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Superfund ProgramProposed PlanNorth Penn Area 7 Site (Operable Unit 2)Upper Gwynedd TownshipMontgomery County, Pennsylvania

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September 2003

EPA Announces Proposed Plan

The United States Environmental Protection Agency Region III (EPA) has identified thePreferred Alternative to address hazardous contamination in the soils ________at the Spra-Fin facility ("Site" or "property") which is part of theNorth Penn Area 7 Superfund Site located in Upper GwyneddTownship, Montgomery County, Pennsylvania. (Terms in bold printare defined in the Glossary.)

Dates to Remember:

This Proposed Remedial Action Plan (PRAP or "Proposed Plan") isbased on North Penn Area 7 site-related documents contained in theAdministrative Record, and including the Remedial Investigationand Feasibility Study (RI/FS). The Administrative Record can befound in either of the Site Information Repositories:

September 12,2003 -October 12,2003Public comment period onAlternatives in Proposed Plan

September 25,2003Public meeting atUpper Gwynedd TownshipBuilding Parkside Placeat 7:00 PM

North Wales Library201 Summit StreetNorth Wales, PA 19454(215)699-5410Hours: Mon-Fri 1:00 PM-4:00 PM

& 7:00 PM-9:00 PM

Public Reading Room ™———Anna ButchAdministrative Record CoordinatorU.S. EPA-Region III1650 Arch StreetPhiladelphia, PA 19103(215)814-3157Hours: Mon-Fri 9:00 AM-4:30 PM

SITE BACKGROUND....................................2SCOPE AND ROLE OF OPERABLE UNIT ORRESPONSE ACTION.....................................4SUMMARY OF SITE RISKS..,.........,.........-,...5NATURE AND EXTENT OFCONTAMINATION.......,..-.....,.....,-............^REMEDIAL ACTION OBJECTIVES.,..........,.....?SUMMARY OF REMEDIAL ALTERNATIVES... ..8EVALUATION OF ALTERNATIVES...............10PREFERRED ALTERNATIVE.....................15COMMUNITYPARTIC1PATION...,.....,...........16

EPA and the Commonwealth of Pennsylvania encouragethe public to review and comment on the PreferredAlternative, the Proposed Plan, and other documents in theAdministrative Record file. The public comment periodbegins on September 12, 2003 and closes on October 12,2003, On September 25, 2003 at 7:00 p.m., EPA will holda public meeting to discuss the Proposed Plan at:

Upper Gwynedd Township BuildingParkside PlaceWest Point, PA 19486

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Written comments, postmarked no later than October 12, 2003 should be sent to:

Deanna G. Moultrie (3HS21)Remedial Project ManagerU.S. EPA1650 Arch StreetPhiladelphia, PA 19103(215)814-5125

Interested persons are encouraged to submit their comments on the Proposed Plan and the otherdocuments in the Administrative Record to EPA during the public comment period. AlthoughEPA has selected a preferred alternative, no final decision has been made. EPA may modify thePreferred Alternative, select another response action, or develop another alternative if publiccomment or new information presented warrants such an action. EPA, the lead agency, inconsultation with the Pennsylvania Department of Environmental Protection (PADEP), thesupport agency, will make its final selection of a remedy for the contamination at the Site in aRecord of Decision (ROD).

This Proposed Plan fulfills the public notification requirements of Sections 113(k)(2)(B), 117(a),and 121(f)(l)(G) of the Comprehensive Environmental Response, Compensation, andLiability Act of 1980, as amended (CERCLA) 42 U.S.C. §§ 9613(k)(2)(B), 9617(a), and9621(f)(l)(G) (also known as "Superfund").

SITE BACKGROUND

North Penn Area 7 ("NP7") encompasses 650 acres in Upper Gwynedd Township, MontgomeryCounty, Pennsylvania. NP7 consists of five current and former manufacturing facilities, one ofwhich is the Spra-Fin facility. NP7 was added to the National Priorities List (NPL) on March31, 1989 for contamination of soil and ground water by chlorinated solvents includingtrichloroethene (TCE), tetrachloroethene (PCE), carbon tetrachloride, methylene chloride, andvinyl chloride (VC).

Spra-Fina Incorporated is one of five potentially responsible party (PRP) facilities associatedwith NP7, and is the subject of this Proposed Plan. The remaining facilities are the former Leeds& Northrup Company, Incorporated facility, the former Ford Electronics and RefrigerationCorporation facility, the Teleflex Incorporated facility, and the former Zenith ElectronicsCorporation facility.

The Spra-Fin facility is located on a 1.1 acre property on Wissahickon Avenue in North Wales,Montgomery County, Pennsylvania. Figure 1 is a map showing the location of NP7 and Figure2 is a map of the Spra-Fin Site area. The Spra-Fin property is identified by the MontgomeryCounty Board of Assessments as parcel #56-00-09940-003, Block 022, Unit 014, UpperGwynedd Township. Wissahickon Avenue borders the property on the southwest side. To theeast, the property is bordered by Southeastern Pennsylvania Transit Authority (SEPTA) railroadtracks. To the north, the property is bordered by a residential property and an industrial property.The property is situated in an overall industrial neighborhood with some residential properties.

