HRS DOCUMENTATION RECORD--REVIEW COVER SHEET

Name of Site: Baghurst Drive

EPA ID No.: PAN000306939

Date Prepared: May 2014

Contact Person Lorie Baker

U.S. Environmental Protection Agency

Philadelphia, Pennsylvania

(215) 814-3355

Baker.Lorie@epa.gov

Pathways, Components, or Threats Not Scored

The surface water migration, soil exposure, and air migration pathways are not scored in this Hazard Ranking 

System (HRS) documentation record because the listing decision is not significantly affected by those pathways. 

The ground water migration pathway score is sufficient to qualify the site for National Priorities List (NPL).
This page has been left blank intentionally.
1 

HRS DOCUMENTATION RECORD

Name of Site: Baghurst Drive Date Prepared: May 2014

CERCLIS ID No.: PAN000306939

 

EPA Region: 3 

Street Address of Site*: Northern Intersection of Hendricks Road and Baghurst Drive

County and State: Harleysville, Montgomery County, Pennsylvania 19438

General Location in the State: Southeastern Pennsylvania

Topographic Map: Perkiomenville, PA

Latitude: *40 ̊17' 58.14" North Longitude: *75 ̊27'18.48" West

 (40.299483 ̊ North) (75.455133 ̊ West)

The site consists of a ground water plume with no identified source(s) of contamination. Therefore, the reference 

point for the street address and site latitude/longitude coordinates is located within the plume at the intersection of 

Hendricks Road and Baghurst Drive as shown on Figure 1 of this HRS documentation record (Refs. 3; 4; 5). 

 

* The street address, coordinates, and contaminant locations presented in this HRS documentation 

record identify the general area the site is located. They represent one or more locations EPA 

considers to be part of the site based on the screening information EPA used to evaluate the site 

for NPL listing. EPA lists national priorities among the known "releases or threatened releases" of 

hazardous substances; thus, the focus is on the release, not precisely delineated boundaries. A site 

is defined as where a hazardous substance has been "deposited, stored, disposed, or placed, or has 

otherwise come to be located." Generally, HRS scoring and the subsequent listing of a release 

merely represent the initial determination that a certain area may need to be addressed under 

CERCLA. Accordingly, EPA contemplates that the preliminary description of facility boundaries 

at the time of scoring will be refined as more information is developed as to where the 

contamination has come to be located. 

 Scores

Ground Water Pathway 100.00

Surface Water Pathway Not Scored

Soil Exposure Pathway Not Scored

Air Pathway Not Scored

HRS SITE SCORE 50.00
2 

WORKSHEET FOR COMPUTING HRS SITE SCORE

Baghurst Drive

S S2

1. Ground Water Migration Pathway Score (Sgw) 100.00 10,000

(from Table 3-1, line 13)

2a. Surface Water Overland/Flood Migration Component Not Scored

(from Table 4-1, line 30)

2b. Ground Water to Surface Water Migration Component Not Scored

(from Table 4-25, line 28)

2c. Surface Water Migration Pathway Score (Ssw) Not Scored 

Enter the larger of lines 2a and 2b as the pathway score.

3. Soil Exposure Pathway Score (Ss) Not Scored 

(from Table 5-1, line 22)

4. Air Migration Pathway Score (Sa) Not Scored

(from Table 6-1, line 12)

5. Total of Sgw2 + Ssw2 + Ss

2 + Sa2 10,000 

6. HRS Site Score Divide the value on line 5

 by 4 and take the square root 50.00
3 

GROUND WATER MIGRATION PATHWAY SCORESHEET

Baghurst Drive

GROUND WATER MIGRATION PATHWAY

Factor Categories & Factors

MAXIMUM VALUE VALUE ASSIGNED

Likelihood of Release

1. Observed Release 550 550

2. Potential to Release

2a. Containment 10 Not scored

2b. Net Precipitation 10 Not scored

2c. Depth to Aquifer 5 Not scored

2d. Travel Time 35 Not scored

2e. Potential to Release

[lines 2a(2b+2c+2d)]

500 Not scored

3. Likelihood of Release 550 550

Waste Characteristics

4. Toxicity/Mobility * 10,000

5. Hazardous Waste Quantity * 100

6. Waste Characteristics 100 32

Targets

7. Nearest Well 50 50

8. Population

8a. Level I Concentrations ** 541.70

8b. Level II Concentrations ** 1

8c. Potential Contamination ** Not scored

8d. Population (lines 8a+8b+8c) ** 542.70

9. Resources 5 Not scored

10. Wellhead Protection Area 20 Not scored

11. Targets (lines 7+8d+9+10) ** 592.70

12. Aquifer Score (lines 3x6x12 divided by 82,500) 100 100.00

13. Ground Water Migration Pathway Score (Sgw) 100 100.00

* Maximum value applies to waste characteristics category.

** Maximum value not applicable.
4 

REFERENCES

Reference

Number Description of the Reference

1. U.S. Environmental Protection Agency (EPA). Hazard Ranking System, Final Rule. Federal Register, 

Volume 55, No. 241, pp. 51532–51667. December 14, 1990. Cover page only. A complete copy of 

the rule is available at http://www.epa.gov/superfund/sites/npl/hrsres/index.htm#HRS Rule. [1 page] 

2. U.S. Environmental Protection Agency (EPA). Excerpts from Superfund Chemical Data Matrix, 

Appendices B-I (Hazardous Substances Factor Values) and B-II (Hazardous Substance Benchmarks). 

SCDM Data Version: 12/31/12. Publication date 1/30/2014. A complete copy of SCDM is available at 

http://www.epa.gov/superfund/sites/npl/hrsres/tools/scdm.htm. [42 pages] 

3. U.S. Environmental Protection Agency (EPA). Superfund Site Information, Baghurst Alley, 

Harleysville, PA: Site Information. Downloaded from 

http://cumulis.epa.gov/supercpad/cursites/csitinfo.cfm?id=0306939 on November 3, 2013. [1 page]

4. U.S. Geological Survey (USGS). Perkiomen, Pennsylvania Quadrangle (7.5×7.5-minute series 

topographic map). 2013. [1 map] 

5. Shannon, Nancy, Weston Solutions, Inc. (WESTON). Project Note to Baghurst Alley Site File: Aerial 

Photograph Indicating Site Latitude and Longitude. Information Obtained from Google Earth® on 

February 12, 2014. [2 pages] 

6. Foster Wheeler Environmental Corporation. Final Site Characterization Report, Baghurst Alley Site, 

Upper Salford Township, Montgomery County, Pennsylvania. PADEP Contract No. 359186. Work 

Requisition No. 31-118. April 2003. [610 pages] 

7. Weston Solutions, Inc. (WESTON®). Draft Hydrogeologic Report for the Baghurst Alley Site. 

PADEP contract No. SAP#4000014758. PADEP Work Assignment No. IRRSC-6. May 2013. [302 

pages]

8. U.S. Environmental Protection Agency (EPA). National Primary Drinking Water Regulations 

Maximum Contaminant Levels. http://water.epa.gov/drink/contaminants/upload/mcl-2.pdf May 2009. 

[6 pages]

9. Pennsylvania Department of Environmental Protection (PADEP). HSCA Response Justification 

Document - Baghurst Alley Site. Upper Salford Township, Montgomery County, Southeast Region. 

November 23, 1999. [2 pages]

10. Pennsylvania Department of Environmental Protection (PADEP). Hazardous Sites Cleanup Program. 

Statement of Decision, Baghurst Alley Site. November 7, 2001. [12 pages]

11. Weston Solutions, Inc. (WESTON®). Well Installation, Groundwater Sampling, and Pumping Test 

Report – Baghurst Alley Site. PADEP Contract No. SAP#4000007413. PADEP Work Assignment 

No. IRRSC5-3-131. June 2008 [83 pages]

12. Armstrong, Dustin. Pennsylvania Department of Environmental Protection (PADEP). Excerpts from 

Baghurst Field Logbooks #1 and #2. July 6 – October 12, 2011. [8 pages]

*Hard Copy of Complete Logbook Available Upon Request from PADEP. 

13. Pennsylvania Department of Environmental Protection (PADEP). Bureau of Laboratories. Analytical 

Report. July 15 – October 29, 2011. [192 pages]
REFERENCES (continued)

Reference

Number Description of the Reference

14. Commonwealth of Pennsylvania. Ground-water Resources of the Brunswick Formation in 

Montgomery and Berks Counties, Pennsylvania (Ground Water Report W 22). PA Department of 

Internal Affairs, Bureau of Topographic and Geologic Survey. 1965 [64 pages]

15. U.S. Environmental Protection Agency (EPA). Contract Laboratory Program (CLP). Modifications 

Updating SOM01.1 to SOM01.2; with attached excerpts from SOM01.1. Amended: April 11, 2007. 

