REMEDIATION SYSTEM EVALUATION

RAYMARK SUPERFUND SITE

HATBORO, PENNSYLVANIA

 Report of the Remediation System Evaluation,

Site Visit Conducted at the Raymark Superfund Site

June 7-8, 2001

Final Report Submitted to Region 3

December 19, 2001

 

 
NOTICE

Work described herein was performed by GeoTrans, Inc. (GeoTrans) and the United States Army Corps

of Engineers (USACE) for the U.S. Environmental Protection Agency (U.S. EPA). Work conducted by

GeoTrans, including preparation of this report, was performed under Dynamac Contract No. 68-C-99-

256, Subcontract No. 91517. Mention of trade names or commercial products does not constitute

endorsement or recommendation for use.

This document (EPA 542-R-02-008m) may be downloaded from EPA’s Technology Innovation Office

website at www.epa.gov/tio or www.cluin.org/rse. 
i

EXECUTIVE SUMMARY

The Raymark site occupies 7 acres off Jacksonville Road in an industrial part of Hatboro, Pennsylvania. 

The pump-and-treat system addresses groundwater contamination, primarily trichloroethylene (TCE),

associated with the operations of various manufacturers of rivets and other metal manufacturers, including

the Penn Rivet and Machine Company that occupied the site from 1947 through 1954. The site has been

divided into the following three operable units:

• OU1, completed in October 1995, addressed the soil contamination with excavation of a former

storage tank location, an asphalt cap, a multi-layer synthetic cap, and soil vapor extraction;

• OU2 addressed the local drinking water supply by installing air strippers on select public wells to

treat contaminated groundwater and vapor phase carbon to treat the off gas from the air strippers;

and

• OU3 continues to address the onsite groundwater contamination by extracting groundwater,

treating it with an air stripper (equipped with vapor phase carbon to treat the off gas), and

discharging the treated water through a storm drain to nearby Pennypack Creek.

Hatboro water supply wells H-14 and H-17 are the only two remaining public water supply wells to

operate. The only costs associated with operation of these wells and treatment of the extracted water that

are associated with the Raymark site are for regular replacement of the vapor phase carbon. 

The RSE team focused on OU3 and found a well-operated treatment system. However, possibly due to the

high turnover rate among EPA Remedial Project Managers for this site and changes in contractors, site

information and background, especially related to system design, is difficult to access or is unavailable. In

addition the recent sampling event in April and May 2000, was the only aquifer monitoring conducted

onsite in over half a decade. Recommendations to improve system effectiveness include the following:

• The site-related wells require surveying and downhole camera work to determine the elevations of

the tops of the well casings and the screened intervals of the wells. Without this information

reliable potentiometric surfaces indicating groundwater flow cannot be generated. In addition, this

information is necessary for plume delineation and evaluation of the capture zone.

• Once this information is obtained for the site-related wells, water level elevations should be

measured and potentiometric surfaces should be generated for pumping and non-pumping

scenarios. This may require the installation of piezometers in each of the underlying stratigraphic

units. In addition, previously collected depth-to-water measurements can be converted to water

elevations for further evaluation.

• The plume should also be better delineated. This can be accomplished through continuing with the

new annual sampling program and adding additional monitoring points in each of the underlying

stratigraphic units.

• Once the potentiometric surfaces are generated and the plume is better delineated, the capture

zones for the extraction wells should be analyzed. This is especially pertinent given the

discrepancy between the extraction rate of 285 gpm suggested in the 1990 Feasibility Study, which
ii

was based on a preliminary capture zone analysis, and the current average extraction rate of 48

gpm. If onsite TCE contamination is not captured by the current pumping program, increased

pumping rates and additional extraction wells will be required.

• Wells associated with the site, including a former extraction well, screen multiple stratigraphic

units, but are no longer used for pumping. These wells should be properly sealed to prevent cross

contamination of the stratigraphic units.

• Samples should be taken of the sediments and surface water of Pennypack Creek, which is located

within a mile downgradient of the Raymark site. Figures in the 1990 Feasibility Study indicate

that the groundwater plume may impact the creek. In addition, the creek is the discharge location

for the treatment plant effluent which, according to a consent decree, may have TCE

concentrations as high as 73 ppb.

• Finally, TCE concentrations in the shallow subsurface underlying the eastern portion of the site

indicate that soil gas may have significant concentrations of TCE. This could adversely impact

onsite and nearby buildings. Air sampling in these buildings should be conducted.

These recommendations will likely require approximately $120,000 in capital costs and might increase

annual costs by more than $12,000. 

The RSE team also found that site-related costs are reasonable, and the team has no current

recommendations for cost reduction. Rather, the focus of the site activities should address the abovementioned effectiveness concerns and the continued operation of the treatment plant. In addition, siterelated data and documents should be organized and made easily accessible to the site managers. Current

efforts to develop new site documents, compile existing documents, and organizing current information will

likely cost $30,000.
iii

PREFACE

This report was prepared as part of a project conducted by the United States Environmental Protection

Agency (USEPA) Technology Innovation Office (TIO) and Office of Emergency and Remedial Response

(OERR). The objective of this project is to conduct Remediation System Evaluations (RSEs) of pumpand-treat systems at Superfund sites that are “Fund-lead” (i.e., financed by USEPA). RSEs are to be

conducted for up to two systems in each EPA Region with the exception of Regions 4 and 5, which already

had similar evaluations in a pilot project.

The following organizations are implementing this project.

Organization Key Contact Contact Information

USEPA Technology Innovation

Office

(USEPA TIO)

Kathy Yager 11 Technology Drive (ECA/OEME)

North Chelmsford, MA 01863

phone: 617-918-8362

fax: 617-918-8417

yager.kathleen@epa.gov

USEPA Office of Emergency and

Remedial Response 

(OERR)

Paul Nadeau 1200 Pennsylvania Avenue, NW

Washington, DC 20460

Mail Code 5201G

phone: 703-603-8794

fax: 703-603-9112

nadeau.paul@epa.gov

GeoTrans, Inc. 

(Contractor to USEPA TIO)

Doug Sutton GeoTrans, Inc.

2 Paragon Way

Freehold, NJ 07728

(732) 409-0344 

Fax: (732) 409-3020

dsutton@geotransinc.com

Army Corp of Engineers:

Hazardous, Toxic, and Radioactive

Waste Center of Expertise

(USACE HTRW CX)

Dave Becker 12565 W. Center Road

Omaha, NE 68144-3869

(402) 697-2655

Fax: (402) 691-2673

dave.j.becker@nwd02.usace.army.mil
iv

The project team is grateful for the help provided by the following EPA Project Liaisons.