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The property currently consists of a one story, brick building (5,584 square feet), and an on-sitetrailer. A second building occupied the street-side portion of the property until late 1996, when itwas consumed by fire. The burned building was demolished and the remains removed from theSite by an order of the Township of Upper Gwynedd in 1997. The concrete pad upon which thedestroyed building was built, is still in place and is used as a parking area and the location of thetrailer. The on-site trailer is used as an administrative office space. One production well iscurrently located on the property and is used as an industrial water source. The property has noconnection to the public water or sewer lines.

The U.S. Environmental Protection Agency is the lead agency for the NP7 Spra-Fin Site, and thePennsylvania Department of Environmental Protection (PADEP) is the support agency.PADEP has provided support concerning State of Pennsylvania cleanup requirements.

Past Investigations and Response Actions

As part of a study for the Wissahickon Valley Watershed Association and the North Perm WaterAuthority (NPWA) conducted in 1981, ten boreholes were drilled in the overburden soilssurrounding the main building on the property. The boreholes were drilled to bedrock, and onesoil sample was collected from the bottom of each hole. Bedrock was generally encountered atdepths ranging from 6 to 10 feet.

Various chlorinated solvents were detected in Site soils during this investigation. The highestlevel of TCE was detected at location BO81-7, near the former location of the undergroundstorage tank, at a concentration of 158,000 ppb. PCE and 1,1,1-trichloroethane (1,1,1-TCA)were also detected in this boring at concentrations of 30,360 ppb and 10,040 ppb respectively. Inother borings, TCE concentrations ranged from 5 to 5,460 ppb; PCE concentrations ranged from0.2 to 870 ppb; and 1,1,1-TCA ranged from less than 0.2 to 40 ppb.

In 1982 and 1983, soil borings were advanced to depths of 7 to 8 feet at seventeen locations onthe property as part of a study conducted by NPWA and the North Perm Water ResourcesAssociation. Soil samples were collected from 3 or 4 depths in each boring and analyzed forTCE.

As a result of the contamination identified during the two mentioned studies, the followingcleanup activities were performed by Spra-Fin:

• The underground storage tank was removed and replaced with a 500 gallon aboveground storage tank. The tank was completely enclosed in a block structure thatwas capable of containing a spill of the entire storage tank. A 200-gallon steelcatch basin was also reportedly installed beneath the tank.

• The exhaust vent from the degreaser area was repositioned from the groundsurface to the roof.

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• Approximately 60 cubic yards of the most heavily contaminated soil wasexcavated and disposed in a sanitary landfill. Following the excavation, anunderground drainage system was installed in the excavation pit. Ground water iscollected by perforated pipes, which ultimately discharge to the sanitary sewersystem.

• The two deep wells at the facility were pumped continuously. Water from one ofthe wells was pumped to the roof of the Spra-Fin building where it underwentaeration treatment via spraying.

• A packed tower was installed on one of the wells in 1986. No further informationregarding the packed tower was available.

The justification for the selection of the cleanup methods described above is unknown.

In July 1999, the Roy F. Weston, Site Assessment Technical Assistance team collected severalsurface and subsurface soil samples in the vicinity of the former underground storage tank as partof an EPA removal assessment. The removal assessment was done to determine if additionalexcavation of contaminated soils was necessary. A total of 11 surface soil and 9 subsurface soilsamples were collected.

Chlorinated volatile organic compounds (VOCs) were detected in all but two of the surface soilsamples collected. VOC contamination concentrations found were: TCE from non-detect to 27ppb, PCE from non-dectect to 16 ppb, Cis-l,2-dichloroethene (Cis-l,2-DCE) from non-detect to5 ppb.

Chlorinated VOCs were detected in all but one of the subsurface samples collected.Contaminant concentrations found were: TCE from non-detect to 180 ppb. PCE from 3 tol 10ppb. Cis-1,2-DCE from non-detect to 110 ppb.

Since 1980, NPWA has sampled ground water in the vicinity of the Site. Typical TCEconcentrations detected in onsite bedrock production wells have been greater than 500 ppb.Samples collected from the onsite bedrock production wells between 1981 and 1984 containedmaximum concentrations of TCE at 36,605 ppb, 1,1-dichloroethylene (1,1-DCE) at 6,801 ppb,andl,l,lTCAat236ppb.

SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION

The Proposed Remedial Action described in this Proposed Plan will comprehensively address thethreats posed by the release of hazardous substances at the Site. The threats posed by the Site aredue to surface and subsurface soils at the Spra-Fin facility that are contaminated with elevatedlevels of VOCs, semi-volatile organic compounds (SVOCs), and inorganic compounds.