[117 pages]

16. Agency for Toxic Substances & Disease Registry (ATSDR). Division of Toxicology ToxFAQs, 1,1,1-

Trichloroethane, CAS # 71-55-6. July 2006. [2 pages]

17. Agency for Toxic Substances & Disease Registry (ATSDR). Division of Toxicology ToxFAQs, 

Trichloroethylene, CAS # 79-01-6. July 2003. [2 pages]

18. Armstrong, Dustin, PADEP. Electronic Mail Correspondence with Nancy Shannon, WESTON. 

Subject: Baghurst Alley Residential Sampling Procedures. November 13 and 26, 2013. [3 pages]

19. Tetra Tech FW. Addendum to Site Characterization Report – Baghurst Alley Site. PADEP Contract

No. ME-359186. Work Requisition No. 31-118. April 2004. [337 pages]

20. Shannon, Nancy. WESTON. Teleconference Record Regarding Potential Source Investigations 

Conducted by PADEP. November 5, 2013. [1 page] 

21. Shannon, Nancy. WESTON. Electronic Mail Correspondence with Mr. Dustin Armstrong, PADEP, 

Regarding Common Well Connections. November 7-12, 2013. [2 pages]

22. Reference Number Reserved.

23. U.S. Census Bureau. State and County Quick Facts for Montgomery County, Pennsylvania. 

Downloaded from http://quickfacts.census.gov/qfd/states/42/42091.html on April 3, 2014. Last 

revised on March 27, 2014. [2 pages]

24. U.S. Environmental Protection Agency (EPA) and The National Environmental Laboratory 

Accreditation Conference (NELAC) Institute. NELAC (National Environmental Laboratory 

Accreditation Conference), program information and accreditation of Lancaster Laboratories. 

Accessed and downloaded from various websites (http://www.epa.gov/nelac/, http://www.nelacinstitute.org/newnelap.php, http://nelac-institute.org/lams/labs/2128/, and http://nelacinstitute.org/lams/labs/1349/) on November 13, 2013. [4 pages] 

25. U.S. Environmental Protection Agency (EPA). Technical Fact Sheet – 1,4-Dioxane. Office of Solid 

Waste and Emergency Response. . January 2013. [5 pages] 

26. Pennsylvania Department of Conservation and Natural Resources. Pennsylvania Groundwater 

Information System. Bureau of Topographic and Geological Survey. Information Accessed from

http://www.dcnr.state.pa.us/topogeo/groundwater/pagwis/records/index.htm on November 27, 2013. 

[3 pages]

27. Reference Number Reserved

5 
6 

REFERENCES (continued)

Reference

Number Description of the Reference

28. Shannon, Nancy, WESTON. Baghurst Alley Project Note To File: Correspondence with Dustin 

Armstrong, PADEP. February 12, 2014 [3 pages] 

29. Shannon, Nancy, WESTON. Baghurst Alley Project Note To File: Envirofacts® Database Search. 

February 16, 2014. [46 pages]

30. USGS. Microbial Degradation of Choroethenes in Ground Water Systems. Toxic Substances 

Hydrology Program. Information Accessed from 

http://toxics.usgs.gov/sites/solvents/chloroethene.html on February 19, 2014. [1 page] 

31. Shannon, Nancy, WESTON. Baghurst Alley Project Note To File: LOQ Equivalent to HRS-defined

SQL. February 19, 2014 [1 page] 

32. EPA. Quick Reference Fact Sheet EPA 540-F-94-028: Using Qualified Data to Document an 

Observed Release and Observed Contamination. Office of Emergency and Remedial Response. 

November 1996. Available from http://www.epa.gov/superfund/sites/npl/hrsres/fact/docoroc.pdf. [18 

pages] 

33. Shannon, Nancy, WESTON. Baghurst Alley Project Note To File: Rock Formations for Completed 

Monitoring Wells. February 20, 2014 [1 page] 

34. Shannon, Nancy, WESTON. Baghurst Alley Project Note To File: Ref. 13 PADEP Laboratory Data 

SQLs. February 25, 2014. [1 page]

35. Shannon, Nancy, WESTON. Baghurst Alley Project Note To File: Persons Per Household Subject to 

Level I or Level II Concentrations. March 1, 2014. [1 page]

36. Morin, Roger H.; Senior, Lisa A.; and Decker, Edward R., Fractured-Aquifer Hydrogeology from 

Geophysical Logs: Brunswick Group and Lockatong Formation, Pennsylvania. USGS Staff --

Published Research. Paper 352. January 1, 2000. http://digitalcommons.unl.edu/usgsstaffpub/352. [12 

pages]
SS – Site Summary

7

SITE SUMMARY

The Baghurst Drive site (EPA ID No. PAN000306939) consists of a contaminated ground water plume with no 

identified source, i.e., no clearly defined attribution to a specific source [Ref. 3]. The hazardous substances 

associated with the site include 1,1,1-trichloroethane (1,1,1-TCA), 1,1-dicloroethene (1,1-DCE), trichloroethylene 

(TCE), vinyl chloride, and 1,4-dioxane, which will be further discussed and documented in subsequent sections of 

this HRS documentation record. The site is located in a rural, residential area in Harleysville, Montgomery County, 

Pennsylvania [Ref. 4; Figure 1]. The site is reported to have impacted 27 residential drinking water wells, including 

a common well with 10 hookups, [Refs. 10, p. 2; 21, pp. 1-2]. The geographic coordinates of the site are 40 ̊ 17' 

58.14" (40.299483) north latitude and 75 ̊ 27' 18.48" (75.455133) west longitude, as measured at the intersection of 

Hendricks Road and Baghurst Drive [Ref. 5; Figure 1]. 

In 1999, a homeowner submitted a water sample to the Montgomery County Health Department (MCHD) per 

county regulations to receive a permit for a residential drinking water well. Analytical results of the water sample 

indicated concentrations of 1,1,1-TCA above the EPA National Primary Drinking Water Standard Maximum 

Contaminant Level (MCL) of 200 micrograms per liter (μg/L) (Refs. 6, p. 12; 8, p. 3). From June 1999 to October 

1999, the MCHD collected samples from several residential drinking water wells in the area and found the wells 

contained one or more volatile organic compounds (VOCs), such as 1,1-DCE; 1,1,1-TCA; TCE; and vinyl chloride, 

as well as 1,1-dichloroethane (1,1-DCA) and 1,2-dichloroethene (1,2-DCE), at concentrations above MCLs [Ref. 6, 

p. 12]. In November 1999, MCHD contacted the Pennsylvania Department of Environmental Protection (PADEP) 

regarding the presence of chlorinated solvents in residential wells [Ref. 9, pp. 1-2]. PADEP immediately began 

supplying 27 residences with bottled drinking water and subsequently equipped the homes with carbon filtration 

systems [Ref. 10, p. 2].

In April 2001, PADEP contracted Foster Wheeler Environmental Corporation (Foster Wheeler) to conduct a source 

investigation for the VOCs detected in the residential wells sampled by MCHD. The source investigation focused 

on a 29-acre farm property located on Hendricks Road. The investigation consisted of advancing soil borings, 

collecting soil samples, installing bedrock monitoring wells, collecting ground water samples from the monitoring 

wells between July 2001 and January 2003, and the collection of surface water samples from seeps and stream water 

in February, March-April, and November 2002 [Ref 6, pp. 7, 9, 22, 23, 38, and 55). Analytical results of the source 

investigation indicated the presence of chlorinated VOCs (primarily 1,1,1-TCA, 1,1-DCE, 1,1-DCA, vinyl chloride,

and TCE) in soil, ground water and surface water. The report concluded that the core area of the highest chlorinated 

VOC concentrations in ground water (based on spatial concentrations) was located on a farm property on Hendricks 

Road and had migrated approximately 800 feet downgradient [Ref. 6, pp. 55, 56, 73, and 74]. EPA has concluded, 

however, that based on the relatively low contaminant levels detected in a limited number of samples, the soil 

contamination detected between 2001 and 2002 on the farm property is not enough evidence to identify it as a 

primary or significant source of the ground water contamination and has been unable to identify a primary source 

(see the attribution discussion in Section 3.1.1 of this HRS documentation record for more detailed information 

pertaining to the unidentified origin of the contaminants).

In 2007 and 2012, PADEP installed wells and conducted pump tests in an effort to find an alternate, local, 

unaffected ground water source for the community [Refs. 7, pp. 8-9; 11, p. 8]. However, the analysis of the ground 

water samples collected from the potential supply wells contained concentrations of arsenic and lead above their 

respective MCLs. The presence of arsenic and lead in the ground water was believed to be naturally occurring as a 

result of diabase intrusions into the Lockatong and Brunswick Formations. The source water from these potential 

supply wells would require treatment prior to distribution. Additionally, a large pumping influence was observed in

nearby residential drinking water wells during pump tests [Ref. 7, pp. 29, 31, 35 and 36]. As of the date of this HRS 

documentation record, the residents have not been connected to an alternative water supply. Affected residents 

continue to receive bottled water for drinking purposes [Ref. 28, pp. 1 and 3]. 

Since 2000, PADEP has periodically collected samples from residential homes that have filtrations systems to 

monitor contaminant concentrations and filter performance [Ref. 28, pp. 1 and 3]. In January and March 2004, 

PADEP began analyzing for 1,4-dioxane, which was subsequently found in some of the affected wells (Ref. 19, p. 

21). However, due to its high water solubility, 1,4-dioxane is not removed by the filtration systems installed on the 

affected residential wells. Therefore, the affected residences are supplied bottled water for drinking purposes. 
SS – Site Summary

8

Additionally, while the systems effectively remove the other site-related VOCs from the residential well water, the 

dermal/inhalation exposure to 1,4-dioxane during bathing or washing is still a concern at the site [Ref. 7, p. 8]. 
^_

TDD#: WS03-13-10-001

Contract: EP-S3-10-05

Prepared: 4/3/2014

Figure 1

Site Location

Baghurst Drive PA State Plane, NAD83  ́ Legend

^_ Site Location 0 2,000

Feet Harleysville, Montgomery County, PA 1:24,000

Map Area

USGS 7.5-Minute Series Topographic Quadrangles:

Perkiomenville, Pennsylvania, 2013
A!

A!

A!

A!

A! A!

A! A!

A!! A!

A!

A!

A!

A!

A! A!

A!

A!

A!

AA!!

