UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 


REGION Ill 


1650 Arch Street 


Philadelphia, Pennsylvania 19103-2029 


DEC 2 3 2013 

The Honorable Christopher Abruzzo, Secretary 

Pennsylvania Department ofEnvironmental Protection 

Rachel Carson State Office Building 

400 Market Street 

Hanisburg, Pennsylvania 17101 

Dear Secretary Abruzzo: 

. The United States Environmental Protection Agency (EPA) is considering proposing the 

Baghurst Alley Site (site), located in Upper Salford Township, Montgomery County, Pennsylvania to 

the Superfund National Priorities List (NPL ), pursuant to its authority under Section 105 of the 

Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), as amended, 42 

U.S.C. Section 9605. The NPL contains a list of priority sites with releases of hazardous substances, 

pollutants or contaminants that require evaluation for possible remediation. It is EPA s policy to 

determine the state's position on a site that EPA is considering placing on the NPL. With this letter 

EPA is seeking the concurrence of the Commonwealth of Pennsylvania which has been delegated to the 

Secretary of Pennsylvania Department ofEnvironmental Protection (PADEP), on adding thj site to the 

NPL. 

The site consists of a ground water plume contaminated with volatile organic compounds 

(VOCs). The suspected source ofthe ground water plume is located on a nearby farm. The 

contamination was first discovered in several residential drinking water wells by the Montgomery 

County Health Department in 1999. In November ofthat year, PADEP installed Point-of-Entry 

Treatment (POET) systems on 16 residential wells and 1 common well, which serves 11 additional 

homes. These wells have been sampled by PADEP on a semi-annual basis to assure that the POET 

systems are performing appropriately. There are also an additional 13 to 15 residential wells that have 

trace contamination. 

In 2000, PADEP performed a site characterization study to try to identify potential source 

area(s). Monitoring wells installed as part ofthe study revealed very elevated concentrations of VOCs 

on the farm property. Also, 1 ,4-dioxane was detected in monitoring and private well samples at levels 

exceeding state standards and Regional Screening Levels (RSLs). The detection of 1 ,4-dioxane 

prompted PADEP to initiate bottled water deliveries to the affected homes, because the previously 

installed POET systems are not capable offiltering out I ,4-dioxane. There are currently 27 residences 

that have been affected by this plume and are receiving treatment systems and/or bottled water. 

Although the Southeast Regional Office of P ADEP continues to work with the township to find a 

permanent alternate source of drinking water for the area, they have requested EPA assistance in 

addressing the site via the Superfund NPL process. 

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Customer Service Hotline: 1-800-438-2474 

EPA is committed to working cooperatively with the state and local community throughout the 

listing and subsequent Superfund cleanup process, and to ensuring that EPA's actions are conducted in 

an open and transparent manner. For a fund-financed remedial action, prior to initiation ofthe remedial 

action EPA and PADEP will collaborate in the development of a Superfund state contract to provide the 

state assurances required by CERCLA, including, for example, the state's statutory cost share for the 

remedial action and assumption of operation and maintenance responsibilities. 

EPA is requesting a written response to thi letter from your office by January 17,2014. EPA 

has et lhi date to allow adequate time to meet the proposed rule schedule. The response letter should 

indicate whether PeMsylvania supports placement of the site on·the NPL. We appreciate your 

consideration of this matter. 

If you have any questions, please do not hesitate to contact me or have your staff contact 

Mrs. Laura Mohollen, EPA's Pennsylvania Liaison, at 215-814-3295. For information regarding the 

proposed NPL listing, your staff can contact Ms. Kathryn Hodgkiss, Acting Director, Hazardous Site 

Cleanup Division at, 215-814-3151. 

Sin,c ely, 	 ). 

\J 1Ct. ~Jvl r·{ ·'./:1.__;.-._ 

Shawn M. Garvin 

Regional Administrator 

cc: 	 Mr. Cosmo Servidio, Director 

PADEP Southeast Regional Office 

Mr. James Woolford, Director 


Office of Superfund Remediation and Technology Innovation 


t\

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Customer Service Hotline: 1-800-438-2474