Region1 

Region 2

Region 3

Region 4

Region 5

Darryl Luce and Larry Brill

Diana Cutt

Kathy Davies

Kay Wischkaemper

Dion Novak

Region 6

Region 7

Region 8

Region 9

Region 10

Vincent Malott

Mary Peterson 

Armando Saenz and Richard Muza

Herb Levine

Bernie Zavala

They were vital in selecting the Fund-lead P&T systems to be evaluated and facilitating communication

between the project team and the Remedial Project Managers (RPM’s).
v

TABLE OF CONTENTS

EXECUTIVE SUMMARY.................................................................. . i

PREFACE .............................................................................. iii

TABLE OF CONTENTS ................................................................... v

1.0 INTRODUCTION ..................................................................... 1

1.1 PURPOSE ................................................................. 1

1.2 TEAM COMPOSITION ......................................................... 1

1.3 DOCUMENTS REVIEWED ...................................................... 2

1.4 PERSONS CONTACTED ....................................................... 3

1.5 SITE LOCATION, HISTORY, AND CHARACTERISTICS ................................. 3

1.5.1 LOCATION ......................................................... 3

1.5.2 POTENTIAL SOURCES ................................................. 4

1.5.3 HYDROGEOLOGIC SETTING ............................................. 4

1.5.4 DESCRIPTION OF GROUND WATER PLUME ................................. 5

2.0 SYSTEM DESCRIPTION .............................................................. 6

2.1 SYSTEM OVERVIEW ......................................................... 6

2.2 EXTRACTION SYSTEM ........................................................ 6

2.3 TREATMENT SYSTEM ........................................................ 6

2.4 MONITORING SYSTEM ....................................................... 6

3.0 SYSTEM OBJECTIVES, PERFORMANCE AND CLOSURE CRITERIA ........................ 7

3.1 CURRENT SYSTEM OBJECTIVES AND CLOSURE CRITERIA ............................. 7

3.2 TREATMENT PLANT OPERATION GOALS .......................................... 7

3.3 ACTION LEVELS ............................................................ 7

4.0 FINDINGS AND OBSERVATIONS FROM THE RSE SITE VISIT .............................. 8

4.1 FINDINGS ................................................................. 8

4.2 SUBSURFACE PERFORMANCE AND RESPONSE ...................................... 8

4.2.1 WATER LEVELS ..................................................... 8

4.2.2 CAPTURE ZONES ..................................................... 8

4.2.3 CONTAMINANT LEVELS ............................................... 8

4.3 COMPONENT PERFORMANCE .................................................. 9

4.3.1 WELL PUMPS AND TRANSDUCERS ........................................ 9

4.3.2 BLOWERS .......................................................... 9

4.3.3 VAPOR PHASE GRANULAR ACTIVATED CARBON ............................. 9

4.3.4 CONTROLS ......................................................... 9

4.3.5 TRAY AERATORS .................................................... 9

4.4 COMPONENTS OR PROCESSES THAT ACCOUNT FOR MAJORITY OF MONTHLY COSTS ........ 10

4.4.1 UTILITIES ......................................................... 10

4.4.2 NON-UTILITY CONSUMABLES AND DISPOSAL COSTS ......................... 10

4.4.3 LABOR ........................................................... 10

4.4.4 CHEMICAL ANALYSIS ................................................ 10

4.5 RECURRING PROBLEMS OR ISSUES ............................................. 10

4.6 REGULATORY COMPLIANCE .................................................. 10

4.7 TREATMENT PROCESS EXCURSIONS AND UPSETS, ACCIDENTAL CONTAMINANT/REAGENT

RELEASES ................................................................ 11
vi

4.8 SAFETY RECORD .......................................................... 11

5.0 EFFECTIVENESS OF THE SYSTEM TO PROTECT HUMAN HEALTH AND THE ENVIRONMENT . 12

5.1 GROUND WATER .......................................................... 12

5.2 SURFACE WATER .......................................................... 12

5.3 AIR .................................................................... 12

5.4 SOILS ................................................................... 12

5.5 WETLANDS AND SEDIMENTS ................................................. 13

6.0 RECOMMENDATIONS .............................................................. 14

6.1 RECOMMENDED STUDIES TO ENSURE EFFECTIVENESS .............................. 14

6.1.1 SURVEY AND EVALUATE WELL CONSTRUCTION FOR ALL SITE RELATED MONITOR AND

EXTRACTION WELLS ................................................. 14

6.1.2 CREATE A POTENTIOMETRIC SURFACE MAP FOR GROUNDWATER AND ESTIMATE FLOW

DIRECTIONS AND MAGNITUDES ........................................ 15

6.1.3 DELINEATE CONTAMINANT PLUME ...................................... 15

6.1.4 EVALUATE CAPTURE OF THE ONSITE TCE PLUME ........................... 16

6.1.5 ENSURE THAT ABANDONED WELLS ARE PROPERLY SEALED ................... 16

6.1.6 EVALUATE IMPACT OF GROUNDWATER AND TREATED WATER DISCHARGE TO

PENNYPACK CREEK ................................................. 16

6.1.7 SAMPLE AIR IN NEARBY BUILDINGS FOR TCE .............................. 17

6.2 RECOMMENDED CHANGES TO REDUCE COSTS .................................... 17

6.3 MODIFICATIONS INTENDED FOR TECHNICAL IMPROVEMENT .......................... 17

6.3.1 COMPLETE THE O&M MANUAL ........................................ 17

6.3.2 ORGANIZE/COMPILE DOCUMENTS AND DATA ASSOCIATED WITH SITE ........... 17

6.3.3 LABEL ALL WELLS AND RENAME WELLS TO AVOID CONFLICTS ................. 17

List of Tables

Table 3-1. Discharge criteria for Outfall 001

Table 3-2. Discharge criteria for Outfall 002

Table 3-3. Discharge criteria for air.

Table 7-1. Cost summary table

List of Figures

Figure 1-1 The area surrounding the Raymark Superfund Site including Hatboro wells H-14 and H-17

Figure 1-2 Site layout showing the locations of the monitoring and extraction wells

Figure 1-3 Cross section of geology underlying the Raymark Site
1

1.0 INTRODUCTION

1.1 PURPOSE

In the OSWER Directive No. 9200.0-33, Transmittal of Final FY00 - FY01 Superfund Reforms Strategy,

dated July 7,2000, the Office of Solid Waste and Emergency Response outlined a commitment to optimize

Fund-lead pump-and-treat systems. To fulfill this commitment, the US Environmental Protection Agency

(USEPA) Technology Innovation Office (TIO) and Office of Emergency and Remedial Response (OERR),

through a nationwide project, is assisting the ten EPA Regions in evaluating their Fund-lead operating

pump-and-treat systems. This nationwide project is a continuation of a demonstration project in which the

Fund-lead pump-and-treat systems in Regions 4 and 5 were screened and two sites from each of the two

Regions were evaluated. It is also part of a larger effort by TIO to provide USEPA Regions with various

means for optimization, including screening tools for identifying sites likely to benefit from optimization

and computer modeling optimization tools for pump and treat systems.

This nationwide project identifies all Fund-lead pump-and-treat systems in EPA Regions 1 through 3 and 6

through 10, collects and reports baseline cost and performance data, and evaluates up to two sites per

Region. The site evaluations are conducted by EPA-TIO contractors, GeoTrans, Inc. and the United States

Army Corps of Engineers (USACE), using a process called a Remediation System Evaluation (RSE),

which was developed by USACE. The RSE process is meant to evaluate performance and effectiveness (as

required under the NCP, i.e., and “five-year" review), identify cost savings through changes in operation

and technology, assure clear and realistic remediation goals and an exit strategy, and verify adequate

maintenance of Government owned equipment. 