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As with many Superfund sites, the problems at NP7 are complex. As a result, the EPA hasdivided the work into three separate planned remedial actions, called operable units (OUs).

• Operable Unit 1 (OU1): Contamination of the soils on four of the five propertiesassociated with NP7.

• Operable Unit 2 (OU2): Contamination of the soils on the remaining property.• Operable Unit 3 (OU3): NP7 Site-wide contamination of the ground water,

OU1 is currently in the Remedial Action/Feasibility Study (RI/FS) phase of the Superfundremedial process. Activities associated with the RI/FS are being performed by the potentiallyresponsible parties, with oversight by the EPA. OU3 is also in the RI/FS phase and is beingconducted by EPA. The OU2 remedial activities are being performed by the EPA. The actionstaken for this operable unit (OU2) are consistent with actions currently underway for OperableUnits 1 and 3.

SUMMARY OF SITE RISKS

As part of the RI process, EPA conducted an analysis to identify human health andenvironmental risks that could exist if no action were taken at the Site. This analysis, completedin accordance with the National Oil and Hazardous Substances Pollution Contingency Plan(NCP), is referred to as the Baseline Risk Assessment. This assessment provides the basis fortaking cleanup action, if any, and indicates exposure pathways that need to be addressed by theremedial action. The Baseline Human Health Risk Assessment (BLRA) evaluated human healthrisks and the Ecological Risk Assessment (ERA) evaluated environmental impacts from the Site.

Baseline Human Health Risk Assessment

The BLRA assesses the toxicity, or degree of hazard, posed by contaminants related to a site, andinvolves describing the routes by which humans and the environment could come into contactwith these substances. Separate calculations are made for those substances that can cause cancer(carcinogenic) and for those that can cause adverse health effects but are non-carcinogenic.

The NCP established acceptable levels of carcinogenic risk for Superfund sites ranging from oneexcess cancer case per 10,000 people exposed, to one excess cancer case per one million peopleexposed. This translates into a risk range of between one in 10,000 and one in 1,000,000 cancercases. Expressed in scientific notation, this risk range is between 1 .OE-04 and 1 .OE-06.Remedial action is warranted at a site when the calculated cancer risk level exceeds 1.OE-04.

The NCP also states that sites should not pose a health threat due to a non-carcinogenic, butotherwise hazardous, chemical. EPA defines a non-carcinogenic threat by the ratio of thecontaminant concentrations at a site that a person may encounter, to the established safeconcentration. If the ratio, called the Hazard Index (HI), exceeds one (1.0), there may beconcern for the potential non-carcinogenic health effects associated with exposure to the

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chemicals. The HI identifies the potential for the most sensitive individuals to be adverselyaffected by the non-carcinogenic effects of chemicals. As a rule, the greater the value of the HIabove 1.0, the greater the level of concern.

The BLRA performed for this property evaluated the potential risk associated with current landuse and potential future use, regarding exposure to on-site and off-site residents and employees.Based on the results of the risk assessment, the following receptors are at risk of developingunacceptable potential health risks as a result of hypothetical exposures to surface and subsurfacesoils at the property:

• Current/Future Industrial Workertotal HI =1.9

• Future Adult and Child Residentstotal HI - 2,7{adult}, and 9.5{child}

total carcinogenic risk = 4.4E-04(adult), 4.5E-04{child},and 8.9E-04{lifetime resident}

• Future Construction Workertotal HI - 2.4

The increased risk to the current or future industrial worker is due primarily to dermal contactwith the chromium in the on-site surface soil. The increased risk tp the future adult and childresidents is primarily due to incidental ingestion of and dermal contact with TCE> chromium,iron, and lead in the on-site soil, and inhalation of airborne contaminants from on-site soil.Finally, the increased risk to the future construction worker is primarily attributable to theincidental ingestion of TCE, and iron; and dermal contact with chromium in the on-site soil.

Ecological Risk Assessment

The ERA was designed to evaluate the potential threats to ecological organisms from exposure toSite contaminants and to establish potential Site-specific clean-up level(s) for the contaminantsof concern. The results of the ERA suggest that Site-related contaminants pose a risk toecological receptors from both direct contact screening and food chain modeling. However, it isimportant to note that the Site is a small, active industrial property without good habitat. It ispossible that many of the modeled receptors are rarely present or never present on the property.The surrounding areas (lawns, fields, and edge communities), while also not valuable habitat,would be more likely to be used by ecological receptors as they are larger and not activelydisturbed by human activity. Therefore, while risk was indicated at this Site, it may be overestimated as ecological receptors would not be attracted to this property.

Additionally, the majority of the risk indicated was due to metals and specifically lead, in surfaceand shallow subsurface soil. The highest lead contamination was limited to several smaller areas

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including the gravel parking lot, and locations behind the plant building. This surface andsubsurface contamination could be removed during the Site remedy thus removing a significantportion of the risk to receptors. Other metals and organics were found in many areas of the Sitebut removal of this surface contamination over a one-acre area could be easily achieved.

