Focused Feasibility Study(FFS) for the Alternate Water Supply.

III. SUMMARY OF COMMENTS RECEIVED DURING PUBLIC COMMENT PERIOD

This section provides a summary of technical and non-technicalissues and concerns raised by the local community and thepotentially responsible parties on the proposed plan for earlyaction at the Dublin TCE Superfund Site and EPA's responses tothose issues. These issues and concerns received at the August 26,1991 meeting and during the public comment period can be groupedinto the following seven categories:

A. Remedial Alternative PreferencesB. Questions/Concerns on EPA's Proposed AlternativeC. General Cost/Funding IssuesD. Potentially Responsible PartiesE. Risk of Contaminants and Other Health ConcernsF. Technical Questions/Concerns on Remedial AlternativesG. Questions/Concerns on FFS and Proposed Plan

1. Structure/Format of Reports2. Background and Assumption Information

H.. Coordination with State and Local AgenciesI.. Superfund Enforcement Process

Section A addresses comments from the public on preferred remedialalternatives. Section B addresses comments specific to EPA'spreferred alternative including questions on why this alternativeis preferred over the other alternatives and how this alternativewill be implemented. Section C addresses how the remedy will befunded and questions on the cost estimates made by EPA. Section Daddresses general comments on potentially responsible parties(PRPs). Section E addresses concerns on the risk associated withthe site-specific contaminants, risk assessment values andquestions regarding bacteria formation. Section F addressesspecific questions on how the remedial alternatives evaluated wouldperform. Section G addresses specific information provided in theEPA documents and the structure of these documents. Section Haddresses how State and Local agencies will be involved in theremedy implementation. Section I addresses general questions andcomments on EPA's enforcement authority.

A summary of the comments and EPA's responses to them is providedbelow.

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A. Remedial Alternative Preferences

• A PRP proposed the implementation of a modified RemedialAlternative 6 instead of EPA's Preferred Alternative 6described in the Proposed Plan. The PRP recommended that thismodified alternative be implemented in phases expanding thepublic distribution system, as described in Alternative 2 ofthe Proposed Plan, while continuing the operation andmaintenance of the individual carbon units. This expansionwill be completed within 6 to 12 months, provided that allcitizens immediately grant access. The next phase wouldinclude the completion of the first portion of the RI/FSwithin an estimated 12 to 18 months after all accessagreements are finalized with citizens owning propertynecessary for investigation.

The PRP also recommended the installation of an air stripperon Dublin Borough Well No. 3 as a precautionary measure. Thisair stripper would be designed to treat the water supplied byWell No. 3 in addition to any water extracted from wellswithin the plume necessary for overall groundwater remediationfor the Site. The PRP proposed that all of the water whichmay be extracted as part of the overall groundwaterremediation be discharged into the public distribution system.

The PRP stated that the vapor discharged from the air stripperwould not require treatment because Dublin is not in an ozonenon-attainment area and that the ARARs identified don71require air treatment. The PRP stated that this modifiedalternative would be performed in same time frame as EPA'sproposed Alternative 6.

The PRPs believe that performing alternative 6 withoutcompleting the first portion of the RI could lead tomisplacement of the well and would be "inconsistent with theNCP".

EPA Response: EPA intended to continue the provision of theexisting treatment and monitoring program for the affectedresidences and businesses until this Early Action remedy wasimplemented. One PRP is required, under the existing RemovalOrder with EPA, to continue the provision of these treatmentsystems until a final water supply remedial action isimplemented at the Site.

EPA is concerned that increasing the capacity of Well No.3 tosupply the affected parties may expand the plume ofcontamination. Therefore, EPA does not agree with thisportion of the PRP's proposed modification.

EPA's proposal of properly installing a new well inside the

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plume or using an existing well within the plume for use as apublic supply well was not intended to be used primarily foroverall remediation of the groundwater. This proposedremedy, however, should not lead to a further spread of thecontamination, and, therefore, is not inconsistent with theNCP. The purpose of installing a new well or using anexisting well for this Early Action is to provide a permanent,clean drinking water source to the affected parties.

Misplacement of the well would not result from implementationof Alternative 6 because this well's primary purpose is notfor treatment and containment of the plume but for supply ofdrinking water. If determined to be necessary upon completionof all or part of RI/FS, wells or a series of wells will beinstalled for the primary purpose of treatment, containment ofthe plume of contamination.

Dublin Borough, located within Bucks County, is within theozone non-attainment area per both Federal and Stateregulations; and, therefore, the air stripper effluent will beregulated by not only State regulations but by Federalregulations. Federal regulations are sited in 40 CFR 81.339.The Commonwealth of Pennsylvania considers the entire state tobe an ozone non-attainment area.

Dublin Borough commented that implementation of Alternative 2,as described in the Proposed Plan, is the simplest, mosteffective means of providing clean, regulated drinking watersource. Dublin Borough stated that the water supply for thisalternative is available, the engineering to design the systemis straightforward, the Borough would not need to maintain aTCE water treatment operation and the job could be implementedprior to the Route 313 renovation work to be performed by thePennsylvania Department of Transportation.

EPA RESPONSE; Although implementation of Alternative 2 wouldbe an easier and faster way to provide clean drinking waterthan implementation of Alternative 6, it could impact thelong-term goals of the overall groundwater clean-up bypotentially expanding the plume of contamination. This couldlead to a more difficult groundwater remedy and also thepotential need for addition of a treatment system for theBorough Supply Wells if they become contaminated.

Dublin Borough supports EPA's recommended alternative if themonitoring well which was installed as part of the permit forDublin Borough Well No. 3 is modified for production and usedas the supply well in the implementation of Alternative 6 andif this remedy will not involve any capital costs to theDublin Borough residents or any abnormal O&M costs to theBorough.

Dublin Borough recommends the use of the monitoring well as asupply well because: (1) this location appears to be in theplume and (2) the monitoring well is a proven source for aproduction well. Dublin Borough also requested participationin the selection of the site for a new well, and design andconstruction of the well.

Dublin Borough stated that Alternative 6 uses proventechnology. The Borough stated that, although EPA could havechosen to obtain water from a water supply well in anotherwater shed so that contaminants would not be pulled into thewater supply, the Borough believes that choosing to installor use a water supply well within the plume of contaminationbenefits both the Borough in trying to expeditiously providean alternate water supply and benefits the PRPs as part of theremedial action. Also, Dublin Borough wants a commitment fromEPA to remediate the groundwater contamination.

EPA RESPONSE; The location of the well will be determinedduring the remedial design phase of remedy implementation.Based on the information provided by the Borough to EPA, themonitoring well is not contaminated with TCE and, therefore,currently is not within the plume of contamination. Itappears that if this well were used, there may be a potentialof spreading the plume of contamination. Nevertheless, thiswell location will be considered during the remedial designphase of remedy implementation.

The affected parties would not be required to pay anyconnection fees, but would be required to pay a monthly orquarterly fee for water charged by the Borough, which wouldprovide sufficient revenues to finance the O&M for the supplywell and the water line extension. The Borough will beresponsible for the O&M of the supply well and the extensionto the water line which will be dedicated to the Borough forits use. The details of any agreements between the Boroughand any party implementing the remedy relating to the fundingof the remedy or any component thereof will be addressedduring the RD/RA stage. CERCLA requires that any PRPimplementing the remedy finance, at a minimum, the O&M forwater treatment system. If the remedy is implemented by theCommonwealth of Pennsylvania, under a State SuperfundContract, EPA will request that the Commonwealth provide itsassurance that the remedy will be implemented. EPA and theCommonwealth of Pennsylvania would not be required, nor wouldthey require any PRP implementing the remedy, to pay any partof the tap-in fee that covers legal fees or other costs notnecessarily related to the connection to the water line.

EPA believes the Borough should be involved in the decision onthe placement of the well if the Borough intends using theconstructed system as part of its existing distribution

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system.

EPA agrees that implementation of Alternative 6 uses a proventreatment technology and is the best way to not only helpcontain the plume of contamination but also to provide cleanwater to the affected parties in the most economical andefficient manner.

By placement of the Site on the National Priorities List(NPL), EPA has committed to investigate and determine the riskassociated with the Site and remediate the Site so that risksare reduced to an acceptable level. This needs to becompleted before the Site is removed from the NPL.

B. Questions/Concerns on EPA's Proposed Alternative

• A meeting attendee wanted to know EPA's rationale forproposing an air stripping system with carbon adsorption,rather than the carbon system alone.

EPA Response. TCE degrades into vinyl chloride, which doesnot adsorb onto carbon as readily as TCE. Therefore, vinylchloride requires a larger quantity of carbon than TCE foradequate treatment. Given that there is TCE and some vinylchloride in the local ground water, there may be somedegradation of vinyl chloride in the ground water. Over time,these levels of vinyl chloride could increase the cost ofusing carbon adsorption. Also, studies show that bacteriacould build up over time in the carbon. Thus, EPA ruled outthis particular technology as a feasible alternative.

• One commenter suggested that a water main be provided onRickerts Road to supply water to residences which arepotentially affected in Hilltown Township. This commenter wasconcerned that there is no data on these wells and that theplume is migrating towards these homes.

EPA RESPONSE; EPA cannot recommend expansion of the watermain to Rickerts Road because, based on EPA's estimate ofcontamination migration, these properties are not currentlyaffected nor are they expected to become contaminated prior toimplementation of a final groundwater remedy at the Site.Wells on properties located on Rickerts Road will be monitoreduntil a final groundwater remedy is in place that will containthe plume to prevent further contaminant migration. If any ofthese wells do show contamination above the remedial actiongoals for this Early Action, the residences or businesses willbe provided with an adequate treatment system or supply ofpublic water.

• One citizen commented that some residences on Elephant Roadhave a water main going past their homes and, although they

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are not hooked up to that main, they have been paying waterrent because of a the local ordinance. The commenter askedhow long it would take to be connected, because a water maindoes not need to be constructed.

EPA Response. One of the reasons EPA recommends thealternative of a well within the plume is to help preventfurther spread of existing contamination. The wells thatcurrently supply the existing systems are outside the plume ofcontamination. If those wells that already have a line infront were hooked up, EPA would be increasing the capacity ofthe wells that supply the distribution system. EPA willconsider the situation of these residents who already have aline running in front of their houses when implementing theearly action.

Several meeting attendees asked EPA to specify on the Site mapwhere the water line and new well would be placed for theProposed Alternative.

EPA Response. Although EPA has not made a final decisionabout where to place the water line, the FFS recommendedplacing a water main up Main Street to Rickerts Road, puttinganother main along Mill Street after Cherry Lane, and puttinga main from South Main Street up to run along Elephant Road.

EPA has determined only a general area for well placement. Inthe FFS, EPA identified certain sources. One such source isthe Whistlewood Apartment Complex. The other productionwells in that area are potential places where EPA couldinstall a larger capacity well, but EPA has not at the presenttime actually identified the source.

A PRP indicated that EPA did not evaluate alternatives tovapor-phase carbon adsorption treatment such as catalyticoxidation, fume incineration, or thermal oxidation. The PRPalso indicates that both vapor- and liquid- phase carbonadsorption of vinyl chloride are not as effective astrichloroethylene adsorption and that EPA did not recognizethis lack of effectiveness in the vapor-phase carbonadsorption in the FFS report.EPA RESPONSE; EPA acknowledges that other treatmenttechnologies are available for the treatment of contaminatedvapor from the air stripper. The technologies identified bythe PRP are recognized by PADER as "Best Available TreatmentTechnologies" for the treatment of air stripper discharge and,therefore, would meet the Pennsylvania ARAR for air strippervapor discharge. EPA has agreed to evaluate thesealternatives during the design phase of remedy implementation,if requested by the party implementing the remedy; although,if treatability studies are required, the party implementing

the remedy will install temporary vapor-phase carbon units onthe air discharge until these studies are complete. EPA doesnot want this action delayed due to additional studies.

EPA also acknowledges that both vapor- and liquid- phasecarbon are poor adsorbents for vinyl chloride. Adsorptiononto liquid-phase carbon was considered to be more criticalbecause of the low MCL established for vinyl chloride (2 ppb) .No air discharge criteria specific for vinyl chloride has beenestablished for the Dublin TCE Site by EPA or PADER.

