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FIVE-YEAR REVIEW REPORT

DUBLIN TCE SUPERFUND SITE

BUCKS COUNTY, PENNSYLVANIA

Prepared by:

U.S. Environmental Protection Agency Region III

Pliiladelpliia, Pennsylvania

SDMS DocID 2130945

E P A Five Year Review S igna tu re Cover Dubl in T C E Superfund Site Bucks County , Pennsylvania

Site Identification Site Name: Dublin TCE EPAID: PAD981740004 Region: EPA Region III State: Pennsylvania City, County: Dublin Borough, Bucks County

Site Status NPL status: F Remediation status: OUl - construction complete; 0U2 - RI/FS stage Multiple OUs: Yes Construction completion date: Not available Fund/PRP/Federal facility lead: PRP Lead Agency: EPA Has site been put into reuse?: N/A

Review Status: Who conducted the review (EPA, state,): EPA Region III Author name: Jill S. Lowe Author title: Remedial Project Manager Author affiliation: EPA Region III Review Period: 1994-1999 Date(s) of site inspection: June 8, 1999 Highlight (statutory or policy): statutory Review Number (1,2 ): 1 Triggering action event: RA onsite Trigger action date: 4/25/94 DueDate: April 1999

^ ^ S G I N A I

E P A Five Y e a r Review S igna ture Cover Dubl in T C E Superfund Site Bucks Coun ty , Pennsylvania

Deficiencies: A Remedial Action has not been implemented for 0U2.

Recommendations and Required Actions: A Remedial Action needs to be implemented for 0U2.

Protectiveness Statement(s):

The remedial action for Operable Unit One is protective, because a drinking water line and treatment system have been installed. Since no remedy has been implemented for Operable Unit Two, at this time, it cannot be considered protective. The overall remedy for the site cannot be considered protective of human health and the environment until an appropriate remedy is implemented for Operable Unit Two. There is, however, no immediate risk to human health and the environment, because the remedy for Operable Unit One has been implemented in accordance with the Record of Decision.

Signature of EPA Division Director and Date:

Xjio/ oO

Abraham Ferdas, Director Date Hazardous Site Cleanup Division

Table of Contents Five Year Review

Dublin TCE Superfund Site

I. Introduction ....; 1 II. Site Chronology 2 III. Background 3-4 IV. Remedial Actions 4-9

A. Remedy Selected '. 5-6 B. System Operations 8 C. Operations and Maintenance Costs 19

V. Five Year Review Findings 9-10 A. Five Year Review Process 9 B. Interview and Site Inspection 9 C. Risk Information Review 10 D. Data Review 10

VI. Assessment : 11-12 VII. Deficiencies 12 VIII. Recommendations and Required Actions : 12 IX. Protectiveness Statement 12 X. Next Review 12

References 13

List of Tables: Table 1: Chronology of Site Events Table 2: Summary of Remedial Action Objectives and Remedial Actions Table 3: Wells to be Monitored Table 4: Volatile Organic Compounds Monitored Table 5: Participants at Site Visit

ORIGINAL

U.S. Env i ronmen ta l Pro tec t ion Agency Region I I I Five Y e a r Review R e p o r t

Dubl in T C E Super fund Site Bucks Coun ty , Pennsylvania

I. Introduction

EPA Region III conducted a five year review of the remedial actions implemented at the Dublin TCE Superfimd Site in Bucks County, Pennsylvania. This review was conducted from June 1999 through December 1999. This report documents the results of the review. 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 the review are documented In the five year review report. In addition, the five year review report will identify deficiencies found during the review and will identify recommendations to address them.

EPA must implement five-year reviews consistent with the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) and the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). CERCLA § 121 (c), as amended, 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.

The NCP part 300.430(f)(4)(ii) of the Code of Federal Regulations (CFR) 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.

This is the first five-year review for the Dublin TCE site. The triggering action for this statutory review is the date of Remedial Action (RA) on-site construction as shown in EPA WasteLAN database: April 25, 1994. An interim remedial action was conducted at the Dublin TCE which resulted in hazardous substances, pollutants, or contaminants remaining onsite. The Site is not yet complete; Operable Unit 2 (0U2) is still in the Feasibility Study (FS) phase of the Remedial Investigation (RI)/FS process.

