United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD.R03.85^016
September 1985
Superfund
Record  of  Decision
Douglassville,  PA

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TECHNICAL REPORT DATA
(Please readjust met ions on the reverse before completing/
1. REPORT NO.
EPA/ROD/R03-85/016
2. —
*. TITLE AND SUBTITLE
SUPERFUND RECORD OF DECISION
Douglassville, PA

7. AUTHOR(S)
8. PERFORMING ORGANIZATION NAME AND ADDRESS


12. SPONSORING AGENCY NAME AND ADDRESS
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460

3. RECIPIENT'S ACCESSION NO.
S. REPORT DATE
September 27, 1985
6. PERFORMING ORGANIZATION CODE
8. PERFORMING ORGANIZATION REPORT NO.
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
13. TYPE OF REPORT AND PERIOD COVERED
Final ROD Report
14. SPONSORING AGENCY CODE
800/00
15. SUPPLEMENTARY NOTES
16. ABSTRACT
The Douglassville Disposal Site occupies approximately 50 acres of land along the
southern bank of the Schuylkill River in southeastern Berks County, Union Township,
Pennsylvania. Site operations included lubricating oil recycling in 1941 and waste
solvents recycling in the 1950 's and 1960 's. Wastes generated from these operations
were stored in several lagoons located in the northern half of the site until 1972.
In November 1970, ten days of heavy rain caused the lagoons to overflow and breach
safety dikes releasing 2-3 million gallons of wastes. The dikes were repaired and a
Federal decree was issued stating that no more waste material was to be stored in t
lagoons. Actions were also initiated to dispose of remaining waste materials. Bei
this action could be carried out, tropical storm Agnes caused the Schuylkill River to
overflow its banks and inundate the entire site. An estimated 6 to 8 million gallons
of wastes were released and carried downstream by floodwaters for about 15 miles. Oil
recycling operations continued until 1979 when corrections mandated by the Pennsyl-
vania Department of Environmental Resources (PADER) became cost-prohibitive. The
site operators then turned to refining waste oils for use as fuel in industrial
boilers, and oily waste sludge from this new recycling process was landfarmed in the
area of the old western lagoon. PADER halted this practice in 1981, and mandated
operational corrections to the landfann configuration.
(see separate sheet)
17.
a. DESCRIPTORS
KEY WORDS AND DOCUMENT ANALYSIS
b.lDENTIFIERS/OPEN ENDED TERMS
Record of Decision
Douglassville, PA
Contaminated Media: gw, sw, sediment, soils
Key contaminants: VOCs, inorganics, phenol,
arsenic, chromium, PCBs, PAHs, pesticides,
acids
18. DISTRIBUTION STATEMENT
19. SECURITY CLASS (This Report/
None
20. SECURITY CLASS (This page I
None

c. COSATI Field/Group

43
22. PRICE
EPA Form 2220-1 (R.v. 4-77)    PREVIOUS EDITION it OBSOLETE

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                                                        INSTRUCTIONS

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        Insert the LPA report number a it appears on the cover of the publication.

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        type or otherwise subordinate it to main title. When a report is prepared in more than one volume, repeat Hie primary lille. add volume
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    S.   REPORT DATE
        Etch report snail carry a date indicating at least month and year. Indicate the lusts -on which it was selected (e.g.. Jai, u] isuii: Jaic <>J
        approval, date of preparation, etc. I.

    6.   PERFORMING ORGANIZATION CODE
        Leave blank.

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        Give name(.s> in conventional order fJolin R. Doc. J. Robert Doc. etc./.  Lift author's affiliation if it differs from (he ivrformim; ..utili-
        zation.

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    11.  CONTRACT/GRANT NUMBER
        Insert contract or grant number under which report was prepared.

    12.  SPONSORING AGENCY NAME AND ADDRESS
        Include ZIP code.

    13.  TYPE OF REPORT AND PERIOD COVERED
        Indicate interim final, etc., and if applicable, dates covered.

    14.  SPONSORING AGkNCY CODE
        Insert appropriate code.

    15.  SUPPLEMENTARY NOTES
        Enter information not included elsewhere but useful, such as:  Prepared in cooperation with. I raiisladuii ul. I'rcsciilctl ji fonii-u-mc- <>i.
        To be published in. Supersedes, Supplements, etc.

    16.  ABSTRACT
        Include a brief (200 words or less) factual summary of the most significant information contained  m Hie report.  It the repot I tnniams j
        significant bibliography or literature survey, mention it here.

    17.  KEY WORDS AND DOCUMENT ANALYSIS
        (a) DESCRIPTORS - Select  from the Thesaurus of Engineering and Scientific Terms the proper autlmri/cJ Ictms Hut identify the major
        concept of the research and are sufficiently specific and precise to be used as index entries for cataloging.

        (b) IDENTIHERS AND  OPEN-ENDED TERMS - Use identifiers for project names, code names, equipment designators, etc. Use open-
        ended terms written in descriptor form for those subjects for which no descriptor exists.

        (c) COSAT1 I H:i_D GROUP • Held and group assignments are to be taken from the 1965 COS AM Subject Category List. Since the ma-
        jority of documents are multidisciplinary in  nature, the Primary I icld/droup assignmcntls) will be specific discipline, area of human
        endeavor, or type of physical object. The application(s) will be cross-referenced with secondary  I ii-KI/(.rou|> assignments tlul will lollou
        the primary posling(s).

   18.  DISTRIBUTION STATEMENT
        Denote releasability to the public or limitation for reasons other than security for example "Release Unliiuiicil." file any availability in
        the public, with address  and price.

    19.8i 20. SECURITY CLASSIFICATION
        DO NOT submit classified reports to the National Technical Information service.

   21.  NUMBER OF PAGES
        Insert the total number of pages, including this one and unnumbered pages, but exclude distribution list, il any.

   22.  PRICE
        Insert the price set by the National Technical Information Service or the Government Printing Office, il known.
EPA Form 2220-1  (R.». 4-77) (R...r,.)

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SUPERFUND RECORD OF DECISION

Douglassville, PA

Abstract - continued

     The selected remedial action for this site includes:  removal and
consolidation in the facility sludge disposal area, of contaminated soils and
sediments from the waste water treatment drainage ditch, drainage swale, buried
lagoon and drum disposal area to a depth to be determined in the pre-design study;1
capping of the former sludge lagoon area and the facility sludge disposal area
in accordance with RCRA standards; installation of levees and dikes to protect
the site from the 100-year flood in compliance with Executive Order 11988; a
pre-design study of the contaminated soils to determine the extent of the
areas to be capped and the extent of soils to be excavated from the drainage
ditch areas.  Total capital cost for the selected remedial alternative is
estimated to be $5,569,500 with O&M costs approximately $196,000 per year.
Ground water pumping and treating and construction of the slurry wall are being
deferred until a supplemental RI/FS is completed.

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                           RECORD OF DECISION
                 REMEDIAL ACTION ALTERNATIVE SELECTION

 Sice:   Douglassville  Disposal  Site, Berks Couity, Pennsylvania

 Documents Reviewed;                                       ....

     I  am basing my decision principally on the following documents
 describing Che analysis  of cost-effecCiveness and feasibility of
 remedial  alternatives for Che  Douglassville Disposal Sice.  Unless
 otherwise specified,  Che underlying technical information Is Included
 in  chese  reporcs.

 -   "Remedial  Investigation Report/Feasibility SCudy of Alternatives",
    (Draft), Berks Associates,  Douglassville Disposal Sice, Berks County,
    Pennsylvania,  (NUS Corporation, June, 1985).

    Summary of Remedial Alternative Selection.

 -   Recommendations by Che Pennsylvania Department of Environmental
    Resources.

 -   Staff  summaries and recommendations, including chese attached.

 Description of Che Selected Remedy;

 -   Removal and consolidation of contaminated soils and sediments from
    Che  waste  water treatment drainage ditch, drainage swale, buried lagoon
    and  drum disposal  area Co a volume to be determined in a pre-design
    study.  The materials  will  be consolidated in the facility sludge disposal
    area and will  be capped in  accordance with the Resource Conservation and
    Recovery Act (RCRA) standards.

 -   Installation of an impermeable cap which complies with Che require-
    ments  of RCRA 40 C.F.R. §264.228(a)(2) on the former sludge lagoon
    area and the facility  sludge disposal area*

 -   Installation of levees and  dikes to protect the site from the 100
    year flood  event in compliance with Executive Order 11988.

 -   Pre-Design study of soils at the site to determine the exact extent
    of theTreas to be capped and the extent of soils to be excavated
    from the drainage  ditch areas.


 Operation and  Maintenance:

     Operation and maintenance will be conducted by the State one year
 subsequent to  the  completion of the above remedial actions.  Operation
 and Maintenance will  be performed on the caps, the dike/levee and the
monitoring system  (including compliance monitoring) in accordance with
RCRA guidance.

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Declarations

     Consistent with the Comprehensive Environmental Response, Compensation
and Liability Act of 1980  (CERCLA) and the National Contingency Plan
(40 C.F.R. Part 300), I have determined that the remedial actions
described above together with proper operation and maintenance constitute
a cost-effective remedy which mit'gates aiid minimizes damage to.public
health, welfare, and the environment.  The remedial action will be
designed to minimize the risk of potential evacuation and temporary
inconveniences to the local population during the excavation and
consolidation phases.

     The State of Pennsylvania has been consulted and agrees with the
approved remedy.  Following placement and installation of the caps and
flood protection structures at the locations Identified In the "Summary
of Remedial Alternative Selection", operation and maintenance activities
will be required to ensure the continued effectiveness and level of
protection of the remedy.   These activities will be considered part of the
approved action and eligible for Trust Fund monies for a period of one
(1) year.  Land use restrictions may also be necessary to ensure the
effectiveness of the remedy.

     In addition, excavation of the contaminated soils and sediments
from the waste water treatment drainage ditch area and consolidation of
this waste in the facility sludge disposal area is necessary to protect
public health, welfare, and the environment.

     I am deferring selection of remedial response measures that involve
active ground water remediation, I.e., pumping and treatment and
construction of the slurry wall.  Further assessment of the nature of
detected contamination and its Impact on the Schulkill River needs to
be assessed further.