A meeting attendee asked why EPA did not recommend UVoxidation as its preferred alternative.

EPA Response. The purpose of conducting an early action atthe Dublin Site is to implement an effective and protectiveremedy as quickly as possible. The technology associated withthe UV method has not been proven at the Site and wouldrequire a treatability study, which EPA estimates would takeat least six months to perform. EPA does not want to delayimplementation of the remedy for another six months while thetreatability study is conducted.

In addition, one of the main advantages of using UV oxidationis its ability to handle organics with molecular weightsgreater than 200 molecular mass much better than othertechniques, such as biodegradation. Because the Dublin TCESite does not present a risk from high molecular weightorganics, and because the early action is an interim measure,EPA did not recommend UV oxidation as its preferredalternative.

EPA's main goal in providing this proposed plan for earlyaction is to eliminate immediate risks presented by the poorquality of the drinking water supply. EPA will examine otheralternatives, such as UV oxidation, during the selectionprocess for a final remedial action, which will focus oncleaning up the ground water at the Site.

A citizen asked if a connection to the main water line wouldbe provided for residents who do not now have contaminatedwells, but whose wells are discovered in the future viamonitoring to be contaminated. Related to that this issue,another commenter asked EPA to estimate the number ofpotentially affected residents (or homes) five years from now.This commenter indicated that previous EPA literature statedthat approximately 170 homes are currently affected by thissituation but that only approximately 70 affected andpotentially affected residences and businesses are addressedin the Proposed Plan.

EPA Response. In the FFS, EPA considered approximately 70

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"connections" for supply of water from the public distributionsystem. The connections included not only individual homesbut also apartment complexes and businesses. This accountsfor the difference in previously reported value of 170 andvalue of 70 used in the FFS (the majority of the residencesaffected are within an apartment complex of 144 units). EPAalso considered monitoring approximately 55 wells until afinal groundwater remedy is in place.

The 70 connections include residences and businesses who arealready affected, or who could potentially be affected beforea final ground water remedy is in place. EPA estimates thetime frame for completion of the ground water remedial actionto be five years from implementation.

Based on an estimate of how quickly the ground watercontamination is migrating, EPA determined a cutoff point forselecting which residents would receive the alternative watersupply and which residents would receive only monitoring oftheir private well. EPA will routinely monitor the wells ofresidents beyond the cutoff point, as described in the Recordof Decision.

If the final ground water remedy can fully contain the plume,the wells of residents beyond the cutoff point may neverbecome contaminated by TCE. If EPA's estimates on how fastthe groundwater is moving are incorrect or if a final remedycan not fully contain the plume of contamination, any personwhose well becomes contaminated above the remedial actionlevels after the water line is installed will either receivea private treatment system or will be connected to the publicdistribution system.

Without a completed RI/FS, EPA cannot determine the additionalresidences which may be impacted by the contamination.

One commenter requested an explanation on the differencebetween locating the supply well within the center of theplume or at the edges of the plume.

EPA RESPONSE; Locating the well inside the plume will help inremoving high concentrations of the TCE from the groundwaterand also will also contribute to containment of the plume.Locating the well on the edge of the plume will remove some ofthe contamination although not as much as if the well wereplaced in the center of the plume. Locating the well at theedge will help in preventing uncontaminated areas frombecoming contaminated. Also, locating the well on the edge ofthe plume will result in lower treatment costs than if thewell were located in the center of the plume.

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11A meeting attendee asked whether EPA is considering thePreferred Alternative as part of a long-term remedy.

EPA Response. EPA considers this alternative as a method toprovide sufficient quantities of potable drinking water to theaffected parties . EPA could choose to incorporate thisalternative into the remedial action although the well willnot be designed specifically for the most efficientgroundwater remediation. In fact, EPA will first try tolocate an existing production well within the plume ofcontamination before a new source location is investigated.

Remediation of fractured aquifers that are contaminated withchlorinated solvents such as TCE (as in the case of the DublinTCE Site) is difficult, at best. TCE, if present in certainconcentrations, will sink in the aquifer and may also gettrapped in the bedrock fractures. During the RI/FS, EPA mayidentify fractures that are highly contaminated with TCE. Inthe long-term remediation, these fractures could be isolated.The pure product could then be removed from these isolatedfractures without extracting an excess of clean groundwater.

When deciding to use a well within the plume of contamination,EPA eliminated the possibility of installing the well in afracture that is currently uncontaminated but ishydrogeologically connected to the fractures which contain thecontamination. Installing this well may not be the bestmethod of completely remediating the aquifer, but it is lesslikely to reduce the spread of contamination.

The Dublin Borough engineer stated that the pipe used in theexpanded public distribution system has to be of adequate sizeto conform with Ordinance No. 200 (i.e. water lines less than12 inches on Main Street are not recommended or allowed).

EPA RESPONSE; EPA is required only to supply a line sizewhich will meet the needs of the affected parties. If theOrdinance requires larger line sizes for future development orother purposes, then the incremental difference in the cost ofthe additional size will have to be paid for by the Borough.

The Dublin Borough engineer commented that Alternative 6 isinadequate because it does not include a line from the newwell to the Borough water tank and conversely a line to supplywater from the Borough tank to the affected area. Theengineer states that this is necessary because it will allowfor uninterrupted service should a repair be necessary, i.e.if a problem with the new well or the water mains from thatwell occurs, then water from the water tank could be suppliedto the affected parties.

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EPA RESPONSE; EPA assumed in the FFS that the new well wouldbe connected to the Borough tank and that the tank would beused for storage purposes, if necessary. Determination ofadditional lines will be made during the design phase ofremedy implementation. EPA will work with the Borough and theparty implementing the remedy to design the best system toprovide a reliable clean drinking water to the affectedparties.

C. General Costs/Funding Issues

• Dublin Borough and the PRPs believe that the use of a 10%discount rate is not accurate.

EPA RESPONSE; The preamble to the NCP (p.8722-8723, March 10,1990 of the Federal Register) states that EPA will follow 0MBCircular A-94 which indicates the use of the 10% discount rateand that OMB is currently reviewing the provisions of thiscircular. If the circular is revised, EPA will address thismatter accordingly. EPA will continue to use the 10% figurein its cost estimates.

• Dublin Borough expressed concern that the tapping-feerequirement by the Borough for connection to the existingpublic distribution system was not included in the costestimates provided in the FFS or Proposed Plan. This fee,according to the commenter, is the fee associated with thedevelopment of the Dublin Borough public distribution systemover time. Alternative 6 is not a stand alone system; itmakes use of the system already in place and therefore, theBorough should be compensated for use of the existing system.

EPA RESPONSE; The costs provided in the FFS were order-of-magnitude estimates. These cost estimates will be refinedduring the remedial design phase of remedy implementation.The portion of tapping fee associated with capital costsincurred by the Borough for construction of the existingdistribution system will be paid by either a PRP or theSuperfund as well as costs related to the connection of thoseaffected parties to the water line. Costs associated withpast legal fees cannot by the Superfund nor can EPA require aPRP to pay these legal fees.

• Dublin Borough and Sequa Corporation are in litigation fordamages and costs, including attorney's fees. Dublin Borough,in the acceptance of a remedial alternative, does not want toincur an unfunded liability for attorney fees. Also, DublinBorough stated that any agreement between a "privateauthorized entity" (i.e., if a PRP were to become a utilityfor supply of water) and Dublin Borough would have to becourt-approved.

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EPA RESPONSE: The attorney's fees are part of the privatelitigation commenced by the Borough and a class of affectedindividuals and is unrelated to the remedy for this earlyaction. The party implementing the remedy must supply a cleandrinking water source and will not be required to pay attorneyfees associated with any previous or on-going litigation. EPAcannot comment on the requirements of the court concerning theaforementioned litigation.

Dublin Borough expressed concern that, due to financialconstraints of Federal or State agencies or unwillingness ofthe PRPs, the Borough may not be provided with funding tofinance the O&M, and, therefore, Dublin Borough could possiblybe in a position where they would have to incur costs for thisEarly Action. Dublin Borough recommended setting up aguaranteed or prepaid source of total O&M through a trustfund. The Borough stated that 53 P.S. 46202(32) allows forthe establishment of a trust fund.

EPA RESPONSE; If Alternative 6 is implemented to become partof the existing Dublin Borough public distribution system, theO&M payment requirements, for the treatment of the drinkingwater in this early action, will be part of the agreementbetween the party implementing the remedy (either the PRPs orthe Commonwealth of Pennsylvania under a State SuperfundContract) and Dublin Borough. EPA believes that a trust fundmay be appropriate in this situation and will consider thisduring remedy implementation.

Several meeting attendees asked whether persons residing alongthe route of the anticipated water line would have to incurany costs associated with its placement.

EPA Response. EPA will attempt to compel the PRPs to financeand implement the action. If the implementation of theAlternative is funded from the Superfund, EPA would pay forresidents to be connected to the line. EPA would not pay forregular (i.e., monthly or quarterly) water bills; users wouldhave to pay their water bills.

Based upon an earlier discussion about extending the watermain on South Main and up to High Street, a meeting attendeewanted to know whether people who have not had TCE detected intheir wells would have to pay connection fees.

EPA Response. EPA's early action is aimed at supplyingresidents who currently have contaminated drinking water orwho have the potential for contaminated drinking water withpotable water. Unaffected residences and businesses would berequired to pay the connection fees if they chose to beconnected to the public distribution system.

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One citizen asked who would finance the annual operation andmaintenance (O&M) costs.

EPA Response. EPA intends that the O&M for the supply welland the water line extension will be financed by the Boroughwith revenues it receives through its monthly or quarterlywater bills from the affected parties. As stated on page 6and 7 of the responsiveness summary and in the description ofAlternative 6 in the ROD, EPA intends to have the PRPs pay forO&M for the water treatment portion of the remedy as part ofits remedial enforcement agreement. If EPA does not reachsuch an agreement with the PRPs for this particular earlyaction Alternative, EPA would request that the Commonwealth ofPennsylvania enter into a State Superfund Contract with EPA,in which the Commonwealth would provide assurances for the O&Mof the remedy.

A PRP stated that all cost estimates provided in the FFS werequestionable. The PRP stated that EPA overestimated thecapital costs in the FFS for all alternatives exceptAlternative 4 which capital costs were underestimated. ThePRP believes that the No Action Alternative costs should haveincluded costs for removing the existing carbon canisters.The PRP commented that EPA was inconsistent in its use of 5200feet of water main for Alternatives 5, 6, and 7 and its use of5600 feet of piping for Alternative 3. The PRP calculatedcosts for all alternatives recommending use of a water main byusing 5600 feet of piping. The PRP stated that EPA did notinclude costs of purchasing property, abandonment of theexisting private wells and removal and disposal of existingcarbon treatment units.

EPA RESPONSE: The Cost of Remedial Action (CORA) model,developed under contract with CH2M Hill for use by EPA, wasused for all cost estimates prepared for the FFS except forthe costs for Alternative 6 of the FFS, which used costsobtained from other sites. The CORA model is intended toprovide order-of-magnitude cost estimates for remedial actionsat Superfund Sites. Refined costs estimates will be providedduring the remedial design of this Action.

Although the CORA model is not designed specifically to be asaccurate as an FS-level cost estimate, EPA believes that forthis action, given the unknown variables which could impactthe costs such as location of a new well, concentration of thecontaminants in the groundwater to be treated, depth of thenew well necessary, possible purchase or compensation for landuse, use of this model was appropriate.

Although the PRP's capital cost estimates are lower than theestimates provided in the FFS, the PRPs did not providesimilar estimates for the operation and maintenance and

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present worth costs. A cost comparison of alternatives cannot be performed on the basis of capital costs alone. Forexample, the O&M costs associated with Alternative 3 of theFFS were high enough to provide this alternative with apresent worth cost comparable to Alternatives 1, 2, 4, 5 and6 of the FFS.

EPA did not include the cost of removing the existing carbonunits in the No Action alternative because that would theninvolve an "action". Different water main lengths were usedfor the various alternatives because the location of theproposed well would be in different locations.