II. Site Chronology

Table 1 lists the chronology of events for the Dublin TCE site.

o ̂ ^GINAL

Table 1: Chronology of Site Events

.Date i : n 'I, • r : %̂ October 26, 1989

August 30, 1990

March 19, 1991

August 15, 1991

December 30, 1991

January 25, 1994

March 3, 1995

December 20, 1995

January 24, 1996

June 19, 1996

June 19, 1998

December 4, 1998

January 4, 1999

July 8, 1999

October 4, 1999

Jfev̂ it; ' - - /^r ' : -•"'' ' ''i 1H'̂ - ' " f ^ y Proposed to NPL List

NPL Listing

RI/FS initiated for OUl Interim Action

RI/FS initiated forOU2

Record Of Decision (ROD) signature for OUl

Remedial design for OUl Phase 1 approved

Remedial design for OUl Phase 2 approved

Remedial Design for OUl Phase 3 approved

Remedial Action for OUl Phase 1 complete

RI/FS draft for 0U2 submitted for EPA review

Remedial Action for OUl Phase 3 complete

EPA approves RI for 0U2 with modifications

Remedial Action for OUl Phase 2 complete

EPA approves Baseline Risk Assessment for 0U2

FS draft for 0U2 submitted for EPA review

III. Background

Physical location and description - The 4 '/z -acre Dublin TCE site is located at 120 Mill Street in Dublin Borough, Bucks County, Pennsylvania. The Site is surrounded by residences and businesses to the east, west, and south. A fioiit orchard borders the Site to the north and west. The Site consists of a one-story brick building surrounded by a parking lot. A fire tower is located at the northern boundary of the property.

An estimated 10,100 people obtain drinking water from public and private wells within 3 miles of the Site. The aquifer is classified as Class IIA, a current source of drinking water. Based on available information, the groundwater flows from southeast to northwest beneath the Site and is controlled predominately by fractures. Groundwater beneath the Site flows towards residential and commercial wells in Dublin Borough.

History - The property has been the site of several manufacturing operations over the last 50 years. The Kollsman Motor Corporation (KMC) owned and operated the Site from 1959 to 1971 and used it to manufacture miniature precision motors, gear trains, clutches, brakes and related electromechanical components which were used in manned aircraft and missiles. Trichloroethylene (TCE) was used as a degreasing solvent in this operation and allegedly disposed of on the property. KMC sold the property to Kollsman Instrument Corporation (KIC) in 1971.

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

John H. Thompson purchased the property in 1986 and is the current owner and operator of the Site. Mr. Thompson uses a portion of the Site to restore antique race cars and leases a portion of the Site to Laboratory Testing, Incorporated (LTI). LTI uses the property for metallurgical testing.

Contaminants Detected - The nature and extent of the contamination associated with the Site has been investigated since 1986. Analytical data for groundwater samples collected from locations throughout Dublin Borough from 1986 to present identified a plume of chlorinated VOCs in the fractured bedrock aquifer beneath the 120 Mill Street property and portions of the Borough. The primary constituent of concern in the groundwater is TCE. The data indicated that the plume migrated from the 120 Mill Street property and extends laterally to the north/northwest from the Site, which coincides with the direction of groundwater flow.

Listing on NPL - As a result of the field investigations, the Site was proposed to the National Priorities List on October 26, 1989 and was formally added to the list on August 30, 1990.

ORIGINAL Operable Units:

The Site was divided into two parts or operable units. Operable Unit One focuses on supplying safe drinking water to the residences and businesses and Operable Unit Two is concerned with the contaminated groundwater.

Operable Unit One (QUI)

During a routine drinking water survey in the summer of 1986, the Bucks County Health Department (BCHD) discovered levels of TCE up to 1000 parts per billion (ppb) in 23 tap water samples (maximum contaminant level is 5 ppb). Approximately 170 homes, apartments and businesses in Dublin Borough were affected. BCHD issued advisories to the public on the best approach to curtail water usage and prevent further exposure to TCE. For residences with TCE levels greater than 5 ppb, BCHD recommended the installation of carbon filters. For TCE levels above 500 ppb, BCHD cautioned residents not to use their tap water for bathing.