     I have determined that the action being taken is appropriate when
balanced against the availability of Trust Fund monies for use at other
sites.
           Date                           (/James M. Sei{/
                                            Regional Administrator
                                                 EPA Region III

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                 Summary of  Remedial Alternative Selection
                       Douglassville Disposal Site
 Site  Location  and Description

      The  Douglassville  Disposal Site occupies approximately 50 acres of
 land  in southeastern Berks County, Union Township, Pennsylvania, along
 the southern bank of the  Schuylkill River  (Figure 1).  State Route 724
 borders the southern edge of the site, and a Penn Central/Conrail
 Railroad  right-of-way extends through the site in an east-west direction
 (Figure 2).  The site is  located approximately 3 miles northwest of
 Pottstown and  11 miles  southeast of Reading, Pennsylvania.  The site
 is located almost entirely within the 100-year floodplain.

      The  area  around the  site can be described as a rural setting consisting
 of cropland, plowed  fields, uncultivated fields, and light residential
 and industrial development.  Within a 1/4-mile radius of the site there
 are approximately 23 housing units sheltering an estimated 58 residents.
 A state adult  care facility, the Colonial Manor Adult Home, is located
 across  Highway 724 from the site.  The city of Pottstown, 2.36 miles
 downstream from  the  site  on the Schuylkill River, has an estimated
 population oft 35,000.  The town of Douglassville lies on the northern
 bank  of the river approximately 1/2-mile northeast of the site and has
 a population of  2,500 people.

      The  Schuylkill  River borders the site to the north and to the
 east.  This stretch  of  the river lies within the boundaries designated
 by the  Pennsylvania  Scenic Rivers Act of 1972 as a component of the
 Pennsylvania Scenic  Rivers System.  The river was ao designated for the
 purposes  of "conserving and enhancing its scenic quality and of promoting
 public  recreational  enjoyment in conjunction with various present and
 future uses of the river" (PADER, March, 1979).  The Schuylkill River is
 used  extensively for municipal and industrial water supply, recreation,
 and waste assimilation.   In the reach extending downstream of the
 Douglassville  Disposal  Site Co the confluence with the Delaware River,
 seven public water supply users withdraw water directly from the
 Schuylkill River (Figure  3).  The distance to the nearest public water
 supply is 4 miles.

     The Jlouglassville  Disposal Site is situated in the Triassic Lowland
 section of the Piedmont Province.  Rock in the general areas of the
 site is mapped as belonging to the Brunswick Formation which consists
 of Jurassic-Triassic aged, fine-to-coarse grained sedimentary rocks.
The predominant  member of the Brunswick Formation consists of red and
 maroon micaeous,  silty mudstone8 and shales.  Structural deformation
 is not severe.   Broad open dips of 25 degrees or less to the north -
 northwest are  prevalent.  However, normal faults are common and are
 located throughout the area.  Several fracture traces are located south
of the site and  it is probable that they project through the site In a
06° NW to 38°  NE direction.

     Ground water in this formation is controlled by secondary
permeability,  i.e.,  water flow takes place along joints, faults, and
bedding plans.   The  Brunswick Formation is generally capable of yielding

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                    _^=^??^^cl>^ ,4'£A fc ^feit^'Ntfi^ii. -4 u^&M&i
                    0 HAND McNALLY ft COMPANY. USED BY PERMISSION.
                    ALL RIGHTS RESERVED.
                                                 FIGURE 1
       GENERAL LOCATION  MAP
DOUGLASSVILLE SITE, UNION TWP.. PA
               NO SCALE

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                                                               ) '  \i   ••:»•*...
                                                              //.  > '       .1
                            OOUOLASSVILLE DISPOSAL SITE.
BASE MAP IS A PORTION OF THE U.3.G.3. BOYERTOWN.PA QUADRANGLE (75 MINUTE SERIES, 1957. PHOTOREVISEO 1973)

CONTOUR INTERVAL 20'.                                                  FIGURE   2


                  LOCATION MAP


DOUGLASSVILLE DISPOSAL SITE. UNION TWR, PA


                  SCALE '«"• 2000'                          I

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                  I COLUMBIA
                  S            f  t/rnr
                    I            / SCHUYlKltL A

                    -
       NORTHUMBERLAND
                                                                        •CUm. fit L KWt* 8*SIH OOUHOMr
                                                                                                                   LOCATION MAP
                                      IOOUOLASSVB.LE OgPOSAL SITEH-

                                                         CHESTER
SCHumatL nvf* BASIM got*****
       SOURCE- PMLAOELPMA ELECTRIC COMPANY. nMf I...-K
                  —), UNITS I •{.ENVIRONMENTAL
                           STAGE. MX 2. 1902

                                 \

             PUBLIC WATER SUPPLY INTAKES


                POTTSTOWN BOROUGH AUTHORITY

®                CITIZENS UTILITY HOME WAttd Cb nr
                SPRINO CITY-ROYERSFOao

             (5) PHOENIXVILLE BOROUCH


                PNILAOELPHIA SUBURBAN WATER CO

                KEYSTONE WATER CO , NORRISTOWN
                DISTRICT

                ©PHN-ADELPHIA WATER Of P t , OUEEN
                LANE WATER TRCATMCNI  PLANT

                PHILADELPHIA WATER OEPT., BELMOMT
                WATER TREATMtNT PLANT
                                                                                                                                               FIGURE 3
           PUBLIC WATER SUPPLY INTAKES DOWNSTREAM OF. DQUGLg 5SVILLE
                  DOUGLASSVILLE  DISPOSAL  SITE, UNION TWP, i A
SCALE IMMILE*

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 adequate water for household  use.   Five  (5)  bedrock residential wells
 are  located  within one (1)  mile of  the site.  Ground water from the
 Brunswick Formation is of  the calcium-carbonate  type, ranging from
 moderately hard to very hard  within the  general  regional area.  Total
 dissolved solids are usually  about  300 parts  per million.

      The Douglassville Disposal Site has been the site of operations of
 Berks Associates,  Inc., since its inception  in 1941.  The Berks Associates,
 Inc., facility currently consists of a waste  oil processing area located
 in the southern portion of  the site. The facility area consists of an
 office building, garage, active and inactive  tanks and other processing
 equipment and a water treatment system with  an oil water separator.  A
 small drainage ditch extends  eastward from the oil/water separator in
 the  center of the  site and  eventually flows  into the Schuylkill River.
 Surface water runoff from the site  also  feeds into this drainage ditch.
 A similar drainage swale runs parallel to the ditch and eventually merges
 with the drainage  ditch further east.  An old lagoon', identified through
 historical aerial  photographs, lies between  the  ditch and the swale.
 The  former drum storage area  is located  just  north of the confluence of
 the  ditch and the  swale. An  adjoining sludge disposal area is located
 just north of the  facility.   Various other trenches and impoundments
 have been noted on site throughout  the years. The bed of the abandoned
 Schuylkill Canal borders the  southwestern portion of the site.  The
 waste oil processing equipment consists  of approximately 40 tanks and
 associated refining  equipment.  The lagoons used for waste disposal
 have been decommissioned and  backfilled.  An  inactive railroad line
 extends through the  site in an east-west direction (Figure 4).
Site History

     In 1941, Berks  Associates,  Inc., began  lubrication oil recycling
operations  at the  site.   Site  operations also  included recycling some
waste solvents  in  the  1950's and 1960's.  Wastes generated from the
oil recycling and  solvent recycling  process  were stored in several
lagoons located In the northern  half of the  site until 1972.  In November
of 1970, ten days  of heavy rain  caused the lagoons  to overflow
and to breach safety dikes causing a release of 2-3 million gallons of
wastes.

     The dikes  were  repaired and a Federal decree was issued that no
more waste  material  was  to be  stored in the  lagoons.  Federal and State
actions were initiated to dispose of the waste material remaining in
the lagoons.  Before this action could be carried out, tropical storm
Agnes caused the Schuylkill River to overflow  its banks and inundate
the entire  site area in  June of  1972.  An estimated 6 to 8 million
gallons of  wastes  were released  and carried  by floodwaters downstream
for about IS miles.  During cleanup  after the  storm, the lagoons were
drained and backfilled.

     Berks  Associates, Inc., continued oil recycling operations
until 1979  when the  operator,  Mr. H. Lester  Schurr, determined that
the operation corrections mandated by the Pennsylvania Department of

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LEGEND
       APPflOXMATE WOODED AMCA


       KfSKKWCE
•rt im MAP «A cotroafTE TAKEN FNOM OCIDKII,
  CMC ACNM. molDtNMmSITS-nC-CXMM SCALE
  MJECT TO MHAU.AX OBIOHTOI.
                                                     X            "•^•>^s>i
                                                      \\  fOMBK&HuH^-  ,^   x (  ^^* I /
                                                       ^•^ "I *!•*•«•««*  ,*'   7^	^^^^	•>*
                                                         --0       .»-'   --"^^v.—-—	
                              GENERAL ARRANGEMENT
                                   DISPOSAL SITE. UNION TWP, PA
                                                                                                                           FIGURE 4
200	0       IOO

   »rw»o» sc»it IN rift

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Environmental Resources (PADER) were cost-prohibitive.  Operations
then turned to the current practice of refining waste oils for use as
fuel in industrial boilers.  Beginning in 1979, oily waste sludge from
the new recycling process was landfarmed in the area of the old western
lagoon.  This practice was halted in 1981 when PADER mandated operational
corrections to the landfarm configuration.

     A 250,000-gallon tank is located in the processing facility'area
and at one time held an estimated 25,000 gallons of water, mixed sol-
vents, and oil sludge.  In the summer of 1983, however, the site operator
evaporated liquid from the tank.  Thick, petroleum-like liquid and
sludge remained in the bottom of this tank at the time of the Remedial
Investigation (RI).  Several hundred drums were stored on the site
from September 1979 to April 1982 in an area at the eastern end of the
site.

     Results from an EPA Region III Field Investigation Team (FIT)
sampling effort in April 1982 showed volatile organic contaminants in
the drinking water well which was utilized by workers at the facility.
A filter was Installed on the facility well in the summer of 1983.
The facility workers are currently supplied with bottled water for
drinking purposes.  During the 1982 sampling effort, the FIT also
sampled the Schuylkill River (upstream and downstream of the site),
the facility discharge, the drainage swale sediment, and a domestic
well (upgradfent from the site).

     Based on the results of FIT investigations the site received a
Hazard Ranking System (HRS) Score of 55.18.  The Douglassville Disposal
Site appeared on the Proposed National Priorities List in December,
1982.  The site appeared on the National Priorities List promulgated by
EPA in September, 1983.