NATURE AND EXTENT OF CONTAMINATION

The RI identified the occurrence of contamination in several of the soil-gas, shallow groundwater and soil samples obtained from the Site. The extent of contamination identified in thesurface and subsurface soil is detailed below. Thirty soil-gas samples were taken as an initialstep for this investigation, and the results were used to identify locations for soil (surface andsubsurface) samples. The shallow ground water samples were obtained due to the observation ofground water, at shallow depths, during soil-gas sampling activities. Ground watercontamination will be addressed in the future as the focus of Operable Unit 3 for the entire NP7site.

Contaminant concentrations were compared to soil screening levels (SSLs), which weredeveloped by EPA to quantify the potential transfer of contamination from soil to ground water,and to PA Statewide Health Standards. All of the detected concentrations of TCE and VC in theshallow, intermediate, and deep samples exceed their respective SSL values, some by a largemargin. This indicates that there is significant potential for those contaminants to migrate fromsoil to ground water at this Site.

The FS for this Site focused on constituents identified as contaminants of concern (COCs) insoil. Soil Preliminary Remediation Goals (PRGs) were identified for all COCs that significantlycontributed to the risk calculated in the human health risk assessment. Specifically, risk-basedPRGs (shown in Table 1) were calculated for the receptors showing the most unacceptable risk.PRGs are cleanup goals for individual chemicals for specific medium and land use combinationsat Superfund sites. The COCs for this Site were defined as follows:

• For carcinogenic risks, COCs are the most significant contaminants that exceed anexcess cancer risk of 1 x 10~4

• For non-carcinogenic risks, COCs are the most significant contaminants that exceed ahazard index of 1.0

The COCs identified for this Site are TCE, chromium, iron and lead. EPA believes that the highconcentrations of iron are indicative of the natural iron-rich conditions present in the soils thatare ubiquitous to the area. As a result, the iron PRG was not used as a remediation cleanup goalfor the Site. Additionally, since the average concentration of the lead detections is not above itsresidential SSL, and given that its presence is not Site-related, EPA will not address leadcontamination on this property.

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Table 1Preliminary Remediation Goals

CompoundTCEChromium

Maximum Concentration710mg/kg715 mg/kg

Preliminary RemediationGoal0.73 mg/kg186 mg/kg

Surface Soils

The volume of contaminated surface soil (including the top one foot of soil) that is currentlyaccessible to human and ecological receptors is estimated to be 565 cubic yards. Thiscontamination extends laterally over an area of 1,689 square yards. The estimated area of soilexcavation is depicted in Figure 3,

Subsurface Soils

The volume of contaminated subsurface soil (soil at a depth of greater than one foot belowground surface) present at the Spra-Fin property, is estimated to be 780 cubic yards, with depthsranging from one to eight feet (depth to bedrock) below ground surface. This contaminationextends laterally over an area of approximately 394 square yards. The estimated area ofexcavation is depicted in Figure 3.

REMEDIAL ACTION OBJECTIVES

The goal for remediation of contaminated surface and subsurface soils at the Spra-Fin facility isto reduce contaminant concentrations to levels that do not present an unacceptable risk to humanhealth and the environment. Several remedial action objectives have been identified to mitigatethe potential present and/or future risks associated with the Site. These remedial actionobjectives are:

• To prevent / minimize human exposure including ingestion, inhalation, and dermalcontact by current residents (trespassers) and facility workers; future contact byconstruction workers, and environmental exposure to contaminants in the surface andsubsurface soils.

• To prevent / minimize the migration of subsurface soil contaminants to the bedrockground water aquifer.

• To prevent / minimize the migration of contamination in surface soils via windblowndust and surface runoff to Wissahickon Creek.

• To prevent / minimize the uptake of contaminants in surface and subsurface soils bybiota.

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In addition, the objectives mentioned above are to be achieved with minimal disruption to theexisting metals finishing business currently operating at the facility.

SUMMARY OF REMEDIAL ALTERNATIVES

The FS Report discusses tbe alternatives considered for the cleanup of the contaminants ofconcern identified during the RI for the Site and provides supporting information leading toalternative selection by EPA. The FS discusses six alternatives, Alternatives A through F. TheseAlternatives were then screened against EPA criteria, which evaluate the alternatives foreffectiveness, implementability, and costs. Alternative B was not analyzed further because theremedy was not effective in protecting human health and the environment, and Alternative C wasnot carried forward due to difficulties associated with the implementation of the remedy. A moredetailed description of Alternatives B and C, and further discussion about why they were notcarried forward can be found in Section 3 of the FS. A brief description of the Alternatives thathave been carried forward follows below.