The Raymark Superfund Site was chosen based on initial screening of the pump-and-treat systems

managed by USEPA Region 3 as well as discussions with the EPA Remedal Project Manager for the site

and the Superfund Reform Initiative Project Liaison for that Region. This site has a long projected

operating life and complicated hydrogeology. This report provides a brief background on the site and

current operations, a summary of the observations made during a site visit, and recommendations for

changes and additional studies. The cost impacts of the recommendations are also discussed.

A report on the overall results from the RSEs conducted for this system and other Fund-lead P&T systems

nationwide will also be prepared and will identify lessons learned and typical costs savings.

1.2 TEAM COMPOSITION

The team conducting the RSE consisted of the following individuals:

Frank Bales, Chemical Engineer, USACE, Kansas City District

Rob Greenwald, Hydrogeologist, GeoTrans, Inc.

Lindsey Lien, Environmental Engineer,USACE, HTRW CX

Doug Sutton, Water Resources Engineer, GeoTrans, Inc.
2

1.3 DOCUMENTS REVIEWED

Author Date Title/Description

US EPA 3/24/1988 Record of Decision, Raymark Site, Hatboro Borough,

Montgomery County, Pennsylvania, AR, Sept. 28,

1990

CH2M Hill, Inc. 9/1990 Draft Final Focused Feasibility Study for Ground

Water Remediation, Raymark Site

CH2M Hill, Inc. 7/1991 Raymark Site RI/FS Final Soil/Source Area Remedial

Investigation Report, Operable Unit No. 1

ERM-Enviroclean, Inc. 6/28/1993 Request for Determination of Requirement for Plan

Approval/Operating Permit Application for

Groundwater Treatment/Soil Vapor Extraction

CH2M Hill, Inc. 9/14/1993 Remedial Action Report, Raymark Superfund Site,

Hatboro, Pennsylvania, Operable Unit 2.

CH2M Hill, Inc. 9/30/1994 Raymark Remedial Action, Operable Units 1 and 3

US EPA 9/12/1995 Superfund Preliminary Site Close Out Report, Raymark

Superfund Site, Hatboro, Pennsylvania

US EPA 4/16/1996 Amended Work Plan for Hatboro Well H16 and the

Raymark Site

Philadelphia Suburban 1997 - 2000 Hatboro Well Monitoring Report, 1997, 1st & 2nd

Quarter 1998, 3rd Quarter 1998, 2nd Quarter 1999, 3rd

Quarter 1999, 4th Quarter 1999, 1st Quarter 2000, 2nd

Quarter 2000, 3rd Quarter 2000

Gilmore & Associates, Inc. 2/5/1997

-

7/17/2000

Raymark Site Groundwater Treatment System

Quarterly Progress Report for November-December

1996, January-March 1997, April-June 1997, JulySeptember 1997, January-March 1998, April-June

1998, July-September 1998, October-December 1998,

January-March 1999, April-June 1999, July-September

1999, October-December 1999, January-March 2000,

April-June 2000

Gilmore & Associates, Inc. 2/18/1999 Communication: TCE concentrations in Wells H14 and

H17 from 1983 through September 1996

CDM Federal Programs

Corporation

5/21/1999 Groundwater Data Trend Analysis Report for Raymark

Site, Hatboro, Montgomery County, Pennsylvania
3

Author Date Title/Description

CDM Federal Programs

Corporation

6/8/1999 Well Survey Letter Report, Raymark Superfund Site,

Hatboro, PA

CDM Federal Programs

Corporation

10/10/2000 Sampling Summary Report for Raymark Superfund

Site, Hatboro, Pennsylvania

CDM Federal Programs

Corporation

12/22/2000 Quarterly Cleanup Status Report, Raymark Site -

Operation and Maintenance, November-December

1999, July-October 2000,

1.4 PERSONS CONTACTED

The following individuals were present for the site visit:

Frank Bales (USACE) 816-983-3591 francis.e.bales@usace.army.mil 

Kathy Davies (USEPA Reg. 3) 215-814-3315 davies.kathy@epa.gov 

Rob Greenwald (GeoTrans) 732-409-0344 rgreenwald@geotransinc.com 

Andy Hopton (CDM Federal) 610-293-0450 hoptonap@cdm.com

Lindsey Lien (USACE) 402-697-2580 lindsey.k.lien@usace.army.mil 

David Minsker (PAPED) 610-832-6193 minsker.david@dep.state.pa.us

Deanna Moultrie (USEPA Reg. 3) 215-814-5125 moultrie.deanna@epa.gov

Jerry O’Hara, Plant Operator, 215-343-2538 johara@buckswater-sewer.org

Jim Romig (CDM Federal) 610-293-0450 romigjm@cdm.com 

Bruce Rundell (USEPA Reg. 3) 215-814-3317 rundell.bruce@epa.gov 

Doug Sutton (GeoTrans) 732-409-0344 dsutton@geotransinc.com

Yan Zhang (GeoTrans) 732-409-0344 yzhang@geotransinc.com

Bob Smauck (Gilmore Engineering, 215-345-4330) was contacted by phone after the RSE visit.

1.5 SITE LOCATION, HISTORY, AND CHARACTERISTICS

1.5.1 LOCATION

The Raymark Superfund Site, located on Jacksonville Road in Hatboro, Montgomery County,

Pennsylvania, occupies 7 acres. Between 1947 and 1954 the Penn Rivet and Machine Company owned

and operated a plant for manufacturing rivets. Various businesses have occupied the area since 1954, and

the site is currently owned and operated by Penn Fasteners, Inc., manufacturers of rivets and other

fasteners. Remedies at the site now address contamination from trichloroethylene (TCE) and other solvents

resulting from waste disposal associated with degreasing and electroplating activities. The area

surrounding the Raymark Site is shown in Figure 1-1 and the site layout is shown in Figure 1-2. 

TCE contamination of the groundwater in the Stockton formation, which supplies Hatboro with drinking

water, was first discovered in 1979, and investigations of groundwater contamination began in 1981. In

1985 the EPA and the Borough of Hatboro filed suit against the owners and operators (former and current

as of 1985) associated with the Raymark Site. A resulting Consent Decree was issued in 1989. The site
4

was divided into three operable units— OU1 to address soil contamination, OU2 to address the drinking

water supply, and OU3 to address groundwater contamination. 

The 1990 Record of Decision (ROD) specified both onsite and offsite extraction and treatment of

groundwater. Onsite extraction and treatment would require the installation of an extraction system and a

treatment system that includes treatment of the water by air stripping and treatment of the offgas with

vapor phase carbon. Offsite extraction would be achieved by pumping from local water supply wells H-14,

H-16, and H-17. Treatment of water extracted from these wells would be accomplished via air stripping

with vapor phase carbon used to treat the offgas. Wells H-14 and H-17 were outfitted with air strippers in

1984 and 1986 as part of a settlement with the Fischer and Porter Company located to the northwest of the

Raymark Site. As part of the Raymark remedy H-16 was to be outfitted with an air stripper and the offgas

from treatment at all three wells would be addressed with vapor phase carbon. Currently, only wells H-14

and H-17 are operating.