D. Potentially Responsible Parties

• A PRP commented that the statement in the FFS indicating thatAthlone Industries, Incorporated purchased the property fromKollsman Instrument Corporation (KIC) in 1973 is incorrect.The commenter indicated that the property did not passdirectly between KIC and Athlone but that KIC granted theproperty to the Bucks County Industrial Development Authority(BCIDA).

EPA Response; Athlone Industries, Incorporated purchased theSite from the BCIDA pursuant to an Installment SalesAgreement. EPA does not believe that this fact will impact itsEarly Action decision.

• One commenter stated that the term "Potentially ResponsibleParty" does not necessarily mean "polluter".

EPA RESPONSE; A potentially responsible party, is defined bySection 107 of CERCLA, 42 U.S.C.S9607, as a current owner oroperator, an owner or operator at the time of disposal at theSite, a person who arranged for treatment or disposal ortransportation for treatment or disposal at the site or atransporter of a hazardous substance to the Site who selectedthe Site for disposal.

• Dublin Borough expressed concern that EPA's proposal asoutlined in the Proposed Plan for Early Action is similar toa previous proposal which was rejected by Sequa Corporation,a Potentially Responsible Party, during negotiations betweenDublin Borough and Sequa Corporation.

EPA RESPONSE; EPA does not have a copy of the offer DublinBorough made to Sequa Corporation as part of the settlement inAugust 1990 and, therefore, can not comment on it. One of thegoals under CERCLA is to provide the opportunity for thePotentially Responsible Parties (PRPs) to implement the remedyprior to using Superfund monies. EPA can do this bynegotiating a consent decree with the PRPs, by issuing the

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PRPs a unilateral order demanding the PRPs to implement theremedy, or petitioning a Federal Court. If these options arenot implemented, the Superfund will pay for the remedy.

E. Risk of Contaminants and Other Health Concerns

• One meeting attendee wanted to know the health effects ofhuman exposure to TCE and the other site contaminants.

EPA Response. Direct contact with to TCE can cause irritationof the eyes, nose, throat, and skin. TCE can cause headaches,nausea, vomiting, lightheadedness, fatigue, and several othergeneral symptoms. TCE can cause symptoms similar to thoseassociated with intoxication. Finally, TCE can cause liverdamage.

Additionally, TCE has been shown to cause cancer in certainlaboratory animals, that is, liver cancer that spreads to thelungs. Because of these research findings based on laboratoryanimals, EPA regulates TCE as a probable human carcinogen. Sofar, there is no evidence that TCE causes cancer in humans,but EPA regulates TCE because of its potential to cause cancerin humans.

TCE naturally degrades to vinyl chloride, which is much moretoxic to humans than TCE. Human exposure to vinyl chloridehas been documented as causing cancer in occupationalsettings. Thus, EPA's primary goal with regard to addressingTCE in ground water is to prevent it from degrading into vinylchloride.

• A citizen was concerned that if carbon treatment were used, abacteria problem might be created or persist in large wells.The citizen thought that, in contrast, the UV technology woulddestroy bacteria.

EPA Response. EPA acknowledges that the citizen is correctthat bacteria could present a problem if carbon treatment wereused. During the design phase, it may be necessary for EPA toinclude a UV oxidation system on a smaller scale strictly totreat bacteria.

• A PRP stated that the nature of the short-term risks toworkers and the environment which are mentioned in theSections of the FFS relating to Alternatives 4, 5, and 6 arenot fully described.

EPA RESPONSE; The short term risks referred to in theseSections indicate not only chemical risks but safety risks.The risks associated with these alternatives include not onlythe risk of exposure to chemicals during well installation butalso the mechanical risks associated with the operation of

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heavy equipment such as drill rigs for well construction andbackhoes for water line installation.

• A PRP stated that Section 1.4 of the FFS titled "baseline riskassessment" does not adequately address baseline risks at thesite and therefore, the PRP does not understand how the EPAwas able to evaluate the reduction of risks, the magnitude offuture risks for each alternative. The PRP also indicatesthat, because no baseline risk assessment was performed, thatthe discussion of risk in the FFS is theoretical. The PRPalleges states that the FFS report is inconsistent with theNCP and RI/FS guidance.

EPA RESPONSE; The preamble of the NCP (8704 March 8, 1990)states that "A completed baseline risk assessment generallywill not be available or necessary to justify an interimaction." EPA believes that use of MCLs and MCLGs for thecontaminants of concern at the Dublin TCE Site are appropriatein evaluating the risks associated with the drinking water atthe site. The preamble also states that "EPA must balance thedesire to definitively characterize site risks and analyzealterative remedial approaches for addressing those threats ingreat detail with the desire to implement protective measuresquickly" and in doing so "EPA intends to perform thisbalancing with a bias for initiating response actions ... asearly as possible".

• A PRP indicated that the FFS states that this alternativepresents a potential health concern regarding the pretense ofbacteria in the treated water. The PRP indicated that thesupply under this alternative would constitute a communitysystem as defined in the Safe Drinking Water Act and that theoperator would be required to meet the regulations in 40 CFR141.72 and the Pennsylvania Code, Title 25, 109.202(3).

EPA RESPONSE; EPA agrees that this alternative would beregulated under the Safe Drinking Water Act and Pennsylvaniaregulations. EPA would like to note that if bacteria wereformed due to activated carbon treatment, the operator may berequired to install a system for bacteria destruction whichmay increase the cost of treatment.

F. Technical Questions/Concerns Regarding Remedial Alternatives

• A PRP commented that none of the remedial alternativesconsidered by the USEPA can prevent the spread ofcontamination or result in complete remediation of the aquiferand that even with a ground-water system designed specificallyfor remediation purposes, it will not be possible to restorethe groundwater within the bedrock aquifer to meet maximumcontaminant levels. The PRP stated that a groundwaterremediation at this Site can only contain and control the

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plume to the maximum extent possible.

EPA RESPONSE: EPA's primary reason for this Early Action isto provide a permanent clean drinking water source to theaffected parties. The primary purpose of this phase is not toprevent the spread of contamination or completely remediatethe aquifer. Remediation and containment of the aquifer willbe addressed during or after the completion of the RI/FS. Adetermination can not be made at this time, prior to anystudies relating to the RI/FS, as to whether a ground watersystem designed specifically for remediation purposes, will beable to meet MCLs

A PRP stated that EPA was incorrect in stating thatAlternatives 4, 5, 6, and 7 of the Proposed Plan would reducethe VOCs in the aquifer because the objective of this EarlyAction will not address the source of the plume and aquiferrestoration is not the objective. The PRP questioned thestatements made by EPA in the Proposed Plan that Alternatives4, 5, 6, and 7 prevent the spread of contamination and thatthese alternatives will reduce the toxicity of thecontaminants via carbon treatment, air stripping or UVoxidation. The PRP indicated that the toxicity of thechemicals could be reduced only by the UV Oxidation technologythrough the breaking of chemical bonds.

The PRP stated that EPA confused mobility with migration bystating that Alternative 4, 5, 6 and 7 would help to inhibitfurther migration. The PRP states that inhibiting furthermigration has nothing to do with reduction of toxicity,mobility or volume.

EPA RESPONSE; The statement that Alternatives 4, 5, 6, and 7would reduce the VOCs in the aquifer is correct regardless ofthe objective of the operable unit.

EPA recognizes that these alternatives will not completelyprevent the spread of contamination but that, when compared toalternatives 1, 2 and 3, these alternatives will help in theprevention of the spread of contamination.

By inhibiting the migration of the VOCs in the aquifer throughextraction of contaminated groundwater, Alternatives 4, 5, 6,and 7 are, in fact, reducing the toxicity, volume and mobilityof the VOCs in the aquifer. The toxicity and volume ofcontaminants in the aquifer are being reduced because thereare less VOCs in the aquifer. The mobility of the VOCs in theaquifer is reduced because these alternatives are helping tocontain the plume of contamination; i.e., contaminants thatwere free to move with the groundwater flow will be pumped upfrom the aquifer and treated.

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UV oxidation is the only treatment technology evaluated in theFFS which can reduce the toxicity of the contaminants; theother treatment technologies will not reduce the toxicity ofthe contaminants but they will reduce the toxicity of thegroundwater.

A PRP indicates that the FFS incorrectly states that theactivated carbon system described in Alternative 4 and the airstripping unit described in Alternative 5 may not be capableof accommodating additional homes that may be added in thefuture. The PRP indicates that the design would incorporateadditional capacity as a matter of engineering practice.

EPA RESPONSE; EPA will not know how many additional homeswill be affected until the RI/FS is complete, the extent ofcontamination has been defined and a containment system is inplace. Therefore, even though additional capacity will beincorporated, EPA does not know what additional capacity willbe required.

A PRP commented that EPA did not consider the ability of theDublin Borough storage tank, located on South Main street, tomeet the proposed increased demands; but the PRP agrees thatthe tank will, in fact, be of adequate size.

EPA RESPONSE: EPA agrees that the tank is of adequate sizebut recognizes that this will be confirmed during the remedialdesign.

A PRP stated that EPA dismissed Alternative 2 of the ProposedPlan because increased pumping of Well No. 3 could result inthe contamination of this well even though EPA stated in theFFS that tests would be performed prior to implementation ofthis alternative to determine if pumping from this well wouldspread the contamination.

EPA RESPONSE; EPA dismissed the use of Alternative 2 becauseof the increased pumping of Dublin Borough Wells No.l, No. 2,or No. 3 could result in the spread of contamination andbecause Well No. 3 is downgradient of the plume ofcontamination. Previous hydrogeological studies have notconfirmed that Well No. 3 is not hydrogeologically connectedto the plume of contamination and it is difficult to determineconclusively the absence of hydrogeological connectionsbetween uncontaminated wells and plumes of contamination.

A PRP commented that obtaining water from outside the DublinBorough community (i.e. from the neighboring communities)should have been considered in greater detail in the FFSreport.

EPA RESPONSE; EPA's primary reason for performing this action

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is to provide a permanent clean drinking water source as earlyas possible. EPA did consider the option of obtaining waterfrom outside of the Borough (Section 2.3 and 3.3 of the FFS),but EPA believes that obtaining water from within the Boroughand expanding Dublin Borough's existing public distributionsystem is the most economical and effective alternative.Alternative 6 is also the consistent with the long-termobjectives of overall remediation of the Site.

A PRP stated agreement with the continued use of theWhistlewood Apartment Complex well and air stripper inevaluating this alternative.

EPA RESPONSE; Even though the apartment complex would retainits air stripper in this alternative, it was assumed that theWhistlewood Apartment Complex would be put on the publicdistribution system and that their well would be abandoned inAlternatives 2, 3, 5, 6, and 7 of the Proposed Plan. If,however, Whistlewood elects not to be put on the publicdistribution system, Whistlewood may elect to continue tooperate the air stripper at its own expense.

A PRP commented that operation treatment system testing wouldnot be necessary for this alternative because it is alreadyfunctional at the site.

EPA RESPONSE; Operational treatment system testing will berequired under this alternative for residences identified inthe FFS which are not currently on the monitoring program buthave the potential to become affected by the contamination.

A PRP indicates that the cost estimate for operation ofRemedial Alternative 5 of the FFS may be subject to errorbecause EPA did not evaluate the effect of possible increasedvinyl chloride concentration with time due to degradation ofTCE in the groundwater. The PRP states that vinyl chloriderequires large quantities of activated carbon in both theliquid and vapor phase treatment.

EPA RESPONSE; The costs provided in the Proposed Plan and FFSare only estimates. The costs will be refined during theremedial design phase of remedy implementation. The CORAmodel for vapor-phase carbon adsorption treatment assumes thatall contaminants are of a molecular weight of 100 and,therefore, this model cannot compare the carbon loadingefficiencies of different types of contaminants.

A meeting attendee asked what happens to the contaminatedcarbon in the carbon adsorption alternative. This citizenexpressed concern about the costs associated with transportingand disposing of the toxic material.

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EPA RESPONSE; Under the carbon adsorption alternative, thecarbon material would not necessarily have to be disposed of.The material could be regenerated either on-site or off-site.EPA will consider cost in deciding whether to recommend on-site or off-site regeneration. In the FFS, EPA examined theoff-site regeneration method.

A PRP disagrees with the comment made by EPA that largerquantities of vinyl chloride in the future may have an impacton the effectiveness and cost of activated carbon treatment.The PRP states this statement may have predisposed thedecision against remedial alternatives employing activatedcarbon adsorption.

