Five-Year Review Report

First Five-Year Review Report for

CryoChem, Incorporated, Superfund Site Berks County

Boyertown, Pennsylvania

September 2003

PREPARED BY:

United States Environmental Protection Agency Region 3

Philadelphia, Pennsylvania

Approved By: Date:

Table of Contents

List of Acronyms…………………………………………………………………... iv Executive Summary…………………………………………………………………vi Five-Year Review Summary Form………………………………………………….vii I. Introduction……………………………………………………………….. 1 II. Site Chronology……………………………………………………………3 III. Background……………………………………………………………….. 5

Physical Characteristics……………………………………………………. 5 Land and Resource Use……………………………………………………..5 History of Contamination………………………………………………….. 5 Initial Response……………………………………………………………. 6 Basis for Taking Action……………………………………………………..7

IV. Remedial Actions…………………………………………………………. 7

Remedy Selection………………………………………………………….. 7 Remedy Implementation…………………………………………………… 11 System Operations/Operation and Maintenance (O&M)………………….. 13

V. Progress Since The Last Five-Year Review……………………………... 14 VI. Five-Year Review Process..........................................................…………. 14

Administrative Components.......................................................................... 14 Community Involvement............................................................................... 15 Document Review......................................................................................... 15 Data Review ..................................................................................................15 Site Inspection ...............................................................................................18 Interviews.......................................................................................................19

VII. Technical Assessment..................................................................................19

Question A: Is the remedy functioning as intended by the decision documents?.................................................................................................... 20 Question B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action objectives (RAOs) used at the time of the remedy selection still valid?.....................................................................20 Question C: Has any other information come to light that could call into question the protectiveness of the remedy?..................................... 21 Technical Assessment Summary................................................................... 21

VII. Issues.............................................................................................................22 IX. Recommendations and Follow-up Actions .................................................23

X. Protectiveness Statements........................................................................... 24 XI. Next Five-Year Review................................................................................24

Attachments Attachment A - Document Review List Attachment B - Historical Sampling Results for the COC's at the Extraction Wells Attachment C - Map Detailing the location of the Monitoring/Extraction Wells and

Surface Sampling Locations Attachment D - ARAR's Table Attachment E - Biological Technical Assistance

Group Memorandum dated 9/18/03

List of Acronyms

ARAR Applicable or Relevant and Appropriate Requirement CERCLA Comprehensive Environmental Response, Compensation and

Liability Act CFR Code of Federal Regulations COCs Contaminants of Concern DCA or 1,1 - DCA 1,1 - Dichloroethane DCE or 1,1 - DCE 1,1- DichIoroethene EPA United States Environmental Protection Agency ESD Explanation of Significant Differences FFS Focused Feasibility Study MCLs Maximum Contaminant Levels MSL Mean Sea Level NCP National Contingency Plan NPDES National Pollutant Discharge Elimination System NPL National Priorities List O&M Operation and Maintenance OU Operable Unit PADEP Pennsylvania Department of Environmental Protection PADER Pennsylvania Department of Environmental Resources PCE Tetrachloroethene PRPs Potentially Responsible Parties RAO Remedial Action Objective

RBC Risk-Based Concentration RI/ FS Remedial Investigation/Feasibility Study ROD Record of Decision RPM Remedial Project Manager SDWA Safe Drinking Water Act SOW Statement of Work TAL Target Analyte List TCA or l, l, l-TCA 1,1,1-Trichloroethane TCE Trichloroethene TCL Target Compound List UV Ultraviolet VOC Volatile Organic Compound

Executive Summary

The remedy for OU-1 of the CryoChem, Incorporated, Superfund Site in Berks

County, Pennsylvania included the installation, operation, and maintenance of dual activated carbon units at homes affected by contamination from the site. The remedy for OU-2 included the installation of nine extraction wells and the construction of a groundwater treatment system consisting of air stripping and vapor phase carbon for the removal of site-related contaminants. Treated groundwater is discharged to an on- site stream. The site remedy achieved construction completion status with the signing of the Preliminary Closeout Report (PCOR) on September 22, 1998. The trigger for this five-year review was the date the site achieved construction completion status.

The assessment of this five-year review found that the remedy was constructed in accordance with the requirements of the Records of Decision (RODs). Two Explanations of Significant Difference (ESDs) were issued for the Site. The first ESD was issued for a change in the selected remedial action for OU1, from the development and construction of an alternative water supply to the continued use of carbon treatment units. The second ESD was issued for a change in the selected remedial action for OU3, from the utilization of soil vapor extraction to remove the contamination from the soil to no further action based on data from investigations conducted at the site. The remedy is protective of human health and the environment and in the interim, while working to achieve the groundwater cleanup goals, the immediate threats have been addressed.

Five-Year Review Summary Form

SITE IDENTIFICATION

Site name: CryoChem, Incorporated, Superfund Site

EPAID:PAD002360444

Region: 3 State: PA City/County: Worman Township/Berks

SITE STATUS

NPL status: X Final Q Deleted Q Other (specify).

Remediation Status (choose all that apply): Q Under Construction X Operating U Complete

Multiple OUs?* XYES NO Construction completion date: September 22,1998

Has site been put into reuse? Q YES G NO N/A - Site continues to be operational

REVIEW STATUS

Lead agency: X EPA Q State Q Tribe Q Other Federal Agency

Author name: Alexis K. Alexander

Author title: Remedial Project Manager Author Affiliation: U.S. EPA - Region 3

Review period: June 1, 2003 through September 2003

Date(s) of site inspection: July 23, 2003

Type of review: X Post-SARA QPre-SARAQ Non-NPL Remedial Action SiteQ Regional Discretion

NPL-Removal onlyNPL State/Tribe-lead

Review number: X 1 (first) Q 2 (second) Q 3 (third) Q Other(specify).

Triggering action:Q Actual RA Onsite Construction at OU #X Construction CompletionQ Other (specify) ______________

Actual RA Start at OU# ____Previous Five-Year Review Report

Triggering action date: September 22, 1998

Due date (five years after triggering action date): September 22, 2003

f lR3003t*8

FIVE-YEAR REVIEW SUMMARY FORM, cont'd.

Issues:

• The action level for DCA as outlined in the OU-1 ROD is significantly below the EPA Region 3 risk-based concentration (RBC) screening value for tap water.

• A gasoline plume from Mike's Fancy Auto Shop on Boyertown Pike has co-

mingled with the CryoChem plume in the residential area downgradient of site. The OU-1 treatment systems carbon usage may be affected by contaminants in both plumes.

