United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROO/R03-88/041
June 1968
Superfund
Record of Decision
Douglassville Disposal, PA
-------
30272-101 .
REPORT DOCUMENTATION
• PAGE*
1. REPORT NO.
EPA/ROD/R03-88/041
3. Recipient** Accession No.
4. Title and Subtitle
SUPERFUND RECORD OF DECISION
P^-iglassville Disposal, PA
ond Remedial Action
5. Report Date
06/24/88
7. Au is)
8. Performing Organization Rept. No.
9. Performing Organization Name and Address
10. Project/Task/Work Unit No.
11. Contract(C) or Grant(G) No.
(C)
12. Sponsoring Organization Name and Address.
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report & Period Covered
800/000
14.
15. Supplementary Notes
16. Abstract (Unit: 200 words)
The Douglassville Disposal site occupies approximately 50 acres of land in Union
Township, Berks County, Pennsylvania. It is almost entirely within the 100-year
floodplain of the Schuylkill River. In 1941, Berks Associates began recycling
lubrication oil at the site; waste solvents were recycled in the 1950s and 1960s.
Wastes generated from those recycling processes were stored in onsite lagoons from 1941
"til 1972. In November 1970, heavy rains caused the lagoons to overflow and release
00,000 - 3,000,000 gallons of wastes down the Schuylkill River. Federal and State
_.-ions were initiated to dispose of the waste material remaining in the lagoons.
Before this action could.be carried out, heavy rains from a hurricane caused the river
to overflow its banks and inundate the entire site area in June 1972. An estimated
6,000,0000 - 8,000,000 gallons of wastes were carried by floodwaters downstream for
about 15 miles. During cleanup after the storm, the lagoons were drained and backfilled
by EPA. Lubrication oil recycling operations continued at the site until 1979 when the
operator determined operational correction mandated by the Pennsylvania Department of
Environmental Resources (PADER) were cost prohibitive. Operations then turned to the
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 onsite. This
(See Attached Sheet)
17. Document Analysis a. Descriptors
Record of Decision
Douglassville Disposal, PA
Second Remedial Action
Contaminated Media: debris
inorganics (lead), PAHs, PCBs, VOCs
c. "^SATI Field/Group
18.
-ility Statement
19. Security Class (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
43
22. Price
(See ANSI-Z39.18)
See Instructions on Reverse
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
Department of Commerce
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EPA/ROD/R03-88/041
Douglassville Disposal, PA
Second Remedial Action
16. ABSTRACT (continued)
practice was halted in 1981 when PADER mandated operational corrections to the
landfarming practices. In late 1985, all oil recycling operations at the facility were
completely discontinued. This operable unit addresses the 3-4 acre area in the southern
most portion of the site and is hydraulically upgradient of the rest of the site. The
area consists of a concrete building, process equipment, piping, and at least 57 process
tanks. The tanks are constructed of wood, concrete, or steel and range in size from
3,000 gallons to 600,000 gallons. Approximately 200,000 gallons of PCB and lead
contaminated oil and waste sludges remain in the tanks. The buildings, tanks, tank
wastes, and processing equipment are impediments to any future soil and ground water
remediation, and are a source of continuing contamination of these media. The primary
contaminants of concern include: VOCs, PCBs, PAHs, and lead.
The selected remedial action for this site includes: removal of liquid and sludge
tank waste with transportation to an offsite incineration facility; decontamination of
tanks, piping, processing equipment, and building materials; offsite disposal of
building rubble, selling of tanks and other metal materials as scrap; offsite disposal
of concrete, asphalt, and other materials; and treatment of generated decontamination
fluids, as appropriate. The estimated capital cost for this remedial action is
$4,050,000. No O&M will be incurred.
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DECLARATION FOR THE RECORD OF DECISION
Site Name and Location
Douglassville Disposal Site - Union Township, Berks
County, Pennsylvania.
Statement of Basis and Purpose
This decision document represents an operable unit
remedial action for the Douglassville Disposal Site developed
in accordance with the Comprehensive Environmental Response,
Compensation, and Liability Act, as amended, and to the extent
practicable, the National Contingency Plan.
This decision is based upon the administrative record.
The attached index identifies those documents which comprise
the administrative record. The following were of particular
relevance for the purposes of this decision document:
1. Remedial Investigation Report/Feasibility Study of
Alternatives, Volumes I, II, and III, Berks Associates,
Douglassville Disposal Site, Union Township Berks Count'y
Pennsylvania, prepared by NUS Corporation, June, 1986.
2. Final Focused Feasibility Study/Facility Removal,
Douglassville Disposal Site, Berks County, Pennsylvania,
prepared by NUS Corporation, April, 1988.
The State of Pennsylvania concurs on the selected remedy.