Brief Description of Alternatives:Alternative A - No Further Action

The NCP requires that EPA consider a "No Action" alternative for every Superfund site toestablish a baseline or reference point against which each of the remedial action alternatives arecompared. In the event that the other identified alternatives do not offer substantial benefits inthe reduction of toxicity, mobility, or volume of the constituents of concern, the No Actionalternative may be considered a feasible approach. This alternative leaves the Site in the currentcondition and all current and potential future risks would remain.

Alternative D - In-Situ Thermal Treatment of Contaminated Subsurface Soils, Excavationand Off-Site Disposal of Contaminated Surface Soils, and Institutional Controls

Capital Costs: $849,000Operation and Maintenance (O&M): $0Present Worth Value: $849,000

This alternative includes the utilization of in-situ thermal treatment technologies, such as in-situthermal desorption or six-phase heating to remove chlorinated VOCs in subsurface soil(individual methods described below), as well as excavation an off-site disposal of surface soilsand limited excavation of organic-contaminated subsurface soils. Subsurface soils that exhibitmetals contamination and that are not collocated with organic subsurface metals would not beexcavated. Alternatively, risk associated with subsurface metals would be managed through anenvironmental easement prohibiting excavation in these areas.

While Alternative D does have a six-month maintenance period associated with it, themaintenance costs have been included in the capital costs calculation.

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In-Situ Thermal DesorptionIn-situ thermal desorption would involve applying heat and vacuum pressure to soilssimultaneously using either surficial blankets or vertical heater / vacuum wells. As the soil isheated, VOCs would be vaporized through a variety of mechanisms. The vaporized water andcontaminants would be withdrawn from the subsurface through the vacuum wells and treated ordisposed.

Six-Phase HeatingSix-phase heating would utilize electrical resistive heating to remediate subsurfacecontamination. Transformers would convert typical three-phase electricity into six phases. Steelelectrodes, which are insetted using standard drilling techniques, would be used to disburse theelectrical phases throughout the subsurface environment. Contaminants would be removed bydirect volatilization and in-situ steam stripping. Vapors and steam would then be collected usinga standard soil-vapor extraction system. Treatment of the off-gas would be required prior torelease to the atmosphere.

Alternative E - Soil Vapor Extraction, Co-metabolic Bioventing, Excavation and_Off-SiteDisposal of Contaminated Surface Soils, and Institutional Controls

Capital Costs: $1,858,000Operation and Maintenance (O&M): $28,000Present Worth Value: $1,886,000

This alternative involves the combined use of soil vapor extraction.and co-metabolic bioventingto facilitate the destruction of chlorinated VOC contamination in subsurface soil (individualmethods described below), and excavation and off-site disposal of surface soils contaminatedwith PCBs and metals. Limited excavation and disposal of organic contaminated subsurface soilto the southeast of the existing building would also be needed. Subsurface soils that exhibitmetals contamination and that are not collocated with organic contaminants would not beexcavated. Also risk associated with subsurface metals would be managed through anenvironmental easement prohibiting excavation in these areas.

Soil Vapor ExtractionSoil vapor extraction operates by maximizing the volatilization of low-molecular weightcompounds, with some biodegradation occurring. Air is withdrawn from the subsurface byapplying a pressure gradient through wells or trenches. The flow of air increases rates ofcontaminant mass transfer in the unsaturated zone by volatilization of contaminants dissolved inpore water, and desorption of contaminants from soil particle surfaces.

BioventingBioventing involves the movement of gases through subsurface soils to enhance thebioremediation of contaminants. Generally, bioventing entails providing oxygen-deprived soilmicrobes with oxygen in-situ by forcing air through unsaturated contaminated soil at low flowrates, with benzene, toluene, ethyl benzene, and xylene (BTEX) compounds in the subsurfaceserving as a carbon source. Co-metabolic biodegradation of chlorinated solvents would occur

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readily in the aerobic environment created through bioventing.

Alternative F - Excavation and Off-Site Disposal of Contaminated Surface and SubsurfaceSoils

Capital Costs: $678,000Operation and Maintenance (O&M): $0Present Worth Value: $678,000

This alternative involves excavating all soils that are contaminated above cleanup goals.Material to be disposed may also include portions of the concrete pads that exist on-site. Allsuch material would be disposed of at a properly licensed municipal or Resource Conservationand Recovery Act (RCRA) landfill, depending on the acceptance criteria of the individuallandfill. Given the low probability of metals and poly-chlorinated biphenyls (PCBs) migrating toground water, subsurface soils exhibiting contamination from only these two chemical classeswould be left in place. If post-excavation sampling demonstrates that subsurface soils containingmetals and/or PCBs will be left on Site in concentrations such that the cancer risk levelassociated with future use of the Site would exceed 1.0 E-04, or that the future use, non-cancerrisk level would exceed an HI of 1.0, then EPA would require institutional controls, such as anenvironmental easement, to limit any future contact with contaminants through excavation and/ordevelopment.