• There is limited information available regarding seasonal changes in the

extraction capture zone as water level monitoring has not been conducted on a routine basis.

• A groundwater extraction system was recently installed at Mike's Fancy Auto

Shop to address the gasoline plume. An evaluation is needed to determine the effect on the OU-2 capture zone when the system is operational.

• 1,4- dioxane was included in a March 2003 sampling event due to recent

information indicating that it is usually present when 1,1 - TCA is a source contaminant. Results from the March 2003 sampling indicated that 1,4-dioxane was present above the EPA Region 3 RBC for tap water in samples collected from several wells. Results from the May 2003 sampling of the residential wells indicated that 1,4-dioxane was also present above the EPA Region 3 RBC for tap water in samples collected from two of the wells.

• The Explanation of Significant Differences (ESD) issued for OU-1 erroneously

called the ESD an interim action when, in fact, this was to be the final action for this OU.

• Routine sampling of upgradient and downgradient monitoring wells has not been

conducted for the site in order to evaluate the performance of the OU-2 remedy.

• Evaluation of the extraction system is needed to determine if the flow rate is changing due to mechanical issues and to see if all extraction wells are necessary.

FIVE-YEAR REVIEW SUMMARY FORM, cont'd. Recommendations and Follow-up Actions:

• Review site data to determine if a new site- specific action level for DCA is needed and, if so, consider issuing an Explanation of Significant Differences (ESD) to formally note the change.

• Coordinate with PADEP on the installation of additional carbon units with MTBE

specific removal carbon in affected properties, ensuring that the conditions of the OU-1 selected remedy as cited in the September 1989 ROD, ESD, and Technical Memorandum, continue to be met.

• Collect site-wide water levels on a quarterly basis for two years and use the data

to prepare potentiometric surface maps.

• Develop a work plan for evaluating and monitoring the effect of gasoline plume extraction system on the GU-2 capture zone.

• Sample the on- site and residential wells two more times for 1,4- dioxane to

confirm the initial results and follow up with treatment, if necessary.

• Consider issuing an Explanation of Significant Differences (ESD) for OU-1 to clarify that the initial ESD addressed fully the requirement for a permanent water supply and should not have been called an interim action.

• Develop OU-2 performance monitoring plan that includes sampling of upgradient

and downgradient wells.

• Develop a work plan for evaluating the extraction system and individual well capture zones.

Protectiveness Statements: The remedy is protective of human health and the environment and in the interim, while working to achieve the groundwater cleanup goals, the immediate threats have been addressed. Other Comments: No other comments.

CryoChem, Incorporated, Superfund Site

Boyertown, Pennsylvania First Five-Year Review Report

I. Introduction

The purpose of the five-year review is to determine whether the remedy at a site is protective of human health and the environment. The methods, findings, and conclusions of reviews are documented in Five-Year Review reports. In addition, Five-Year Review reports identify issues found during the review, if any, and identify recommendations to address them.

The Agency is preparing this Five- Year Review report pursuant to the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) '121 and the National Contingency Plan (NCR). CERCLA' 121 states:

If the President selects a remedial action that results in any hazardous substances, pollutants, or contaminants remaining at the site, the President shall review such remedial action no less often than each five years after the initiation of such remedial action to assure that human health and the environment are being protected by the remedial action being implemented. In addition, if upon such review it is the judgment of the President that action is appropriate at such site in accordance with section [104] or [106], the President shall take or require such action. The President shall report to the Congress a list of facilities for which such review is required, the results of all such reviews, and any actions taken as a result of such reviews.

The Agency interpreted this requirement further in the NCP; 40 CFR '300.430(f)(4)(ii) states:

If a remedial action is selected that results in hazardous substances, pollutants, or contaminants remaining at the site above levels that allow for unlimited use and unrestricted exposure, the lead agency shall review such action no less often than every five years after the initiation of the selected remedial action.

The United States Environmental Protection Agency (EPA), Region 3, conducted

the five-year review of the remedy implemented at the CryoChem, Incorporated, Superfund Site in Boyertown, Pennsylvania. This review was conducted for the entire site by the Remedial Project Manager (RPM) from June 1, 2003 through September 2003. This review included a technical review conducted by EPA's contractor, Tetratech NUS, to assess the technical components of the remedy. The resulting report, the Technical Review Report (TetraTech NUS - July 2003), was used as the basis for this Five-Year Review Report. The Five-Year Review Report documents the results of the review.

This is the first five-year review of the remedy implemented at the CryoChem, Incorporated, Superfund Site. The triggering action for this review is the date the site achieved construction completion status. Construction completion was documented by the signing of the Preliminary Closeout Report which occurred on September 22, 1998. A five-year review is required due to the fact that until the groundwater extraction and treatment remedy achieves the site-specific remediation goals, hazardous substances, pollutants, or contaminants will remain at the site above levels that allow for unlimited use and unrestricted exposure.

II. Site Chronology Table 1 - Chronology of Site Events

Date Event 1962 CryoChem, Inc., previously named CryoChem Engineering and

Fabrication, Incorporated, begins operations at the site. 1973 to 1983

CryoChem used a material containing the solvent 1,1,1- trichloroethane (1,1,1- TCA) to remove a crack seeking dye from finished metal products. Excess solvent was collected in shop drains and ultimately discharged into nearby surface waters. An unspecified quantity of 1,1,1- TCA was spilled into the shop drain near the dye wiping process sometime during the early 1980' s.

1981

Pennsylvania Department of Environmental Resources (PADER) sampled nine residential wells located near the CryoChem facility and detected the presence of chlorinated solvents, including 1,1,1- TCA.

1982

PADER inspects the CryoChem facility and determines an uncontained drum storage area is located approximately 10 feet from where the spill of 1,1,1- TCA occurred. Aqueous samples collected during the site visit reveal high levels of 1,1,1- TCA.

1983

PADER finds CryoChem, Inc., in violation of the Clean Streams Act for discharging industrial wastes without a permit.

May 1983

Gilbert Associates, Inc., consultants to CryoChem, Inc., submit report to PADER identifying low levels of chlorinated solvents in site groundwater and surface water.

December 1983

EPA samples groundwater, surface water, sediments, and residential wells in vicinity of site. Various chlorinated organic compounds are identified.

June 10, 1986

EPA proposes CryoChem, Inc., Site for National Priorities List (NPL).

September 1987 EPA installs treatment units on residential wells at 13 properties as part of Removal Response Action.

February 1988 EPA signs a Consent Order with CryoChem PRPs to conduct an RI/FS.