A!

A!

A!

A!

A!

A! A!

A!

A!

A!

A!

TDD#: WS03-13-10-001

Contract: EP-S3-10-05

Prepared: 4/3/2014

Figure 2

Site Layout

Baghurst Drive PA State Plane, NAD83  ́ Legend

A! Site Well

Source 1 0 1,000

Feet Harleysville, Montgomery County, PA 1:12,000

Map Area Note: The plume area shown on the map is based on 

 the analytical data for wells that document an 

 observed release contained in Refs. 7 and 13 

 of this HRS documentation record.

Service Layer Credits: Source: Esri, DigitalGlobe,

GeoEye, i-cubed, USDA, USGS, AEX, Getmapping,

Aerogrid, IGN, IGP, swisstopo, and the GIS User

Community
A!

A!

A!

A!

A!

A! A!

A! A!

A!! A!

A!

A!

A!

A!

A! A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

AA!!

A!

A!

A!

A!

A! A!

A!

A!

A!

A!

A!

&<

&<

&<

&<

&< &<

&< &<

&< &<

&<

&<

&<

&<

&< &<

&<

&<

BAMW28

BAMW30

BAMW32

BAMW33

BAMW34

BAMW05 BAMW07

BAMW09 BAMW10

BAMW11

BAMW12

BAMW13

BAMW14

BAMW15

BAMW16

BAMW17 BAMW18

BAMW19

BAMW20

BAMW21

BAMW22

BAMW25

BAMW36

2096H

2179H

1760B

1744B

1746B

1780B

1800B

1810B

1747H

1775B

1767B

1787H

1836H

1886H

1898H

1926H

226'-41'

225'--146'

220'-60'

217'-28'

216'-86'

161'-54'

197'-52'

392'-22'

373'-243'

317'-157'

331'-133'

336'-78'

397'-92'

321'-43'

306'-51'

358'--2' 400'-220'

321'-154'

390'-130'

390'-130'

212'-52' 212'-52'

206'--54'

234'-100'

381'-86'

137'--226'

102'-38'

351'-91'

340'-255'

255'-75'

287'-137'

336'-191'

336'-116'

339'-159'

211'-21'

419'-149'

289'-92'

420'-102'

379'-256'

335'-267'

396'-258'

377'-302'

331'-219'

218'-83'

176'-67'

431'-331'

TDD#: WS03-13-10-001

Contract: EP-S3-10-05

Prepared: 4/3/2014

Figure 3

On-site and Nearby Wells

Baghurst Drive  ́ PA State Plane, NAD83

Legend

&< Observed Release

Well

A! Background Well

(no detections)

A! Level II Well

A! Level I Well

Source 1

Domestic Well Completion

Brunswick Fm (Trb)

Lockatong Fm (Trl)

Not Listed

0 1,000

ft Harleysville, Montgomery County, PA

1:12,000

Notes: 

1. The plume area shown on the map is based on the analytical

 data for wells that document an observed release contained in

 Refs. 7 and 13 of this HRS documentation record.

2. Domestic well data (location, depth, construction, and

 formation) were obtained from the PAGWIS database cited in

 Reference 26 of this HRS documentation record.

3. Bedrock geology of Pennsylvania: Pennsylvania Geological

 Survey, 4th series (compiled in 2001). 1:250,000 scale. 

Service Layer Credits: Source: Esri, DigitalGlobe,

GeoEye, i-cubed, USDA, USGS, AEX, Getmapping,

Aerogrid, IGN, IGP, swisstopo, and the GIS User

Community

Map Area

Postings provide open interval

(Mean Sea Level)
SD-Characterization and Containment

Source No.: 1

12

SOURCE DESCRIPTION

2.2 SOURCE CHARACTERIZATION

Number of the source: 1

Source Type of the source: Other

Name and description of the source: Contaminated Ground Water Plume with no identified source

The source, contaminated ground water plume with no identified source, is characterized by analytical results of 

ground water samples collected from monitoring wells in November 2012 and residential drinking water wells 

collected in July 2011 as described below and in Section 3.1.1 of this HRS documentation record. To date, EPA and 

PADEP have not identified a source for the contaminants present in the ground water. Please refer to the discussion 

regarding attribution in Section 3.1.1 of this HRS documentation record for more detailed information pertaining to 

the unknown origin of the contaminants.

In November 2012, ground water samples were collected from monitoring wells located at the site [Ref. 7, pp. 11, 

12, 77-116]. Analytical results of the ground water samples collected from the monitoring wells using pumps or 

bailers indicated the presence of 1,1,1-TCA with a maximum concentration of 18,000 μg/L detected in well 

BAMW28D; 1,1-DCE with a maximum concentration of 2,300 μg/L detected in well BAMW19S; TCE with a 

maximum concentration of 58 μg/L detected in well BAMW28D; vinyl chloride with a maximum concentration of 2 

μg/L detected in well BAMW25D; and 1,4-dioxane with a maximum concentration of 220 μg/L detected in well 

MW19D [Ref. 7, pp. 21, 57, 85, 87, 88, 105, 164, 170, 172, and 249]. For the presentation of 2012 analytical results 

documenting the ground water plume, including comparison to background, see Section 3.1.1 of this HRS 

documentation record.

In July 2011, ground water samples were collected from 15 residential drinking water wells, including one common 

well [Ref. 12, pp. 2-5]. An additional residence was sampled in October 2011 [Ref. 12, p. 8]. Analytical results of 

the ground water samples collected from the drinking water wells indicated the presence of 1,1,1-TCA with a

maximum concentration of 962 μg/L detected in well 1886H; 1,1-DCE with a maximum concentration of 647 μg/L 

detected in well 1886H; TCE with a maximum concentration of 9.23 μg/L detected in well 1886H; and 1,4-dioxane 

with a maximum concentration of 69.6 μg/L detected in well 1886H [Ref. 13, pp. 47, 48, and 51]. For the 

presentation of 2011 analytical results documenting the ground water plume, including comparison to background, 

see Section 3.1.1 of this HRS documentation record.

Additional evidence of contamination includes samples collected from wells via hydrosleeve and passive diffusion 

bag (PDB) samplers for VOC and 1,4-dioxane analysis. Analytical results of samples collected from wells using 

PDB samplers indicated that the highest concentration of 1,1 DCE was 4,400 μg/L, the highest concentration of 

1,1,1-TCA was 27,000 μg/L in sample MW19S-DIS, and the highest concentration of 1,4-dioxane was 490 μg/L in 

sample MW09-DIS [Ref. 7, pp. 88, 89, 184, 186]. 

Ground water samples have been periodically collected at the site by PADEP since 2000; however, only the most 

recent sample results, with respect to applicable background samples, are included in this HRS documentation 

record to be most reflective of current conditions [Ref. 28, pp. 1 and 3].

Location of the source, with reference to a map of the site:

The ground water plume is identified by contamination found in the monitoring wells and residential drinking water 

wells [Figure 2]. For the purpose of this HRS evaluation, these wells represent a minimum of the plume extent. The 

site is located in southeastern Pennsylvania and is shown in Figures 1 and 2 of this HRS documentation record.
SD-Characterization and Containment

Source No.: 1

13

Containment

Release to ground water:

Analytical results for ground water samples collected from monitoring wells and private drinking water wells 

indicate that a release of hazardous substances has occurred to the ground water migration pathway as documented 

in Section 3.1.1 of this HRS documentation record. Based on this evidence of hazardous substance migration, a 

containment factor value of 10 is assigned for the ground water migration pathway [Ref. 1, p. 51596, Table 3-2].
SD- Hazardous Substances

Source No.: 1

14

2.4.1 Hazardous Substances

Ground water samples collected in 2011 and 2012 from monitoring wells and residential drinking water wells 

indicate the presence of chlorinated solvents such as 1,1,1-TCA, 1,1-DCE, TCE, vinyl chloride, and 1,4-dioxane 

[Refs. 7, pp. 162-298; 13, pp. 1-84]. These hazardous substances are not naturally occurring [Refs. 16, p. 1; 17, p. 

1]. 1,1,1-TCA and TCE are man-made chlorinated solvents that are commonly used as cleaning and degreasing 

agents, while 1,1-DCE and vinyl chloride can be degradation breakdown products of either or both 1,1,1-TCA and 

TCE [Refs. 6, p. 48; 30, p. 1]. Additionally, 1,4-dioxane was historically used as a stabilizer for chlorinated 

solvents, primarily 1,1,1-TCA. [Ref. 25, p. 1].

These contaminants are not ubiquitous and were not detected in ground water samples collected from background 

wells (BAMW20, BAMW21, BAMW22, BAMW32S, BAMW32D, and BAMW36S for monitoring wells and 

2096H and 2179H for residential drinking water wells) above applicable sample quantitation limits (SQL) [Refs. 7, 

pp. 209, 225, 227, 221, 223, and 251; 13, pp. 65-71 and 72-78; 31, p. 1; 34, p. 1]. For the presentation of analytical 

results documenting hazardous substances associated with the ground water plume, see Section 3.1.1 of this HRS

documentation record and Figure 3 for sample locations.
SD-Hazardous Waste Quantity

Source No.: 1

15

2.4.2 Hazardous Waste Quantity

2.4.2.1.1 Hazardous Constituent Quantity

The hazardous constituent quantity for Source No. 1 could not be adequately determined according to the HRS 

requirements; that is, the total mass of all Comprehensive Environmental Response, Compensation, and Liability 

Act (CERCLA) hazardous substances in the source is not known and cannot be estimated with reasonable 

confidence [Ref .1, pp. 51590-51591, Section 2.4.2.1.1]. There are insufficient historical records and current data 

available to adequately calculate the total mass of all CERCLA hazardous substances in the source and the 

associated releases from the source. Therefore, there is insufficient information to evaluate the associated releases 

from the source to calculate the hazardous constituent quantity for Source No. 1 with reasonable confidence, and 

hazardous constituent quantity is not scored (NS). 