Current Site Status

     Remedial Investigation activities consisted of investigations of
surface and subsurface soil, sediment, surface and ground water, geology,
and air quality*

Hydrogeology

     Ground water and geological Investigations consisted of
drilling^23 bore holes at 13 different locations around the perimeter
of the waste disposal site.  At each of the 13 locations, except at
well KW-2, a deep and shallow well were coapleted so that ground water
In both alluvium and bedrock could be observed.  Host of the deep wells
are approximately 40 feet deep, the shallow wells are generally 20
feet, and several are only 10 feet deep.  Seventeen test pits were
excavated to obtain additional sub-surface data at the site.  Monitoring
wells and test pit locations can be found in Figure 5.

     The second major stage of the hydrogeologic investigation was the
determination of aquifer parameters including localized transmlssivities
and hydraulic conductivity.  These parameters were used to develop
estimates on the rates and volumes of ground water moving through the
site. The velocity of ground water moving through the site in the alluvium
was estimated at .278 feet per day while the movement through bedrock was

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 GEND



 ^3   APPflOIMllATE WOODED AM*




 ^   RESIDENCE
 \ssaa



 V    APPHOWMATE MOMTONMe WILL JLjOC*




19    WUH» 0 MONITORING WELLS




 0    TEST PIT LOCATION




 
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 1.39  feet  per  day.   Additional  investigative work at the site included
 searches for seeps and exposure of bedrock and overburden.  Offsite
 activities included  a water well  inventory and sampling program of
 nearby  residential wells, and examination of bedrock outcrops in the
 general Berks  County area.

      Site  geology generally consists of 10 to 20 feet of overburden,
 made  up of topsoil,  alluvium, waste material, and backfill material In
 overlying  lagoon areas.  Underlying bedrock is composed of red shale,
 siltstone,  and some  fine sandstones.  The bedrock surface dips in a
 northeasterly  direction toward  the Schuylkill River.  A geologic cross-
 section of the site  Is illustrated In Figure 6.

      Ground water flows in a north to northeasterly directi.on toward the
 Schuylkill River.  Overall relief on the water level contour is about
 20 feet.   The  gradient is very  low In the flood plain area, but steepens
 considerably southward, roughly parallel to the topography.  Many of
 the wells  placed in  the alluvium were dry, which indicates that the
 top of  the saturated zone In most of the monitoring locations was
 below the  top  of bedrock at that time.

      Vater levels and fluctuations observed in paired wells over the
 course of  the  Rl are indicative of a single open water table regime with
 general movement north and then northeast toward the Schuylkill River.
 Based on USGS  and site-specific information, seasonal water level
 fluctuations of 9 feet are expected.  The Schuylkill River exerts an
 increasing  influence on ground water levels and movement patterns as
 distance from  the river decreases.  The regional ground water will
 discharge  into the river except during flood events.

      Monitoring wells and residential wells were sampled and analyzed
 for EPA Contract Laboratory Program Hazardous Substances List (HSL)
 organics and inorganics in September 1984 and March 1985.  No contamination
was found  in the residential wells during this sampling effort.  All
 residential wells are located upgradient from the site.

      Site monitoring well data indicated that ground water was contaminated
 throughout  the site.  Volatile organic compounds constitute the majority
of site ground water contaminants.  Acid, base/neutral, and Inorganic
ground water contaminants were also detected.  The attached table
summarizes ground water results; EPA water quality criteria are exceeded
in ground water for  several organic and inorganic contaminants, including
benzene, chlorobenzene, 1.2-dichloroethane, tetrachloroethene, phenol,
arsenic and chromium.

     Contaminated plant waste deposited in the sludge disposal area
next  to the active facility and the abandoned sludge lagoons contained
a large number of volatile components.  The high water solubility and
low soil adsorption  partition coefficients of these compounds accounts
for their presence in the ground water samples.  Infiltration of percolating
rainwater  is apparently leaching volatiles into the bedrock aquifer
from contaminated sludges and soils in this area.  The presence of
volatile compounds in soil samples taken from test pits in the lagoon
area suggests that this is an ongoing process.  Seasonal fluctuations

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   •"«•» •ntmt.aamm m

 KOLOOC OOSS XtnON •••'
                                                                                    -I-
                                                                                          I V*tl«r- *.<•>..v
OtOlOOCCf ISSJtCtON IB'
                                                                                         gtouwic
                                                                                      .    ._  _ .
                                                                                   * "•! !»*>•* I  "••^•••••il^..

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Based  on  theoretical  and observed ground water level fluctuations and
regional  precipitation, calculations were made to estimate the volume of
water  that  passes  through  the contaminated subsurface which is attributal
to infiltation as  opposed  to the volume directly related to ground
water  contacting the  waste due to water table fluctuations.  In the
former lagoon area infiltration accounts for 1002 of the volume of
water  passing through the  waste area in a normal year, and 99.62 for a
wet season.  In the facility sludge disposal area infiltration accounts for
80Z (normal) and 88Z  (wet) of the total volume.

Surface Water

     Surface water samples were taken in the discharge drainage ditch
and the Schuylkill River.  Results of sample analyses revealed the
presence  of several organic and inorganic contaminants, in the discharge
drainage  ditch.  Samples from the ditch taken close to the facility
exceeded  EPA Water Quality Criteria for benzene, tetrachloroethene,
1,1,1  trichloroethane, and lead.  Samples taken further from the facility
in the discharge drainage  ditch did not contain any organic contamination
but did contain lead  (500  ppb) above the EPA Water Quality Criterion.

     Hydrogeologlcal  data  for the site does indicate that contaminated
ground water is entering the Schuylkill River.  However, the presence of
tetrachloroethene, which was detected in the Schuylkill River sample,
may be questionable because upstream and downstream samples showed
similar analytical results.  Dilution may be the main reason site
ground water contaminants  are absent in Schuylkill River samples.
Further analysis needs to  be conducted to determine if site contaminants
are affecting the  River during low flow periods.

Sediment

     Sediment samples were taken from the discharge drainage ditch, the
drainage  swale vest of the processing facility and the Schuylkill River.
The facility discharge drainage ditch contains sediments contaminated
with several volatile, acid, and base/neutral fraction organics and
PCBs as well as a  number of inorganic contaminants including lead.
The drainage swale west of the processing facility contains similarly
contaminated sediments.

     Schuylkill River sediment samples were also contaminated with
volatile^  acid and base/neutral organics, PCBs, and inorganics.
Although  sediment  contaminants in the Schuylkill River were similar to
those  found on site,  it is difficult to definitively say they are from
the Douglassvllle  Disposal Site, since the Schuylkill River is the
recipient of numerous other Industrial and municipal discharges.  Both
sediment  and surface  water sample locations are shown in Figure 7.

Air

     Air samples revealed only low levels of contamination.  Volatile
contaminants were  detected at concentrations no greater than 11 ug/m^.
The highest volatile  concentrations were detected within the facility
boundaries.  A number of the compounds detected were also detected in

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.EGEND
        APPMMMATE WOCX1CO ARE*
        RESIDENCE
        APPROXMATE SO*. SAMPUNS LOCATION
        tivtmtmtn. SUHFJKE MATCH SAMPLMO IOCATKM
        APPRCKMATC XOMCNT SAMMJM UXMTUN
        APMOWMAU WASTE (WT| ANO TANK 
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 the  field  or  laboratory blanks.  Levels of most of the contaminants can
 be considered  to  be  background levels.  The presence in the air of
 several  compounds slightly  above background levels is most likely due
 to current processing activities.  Air sample locations are found in
 Figure 5.

 Surface  Soils

     Surficial soils at  the Douglassville Disposal Site are contaminated
 with PCBs, phthalate esters, polynuclear aromatic hydrocarbons (PAHs),
 pesticides, various  volatile organics, and trace elements.  Surface
 soil sample locations are shown in Figure 7.

     PCBs were detected  in  11 of 16 surface soil samples.  Concentrations
 of PCBs  ranged from  39  ug/kg to 24,000 ug/kg.  PCB contamination was
 detected in surface  soil samples 1, 3, 4, 5, 6, 7, 102, 103, 105, 106,
 and 106A.

     Various phthalate esters were identified in 9 of 16 surface soil
 samples.  Compounds  identified include bis(2-ethylhexyl)phthalate, di-n-
 butyl phthalate,  and di-n-octyl phthalate.  Concentrations of these
 compounds ranged  from 170 ug/kg to 9100 ug/kg.  Phthalates were found
 in samples 3, 4,  5,  9,  103, 104, 105, 106, and 106A.

     Of  the trace elements  identified in site soil, arsenic, cadmium,
 chromium, lead, and  mercury are of some concern because of their known
 toxiclty to human and environmental receptors.  Concentrations of these
 elements encountered in  site surface soil and results for the background
 sample (101) and  literature background levels are as follows:

              Concentration        Backround concentration (mg/kg)
 Element       Range (mg/kg)     Sample 101    Berks Co.  Literature*

Arsenic           ND  - 8.98           ND            —         6

Cadmium           ND  - 3.2            ND           0.16        0.5

Chromium          9.7 - 227           15           10.4        100

Lead              1.3 -  7,100         49           26.1         10

Mercury           ND  - 1.0            0.29          —          0.3

* Literature values  are  general, not site-specific data based on reports
by Allaway, 1968p Ward,  1976; and Lish, 1972.
     Lead showed the greatest deviation from background levels and was
an order of magnitude higher in samples 3, 4, and 5 than in any other
surface soil samples.

     Surface soil contamination with polynuclear aromatic hydrocarbons
(PAHs) and volatile organics was not as extensive as contamination by
the phthlates, metals, and PCBs.  Some pesticide contamination was found.
This may be attributed to former and current agricultural activites.

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 Subsurface  Soil

      Subsurface  soil  samples were obtained from a number of che test
 pits excavated at  the site  (see  Figure  5).  Subsurface soil contamination
 generally reflects  the contamination detected in surface soil samples,
 although higher  concentrations of volatile contaminants were identified.
 Subsurface  soil  samples taken from  test pits located in the former
 northeastern lagoon area, the northwestern area, and the northeast
 corner  of the production facility were contaminated with lead, PCBs,
 and  phthalate esters.   Samples obtained In these areas were also conta-
 minated with chlorinated aliphatics, monocyclic aromatic hydrocarbons,
 and  polynuclear  aromatic hydrocarbons.  These compounds are generally
 associated  with  industrial  solvents, petroleum production byproducts,
 and  coal tar.