October 4, 1989 The CryoChem, Inc., Site is placed on the NPL. 1989 EPA conducts a Focused Feasibility Study (FFS) for Operable Unit 1

to evaluate remedial alternatives for providing an alternate drinking water supply for residential wells. Based on the FFS EPA installs treatment units on seven additional properties.

September 29, 1989

EPA issues Record of Decision (ROD) for OU-1 which outlines continued O&M of residential treatment systems and development of a permanent clean water supply.

June 1990

JACA Corporation submits Final Remedial Investigation Report for the CryoChem Site on behalf of the PRPs.

June 1990

JACA Corporation submits Final Feasibility Study for the CryoChem Site on behalf of the PRPs.

September 28, 1990 EPA issues Record of Decision for OU-2 which outlines design and installation of a groundwater extraction and treatment system

September 30, 1991 EPA issues Record of Decision for OU-3 which outlines the utilization of soil vapor extraction to remove soil contaminants.

September 22, 1994

EPA issues Explanation of Significant Differences (ESD) for OU-1 which outlines change in selected remedy from development and construction of alternate water supply to continued use of carbon treatment units.

September 20, 1996

EPA issues Technical Memorandum for OU-1 which outlines changes to ESD Scope of Work.

May 1998

CH2M Hill submits Remedial Action Report: Operable Unit 2 CryoChem Site documenting completion of construction of OU-2 groundwater extraction and treatment system.

September 22, 1998 EPA issues Explanation of Significant Differences for OU-3 which outlines change in remedial action from soil vapor extraction to no further action.

September 22, 1998

Preliminary Closeout Report for OU-2 signed.

III. Background Physical Characteristics

The CryoChem, Incorporated, Superfund Site is located along Route 562 (Boyertown Pike) in Earl and Douglas Townships, Berks County, Pennsylvania, approximately three miles west of Boyertown. Although the entire CryoChem, Incorporated, facility is approximately 19 acres, the area of concern is mainly confined to the southern four acres that include a fabrication building, office building, and several warehouses. The CryoChem, Incorporated, Superfund Site (Site) includes the southern portion of the CryoChem, Incorporated, facility contaminated groundwater (attributable to former plant operating practices), and a nearby residential neighborhood located immediately southeast of the plant. Land and Resource Use

Currently, the 19-acre CryoChem facility is being leased and operated by Apex Industries for metal fabrication. To the north, east and south of the facility are residential properties and farmland. A small gas station and auto repair, Mike's Fancy Auto Shop, is also located across the road from the CryoChem, Incorporated, facility. Immediately west of the facility, C. S. Garber Drilling owns and operates an office and equipment yard. Other light industries and a small restaurant are also located east and west of the CryoChem facility along Boyertown Pike.

Groundwater, which is the primary source of drinking water for the homes and businesses located in the immediate vicinity of the site, flows from northwest to southeast beneath the site and is controlled predominantly by fractures within the bedrock. History of Contamination

Beginning in the early 19601s CryoChem manufactured metal products, primarily pressure vessels, at the Boyertown site. Prior to 1982, the company used an organic solvent (containing at least 93,5% of 1,1,1- trichloroethane) to remove a dye that was applied to welded connections to check for weld integrity. Spilled solvent is suspected to have collected in the shop drain system that discharged into on- site surface waters that eventually lead to Ironstone and Manatawny Creeks. In addition, spilled solvent was also discarded at the rear of the fabrication building resulting in contamination to a limited area of soil behind the fabrication building and subsequently to the local groundwater system. Contamination in groundwater at the site consists primarily of volatile organic compounds (VOCs). A series of environmental samples collected between 1981 and 1987 by the Pennsylvania Department of Environmental Resources (PADER), EPA, and other parties, found several volatile organic compounds (VOCs) in an on-site production well located at the CryoChem facility and in nearby residential wells. VOCs were also

detected in site surface waters that flow to Ironstone Creek and eventually lead to Manatawny Creek. Initial Response

On June 10, 1986, EPA proposed that the CryoChem site be added to the National Priorities List (NPL) based upon its Hazard Ranking System score of 28.58. If a site scores greater than 28.5 it can be recommended for the NPL. The CryoChem site was added to the NPL on October 4, 1989.

In February 1988, EPA entered into a consent agreement with CryoChem and eight other parties, all of whom were potentially responsible for the contamination. According to the consent agreement the potentially responsible parties (PRPs) would conduct a remedial investigation to determine the nature, extent and sources of contamination at the Site and surrounding property. A complete discussion of the remedial investigation and results arc found in the June 1990 Final Remedial Investigation Report for the CryoChem Superfund Site (JACA Corporation, 1990). The Remedial Investigation (RI) concluded that the CryoChem facility was a source of 1,1,1 - trichloroethane (TCA) contamination in groundwater. In addition, since 1,1- dichloroethene (DCE) and 1,1- dichloroethane (DCA) are potential degradation products of TCA, CryoChem, Incorporated, may also be the source of DCE and DCA which arc found in groundwater beneath and immediately downgradient of the facility. Groundwater samples collected from wells located upgradient of the facility showed elevated levels of trichloroethene (TCE) that indicate that another source or sources of TCE contamination are most likely present in the area. The Feasibility Study (FS), which compares the various alternatives for cleaning up the site, was completed in June 1990.

Basis for Taking Action Contaminants

Hazardous substances that have been detected at the site in each media are: Groundwater Surface Water Soil TCA TCA DCA DCA DCA PCE DCE DCE TCE PCE (Tetrachloroethene)

Based on the RI data, EPA determined that exposure to the contaminated plume, including groundwater and surface water, may present an imminent and substantial endangerment to public health, welfare, or the environment. Exposure pathways considered were groundwater ingestion, inhalation of contaminants volatilized from household use of groundwater, surface water ingestion, dermal absorption of contaminants while swimming in surface waters, ingestion of contaminants from eating fish, ingestion of soil by children trespassing on the site, dermal contact of site soil by CryoChem workers, and inhalation of soil contaminants by CryoChem workers. The concentration of contaminants in the groundwater at the site were above the Maximum Contaminant Levels (MCLs), which are enforceable drinking water standards established under the Safe Drinking Water Act (SDWA), 42 U.S.C."300f to 300J-26. IV. Remedial Actions Remedy Selection

The CryoChem Superfund Site was originally divided into three operable units (OUs) as follows:

• Operable Unit 1 (OU-1) Drinking Water Supply • Operable Unit 2 (OU-2) Area-Wide Groundwater • Operable Unit 3 (OU-3) Source Area (Soil)

EPA issued three separate RODs which addressed the OUs as stated above. The

following provides a summary of each ROD.