Hazardous Constituent Quantity (C) Value: NS

2.4.2.1.2 Hazardous Wastestream Quantity

The hazardous wastestream quantity for Source No. 1 could not be adequately determined according to the HRS 

requirements; that is, the total mass of all hazardous wastestreams and CERCLA pollutants and contaminants for the 

source and releases from the source is not known and cannot be estimated with reasonable confidence [Ref. 1, p. 

51591, Section 2.4.2.1.2]. There are insufficient historical and current data available to adequately calculate the total 

mass of all hazardous wastestreams and CERCLA pollutants and contaminants for the source and the associated 

releases from the source. Therefore, there is insufficient information to adequately calculate or extrapolate the 

hazardous wastestream quantity for Source No. 1 with reasonable confidence, and hazardous wastestream quantity is 

not scored. 

Hazardous Wastestream Quantity (W) Value: NS

2.4.2.1.3 Volume

Based on sampling data of monitoring wells and residential drinking water wells, a contaminated ground water 

plume with no identified source has been documented. However, the vertical and horizontal extents of the ground 

water contamination have not been identified. Therefore, for Source No. 1, a value of unknown, but greater than 

zero has been assigned for the source hazardous waste quantity (HWQ) value for volume. The source type is 

‘Other;’ therefore, the volume value is divided by 2.5 to obtain the assigned value, as shown below [Ref. 1, p. 

51591, Section 2.4.2.1.3, Table 2-5].

Dimension of source (yd3

): >0 yd3

Volume (V) Assigned Value: (>0)/2.5 = >0

2.4.2.1.4 Area

Tier D is not evaluated for source type “other” [Ref. 1, p. 51591, Table 2-5, Section 2.4.2.1.3].

Area of source (ft2

): N/A

Area (A) Assigned Value: 0

2.4.2.1.5 Source Hazardous Waste Quantity Value

The source hazardous waste quantity value for Source 1 is >0 for Tier C - Volume [Ref. 1, p. 51591, Section 

2.4.2.1.5].

Source Hazardous Waste Quantity Value: >0
SD-Summary

16

SITE SUMMARY OF SOURCE DESCRIPTIONS

Source Number Source Hazardous 

Waste Quantity 

Value

Containment

Ground Water Surface 

Water

Air (Gas) Air 

(Particulate)

1 >0 10 NS NS NS

NS = Not scored. 
GW-General

17

3.0 GROUND WATER MIGRATION PATHWAY

3.0.1 General Considerations

Aquifer/Stratum 1 

Aquifer/Stratum Name: Fractured Bedrock Aquifer System (Brunswick and Lockatong Formations)

The Baghurst Drive site and the surrounding study area are underlain by surficial soils that lie above either the 

Brunswick or Lockatong Formation [Ref. 6, p. 26]. The overburden soils generally consist of either topsoil or 

pavement for the upper one-foot below ground surface (bgs). Weathered bedrock soils underlie the topsoil or 

pavement and are present from 1 foot to approximately 9 feet bgs. The overburden soils are similar in chemical 

composition to the underlying bedrock. Generally, the upper few feet of bedrock is severely weathered [Refs. 6, pp. 

26, 109-168; 7, pp. 118-155; 11, pp. 52, 54-56; 19, pp. 85-139].

The Lockatong Formation, which outcrops in the northeast portion of the site, consists of cyclic gray siltstones, 

mudstones, and black shale interbedded with less abundant, cyclic red siltstones, mudstones and sandstones. A gray

argillite (slightly metamorphosed siltstone) of the Lockatong Formation represents the lowermost stratigraphic unit 

in the aquifer being evaluated. The Lockatong Formation grades laterally into red beds of the Brunswick Formation. 

The formational contact between the Brunswick Formation and the Lockatong Formation is gradational and has 

historically been placed where red mudstones predominate over the gray. The Brunswick Formation consists 

predominantly of reddish–brown shale, mudstones, siltstones, and sandstones. A complex series of diabase sheets 

and dikes extensively intruded the Triassic sedimentary rocks (i.e., the Brunswick and Lockatong Formations) 

during the early Jurassic Period. The nearest outcrop of diabasic rocks in relation to the site lies about one half mile 

to the west of the plume. As a result, the sedimentary rocks are slightly contact metamorphosed and sometimes 

described as argillite [Ref. 6, pp. 25, 26, and 67-71; 11, p. 9]. This potential aquifer discontinuity does not affect the 

scoring evaluation because there are no target wells scored within or west of the diabase [Refs. 6, p. 67; and Figure 3 

of this HRS documentation record]. 

In the vicinity of the site, both the Lockatong and Brunswick formations dip to the southwest, causing the 

Brunswick Formation to thicken toward the southwest and pinch out towards the northeast. Additionally, a nearby 

fault located just north of the site has caused localized folding of the strata, essentially forming upper and lower 

units of the Brunswick Formation separated by a layer of the Lockatong Formation [Refs. 6, pp. 67-71; 11, p. 9 and 

52]. As illustrated on geologic cross-sections and monitoring well logs prepared for the site, the upper layer of the 

Brunswick Formation directly underlies the site in the southern and western portions; the Lockatong Formation 

underlies the upper Brunswick, and a lower layer of the Brunswick underlies the Lockatong [Refs. 6, pp. 68-71 and 

115-168; 11, p. 52). In the northern and eastern portions of the site, the upper Brunswick is not present. The 

Lockatong Formation directly underlies the site with the lower Brunswick underlying the Lockatong Formation 

[Ref. 11, pp. 52, 54-56; 7, pp. 118-132]. 

The fractured, layered sedimentary rocks of the Brunswick and Lockatong Formations form a regional aquifer 

system that consists of gradational sequences of shale, siltstone, and sandstone, with fluid transport occurring 

primarily in fractures because of poor primary porosity [Ref. 36, pp. 2 and 3]. This aquifer system comprises a 

series of dipping lithologic units with different hydraulic properties. The ground water system can be visualized as a 

series of beds with high transmissivities separated by beds with relatively low transmissivities. These beds vary from 

a few inches to a few feet, and act as a series of alternating aquifers and confining or semi-confining units that form 

a leaky, multi-aquifer system [Ref. 6, p. 26, 28]. Generally, the Lockatong Formation represents a confining or 

semi-confining unit, and the Brunswick Formation represents a water-bearing unit. However, there are monitoring 

and drinking water wells in the area that are screened in the Lockatong Formation [Ref. 26, p. 3] (see also Figure 3 

and the monitoring well observed release tables in Section 3.1.1 of this HRS documentation record). 

The direction of ground water flow in the fractured bedrock aquifer system beneath the site is generally westsouthwest. Ground water flow in the aquifer system mimics topography and the direction of dip of the bedding 

planes with a horizontal gradient that averages about 0.11 foot/foot to the west-southwest and a downward vertical 

gradient between 0.01 and 0.972. However, consumptive use in the residential neighborhood along Baghurst Drive 

has an influencing factor on the direction of ground water flow to the south [Ref. 6, pp. 21, 30, 55, 56, 73, and 74]. 
GW-General

18

Aquifer Interconnection

Ground water movement within the rocks of the Brunswick and Lockatong Formations flows through secondary 

openings that were developed by external forces, following deposition of the beds. Some of these openings are 

fractures that parallel the bedding planes. The most important openings are nearly vertical joint planes that cross 

each other at various angles throughout the beds and provide an interconnected series of channels through which 

ground water can flow [Ref. 14, pp. 11, 12, 15, and 16]. As illustrated by the well logs, fractures are present in both 

formations throughout the site [Refs. 6, pp. 115-68; 7, pp. 54-56; and 7, pp. 118-132]. The site well logs also 

illustrate the continuous nature of the Brunswick and Lockatong Formations with no aquifer discontinuity or 

confining layer, such as an intrusion or clay layer, to separate the two formations [Refs. 6, pp. 115-168; 7, pp. 118-

132; 19, pp. 95-139]. 

Despite differences in transmissivity between the Brunswick and the Lockatong formations reflected in site reports, 

the material of each formation (i.e. alternating beds of slightly metamorphosed siltstones, mudstones, and sandstones 

as described above) is similar enough to result in a hydraulic conductivity for each formation of 10-6 [Ref. 1, p. 

51601, Section 3.1.2.4 Table 3-6; Ref. 6, p. 26, 28]. Additionally, as documented in Section 3.1.1 of this HRS 

documentation record, hazardous substances associated with this plume were documented in both the Brunswick and 

the Lockatong Formations at levels significantly above background levels. Therefore, based on the similar hydraulic 

conductivity of the formations, the presence of numerous fractures within the formations and the documentation of 

plume-related contamination in both formations significantly above background levels, the formations are 

considered a single interconnected hydrologic unit for HRS scoring purposes, i.e., the fractured bedrock aquifer 

system.
GW-Observed Release

19

3.1 LIKELIHOOD OF RELEASE

3.1.1 Observed Release

Aquifer Being Evaluated: Fractured Bedrock System (Brunswick and Lockatong)

An observed release is documented for the Baghurst Drive site. Chemical analyses for ground water samples 

collected from monitoring wells and residential drinking water wells show the presence of chlorinated solvents such 

as 1,1,1-TCA, 1,1-DCE, TCE, vinyl chloride, and 1,4-dioxane [Refs. 7, pp. 162-298; 13, pp. 1-84].