EVALUATION OF REMEDIAL ALTERNATIVES

In selecting the preferred alternative, EPA evaluated each proposed remedy against the ninecriteria specified in the NCP. The alternative must first satisfy the threshold criteria. Next, theprimary balancing criteria are used to weigh the trade-offs or advantages and disadvantages ofthe alternatives. Finally, after public comment has been obtained the modifying criteria areconsidered. Below is a summary of the nine criteria used to evaluate the remedial alternative.

Threshold Criteria• Overall protection of human health and the environment addresses whether a

remedy provides adequate protection and describes how risks are eliminated,reduced, or controlled.

• Compliance with Applicable or Relevant and Appropriate Requirements (ARARs)Any cleanup alternative considered by EPA must comply with all applicable orrelevant and appropriate federal and state environmental requirements.Applicable requirements are those environmental standards, requirements, criteria,or limitations promulgated under federal or state law that are legally applicable tothe remedial action to be implemented at a site. Relevant and appropriaterequirements, while not being directly applicable, address problems or situationssufficiently similar to those encountered at a particular site and their use is well

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suited to that site. Only those State standards that are promulgated, are identifiedby the State in a timely manner, and are more stringent than federal requirementsmay be applicable or relevant and appropriate. There are three classifications ofARARs: chemical specific, location specific, and action specific.

Primary Balancing Criteria• Long-term effectiveness and permanence refers to the ability of a remedy to

maintain reliable protection of human health and the environment over time oncecleanup goals are achieved.

• Reduction oftoxicity, mobility, or volume through treatment addresses the degreeto which alternatives will reduce the toxicity, mobility, or volume of thecontaminants causing the site risks.

• Short-term effectiveness establishes the period of time needed to achieveprotection and, any adverse impacts on human health and the environment thatmay be posed during the construction and implementation period until cleanupgoals are achieved.

• Implementability addresses the technical and administrative feasibility of aremedy, including the availability of materials and services needed to implement aparticular option.

• Cost includes estimated capital, operation and maintenance costs, and the presentworth value of the total costs.

Modifying Criteria• State Acceptance indicates whether, based on its review of supporting documents

and the Proposed Plan, the State concurs with, opposes, or has no comment on thepreferred alternatives.

• Community Acceptance will be assessed in the Record of Decision following areview of public comments received on the Proposed Plan and supportingdocuments included in the Administrative Record.

In the following analysis, the remedial alternatives are evaluated in relation to one another foreach of the initial seven criteria. The purpose of this analysis is to identify the relativeadvantages and disadvantages of each alternative.

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COMPARATIVE ANALYSIS OF ALTERNATIVES

Overall Protection of Human Health and the EnvironmentAlternative A, the No Action alternative, provides no protection against possible exposure tocontaminated soil, nor does it provide protection of ground water from contaminants in the soil.

Alternatives D,E, and F provide a high degree of protection of both human health and theenvironment by removing and/or treating contaminated soil at the Site. Alternatives D and E, thethermal treatment and soil vapor extraction alternatives, respectively, are in-situ treatmentapproaches while Alternative F relies on excavation of contaminated material. Alternatives Dand E have excavation components.

Compliance with ARARsAlternative A would not comply with numerous ARARs. Alternatives D, E, and F are expectedto comply with all chemical, location, and action-specific ARARs. These would include LandDisposal Requirements and air emission standards during remedial activities.

The following are the major ARARs that are relevant to the Alternatives under consideration:

Chemical-Specific ARARs

1. Resource Conservation and Recovery Act (RCRA) regulations 40 C.F.R. § 261, whichdetermines which wastes are "hazardous wastes" that must be handled under RCRA.These regulations are applicable to all of the Alternatives, to the extent the Alternativesgenerate hazardous wastes.

2. Pennsylvania Hazardous Waste Regulations, Pennsylvania Code; Title 25, § 261a.5(b),which determines which wastes are "hazardous wastes" that must be handled underRCRA. This regulation is applicable to all of the Alternatives, to the extent theAlternatives generate hazardous wastes.

3. The Pennsylvania Land Recycling Program Regulations at Pa. Code § 250.305, AppendixA, identify soil cleanup levels which are applicable to the implementation of the remedyand all of the Alternatives.

4. Clean Air Act, 42 U.S.C. § 7412, and enacting regulations, 40 C.F.R. §§ 61.60, 61.240-247, which set limits on the emission of certain hazardous pollutants into the air. Thesestatutes and regulations are applicable to the air pollution control measures to beemployed in Alternatives D and E.

5. Air Resources, Pennsylvania Code, Title 25 §§123.1, 123.21, 123.22, 123.31, and123.41-123.121 emissions of specific air pollutants. These regulations are applicable tothe air pollution control measures to be employed in Alternatives D and E.

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Action-Specific ARARs

6. Resource Conservation and Recovery Act (RCRA), 42 U.S.C. §§ 3004(d), (e) and (m),and enacting regulations, 40 C.F.R. § 268, which ban the land disposal of untreatedhazardous wastes. These regulations are applicable to all of the Alternatives, to theextent the Alternatives generate hazardous wastes.