September 29, 1989 ROD - OU-1 (Drinking Water Supply)

On September 29, 1989, EPA issued the first ROD for the CryoChem Superfund Site. The ROD outlined EPA's selected final remedy for OU-1 which included the following major components: (1) Continued operation and maintenance, until a permanent clean water supply is developed, of dual activated- carbon units installed at 13 homes affected by the CryoChem site; (2) Installation and maintenance, until a permanent clean water supply is developed, of dual activated- carbon units at homes affected by contamination from the site that are not currently equipped with carbon units; (3) Periodic chemical sampling of 13 currently unaffected homes and businesses, which could potentially be affected by contamination from the site due to their location near the site; (4) Installation, operation, and maintenance of dual activated carbon units at residential wells which become affected by contamination from the CryoChem site; and (5) Development, construction, and operation of a new clean water supply well and distribution system to provide clean water to affected and potentially affected homes and businesses; and (6) Operation of a new clean water supply well and distribution system to provide clean water to affected homes and businesses.

Explanation of Significant Differences - OU-1

An Explanation of Significant Differences (ESD) was issued for OU-1 on September 22, 1994. The ESD was issued by EPA for a change in the selected remedial action for OU-1, from the development and construction of an alternate water supply to the continued use of carbon treatment units. In error, the ESD was called an interim remedy when, in fact, this was to be the final remedy for this OU. EPA plans to issue another ESD to correct this. The initial ESD was based on the following circumstances:

• One of the major components of the OU-1 ROD was the development and construction of a new clean water supply well and distribution system to provide clean water to affected and potentially affected homes and businesses.

• EPA had requested that the local authorities consider the possibility of handling

the operation and maintenance of the proposed clean water supply (public water line) which had been selected as the remedy for OU-1. As none of the local authorities had expressed interest, an experienced authority was unavailable to oversee the operation and maintenance of the proposed alternated water supply.

• The affected community had initially expressed and continued to express, a strong

preference for the carbon treatment units which were previously installed as part of EPA's Removal Response measure and continued to be in use, as opposed to the proposed public water line.

The remedy is considered by EPA to be protective of human health and the

environment, to comply with federal and state applicable or relevant and appropriate requirements, and to be cost-effective. The ESD contained guidelines for determining when safe water quality limits have been achieved, and also provided for the monitoring of water quality at the contaminated wells as well as at other wells determined to be subject to a risk of contamination. A Statement of Work (SOW) for the Operation and Maintenance of the Carbon Units was included in the ESD. The SOW outlined the monitoring frequency at the various OU-1 properties, the methodology for replacement of carbon filters at the affected residences, and a schedule for replacement of ultraviolet (UV) lamps.

Technical Memorandum Modifying Statement of Work for CryoChem OU-1

A Technical Memorandum that modified the Statement of Work for OU-1 was issued by EPA on September 20, 1996. The Technical Memorandum set forth the operation and maintenance requirements for the OU-1 treatment systems and revised monitoring requirements based on a review of the systems operational requirements and monitoring results collected since 1987. The memorandum did not modify the nature of the selected remedy as outlined in the ROD and ESD.

September 28, 1990 ROD - OU-2 (Area Wide Groundwater)

Operable Unit 2 (OU-2) addresses the remediation of groundwater impacted by the site-related contaminants. On September 28, 1990, EPA signed a ROD for OU-2. The Remedial Action Objectives (RAOs) for OU-2 are:

• Protect public health, welfare, or environment • Prevent further off-Site migration of contaminants in groundwater and surface

water • Prevent contaminant migration into unaffected areas • Restore the aquifer to beneficial use, if practicable

The major components of the OU-2 ROD are: (I) Completion of a groundwater

remedial design study to determine the most efficient design for a groundwater treatment system, (2) Installation, operation, and maintenance of groundwater extraction wells to remove contaminated groundwater from beneath the site and to prevent contaminants from migrating to currently unaffected areas, (3) Installation, operation, and maintenance of air stripping towers to treat groundwater to applicable levels, (4) Construction, operation, and maintenance of a pipeline from the air stripping towers to surface water near the site to discharge treated groundwater, and (5) Periodic groundwater monitoring to ensure that the remedy is effective. The site contaminants of concern (COCs) identified in the 1990 ROD are 1,1,1-trichloroethane (TCA), 1,1-dichloroethane (DCA), tetrachloroethene (PCE), trichloroethene (TCE), and 1, 1-dichloroethene (DCE).

September 31, 1991 ROD - OU-3 (Contaminated Soil)

In September 1991 EPA issued the ROD for OU- 3 which addressed the soil contamination at the site. The Remedial Action Objectives ( RAOs) for OU- 3 are:

• Protect public health, welfare, or environment • Prevent further migration of contaminants from the soil to the ground water • Prevent soil contaminant migration into unaffected areas

The major components of the ROD are: (1) Sampling the contaminated area (and

sampling two other areas) to better define the extent of the contamination, (2) Utilization of soil vapor extraction to remove the contamination from the soil, and (3) Confirmation sampling.

Explanation of Significant Differences - OU-3

An Explanation of Significant Differences was issued for OU-3 on September 22, 1998. The BSD was issued by EPA for a change in the selected remedial action for OU-3. The 1991 ROD outlined as a major component the utilization of soil vapor extraction to remove elevated levels of site related contaminants detected in soils located behind the CryoChem fabrication building. However, based on subsequent soil investigations completed in 1992 and 1995, a soil gas survey conducted in May 1996, and physical characteristics of the area considered for soil vapor extraction, EPA determined that implement ing the selected remedy for OU-3 was not needed for the protection of human health and/ or the environment. EPA changed the remedial action for OU-3 to no further action. Remedy Implementation Operable Unit 1

The primary objective of the remedial action is to supply clean water to residents living near the CryoChem site. The ROD for OU-1 was signed on September 29, 1989. However, prior to that date, EPA had installed dual activated carbon unit treatment systems and UV lamps on the water supplies of 20 properties that had been impacted by the site related contaminants. Currently, 12 properties have treatment units for the removal of site-related contaminants. The 8 homes that were removed from the monitoring program met the removal requirements of the September 1989 ROD, the ESD, and the Technical Memorandum. Operable Unit 2