A separate ROD required a soil vapor extraction (SVE) system and two caps to address soil contamination. 

The SVE system began operation in March 1994 and was shut off in October 1995 when soil cleanup

levels were reportedly met. A multilayer low permeability cap covers a soil pile over the former lagoon

area. The soil pile, resulting from spoils from drilling and excavations for site piping, and cap rise to a

height of approximately 10 to 15 feet over the rest of the site. An asphalt cap, which currently serves as a

parking lot, covers the remainder of the site not occupied by building.

1.5.2 POTENTIAL SOURCES

From 1948 to 1972 wastes, including TCE, from degreasing and electroplating activities were discharged

into four onsite, unlined lagoons. Other potential sources of contamination included possible leaks from

aboveground storage tanks and possible discharges through building drains. Sludge from the lagoons was

removed in 1972 and the lagoons were backfilled with clean soil. Soil contamination was addressed by the

SVE system in from March 1994 to October 1995 and the multilayer and asphalt caps.

TCE concentrations in groundwater during the initial investigations were as high as 47,000 parts per billion

(ug/L). Samples of the surface soils during the Remedial Investigation yielded only 18 ug/kg of TCE,

however, subsurface soil samples taken near the former lagoons yielded concentrations of TCE as high as

7,000 ug/kg. Soil gas concentrations for TCE were highest in the soils underlying former storage-tank

area. Freephase solvents were not discovered during the Remedial Investigation, but discussions during the

RSE visit indicated anecdotes of freephase being discovered during the installation of a well in 1992 by the

USGS.

It is important to note that other industrial sources of groundwater contamination exist in the area and may

have contributed to the regional groundwater plume including the Fisher and Porter Company located to the

northwest of the Raymark site that financed the installation of the air strippers on wells H-14 and H-17. 

1.5.3 HYDROGEOLOGIC SETTING

Soil thickness at the site varies from 4 to 10 feet and consists of fine sands and silts. Beneath this soil lies

bedrock from the Stockton formation consisting of various layers of sandstone and siltstone which are

depicted in Figure 1-3. According to the Remedial Investigation, the bedding of these units shows no

particular pattern or order. The 1990 Feasibility Study considers the following four stratigraphic zones

based on the logs of well PF-1 and a packer test conducted in that well. 
5

• Zone 1 above 75 feet below ground surface (bgs) is poorly transmissive and yields 0.1 gpm per

foot of drawdown.

• Zone 2 extends from 75 to 95 feet bgs and is also poorly transmissive, yielding 0.36 gpm per foot

of drawdown.

• Zone 3 extends from 95 to 125 feet, and was described, as a result of the packer test (USGS report

dated July 20, 1989), as a zone that does not contribute water to the well.

• Zone 4 extends below 125 feet, is highly transmissive, and yields 5.4 gpm per foot of drawdown.

The site hydrogeology is otherwise not well documented or understood based on the documents reviewed by

the RSE team. Groundwater depths have been recorded as part of the site activities, but with the absence of

elevations for the tops of the well casings, these depths could not be converted to water elevations. Thus,

no potentiometric surface of groundwater at the site is available. In general, water elevations are estimated

to vary from 205 to 225 feet above mean sea level (MSL) with the highest levels occurring in the winter

and early spring. Given a site elevation of 265 feet MSL, this translates to water depths of 40 to 60 feet

below ground surface, depending on the season. 

Pennypack Creek passes within a mile of the site to the west and southwest. While regional groundwater

flow is expected to flow in this direction, the large number operating wells in the area could significantly

affect the speed and direction of groundwater. Actual groundwater flow directions are not known. The

average yield for a well in the area is approximately 130 gpm. 

1.5.4 DESCRIPTION OF GROUND WATER PLUME

The Feasibility Study conducted in 1990 depicts the TCE groundwater contamination as extending nearly a

mile west of the site toward Pennypack Creek as well as 2,000 or more feet to the north of the site. 

Sampling conducted in April and May 2000 show TCE concentrations onsite as high as 2,300 ppb. In

addition, offsite wells have TCE concentrations as high as 1,000 ppb and Hatboro well H-14, over a half

mile to the west of the site, has a TCE concentration of approximately 150 ppb. Likely due to the complex

nature of the fractured bedrock subsurface, concentrations vary significantly with location. For example,

offsite wells R-3 and R-4 are 400 feet apart horizontally and 10 feet apart vertically, but R-3 (located

closer to the site than R-4) has a TCE concentration of 7 ppb while R-4 has a concentration of 680 ppb. 

The TCE concentration data from the 21 monitoring wells sampled in April and May 2000 and from the

two public wells (H-14 and H-17) that are sampled quarterly are insufficient to completely delineate the

plume and insufficient information is available to determine the directions in which the plume may be

spreading. 
6

2.0 SYSTEM DESCRIPTION

2.1 SYSTEM OVERVIEW

The current onsite system began extracting and treating groundwater in November 1996. Extracted

groundwater is pumped directly from two extraction wells into two tray aerators located in the treatment

building and is then discharged via below grade piping and a storm sewer to a creek approximately one half

mile southwest of the plant. The exhaust from the tray aerators is vented through a single GAC unit.

Two of the Hatboro water supply wells, H-14 and H-17, have continued to operate both as a groundwater

remedy (independent of the Raymark site) and for water supply, especially during peak usage. H-14 is

located approximately 3,500 feet to the west of the site and H-17 is located approximately 2,000 feet to the

northwest of the site. Air strippers are used to treat the water and the Raymark remedy funds the

replacement of vapor phase carbon used to treat the off gas.

2.2 EXTRACTION SYSTEM

The extraction system is comprised of two wells (RW-1R and MW-3D). RW-1R was reconstructed in

1999 to replace RW-1 that collapsed. The pump size is 2 horsepower (hp) and pumps at a constant rate of

37 gallons per minute (gpm). The extraction well MW-3D uses a 1 hp pump to extract water on 90-second

cycles at a rate of approximately 23 gpm. During the RSE, this pumping rate and cycling corresponded to

maintaining water levels between set points of 41 and 60 feet below ground surface. Given these extraction

rates, on average the extraction systems pumps approximately 48 gpm. 

2.3 TREATMENT SYSTEM

The treatment system includes two tray aerators in series with air supplied by up to five blowers. In an

effort to reduce energy consumption, the use of four blowers (one spare) was cut to two blowers in

November 1998. While this increased the plant effluent concentrations from less than 5 ppb to 30 or 40

ppb, these concentrations are still below the discharge concentration of 73 ppb. A blower is used to feed

the off gas from the air strippers to a single vapor phase carbon unit. The treated water is discharged

through a storm drain to Pennypack Creek approximately a half mile from the site.

2.4 MONITORING SYSTEM

The monitoring system consists of 23 sampling points, including 12 offsite wells and 11 onsite wells. The

offsite wells include five of the Hatboro wells (H-2, H-7, H-10, H-14, and H-17). While concentrations

had been measured regularly from H-14, H-17, and the two onsite extraction wells, samples from the other

wells had not been taken in approximately 8 years until the April and May 2000 sampling which was the

first event of a new annual sampling program. Another event is planned for June or July of 2001.