EPA RESPONSE; EPA believes that increased quantities of vinylchloride will not have an effect on carbon adsorptioneffectiveness and cost. Although it is true that increasedconcentration of a single contaminant does increase theutilization rate (i.e. as the concentration of a contaminantincreases, the actual amount of contaminant adsorbed willincrease), this phenomenon does not necessarily occur whenother contaminants are present. Competitive adsorption byeven traces of another contaminant can greatly reduce theadsorption rate or capacity. At the Dublin TCE Site,trichloroethylene, vinyl chloride and other chlorinatedhydrocarbons are present in the groundwater. Therefore, theeffectiveness of the carbon adsorption on TCE may, in fact, bedecreased with increasing vinyl chloride concentration.

When considered as a single contaminant, the adsorptionproperties of vinyl chloride are not as great as theadsorption properties of trichloroethylene. Iftrichloroethylene is degraded into vinyl chloride in thegroundwater, the vinyl chloride concentration will increasewhile the trichlorethylene concentration will decrease. Ifall of the TCE disappeared and only vinyl chloride was left inthe groundwater, more carbon may be necessary for vinylchloride treatment than for TCE treatment.

Moreover, EPA decided not to use carbon adsorption as theproposed remedial alternative not only due to the vinylchloride considerations, but also due to possible bacteriaformation and fouling of the carbon bed which would requireadditional operation and maintenance.

A PRP stated that the comment made in the FFS indicating thatthe carbon system used in this alternative would include twocarbon units in series and, therefore, would be similar to theexisting in-house systems was misleading because the actualcarbon unit used in this alternative would be larger and wouldpossibly involve more equipment.

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EPA RESPONSE; EPA does not believe this statement ismisleading because EPA indicates that the unit would besimilar to the in-house units because it would consist of twounits in series. No mention of size or piping was made.

A PRP states EPA did not consider off-site regeneration of thespent activated carbon used for the treatment of extractedgroundwater (i.e., liquid-phase carbon treatment).

EPA RESPONSE; EPA agrees with the PRP that off-siteregenerated carbon is often more cost-effective than on-siteregenerated carbon or disposal of spent carbon in a landfill.Section 2.4.3.1 of the FFS was not clear in its description ofthe disposal and regeneration of activated carbon. Review ofthe Cost of Remedial Action module for liquid-phase carbonadsorption indicates that off-site regenerated carbon, was, infact, used to determine the costs for this alternative. Thediscussion of disposal and regeneration of activated carbon inthe FFS actually refers to vapor-phase carbon. In thecalculations of vapor-phase carbon costs for EPA's preferredalternative, disposable carbon was used because it wascalculated to be the least expensive of the two"disposal/regeneration" alternatives. Although it was notexplicitly stated in the CORA manual, it was assumed that thedisposed carbon was taken off-site for regeneration ratherthan disposed of in a landfill. The RCRA land-banrequirements regulate and restrict disposal of this type ofwaste in a landfill.

A PRP commented that the data necessary for design of theactivated carbon system described in Remedial Alternative 4 ofthe FFS should be described. For instance, the PRP statesthat the FFS did not indicate that influent flow rate is oneof the dependent variables in calculating the volume of carbonrequired.

EPA RESPONSE; EPA refers the commenter to Section 2.4.3.2 ofthe FFS where carbon adsorption treatment is described. Thedata required for design would include, but not be limited to,contaminant concentration and type, water flow rate,temperature, bacteria concentration, and particulateconcentration. This comment does not affect the decision EPAmade in this Early Action. The same flow value was used inthe cost calculations for each alternative; and, therefore,the costs are comparable to each other.

A PRP indicated that the FFS states that the effluent of thecarbon treatment system described in the FFS should bemonitored to ensure that the effluent is "free ofcontaminants." The PRP indicates that this statement isinconsistent with the remedial goals established for the site(i.e. MCLs).

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EPA RESPONSE; EPA agrees that the statement should read "freefrom contaminants in excess of the remedial goals."

A PRP indicated that the statement made in the FFS that airstripping costs are low compared to other physical andchemical treatment options is not necessarily true because airstripping may require off-gas treatment.

EPA RESPONSE; EPA believes that the statement made in the FFSis accurate. EPA indicated only that air stripping alonewould be less expensive than other treatment technologies.Vapor-phase treatment was discussed further down in Section2.4.3.2 of the FFS. EPA does recognize that air strippingwith vapor-phase carbon adsorption treatment may be moreexpensive than other technologies. This is indicated in thecost comparisons of the air stripping with vapor-phase carbonadsorption treatment alternative and the liquid-phase carbonadsorption treatment alternative.

A PRP states that the FFS does not provide detail regardingwhether the air stripper gas would be preheated to reduce itsrelative humidity making it difficult to verify the capitaland operating costs.

EPA RESPONSE; The CORA cost modules description indicatesthat the vapor stream is at 100% relative humidity and 50 F.Both the regenerable and non-regenerable systems compared inthis module use a pre-heater on the vapor stream to reduce therelative humidity prior to discharge into the carbon units.

A PRP stated that the FFS did not indicate that large amountsof electrical energy would be required for Alternative 6 inthe FFS and that this would increase the operational costssignificantly.

EPA RESPONSE; The costs listed for UV oxidation are based onuse of this technology at other sites. The costs doincorporate electrical energy. The costs for UV oxidation arenot significantly higher than any other comparable alternativeevaluated. The costs estimated by the PRP are actually lowerthan EPA's estimated costs.

A PRP stated that in the FFS EPA mislead the reader by statingthat this alternative "would completely destroy thecontamination within the groundwater". The PRP states that UVOxidation would only destroy the contamination in theextracted groundwater.

EPA RESPONSE; EPA agrees that UV Oxidation will only destroythe contamination in the extracted groundwater. EPA believesthat the technology was fully described in Section 2.4.3.3indicating that only the extracted water would be treated and

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not the entire plume of contamination. EPA also states inSection 1.1 that the primary purpose is to supply a cleandrinking water source, not to address the final remedialactions at the Site including the final groundwaterremediation.

• A PRP questions the evaluation of UV technology when the FFSdoes not identify whether this technology can meet theremedial goals (i.e., MCLs).

EPA RESPONSE; The NCP (p.8849, March 8, 1990) states thatinnovative technologies shall be developed for furtherconsideration if those technologies offer the potential forcomparable or superior performance or implementability. EPAbelieves, based on the UV oxidation treatability studiesconducted at other sites, that this technology has thepotential for performance comparable to the other technologiesevaluated.

• A PRP indicated that EPA incorrectly identified local noiseregulation as a potential ARAR and that EPA's failure toevaluate local noise regulation as "to be considered"information is inconsistent with the NCP and the RI/FSguidances.

EPA Response; The penultimate sentence in Section 3.6.5 ofthe FFS will be amended to read: "Local noise regulation is tobe considered as an ARAR in this evaluation".

• A PRP indicates that EPA made an assumption that groundwatercleanup levels for the Site require MCLs in the evaluation ofalternatives in the FFS and that this is not an assumptionbecause MCLs were previously identified as ARARs.

EPA RESPONSE; The PRP is correct that MCLs are ARARs.

• A PRP commented that the FFS report did not state whetherAlternative 3 would comply with action-specific ARARsregarding off-gas treatment for air strippers.

EPA RESPONSE; Alternative 3 would not need to meet any ARARswith regard to off-gas treatment because this alternativeinvolves the use of liquid-phase carbon adsorption systemswhich do not emit any off-gas.

• A PRP indicated that the disposal of treated well developmentwaters resulting from the installation of a new well asdescribed in Section 3.5.3 is not discussed in Section 3.5.5,Regulatory and Institutional Analysis. Also, the PRPsindicate that the National Pollutant Discharge EliminationSystem (NPDES) might be an ARAR for this waste.

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EPA RESPONSE; Section 3.5.5 should indicate that these wasteswill meet all ARARs. NPDES is evaluated in the ROD.

• A PRP stated that EPA did not perform the evaluations requiredin the CERCLA Compliance with Other Laws Manual whenidentifying the ARARS in Appendix A of the FFS. The PRPstated that if EPA had performed this evaluation that EPAwould have concluded that OSWER directive 9.355.0-28 does notrequire the use of air pollution controls because Dublin isnot in an ozone non-attainment area.

EPA RESPONSE; EPA disagrees with this comment. DublinBorough is in an ozone non-attainment area and therefore,OSWER Directive 9355.0-28 is to be considered an ARAR for theRecord of Decision. Because a location for the well proposedin Alternative 6 of the Proposed Plan has not yet beendetermined, it is impossible to establish whether an airtreatment system would be required under the Federalrequirements. State regulations (25 PA Code 127.14) dorequire emission controls on any new source which is notexempt under the code. The emission controls must use bestavailable technology as determined by PADER. Vapor phasetreatment under State regulations may be exempt if the sourceis considered minor. Since EPA does not know what theemission levels will be at this point, a conservative approachwas taken and it was assumed that this regulation is an ARAR.The information listed on Administrative Record page AR300770was not used for purposes of the FFS and ARAR evaluationbecause it is out-dated. USEPA did not determine the risklevels associated with air pollution because it has not yetbeen determined what the concentration levels or the locationof the emission point will be.

G. Questions/Concerns on FFS and Proposed Plan

1. . Structure/Format of Reports

• A PRP commented that the FFS report does not follow the formatand structural requirements specified in the RI/FS guidanceand that the evaluation criteria that were utilized in the FFSare not consistent with the requirements of the NCP and theRI/FS guidance. The PRP states that EPA did not correctlyapply the nine criteria in the Proposed Plan.

EPA RESPONSE; The FFS report did not follow the structuralguidelines in the RI/FS guidance document. This was tostreamline the approach to developing the specific action ofproviding an alternate water supply to the residents ofDublin. EPA disagrees that the evaluation criteria were notconsistent with the requirements of the NCP. Although the FFShad a different format, the evaluation criteria are consistentwith the evaluation criteria described in the NCP. The

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"Engineering" criteria described in the FFS evaluates the"implementability", "short-term effectiveness", "reduction intoxicity, mobility, and volume criteria" as described in theNCP. The "Cost" criteria evaluated in the FFS is identical tothe cost criteria described in the NCP. The "environmental"criteria described in the FFS evaluates the "overallprotection of human health and the environment", the "long-and short-term effectiveness" and the "reduction in toxicity,mobility, and volume" criteria as described in the NCP. The"public health" criteria uses the "overall protection of humanhealth and the environment" and the "short-term effectiveness"criteria as described in the NCP.

As stated in the NCP, the "State Acceptance" criteria may notbe completed until comments on the RI/FS are received but maybe discussed in the Proposed Plan (as they were). CommunityAcceptance criteria may not be completed until the comments onthe Proposed Plan are received.

A PRP stated that the alternative involving blendinguncontaminated water with contaminated water discussed in theFFS is randomly included in the body of the report withoutprior introduction or further consideration.

EPA RESPONSE; This alternative should have been introduced inSection 2.0 of the FFS. EPA states the reasons why thisalternative was not considered further in Section 2.5.

A PRP stated that because EPA did not evaluate whetheradditional residences could be incorporated into RemedialAlternative 1 (EPA is assuming that the PRP is referring tothe No Action alternative as Alternative 1 although it is notclearly stated in its comments) and did evaluate this inAlternatives 2 through 6, EPA was inconsistent in itsevaluation.

EPA RESPONSE; EPA evaluated the No Action alternative in the"Identification and Preliminary Screening" Section of the FFSand determined that this alternative would not be carried intothe detailed analysis section. EPA stated that it wouldaddress the ease of adding additional homes to the system onlyfor those alternatives carried into the detailed analysissection.

A PRP stated that the evaluation of the no-action alternativein the FFS was brief and resulted in the elimination of thisalternative prior to the detailed analysis of alternatives andthat detailed analysis of the No Action alternative is aprocedural requirement of the NCP. Therefore, the PRPsuggests that the FFS issued by EPA is inconsistent with theNCP.

