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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(b) IDENTIHERS AND OPEN-ENDED TERMS - Use identifiers for project names, code names, equipment designators, etc. Use open-
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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^..
-------
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.
-------
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.
-------
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
-------
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.
-------
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
-------
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
-------
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
-------
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
-------
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.
-------
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.
-------
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.
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:onlacl camaln
•onlble
•ope luia
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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
,
-------
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.
-------
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
-------
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.
------- |