Water levels were also measured during the April and May 2000 sampling event; however, because the

elevations for the tops of the well casings are unknown, a water level map cannot be constructed. 
7

3.0 SYSTEM OBJECTIVES, PERFORMANCE AND CLOSURE 

CRITERIA

3.1 CURRENT SYSTEM OBJECTIVES AND CLOSURE CRITERIA

The ROD specifies the following site-specific remedial objectives for OU2 and OU3:

• Protect public health and the environment

• Reduce further migration of contaminated groundwater from the site towards public supply wells

• Contain the contamination within the currently affected area

• Reduce the risk resulting from release of contaminants into the air from treatment devices

• Contribute to the restoration of the aquifer to its beneficial use, and further to background quality,

if practicable

3.2 TREATMENT PLANT OPERATION GOALS

As specified in the consent decree, the discharge criteria for the treatment plant is 73 ug/L (ppb) of TCE

and 7.3 ug/L (ppb) of carbon tetrachloride. Given plant influent concentrations of TCE, this requires

approximately 93% removal efficiency of the plant. Historically, the treatment plant has operated well

below this 73 ug/L discharge limit. With four of five blowers operating for the air strippers, effluent

concentrations are typically less than 5 ug/L, and with two of five blowers operating, effluent

concentrations are typically around 30 ug/L. The system currently operates with two blowers. The

remaining TCE in the effluent is likely transferred to the atmosphere as the effluent travels from the site to

Pennypack Creek through the storm drain. 

3.3 ACTION LEVELS

Concurrent with remedial objective #5, the ROD specifies a cleanup level of 5 ug/L or background if

practicable. However, the main objectives of the site pertain to containment of onsite groundwater

contamination. 
8

4.0 FINDINGS AND OBSERVATIONS FROM THE RSE SITE VISIT

4.1 FINDINGS

In general, the RSE team found the treatment system well operated and well maintained. However,

possibly due to the high turnover rate among EPA Remedial Project Managers for this site and changes in

contractors, site information and background, especially related to system design, is difficult to access.

4.2 SUBSURFACE PERFORMANCE AND RESPONSE

4.2.1 WATER LEVELS

Although water depths have been recorded as recently as April and May 2000, unknown elevations for the

tops of the well casings prevent this information from being used to generate a potentiometic surface of

groundwater beneath the site. Thus, the hydraulic gradients and groundwater flow remain unknown.

Given the location of Pennypack Creek and several pumping wells to the west as well as the extent of the

plume to the west, it is likely that groundwater in the area of the Raymark site flows to the west. 

4.2.2 CAPTURE ZONES

Due to a lack of reliable water-level measurements and only one recent sampling of groundwater

concentrations the capture zones associated with the two onsite extraction wells cannot be determined. 

A preliminary capture zone analysis, however, was conducted as part of the 1990 Feasibility Study. This

analysis and the subsequent remedy alternatives described in that report suggested onsite pumping of 285

gpm— five wells in Zone 4 (i.e., below 125 feet bgs) would each extract 50 gpm and seven wells in Zone 1

(i.e., above 75 feet bgs) would each extract 5 gpm. These recommended wells in Zone 1 and Zone 4 were

to be aligned along the downgradient boundary of the site. The designed treatment capacity of the

treatment plant of 100 gpm as stated in the 1994 Construction Report and the current extraction rate of

approximately 48 gpm from two wells differs significantly from this original analysis. As many of the

design documents were inaccessible to the site managers and the RSE team, justifications for this decrease

in the extraction could not be found.

4.2.3 CONTAMINANT LEVELS

Contaminant levels at the site vary with location and depth. In the April and May 2000, TCE

concentrations above 1,000 ppb were measured in onsite wells PF-1s, MW-2I, and MW-3I, which have

depths of 69, 146, and 142 feet below ground surface (bgs), respectively. Both MW-2I and MW-3I are

located on the western portion of the property where other groundwater samples suggest contamination as

deep as 205 feet bgs and as shallow as 56 feet bgs. PF-1s is located on the eastern portion of the site where

the former lagoons were located and where the SVE system operated. This location is now occupied by the

multilayer low permeability cap covering the pile of excavated soil. The other high TCE concentration
9

recorded on the eastern portion of the site is in MW-1S, which screens the shallow subsurface in the area of

the former lagoons. 

4.3 COMPONENT PERFORMANCE

4.3.1 WELL PUMPS AND TRANSDUCERS

Well RW-1R replaced the original RW-1 well which had collapsed around the pump. This replacement well

is completed to a depth of 200 feet bgs with the transducer placed at 190 bgs. The screened interval currently

is unknown. The pump is 2 hp and pumps continuously at 37 gpm. The well and pump have functioned

without incident since installation in 1999. 

Extraction well MW-3D (which differs from monitoring well MW-3D) is completed to a depth of 145 bgs with

the transducer at 135 bgs. The screened interval is not currently know. The pump is 1 hp and cycles on 90-

second intervals at a rate of 23 gpm. 

The average total pumping rate over time from both wells is approximately 48 gpm.

4.3.2 BLOWERS

There are five blowers capable of providing compressed air to the two tray aerators. The fifth blower has

historically been used as a reserve unit and is generally not operated. In November 1998, the number of

utilized blowers was decreased from four to two in order to save electricity. This practice still continues and

results in TCE effluent concentrations of approximately 30 ppb, which is well below the discharge criteria of

73 ppb. A separate blower is used to move the exhaust from the tray aerator through the vapor phase GAC

unit.

4.3.3 VAPOR PHASE GRANULAR ACTIVATED CARBON

A single vapor phase GAC unit is located outside of the treatment building. The unit contains approximately

1,000 pounds of GAC. The air is heated to lower than 40% relative humidity prior to entering the GAC to

minimize moisture within the unit. The current operation includes monitoring the exhaust with a PID. If the

PID registers a reading of greater than 2 ppm, the GAC is replaced. The site operators estimate that the GAC

is replaced three times per year.

4.3.4 CONTROLS

The plant operates remotely. The control system includes an autodialer to warn the plant engineer when the

system has shutdown. The operator can reach the site within 45 minutes.

4.3.5 TRAY AERATORS

Two dual tray (i.e., trays on both the top and bottom) aerators manufactured by Lowry Engineering, Inc. of

Durham, North Carolina are operated in series and utilize perforated piping to transfer VOCs to the air exhaust

stream. The perforated piping with 1/16-inch diameter perforations was clogging; therefore, the piping was

replaced with 1/8-inch diameter perforations. Even though this decreases the surface/transfer area of the air

that enters the aerators, the plant has continued to meet effluent requirements and the efficiency has increased

due to increased air flow. The second aerator must maintain a lid pressure of 5-6 inches of water to achieve
10

treatment goals. Because of delicate balance between the aerator and the 5 hp vacuum blower that feeds the

vapor GAC unit, the system requires seasonal adjustments by the operator. 

The two aerators, with four blowers operating, are designed to handle 100 gpm with a water temperature of

50 degrees Fahrenheit and TCE concentrations of 3,250 ppb. 