7. Resource Conservation and Recovery Act (RCRA) regulations, 40 C.F.R. §§262.263.20(a) and (b), 264 Subparts I and J, and 265 Subparts I and J, which apply to thegeneration, manifesting, and on-site storage of hazardous wastes. These regulations areapplicable to all of the Alternatives, to the extent the Alternatives generate hazardouswastes.

8. Pennsylvania Water Quality Standards, Pennsylvania Code, Title 25, §§ 93.4c. 93.9f,which limit the release of contaminants into the surrounding watershed. Theseregulations are applicable to all of the Alternatives.

9. Air Resources, Pennsylvania Code, Title 25, §§ 121.1, 121.7, and 121.9, which areapplicable to fugitive dust control and use of Best Available Technology (BAT). Theseregulations are applicable to the air pollution control measures to be employed inAlternatives D and E.

10. Pennsylvania's Erosion and Sedimentation Control and Restoration Regulations,Pennsylvania Code, Title 25, §§ 102.1, 102.2, 102.4, 102.11, 102.22, are applicable to theearth-moving activities associated with all of the Alternatives.

11. Pennsylvania Hazardous Waste Regulations, Pennsylvania Code, Title 25 § 268a. 1 (c),which bans the land disposal of untreated hazardous wastes. This regulation is applicableto all of the Alternatives, to the extent the Alternatives generate hazardous wastes.

12. Pennsylvania Hazardous Waste Regulations, Pennsylvania Code, Title 25, §§ 262.20,262.22, 262.23, 262.33, 262.34, 264 Subparts I and J, and Subparts I and J, which applyto the packing, placarding, and labeling requirements of hazardous waste for shipment,and on-site accumulation and storage of hazardous waste. These regulations areapplicable to all of the Alternatives, to the extent the Alternatives generate hazardouswastes.

Long-Term Effectiveness and PermanenceAlternative A would have little long-term effectiveness. This alternative would not restore thesurface or subsurface soil and would allow for continued exposure to on-site contaminants.

Each of the three treatment alternatives provides long-term effectiveness in removingcontaminants from the subsurface. Alternative D provides long-term protection for the localpopulation through removal of organic materials from the subsurface. Alternative E would alsoremove organics from the subsurface, but the alternative is limited to volatile and biodegradable

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organics, as opposed to all organics as in Alternative D. Both Alternatives D and E wouldrequire maintenance as the treatment is estimated to take approximately 6 months to complete.Alternative F is the most effective and permanent alternative since all organic contaminantswould be excavated from the subsurface and disposed of off-site.

Reduction ofToxicity^ Mobility, or Volume through TreatmentAlternative A does not utilize on-site treatment to address any contaminated media since noaction will be performed. As a result, Alternative A does not affect toxicity, mobility, or volumeof contaminants.

Alternatives D and E utilize active in-situ treatment methods to reduce the toxicity, mobility, andvolume of organic materials in the soil. Both Alternatives D and E would reduce toxicity bytreating extracted vapors and liquids at the surface with collection systems, and mobility wouldbe decreased as a result of the vacuum systems employed to extract vapors. Both alternativeswould reduce volume by removing contaminants from the subsurface through treatment.

Alternative F, the excavation alternative, would reduce the mobility and volume of soilcontaminants by removing the contaminants through the excavation process but not throughtreatment. The toxicity of the contaminants would not be affected unless a treatment process(such as incineration) occurs at the disposal facility prior to final deposition.

Short-Term EffectivenessAlternative A has no implementation period and no resulting short-term effectiveness.Alternative D and E have similar, low to moderate short-term impacts to construction workersand the community during the installation of the bioventing, heating, and extraction wells.Alternative F, due to the intensive excavation that would be required, has a much higher impactto construction workers as a result of exposure to contaminants during the excavation. Duringexcavation, releases of material may impact local populations, but common techniques can beapplied to limit this exposure.

Implem en tabilityAlternative A would be the easiest to implement due to lack of any active treatment orconstruction activities.

As a result of the small size of the Site (slightly more than one acre including buildingfootprints), all of the treatment alternatives would have implementability issues due to theinstallation of treatment equipment. All of the alternatives (Alternatives D, E, and F) aretechnically and administratively implementable.

Alternative D would require some specialized equipment for soil heating, but most of the otherequipment required is easily obtainable. Specialized expertise would be required to design,construct, and operate the treatment process. Alternative E, soil vapor extraction and bioventing,contains air injection and extraction wells that use common drilling techniques for theirinstallation, with specialized equipment for pumping air into the subsurface and extracting theorganics. The soil treatment proposed in Alternative E relies on a proven technology and is

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expected to be more implementable the Alternative D. Alternative F, excavation and off-sitedisposal, is the easiest alternative to implement, using common construction techniques.However, this Alternative would require the temporary closure of the facility for approximatelytwo weeks.