 Summary of  Conditions
                                          •
 Based on the  results of sampling, there are the four (4) distinct
 areas of concern for  the Douglassville Disposal Site.  These include:

      0  the  former sludge lagoon  area, including the landfarming area
        in the northeastern  quandrant of the site along the bank of
        Schuylkill River;

      0  the  sludge disposal  area, located between the facility processing
        area and  the Penn Central/Conrail Railroad tracks; this includes a
        drainage  swale  to the west of this area;

      0  the  facility processing area;

      0  the  area  which  includes the  drainage ditch flowing from the
        facility  processing  area  to  the Schuylkill River along with
        the  land  directly adjacent to this ditch.  This land contained
        a small lagoon  at one time and was also used as a drum storage area.

     Surface  and subsurface soils in the former sludge lagoon and sludge
disposal areas are contaminated  with a number of HSL compounds.  Volatile
organic  contaminants of  concern  include benzene, 1.2 - dichloroethane,
1,1,1 -  trichloroethene, ethyl benzene, tetrachloroethene, toluene,
trichloroethene, and xylene.  Also, Che presence of PCBs and lead is
of primary  concern.  These  compounds were detected at maximum concentrations
of 500,000  ug/kg and 56,300 mg/kg,  respectively.  These concentrations
Indicate the  need for  control, destruction and/or secure disposal of
Che wastes  in accordance with federal regulations.  The greatest concentration
of PCBs  was Identified in the sludge disposal area adjacent to the
processing  facility grounds.  The greatest degree of lead contami-
nation was  found in the drainage swale west of the processing facility.
Lead was also found at  significant  concentrations (up to 23,400 mg/kg) in
the former  lagoon and  landfarming areas in the northeastern corner of
the site.   PCBs  and lead were also  found along the riverfront in surface
and subsurface soils,  and in sedmient samples from the facility discharge.
A listing of  the site's  critical contaminants with their range of
concentrations is found in  Table 1.

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                                    TABLE 1

                             CRITICAL CONTAMINANTS
                          DOUGLASSVILLE DISPOSAL SITE
      Contaminant
 Benzene
 CAS No. 71-43-2
 1,2-Dichloroethane
 CAS No. 107-06-2

 1,1,1-Trichloroethane
 CAS No. 71-55-6
Ethylbenzene
CAS No. 100-41-4
Tetrachloroethene
CAS No. 127-18-4
       Media
Toluene       _____
CAS No. 107-88-3
Ambient Air
Subsurface Soil
Surface Water
Monitoring Wells

Subsurface Soil
Monitoring Wells

Ambient Air
Subsurface Soil
Surface Water
Sediment
Monitoring Wells

Ambient Air
Subsurface Soil
Surface Water
Sediment
Monitoring Wells

Ambient Air
Surface Soil
Subsurface Soil
Surface Water
Sediment
Monitoring Wells

Ambient Air
Surface Soil
Subsurface Soil
Surface Water
Sediment
Monitoring Wells
        Range
2.6 - 3.3 yg/m3
6.6 - 9,200 ygAg
7.4 - 11.0 yg/l
7.6 - 100 ug/l

5.2 - 45 yg/kg
45 - 330 yg/l

2.7 yg/m3
8.2 - 34 yg/kg
40 - 47 yg/l
34 - 120 yg/kg
2 -~30  yg/l

2.6 - 3.4 yg/m3
7.4 - 36.000 yg/kg
6.5 - 8 yg/l
2,200 - 16,000 yg/kg
2.4 - 160 yg/l

2.6 - 8.0 yg/m3
18 ygAg
6.4 - 17.000 ygAg
13 yg/l
820 ygAg
2.1 - 29 yg/l

2.6 - 28 yg/m3
33 - 257 yg.'kg
17 - 79.000 ygAg
2.5 - 70 yg/l
43 - 36,000 ygAg
3.6-91 yg/l
 No. of
Samples
In Which
Detected

    4
    6
    3
    9

    3
    6

    1
    5
    3
    2
    9

    3
   10
    3
    2
    7

    5
    1
    7
    2
    1
   13

    5
    7
   12
    4
    3
    7

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 TABLE 1
 CRITICAL CONTAMINANTS
 DOUGLASSVILLE DISPOSAL SITE
 PAGE TWO
      Contaminant
 Trichloroethene
 CAS No. 79-01-6
Xylene
CAS No. 95-47-6
       Media
PCB-1254
CAS No. 17097-69-7
PCB-1248
CAS No. 12672-29-6
PCB-1260
CAS No: 11046-82-5
Bis (2-ethvlhexYl)—
phthalate
CAS No. 117-81-7
lead
CAS No. 7439-92-1
Ambient Air
Subsurface Soil
Surface Water
Sediment
Monitoring Wells

Ambient Air
Surface Soil
Subsurface Soil
Surface Water
Sediment
Monitoring Wells

Surface Soils
Subsurface Soil
Sediment
Monitoring Wells

Surface Soil
Subsurface Soil
Sediment

Surface Soil
Subsurface Soil
Sediment

Surface Soil
Subsurface Soil
Surface Water
Sediment
Monitoring Wells

Surface SoH
Subsurface Soil
Surface Water
Sediment
Monitoring Wells
Residential Wells
        Range
2.6 yg/m3
14 - 59.000 yg/kg
19-367 yg/l
30 - 460 yg/kg
3.3 - 68 yg/l

2.6 - 16 yg/m3
42-120 yg/kg
6.6 - 85,000 yg/kg
20 yg/l
400 - 32.000 ua/kg
2.3 - 820 yg/l

38 - 1.700 yg/kg
290 - 12.000 yg/k i
86 yg/kg
1.7 yg/l

1,200 yg/kg
1,800 - 25,000  yg/:g
130 - 30,000
70 - 24,000 ygAg
57 - 500,000 yg/kg
62 - 48,000 ygAg
182- 9.100
2,800 - 20,000 yg/l g
26 - 85 yg/l
470 - 91,000 ygAg
24 yg/l

1.3-7.100 mgAg
52 - 23,400 mg/kg
5.2 - 973 yg/l
22.2 - 56,300  mg/kg
5.1 - 9.3 yg/l
5.1 - 6.5 yg/l
 No. of
Samples
In Which
Detected

    1
    9
    3
    2
   11

    5
    4
   14
    2
    6
    7
    1
    1

    1
    2
    3

   10
   16
    6

    7
    2
    2
    4
    1

   16
   23
    5
   10
    8
    2

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     Migration of soil and sediment contaminants is occurring by the
following mechanisms:

     0  erosion of contaminated participates during storm events, or
        because of Hooding.  The presence of FCBs in the upstream
        sediment sample (SD-007) indicates that this may have occurred
        during the 1972 flood, or as a result of upstream conditions.

     0  airborne migration of contaminated particulates;

     0  infiltration of precipitation through contaminated soils and
        sediments, causing various organic compounds to be leached
        into ground water;

     0  seasonal fluctuations in ground water elevations, causing
        subsurface organic soil contaminants to be leached into the
        ground water when the water table rises sufficiently to contact
        contaminated soil zones;

     0  flow free the contaminated drainage ditch that is transporting
        sediments and soils in the ditch.

Health and Environmental Impacts

     Potential environmental and health impacts associated with the
site are summarized below.

     0  Receptors using ground water for drinking purposes were located
        only upgradient of the site at the tine of sampling, and would
        not be exposed to the site contaminants as long as ground water
        migration patterns remained unchanged.  However, changes In
        future ground water use (e.g., by pumping, increased usage, or
        river-induced changes in ground water gradient) could alter
        the migration of contaminants.  There would then be a potential
        for chronic and carcinogenic health effects if the contaminants
        were Ingested over a long period of time at the concentrations
        observed currently in ground water.

     0  The primary site specific hazard attributable to the Douglassville
        Disposal Site is through dermal exposure to site contaminants
        torsoils, onsite surface waters, and offsite surface waters
        if the contaminants migrate.

     "  Ingestion of any of the volatile organic contaminants in the
        food chain Is not considered to be an immediate hazard.  The
        possibility of high Clow or flooding conditions In the Schuylkill
        River could transport relatively immobile contaminants (PCBs,
        lead).  These contaminants have a potential for bioaccumulation,
        therefore increasing the potential for health impacts from
        this route of exposure.

     0  Toxic effects on aquatic biota may be expected if high flow
        or flooding of the Schuylkill River occurs, or contaminants
        migrate via ground water into the Schuylkill River at significant
        concentrations.

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Alternatives Evaluation

     The major objectives for remedial action to be taken at the
Douglassvllle Disposal Site are to mitigate or eliminate public health
effects and environmental contamination through direct contact and
migration of contaminated soils, sediments, and surface waters and
to prevent infiltration of surface water through contaminated soil
zones.  The decision whether further remedial action is necessary
for ground water contamination and for the slurry wall installation
will be deferred pending further Investigation.

     Any remedial alternative proposed onsite must take into con-
sideration the location of the site which is almost entirely within
the 100-year floodplain.

     The NCP specifies that remedial alternatives should be classified
either as source control (40 CFR 300.68(e)(2)) or offsite (management
of migration) remedial actions (40 CFR 300.68(e)(3)).  Source control
remedial actions address situations in which hazardous substances remain
at or near the areas in which they were origii illy located and are not
adequately contained to prevent migration into the environment.  Offsite
remedial actions address situations in which the hazardous substances
have migrated from their original locations.  Alternatives developed
may fall solely in either classification or may involve a combination
of source control and management of migration measures, as problems at
the site dictate.

     In an effort to determine remedial alternatives for the subject
site, feasible technologies were Identified for consideration In each
response action category (source control and management of migration).
Available technologies were then screened to eliminate all but the
most feasible and implementable alternatives.  This screening included:
technical (site conditions or waste characteristics), environmental
and public health, institutional, performance and cost criteria.   A
list of the remedial technologies that were screened for this site can
be found in Table 2.

     Those technologies that passed the technology screening process
were used to form remedial alternatives.  Remedial alternatives were
developed using best engineering judgement to select a technology or
groups of -technologies that best address the problems existing at the
site.

     In order to study a range of responses, remedial alternatives
that fall into one of five different categories were developed.  These
categories are described below.