The September 28, 1990, ROD for OU-2 outlined several remedial action objectives that included: (1) preventing further off- site migration of contaminated groundwater, (2) preventing migration of contaminated groundwater into surface water and into currently unaffected areas, and (3) restoring the aquifer to its beneficial use, if practicable. In 1992, EPA conducted the pre-design investigation to characterize the nature and extent of groundwater contamination in the overburden and bedrock aquifers located beneath and in the immediate vicinity of the site. The pre- design investigation resulted in the following conclusions: (1) air-stripping followed by vapor-phase carbon adsorption of the site related VOCs in the stripper off- gas was the treatment system to be implemented; (2) a groundwater extraction system consisting of extraction wells with intersecting zones of influence placed along the downgradient boundary of the site would prevent offsite migration of contaminants; (3) an air stripper will treat the extracted groundwater to applicable discharge levels; (4) treated groundwater will be discharged to a surface water stream located onsite; and (5) a groundwater monitoring plan is needed to provide data to determine the effectiveness of the remedy. In September 1995, EPA installed nine groundwater extraction wells along the eastern and southeastern perimeter

of the CryoChem Inc. property to capture the contaminated groundwater beneath the facility. A separate building was constructed to process the extracted groundwater through air stripping and carbon adsorption before the treated water is discharged to an on-site stream. Initial start-up of the system occurred in May 1998. Due to a number of operating problems the treatment system was shut down from February 27, 1999 until April 18, 2000 when operations resumed. Since that time the plant has been running continuously. The initial design flow selected for each of the extraction wells was 7 gallons per minute (gpm) or approximately 65 gpm from the nine wells. However, results from pumping tests conducted in 1995 during the design investigation indicated maximum yields of 5 gpm from the extraction wells or a maximum total yield of 45 gpm. The system was constructed for a maximum design flow of 100 gpm to provide excess capacity should additional extraction wells be needed in the future or to accommodate higher pumping rates. The system is designed to operate 24 hours per day, seven days per week, on a continuous flow through basis. Four adjacent monitoring wells are used to measure water levels for monitoring the effectiveness of the capture zone and to reduce impact on nearby residential water well levels. During the period from April 2000 through May 2003, approximately 64.7 million gallons of groundwater have been pumped and treated by the OU-2 system. Operable Unit 3

No remedy was implemented for OU- 3 in accordance with the ESD dated September 22, 1998. System Operation/Operation and Maintenance (O&M) Operable Unit 1

Eleven residences and one business located downgradient of the CryoChem facility are equipped with treatment systems for the removal of site related organics. The primary activities associated with O& M include the following:

• Monitoring and sampling of all residential homes in the OU-1 program. • Maintenance of the individual treatment units, including media replacement for

the sediment and carbon filter units and bulb replacement for the UV lamps.

In 2002, a survey was conducted on each of the treatment systems to determine equipment and operating status. Based on that survey, two properties were equipped with water softening units to enhance the performance of the treatment systems.

O&M costs vary depending on the number of properties in the OU-1 monitoring program and the number of sampling events conducted. Current costs ( rounded to nearest $1,000) are $72,000 per year.

Operable Unit 2

Operations and maintenance (O&M) activities are conducted according to the O&M Plan dated March 2001. Revisions to the O&M plan to reflect recent changes are currently underway. The primary activities associated with O&M include the following:

• Monthly collection of influent and effluent samples and monitored for National Pollutant Discharge Elimination System (NPDES) discharge requirements. Monitored parameters include 1,1-DCA, 1,1-DCE, PCE, 1,1,1-TCA, TCE, and vinyl chloride (VC).

• Semi-annual monitoring of the vapor phase effluent, usually March and

September, to determine if carbon replacement is required.

• Carbon replacement of the lead tank is conducted every six months, as determined by the vapor phase sampling.

• Annual sampling of the nine extraction wells and four monitoring wells for low

concentration VOCs and inorganics.

• Cleaning of the air stripper to remove mineral deposition is also conducted every three to six months.

Overall, the historical data of site related contaminant levels show a decreasing trend

over the past five years. In the past year, none of the monitored parameters were present above the laboratory detection limits in any of the effluent samples, indicating that the treatment system is effectively removing the contaminants from the extracted groundwater.

Operation and maintenance activities associated with the treatment plant generally consist of weekly data downloads and review and a once per month site visit to conduct routine maintenance. Operational problems that have been encountered include faulty flow meters and keypads, and a decrease in pumping rates that may be due to seasonal or drought affects or mineral deposition within the extraction wells and/ or lines. Local power outages, usually storm related, also contributed to several short- term operational interruptions.

Current O&M costs (rounded to nearest $1,000) are $396,000 for a two-year period. These costs are slightly higher than normal due to the increase in technical analysis conducted to evaluate the system performance for this review. V. Progress since the Last Five-Year Review This is the first five-year review for the site.

VI. Five-Year Review Process Administrative Components The five-year review included the following administrative components:

• Document Review • Data Compilation and Review • Five-Year Review Report Development and Review

Community Involvement

A notice was printed in the Reading Eagle newspaper on August 17, 2003. This notice stated that a five-year review was to be conducted, and explained what a five-year review is and why one was being done for this site. It also invited the public to send written comments or concerns and directed them to the site repositories for more information. In October, a notice will be sent to the same local newspaper to announce that the Five-Year Review report is complete and available for public review at the site repository. Document Review

This five-year review consisted of a review of relevant documents including the RODs, BSD, Technical Memorandums, administrative orders, O&M records, drinking water criteria, and monitoring data. A complete list of the documents reviewed can be found in Attachment A. Data Review

Operable Unit 1

Operable Unit 1 of the CryoChem Site addresses the remediation of the drinking water supply of residences and businesses located adjacent to, or downgradient of the CryoChem, Incorporated, facility that have been impacted by the site related contaminants. Monitoring of the OU-1 treatment systems has been conducted in accordance with the Scope of Work included in the September 1994 ESD and as modified by the September 1996 Technical Memorandum. Initially, 20 residences and businesses were equipped with treatment units for removal of the site related contamination. Currently, 12 properties have treatment units as outlined under the OU-1 program. No new properties have been added to the OU-1 program since the 1989 FFS.