The EPA region III Emergency Response Section received a request from BCHD to evaluate the Site on September 3, 1986. A preliminary assessment, conducted by EPA, determined the current water usage status of all residential and commercial wells which were found to be contaminated with TCE.

In 1991, EPA conducted a Focused Feasibility Study (FFS) for OUl to evaluate remedial alternatives for providing an alternate clean drinking water supply to the affected and potentially affected residences and businesses.

On December 30, 1991, EPA issued a ROD for OUl. The preferred alternative in the ROD was for an Alternate Water Supply, which was to be constructed in three phases.

Operable Unit Two (OU2)

0U2 will address the investigation and remediation of the groundwater, soil, and surface water at the Site. Currently, 0U2 is undergoing the RI/FS process, which was initiated in August 1991. The draft RI/FS was submitted in June 1996. On December 4, 1998, the EPA accepted the RI with modifications. The Baseline Risk Assessment was approved on July 8, 1999. The first draft of the FS was submitted on October 4, 1999, and is currently being reviewed by the EPA.

IV. Remedial Action - OUl

On June 29, 1987, EPA entered into a CERCLA Section 106 Consent Agreement and Order with John H. Thompson. Mr. Thompson agreed to: (1) take action to assure that all residents and commercial employees exposed to TCE levels greater than 5 ppb would have an adequate treatment system in place or would be supplied with bottled water (as specified in the Work Plan attached to the Consent Agreement and Order), (2) conduct periodic monitoring of all carbon filters and air strippers being used by the residences and businesses to assure that the units were functioning properly, and (3) conduct periodic groundwater monitoring of wells for all residences and businesses at risk in accordance with the Work Plan.

ORiG

This Consent Order and Agreement was amended in April 1991 to provide point-of-entry carbon filtration systems (i.e. treatment systems installed on the water source entering the household) to all residential dwellings with groundwater contamination greater than 5 ppb of TCE. At businesses, either bottled water or point-of-use carbon filtration systems are provided. This amendment addressed the risk posed by inhalation of TCE vapors released from the groundwater. Residences that were previously supplied with only point-of-use treatment systems (i.e. treatment systems located at the kitchen tap) are now being supplied with the point-of-entry systems. Residential well testing conducted under this order

. indicated that groundwater is contaminated with several volatile organic compounds (VOCs), including trichloroethylene (TCE), tetrachloroethylene (PCE) and vinyl chloride.

On June 4, 1990, the Commonwealth of Pennsylvania, Department of Environmental Protection (PADEP) and Sequa Corporation (successor in ownership to Kollsman Motor Corporation and Kollsman Instrument Corporation) entered into a Consent Order and Agreement under the Commonwealths' Clean Streams Act. Sequa Corporation agreed to investigate and abate the groundwater contamination problems at or near the Site in accordance with the Work Plan attached to the Consent Order and Agreement. Under the Consent Order and Agreement executed by Sequa and PADEP, Sequa also agreed to submit a Recommended Remedial Action Plan to address the contaminated groundwater and provide for a water distribution system.

John H. Thompson, at the request of PADEP, installed two monitoring wells at the Site in 1988. Eight additional monitoring wells were installed off of the 120 Mill Street property under a separate study by Geraghty & Miller. The monitoring wells installed both on-site as well as off-site show contamination by VOCs, including TCE and vinyl chloride. Three municipal supply wells located in the Borough were tested for VOCs in 1991 by Dublin Borough. No contamination was detected in these wells.

In 1991, EPA conducted a Focused Feasibility Study (FFS) for OUl to evaluate remedial alternatives for providing an alternate clean drinking water supply to the affected and potentially affected residences and businesses.