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EPA RESPONSE: Detailed analysis is required of only a limitednumber of alternatives that represent the most viableapproaches to remedial action after evaluation in thescreening stage. Because the No Action alternative would notmeet the basic risk level and ARARs determined in this earlyaction, it was eliminated from the evaluation. In the FFS,development and screening of alternatives was incorporatedinto one section, Section 2.0.

• A PRP commented that the No Action alternative was not clearlyevaluated in the FFS with respect to effectiveness,implementability and cost criteria. In particular, the PRPbelieves that the data supporting the effectiveness of thisremedial action, as provided in the Removal Action currentlybeing performed at the Site, should be incorporated in the FFSreport.

EPA RESPONSE: The data supporting the effectiveness of thecarbon adsorption systems, as of June 1991, was incorporatedinto Appendix B of the FFS report. The cost information isprovided in Table 3-3 of the FFS report. Effectiveness ofcarbon adsorption is described in detail in section 2.4.3.1.The implementability of this alternative is discussed inSection 3.4.

• A PRP believes that the discussions in the FFS of accessagreements for this alternative should be located in Section3.4.5 as opposed to Section 3.4.1. The PRPs also indicatethat EPA was inconsistent with the NCP and RI/FS guidancebecause EPA did not consider the ability to obtain accessagreements; EPA only identified the need to obtain accessagreements.

EPA RESPONSE; EPA believes that the discussion of accessagreements under Section 3.4.1 is appropriate. EPA furtherbelieves that it was not necessary to discuss the ability toobtain access because of the progress made by the PRP toobtain access as a requirement of the Consent Order executedby Sequa Corporation and PADER. The Engineering Analysissection not only deals with the technical implementability butadministrative implementability as well. Discussions inSection 3.4.5 are limited only to Federal, State, and localregulations which may be appropriate to a particularalternative. The NCP does indicate that the administrativefeasibility be taken into consideration when evaluatingalternatives. The alternative discussed in Section 3.4 of theFFS would be much more difficult to implement from anadministrative viewpoint than the other alternatives discussedin the FFS because many more access agreements would benecessary.

2. Background and Assumption Information

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A PRP commented that the Proposed Plan was incorrect instating that the Bucks County Health Department discoveredconcentrations of TCE up to 1,000 ppb in 23 and thatapproximately 170 residences were affected. The PRP indicatesthat the correct numbers are 24 and 174, respectively and thata total of 38 samples were taken.

EPA RESPONSE: EPA does not find a significant difference inthe statements made by the PRP and by EPA in the Proposed Planto warrant concern. EPA agrees that of the approximately 170residences that were affected, the majority of these were fromthe Whistlewood apartment complex.

A PRP stated that the value of 104 feet/year for groundwatervelocity that was used in the FFS is an estimate and should beused with caution.

EPA RESPONSE; EPA agrees that this value is an estimate. TheProposed Plan is not a substitute for the FFS or anydocumentation in the Administrative Record. Review of theWeston document does indicate that this value is anassumption. Because EPA recognizes this value as an estimate,EPA conservatively incorporated monitoring of residencesoutside the area determined to be potentially affected so thateven if this value is significantly overestimated, the publicwill be adequately protected.

A PRP stated that EPA incorrectly estimated the water demandin the FFS by using the lowest per capita consumption figurereferenced and an incorrect residence occupancy figure andthat this incorrect estimate could affect the long-termeffectiveness of any remedial alternative which utilizes pointsource water supplies, and could result in a water supplysystem with inadequate capacity and in an underestimation incosts. The PRP indicated that EPA did not consider theinherent phenomenon of increased water use when residencesswitch from individual wells to a public water system.

EPA RESPONSE: EPA believes that the water usage value usedin the FFS is conservative, but also recognizes that thisvalue is only an estimate and that a more accurate value willbe developed during the design phase of remedy implementation.Only 20% by volume of the total water usage estimate is basedon calculated water consumption. This portion of the totalestimate is based on calculations for 46 residences and 4businesses for which actual data was unavailable. Theremaining eighty percent by volume of the total water usageestimate is based on actual data supplied by the Borough ofDublin and the residents of Dublin. EPA believes that DublinBorough uses significantly less water than the averagespresented in the guidance documents based on a review of the

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actual data provided by the Borough.

In addition, the total water usage value calculated for watercapacity is 45,338 gallons/day but EPA conservatively roundedthis figure off to 50,000 gallons/day. Therefore, even if theresidences and businesses do increase their consumption by 10%after switching from private to public water supply, theestimate would still be reliable.

EPA believes that the consumer would probably use less waterwhen hooked to a public system because public systemstypically charge consumers for water usage. In fact, inDublin Borough because of necessary water conservationmeasures, residences supplied with public water have to payincreased rates for any amount of water used over the 60gallon/day/person limit.

Although the PRP indicates here that EPA may haveunderestimated the costs of a public distribution system inthis statement, in additional comments to EPA, the PRP does anextensive evaluation of EPA's cost and comes to the conclusionthat EPA has, in fact, overestimated the costs.

A PRP made several statements regarding the hydrogeologicaland soil information presented in the FFS. The PRP indicatedthat there are not any bedrock outcrops even though reportsreferenced in the FFS state that geological information wasdetermined based on outcrop locations outside the Borough.The PRP indicated that USEPA did not consider recentlyavailable published literature which reclassifies the bedrockunits. Also, the PRP disagrees with the statement in the FFSindicating the soil types located at the Site. The PRP alsodisagrees with the manner by which the soil gas and soilcontaminants were reported in the FFS.

EPA RESPONSE; EPA reiterates that the purpose of the FFS wasnot to fully define the characteristics of the Site, includinggeology, soils and extent of contamination. EPA does notbelieve that the information provided by the PRP affects itsdecision in this Early Action, although EPA recognizes thatthis information may be useful in the performance of theRI/FS.

EPA does not find any contradiction in the statements made bythe PRP and the FFS in terms of outcrop locations. The FFSrefers to outcrops outside of the Borough while the PRP refersto an absence of outcrops within the Borough.

A PRP stated that the FFS report was inconsistent in that itstated that "0.06 ppb of PCE was measured during pump tests onthe well [Borough Well No. 3] in 1989" whereas a report byMercuri and Associates (1988) indicates that 0.9 ppb of PCE

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was detected in a sample collected in August 1988.

EPA RESPONSE: The values stated in the FFS are incorrect. Thestatement should read: "Although the most recent sampling ofthe Borough Well #3 showed no volatile organic contamination,0.9 ppb of PCE was measured during pump tests conducted on thewell in 1988 (Hydrogeological Study, Mercuri & Assoc.)". EPAdoes not believe that this correction has an impact on itsdecision in this Early Action.

H. Coordination with State and Local Agencies

• One commenter, who was supportive of the proposed alternative,wanted to know if EPA was working with Hilltown TownshipOfficials at least on a preliminary basis during this earlystage and also wanted to know if EPA would recommend anyspecial testing of the wells located on Quarry Road at thepresent time.

EPA RESPONSE; EPA has notified Hilltown Township officials ofthe Early Action and the upcoming RI/FS. Hilltown Townshipas well as Bedminster Township officials have been put on theEPA mailing list for the Dublin TCE Site and will receivecopies of the Record of Decision for this action as well asany future fact sheets or EPA information on this Site.Although EPA would not recommend sampling of wells on QuarryRoad at the present time due to the Dublin TCE Site, thissampling will be considered during the implementation of theRI/FS.

• Representatives from the Commonwealth of Pennsylvania statedthat PADER already has an agreement with a PRP to complete aninvestigation and remediation of the groundwater and providea public water supply which PADER intends to enforce.

EPA RESPONSE; EPA is currently working with PADER inimplementing the RI/FS and this Early Action while keeping theCommonwealth order on track. As PADER stated, the PADER andEPA have a good working relationship at this site and willcontinue to work together throughout the investigation andremedy implementation phases of the project.

• Dublin Borough expressed concern that Section 1402 of theBorough Code may not allow a PRP or an EPA contractor tolawfully build a water system and then turn the system over toDublin Borough because Section 1402 requires competitivebidding in public works. Dublin Borough is concerned that ifthe Borough allowed a PRP to construct the system, then it mayconstitute preferential treatment.

Dublin Borough stated that the Borough itself has theauthority and expertise to design, bid, construct and operate

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Alternative 6 and is in a much better position to build sucha system than a private corporation.

EPA RESPONSE: If the work is performed under Superfund, EPAwould be required to use a competitive bidding process forsubcontracted work. Therefore, the construction of the watersystem and its dedication to the Borough would not violateSection 1402 of the Borough Code. If the Borough wants toconduct the work as a subcontractor, it can submit a bid tothe PRPs for their consideration.

Dublin Borough expressed concern that implementation of thePreferred Alternative would involve the creation of a newwater authority or agreement reached between Dublin Boroughand the party implementing the remedy. If an agreement wasnegotiated, Dublin Borough would require a settlement on costsand complications associated with implementation, compliancewith Ordinance No. 200, the Tapping Fee Ordinance, thePlumbing Code, and several other concerns including operationand maintenance (O& M).

EPA RESPONSE: The original intent of Alternative 6 was forthe party implementing the remedy to come to an agreement withDublin Borough over the payment of the costs for the O&M ofthe treatment system so that Dublin Borough could perform O&Mof the well, treatment system, water mains, etc. as part ofits O&M duties on the existing public distribution system.

If an agreement cannot be reached, then a separate waterauthority would be established. If a separate water authoritywere established, the remedy would need to be re-designed sothat it would operate a distribution system separate from theexisting Dublin Borough public distribution system.

EPA prefers that the PRPs implement remedy. The Ordinanceswill be complied with to the best of EPA's ability, however,these ordinances do not constitute ARARs since they do notrelate to cleanup standards.

One commenter explained that the Pennsylvania Department ofTransportation (DOT) is proposing to reconstruct Highway 313,which extends the entire length of the Borough, and asked whatcould be done to avoid tearing up the new road.

EPA RESPONSE. EPA hopes to be able to work with DOT and theBorough to come up with the best engineering solution. EPAdoes not want to tear up a newly laid road. One possibilityis to design the water main and install it prior to putting inthe treatment system and the well.

Dublin Borough's understanding is that this Early Actionaddresses only the supply of water to the affected properties

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and the aquifer clean-up will be addressed in the next severalphases. Dublin Borough is concerned that Alternative 6 couldput the Borough into the long-term business of site clean-up.Dublin Borough does not want to be held liable for the clean-up and expressed concern that this action could bankrupt theBorough. Dublin Borough does not want this Early Action to bethe overall site cleanup and does not want EPA, PADER or thePRPs to claim at a future date that this preferred alternativeis a part of the operable unit of overall site clean-up.

EPA RESPONSE; Although this preferred alternative, whenimplemented, will extract and clean the contaminatedgroundwater prior to discharge to the expanded publicdistribution system, it will not be designed as a completegroundwater remediation and containment system. It ispossible, although not probable, that this one well could actas the complete groundwater remediation system. The answerwill be determined at the conclusion of the RemedialInvestigation/ Feasibility Study (RI/FS) . Dublin Borough, nothaving been identified as a PRP, will not be responsible forthe costs of O&M for this £arly Action or for the costs orimplementation of any future actions. The primary purpose ofAlternative 6 is to provide a clean" permanent source ofdrinking water to the affected parties at or near the DublinTCE Site and the well, treatment system, water mains, etc.will be designed with this purpose in mind.

Dublin Borough expressed concern that EPA defines "clean-up"in the FFS as 30 years and that PADER defines "clean-up" asthe time until the contamination reaches a background level.

EPA RESPONSE; The primary purpose of this remedy is toprovide the residents with clean drinking water as defined bythe SDWA. The use of 30 years is an estimate of the time itwill take for the ground water extracted from the new well toreach a level that is acceptable according to the SDWA so thatthe treatment system can be removed. This is only an estimatefor costing purposes. The treatment system called for in thisROD will remain on the well as long as it is required toattain the SWDA level. PADERs "background" level addressesthe overall groundwater remediation and not the supply of adrinking water source. Therefore, if it takes 30 years toclean the TCE to 5 ppb, then operation of the treatment systemon the new well would cease under this action. The overallgroundwater remedy action may require that the treatment onthe water from this well continue until the background levelsare reached. If this is necessary, it would be covered undera separate action for groundwater remediation, not this actionwhich relates to the establishment of an alternative watersupply. EPA/PADER or the PRPs would pay for this under theoverall remedy for the site.