4.4 COMPONENTS OR PROCESSES THAT ACCOUNT FOR MAJORITY OF

MONTHLY COSTS

Annual costs of the system, excluding those associated with analytical work, are likely less than $100,000 but

will increase in the future with additional monitoring and characterization.

4.4.1 UTILITIES 

The groundwater treatment building has a phone and electricity but no natural gas. With two of the five

blowers feeding air to the tray aerators, the electric bill is approximately $800 per month or $10,000 per year.

4.4.2 NON-UTILITY CONSUMABLES AND DISPOSAL COSTS

Costs for non-utility consumables and disposal associated with the site include materials necessary for sampling

and replacement of the onsite vapor phase carbon each year. These costs are approximately $5,000 per year.

The costs for replacement of the vapor phase carbon units on wells H-14 and H-17 are not included in this

estimate.

4.4.3 LABOR 

Labor involves the annual sampling event, project management, and weekly visits to the site by the plant

operator. Labor costs are under $50,000 per year. 

4.4.4 CHEMICAL ANALYSIS

Analyses are performed under the CLP program, and those costs are not directly assigned to the site.

4.5 RECURRING PROBLEMS OR ISSUES

The operations of the plant have not reported major upsets in plant operations other than occasional weather

related power outages. 

4.6 REGULATORY COMPLIANCE

The plant has not exceeded the effluent TCE concentration standards of 73 ppb.
11

4.7 TREATMENT PROCESS EXCURSIONS AND UPSETS, ACCIDENTAL

CONTAMINANT/REAGENT RELEASES

The system has been operated with no major upsets or releases.

4.8 SAFETY RECORD

No accidents have been reported.
12

5.0 EFFECTIVENESS OF THE SYSTEM TO PROTECT HUMAN

HEALTH AND THE ENVIRONMENT

5.1 GROUND WATER

Groundwater in the region surrounding the Raymark site has historically been used for the public water supply.

Figure 1-6 of the 1990 Feasibility Study indicates that nine public wells are within the area or on the border

of the estimated TCE plume (H-1, H-2, H-3, H-9, H-12, H-14, H-15, H-16, and H-17). Operation of all of

these wells except H-14 and H-17 has been discontinued. Air stripping towers and vapor phase carbon units

have been installed on H-14 and H-17 and treat the water that is used for the public. 

A lack of monitoring since the Remedial Investigation and the absence of reliable water-level measurements

make delineating the plume (horizontally and vertically) and forecasting its transport impossible. Thus, TCE

contamination of the groundwater in this area likely continues to pose a hazard for the public water supply if

it is not properly treated. In addition, the RSE team and site managers cannot assess whether the primary

objectives of the ROD are being satisfied.

5.2 SURFACE WATER

Pennypack Creek to the west and southwest of the site represents the only surface water potentially impacted

by the groundwater contamination and the treatment operations. Based on the estimated plume provided in

the 1990 Feasibility Study it appears the contamination has reached the creek. In addition, the effluent from

the onsite treatment plant, which may reach concentrations as high as 73 ppb, is discharged to the creek. The

creek is used for fishing and therefore represents a potential exposure pathway to the public. The RSE team

is unaware of any recent sampling of the creek water.

5.3 AIR

Off gas from the onsite tray aerators (and Hatboro water supply wells H-14 and H-17) is treated with vapor

phase carbon. Thus, TCE emissions from these treatment operations are negligible. The majority of the

contamination associated with the western portion of the Raymark site occurs at a depth of approximately 100

feet; therefore, elevated TCE concentrations in the soil gas in this part of the site are likely low. However,

relatively high TCE concentrations in groundwater (in excess of 1,000 ppb) have been found in shallow

monitoring wells on the eastern portion of the site. This could lead to elevated soil gas concentrations in this

portion of the site and possibly in some of the onsite or nearby buildings.

5.4 SOILS

The contaminated soils have been excavated, piled on site, capped with a synthetic liner, and treated with an

SVE system. Operation of the SVE system was discontinued in October 1995 after cleanup levels were

reportedly met. The RSE team did not see any data from the operation of the SVE system or any subsequent
13

data regarding soil contamination. The site has been covered with an asphalt cap that now serves as a parking

lot; thus, if contaminated soils did remain, access to them would be limited.

5.5 WETLANDS AND SEDIMENTS

The RSE team is not aware of any recent sampling of the Pennypack Creek sediments. As with the creek itself,

these sediments could potentially be impacted either by discharge of contaminated groundwater or treated water

(with TCE concentrations allowed up to 73 ppb) to the creek. 
14

6.0 RECOMMENDATIONS

Cost estimates provided have levels of certainty comparable to those done for CERCLA Feasibility Studies

(-30/+50%), and these cost estimates have been prepared in a manner consistent with EPA 540-R-00-002, A

Guide to Developing and Documenting Cost Estimates During the Feasibility Study, July 2000. 

6.1 RECOMMENDED STUDIES TO ENSURE EFFECTIVENESS

6.1.1 SURVEY AND EVALUATEWELL CONSTRUCTION FOR ALL SITE RELATED MONITOR AND

EXTRACTION WELLS

Well construction logs and pertinent information from those logs is not readily available to EPA site managers,

site contractors, or the RSE team. Therefore, information such as the screened intervals and elevations of the

tops of the well casings for the monitoring and extraction wells are not known. Without the screened intervals

of the extraction wells it cannot easily be determined from which portions of the aquifer water is being

extracted. Also, although the depths of monitoring wells indicate the approximate depth being sampled, without

knowledge of the screened interval, it cannot be determined if water is coming from a vertical interval of 10

feet, 20 feet, or more. Thus, it is not known if a given monitoring well is sampling from a single stratigraphic

unit or from two separate units. Without the elevations for the tops of the well casings, water levels cannot

be determined, and without these water levels, a potentiometric surface cannot be generated to indicate

directions and magnitudes of groundwater flow. With unknown screened intervals for the extraction and

monitoring wells and without a potentiometric surface the extent of contaminant containment or capture cannot

be evaluated. Thus, it cannot be determined if the current remedy is consistent with the ROD in containing

contamination and reducing migration of TCE offsite.

The RSE team recommends a thorough investigation of the well construction data. This would involve tracking

down and evaluating the well construction logs. However, it is strongly advised that the site managers also hire

a survey crew to accurately determine the elevations of the well-casing tops. Downhole camera work should

also be conducted to determine the condition of each of the wells, but more importantly to determine the

screened intervals of each well. 

Accurate, up-to-date information may be available for some of the Hatboro water supply wells within a mile

of the Raymark Site. If the screened intervals of the wells are known and a known reference elevation is

available for accurate water-level measurements, then surveying and downhole camera work is not needed for

these wells. 

It appears that 21 wells (including Hatboro wells H-2, H-7, H-10, H-14, and H-17) are available for sampling

and measuring water levels. Excluding the Hatboro wells, there are 16 wells. Adding the two extraction wells,

the surveying and downhole camera work would need to be done for 18 (excluding the Hatboro wells) to 23

wells. The studies could likely be conducted for approximately $10,000. 
15

6.1.2 CREATE APOTENTIOMETRIC SURFACE MAP FORGROUNDWATER ANDESTIMATEFLOW

DIRECTIONS AND MAGNITUDES

Once the screened intervals and tops of casings are known for each of the 23 wells (including H-14 and H-17),

water levels should be measured and used to generate potentiometrics surfaces for groundwater underlying the

Raymark site for a variety of pumping conditions including the following scenarios:

• no pumping;

• pumping from the onsite extraction wells at the current average extraction rate of 48 gpm but no

pumping from Hatboro wells H-14 and H-17; and

• pumping from the onsite extraction wells at 48 gpm and from Hatboro wells H-14 and H-17. 