CostAlternative A has no costs associated with is since no remedial activities are expected.Alternative D has a cost of $849,000, mainly as a function of capital costs. Alternative E wouldcost $1,886,000, with the installation and operation of the bioventing and soil vapor extractionsystem being the most expensive components of the alternative. Alternative F is projecting tocost $678,000, with the total cost being driven by excavation and disposal of contaminated soil.

PREFERRED ALTERNATIVE

EPA's preferred alternative for addressing contaminated ground water at the North PennArea 7 Superfund Site Spra-Fin Facility (OU2) is: Alternative F - Excavation and Off-SiteDisposal of Contaminated Surface and Subsurface Soils

Estimated Capital Costs: $678,000Estimated Annual O&M Costs: $0Estimated Total Present Worth Costs: $678,000

A detailed breakdown of Capital and O&M costs for each component of the preferred alternativecan be found in the FS Report. A copy of the FS can be found in the Administrative Recordlocated at either of the Site information repositories.

Based on the information currently available, EPA believes the Preferred Alternative meets thethreshold criteria and provides the best balance of tradeoffs among the other alternatives withrespect to the balancing and modifying criteria. The EPA expects the Preferred Alternative tosatisfy the following statutory requirements of CERCLA § 121(b): 1) be protective of humanhealth and the environment; 2) comply with ARARs; 3) be cost-effective; 4) utilize permanentsolutions and alternative treatment technologies to the maximum extent practicable; and 5)satisfy the preference for treatment as a principal element.

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COMMUNITY PARTICIPATION

This Proposed Plan is being distributed to solicit public comment on the appropriate cleanupaction for the Spra-Fin Site. EPA relies on public input so that the remedy selected for eachSuperfund site meets the needs and concerns of the local community. EPA is providing a 30-day public comment period beginning on ADD, 2003 and ending on ADD, 2003, to encouragepublic participation in the selection process. EPA will conduct a public meeting during thecomment period in order to present the Proposed Plan and supporting information, answerquestions, and accept both oral and written comments from the public. The public meeting willbe held on ADD, 2003, at 7:00 p.m. at the Upper Gwynedd Township Building, Parkside Place,West Point, PA 19486.

EPA will summarize and respond to comments received at the public meeting and writtencomments post-marked by ADD, 2003, in the Responsiveness Summary section of the Record ofDecision, which will document EPA's final selection for cleanup. To obtain additionalinformation relating to this Proposed Plan, please contact either of the following EPArepresentatives:

David Polish Deanna MoultrieCommunity Involvement Coordinator Remedial Project ManagerU.S. EPA - Region III U.S. EPA - Region III1650 Arch Street 1650 Arch StreetPhiladelphia, PA 19103 Philadelphia, PA 19103(215)814-5523 (215)814-5125

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GLOSSARY

Administrative Record - EPA's official compilation of documents, data, reports, and otherinformation that is considered important to the status of, and decisions made relative to aSuperfund site. The record is placed in the information repository to allow public access to thematerial.

Aquifer - An underground geologic formation, or group of formations, containing useableamounts of ground water that can supply wells and springs.

Ground water - Water found beneath the earth's surface that fills bedrock fractures and poresbetween soil, sand and gravel particles to the point of saturation. Ground water often flows moreslowly than surface water. When it occurs in sufficient quantity, ground water can be used as awater supply.

Information Repositories - The locations where documents and data related to the Superfundproject are placed by EPA, to allow the public access to the material.

National Oil and Hazardous Substances Pollution Contingency Plan (NCP) - The Federalregulation that guides the determination and manner in which sites will be cleaned up under theSuperfund program

National Priorities List (NPL) - EPA's list of the nation's top priority hazardous waste sitesthat are eligible to receive federal money for response action under Superfund.

Polycyclic Aromatic Hydrocarbons (PAHs) - Polycyclic aromatic hydrocarbons (PAHs) are agroup of over 100 different chemicals that are formed during the incomplete burning of coal, oiland gas, garbage, or other organic substances like tobacco or charbroiled meat. PAHs are alsofound in coal tar, crude oil, creosote, and roofing tar.

Potentially Responsible Parties (PRPs) - Parties who may be legally responsible for the cleanup of hazardous substances at a Superfund site.

ppb - Parts per billion. Five parts per billion is a fractional representation of 5 parts in 1 billionparts. For solids, ppb is a fraction based on weight and can be expressed as micrograms perkilogram or ug/kg, For liquids, ppb is based on volume and can be expressed as micrograms perliter or ug/L.

Resource Conservation and Recovery Act (RCRA) - A statute under which EPA andauthorized States established the management of hazardous waste.

Record of Decision (ROD) - A legal document that describes the remedial actions selected for aSuperfund site, why certain remedial actions were chosen as opposed to others, how much theywill cost, and how the public responded.

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