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I. Superfund Enforcement Process

• A citizen wanted to know how long it would take to implementthe proposed plan for early action and how long EPA estimatesit will take to compel the PRPs to pay for the action.

EPA RESPONSE; EPA has the authority to order a PRP to performthe remedy or EPA can implement the remedy itself.

Enforcement efforts will begin when EPA sends the PRPs"special notice letters," in which EPA requests that the PRPsparticipate in the implementation of the remedy. EPA allowsthe PRPs 60 days from the date of receipt of the specialnotice letters to submit to the Agency a "good faith offer,"stating their willingness to perform the work. The good faithoffer also shows EPA that the PRPs are financially capable ofimplementing the remedy.

Once EPA receives the good faith offer, the parties haveanother 60 days in which to negotiate an agreement toimplement the remedy. At the end of that time, if the PRPshave not agreed to implement the remedy, or if the PRPs arenot financially capable of doing so, EPA has severalalternatives. One alternative is to proceed to implement theremedy, financed by the Superfund. Another alternative is toissue a "unilateral administrative order," in which EPAdemands that the PRPs implement the remedy. Or, EPA mayimplement the remedial design and then order PRPs to implementthe remedial action.

In the proposed plan for early action, EPA noted thatAlternative Six would take from 12 to 15 months to implement.Implementation will begin after EPA has come to an agreementwith the PRPs, or after EPA has decided that there will be noagreement.

• Several commenters stated that EPA can either sign an orderwith the PRPs, use the Superfund or issue a Section 106 Orderfor the PRPs to implement the remedy. If the PRPs do notcomply with the Section 106 order then they are subject totreble damages and a $25,000 per day civil penalty for everyday of violation. One commenter wanted to know why EPA doesnot use this authority to get the job done faster rather thanwaiting the 120 days to receive a good faith offer andnegotiate an agreement. This commenter wants to know why EPAdoes not use "Prosecutorial Discretion". This commenterbelieved this was important not only for the public but alsobecause of the work being planned by PENNDOT for resurfacingRoute 313.

EPA Response; The statute directs the Agency, through thePresident, to offer PRPs an opportunity to negotiate a

AR30(6lf!

34

settlement if it would "expedite remedial action." Once suchspecial notice is issued, the Agency "may not commence anyaction" for the 120 day negotiation moratorium. The ultimatedecision on how to finance this remedy, however, is at EPA'sdiscretion; and, EPA will not make any such determinations atthis time.

APPENDICES A, B AND C


DUBLIN TCEADMINISTRATIVE RECORD FILE *

INDEX OF DOCUMENTS

SITE IDENTIFICATION

1. Report: A Water Resources Study of the Dublin Area,Dublin, Pennsylvania, prepared by InternationalExploration, Inc., 5/7/84. P. 100001-100066.

2. Report: Analysis of Hydrologic Data gathered in1984 for the Dublin Study Area, prepared byInternational Exploration, Inc., 2/12/85.P. 100067-100142.

3. Quarterly Review of Dublin Hydrologic Data, April1985 - June 1985, 7/5/85. P. 100143-100173.

4. Quarterly Review of Hydrologic Data, July 1985 -September 1985, 10/8/85. P. 100174-100203.

5. Quarterly Review of Hydrologic Data, October 1985 -. December 1985, 1/86. P. 100204-100228:

6. Quarterly Review of Hydrologic Data Collected inDublin Borough, January 1986 - March 1986, 4/15/86.P. 100229-100284.

•7. Quarterly Review of Hydrologic Data, Dublin Borough,••-... April 1986 - June 1986, 7/28/86. P. 100285-100308.

8. Letter to Ms. Lori Acker, U.S. EPA, from Mr. EverettC. Hogg, County of Bucks, Department of Health, re:Tabulation of TCE analysis results for samplescollected from wells in Dublin Borough, 8/29/86,

• P. 100309-100369. The?fallowing are attached:

a) four handwritten TCE sample result forms;b).v;$. a. map of Dublin;

. vc) ..:.;'if'handwritten memorandum dated September2, 1986 regarding the data;

d) a handwritten memorandum regarding DublinBorough's wells;

e) two ground water contour maps;f) a hydrologic monitoring locations map;g) a map illustrating the largest consumers

of ground water;

Administrative Record File available 8/5/91.

h) a map illustrating the monitor welllocations surrounding the Rosenelli Testwell;

i) a monitor well data sheet;j) special analyses report, sample numbers

111108-13, 0111116-17, 0111119-24,0161129-36, 0161149-52, 0161171-82, and1161202;

k) Quality Control Laboratory, Inc., reportnumbers 86024522, 86023626, 86024875,86024422;

1) two water quality analysis reports;m) a well water sample report.

9. Report: Preliminary Assessment of Dublin WaterSupply Site, prepared by NUS Corporation,12/23/88.P. 100370-100778.

10. Report: Site Inspection Using Available Informationof Dublin Water Supply, prepared by NUS Corporation,8/9/89.P. 100779-101224.

11. National Oil and Hazardous Substance ContingencyPlan, The National Priorities List Revisions:Amendment, Proposed Rule Public Docket Index -Update #10, 10/26/89. P. 101225-101226.

12. Letter to Mr. Larry Reed, U.S. EPA, from Mr. John P.Judge, Cohen, Shapiro, Polisher, Shiermen and Cohen,re: Supplemental public comment of SequaCorporation to proposed listing of Dublin,Pennsylvania TCE Site on the National PrioritiesList, 6/15/90. P. 101227-101448.

III. REMEDIAL RESPONSE PLANNING

1. Report: Report of Hydrogeologic Analysis of theBorough of Dublin, Groundwater Supply Wells,prepared by Mercuri and Associates, Inc., 4/87.P. 300001-300080.

2. Report: Results of Soil Sampling Program, preparedby BCM Engineers, Inc., 3/88. P. 300081-300147. Atransmittal letter is attached.

* 3. Exhibit List-H: Cost Study-Dublin Borough WaterSystem, 8/8/88. P. 300148-300155.

* 4. Exhibit List-B: Geaghty & Miller Map, 8/11/88.P. 300156-300258.

5. Report: Results of Groundwater Investigation,prepared by BCM Engineers, Inc., 10/88. P. 300259-300311. A transmittal letter is attached.

6. Delaware River Basin Commission, Application forApproval of a Proposed Groundwater Withdrawal,11/28/88. P. 300312-300509. A hydrogeologicalanalysis of the Rosenelli well report is attached.

* 7. Exhibit List II-O: Recent information, test, etc.,4/89. P. 300510-300523.

8. Letter to Mr. George C. Elias, Delaware River BasinCommision, from Mr. John F. Fabian, PADER, re:Approval of Water Supply Application No. 0989504,6/1/89. P. 300524-300524.

9. Letter to Mr. Robert E. Day-Lewis, PennsylvaniaDepartment of Environmental Resources (PADER), fromMr. John Philip Diefender, Stuckert and Yates, re:Exhibits to proceedings, 7/26/89. P. 300525-300525.

10. Letter to Mr. Robert Day-Lewis, PADER, from Ms.Barbara J. Rudnick, Mercuri and Associates, Inc.,re; Confirmation of discussion on ground water,9/18/89. P. 300526-300526A.

Only relevant portions of this document have beenreproduced. The complete document can be found atU.S. EPA Region III, Philadelphia, PA.

11. Letter to Mr. John P. Diefenderfer, Stucker andYates, from Mr. Anderson Lee Hartzell, PADER, re:Proposed permitting of the Rosenelli well in Dublin,9/19/89. P. 300527-300529.

12. Letter to Mr. Luther L. Wonsidler, Dublin Borough,from Mr. Lewis Luchie, PADER, re: Water SupplyPermit No. 0989504, 9/21/89. P. 300530-300536. Thefollowing are attached:

a) Public Water Supply Permit No. 0989504;b) notification regarding quarterly analysis

for trichloroethylene;c) Agreement between PADER and the Borough of

Dublin in the issuance of the permit;d) letter regarding site visit;e) a Dublin Borough well data printout.

13. Letter to Dr. Bruno Mercuri, Mercuri and Associates,Inc., from Mr. Robert E. Day-Lewis, PADER, re:Agreement on location of monitoring well, 9/27/89.P. 300537-300537.

14. Agreement between the Borough of Dublin and PADER,10/2/89. P. 300538-300539.

15. Letter to Mr. Robert Day-Lewis, PADER, from Ms.Barbara A. Dolce and Mr. Robert A. Saar, Geraghtyand Miller, Inc., re: Additional informationconcerning ground water recovery and treatment on ornear the 120 Mill Street property, 10/19/89.P. 300540-300545. Table 1 - Water andTrichloroethene (TCE) Volumes in Contaminated Areas,Dublin Borough, Pennsylvania and Table 2 - PumpingRates for Remediation of High Concentration Areanear 120 Mill Street Property, Dublin Borough,Pennsylvania are attached.

16. Letter to Mr. Robert E. Day-Lewis, PADER, from Mr.John A. Garges, BCM Engineers, Inc., re:Confirmation of a telephone conversation concerningthe Thompson water tower leak, 1/10/90. P. 300546-300546.

17. Report: Hydrogeologic Analysis of Dublin BoroughWells no. 1 and no. 2, Consultant's Report for the •)Year 1989, prepared by Mercuri and Associates,Inc.,3/90.PT 300547-300759.

18. Letter to Mr. John H. Thompson, ThompsonOrganization, from Mr. William H. Jolly, PADER, re:Confirmation of results for investigation regardingrelease of TCE contaminated water, 3/27/90.P. 300760-300767. The following are attached:

a) letter regarding the investigation ofthe Thompson water tank;

b) a Statement of Conditions BuildingPermit 190-873-BZP;

c) hand drawn map of a contaminantchamber;

d) Application for Permit for Erection ofNew Building or Alternation ofAddition to an Existing Building;

e) memorandum regarding a daily report ofactivity at the Thompson tank;

f) hand drawn map of Thompson tank;

19. Letter to Dr. Robert A. Saar, Geraghty and Miller,Inc., from Mr. Robert E. Day-Lewis, PADER, re:Comments regarding the Conceptual RemedialAlternatives Work Plan, 3/28/90, P. 300768-300769.

20. Letter to Mr. Mark J. Vasoli, Dublin Borough, fromMr. William D. Kee, Cowan Associates, re: Estimateof operation and maintenance costs for the proposedwater treatment plant, 4/18/90. P. 300770-300777.The cost estimates and a water distribution systemmap are attached.

21. Letter to Mr. John Diefenderfer, Stuckert and Yates,from Mr. William D. Kee, Cowan Associates, Inc., re:Comments to a site investigation, 4/18/90.P. 300778-300780.

22. Report: Results of Source Investigation, 120 MillStreet Site, Dublin Borough, Pennsylvania, preparedby Geraghty and Miller, Inc., 6/90.P. 300781-300937. A transmittal letter is attached.

23. Report: Cost of Remedial Action, prepared by CH2MHill, 7/12/90.P. 300938-300998. A transmittalletter is attached.

Only relevant portions of this document have beenreproduced. The complete document can be found atU.S. EPA Region III, Philadelphia, PA.

24. Letter to Mr. Larry Reed, U.S. EPA, from Mr. Leon T.Gonshur, PADER, re: Consent Order and Agreementbetween PADER and Sequa Corporation, 7/26/90.P. 300999-301011. The Consent Order and Agreementis attached.

25. Letter to Mr. Mark Vasoli, Borough of Dublin, Mr.John P. Diefenderfer, Stuckert and Yates, and Mr.William Kee, Cowan and Associates, re: Comprehensivereport on drilling and construction of a TCEmonitoring well, 8/15/90. P. 3011012-301014. TheTCE monitoring well report is attached.

26. Letter to Ms. Diane Walker, U.S. EPA, from Mr. JohnP. Judge, Cohen, Shapiro, Polisher, Shiekman, andCohen, re: Response of Sequa Corporation to letterdated August 22, 1990, 10/26/90. P. 301015-301076.A response letter dated October 24, 1990 and exhibitA: Source Investigation Work Plan 120 Mill StreetSite and Conceptual Remedial Alternatives for theBedrock Aquifer Underlying Dublin Borough,Pennsylvania are attached.