     0  No action (no-action alternatives could include monitoring
        activities).

     *  Alternatives which do not attain applicable or relevant public
        health or environmental standards but will reduce the likelihood
        of present or future threat from the hazardous substances.  This
        must include an alternative which closely approaches the level
        of protection provided by the applicable or relevant standards

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                                  TABLE 2
                  POTENTIAL REMEDIAL ACTION TECHNOLOGIES
                        DOUGLASSVILLE DISPOSAL SITE
                     Technology
No Action (with monitoring)
Surface Capping (Clay and Synthetic)
Groundwater Barriers (Slurry Wall and Grout Curtain)
Groundwater Pumping
Subsurface Collection  Drains
Surface Water Diversion
Soil/Sediment Excavation
In Situ Treatment:
   Permeable Treatment Beds
   Solvent Flushing
   Bioaugmentation
Onsite Wastewater Treatment:
   Flow Equalization
   Activated Carbon
   Biological Treatment
   Precipitation
   Solidification/Fixation
   OII-WatftL-Separation
   Air Stripping
   Dissolved Air Floatation
   Sludge Treatment (Thickening and Dewatering)
Orfsite Wastewater Treatment
Incineration  (Onsite and Orfsite)
Onsite RCRA Approved Landfill
Orfsite RCRA Approved Landfill
Onsite Storage
 Retained
for Further
Evaluation

    Yes
    Yes
    Yes
    Yes
    No
    Yes
    Yes

    No
    No
    No

    No
    Yes
    NO
    NO
    No
    Yes
    Yes
    Yes
    Yes
    No
    Yes
    Yes
    Yes
    No

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                                   10
        and meets CERCLA's objective of adequately protecting public
        health, welfare and environment.

     0  Alternatives which attain applicable and relevant federal public
        health or environmental standards.

     0  Alternatives which exceed applicable and re1 want public health
        or environmental standards.

     0  Alternatives for treatment or disposal at an offsite facility
        approved by EPA.

        The evaluation criteria selected were:  technical feasibility,
public health, environment, Institutional evaluation, and cost-effective-
ness.  Particular emphasis within each of the criteria is listed below:

     - Technical Feasibility
       0 Performance
       0 Operation and Maintenance
       0 Implementabillty
       0 Reliability
       0 Safety

     - Public Health Evaluation
       0 During and after implementation

     - Environmental Evaluation
       0 Reduction of environmental impacts
       0 Protection of natural resources

     - Institutional Evaluation
       0 Impact of applicable standards
       0 Community impacts

     - Cost-Effectiveness
       0 Capital costs
       0 Operation and maintenance costs
       0 Present worth values
       0 Sensitivity analyses

     The remaining alternatives after screening are shown in Table 3.
This iniirrl B oniiiiiiii 1 rrn technical, environmental, public health and
other concerns associated with each alternative and gives cost ranges
for both capital and present worth costs.  A more detailed project cost
breakdown can be found in Table 4.

Description of Remedial Alternatives

A.  No-Action with Monitoring

Alternative No. 1 - No-Action with Monitoring

     Under the no-action alternative, no steps would be taken to control
the source or mitigate migration of site contaminants.  The contaminants

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                                    11
would continue  to migrate  into the river by surface and ground water
flow, and by erosion  from  storm water runoff*  Direct contact with
contaminated soils.would continue to be a threat to human health and
the environment.  Contaminated ground water would continue to be generated
as a result of  Infiltration of precipitation through contaminated soil
zones and also  by contact  of contaminated soils with ground water,
which will rise due to  seasonal fluctuations.

     A long-term monitoring program would be established and implemented
to observe and  provide  early warning of contaminants migrating from
the site.  In addition, a  fence would be installed around the perimeter
of the site to  reduce the  potential for direct contact by human and
animal receptors.

     Due to the presence of contaminants in onsite soils, surface water,
and ground water, a comprehensive sampling and analysis program would be
developed to include  surface water, sediment and ground water sampling.

     Sample locations would be Identified to provide the most beneficial
data.  Surface  water  and sediment samples would be taken in the discharge
drainage ditch  and at several locations upstream, downstream, and along
the Schuylkill  River.

     Monitoring wells would be located so that contaminant loadings
into the Schuylkill,  upgradient and downgradient ground water quality,
and ground water flow directions could be monitored.

     Due to water table fluctuations and seasonal precipitation fluctua-
tions, sampling and analyses should be conducted twice a year, once
during high ground water flows in the late spring and once during
periods of low  ground water levels in late fall.
B.  Alternatives that Meet the Objectives of CERCLA

Alternative No. 2 - Transfer Contaminated Soils and Sediments From
Drainage Ditch to Facility Sludge Disposal Area, Install Surface Caps
in the Facility Sludge Disposal Area and the Former Sludge Lagoon Area.

     Implementation of this alternative would involve excavation or
dredging the sediments from the drainage ditch that flows from the
active facility eastward toward the river.  The ditch is approximately
1,600 feet~Tong and the sediments contain organic and inorganic contami-
nants such as PCBs, lead, naphthalene, and trichloroethene.  Surface
soils In the former drum storage area as veil as a small former lagoon
area adjacent to the drainage ditch nay also require excavation and
consolidation in the facility sludge disposal area.  Sampling to be
done in a pre-design study will help determine the extent of vertical
contamination in these areas and will tighten the estimate on how much
contaminated material needs to consolidated.  The current estimated
volume of material from those two areas is 32,500 cubic yards.

     Following consolidation of excavated or dredged materials, the
facility sludge disposal area and the former sludge lagoon area would

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                                    12
 be capped  Co prevent  erosion of  contaminated  surface soils and signifi-
 cantly  reduce leachate generated by  infiltration of precipitation
 through contaminated  subsurface  soils.  The cap would consist of 1.5
 feet  of compacted  clay,  12  inches of borrowed fill, and 6 inches of
 topsoil.   A gas  collection  and venting system would be installed to
 prevent damage to  the cap from volatile organic gases which may be
 generated  by the contaminated soils.

      A  French drain and  dike would be installed around the facility to
 direct  surface runoff away  from  the  contaminated facility.  A similar
 French  drain and dike would also be  installed between the cap on the
 former  sludge lagoon  area and the Schuylkill  River to protect the cap
 against high river flows.

 Alternative No.  3  - Transfer Sediments from Drainage Ditch to Facility
 Sludge  Disposal  Area  and Install Cap; Install Cap in Former Sludge
 Lagoon  Area;  Pump  and Treat Ground Water in Sludge Disposal and Former
 Sludge  Lagoons Areas.

      This  alternative includes all of the items of Alternative No. 2 .
 with  the addition  of  pumping and treatment of ground water beneath the
 site.   The items which are  common to the previous alternatives will
 not be  described in this discussion.

      Ground water  would  be  pumped and treated in order to control
 contaminant migration to the Schuylkill River.  A well point dewaterlng
 system  would  be  used, consisting of  intermittently spaced wells pumped
 by submersible pumps, and connected  by a header pipe.  In addition to
 removing ground  water for treatment, the well points can also be utilized
 to lower the  water table to prevent  rising ground water from contacting
 contaminated  soils.

     Modeling  of the hydrogeologic system at  the site indicates that
 optimum ground water discharge would be achieved by using eight wells
 with a  total  pumping rate of 182 gpm in the facility sludge disposal
 area, and  nine wells with a total pumping rate of 72 gpm in the former
 sludge  lagoon  area.

     Contaminated  ground water could be treated to comply with any discharge
 standard developed using dissolved air flotation, air stripping, and
 activated  carbon.  Flow  equalization could also be utilized.  Sludges
 and waste  csxbon generated  by the treatment process would be disposed
 offsite at  an  EPA-approved  facility.

 C.  Alternatives that Attain all Applicable or Relevant Public Health
 or Environment Standards. Guidance,  or Advisories

Alternative No.  4  - Transfer Sediments from Drainage Ditch to Facility
Sludge Disposal Area; Install a  RCRA Cap in the Facility Sludge Disposal
Area and the Former Sludge  Lagoon Area; Install a Levee Around the
Former  Sludge  Lagoon Area;  Install a Slurry Wall Between the Former
 Sludge Lagoon  Area and the  Schuylkill River;  Pump and Treat Ground
Water; Provided Monitoring  and Post-Closure Care.

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                                   13
     This alternative Incorporates all the elements of Alternative 3 in
addition to the following elements:

     - Upgrade the cap in Alternative No.3 to a RCRA cap.

     - Install a levee to provide protection against the 100-year"
       flood event.

     - Install a slurry wall between the Schuylkill River and former sludge
       lagoon area to provide protection against localized reversal of
       ground water flow patterns due to high water elevations in the
       Schuylkill River.

     - Implement a monitoring program and post-closure care program as
       required under RCRA regulations.

     A surface cap meeting the performance standards of the Resource
Conservation, Recovery Act (RCRA), 40 CFR 264, will be constructed.
The cap proposed in this alternative is designed to virtually eliminate
infiltration, whereas the cap proposed in Alternative 3 woulu only reduce
infiltration.

     The levee would be installed around the perimeter of the surface
cap in the former sludge lagoon area to provide protection against the
100-year flood event.  The levee would have two feet of freeboard and
be designed to insure stability and prevent erosion.  This would provide
a greater degree of protection against flooding than the dike/French
Drain system proposed in the previous alternative.

Alternative No. 5 - Transfer All Sediments and Soils to Former Sludge
Lagoon Area; Install a RCRA Cap with Levees; Install Slurry Wall; Pump
and Treat Ground Water; Provide Monitoring and Post-Closure Care.

     This alternative is the same as Alternative 4, except that all
contaminated sediments and soils would be transferred to the former
sludge lagoon area where they would be capped as described in Alterna-
tive 4.  Approximately 100,000 cubic yards of material would have .to
be transferred from the facility sludge disposal area.

     Soils would be excavated until the levels of contaminants found in
unexcavatetf-material are such that no significant impact to ground
water quality would be expected.  The 100,000 cubic yard estimate is
based on excavation to a depth of IS feet.  Verification of estimates
on the extent of the contamination would be done In a pre-design study.

D.  Alternatives that Exceed All Appllcables or Relevant Public Health
and Environmental Standards Guidances, and Advisories.

Alternative No. 6 - Transfer All Sediments to an Onsite RCRA Approved
Landfill with Levees; Pump and Treat Ground Water; Provide Monitoring
and Post-Closure Care.

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                                    14
     This alternative differs from Alternative 5 in that a landfill
would be constructed onsite to receive all contaminated soils.  The
landfill would incorporate a double liner leachate collection system
and have a design life of 30 years consistent with the requirements of
RCRA. The levee would be constructed around 3 sides of the landfill to
protect against washout during flood events.