Description of the Selected Remedy
This is an operable unit in the process of remediation
of the Douglassville Disposal Site. Other remedial actions
will be delineated in future Records of Decision.
The selected site remedy does not attempt to meet compliance
with all applicable or relevant and appropriate requirements
(ARARs) which would be pertinent to a final remedy for the site..
However, this remedy will be consistent, to the extent practicable,
with those ARARs which are pertinent to the particular circumstances
of this operable unit.
The selected remedial action consists of:
1. Removal of the liquids and sludges remaining in the
tanks of the former processing facility.
2. Removal of liquids and sludges from incidental tanks
and trucks on other portions of the facility.
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-2-
3. Transporting these liquids and sludges to an offsite
facility for incineration.
4. Decontamination of tanks, piping, and structures.
5. Dismantlement of the entire former processing facility,
6. Disposal of the uncontaminated tanks by sale as scrap.
7. Disposal of the uncontaminated rubble in an offsite
disposal facility.
8. Disposal of rubble which cannot be satisfactorily
decontaminated in an offsite permitted hazardous
waste disposal facility.
Declaration
The selected operable unit remedy is protective of human
health and the environment, attains Federal and State require-
ments that are applicable or relevant and appropriate, and is
cost effective. The action being taken is appropriate when
balanced against the availability of Trust Fund monies for use
at other sites. This remedy satisfies the preference for treat-
ment that reduces toxicity, mobility or volume as principal
elements. Finally, it is determined that this remedy utilizes
permanent solutions and alternative" treatment technologies to
the maximum extent practicable. / /
Date / JamesTu Seif
"Regional Administrator
Region III
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Site Description and Summary of
Remedial Alternative Selection for
the Douglassville Disposal Superfund Site
Former Processing Facility/Tank Farm Operable Unit
Introduction
The Superfund investigation of the Douglassville Disposal
Site addresses various environmental media and their contamina-
tion with polychlorinated biphenyls (PCBs), lead, volatile
organic compounds and polynuclear aromatic hydrocarbons (PAHs)
in an oil matrix. For the purposes of the investigation, the
site has been divided into areas suspected of containing certain
types or degrees of contamination, or which have certain physical
or historical use characteristics thereby allowing a reasonable
degree of definition. These areas include an oily filter cake
disposal area; two former sludge lagoon areas; a former drum
storage area; a former landfarm area; the former processing
facility/tank farm area; ground water and surface waters.
This Record Of Decision will summarize the results of a
Focused Feasibility Study which addresses the former processing
facility/tank farm area, and will present a remedy for this
operable unit. Other aspects of the site'wiil be addressed in
subsequent Records Of Decision which will be based upon a compre-
hensive RI/FS presently being completed.
Site Location and Description
The Douglassville Disposal site occupies approximately 50
acres of land in Union Township, southeastern Berks County,
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 of the Schuylkill
River.
The area around the site can be described as a rural setting
consisting of cropland, 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, approximately 4 miles downstream from the site on
the Schuylkill River, has an estimated population of 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.
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-2-
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 so designated for the purposes of "conserving and enhancing
its scenic quality and of promoting public recreational enjoy-
ment 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, recrea-
tion, and waste assimilation. In the reach extending downstream
of the Douglassville Disposal Site to the confluence with the
Delaware River, seven public water supply users withdraw water
directly from the Schuylkill River. The distance to the
nearest public water supply intake is 4 miles at Pottstown.
Geologically, the Douglassville 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 mudstones 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 planes. The Brunswick Formation is generally capable
of yielding adequate water for household use. A number of
residential wells are located with 1/2 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 water table at the site varies from
10 to 20 feet.
The Douglassville Disposal Site was the place of operations
of Berks Associates, Inc., since its inception in 1941. The
non-operating facility currently consists of a former waste oil
processing area located in the southern portion of the site and
various areas which were used for waste disposal. The former
processing facility/tank farm area consists of an office
building, garage, 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
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-3-
r ^
PENNSYLVANIA /'
P
;L'*OHANGL£ LOCATION
IDOUGLASSVILLE DISPOSAL
BASE MAP IS A PORTION OF THE U.S.G.S. BOYERTOWN, PA QUADRANGLE (7.5 MINUTE SERIES, 1957, PHOTOREVISEO
1973). CONTOUR INTERVAL 20'.
FIGURE I
LOCATION MAP
DOUGLASSVILLE DISPOSAL SITE. UNION TWP. PA
IMUS
CORPORAnON
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POTENTIAL SOURCE
AREA/NUMBER(TVP)
ABANDONED SCHUVLKILL
CANAL
M) AbANOONlU INCINERATOR
-SLUDGE TRUCKS
4) f *f «« Slurff « Oli(K,»4 A >.< A
fixnwr Siu^gl Dii^«t*l A(*< •
III Af M
(ofln«««K A lur (Oun^lnfl ATM
Of um * T»nk«t Af ••
i.«kl*»d U»o«n A...