A. Remedy Selected - OUl

On December 30, 1991, EPA issued a ROD for OUl. Table 2 provides a summary of Remedial Action objectives and Remedial Actions. The ROD was for an Alternate Water Supply, to be constructed in three phases. The first phase included a 1 Vz mile extension of the existing water line in Dublin Borough to homes which were affected or could potentially be affected by contaminated groundwater from the Site. This phase was expedited so that the water supply line could be installed in coordination with highway construction work on PA Route 313 conducted by the Pennsylvania Department of Transportation (PennDOT). Service lines were also installed into the homes that were designated for connection during this phase, which was complete in January 1996.

The second phase included the installation of a public water supply well and an associated treatment system, the completion of 62 service connections after the new supply well and treatment system were placed into continuous operation, and subsequent abandonment of 70 private supply wells which were taken out of service. The supply well and treatment system were completed on

February 9, 1998, the services connections were completed on October 23, 1998 and the well abandonment activities were completed in January 1999.

The third phase of the project included the fiirther extension of the water line into Hilltovm Townnship. This provided public water to an additional 20 homes, which EPA determined were affected or could potentially be affected from site contamination. This included the installation of an additional 1 V2 mile of water supply lines and a meter pit that allows Dublin Borough to sell bulk water to the Hilltown Township Water and Sewer Authority. This phase was completed in April 1998.

The Remedial Action also required the quarterly monitoring of Residential and Commercial wells that are not addressed by the public water supply but which haye the potential for contamination. Table 3 lists the sample locations and Table 4 lists the VOCs to be monitored. The monitoring will continue until the EPA deems it no longer necessary. The list of sample locations will be amended as required.

Table 2: Summary of Remedial Action Objectives and Remedial Actions

;Activity{y^§v;H;r ROD signed:

Remedial Action Objectives:

Remediali;''£;i -,.' '••-•' Actionsi'̂ lfj^^f!: ;

0

'•sm^^i;^^:Ui':. '.,••'•.'•V:!̂ f̂:•: - ' ^ 'Mir^ l - :

December 30, 1991

To provide safe drinking water

Alternative:^^ -fTreatnient of Watierlfrdm a New ^''^ellfor.v an ExistrngWeU WitMn thie Plume witK'Air Stripping and : :Vapcir-Phasi^,Ca'rbbi Adsor^^ .--, -/, }:^.:^fi., ''-:-

Development, construction and operation of a new, or existing, water well within the plume of contamination

Construction and operation of water treatment system to provide water which does not exceed Maximum Contaminant Levels (MCLs)

Expansion of the existing Dublin Borough public water distribution system

Continued monitoring of residential and commercial wells at homes not addressed by the public water supply, but which have a potential for contamination

Operation and maintenance of the selected remedy

ORj ^^INAL

Table 3: Wells to be Monitored

DUBLIN TCE SITE ADDITIONAL WELLS TO BE MONITORED

AS PER TABLE 2 OF ROD

Maple Street

111

113

119

121

123

127

131

Woodedge, Apartments

Cherry Lane

115

119

121 •

Deep Run Road

109

110

112

111

114

Middle Road

104

105

111

112

115

116

117

Rickets Road (Hilltown Township)

3020

3000

2930

Dublin Acres

154 Marilyn Lane

Frontier Road

217

^AL

Table 4: Volatile Organic Compounds Monitored

' ^S- x f e liil^^^YoJ^'s.^l^fe&cbti^^'ff^s-'lilg^^ ^ ^ i _ _̂ Chloromethane

Chloroethane

Carbon Disulfide

Cis-1,2-Dichloroethene

Carbon Tetrachloride

Cis-l,3-Dichloropropene

1,1,2-Trichloroethane

Bromoform

Tetrachloroethene

Chlorobenzene

Total Xylenes

Bromomethane

Methyl Chloride

1,1-Dichloroethene

Trans-1,2-Dichloroethene

Bromodichloromethane

Trichloroethene

Benzene

4-Methyl-2-Pentanone

Toluene

Ethylbenzene

Vinyl Chloride

Acetone

1,1-Dichloroethane

Chloroform

1,2-Dichloropropene

Dibromochloromethane

Trans-1,3-Dichloropropene

2-Hexanone

1,1,2,2-Tetrachloroethane

Styrene

B. System Operations

A Pre-Certification Inspection was performed by the EPA and PADEP on June 8, 1999. At that time, the work performed previously as Phases I and II was reinspected, and a sampling of the properties included in Phase III were inspected. As a result of this pre-inspection, the EPA agreed that the work had been performed in accordance with the Order and was complete.