Alternative No. 7 - Incinerate All Contaminated Soil and Sediment Onsite
and Disposal of Residues in Former Sludge Lagoon Area and Facility Sludge
Disposal Area Under RCRA-Approved Cap; Pump and Treat Ground Water;
Provide Monitoring and Post-Closure Care.

     This alternative incorporates all of the elements of Alternative 5
with the addition of incineration.

     Mobile incinerators would be brought onsite to incinerate an estimated
347,000 cubic yards of contaminated soils and sediments to remove organic
contaminants.  The residue, which would still be contaminated with metals,
would be backfilled in the facility sludge disposal area and former sludge
lagoon area where it would be capped to prevent infiltration of precipitation.
Levees and dikes would be provided to protect the caps against storm events.
                *
E.  Alternatives that Specify Qfi[site Disposal

Alternative No. 8 - Remove All Contaminated Soils and Sediments and Dispose
in Offsite RCRA-Approved Landill; Pump and Treat Ground Water.

     Under this alternative approximately 347,000 cubic yards of
material would be removed to a RCRA approved landfill.  The site would
be backfilled to grade and revegetated.  Ground water would be pumped
and treated as described in Alternative No. 3.

Alternative No. 9 - Remove All Contaminated Soil and Transfer to Offsite
Incinerator; Pump and Treat Ground Water

     Under this alternative all the actions described in Alternative
No. 6 would be implemented.  Prior to disposal of the contaminated soil
in an offsite RCRA landfill the soils would be incinerated to remove organic
contamination.

F. Recommeffded Alternative

     Section 300.68(J) of the National Contingency Plan (NCP) [47FR 31180;
July 16, 1982] states that the appropriate extent of remedy shall be deter-
mined by the lead agency's selection of a remedial alternative which the
agency determines is cost-effective (i.e., the lowest cost alternative
that is technically feasible and reliable) and which effectively mitigates
and minimizes damage to and provides adequate protection of public health,
welfare, and the environment.  In selecting a remedial alternative EPA
considers all environmental laws that are applicable and relevant.  Based
on the evaluation of the cost-effectiveness of each of the proposed altern-
atives, the comments received from the public, information from the Feasi-
bility Study and Information from the Pennsylvania Department of Environ-
mental Resources (PA DER), we recommend Alternative No. 4 be implemented

-------
                                        1AM! 3

                       MUCDIM AC1ION A1TERMATM IRAI* Olf MA IRIX
                                DOUGLASSVHIE DtSTOSAl SUE
Co«l Ranae Itl.OOOtl
Remedial Action

1.





2.







1.









Alternative Capital
No action with 1210-211
monlloiing w»d
lence



Non RCHA approved l.7«4-2.3«0
caps In UcHily
•nd lagoon ereei
with French drains.
dike, gas venting.
•iid monitoring


Non-RCHA approved 3.17t-4.902
caps to lacUMy
•nd lagoon Ateat
with yaa vcnlln||.
(pound w*IM
Ircatmant. end
monlloiing



Technical
Pr«tanl Worth Concamt
SI.3M-M43 Will not mllluat*
conlainlnanl
>ouica>



IISO-?.?^ 3cii,ni Mi'i-
liailon Iliroueh
conlimlnaltd
tolli. taducai
turfac* funolf.



6.003-7.227 Reduce* billl-
litllon and
laachal*
pioducllon;
allecllvanatt
ol groundwalw
pumping Irom
liacluied rock
dllllcull lo
dalmnln*.
Pi btic llaallh
Cone tin)
•oitlbla a»po-
•.uia iliks
hio igh Ingat-.
Ion. Inhalation.
.md dumal
:onlacl camaln
•onlble
•ope luia
•likt reduced
h«
IliilllL'uil lly
ivpuiilcil
lluiiilinii





-------
                                     15
 at  the Douglassville Disposal Sice with the exception of ground water
 pumping and treatment and the slurry wall.  Installation of an impermeable
 cap will significantly reduce the amount of contaminated ground water
 being generated by the site.

     This selected remedy will mitigate all surface contamination 'problems
 at  the site which were identified in the Remedial Investigation.  In
 addition, the proposed remedial action will significantly reduce generation
 of  contaminated ground water by eliminating infiltration of precipitation
 through the contaminated soil zones.

     Excavation of sediments and contaminated soils from the discharge
 drainage ditch and from adjacent areas will eliminate direct contact
 and contaminated sediment deposition.  In addition, these soils and sediments
 currently are located in a depressional area onsite and the water table
 frequently contacts the waste.  Consolidation of these materials at a higher
 contour level, such as in the facility sludge disposal area, will eliminate
 this source of ground water contamination.  Since the facility sludge
 disposal area is contaminated with the same type of contaminants as in the
 drainage ditch area, the consolidation of these wastes is in compliance
 with RCRA.  The facility sludge disposal area will be capped to eliminate
 contaminant transport by infiltration of precipitation.  Pre-design samples
 (borings) will be taken at locations along the drainage ditch, in the
 former drum storage area and in the old lagoon area near the drainage to
 determine the vertical extent of the contamination.  This will either
 verify or revise the 32,500 cubic yard estimate of contaminated material
 needed to be excavated and consolidated.  If the core borings indicate
 that contamination is much deeper than estimated and that consolidation of
 the entire contaminated zone is technically impractable or not cost effective,
 this portion of the selected alternative will be revised.  Possible solutions
 may include capping the area, lining the ditch or limited excavation and
 consolidation of wastes.  In any event, before work starts in this area
 the current discharge from the active facility must be diverted so not to
 interfere with construction and not to disrupt active processing at the
 facility.

     Installation of an impermeable cap will eliminate direct contact
 with and erosion of surface soils and contaminated sediments as well as
 infiltration of precipitation through contaminated soil zones.  As mentioned
 previously in this document, It was calculated that infiltration of precipi-
 tation accounts for 802-100t of the total volume of water passing through
 the contaminated subsurface zones.  Since a RCRA cap will virtually eliminate
 infiltration, this source of contamination to the ground water will be
 significantly reduced or eliminated.  The cap will be installed over the
 former sludge lagoon, the sludge disposal area and the facility sludge
 disposal area.  The cap will meet the recommended standards as specified
 in 40 CFR 264 of RCRA.

     Capping of these specified areas will include installation of a
gas ventilation system.  French drains will be laid out on a 200 foot
horizontal grid with a vertical PVC vent at the Intersection of each drain
 (Figure 8).  Based on this configuration approximately 3000 feet of
French drains will be required.  These drains should slope slightly

-------
                                    16
 to  the  collection points  along  the  center drain.  Monitoring should be
 performed  periodically  to determine that any gaseous emmissions do not
 exceed  acceptable levels.

     Since  the site  is  located  almost entirely within the 100-year flood
 plain,  a levee/dike  system will be  utilized to protect the cap from
 the  100-year event and  to divert surface runoff from the capped areas.
 The  levee  will be constructed around the perimeter of the surface cap
 and  will provide  a freeboard of at  least two feet.  This means the
 top  of  levee elevation  will range from 3-15 feet high depending on the
 contours of the land.   The levee must be constructed with fairly impermeable
 material to prevent  seepage and must be well compacted to insure stability
 and  prevent erosion*  Tile drains equipped with one way valves will be
 installed within  the embankment to  provide drainage of rainwater which
 falls within the  levee.

     Once the cap has been installed, a detection monitoring program as
 specified under RCRA will be implemented.  This will include installing
 monitoring wells  (where current wells don't exist) downgradient from
 each capped area  to determine the extent of contamination that may be
 emanating from these closed areas.  One upgradient well will be needed
 at each area to determine the water quality before it passes through
 Che  closed lagoons or sludge disposal areas.  At this time it appears
 that approximately 6-8  wells would  be needed for Che monitoring program.
 The operator must monitor semi-annually at all compliance points for
 volatile organics, inorganics,  PCBs, oil and grease.

     Ground water pumping and treating and construction of Che slurry wall
 are  being deferred until  more data  can be generated concerning what toxic
 effects, if any the contamination is having on the target stream (Schuylkill
 River).  A decision on  what corrective ground water action is necessary to
 address fluctuating ground water elevations contacting contaminated soil
 zones is also being deferred pending further analysis.  The additional
 data needed to make these decisions will be collected through a supplemental
 remedial investigation  and feasibility study.  Potential impacts on the
ground water from che active facility will also be investigated.

     Upon completion of the recommended remedial actions, future land
use activities should be  restricted so as not to permit damage Co or
 removal of che soil cover, gas  vents, and other structures necessary
 Co ensure leag-term integrity and effectiveness of che remedial response.


Operation and Maintenance

     Monitoring and post-closure maintenance activities are required to
verify the site cleanup,  effectively maintain permanent onsite actions,
and monitor potential contaminant migration.  Sampling of surface water
and sediment in Schuylkill River should be conducted quarterly for aC
 least the first two years after remediation Is completed and semi-annually
 thereafter to assess the  effectiveness of remedial actions.  Ground water
 should also be sampled  at the same  frequency as surface waters and
 sediments.  Ground water  sampling is necessary to monitor pollutant
 levels and movement patterns.   Surface water and sediment sampling

-------
DRAINAGE
DITCH
                                               •3AS COLLECTION DRAINS
                                                   DIKE AND
                                                   DRAINAGE DITCH
                                                          /.  	f]
                                                                            FIGURE 8
       CONFIGURATION OF GAS COLLECTION SYSTE A FOR CAPPED AREAS
              DOUGLASSVILLE DISPOSAL SITE.UNION TWP.PA
                               SCALE l"=300'

-------
                                   17
will be needed  Co monitor  the impacts of ground water entering surface
waters and accumulating  in sediments.

     The soil cap should be effective as long as it is not disturbed.
Post-closure inspection  and maintenance are required to restore and
rehabilitate the cap  to  insure its integrity.  Regrading and reseeding
would also be required to  ensure the effectiveness of the caps.

     Routine inspection  and maintenance of the levee and dike structures
will also be required to ensure their effectiveness in protection
against the 100-year  flood event.

     All operation and maintenance requirements will be the responsibility
of the State of Pennsylvania one year subsequent to completion of construction.
Annual cost for operation  and maintenance is estimated to be $196,000.