During the past three years, 1,1 -DCA and 1,1 -DCE have routinely exceeded their respective action levels. As outlined in the September 1989 ROD, the action level for 1,1-DCA is 0.38 µg/1. However, based on a review conducted by EPA, consideration will be given to changing the action level to 800 µg/1 to reflect current information known about this contaminant and the evolution of the risk assessment process itself. An Explanation of Significant Differences would be issued to formally note the change as a recommendation from this five- year review. Since construction completion, 3 of the 5 contaminants for which groundwater cleanup levels have been established remained below their respective cleanup goals for the residential homes. For all of the contaminants at all locations, the historical information shows a downward trend in concentrations. Vinyl chloride (VC), a daughter product of TCE, was also included in the sampling events to monitor the levels as the contaminants degrade. VC has not been detected to date. Operable Unit 2

Monitoring of the OU-2 remedy was limited to annual sampling of the nine extraction wells (EW-1 through EW-9) and four monitoring wells (MW-1 through MW-4) from May 1998 until early 2003. A site wide groundwater sampling event was conducted from March 24, 2003 through April 7, 2003. For purposes of this report, this event is referred to as the March 2003 sampling event. The March 2003 sampling event was the first site wide event conducted since the 1992 preliminary design field investigation. A total of 40 well locations were sampled, including the nine extraction wells, four extraction monitoring wells, one plant production well, and 26 monitoring well. Samples were collected from each well for volatile organic compounds (VOCs) and 1,4-dioxane. 1,4-dioxane was included in the March 2003 sampling event as it is typically found where TCA is detected because of its use to stabilize TCA. Samples were also collected from each of the nine extraction wells and analyzed for inorganics. Attachment B summarizes the historical sampling results for the site specific contaminants of concern (COCs) for each of the extraction wells. Also included is a figure (Attachment C) tha t details the location of each of the monitoring wells. Concentrations of the COCs in groundwater have decreased significantly over time both within the source area (i.e., CryoChem facility) and downgradient. In addition, the COCs were not detected during the March 2003 sampling in any wells where they had previously not been found. A review of the historical results also indicates that 1,1 -DCA and 1,1 -DCE are the only contaminants that are routinely being detected at levels above the action levels. Both 1,1 - DCA and 1,1-DCE are breakdown products of 1,1,1-TCA, which was the primary chlorinated organic in the solvent material used in the CryoChem weld integrity operation.

1,1 - DCA concentrations ranged from non- detect to 12 µg/ 1 in samples collected during the March 2003 sampling event. Concentrations of 1,1- DCA observed from wells sampled in 1992 ranged from non- detect to 120 µg/ 1. The May 1992 sampling event is being used as a historical baseline as a number of site monitoring wells

were installed in 1992 as part of the OU-2 preliminary design investigation. The 1992 sampling of these wells and wells installed during the RI represents the most complete site wide sampling event conducted prior to the March 1998 treatment plant start-up.

1,1-DCE concentrations ranged from non- detect to 36 µg/1 in the March 2003 samples. Concentrations in samples collected during the 1992 investigation ranged from non- detect to 330 µg/1. The MCL action level for 1,1 - DCE is 7.0 µg/1. The most elevated concentrations have been observed in groundwater samples collected from well RMD2. 1,1- DCE was detected at 27 µg/1 in only one overburden well, R1-1S2, during the 1992 sampling event. In March 2003 1,1-DCE was detected at a concentration of 9 µg/1 in overburden well RI-1S. In 1992, 1,1-DCE was detected above its MCL in three wells, RI-1D, RI-13D1, and RI-13D3. In March 2003, 1,1-DCE was detected above 7 µg/1 in only one bedrock monitoring well, RI- 1D2, however, it was detected in a number of extraction wells.

Contaminant trend graphs for each of the nine extraction wells is shown in Attachment B. All of the extraction and extraction monitoring wells are at depths ranging from 250 to 350 feet below ground surface. 1,1- DCA and 1,1- DCE are the COCs that have routinely exceeded the OU-1 action levels of 0.38 µg/1 and 7.0 µg/1 in both the extraction and extraction monitoring wells. However, DCA and DCE concentrations have decreased since the OU-2 system became operational, 1,1 -DCA concentrations in the nine extraction wells during the March 2003 sampling ranged from non- detect to 10 µg/1. In October 1995 following installation of the extraction wells, but prior to start-up of the treatment plant, the concentration of 1,1-DCA ranged from 1.2 µg/1 to 44.6 µg/1. 1,1-DCE concentrations in March 2003 ranged from non- detect to 57 µg/1 and was detected above its MCL in three of the nine wells sampled. The wells were EW-4, EW-8, and EW-9. In October 1995 the concentration of 1,1- DCE in the nine extraction wells ranged from 0.8 µg/1 to 184 µg/1. Four extraction wells (EW-4, EW-5, EW-8, and EW-9) exceeded the MCL for 1,1- DCE in October 1995. For the four extraction monitoring wells the most elevated concentrations of the site COCs have been observed in well MW-3. Surface Water Monitoring

A figure that details the March 2003 surface water sample locations is also provided in Attachment C. Based on the results and historical reports, it appears that the spring denoted as location SW-7 is most likely the result of groundwater being discharged from the upper bedrock aquifer. As noted during the RI, a normal fault contact exists between the underlying Leithsville Formation and the Brunswick Formation of the Triassic Period. The linear east-west alignment of the stream and significant change in soil characteristics imply the presence of the fault. This results in an upwelling of groundwater when the more permeable Leithsville Formation encounters the less permeable Brunswick Formation. The occurrence of several springs in the area supports this conclusion.

Based on a review of the results, it can be concluded that at location SW-7, concentrations of the site contaminants have decreased or are the same as the results obtained in the 1992 and 1995 samples from the same location. None of the March 2003 surface water sampling results exceeded the respective MCLs for the site related contaminants. 1,1-DCA was detected at 1 µg/1, slightly above the current OU-1 action level of 0.38 µg/l. Site Inspection

The Site inspection was conducted on July 23, 2003. The inspection was attended by Mindi Snoparsky, EPA Hydrologist; Alexis Alexander, EPA RPM; and Mary Mang, EPA contractor. The purpose of the inspection was to assess the protectiveness of the remedy, including the physical condition of the treatment plant and on-site extraction and monitoring wells.

No significant issues were identified. There were no signs of graffiti or damage

from trespassers. A rubber hose for the off-gas valve on one of the carbon canister was eroded. Replacement will be done on the next monthly visit.

Interviews

During interviews, local residents expressed concern about the following:

Resident Comment : I didn't realize that the re was a problem before I bought my home. EPA Response: ERA does not regulate or enforce real estate public disclosure laws. Any concerns in this area should be discussed with legal counsel.

Resident Comment : There's an awful lot of testing going on. People are going in

and out of my house all of the time. EPA Response: EPA conducts sampling of the homes once a year, usually in May. The state is doing their own sampling in association with their cleanup efforts at Mike's Fancy Service Station. We notify all of the residents prior to coming out to sample.

Resident Comment : I bought my home after the tanks were already in the

basement so I was aware of the problem. It doesn't cost me anything so I don't care. Right now, I don't have any health problems with my children and they have lived here since they were babies.

EPA Response: (No response needed.)