Direct Observation

The aquifer is not evaluated for observed release by direct observation.

Chemical Analysis

Since 1999, chlorinated solvents have been documented in ground water at Baghurst Drive [Ref. 6, p. 12]. 

However, only the most recent sample results, with respect to applicable background samples, for each affected well

are included in these results.

In November 2012, ground water samples were collected from monitoring wells at the site [Ref. 7 pp. 77-116, 195-

196, 260-262, and 296-297]. Samples were analyzed for VOCs via EPA Method SW846-8260B [Ref. 7, pp. 162-

298]. The analytical tests were conducted in accordance with the National Environmental Laboratory Accreditation 

Conference (NELAC) requirements [Ref. 24, pp. 1-3]. 

The VOCs 1,1,1-TCA, 1,1-DCE, TCE, vinyl chloride, and 1,4-dioxane were detected in the monitoring well samples 

at the following maximum concentrations: 1,1,1-TCA at 18,000 μg/L detected in well BAMW28D; 1,1-DCE at 

2,300 μg/L detected in well BAMW19S; TCE at 58 μg/L detected in well BAMW28D; vinyl chloride at 2 μg/L

detected in well BAMW25D; and 1,4-dioxane at 220 μg/L detected in well MW19D [Ref. 7, pp. 21, 57, 164, 170, 

172, and 249]. These hazardous substances were not detected in the background samples above the limits of 

quantitation (LOQs) [Ref. 7, pp. 209, 221, 223, 225, 227, 251, 253, and 268; 31, p. 1].

 

Ground water samples were collected from residential drinking water wells at the site from July to October 2011

[Ref. 12, pp. 1-8]. Samples were analyzed for VOCs via EPA Test Method 524.2 and PADEP Bureau of 

Laboratories (BOL) method BOL6038 for 1,4-dioxane [Ref. 13, pp. 1-3, 5-7, 9-11, 13-15, 17-19, 21-23, 25-27, 29, 

32-34, 36-38, 40, 43-45, 47-49, 51, 54-56, 58-60, 62, 65-67, 69, 72-74, 76, 79-81]. The analytical tests were 

conducted in accordance with the NELAC requirements [Refs. 13, pp. 3, 7, 11, 15, 19, 23, 27, 30, 34, 38, 41, 45, 49, 

52, 56, 60, 63, 67, 74, 77, 81, and 84; 24, pp. 1, 2, and 4]. Additionally, EPA’s CLP trace concentration VOC 

analysis is based on EPA Test Method 524.2 [Ref. 15, p. 68].

The VOCs 1,1,1-TCA, 1,1-DCE, TCE, and 1,4-dioxane were detected in the residential drinking water well samples 

at the following maximum concentrations in well 1886H: 1,1,1-TCA at 962 μg/L; 1,1-DCE at 647 μg/L; TCE at 

9.23 μg/L; and 1,4-dioxane at 69.6 μg/L [Ref. 13, pp. 47, 48, 50, 51, 53]. These hazardous substances were not 

detected in the background samples above sample quantitation limits (SQLs) [Ref. 13, pp. 65-71 and 72-78].

Note about background conditions: 

For the site-specific samples, all background and contaminated samples documenting the observed release in 

monitoring wells were collected from the hydrologic unit being evaluated (fractured bedrock of the Brunswick and 

Lockatong) [Refs. 6, pp. 67-71, 115-118, 125-129, 134-158, 164-168; 7, pp. 125-132; 19, pp. 95-98, 101-103, 110-

139; 33, p. 1]. Monitoring well sample collection and analysis procedures for the background and release samples, 

which were all collected during the same timeframe (November 13 to 20, 2012), were identical [Ref. 7, pp. 77-114, 

195-196, 260-262, 296-297]. 

Information regarding the exact depths, well construction, and lithology of the residential drinking water wells being

used to document an observed release is not known. Available information for other domestic wells in the vicinity 
GW-Observed Release

20

of the site, particularly toward the south and west where the upper unit of the Brunswick Formation is present, 

indicate that the majority of the domestic wells in this region are completed in the Brunswick Formation, range in 

depth from approximately 150 to 300 feet bgs, and are cased to approximately 20-40 feet bgs, as shown on Figure 3 

of this HRS documentation record [Ref. 26, pp. 1-3]. Based on the consistency of this regional data, the residential 

background and release wells presented in this HRS documentation record are expected to be of similar depth, 

construction, and lithology.
GW-Observed Release

21

Background Concentrations

Monitoring wells

Sample ID Surface

Elevation

(msl)

Completed 

Well Depth

(feet bgs)

Screened 

Interval

(feet bgs/

msl*)

Formation Sample

Date 

Reference(s)

BAMW20 408.89 34 14-34/

394.89-

374.89

Lockatong 11/15/12 6, pp. 16, 70, 

156; 7, pp. 

99, 261 

BAMW21 360.39 40 20-40/

340.39-

320.39

Lockatong 11/14/12 6, pp. 16, 

157; 7, pp. 

83, 260

BAMW22 383.26 41 21-41/

362.26-

342.26

Lockatong 11/15/12 6, pp. 16, 70, 

158; 7, pp. 

100, 261

BAMW32S 409.35 61 45-60/

364.35-

349.35 

Lockatong/

Brunswick

11/15/12 7, pp. 97, 

260; 19. pp. 

28, 110-112; 

33, p. 1

BAMW32D 409.35 100 79-99/

330.35-

310.35

Brunswick 11/15/12 7, pp. 98, 

261; 19, pp. 

28, 113-116; 

33, p. 1

BAMW36S 397.30 375 140-170/

257.3-227.30

Brunswick 11/16/12 7, pp. 107, 

125-132, 262; 

11, p. 55

bgs – below ground surface

msl – mean sea level

* msl screened interval determined by subtracting the depth in feet bgs from the surface elevation

Sample ID Hazardous Substance Concentration 

(μg/L)

LOQ1 (μg/L) Reference(s)

BAMW20 1,1,1-TCA ND 0.5 7, p. 225

1,1-DCE ND 0.5

TCE ND 0.5

Vinyl Chloride ND 0.5

1,4-Dioxane ND 2

BAMW21 1,1,1-TCA ND 0.5 7, p. 209

1,1-DCE ND 0.5

TCE ND 0.5

Vinyl Chloride ND 0.5

1,4-Dioxane ND 2

BAMW22 1,1,1-TCA 0.3J 0.5 7, p. 227

1,1-DCE ND 0.5

TCE ND 0.5

Vinyl Chloride ND 0.5

1,4-Dioxane ND 2

BAMW32S 1,1,1-TCA ND 0.5 7, p. 221

1,1-DCE ND 0.5

TCE ND 0.5

Vinyl Chloride ND 0.5

1,4-Dioxane ND 2
GW-Observed Release

22

Background Concentrations (continued)

Monitoring wells (continued)

Sample ID Hazardous Substance Concentration 

(μg/L)

LOQ1 (μg/L) Reference(s)

BAMW32D 1,1,1-TCA ND 0.5 7, p. 223

1,1-DCE ND 0.5

TCE 0.2J 0.5

Vinyl Chloride ND 0.5

1,4-Dioxane ND 2

BAMW36S 1,1,1-TCA ND 0.5 7, p. 251

1,1-DCE ND 0.5

TCE ND 0.5

Vinyl Chloride ND 0.5

1,4-Dioxane ND 2 1 The LOQ is equivalent to the HRS-defined Sample Quantitation Limit (SQL), i.e., the quantity of a substance that can reasonably be quantified 

given the limits of detection for the methods of analysis and sample characteristics that may affect quantitation such as dilution or concentration

[Refs. 1, p. 51586, 51589; 31, p. 1].

J - estimated value – The result is ≥ the Method Detection Limit (MDL) and < the Limit of Quantitation (LOQ) (Ref. 7, p. 263). Based on the 

definition of the qualifier, no bias is associated with this result. Therefore, the analyte’s background concentration equals the SQL (Ref. 1, p. 

51589, Table 2-3; 32, p. 8).

Background Concentrations

Residential Wells

Sample ID Sample Date Hazardous 

Substance

Concentration 

(μg/L)

SQL1 (μg/L) Reference(s)

2096H 7/6/11 1,1,1-TCA ND 0.25 12, pp. 1-2; 13, pp. 65-71, 

1,1-DCE ND 0.25 165, and 186; 34, p. 1 

TCE ND 0.25

Vinyl Chloride ND 0.25

1,4-Dioxane ND 5

2179H 7/6/11 1,1,1-TCA ND 0.25 12, p. 3; 13, pp. 72-78, 

1,1-DCE ND 0.25 167, and 187; 34, p. 1

TCE ND 0.25

Vinyl Chloride ND 0.25

1,4-Dioxane ND 5 1 For the residential well data, SQL is defined as being equivalent to the HRS-defined SQL, i.e., the quantity of a substance that can reasonably be 

quantified given the limits of detection for the methods of analysis and sample characteristics that may affect quantitation such as dilution or 

concentration [Refs. 1, p. 51586, 51589; 34, p. 1].
GW-Observed Release

23

Contaminated Samples

Monitoring wells

Sample ID Surface 

Elevation

(msl)

Completed 

Well

Depth

(feet bgs)

Screened 

Interval

(feet bgs/

msl)*

Formation Sample

Date 

Reference(s)

BAMW5S 302.30 100 69-99/

233.30-203.30

Brunswick 11/13/12 6, pp. 16, 70, 115, 116; 7, pp. 