27. Letter to Mr. Edwin B. Erickson, U.S. EPA, from Mr.John Philip Diefenderfer, Stuckert and Yates, re:Recovery cleanup at the Dublin Site, 12/11/90.P. 301077-301117. The following are attached:

a) letter by EPA in response to the December11, 1990 correspondence;

b) letter regarding the estimate of operationand maintenance (0 and M) cost for theproposed Water Treatment Plant (WTP);

c) Operating and Maintenance Manual;d) two Thompson/Sequa TCE Removal System

maps.28. Letter to Mr. Philip Rotstien, U.S. EPA, from Mr. J.

Vaaoli, Borough of Dublin, re: Monitoring well TCEtest results, 2/9/91. P. 301118-301120. A letterregarding a laboratory report and a laboratorysample results form are attached.

29. Memorandum to file from Mr. Mark J. Vasoli, Boroughof Dublin, re: Organic volatile test results,2/21/91. P. 301121-301126. Two Certificates ofAnalysis, two Chemical or Radiological AnalysisInput forms, and a Chain of Custody are attached.

30. Memorandum to Ms. Diane Walker, U.S. EPA, from Mr.David M. Kargbo, U.S. EPA, re: Review of March 1990Hydrogeologic Analysis of Wells 1 and 2, 3/19/91.P. 301127-301129.

31. Phone Conversation Record of Mr. Mark Vasoli,Borough of Dublin, with Ms. Diane Walker, U.S. EPA,re: Public distribution system, 5/22/91.P. 301130-301131.

32. Phone Conversation Record of Ms. Susan Coburn,Whistlewood Apartment Complex, with Ms. DianeWalker, U.S. EPA, re: Structure and capacity of thewater production well, 5/23/91. P. 301132-301132.

33. Phone Conversation Record of Mr. David Shapowal,Thompson Toyota, with Ms. Diane Walker, U.S. EPA,re: Wells located at 120 Mill Street, 5/23/91.P. 301133-301133.

34. Letter to Ms. Diane J. Walker, U.S. EPA, from Mr.Mark J. Vasoli, Borough of Dublin, re: Map withborough properties currently tied into the publicwater system, 5/29/91. P. 301134-301135. The mapis attached.

35. Letter to Ms. Diane Walker, U.S. EPA, from Mr.Thomas R. Hartnett, PADER, re: Preliminary list ofApplicable or Relevant and Appropriate Requirements(ARARs), 6/3/91. P. 301136-301138.

36. Phone Conversation Record of Mr. Mark Vasoli,Borough of Dublin, with Ms. Diane Walker, U.S. EPA,re: Water line construction estimates, 6/10/91.P. 301139-301139.

37. Letter to Mr. Mark Vasoil, Borough of Dublin, fromMs. Diane Walker, U.S. EPA, re: Water lineconstruction estimates, 6/12/91. P. 301140-301144.The cost estimates are attached.

38. Phone Conversation Record of Mr. Bruno Mercuri,Mercuri and Associates, Inc., with Ms. Diane Walker,U.S. EPA, re: Information about the publicdistribution system, 6/13/91. P. 301145-301147.

SR3QI650

39. Phone Conversation Record of Mr. Mark Vasoli,Borough of Dublin, with Ms. Diane Walker, U.S. EPA,re: Water usage in the borough, 6/21/91.P. 301148-301149.

40. Letter to Ms. Diane J. Walker, U.S. EPA, from Mr.John Philip Diefenderfer, Stuckert and Yates, re:Dublin Borough Ordinance No. 205, 6/26/91.P. 301150-301156. The ordinance is attached.

41. Memorandum to file from Ms. Diane Walker, U.S. EPA,re: A January 18, 1991 meeting to discuss waterusage, (undated). P. 301157-301157.

42. Memorandum to Ms. Diane Walker, U.S. EPA, from Mr.Anderson Lee Hartzell, PADER, re: Consent Order andagreement between PADER and Sequa Corporation,(undated). P. 301158-301169. The Consent Order isattached.

43. Map of Dublin, (undated). P. 301170-301171. Apartial list of wells in Dublin from a reportentitled Pennsylvania Department of InternalAffairs, Groundwater Resources of Bucks County, PAis attached.

IV. REMOVAL RESPONSE PROJECTS

1. Memorandum to Mr. Gerry Heston, U.S. EPA, from Mr.Mark Tucker, Roy F. Weston, Inc., re: Carbonefficiency, 8/19/86. P. 400001-400010.

2. U.S. EPA Incoming Spill Report, Dublin Water Supply,8/27/86. P. 400011-400011.

3. Trichloroethylene (TCE) Factual Information Sheet,prepared by Chemical Information Systems, Inc.,8/29/86. P. 400012-400018.

4. Letter to Ms. Lori Acker, U.S. EPA, from Mr. EverettC. Hogg, County of Bucks, re: Transmittal of TCEanalysis results, 8/29/86. P. 400019-400023. Theresults are attached.

5. Pollution Report #1, Dublin Water Supply, 9/9/86.P. 400024-400025.


7. Hazardous Waste Site Investigation and EmergencyResponse Safety Plan, prepared by Roy F. Weston,Inc., 9/10/86. P. 400028-400034.

8. Memorandum to Mr. Jay Rodstein, U.S. EPA, from Mr.Greg Janice and Mr. Peter Harnett, Roy F. Weston,Inc., re: Background information on Dublin TCESite, 9/15/86. P. 400035-400089.


10. Memorandum to Mr. Jay Rodstein, U.S. EPA, from Mr.T Greg- Janice and Mr. Peter Harnett, Roy F. Weston,Inc., re: Transmittal of Scope of Work, 9/18/86.P. 400092-400095. The Scope of Work is attached.

11. Pollution Report 14, Dublin Water Supply, 10/6/86.P. 400096-400097.


^30/652



15. Pollution Report 18, Dublin Water Supply, 10/22/86.P. 400104-400105.

16. Memorandum to Mr. Charles J. Walters, U.S. EPA, fromthe Acting Director, Department of Health & HumanServices, re: Health consultation for Dublin WaterSupply, 10/23/86. P. 400106-400117.


18. Letter to Mr. John N. Thompson from Mr. Walter E.Stanley, Jr., PADER, re: Results of sampling tests,11/12/86. P. 400120-400121.



21. Letter to Mr. Michael Mason, U.S. EPA, from Mr.Robert C. Brod, BCM Engineers, Inc., re:Residential well sampling plans, 11/25/86.P. 400127-400328.

»

22. Tap Water Summary, Dublin TCE Site, 12/2/86.P. 400329-400342.

23. Letter to Ms. Deane Bartlett, U.S. EPA, from Mr.Brian J. McCullough, Connolly, Chandor & McAndrews,re: Comments on BCM's proposal, 12/30/86.P. 400343-400357. The Proposal for GroundwaterContamination Investigation and Remediation Plan isattached.

24. Letter to Mr. Michael Mason, U.S. EPA, from Mr.Michael Galvin, Versar, Inc., re: Split samplingresults, 1/12/87. P. 400358-400361. A data summarysheet and a chain of custody form are attached.

10 /5R30I653

25. Memorandum to Mr. Michael Mason, U.S. EPA, and Mr.Robert Young, PADER, from Mr. Peter G. Noll, Countyof Bucks, re: Comments on ground water monitoringproposal, 2/5/87. P. 400362-400362.

26. Letter to Ms. Deane H. Bartlett, U.S. EPA, from Mr.Brian J. McCullough, Connolly, Chandor & McAndrews,re: Ground water sampling, 3/11/87. P. 400363-400368.

27. Letter to Ms. Deane H. Bartlett, U.S. EPA, from Mr.Robert C. Brod, BCM Engineers, Inc., re:Transmittal of draft Work Plan, 3/27/87. P. 400369-400377.

28. Letter to Ms. Deane H. Bartlett, U.S. EPA, from Mr.Steven F. Kemp, BCM Engineers, Inc., re:Transmittal of Work Plan, 5/21/87. P. 400378-400386.

29. Letter to Mr. Michael Mason, U.S. EPA, from Mr.Steven F. Kemp, BCM Engineers, Inc., re:Transmittal of Work Plan, 5/21/87. P. 400387-400389.

30. Consent Agreement and Order, In the Matter Of:Dublin TCE Site, John H. Thompson, Respondent,Docket No. III-87-22-DC, 6/29/87. P. 400390-400398.

31. Report: Revised Hydrogeologic Investigation Planfor Thompson Property, prepared by BCM Engineers,Inc., 7/87.P. 400399-400415.

32. Letter to Mr. Steven F. Kemp, BCM Engineers, Inc.,from Mr. Robert 0. Young, PADER, re: Revisedhydrogeologic investigation plan, 8/31/87.

-. P. 400416-400418.

33. Letter to Mr. Robert Wallace, Funk Water QualityCompany, from Mr. Robert J. Wyatt, BCM Engineers,Inc., re: Installation of. water treatment systems,9/2/87. P. 400419-400423.

34. Letter to Mr. Robert 0. Young, PADER, from Mr.Steven F. Kemp, BCM Engineers, Inc., re: Soil vaporsurvey results, 11/18/87. P. 400424-400431.

35. Tap Water Summary, Dublin TCE Site, 12/1/87.P. 400432-400439.

36. Letter to Mr. Michael Mason, U.S. EPA, from Mr.Robert J. Wyatt, BCM Engineers, Inc., re: Resultsof tap water sampling, 1/15/88. P. 400440-400444.

37. Letter to Mr. Michael Mason, U.S. EPA, from Mr.Steven F. Kemp, BCM Engineers, Inc., re: Work Planimplementation, 1/19/88. P. 400445-400457.

38. Report: Assessment of Source Contamination inWhistlewood Apartment Complex Water Supply Well,prepared by Roy F. Weston,Inc., 2/15/88.P. 400458-400495.

39. Tap Water Sampling Results, Dublin TCE Site, 2/2/88.P. 400496-400676.

40. Memorandum to Ms. Henrietta Woodward, U.S. EPA, fromMr. Cornelius F. Carr, U.S. EPA, re: Fileaccessibility, 3/88. P. 400677-400680.

41. Memorandum to Mr. Michael Mason, U.S. EPA, from Mr.Daniel K. Donnelly, U.S. EPA, re: Transmittal ofanalytical reports, 3/30/88. P. 400681-400684.

42. Letter to Mr. John Galligan, Jr., John Galligan andSons, from Mr. Robert J. Wyatt, BCM Engineers, Inc.,re: Filter renewal in Dublin, 4/7/88. P. 400685-400686.

43. Letter to Mr. Steven F. Kemp, BCM Engineers, Inc.,from Mr. Robert E. Day-Lewis, PADER, re: Soilsampling program, 4/8/88. P. 400687-400687.

44. Letter to Mr. Bob Day-Lewis, PADER, from Mr. RobertJ. Wyatt, BCM Engineers, Inc., re: Monitoring welllocation modification, 4/21/88. P. 400688-400689.

45. Letter to Mr. Michael Mason, U.S. EPA, from Mr.Robert J. Wyatt, BCM Engineers, Inc., re: Samplingresults, 4/22/88. P. 400690-400796.

46. Letter to Ms. Mary Letzkus, U.S. EPA, from Mr. ScottSlagley, Versar, Inc., re: Transmittal ofanalytical results of the volatile organics analysissamples, 7/25/88. P. 400797-400814.

12 AR30I655

47. Letter to Ms. Mary Letzkus, U.S. EPA, from Mr.Robert J. Wyatt, BCM Engineers, Inc., re: Summaryof tap water sampling results, 8/18/88. P. 400815-400830. The results are attached.

48. Letter to Ms. Mary Letzkus, U.S. EPA, from Mr. ScottA. Slagley, Versar, Inc., re: Results of volatileorganics water samples analysis, 8/24/88.P. 400831-400834.

49. Letter to Ms. Mary Letzkus, U.S. EPA, from Mr. ScottA. Slagley, Versar, Inc., re: September monthlyreport, 10/4/88. P. 400835-400845. The report isattached.

50. Letter to Ms. Mary Letzkus, U.S. EPA, from Mr.Robert J. Wyatt, BCM Engineers, Inc., re: Resultsof tap water sampling, 11/8/88. P. 400846-400949.The results are attached.