Evaluation of Alternatives Not Selected

     The No-Action with  Monitoring alternative was not selected since this
option would tkot mitigate  contaminant sources.  Potential direct contact
threat would remain as well as possible risks through ingestion and inhalation.
No environmental*regulatory standards would be met under this alternative.

     Alternative 2 involves surface caps in the facility and lagoon areas
with French Drains, dikes, gas venting and monitoring.  Although this
alternative may reduce risk exposure through reduced infiltration and reduced
direct contact probability, it does not eliminate these threats completely.
The caps would still allow an amount of infiltration that could carry con-
taminants to the ground  water system.

     Alternative 3 upgrades Alternative 2 to include ground water pumping and
treating.  Effectiveness of the surface caps in Alternatives 2 and 3
may be reduced by repeated flooding.  Infiltration through caps will
continually carry contaminants to the ground water.

     Alternative 5 would consolidate all site waste into the sludge disposal
area.  This was not preferred since it would cause an unnecessary amount of
environmental disturbance  during transferal of large amounts of waste.
It would also require an extensive amount of backfilling which is not
as cost-effective or more  environmentally sound than capping.

     Alternative 6 would create a RCRA landfill in the lagoon area with a
levee and ground water treatment and monitoring.  This was not selected due
to staging problems that would occur when attempting to construct the landfill.
All sludges from the lagoon areas would need to be excavated and staged
somewhere until construction of the landfill was completed.  The large quantity
of material excavated and  transported would pose a high risk of exposure from
volatilization of organics.  A large quantity of waste may be lost downstream
If exposed during a heavy  flood event.

     Alternative 7 provides for Incineration of the waste.  Since toxic
metals are not eliminated  by this process this option was not chosen.  In
addition, soil volumes would not be substantially reduced, emissions from
incinerator stacks may increase air pollution in the area and portable
incinerators are not  currently available.  Another reason for rejection

-------
                                       18
 Is  the  length of  time  for  complete cleanup (6 years).  In addition this
 alternative appears to be  cost prohibitive at $67-$lA7 million.

     Alternative  8 (offsite disposal of all wastes) was rejected
 due to  t>-« high transportation and disposal costs (an order of magnitude
 higher  than the selected alternative).  In addition, complete excavation
 would expose volatile organics to the atmosphere and increase the potential
 for direct contact exposure.

     Alternative  9 evaluates offsite incineration of all waste.  This option
 was eliminated due to  the  magnitude of cost ($417 million) relative to the
 other alternatives.  In addition, the capacity of a sole incineration
 facility may be exceeded.


 Consistency with  Other Environmental Laws

     EPA is currently proposing a regulation requiring the agency to select
 a remedial Superfund remedy which "attains or exceeds applicable or
 relevant Federal  public health or environmental standards".  See proposed
 40 C.F.R. S300.68(f).

     Environmental laws which may be applicable or relevant to remedial
 activity are:

     - National Environmental Policy Act (NEPA)
     - Clean Air  Act (CAA)
     - Clean Water Act (CWA)
     - Safe Drinking Water Act (SDWA)
     - Resource Conservation and Recovery Act (RCRA)
     - Pennsylvania Clean  Streams Act
     - Toxic Substances Control Act (TSCA)
     - Executive  Orders 11988 and 11990 on Floodplains and Wetlands

     The alternative chosen meets the NEPA functional equivalency exception
 because the necessary and  appropriate Investigation and analysis of
 environmental factors as they specifically relate to the Douglassville
 Disposal Site and the recommended alternative were considered and
 evaluated in the  Remedial  Investigation/Feasibility Study.  In addition,
 a meaning fi*l_apportunity for public comment on environmental issues
was provided before the final selection of the remedial alternative
was made.

     Compliance with all applicable substantive requirements of the
 CWA and CAA as well as the Pennsylvania Clean Streams Act will be
 incorporated into the design of the remedial alternatives.  Any
discharge into the atmosphere of gas from excavation of the drainage ditch
will be monitored and treated as necessary.  All state permits for discharge
of treated surface water will be acquired and complied with as necessary.

     The caps placed over  the facility sludge disposal area, former
sludge lagoon area, and sludge disposal area shall be designed to meet
EPA* s engineering specifications for constructing a RCRA cover required by
40 C.F.R S264.228.  Ground water monitoring shall be developed during

-------
                                     19
design co satisfy  the  requirements of 40 C.F.R. Part 264 Subpart F.
Excavation of "contaminated materials and sediments in the drainage ditch
area will be removed and consolidated if estimated volumes are verified in
the pre-design study.  The area will then undergo "clean closure" as per
RCRA regulations.

     Further investigation of ground water was elected to satisfy the
requirements of RCRA 40 C.F.R. Part 264 Subpart F.  Organic contamination
was detected in onsite ground water.  RCRA 40 C.F.R. Part 264 Supbpart
F would require further Investigation as to the nature, source, and
extent of this contamination.  Additional study work will be conducted
to establish an Alternate Concentration Limit, if necessary, and to assess
the need for corrective action as defined in 40 C.F.R. Subpart F.
Proposed Action

     We request your approval of the recommended remedial alternative
as described above.  We also request that you approve the deferment of
ground water pumping and treatment and construction of the slurry wall
until further investigations can be performed.  The estimated cost of
the approved portion of this project for design and construction is
$5,569,500.  This includes the Corps of Engineers supervisory cost.

-------
     Remedial Action Alternative

1.   No action with monitoring

2.   Non-RCRA approved caps In facility
    and lagoon areas with monitoring

3.   Non-RCRA approved caps In facility
    and lagoon areas with groundwater
    treatment and monitoring

4.   RCRA-approved caps In facility and
    lagoon areas with groundwater
    treatment and monitoring

5.   Transfer of all soils to lagoon
    area. RCRA-approved cap In lagoon
    area,  with groundwater treatment
    and monitoring

6.   RCRA-approved landfill In lagoon
    area with groundwater treatment
    and monitoring
                                              t
                                                    TABLE
                                         PROJECT COSf SUMMARY ((1.000s)
                                           Capital Cost
                                            Estimates
  Low
High
$    210  $   218

   1.794    2.340


   3.176    4.902




   5.763    8.535




   7,054   11.936





  18.146   30.202
                          Operation & Maintenance
                               Cost Estimates
Yrs
1-2
 Yrs
3-30
Yrs    Yrs
1-2   3-30
            $  126  $ 126  $  130  $130

               148    148     152   152
               388
         150
          675   150
               452    193     739   193
               421    172     708   172
               464    208     751   208
 Present Worth
Analyses (30 Yrs)
 Low     High
                               $ 1,398  $  1.443

                                 3.189     3.773
                  5.003    7.227
                                 8.032   11.302
                                 9.108   14.488
                                20.551   33.105

-------
TABLES
PROJECT COST SUMMARY ($ 1.000s)
PAGE TWO
     Remedial Action Alternative

7.   Onsite Incineration, RCRA-approved
    caps in facility and lagoon areas
    with groundwater treatment and
    monitoring

B.   Offslte disposal In RCRA-approved
    landfill with groundwater treat-
    ment and monitoring

9.   Offsite Incineration and disposal
    with groundwater treatment and
    monitoring
   Capital Cost
     Estimates
  Low      High

$ 67.349  $147,373
 105.932   197.383*
 417.903  678,892
                                                                    Operation & Maintenance
                                                                        Cost Estimates
  Yrs
  1-2
 Yrs
3-30
Yrs
1-2
 Yrs
3-30
$  452  $  193   $  739  $193
   373
 1.405
  135
 660    135
 Present Worth
Analyses (30 Yrsl
 Low     High
                        $69.618  $150^140
          107.610  199.567
  135*  2,252   135*    422.155  685.035
  Cost given actually represents annual  O&M cost for years  4-30 only.  Costs for year 3 are
  $1,167.000  (Low) and  $1.727.000 (High), representing  the third  year of O&M costs Incurred for
  the drum packaging plant.

-------
IAUU3
R1MUNAI ACTION AUERMAIrVt: INADf -Off MAI MM
DOUGLASSMUE DISPOSAL SITE
PAGCfOOR
                               CQtj
Ranoa m.OOOsI
Remedial Action
Alternative Capital Piasanl Worth
7 Ontlle mctaera- $67.34*- 147.373 $«fl.6ll-l&O.I40
lion. RCRA-
apotovad caps In
lacllily and
lagoon aieai
wllh levee.
gioundwaler
liaalinenl end
moniioiing








8 Ollsile 104.831- 197,183 I07.818-189.S87
disposal to
RCRA-appioved
landllU wllh
groundwalar
Ireatmenl and
moniioiing

•



Technkal
Concains
Organic contamin-
ation souices
eKecllvely ellmln-
aled.
Tonic melala not
destroyed by
inclneiatlon.
Soils volumea not
(ubslanllatly
i educed
Etleclivenetf ol
gioundweler pump-
Ing liom liacluiad
lock dillicull to
deieimlne.


Contamination
lourcea eUmlnaled
horn site.
Removal of
source proven
technology.
Ellactlveneit
ol gioundweter
pumping liom
lieclured lock
dilllcull to
deleimlne.
Public Haallh
Concains
»lat k emissions
no> lioiad and
:on rolled to
•nln mite tisks ol
nhalalion
'mposuie.
ICF*.-appi.vad
:ap . highly
mp -Mineable.
•edrclng
leiiual
tuprsuie to a
minimum
jioundwalar
reaimanl
Himinates
ngestion risk
'nhatallon and
dermal
iipesuie risks
during lians-
;iort Souice
emuval and
troundwaler
lealmanl
nllminale long
•eim enposuie
•Isks

Envlionmamal
Concerna
Stack emissions
monitored and
treated.
Migration to
surface and
gioundwaler
reduced.
leachale
geneietlon
leduced.
Oroundwater
contamination
mitigated.




Potential
environmental
exposure during
transport.
Source removal
eliminates
environmental
concein hi site
vicinity.
Groundwalaf con-
lamlnallon
mitigated.
Inslltullnnal
Concerns
Slack emissions
must meat NAAOS
Incinerator and
caps musl moel
RCHA rei|uuaments.
Subiecl to llooil-
plain reyiilalions
Musi meet Slai
01 federal water
quality require-
ments.






Requites I'AIHH
lianspnilatirm
licenses. IICIIA
lianspoil and
disposal
inanilasis
Musi conluini lu
1)0 1 legulallons
Musi moel Slate
01 f edeial waiei
quality require-
ment!