79, 195

BAMW5D 302.45 149 119-149/

183.45-153.45

Brunswick 11/13/12 6, pp. 16, 70, 117, 118; 7, pp. 

93, 195

BAMW7S 294.55 118 101-116/

193.55-178.55

Brunswick 11/13/12 6, pp. 16, 71, 125, 126; 7, pp. 

92, 195

BAMW7D 294.55 203 125-140/

169.55-154.55

Brunswick 11/13/12 6, pp. 16, 71, 127-129; 7, pp. 

91, 195

BAMW9 311.39 101 60-100/

251.39-211.39

Brunswick/

Lockatong

11/13/12 6, pp. 16, 70, 134, 135; 7, pp. 

90, 195

BAMW10S 288.74 102 72-102/

216.74-186.74

Brunswick 11/14/12 6, pp. 16, 68, 71, 136, 137; 7, 

pp. 95, 260

BAMW10D 288.87 132 112-132/

176.87-156.87

Brunswick/

Lockatong

11/14/12 6, pp. 16, 68, 71, 138, 139; 7, 

pp. 94, 260

BAMW11S 301.46 15 5-15/

296.46-286.46

Lockatong 11/20/12 6, pp. 16, 68, 69,70, 140; 7, 

pp. 113, 296

BAMW11D 300.74 42 20-40/

280.74-260.74

Lockatong 11/20/12 6, pp. 16, 68, 69, 70, 141; 7, 

pp. 114, 296

BAMW12S 332.2 55 35-55/

297.2-277.2

Brunswick 11/19/12 6, pp. 16, 69, 142; 7, pp. 111, 

296

BAMW12D 332.2 110 90-110/

242.2-222.2

Lockatong 11/19/12 6, pp. 16, 69, 143, 144; 7, pp. 

110, 296

BAMW13 357.23 25 15-25/

342.23-332.23

Lockatong 11/15/12 6, pp. 16, 70, 145; 7, pp. 96, 

260

BAMW14 327.92 25 15-25/

312.92-302.92

Lockatong 11/19/12 6, pp. 16, 146; 7, pp. 112, 

296; 33, p. 1

BAMW15S 277.71 70 50-70/

227.71-207.71

Brunswick 11/14/12 6, pp. 16, 69, 147, 148; 7, pp. 

80, 261

BAMW15D 277.71 103 81-103/

196.71-174.71

Brunswick/

Lockatong

11/14/12 6, pp. 16, 69, 149, 150; 7, pp. 

78, 261

BAMW16 350.85 32 12-32/

338.85-318.85

Brunswick/

Lockatong

11/19/12 6, pp. 16, 71, 151; 7, pp. 109, 

296

BAMW17 359.04 25 15-25/

344.04-334.04

Lockatong 11/14/12 6, pp. 16, 71 152; 7, pp. 82, 

260

BAMW18 359.04 20 10-20/

349.04-339.04

Lockatong 11/14/12 6, pp. 16, 153; 7, pp. 84, 260; 

33, p. 1

BAMW19S 321.16 52 16-36/

305.16-285.15

Brunswick 11/13/12 6, pp. 16, 70, 154; 7, pp. 88, 

195

BAMW19D 321.16 52 42-52/

297.16-269.16

Lockatong 11/13/12 6, pp. 16, 70, 155; 7, pp. 87, 

195

BAMW25S 292.79 144 124-144/

168.79-148.79

Brunswick 11/16/12 6, pp. 16, 70, 71, 164, 165; 7, 

pp. 104, 262

BAMW25D 292.84 188 168-188/

124.84-104.84

Lockatong 11/16/12 6, pp. 16, 70, 71 166, 167, 

168; 7, pp. 105, 262
GW-Observed Release

24

Contaminated Samples (continued)

Monitoring wells (continued)

Sample ID Surface 

Elevation

(msl)

Completed 

Well

Depth

(feet bgs)

Screened 

Interval

(feet bgs/

msl)*

Formation Sample

Date 

Reference(s)

BAMW28S 338.85 31 20-30/

318.85-308.85

Brunswick 11/13/12 7, pp. 86, 195; 19, pp. 95-96; 

33, p. 1

BAMW28D 338.85 41 36-41/

302.85-297.85

Lockatong 11/13/12 7, pp. 85, 195; 19, pp. 97, 98; 

33, p. 1

BAMW30 359.29 70 60-70/

299.29-289.29

Lockatong 11/14/12 7, pp. 81, 260; 19, pp. 101-

103; 33, p. 1

BAMW33S 294.01 143 121-141/

173.01-153.01

Brunswick 11/15/12 7, pp. 103, 261; 19, pp. 117-

121; 33, p. 1

BAMW33D 294.01 158 147-157/

147.01-137.01

Brunswick/

Lockatong

11/16/12 7, pp. 102, 261; 19, pp. 122-

127; 33, p. 1

BAMW34S 234.54 146 123-143/

111.54-91.54

Brunswick 11/20/12 7, pp. 115, 296; 19, pp. 128-

132; 33, p. 1

BAMW34D 234.54 203 193-203/

41.54-31.54

Brunswick 11/20/12 7, pp. 116, 297; 19, pp. 133-

139; 33, p. 1

bgs – below ground surface

msl – mean sea level

* msl screened interval determined by subtracting the depth in feet bgs from the surface elevation 

Sample ID Hazardous Substance Concentration 

(μg/L)

LOQ1(μg/L) Reference(s)

BAMW5S 1,1,1-TCA 10 0.5 7, p. 176

1,1-DCE 18 0.5

1,4-Dioxane 22 2

BAMW5D 1,1,1-TCA 94 10 7, p. 168

1,1-DCE 29 10

TCE 0.7 0.5

1,4-Dioxane 6.4 4

BAMW7S 1,1,1-TCA 1,800 250 7, p. 180

1,1-DCE 1,200 25

1,4-Dioxane 83 20

BAMW7D 1,1,1-TCA 2,500 250 7, p. 178

1,1-DCE 1,500 250

1,4-Dioxane 90 10

BAMW9 1,1,1-TCA 4,400 500 7, p. 174

1,1-DCE 990 50

1,4-Dioxane 210 20

BAMW10S 1,1,1-TCA 3,000 100 7, p. 213

1,1-DCE 1,900 100

TCE 27 10

1,4-Dioxane 130 40

BAMW10D 1,1,1-TCA 390 25 7, p. 215

1,1-DCE 290 25

TCE 16 2.5

1,4-Dioxane 47 20
GW-Observed Release

25

Contaminated Samples (continued)

Monitoring wells (Continued)

Sample ID Hazardous Substance Concentration 

(μg/L)

LOQ1(μg/L) Reference(s)

BAMW11S 1,1,1-TCA 160 10 7, p. 284

1,1-DCE 20 0.5

1,4-Dioxane 4.9 2

BAMW11D 1,1,1-TCA 700 25 7, p. 286

1,1-DCE 79 2.5

1,4-Dioxane 11 4

BAMW12S 1,1,1-TCA 1,900 50 7, p. 274

1,1-DCE 820 50

TCE 16 5

1,4-Dioxane 93 10

BAMW15S 1,1,1-TCA 1,900 100 7, p. 241

1,1-DCE 1,200 100

TCE 15 10

1,4-Dioxane 110 40

BAMW15D 1,1,1-TCA 63 5 7, p. 243

1,1-DCE 59 5

TCE 4.1 0.5

1,4-Dioxane 9.1 2

BAMW16 1,1,1-TCA 1,800 50 7, p. 270

1,1-DCE 170 5

1,4-Dioxane 37 10

BAMW17 1,1,1-TCA 220 10 7, p. 205

1,1-DCE 49 10

TCE 6.2 0.5

1,4-Dioxane 7.6 2

BAMW19S 1,1,1-TCA 15,000 1,000 7, p.172

1,1-DCE 2,300 100

1,4-Dioxane 180 40

BAMW19D 1,1,1-TCA 15,000 1,000 7, p. 170

1,1-DCE 1,300 100

1,4-Dioxane 220 40

BAMW25S 1,1,1-TCA 720 25 7, p. 247

1,1-DCE 270 25

1,4-Dioxane 31 4

BAMW25D 1,1,1-TCA 140 10 7, p. 249

1,1-DCE 470 10

TCE 4.6 1

Vinyl Chloride 2 1

1,4-Dioxane 23 2

BAMW28D 1,1,1-TCA 18,000 1,000 7, p. 164

1,1-DCE 1,000 100

1,4-Dioxane 180 40

BAMW33S 1,1,1-TCA 5,000 250 7, p. 235

1,1-DCE 1,800 250

1,4-Dioxane 110 10

BAMW33D 1,1,1-TCA 3.3 0.5 7, p. 239

1,1-DCE 1.3 0.5
GW-Observed Release

26

Contaminated Samples (continued)

Monitoring wells (Continued)

Sample ID Hazardous Substance Concentration 

(μg/L)

LOQ1(μg/L) Reference(s)

BAMW34S 1,1,1-TCA 410 10 7, p. 288

1,1-DCE 220 10

TCE 2.6 1

1,4-Dioxane 24 4

BAMW34D 1,1,1-TCA 500 25 7, p. 290

1,1-DCE 290 25

TCE 3.2 1

1,4-Dioxane 29 4 1 The LOQ is equivalent to the HRS-defined SQL, i.e., the quantity of a substance that can reasonably be quantified given the limits of detection 

for the methods of analysis and sample characteristics that may affect quantitation such as dilution or concentration [Refs. 1, p. 51586, 51589; 31, 

p. 1].