The potentiometric surfaces generated for the pumping scenarios should not include the water level

measurements from the extraction wells as this will bias any analysis in favor of capture. The potentiometric

surfaces should have sufficient resolution to determine the likely portions of the site boundary from which

contaminants are most likely to migrate offsite and in which stratigraphic units this migration would likely

occur. Given the limited number of points for measuring water levels and the vertical variation in the Stockton

formation, additional piezometers placed at various locations and depths, are likely required to yield informative

potentiometric surfaces. The specific locations of these additional piezometers may be better determined once

water levels are measured and analyzed from the current measurement points. 

Water levels are currently measured as part of the new annual sampling program; thus, the actual

measurements will not add to the annual costs. The analysis of the potentiometric surfaces generated from the

water levels (plus from previous depth-to-water measurements) would require an initial cost of approximately

$15,000 for initial work (such as developing a CADD site map and creating historical potentiometric surface

maps), and approximately $2,000 per year in the future for developing the potentiometric surfaces. Installation

of an additional shallow piezometer (less than 100 feet deep) would require approximately two days of drilling

and would cost approximately $7,000. Installation of an additional deep piezometer (approximately 200 feet

deep) would cost approximately $11,000. The addition of eight piezometers screening various depths would

therefore require a one time expenditure of approximately $72,000. 

6.1.3 DELINEATE CONTAMINANT PLUME

The extent of groundwater TCE contamination onsite should be further investigated as well, especially along

the site boundaries. A cluster of sampling points each independently screening the stratigraphic units shown

in Figure 1-3 and located midway between the MW-3 and MW-2 clusters would help delineate the plume on

the western boundary of the site. This is significant given that groundwater likely flows to the west toward

Pennypack Creek and Hatboro wells H-14 and H-17. Another cluster of sampling points each screening the

stratigraphic units shown in Figure 1-3 and located midway between the MW-3 cluster and the rear end of the

property (to the east) would help delineate the plume on the southern/western site boundary. This is also

significant because Pennypack Creek turns and passes within a mile to the southwest of the site and

groundwater could be flowing in that direction. These points should be added to the annual sampling program

and analyzed for volatile organic compounds (VOCs).

The locations of some of the piezometers installed to generate potentiometric surfaces may coincide with the

locations of these recommended sampling points. In such cases, monitoring wells should be installed in place

of the recommended piezometers. The cost of monitoring well would exceed the cost of a piezometer by up
16

to $500 due to a difference in the cost of materials. Sampling and analysis at an independent laboratory of the

new wells, assuming one sampling event per year, might cost $4,000 per year.

6.1.4 EVALUATE CAPTURE OF THE ONSITE TCE PLUME

Once the groundwater flow and plume extent onsite is better understood, the capture zones of the onsite

extraction wells should be evaluated. This is especially pertinent given the discrepancy between the extraction

rate of 285 gpm suggested in the 1990 Feasibility Study, which was based on a preliminary capture zone

analysis, and the current average extraction rate of 48 gpm. The first step is to examine the onsite contaminant

plume and determine a target capture zone (i.e., a theoretical capture zone that prevents the offsite migration

of contamination). The second step is to compare the target capture zone with the actual one as determined

by the potentiometric surface interpreted from water levels measured during onsite pumping. Also, site

managers should overlay the plume map interpreted from groundwater sampling with the potentiometric surface

interpreted from water levels measured during onsite pumping. If the potentiometric surface has sufficient

resolution, this will give a general idea as to the portions of the contamination that are and are not captured by

these extraction wells. It may be evident from this evaluation that capture of onsite contamination requires

increased pumping from the existing wells, or possibly additional wells as suggested in the Feasibility Study.

For capture to be achieved, hydraulic gradients measured from water levels taken from surrounding

piezometers and monitoring wells (and not the extraction wells) must indicate groundwater flow in the direction

of the extraction well. Due to regional/background groundwater flow, capture is not necessarily achieved when

a well or piezometer indicates drawdown from nearby pumping. 

Given the complexity of the fractured bedrock and the stratigraphy underlying the site, it may be impracticable

to develop a potentiometric surface map that indicates capture with adequate confidence. Thus, downgradient,

offsite wells will require continued monitoring to ensure that concentrations downgradient of the site are

decreasing. If these concentrations do not decrease over time, then it is likely that contamination is migrating

offsite and contributing to contamination in these offsite wells.

The capture zones should be evaluated at least once per year by analyzing the potentiometric surface and the

trends in TCE concentration in the downgradient sentinel wells. The extraction rates, and possibly the addition

of new extraction wells, should be adjusted accordingly to prevent migration of contaminants offsite. The

analysis of the capture zones in the various stratigraphic units and a written summary of the results should

result in a cost increase of approximately $4,000 per year.

6.1.5 ENSURE THAT ABANDONED WELLS ARE PROPERLY SEALED

A number of wells near the Raymark site, including the former extraction well (RW-1) that collapsed, are no

longer used for pumping. If these wells have not properly been sealed then they may offer avenues of cross

contamination between stratigraphic units. Therefore, the RSE team recommends sealing unused wells that

have screened intervals intersecting multiple stratigraphic units. This may be problematic for some of the

former water supply wells if the Hatboro Water Authority plans on reusing them. Assuming five wells require

sealing, this would be a one time cost of approximately $15,000.

6.1.6 EVALUATE IMPACT OF GROUNDWATER AND TREATED WATER DISCHARGE TO

PENNYPACK CREEK

The RSE team is unaware of any water quality sampling of Pennypack Creek, especially where the plant

effluent is discharged and near H-9 where the plume may be discharging to the creek. Sampling of the stream
17

water and sediments in these two location would indicate the extent of TCE contamination, if any. Such

samples could be collected and analyzed annually. Collecting and analyzing these samples as part of the new

annual sampling program should cost an additional $1,000 per year.

6.1.7 SAMPLE AIR IN NEARBY BUILDINGS FOR TCE

Due to the relatively high concentrations of TCE in the groundwater, especially at the shallower depths near

the MW-1 and PF-1 clusters, the air in onsite and nearby buildings, especially the residence to the north, should

be sampled for TCE. This should be done quarterly for one year and annually thereafter. Total cost in the first

year would likely be $5,000. If the air sampling is conducted in the future as part of the annual sampling

program the additional cost would be approximately $1,000 per year. 

6.2 RECOMMENDED CHANGES TO REDUCE COSTS

The onsite extraction and treatment system currently operate at cost of less than $100,000 per year (excluding

analytical work), and the extracted water has concentrations similar to those assumed in the design. Therefore,

the RSE does not have any recommendations that would result in significant cost reductions.