On January 4, 1999, the EPA accepted the Certification of Completion Report for the Remedial Action. The system was determined to be performed in accordance with the requirements of the Order and the Performance Standards. The acceptance letter stated that the monitoring program will be required to be conducted to ensure that residences and businesses not connected to the public water supply have a safe source of drinking water.

The water line which was constructed under this Remedial Action has been transferred to Dublin Borough for operations and maintenance. On January 26, 2000, the EPA interviewed the Dublin Borough Manager, Tom Suplee and the Assistant Manager, Bob Edwards, to inquire if any complaints have been received regarding the water line. They stated that none have been received to date and the system is operating as designed.

ORIGINAL C. Operations and Maintenance Costs

The operations and maintenance costs for the remedial action have not been provided. The ROD estimated the annual operations and maintenance costs to be $300,000. In a settlement agreement with Dublin Borough, Sequa transferred ownership of the water line and treatment system to the Borough after construction. The annual operations and maintenance costs were part of this settlement and are now the responsibility of Dublin Borough.

V. Five Year Review Findings

A. Five Year Review Process

A site visit and interview lead by EPA were conducted at Dublin TCE Superftand Site on June 9, 1999. The participants were:

Table 5: Participants at Site Visit

Participant

Pat DeGhangi

Richard Longstreth

Bob Edwards

Jerry Brown

Mike Timcik

Pat McManus

Jill Lowe

Affdiation

CKS Engineers, Inc.

CKS Engineers, Inc.

Dublin Borough

Dublin Borough

PADEP

EPA

EPA

Title

Project Manager

Project Manager

Assistant Borough Manager

Water Department Supervisor

Project Manager

Remedial Project Manager

Remedial Project Manager

After the onsite visit, the EPA had a telephone discussion, on January 26, 2000, with Dublin Borough Manager, Tom Suplee about the public water line.

B. Interview and Site Inspection

The five year review consisted of an interview and a site inspection conducted during the pre-certification inspection . The interview covered the public water line remedy, including the treatment system, its operation and maintenance, administrative controls, and the long term monitoring.

The site inspection included a tour of the treatment building and inspection of the following properties:

194 Main Street (Dublin Fire House)

0^/G/A/. ̂AL

142 Main Street (First Federal Bank) • 146 Main Street (Whistlewood Apartments)

155 Elephant Road (Worthington) 130 Main Street (Moyer)

All the wells and connections seemed to be in good working condition.

Treatment Building - The treatment building consists of a manganese sequestering system, a multi-staged diffused air stripper, off-gas treatment system, effluent tank and booster pump and a chlorination system. Under normal operating conditions, the treatment facility is unattended. To notify operating personnel of potential problems, the facility is equipped with an auto-dialer system. All the equipment was in good condition and has been operating on a continuing basis without any problems for several months. Lowery, the air stripper manufacturer, did have to install a set of enlarged air injectors because the original injectors were getting clogged. However, since the new air injectors were installed no ftirther problems have been encountered.

On January 26, 2000, a telephone interview was held with the Dublin Borough Manager Tom Suplee and the Assistant Manager, Bob Edwards. They both reported that there have been no problems with the water line. Operation of the line has been problem free and there have been no complaints from the residents that the line serves.

C. Risk Information Review

ROD OUl

ROD OUl references an extensive list of federal and state water £ind air statutes and regulations (page 41 ROD OUl). The remedy focuses on providing a permanent clean drinking water supply for the residences and businesses whose groundwater has been or may become contaminated by the Site. The water line and treatment system are now part of the Dublin Borough Public Water System, and therefore, are subject to all the regulations as required in the Safe Drinking Water Act (SDWA). The SDWA was referenced as an applicable or relevant and appropriate requirement (ARAR) in the ROD.