Contaminated Samples (continued)

Residential wells

Sample ID Sample Date Hazardous 

Substance

Concentration 

(μg/L)

SQL1

(μg/L)

Reference(s)

1747H 7/6/11 1,1,1-TCA 217 2.5 12, p. 3; 13, pp. 5, 6, 8, 109, 

110, and 174; 

34, p. 1

1,1-DCE 99.4 2.5

TCE 1.47 0.25

1787H 7/27/11 1,1,1-TCA 244 2.5 12, p. 5; 13, pp. 25, 26, 28, 

1,1-DCE 155 2.5 29, 31, 97, 99, 192; 34, p. 1

TCE 1.67 0.25

1,4-Dioxane 15.9 5

1836H 7/14/11 1,1,1-TCA 551 2.5 12, p. 4; 13, pp. 91 and 93; 

1,1-DCE 338 2.5 34, p. 1

TCE 3.59 0.25

1886H 7/6/11 1,1,1-TCA 962 25 12, p. 2; 13, pp. 47, 48, 50, 

51, 53, 105, 163, and 185; 

34, p. 1

1,1-DCE 647 25

TCE 9.23 0.25

1,4-Dioxane 69.6 5

1898H 10/12/11 1,1,1-TCA 190 2.5 12, p. 8; 13, pp. 54-57, 101, 

1,1-DCE 123 2.5 and 103; 34, p. 1

TCE 0.833 0.25

1926H 7/6/11 1,1,1-TCA 43.9 0.25 12, p. 3; 13, pp. 59, 61, and 

1,1-DCE 4.17 0.25 169; 34, p. 1

1744B

(Common 

Well) 

7/6/11 1,1,1-TCA 44.8 0.25 12, p. 3; 13, pp. 79, 80, 82-

84, 176, and 189; 21, pp. 1-

2; 34, p. 1

1,1-DCE 31.8 0.25

TCE 0.368 0.25

1,4-Dioxane 5.79 5

1746B 7/7/11 1,1,1-TCA 365 2.5 12, p. 4; 13, pp. 1, 2, 4, 113, 

1,1-DCE 232 2.5 and 115; 34, p. 1

TCE 2.54 0.25

1760B 7/6/11 1,1,1-TCA 370 2.5 12, p. 3, 13, pp. 9, 10, 12, 

1,1-DCE 234 2.5 107and 171; 34, p. 1

TCE 2.56 0.25
GW-Observed Release

27

Sample ID Sample Date Hazardous 

Substance

Concentration 

(μg/L)

SQL

(μg/L)

Reference(s)

1767B 7/14/11 1,1,1-TCA 335 2.5 12, p. 4; 13, pp. 13, 14, 16, 

1,1-DCE 236 2.5 119, and 121; 34, p. 1

TCE 2.22 0.25

1775B 7/14/11 1,1,1-TCA 399 2.5 12, p. 4; 13, pp. 17, 18, 20, 

1,1-DCE 265 2.5 87, and 89; 34, p. 1

TCE 2.52 0.25

1780B 7/7/11 1,1,1-TCA 16.6 0.25 12, p. 4; 13, pp. 21, 22, 24, 

1,1-DCE 10.2 0.25 and 117; 28. p. 1; 34, p. 1

1800B 7/6/11 1,1,1-TCA 101 2.5 12, p. 2; 13, pp. 32, 33, 35, 

TCE 0.723 0.25 123, and 161; 34, p. 1

1810B 7/6/11 1,1,1-TCA 561 2.5 12, p. 2; 13, pp. 37, 39, 40, 

1,1-DCE 319 2.5 42, 85 159, and 184; 34, p. 1

1,4-Dioxane 32.2 5 1 For the residential well data, SQL is defined as being equivalent to the HRS-defined SQL, i.e., the quantity of a substance that can reasonably be 

quantified given the limits of detection for the methods of analysis and sample characteristics that may affect quantitation such as dilution or 

concentration [Refs. 1, p. 51586, 51589; 34, p. 1].
GW-Observed Release

28

Attribution:

The hazardous substances associated with the site are not naturally occurring [Refs. 16, p. 1; 17, p. 1]. 1,1,1-TCA 

and TCE are man-made chlorinated solvents that are commonly used as cleaning and degreasing agents, while 1,1-

DCE and vinyl chloride can be degradation breakdown products of either or both 1,1,1-TCA and TCE [Refs. 6, p. 

48; 16, p. 1; 17, p. 1; 30, p. 1]. Additionally, 1,4-dioxane was historically used as a stabilizer for chlorinated 

solvents, primarily 1,1,1-TCA [Ref. 25, p. 1]. 

In April 2001, PADEP contracted Foster Wheeler to conduct a source investigation for the VOCs detected in the 

residential wells. The source investigation focused on a 29-acre farm property located at on Hendricks Road. The 

investigation consisted of advancing 225 soil borings, collecting 363 soil samples, installing 21 bedrock monitoring 

wells, collecting ground water samples from the monitoring wells during four separate sampling events conducted 

between July 2001 and January 2003, and the collection of 42 surface water samples from seeps and stream water 

during three separate sampling events conducted in February, March-April, and November 2002 [Ref 6, pp. 7, 9, 22, 

23, 38, and 55). Analytical results of the source investigation indicated the presence of chlorinated VOCs (primarily 

1,1,1-TCA, 1,1-DCE, 1,1-DCA, vinyl chloride, and TCE) in soil, ground water and surface water. The report 

concluded that the core area of the highest chlorinated VOC concentrations in ground water (based on spatial 

concentrations) was located on the farm property on Hendricks Road and had migrated approximately 800 feet 

downgradient in a west-southwest direction; however, the consumptive use in the Baghurst Drive residential 

neighborhood has an influence on the direction of ground water flow to the south [Ref. 6, pp. 55, 56, 73, and 74]. 

Of the 225 soil borings advanced and 363 soil samples collected on the farm property, thirty-three contained 1,1,1-

TCA (maximum concentration of 180 μg/kg), four contained 1,1-DCE (maximum concentration of 18 μg/kg), two 

contained 1,1-DCA (maximum concentration of 10 μg/kg, and seven contained TCE (maximum concentration of 24 

μg/kg) [Ref. 6, pp. 40, 103, 104, 421-422, 430-431, 436, 451, 455-456, 462, 465-469, 472-474, and 477-478]. Due 

to the relatively low levels of contaminants detected and the small number of samples containing contaminants, EPA 

could not confirm that the soil contamination detected between 2001 and 2002 on the farm property is contributing 

to, or is a significant contributor of, the ground water contamination being scored. 

Over the past decade during numerous rounds of sampling events, affected residents have alleged to PADEP that 

dumping of waste had occurred on the farm property [Ref. 20]. PADEP conducted several investigative interviews 

with the farm property owner and nearby residents; however, the agency was unsuccessful in documenting that 

waste was in fact dumped on the property and in identifying potential responsible parties [Ref. 20]. The farm 

property owners have maintained that, to their knowledge, waste was never dumped on the property [Ref. 20]. The 

site is located in a rural area with no discernible industrial or commercial facilities within a half-mile radius of the 

site [Refs. 4 and 20].

No other potential sources for the ground water contamination comprising the plume have been identified. A search 

of the Envirofacts® database identified nine facilities with National Pollution Discharge Elimination System 

(NPDES) permits within approximately 1 mile of the site reference point. Six of these facilities are identified as

individual private residences, a subdivision, or dwelling other than apartments; two are sewage treatment facilities; 

and one is a bulk fuel storage facility. The NPDES permits for all nine facilities are for discharges from nonPublicly Owned Treatment Works (POTW) systems. No violations were noted at any of the facilities. One Toxics 

Release Inventory (TRI) facility was identified. This facility is listed as being a metal fabricator that transports 

chromium compounds offsite for recycling. This facility is located more than 1.5 miles from the site and is not 

expected to be the source or contribute to the source of contamination at the site [Ref. 29, pp. 1-46]. 

Hazardous Substances Released:

1,1,1-Trichloroethane (1,1,1-TCA) 

1,1-Dichlorothene (1,1-DCE)

Trichloroethylene (TCE) 

Vinyl Chloride

1,4-Dioxane

==================================================================================

 Ground Water Observed Release Factor Value: 550
GW-Waste Characteristics

29

3.2 WASTE CHARACTERISTICS

3.2.1 Toxicity/Mobility

Hazardous Substance Source 

Numbers

Toxicity 

Factor Value

Mobility 

Factor Value

Toxicity/ 

Mobility

Reference

1,1,1-TCA 1, OR 1 1.0 1 2, p. 10

1,1-DCE 1, OR 10 1.0 10 2, p. 4

TCE 1, OR 1,000 1.0 1,000 2, p. 10

Vinyl Chloride 1, OR 10,000 1.0 10,000 2, p. 10

1,4-Dioxane 1, OR 100 1.0 100 2, p. 5

OR = Observed Release

3.2.2 Hazardous Waste Quantity

Source Number Source Hazardous Waste Quantity 

(HWQ) Value (Ref. 1 Section 2.4.2.1.5)

Is source hazardous constituent 

quantity data complete? (yes/no)

1 >0 No

Sum of Values: >0

The sum corresponds to a hazardous waste quantity factor value of 1 in Table 2-6 of the HRS [Ref. 1, p. 51591]. 

However, based on the fact that the hazardous constituent quantity is not adequately determined (see Section 

2.4.2.1.1 of this HRS documentation record) and targets are subject to Level I concentrations (see Section 3.3.2.3 of 

this HRS documentation record), a hazardous waste quantity factor value of 100 is assigned if it is greater than the 

hazardous waste quantity value from Table 2-6 (i.e., 1) [Ref. 1, pp 51591-51592, Section 2.4.2.2]. Therefore, a 

hazardous waste quantity factor value of 100 is assigned for the ground water pathway [Ref. 1, pp 51591-51592, 

Section 2.4.2.2]. 