51. Tap Water Residential Sampling Data, 12/6/88.P. 400950-400958.

52. Memorandum to Mr. Eric Johnson, U.S. EPA, from Mr.Daniel K. Donnelly, U.S. EPA, re: Results ofvolatile organics analysis, 1/4/89. P. 400959-400966. The results are attached.

53. Memorandum to Mr. Eric Johnson, U.S. EPA, from Ms.Theresa A. Simpson, U.S. EPA, re: Review oforganic data, 2/8/89. P. 400967-400998. The reviewis attached.

54. Memorandum to Mr. Eric Johnson, U.S. EPA, from Mr.Daniel K. Donnelly, U.S. EPA, re: Volatile organicsanalysis report, 5/2/89. P. 400999-401007. The

• report is attached.

5ST. Letter to Ms. Mary Letzkus, U.S. EPA, from Mr. JohnA. Garges and Mr. John V. Interrante, BCM Engineers,Inc., re: Transmittal of analytical results for tapwater sampling, 5/12/89. P. 401008-401215. Theresults are attached.

56. Letter to Mr. Peter Kho, U.S. EPA, from Ms. VirginiaH. Pohlman, Versar, Inc., re: Detection differencesfor TCE, 5/18/89. P. 401216-401217.

13 AR30I656

57. Residential water sampling results, 7/21/89.P. 401218-401228.

58. Memorandum to Mr. Peter Kho, U.S. EPA, from Ms.Theresa A. Simpson, U.S. EPA, re: Organic datareview, 8/16/89. P. 401229-401290. The review isattached.

59. Letter to Mr. Rich Dolcey, U.S. EPA, from Mr. JohnA. Garges and Mr. Steffan R. Helbig, BCM Engineers,Inc., re: Transmittal of analytical results fortap water sampling, 8/28/89. P. 401291-401422. Theresults are attached.

60. Letter to Mr. Peter Kho, U.S. EPA, from Mr. MarkdiFeliciantonio, COM Federal Programs Corporation,re: Data base for work assignment, 8/30/89.P. 401423-401435. The tap water sampling summary isattached.

61. Memorandum to Mr. Eric Johnson, U.S. EPA, from Ms.Theresa A. Simpson, U.S. EPA, re: Organic datareview, 9/7/89. P. 401436-401491. The review isattached.

62. Letter to Ms. Jean Cooper, U.S. EPA, from Mr. PaulWooldridge, Versar, Inc., re: Transmittal of sampleshipping log and chain of command records, 9/11/89.P. 401492-401495. A shipping log and two recordsare attached.

63. Memorandum to Mr. Peter Kho, U.S. EPA, from Mr.Daniel K. Donnelly, U.S. EPA, re: Volatile organicsreport, 10/16/89. P. 401496-401522. The report isattached.

64. Letter to Mr. Edwin Erickson, U.S. EPA, from Mr.John Philip Diefenderfer, Stuckert and Yates, re:Comments on the Consent Order, 6/25/90.P. 401523-401530.

65. Letter to Mr. John P. Diefenderfer, Stuckert andYates, from Mr. Dennis P. Carney, U.S. EPA, re:Response to letter of June 25th and comments on theConsent Order, 9/5/90. P. 401531-401532.

14 AR30I657

66. Letter to Mr. Kenneth Kryszczun, U.S. EPA, from Mr,Charles Walters, Agency for Toxic Substances andDisease Registry, re: Transmittal of DraftPreliminary Health Assessment, 10/23/90,P. 401533-401557. The report and a letter areattached.

67. Dublin TCE Site, Work Plan, (undated.) P. 401558-401565.

68. Modification to the Consent Agreement and Order ofJune 29, 1987 Between United States of America andJohn H. Thompson, Docket No. III-87-22-DC, 4/91.P. 401566-401567.

15

AR30I658

V. COMMUNITY INVOLVEMENT/CONGRESSIONAL CORRESPONDENCEIMAGERY

1. Letter to the Honorable Peter H. Rostmayer, U.S.House of Representatives, from Mr. Edwin B.Erickson, U.S. EPA, re: Progress of activity by EPAat the Dublin TCE Site, 10/18/90. P. 500001-500007.A copy of the letter with concurrences and atransmittal letter regarding the site is attached.

2. Letter to the Honorable Peter H. Rostmayer, U.S.House of Representatives, from Mr. Edwin B.Erickson, U.S. EPA, re: Alternative options for thewater supply for residents whose wells may beaffected by contamination from the site, 5/15/91.P. 500008-500011. A copy of the letter withconcurrences, a letter concerning a focusfeasibility study and payments of costs related tocleanup, and a transmittal letter regarding the siteare attached.

3. Letter to Ms. Elaine Spiewak, U.S. EPA, from Mr.Mark diFeliciantonio, COM Federal ProgramsCorporation, re: Fact Sheet for Dublin TCE Site,5/17/91. P. 500012-500020. The fact sheet isattached.

16

SITE SPECIFIC GUIDANCE DOCUMENTS INCLUDED

1. "Ultraviolet Light, Researchers Use UV Light for VOCDestruction," Hazmat World, 5/90.

2. Bucks County Water Supply Inventory, prepared byBucks County Planning Commission, 12/88.

3. The Hazards of Using Point-of-Use Water TreatmentDevices Employing Activated Carbon, prepared byHealth and Welfare Canada, 12/80.

4. "Bacteria Associated with Granular Activated CarbonParticles in Drinking Water," Applied andEnvironmental Microbiology, 9/86.

5. "Growth and Persistence of Pathogens on GranularActivated Carbon Filter," Applied and EnvironmentalMicrobiology, 12/85.

6. Air Stripper Design Manual, prepared by ResearchTriangle Institute, 5/90.

7. Technology Evaluation Report; SITE ProgramDemonstration of the Ultrox InternationalUltraviolet Radiation/Oxidation Technology, 1/90.

8. Ultrox International Ultraviolet Radiation/OxidationTechnology, Applications Analysis Report, 9/90.EPA/540/A5-89/012

9- Point-of-Entry Drinking Water Treatment Systems forSuperfund Applications, prepared by PEI Associates,Inc., 6/89. ——————EPA/600/2-89/027

10^ Environmental Pollution Control AlternativesDrinking Water Treatment for Small Communities,J7W.EPA/625/5-90/025.

17

^301660

BIBLIOGRAPHY OF SITE SPECIFIC GUIDANCE DOCUMENTS

1. A Guide to Selecting Superfund Remedial Actions,4/1/90.OSWER #9355.0-27FS

2. Control of Air Emissions from Superfund AirStrippers at Superfund Groundwater Sites.OSWER #9533-0-28

3. Guidance for Conducting Remedial Investigations andFeasibility Studies Under CERCLA, prepared byOSWER/OERR, October 1, 1988.OSWER #9355.3-01

4. A Compendium of Technologies Used in the Treatmentof Hazardous Wastes,prepared by ORD/CERI,September1, 1987.EPA-625/8-87/014

5. Carbon Absorption Isotherms for Toxic Organics,prepared by R.A. Dobbs, MERL, and J.M. Cohen, MERL,April 1, 1980.EPA-600/8-80-023

6. Handbook Remedial Action at Waste Disposal SitesTRevised), prepared by ORD/HWERL and OSWER/OERR,October 1, 1985.EPA-625/6-85/006

7. Guidance Document for Providing Alternate WaterSupplies, prepared by OERR, February 1, 1988.OSWER #9355.3-03

8. Remedial Action Costing Procedures Manual, preparedby JRB Associates/CH2M Hill, ORD/MERL, andOSWER/OERR, October 1, 1987.EBA-600/8-87/049

18 AR30I66I

TABLES 1 THROUGH 5


3R30I662

Table 1Affected or Potentially Affected Residences and Businesses

Known to-date

North Property Occupancy WaterMain Street Owner Usage fotidl

105 DellaBadia Business 500**106 Dairy Queen Business 100-314+112 Rhine Station Business 37-60+113 Hinsdale Residence 160**115 Boyle Residence 160**116 Occhi Residence 160**117 Buchanan Residence 160**119 Hirst Residence 160**122 Rufe Residence 160**123 Emico Business B-931-1200,

A-100-160+124 Meyers Residence 160**126 Meyers Residence/Business 300**128 Fluck Residence 160**131 Evans Post Office 160**130 Moyer Residence/Business A-200-300+

B-54-199+133 McVaugh Business 900-1500+133W. Jacobs Residence 160**138 Moyer Business 160**139 Bishop Business 37-52+142 First Federal Business 21-47+145 Bucks Bank Business 95-241+146 Whistlewood Residences 16000-17000+149 Grady Residence 160**150 Daniel Residence 160**153 Myrick Residence 160**161 Shopping Cnt Businesses 6000+164 Haring Residence 160**169 Southland Business 179-251+170 Tenley Residence 900-1900+173 My«rs Residence 160**174 Jaaes Residence/Business 170-215+179 Crouthamel Residence/Business 500**183 Moyer Business 2235-2670+194 Dublin Fire Business 1000+Mill Straat

104 Farm Bureau Business 500**120 Thompson/LTI Business 1- 300**f

2- 73-106+3-127-311+4-972-1200+

3H30I663

TABLE 1 (continued)

Maple Street100 Shultz Residence 160**104 Buchanan Business/Residence 500**108 Williams Residence 160**110 Bishop Residence 160**112 Klemco Business 160**114 Klembeth Residence 160**116 Rice Residence 160**118 Hilltownlnvest Business 160**120 Detweiler Residence 160**122 Vasconez Residence 160**126-132 Shaddinger Residence 223-288+134 Schilling Residence 160**136 Kohl Residence 160**

Elephant Road

in stauffer Residence 160**113 Residence 160**114 Slaymaker Residence 160**115 Grace Residence 160**116 Black Residence 160**118 Black Residence 160**119 Hess Residence 160**139 Meyers Residence 160**141 Gahman Residence 160**146 Moyer Residence 160**147 Detweiler Residence 160**149 Fair Residence 160**150 Datweiler Residence 160**151 Sulpizio Residence 160**152 Rush Residence 160**153 Hager Residence 160**154 Fretz Residence 160**155 Worthington Residence 160**156 Blichasz Residence 160**

South Main Street

101 Dublin Inn Business 302-364+

KEY*Bourough Hydrogeologist's Estimate** EPA Estimate based on similar use and Guidance Documents+ Dublin Bourough Actual MeasurementsA and B refer to two wells on site1,2,3 and 4 refer to point measurments of water usage8 - water supply no longer in use

Table 2

Residents and Businesses for Monitoring ProgramKnown to-date

South Main Street

103105106

Maole Street

111113119121123127131Woodedge Apts.Cherry Lane

105107111115119121

Elephant Road

162164166168172174178

Deep Run Road

101103105108109110112111114

AR30I665

TABLE 2 (continued)

Middle Road

104105111112115116117

Rickerts RoadHilltown Township

Home at corner of Rickerts and North Main Street33043234323232243212320631323126302030002930

Dublin BoroughDublin AcresState Police

Frontier Road

215217

Table 3

Remedial MaximumContaminant Action Level On-Site

Level(PPb) (ppb)

1,1,1-Trichloroethane-i- 200a 53.8

Trichloroethylene 5a 10,000

Tetrachloroethylene 5a 13

1,1-Dichloroethylene 7a 9.8

cis-l,2-Dichloroethylene* 70a 14.7

trans-l,2-Dichloroethylene* 100a 7.4

Vinyl Chloride 2a 28

Notes:

a- Maximum Contaminant Level*- Compounds have not exceeded the MCLs in the groundwater at

the site but are degradation products of Trichlorethyleneand Tetrachlorethylene and, thus, may increase inconcentration over time

+- Compound has not exceeded MCL

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TABLB 5

COST SUMMARY

ALTERNATIVE CAPITAL O&M PRESENT WORTH*lil

2 2,200,000 138,000 2,600,000

3 2,600,000 169,000 3,300,000

4 100,000 390,000 2,800,000

5 3,000,000 250,000 4,500,000

6 3,100,000 300,000 5,000,000

7 3,100,000 260,000 4,600,000

* Present Worth Costa are estimated over a 30 year period at a 10% discount rate

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