EPA interviewed a representative from the Douglass- Berks Police Department

and the Douglass-Berks County Board of Supervisors. There were no concerns regarding the site and no nuisance calls or emergency response calls at the site. The state representative from the Environmental Clean- Up Program stated that the reporting requirements associated with the Site had been met and that there currently no concerns that needed to be addressed. VII. Technical Assessment

The following discussion pertains to OU-1 and OU-2.

Question A: Is the remedy functioning as intended by the decision documents?

Based on the monitoring data collected to date and the review of documents, the OU-1 remedy is functioning as intended by the September 1989 ROD, the BSD, and the Technical Memorandum. The remedial action objective of providing a clean water supply for the residents whose groundwater has been contaminated by the site is being achieved.

For OU-2, a bedrock potentiometric surface map was constructed from water levels collected on May 6, 2003. Using this map the approximate limits of the capture

zone of the extraction well network were determined. The current capture zone extends to the east towards Sunrise Lane, beyond Route 562 (Boyertown Pike) to the south, and to an as yet to be determined distance to the north and west. The estimated capture zone for May 2003 is similar to the design capture zone simulated in 1995, though it appears to extend farther to the east than the simulated capture zone. EPA completed construction of the OU-2 groundwater treatment system on May 23, 1998. Based on the OU-1 and OU-2 monitoring data collected since 1998, the completion of construction, the ongoing operation and maintenance of the treatment system, and the capture zone analysis, the OU-2 remedy is functioning as intended in the September 1990 ROD.

Question B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action objectives (RAOs) used at the time of the remedy selection still valid?

There have been no changes in the physical conditions of the site that would

affect the protectiveness of the remedy. The cleanup level of 0.38 µg/1 for 1,1-DCA as outlined in the ROD for OU-1 no longer appears valid. The risk- based concentration for tap water as outlined in the April 2003 EPA Region 3 RBC table is 800 µg/1. Changes in Standards and To Be Considered

Review of appropriate guidance documents indicate that all Applicable or Relevant and Appropriate Requirements (ARARs) associated with providing affected residents with a clean water supply are being met.

All current ARARs associated with the discharge of treated effluent from the OU-2 groundwater treatment system are being met. See Attachment E for a complete list of the ARARs associated with this Site. Changes in Exposure Pathways, Toxicity and Other Contaminant Characteristics

For OU-1 and OU-2, the current and potential future exposure assumptions used to develop the Human Health Risk Assessment and RAOs used at the time the remedy was selected are still valid. Due to changes in the carcinogenic slope factors for the ingestion and inhalation pathways, the risk based remediation goal outlined in the OU-1 ROD for 1, 1-dichloroethane (0.38 µg/1) is no longer valid. No other significant changes to exposure pathways, toxicity data, or guidance were found that would change clean- up levels except for 1,1-DCA. EPA is proposing that the remediation goal for DCA be changed to the Region 3 Risk Based Concentration for tap water, as published in April 2003. The new proposed action level for DCA is 800 micrograms per liter (µg/1).

Question C: Has any other information come to light that could call into question the protectiveness of the remedy?

An interim remediation (groundwater extraction and treatment) system has been installed at Mike's Fancy Service Station to address groundwater contaminated with gasoline contaminants including methyl tert-butyl ether (MTBE). The effect of the long-term operations of the MTBE extraction system on the OU-2 capture zone should be evaluated. Technical Assessment Summary

According to the data reviewed, the OU-1 interim remedy and the OU-2 remedy are functioning as intended by their respective RODs (and addendums, if applicable). There have been no changes in the physical conditions of the site that would affect the protectiveness of the remedy. The action specific ARAR for the treatment plant effluent discharge is being met. The number of properties downgradient of the source area that have been impacted by unacceptable levels of the site COCs has decreased. VIII. Issues Issues and Potential Affect on Protectiveness Issue Currently Affects

Protectiveness (Y/N)

Affects Future Protectiveness (Y/N)

Action level for DC A as outlined in the OU-1 ROD is significantly below EPA Region 3 RBC screening value for tap water.

N N

Gasoline plume from Mike's Fancy Auto Shop on Boyertown Pike has co-mingled with CryoChem plume in residential area downgradient of site. OU-1 treatment systems carbon usage affected by contaminants in both plumes.

N Not Enough Information

Limited information regarding seasonal changes

N N

in extraction capture zone. Groundwater extraction system installed at Mike's Fancy Auto Shop. Need to evaluate effect on OU-2 capture zone when system operational.

N Not Enough Information

Detected 1,4-dioxane above RBC in several facility wells during March 2003 sampling.

Not Enough Information Not Enough Information

No routine sampling of upgradient and downgradient monitoring wells.

N N

Need to evaluate extraction system to determine if flow rate changing due to mechanical issues and if all extraction wells necessary.

N Not Enough Information

IX. Recommendations and Follow-Up Actions

Table 3 Issue Recommendations/

Follow-Up Actions Party Responsible

Oversight Agency

Milestone Date

Affects Protectiveness (Y/ N)

DCA Cleanup Level Below RBC

Change DCA action level for OU-1.

EPA

EPA 09/30/04

N

Gasoline plume effect on OU-1 treatment systems

Install additional carbon units with MTBE specific removal carbon in affected properties or prepare work plan to investigate usage issue.

Mike's Fancy Auto Shop

PADEP 06/30/04

N

Limited info on seasonal

Collect site wide water levels on

EPA

EPA Initiate 10/03;

N

changes and groundwater extraction

quarterly basis for 2 years and prepare bedrock potentiometric surface maps.

Complete 10/05

Effect of gasoline plume extraction system on OU-2 capture zone

Develop work plan for evaluating effect of gasoline plume extraction system.

EPA

EPA 03/31/04

N

1 ,4-dioxane detected in several wells above RBC

Monitor influent and effluent on monthly basis and add to annual monitoring list.

EPA

EPA Initiate 10/ 03; Complete 09/30/05

N

No routine monitoring of upgradient and downgradient wells

Develop OU-2 performance monitoring plan that includes sampling of upgradient and downgradient wells.

EPA EPA 03/01/04

N

Extraction System Evaluation

Develop work plan for evaluating extraction system and individual well capture zones.

EPA EPA 09/30/04 N

X. Protectiveness Statements

The remedy for OU-1 is protective of human health and the environment because the monitoring data indicate that the treatment systems are effectively remediating the site related contaminants of concern. Initially, 20 properties were equipped with treatment units. Based on the 2003 monitoring data and the proposed change in the action level for DC A, only seven properties will be included in the OU-1 program following EPA's action to increase the DCA action level from 0.38 µg/1 to 800 µg/ 1.