6.3 MODIFICATIONS INTENDED FOR TECHNICAL IMPROVEMENT

6.3.1 COMPLETE THE O&M MANUAL

The operator that currently visits the site weekly is the only person familiar with plant operations. He works

from experience and not from a manual. The practices necessary for operating the plant smoothly should be

documented for potential future operators. Discussions during the RSE indicated that this manual is currently

being prepared. A one-time cost of $10,000 is possible for this item.

6.3.2 ORGANIZE/COMPILE DOCUMENTS AND DATA ASSOCIATED WITH SITE

Due to the high turnover rate of the EPA Remedial Project Managers for this site and shift away from the

contractor that designed and originally operated the plant, much of the original design and operation

information is not readily available. This unavailable information includes but is not limited to the screened

intervals of the wells, the elevations of the tops of the well casings, monitoring data from the SVE operation,

design reports, and the as-built drawings. In addition, the site Remedial Investigation, Feasibility Study, and

monitoring results were obtained from the site contractor and may not be easily accessible in the EPA offices.

All of these documents should be readily available to the site manager. The Union Library Company of

Hatboro located at 243 South York Road in Hatboro, is designated as a location for public files associated with

this site. The site managers should visit this location to identify and copy any site-related documents not

currently available in the EPA offices. A one-time cost of $5,000 is possible for these activities.

6.3.3 LABEL ALL WELLS AND RENAME WELLS TO AVOID CONFLICTS

The site-related wells should be named with a consistent nomenclature. At the time of the RSE, the names of

various wells included MS-1, MW-1S, R-1, RW-1, USGS, MW-3D (monitoring), and MW-3D (extraction).

For example, all monitoring wells associated with the site should have the prefix MW and all extraction or

recovery wells should have the prefix RW. Each well could then be given a number and a suffix of S, I, or D

indicating shallow, intermediate, or deep, respectively. A table should be constructed and included in all future
18

site documents listing the current names of wells and the recommended names so that wells can easily be

tracked. This table should also include pertinent well construction data including the depths, screened intervals,

and the elevations for the tops of the well casings.

In addition, the wells are not labeled making it difficult to identify each well without a site map. To avoid

confusion and possible errors during sampling and measuring water levels, all of the wells should be clearly

labeled. Over time, cost of these items is estimated at approximately $10,000.

6.4 MODIFICATIONS INTENDED TO GAIN SITE CLOSE-OUT

The RSE team has no recommendations for gaining site close out; rather, the RSE team suggests that the

additional characterization steps outlined in Section 6.1 are of primary importance. However, this

characterization is the first step of a detailed exit strategy that should be developed to ensure that the site does

not operate after ROD goals have been achieved. Of particular importance is to develop the exit strategy based

on the ROD objectives and not on the TCE concentrations found offsite that may have come from other

sources within the region. With regard to onsite contamination, if annual sampling events do not indicate

declines in TCE concentrations, investigations should be conducted to determine if any existing sources exist

either onsite or upgradient. Alternative remedial strategies should be periodically reviewed for potential

application at this site.
19

7.0 SUMMARY

In general, the RSE team found a smoothly running treatment system, but a site that was poorly characterized,

possibly due to a high turnover rate of EPA Remedial Project Managers for the site. The observations and

recommendations mentioned are not intended to imply a deficiency in the work of either the designers or

operators but are offered as constructive suggestions in the best interest of the EPA and the public. These

recommendations have the obvious benefit of the operational data unavailable to the original designers.

Several recommendations are made to assure system effectiveness and improve the technical operation of the

system. However, recommendations were not made that are pertinent to cost reduction or gaining site close

out. The recommendations to improve effectiveness include surveys and downhole camera work of existing

wells to determine the elevations of the tops of the well casings and the screened intervals. Once this

information is gained, the RSE team recommends collecting 1) water levels and using them to generate

potentiometric surfaces of the groundwater and 2) groundwater quality samples and using them to better

delineate the onsite plume. Subsequent to these studies, a capture zone analysis should be conducted and

groundwater extraction should be adjusted accordingly. With regard to technical improvement, the RSE team

agrees with the current effort to develop an operations and maintenance plan and recommends that the site

managers compile and organize site related data and documents.

Recommendations, and estimated cost increases/decreases associated with those recommendations, are

presented in Table 7-1.
20

Table 7-1. Cost Summary Table

Recommendation Reason

Estimated Change in

Capital

Costs 

Annual

Costs

 Lifecycle

Costs*

 Lifecycle

Costs**

6.1.1 Survey site-related

wells 

Effectiveness $10,000 $0 $10,000 $10,000

6.1.2 Measure water levels

and develop potentiometric

surfaces (costs include the

addition of eight

piezometers)

Effectiveness $87,000 $2,000 $147,000 $119,200

6.1.3 Delineate onsite plume

(includes extra costs for

installing monitoring wells

instead of piezometers in

6.1.2)

Effectiveness $4,000 $4,000 $124,000 $68,500

6.1.4 Analyze capture zone Effectiveness $0 $4,000 $120,000 $64,500

6.1.5 Properly seal

abandoned wells

Effectiveness $15,000 $0 $15,000 $15,000

6.1.6 Evaluate TCE impact

on Pennypack Creek

Effectiveness $0 $1,000 $30,000 $16,100

6.1.7 Sample air in buildings

for TCE

Effectiveness $5,000 $1,000 $35,000 $21,100

6.3.1 Complete O&M

manual

Technical

Improvement

$10,000 $0 $10,000 $10,000

6.3.2 Compile and organize

site data and documents

Technical

Improvement

$10,000 $0 $10,000 $10,000

6.3.3 Rename and label site

wells

Technical

Improvement

$10 ,000 $0 $10,000 $10,000

Costs in parentheses imply cost reductions.

* assumes 30 years of operation with a discount rate of 0% (i.e., no discounting)

** assumes 30 years of operation with a discount rate of 5% and no discounting in the first year
FIGURES
H-17

H-14

0 2000 4000

SCALE IN FEET

 FIGURE 1-1: THE AREA SURROUNDING THE RAYMARK SUPERFUND SITE INCLUDING HATBORO WELLS H-14 AND H-17

 (Note: This figure is adapted from the 1988 USGS topographical map, Hatboro Quadrangle Pennsylvania, 7.5 minute series.)

Fischer and

Porter Company

Raymark

Superfund

Site
?

(Note: This figure is adapted from Figure 1-2 from the Raymark Site RI/FS Final Soil/Source Area Remedial Investigation Report, Operable Unit No. 1.,

CH2M Hill, 1991.)

FIGURE 1-2. SITE LAYOUT SHOWING LOCATIONS OF THE MONITORING WELLS AND THE EXTRACTION WELLS.
?

(Note: This figure is taken from Figure 3-2 from the Raymark Site RI/FS Final Soil/Source Area Remedial Investigation Report, Operable Unit No. 1.,

CH2M Hill, 1991.)

FIGURE 1-3. CROSS SECTION OF THE GEOLOGY UNDERLYING THE RAYMARK SITE.
U.S. EPA National Service Center 

for Environmental PublicationsP.O. Box 42419Cincinnati, OH 45242-2419

Solid Waste and Emergency Response(5102G)

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