D. Data Review

The primary remedial objective of the OUl ROD is to supply clean drinking water to residences and businesses whose wells are currently or potentially affected by the Dublin TCE Site. The water line and treatment system that were constructed meets this objective.

A secondary objective of the ROD was to ensure that the contamination does not migrate to additional residences and businesses not serviced by the new water line and treatment system. A well sampling program has been initiated which will monitor wells beyond the contamination to ensure the plume is not migrating. If sampling indicates that the contamination is moving, additional measures will be taken to ensure a clean drinking water supply.

1 0

ORIGINAL

VI. Assessment

The following conclusions support the determination that the interim remedy at the Dublin TCE Superfund Site remains protective of human health and the environment:

Question A: Have conditions external to the remedy changed since the remedy was selected?

• No changes in land use: There have been no changes in land use, however, the area surrounding the Site is developing.

• No changes in known contaminants, sources, or pathways at the Site: There have been no changes in contaminants.

• No changes in known hydrologic/hydrogeologic conditions: No changes in hydrologic conditions are knovm to date. The OUl supply well may change the plume configuration with its continued pumping.

Question B: Has the remedy been implemented in accordance with the decision documents?

• HASP/Contingency Plan: There is a Health and Safety Plan which was submitted as part of the remedial design.

• Access and Institutional Controls: Dublin Borough Ordinance No. 164, requires that private wells be abandoned, as a general rule, when a borough water line exists to service a home or business. The Borough Ordinance does, however, exclude those residents and business owners and operators who have utilized private wells prior to the construction of the Borough water line. The ROD did not require additional institutional controls.

• Remedy performance: The water line and treatment system are operating and fiinctioning as designed. Clean drinking water is being supplied to residences and businesses.

• Adequacy of system operation: The water line and treatment system are operating as designed. There have been minor upgrades to the air stripper to enlarge the air injectors.

• No need for optimization: There is no need for optimization.

• No early indicators of potential remedy failure: There are no early indications of remedy failure.

Question C: Has any risk information changed since the remedy was selected?

1 1

ORIGINAL

• Changes in ARARs: The remedy is now being operated as part of the Dublin Borough Water System, which is regulated by the Safe Drinking Water Act. All ARARs are being met.

VII. Deficiencies

A Remedial Action has not been implemented for 0U2.

VIII. Required Actions

A Remedial Action needs to be implemented for 0U2.

,, Repbnim'eridatioris//^ ;, Required Actions

Proposed Plan

Record of Decision

Implement Remedy

MIPW ' i ; ^responsible]: V

EPA

EPA

PRP

tt.!' Oversight^ ;,i^, Agency-J-:-'

EPA

EPA

EPA

••;, Milestone^;

2001/1

2001/2

2003/4

^ Required.^Wdhs: 'C. CurrentlyiEffects •'.:Protectiveness.'(Y/N)

Y

Y

Y

IX. Protectiveness Statements

The protectiveness of OUl and 0U2 are discussed individually below.

Operable Unit One

The remedy for OUl is protective of human health and the environment for current use. The remedy supplies a permanent source of clean drinking water for residences and businesses.

Operable Unit Two

The remedy for 0U2 has not been established. 0U2 is currently in the Remedial Investigation/Feasibility Study phase of the Superfimd process. The interim action, OUl, will be incorporated into the action taken at 0U2.

X. Next Review

This is a statutory review. The next review will be conducted by February, 2005.

12

ORIGIN

References

Final Inspection - Water Line Connection/Well Abandonment, Dublin TCE Superftind Site, Dublin, PA, dated June 11, 1999.

Record of Decision Operable Unit One - Dublin TCE Superfijnd Site, Dublin Borough, Bucks County, PA, signed December 30, 1991.

Dublin TCE Project - Well Abandonments Report, CKS Engineering, dated March 1, 1999

Dublin TCE NPL Site - August 1998 Progress Report, CKS Engineering, dated September 5, 1998

Final Design Documents: Water Treatment System, Operable Unit One, Dublin TCE Site, Bucks County, PA, dated March 1995

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