The remedy for OU-2 is protective of human health and the environment because monitoring data collected in 2003 indicates that site- related contaminants are not migrating to unaffected areas and the contaminants in the groundwater beneath the facility are being removed and effectively treated. Based on the capture zone analysis, the OU-2 pump and treat system is withdrawing groundwater per the design capture zone. No protectiveness statement is needed for OU-3.

The remedial actions at OU-1, OU-2, and OU-3 are protective and therefore the Site remedy is protective of human health and the environment. XI. Next Five-Year Review

The next five-year review will be completed no later than September 2008, five years from the signature date of this review.

ATTACHMENT A

LIST OF DOCUMENTS REVIEWED CH2M Hill. 1992. Draft CryoChem Predesign Field Investigation. Reston, Virginia. September. CH2M Hill. 1994. CryoChem OU-2 Remedial Design/Remedial Action. Sampling and Analysis Plan. CryoChem Site. Reston, Virginia. February. CH2M Hill. 1995a. Preliminary Design Report: Groundwater Treatment System. Operable Unit 2. CryoChem Site, Berks County. Pennsylvania. Reston, Virginia. October. CH2M Hill. 1995b. Field Activity Report: Well Installation. Aquifer Testing. Geophysical Logging. Groundwater Sampling. Operable Unit 2. Cryochem Site. Berks County. Pennsylvania. Reston, Virginia. November. CH2M Hill. 1998. Remedial Action Report: Operable Unit 2 Cryochem Site. Reston, Virginia. May. JACACorp. 1990. Final Remedial Investigation Report for the CryoChem Site. Fort Washington, Pennsylvania. June. JACACorp. 1990. Final Feasibility Study for the CryoChem Site. Fort Washington, Pennsylvania. June. Engineering Technologies Associates, Inc. (ETA). 2002. CryoChem Groundwater Treatment Facility. Bovertown. Pennsylvania. Operation & Maintenance Manual. Volume I. Columbia, Maryland. January. Tetra Tech NUS Inc. ( TtNUS). 2002. Semiannual Performance Report. January 1. 2002 - June 30. 2002. for Long-Term Remedial Action of Area- Wide Groundwater (OU-2). Cryochem Superfund Site. Earl Township. Berks County. Pennsylvania. King of Prussia, Pennsylvania. September. U. S. Environmental Protection Agency (USEPA). 1988. Administrative Order by Consent (Consent Order) Between the USEPA and the Cryochem Site Potentially Responsible Parties. Philadelphia, Pennsylvania. February 19. USEPA. 1989. Declaration for the Record of Decision. Operable Unit 1. Cryochem Site. Philadelphia, Pennsylvania. September 29. USEPA. 1990. Declaration for the Record of Decision. Operable Unit 1 Cryochem Site.

Philadelphia, Pennsylvania. September 28. USEPA. 1994. Explanation of Significant Differences. Cryochem Superfund Site. Operable Unit 1 (Drinking Water). Worman. Earl Township. Pennsylvania. Philadelphia, Pennsylvania, September 22. USEPA. 1996. Technical Memorandum Modifying Statement of Work for Cryochem OU-1. Philadelphia, PA. September 20. USEPA. 1998. Explanation of Significant Differences. Cryochem Superfund Site. Operable Unit 3 (Contaminated Soil). Earl Township. Pennsylvania. Philadelphia, Pennsylvania. September 22. USEPA. 1998. Preliminary Close Out Report (Long Term Remedial Action) Cryochem Superfund Site. Earl Township. Pennsylvania. Philadelphia, Pennsylvania. September 22. Vitillo Corporation. 2002. Summary Report May 2002 Sampling Event. Cryochem Operating Unit # 1. Earl and Douglas Townships. PA. Reading, Pennsylvania. August.

ATTACHMENT B

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xicit

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nsid

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le de

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p sta

ndar

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tern

ativ

e. T

he pr

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s of r

iskan

d de

velo

pmen

t of c

lean

up st

ado

cum

ented

in th

e 19

93 R

OD.

The

objec

tive

of th

is re

gulat

ion

is to

resto

re a

ndm

aint

ain

the

chem

ical

, phy

sical

, and

bio

logi

cal

inte

grity

of t

he N

atio

n's w

ater

s.

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ts f

orth

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ATTACHMENT E

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III 1650 Arch Street

Philadelphia, Pennsylvania 19103-2029

September 18, 2003 SUBJECT: Five Year Review; Cryochem Superfund Site; Boyertown, Pennsylvania FROM: Bruce R. Pluta, Coordinator Biological Technical Assistance Group TO: Alexis Alexander (3HS21) Eastern PA Remedial Section Per you request, I have reviewed and assessed the most recent site data as it pertains to potential impacts on ecological receptors. A focal point of the review was whether or not the baseline data specified in the ROD was collected and if subsequent data collection efforts allowed for comparison to the baseline. The ROD specifies the following:

A pre-discharge evaluation of the stream biota would be conducted for the purpose of providing a baseline against which any potential impacts of the discharge upon the receiving stream could be evaluated. An effluent toxicity test would be performed on the treated discharge and post-discharge downstream sampling would be conducted to evaluate the persistence of the potential toxicants discharged from the treatment units. In addition, downstream potentially sensitive environments, if any, would be fully evaluated to determine if the discharge results in adverse impacts.

Based on a review of the most recent data, as well as the available historical data, it appears that neither the pre-discharge/baseline data, effluent toxicity test data, or comparable data from subsequent years was ever collected. Thus, the evaluation referred to in the ROD cannot be conducted. It should be noted that the original comment which resulted in this specification was made by the Bioassessment Work Group, the precursor to the BTAG, in a memo dated May 10, 1990. The comment was specifically concerned about the possibility of an impact of a "significant discharge" and the "persistence of the potential toxicants. "It was also noted that the "monitoring may only have to be done initially to document that the toxicants are not persistent." While the recommended data does not appear to have been collected, monitoring of the contaminant concentrations in both the receiving water and the site effluent has been ongoing. Based upon a review of the most recent data and comparison with appropriate ecologically-based screening values, the levels of contaminants monitored are not

expected to pose an unacceptable risk to ecological receptors. Given the concentrations of contaminants currently being reported, the decreasing trend of contaminant concentrations, their persistence, and their known ecotoxicological properties, it does not appear that implementation of the biological monitoring program suggested in the ROD is warranted at this time. Thank you for the opportunity to provide support for this site. Please contact me at x 4-2380 if you have any questions.