3.2.3 Waste Characteristics Factor Category Value

Vinyl chloride corresponds to the toxicity/mobility factor value of 10,000, as shown previously (see Section 3.2.1 of 

this HRS documentation record).

Toxicity/Mobility Factor Value (10,000) x Hazardous

Waste Quantity Factor Value (100): 1 x 106

The product (1 x 106

) corresponds to a Waste Characteristics Factor Category Value of 32 in Table 2-7 of the HRS 

[Ref. 1, p. 51592].

==================================================================================

Hazardous Waste Quantity Factor Value: 100

Waste Characteristics Factor Category Value: 32
GW-Targets/Nearest Well

30

3.3 TARGETS

In 1999, PADEP began supplying bottled water and connected carbon filtration systems to 27 residences in the 

vicinity of the site [Ref. 10, p. 2]. However, because they are sufficient to score the site, for the purpose of this HRS 

documentation record, the target populations being evaluated are the persons who obtain drinking water from the 14 

residential drinking water wells that were sampled between July and October 2011 that contain contaminants 

attributable to the site [Ref. 12, pp. 1-8]. Twelve of the wells, including one common well that supplies drinking 

water to 10 residences, contained contaminants attributable to the site at concentrations exceeding applicable 

benchmarks as presented in Section 3.3.2.2 of this HRS documentation record [Ref. 21, pp. 1-2]. 

The residents who reside at the homes with the wells that are being used to score the site are currently being 

provided with bottled water for drinking purposes. The wells being used to score the site are also equipped with 

treatment systems. The provided bottled water and treatment systems are a direct result of site related contaminants 

and are provided by PADEP under its interim Response Action for the site [Ref. 28, pp. 1-3]. 

3.3.1 Nearest Well

Because actual contamination at Level I concentrations has been documented, a nearest well factor value of 50 is 

assigned [Ref. 1, pp. 51602, 51603, Section 3.3.1].

==================================================================================

Nearest Well Factor Value: 50
GW-Population/Level I

31

3.3.2 Population

3.3.2.1 Level of Contamination

3.3.2.2 Level I Contamination 

Sample Substance Concentration

(μg/L)

Benchmark

Concentration* 

(μg/L)

Benchmark 

Type* 

Reference(s)

1747H 1,1,1-TCA 217 200 MCL 2, p. 25; 13, p. 5

1,1-DCE 99.4 7 MCL 2, p. 18; 13, p. 6

TCE 1.47 1 CRSC 2, p. 25; 13, p. 5

1787H 1,1,1-TCA 244 200 MCL 2, p. 25; 13, p. 25

1,1-DCE 155 7 MCL 2, p. 18; 13, p. 26

TCE 1.67 1 CRSC 2, p. 25; 13, p. 26

1,4-Dioxane 15.9 0.6 CRSC 2, p. 19; 13, p. 29

1836H 1,1,1-TCA 551 200 MCL 2, p. 25; 13, p. 93

1,1-DCE 338 7 MCL 2, p. 18; 13, p. 93

TCE 3.529 1 CRSC 2, p. 25; 13, p. 91

1886H 1,1,1-TCA 962 200 MCL 2, p. 25; 13, p. 47

1,1-DCE 647 7 MCL 2, p. 18; 13, p. 48

TCE 9.23 1 CRSC 2, p. 25; 13, p. 47

1,4-Dioxane 69.6 0.6 CRSC 2, p. 19; 13, p. 51

1898H 1,1,-DCE 123 7 MCL 2, p. 18; 13, p. 56

Common Well 1,1-DCE 31.8 7 MCL 2, p. 18; 13, p. 80

1,4-Dioxane 5.79 0.6 CRSC 2, p. 19; 13, p. 83

1746B 1,1,1-TCA 365 200 MCL 2, p. 25; 13, p. 2

1,1-DCE 232 7 MCL 2, p. 18; 13. p. 2

TCE 2.54 1 CRSC 2, p. 25; 13, p. 1

1760B 1,1,1-TCA 370 200 MCL 2, p. 25; 13, p. 10

1,1-DCE 234 7 MCL 2, p. 18; 13, p. 10

TCE 2.56 1 CRSC 2, p. 25; 13, p. 9

1767B 1,1,1-TCA 335 200 MCL 2, p. 25; 13, p. 14

1,1-DCE 236 7 MCL 2, p. 18; 13, p. 14

TCE 2.22 1 CRSC 2, p. 25; 13, p. 13

1775B 1,1,1-TCA 399 200 MCL 2, p. 25; 13, p. 18

1,1-DCE 265 7 MCL 2, p. 18; 13, p. 18

TCE 2.52 1 CRSC 2, p. 25; 13, p. 17

1780B 1,1-DCE 10.2 7 MCL 2, p. 18; 13, p. 21

1810B 1,1,1-TCA 561 200 MCL 2, p. 25; 13, p. 37

1,1-DCE 319 7 MCL 2, p. 18; 13, p. 37

1,4-Dioxane 32.2 0.6 CRSC 2, p. 19; 13, p. 40

* Maximum Contaminant Level/Maximum Contaminant Level Goal (MCL/MCLG), Reference Dose Screen Concentration

(RfD), and Cancer Risk Screen Concentration (CRSC) are used as benchmarks for 1,1,1-TCA, 1,1-DCE, TCE, and 1,4-dioxane

[Ref. 1, p. 51593, Section 2.5.2; 2, pp. 18, 19, 25, and 43]. The lowest applicable benchmark is listed and used for 

determination of the level of actual contamination at each sampling location [Ref. 1, pp. 51592-51593, Sections 2.5.1 and 

2.5.2]. 
GW-Population/Level I

32

Residential Well Location Population Served Reference(s)

1747H 2.53 23, p. 1; 35, p. 1

1787H 4 23, p. 1; 35, p. 1

1836H 5 23, p. 1; 35, p. 1

1886H 2 23, p. 1; 35, p. 1

1898H 2 23, p. 1; 35, p. 1

1744H (Common Well) 25.64 21, pp. 1, 2; 23, p. 1; 35, p. 1

1746B 2 23, p. 1; 35, p. 1

1760B 3 23, p. 1; 35, p. 1

1767B 0 23, p. 1; 35, p. 1

1775B 2 23, p. 1; 35, p. 1

1780B 4 23, p. 1; 35, p. 1

1810B 2 23, p. 1; 35, p. 1

Total Population 54.17

As shown in the tables above, 11 residential drinking water wells, including one common well that supplies drinking 

water to 10 residences, are subject to Level I concentrations. Several attempts were made to contact the residences 

to obtain an accurate count of persons per household. An accurate persons per household count was obtained for 13

of the 21 residences (11 individual domestic well locations and the 10 residences supplied by the common well)

with wells containing contaminant observed release concentrations above health-based benchmarks. The remaining 

eight residences could not be reached or did not have an active listed phone number; therefore, the county average of 

2.53 persons per household for Montgomery County as currently reported by the U.S. Census Bureau was used to 

determine the population at those residences. The total population served by drinking water from points of 

withdrawal subject to Level I concentrations is 54.17 [Ref. 1, p. 51603, Section 3.3.2.2; 21, pp. 1, 2; 23, p. 1; 35, p. 

1]. This population is multiplied by 10 to determine the Level I concentrations factor value, as shown below [Ref. 1, 

p. 51603, Section 3.3.2.2].

==================================================================================

Total Level I Population: 54.17 

Level I Concentration Factor Value: 52.92 x 10 = 541.70 

(Ref. 1, p. 51603, Section 3.3.2.2) 
GW-Level II/Potential/Resources/Wellhead Protection

33

3.3.2.3 Level II Concentrations

In addition to the drinking water wells subject to Level I concentrations, there are two separate residential wells 

subject to Level II concentrations (i.e., below all applicable benchmarks), as follows:

Sample Substance Concentration (μg/L) Reference(s)

1926H 1,1,1-TCA 43.9 13, p. 59

1,1-DCE 4.17 13, p. 59

1800B 1,1,1-TCA 101 13, p. 33

TCE 0.723 13, p. 32

As shown in the table above, two single-household residential wells are subject to Level II concentrations; however, 

currently, the residence from which sample 1800B was collected is not used as a permanent residence. One person 

currently resides at sample location 1926H. Therefore the total population served by drinking water from points of 

withdrawal subject to Level II concentrations is 1 [Ref. 1, p. 51603, Section 3.3.2.3; 35, p. 1]. This population is 

assigned as the Level II concentrations factor value, as shown below [Ref. 1, p. 51603, Section 3.3.2.3]

==================================================================================

Population Served by Level II Wells: 1

Level II Concentrations Factor Value: 1

[Ref. 1, p. 51603, Section 3.3.2.3]

3.3.2.4 Potential Contamination

Since Level I and Level II concentrations result in a maximum score of 100.00 for the ground water migration 

pathway, the Potential Contamination Factor Value was not scored.

Potential Contamination Factor Value: NS

3.3.3 Resources

Since Level I and Level II concentrations result in a maximum score of 100.00 for the ground water migration 

pathway, the Resources Factor Value was not scored.

==================================================================================

Resources Factor Value: NS

3.3.4 Wellhead Protection Area

Since Level I and Level II concentrations result in a maximum score of 100.00 for the ground water migration 

pathway, the Wellhead Protection Area Factor Value was not scored.

==================================================================================

Wellhead Protection Area Factor Value: NS