Olhois
I'liiialile

i:urienlly
nnavailalile
liiisnin duo lu
lhiuilmi| rcdui:ucl
liy levi'tf



y





,
lllijll HanspufU
Iron anil disposal
mils
(lllsrla disposal
IdCillly inirsl he
In cornplianie
wilh all a|>|ili •
table enviiun-
inenidl reijnlairurii




-------
IAINE3
MMtOMl ACIION MlENMAUVC IRAUf-OFF MA1MX
DOUGIASSVMIE DISPOSAL SIIE
PAG£ IM
                                   Coti Harm* lll.ooosl
Remedial Action
   Allainally*

  Ollsll*
  Incineration and
  disposal with
  gioundwalar
  tieelmenl *nd
  monitoring
                               Caoltll
                          S4I7.90J-I7M92
  Pt«s*m worth

t422.ISS-6«S.03S
                                                                          Technical
                                                                          Concttni
Contamination
sources eliminated
liom sit*.
Capacity ol sol*
Inclnaiallon
lacilily may be
  Public health
    Concerns

S >urc* removal
and ground-
water treat-
ment eliminate
long term
exposure risks.
                                                                      Immedlsle access
                                                                      lo rail trans-
                                                                      portation
                                                                      unavailable
                                                                      Effectiveness ol
                                                                      groundwaler
                                                                      pumping from
                                                                      fractured rock
                                                                      dllftcull to
                                                                      determine.
 Environmental
    Concerns

Sourc* rwnoval
allmlnales
environmental
concern In sit*
vicinity.
Groundwater
contamination
nililgeted.
   Inslllulional
    Cuncemi

ReqiHies PAItER
liansportallon
licenses. RCIIA
transport and
disposal
manllesls
Musi conform lo
OOf reyulallons.
Must meet Slat*
or f adcial water
quality requite -
menls
	Pillars	

lliljti iianiiMii-
lion and
Im mciallon/
disposal costs
Inclnoialiun
lacilily must be
In <.fiiit|iliance
will Jll appll-
radio eiivlion-
inenlal rouuUllons.
liicineiatiuii
losuluos will
te<|inro disposal
In a secure.        (
peuniiled facility.

-------
IA1NC 3
MMtlNM ACIMMt ALTERNATIVE TRADE-Off MATRIX
DOUGIASSMUE DISPOSAL SITf
PAGE TWO
                               Cort Ranaa m.OOOsI
Ramadial Action
AHainlllva Capital
4 RCIIA approved I&.783-I.&3V
cap* in racUlty
•nil lagoon araat
with lavaa. tlutry
wan. gas wanting.
gioundwalar
liaalmanl Mid
monitoring






6 Translar ol aH /.OM-II.IM
toll* to lagoon
aiaa. BCRA-
•pprovad cap In
laguon aiaa wllh
lavaa. slmry
wall, gai training.
gioundwalai
liaalinanl and
monlioilng







Tachnlctl
•tatant Worth Concarni
$8.032- 11.301 Inllllrallon
and laachala
production
nilnlmltad.
allacllvanatt
ol groundwaltr
pumping horn
Iraciuiad lock
dilllcult to
datarmlna.
Croundwalar
migration undar
flurry wall dua
to Iracluras.
9. 108- I4.4M Conumlnallon
tourcai raducad
to ona. Inlll-
lrallon and
laacnata
production
rnlnlmliad.
Ettacllvanaii
ol gioundwalar
pumping from
Iraciuiad rock
dilllcult to
dalarmina.
Gioundwalar may
mlgrala undar
ilurry wall dua
Iraclurat.
l-utlic Maallh
Cone arm
RC lA-appiovad
ca| « highly
Impainiaabla.
raduclng risk
ol opoiura lo
• minimum.
Ori undwaiar
Iraatniant
•lit ilnatat
lulura
Ing islton rltk.



Pulilk anpoiura
rltit raducad
dua lo
cortolldallon
ol all watlat
larthar Iroin
rai:dancos.
RCDA-approvad
cap highly
Itn) annatbla.
raducing
axpotura lo a
minimum.
Cro indwalar
Iraalmant
•tin Inalai lulura
ng< stion risk.
{nvlionmanlal
Concarni
Migration lo
turfaca and
groundwalw
raducad.
laachal*
ganarallon
radocad.
Groundwata*
contamination
mlllgalad.




Migration lo
luitaca and
gioundwalar
raducad.
laachat*
ganarallon
raducad.
Gioundwatar
Conumlnallon
miilgatad.







Inslliuiional
Coiiceini Uiheis
Maali RCHA rrusinn dua lo
raiiulramenli. llnoilniy
Subjacl to leiliimil by
Hood plain Inviia
reguUliuni.
Must meat Slaia
or f adaral
watar quality
raquiiamanls





Maalt RCIIA 1 MISIIIII dua
raquiraiiionts lo lluiKlinu
Subjact lo lutlm-nil by
Hood plain lavaa
regulations
Must maal fadaral
or Slalo walar
quality iai|uua-
rnaiils.






1


-------
IAIMI 3
M.MIIMM ACimN AUEMMAIIVE IHADE-OfF MATRIX
OOUGIASSVaiE INSTOSA1 SIIE
PAGC limit

                                           1» 1.000*1
   Remedial Action
     Alternative

    RCRA-approved
    landfill in
    (•Boon area
  1  with levee.
    groundwater
    treatment md
    nionlluilng
* ' lechnkel
Capital Preienl Worth Concern!
t1l.l4e-30.202 120.551-3X105 Contaminant
aourcea ellec-
llvely contained.
However,
long-term
lallablUly of
landllllt not
yal ailaMltlMd.
Etlactlvanatt
ol gioundwaiar
pumping from
liacluiad rock
dllllcull to
dataimlna.












Public llaallh
	 C incatni
f iblk anpotuf*
rl^kt aducad
d-ia In
c-mtolldailon
o' all wtiiit
It tlhtf Irom
rnldfncai
RCRA -approvad
landll
p-o«l lat high
dagira ol con-
ti inn ant.
g aatly raduclng
••pofura iltki
o* ollitla
iLcaploit
Croundwalai
tivilmant
t Imlnatat
Ibluia Ingaillon
risk.





Environmental
Concarni
Large quantity
ol material
e»cawaled and
Iraniporled
posei high
rlik ol
environmental
ellacta.
especially
volalUltatton
ol organlca.
during con-
ilrucllon.
Contaminant
migration to
lurlace and
groundwalw la
reduced aNar
contlructlon It
completed.
Leachate genera-
tion reduced end
collected.
Oioundwater con-
tamination
mitigated.
Inilltulional
Contains
Meelt nCRA
requliainanii
Subjacl to
Mood plain
regulations.
Mutt meet State
or Ceileial wjl«i
quality requlre-
menli.


















Olticrs
trutlim ol con-
laiittitutuiJ toil
loilui uil by
leiniiuiary dikat
and i«dlin«nl«-
liun putitli. tnil
liy ItfVttO


















,

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                    Douglassville  Responsiveness  Summary











      The  Douglassville  Superfund  Sice consists of approximately 50 acres




 just  west of  Douglassville,  Berks Coir ;y, Pennsylvania, on  the southern




 bank  of the Schuylkill  River.  A  waste oil processing facility is located




 on  site,  along with a series of backfilled lagoons.  The facility includes




 office buildings, a garage, a water treatment system, a former drum




 storage area, and an oil/water separator.  In September, 1983, the site




 was placed on the National Priorities List.  EPA received no comments




 from  the  nearby community regarding placement of the site on the NPL.




 EPA held  a public meeting in March, P84, to discuss the site Remedial




 Investigation and Feasibility Study workplan.  Eight Interested members




 of the nearby community attended  the meeting.  Host of their questions




 centered  on two main issues:  the timeframe of the work, and the extent




 of contamination.   EPA explained  that the Remedial Investigation would




 address the extent  of contamination, and it would take approximately 7




 months to complete.  EPA also said the Feasibility Study is expected to




 take  about four months to complete, after thlgr ••medial Investigation is




 finished.




      In August, 1984, questionnaires requesting information on private




water wells were sent to residents living near the site.  A door-to-door




 survey to discuss well sampling was conducted by EPA.  Residents were not




highly concerned with the site, but, several of them asked to have their




wells tested.  Also, some residents, when asked, commented that the site




operations were "quiet" and that  the trucks entering and leaving the site




were  "cautious and  careful."  Children often play on and near the site.

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Two residents said they didn't feel work was necessary at Che site because



they would prefer  to  see  the money used to correct a road drainage problem.



Only two residents expressed some concern over the potential for



contamination of private water supplies and possible health effects of



contaminants found on site.  Both of those residents requested that EPA



sample their water wells.  Several times, the 1972 storm known as Hurricane



Agnes was referred to by the residents.  They told EPA that after the



flooding of the Schuylkill River, (which was caused by Hurricane Agnes)



several houses on Highway 724 were coated with oil.  News accounts



following the flooding of 1972, and backfilling of the lagoons, however,



brought no response from local residents.  Questions from the two residents



regarding the possibility of private well contamination were answered



when they received the sample results, which showed contaminants below



levels of concern.



     As the Remedial  Investigation of the site progressed, residents and



the press did not display a high level of interest in EPA's work at the



site.  The RI/FS was  completed and placed in the repository at the Union



Township Building in June, 1985.  Notice of a public meeting was made



through a press release to area media.  The meeting was held Wednesday,



July 10, 1985 at the Union Township Building.  About 20 people attended



the meeting.  The comments centered on a specific lagoon area which is




contaminated with PCBs.  Several residents asked If their ground water



would eventually be affected by PCBs from the site.  Those people were



told the threat only existed from direct contact, and after the sampling

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in September, 1984, PCBs were not detected in the residents' private




water wells.  The only written comments that EPA received were from 3




resident who lived a few houses away from the site.  The resident noted




that the onsite well with the highest level of contamination is closest




to the residential area.  This resident has suggested that, in the place




of new onsite monitoring wells, EPA should regularly test privately-owned




wells as part of the implementation of the design stage of the project.




This suggestion was also mentioned at the public meeting.  In response,




EPA explained that a hyrirogeologic study was conducted at the site, and




the ground water gradient is in the direction away from the residential




water wells.  If contamination increases in the onsite monitoring wells,




then there is the possibility that private wells will be tested again.




     EPA will hold a public meeting when the design stage is complete to




discuss the work that will be done during the site cleanup.

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