Drum. T«nk 1 •«lut« Af ••
GENERAL SITE FEATURES AND POTENTIAL SOURCE AREAS
DOUGLASSVILLE DISPOSAL SITE. UNION TWP, PA
i
4--
FlGUHf
IJK~lG
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-5-
aerial photographs, lies between the ditch and the swale. A
former drum storage area is located just north of the confluence
of the ditch and the swale (Figure 2).
A filter cake disposal area is located just north of the
former processing facility/tank farm area. Various trenches
and impoundments have been noted on-site. The lagoons formerly
used for waste disposal have been backfilled.
An inactive railroad line extends through the site in an
east-west direction, and the abandoned Schuylkill Canal borders
the southwestern portion of the site.
Site History
In 1941, Berks Associates, Inc., began lubrication oil
recycling operations at the site. Site operations also in-
cluded 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 which
flowed down the Schuylkill River.
The dikes were repaired pursuant to the provisions of a
consent order entered into between Berks Associates, Inc., and
the United States. That order also prohibited Berks Associates
from storing waste materials 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, the
heavy rains of Hurricane Agnes caused the Schuylkill River to
overflow its banks and inundate the entire site area in June of
1972. An estimated 6-8 million gallons of wastes were released
and carried by floodwaters downstream for about 15 miles. During
cleanup after the storm, the lagoons were drained and backfilled
by EPA.
Berks Associates, Inc., continued lubrication oil recycling
operations until 1979 when the operator determined that
operational corrections mandated by the Pennsylvania Department
of Environmental Resources (PADER) were cost-prohibitive.
Operations then turned to the 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
landfarming practices.
Results of an EPA Region III Site Investigation in April,
1982 showed volatile organic contaminants in the drinking water
well which was utilized by workers at the facility. During
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-6-
the Site Investigation the Schuylkill River (upstream and down-
stream of the site), the facility discharge, the drainage swale
sediment, and a domestic well (upgradient from the site) were
also sampled.
Based on the results of the Site Investigation the site
received a Hazard Ranking System (MRS) Score of 55.18. The
Douglassville Disposal Site was proposed for inclusion on the
National Priorities List in December, 1982. The site was pro-
mulgated on the National Priorities List in September, 1983.
A Phase I Remedial Investigation/ Feasibility Study (RI/FS)
was conducted by EPA in 1984-85. That RI/FS did not include the
processing facility/ tank farm area which was still in operation
at the time. A Record of Decision was signed in September, 1985
recommending containment of wastes in the area addressed by the
Phase I RI/FS. That Record of Decision deferred the consider-
ation of resolutions for ground water contamination to future
RODs.
In late 1985 all oil recycling operations at the facility
were completely discontinued. In April 1988, EPA completed a
Focused Feasibility Study ( FFS ) to specifically address the
contamination at, and the remedial alternatives for, the former
processing facility/ tank farm portion of the site. EPA is
presently completing a comprehensive Phase II RI/FS which will
address all aspects of the contamination at the Douglassville
Disposal Site.
Scope and Role of the Operable Unit
This Record of Decision addresses the former processing
facility/ tank farm area and incidental tanks and vehicles as an
.operable unit pursuant to EPA' s April, 1988 FFS. The 3-4 acre
area is located in the southernmost portion of the site and is
hydraulically upgradient of the rest of the site (Figure 3).
The area consists of concrete buildings, process equipment,
piping and tanks that were used for oil recycling operations.
At least 57 process tanks, both in and above ground, have bean
inventoried. These tanks are constructed of wood, concrete or
steel and range in size from 3,000 gallons to 600,000 gallons.
Approximately 200,000 gallons of PCB and lead-contaminated oil
and sludge wastes remain in the tanks. The buildings, tanks,
tank wastes and processing equipment stand as impediments to
any soil and ground water remediation which might be desired
in the future, and as a source of continuing contamination
of these media.
Summary of Operable Unit Risks
The former processing facility/ tank farm area is one of the
most contaminated portions of the site. Soils have received more
than 40 years of spills from the oil and solvent reclaiming
processes which operated at the site. This pollution of the soil
apparently extends to the water table. Ground water under the
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ft/ //
AREA DESCRIPTION
(A) STORAGE TANKS
(i) LABORATORY 8 OFFICE BUIL UlNl /
(cf) PROCESS BUILDING a EOUICMI N i
(o) STORAGE TANKS
E PROCESS TANKS
STORAGE TANKS
G PROCESS HEATERS
(H) STORAGE TANK
(T) PROCESS TANKS
(j) BUILDINGS
(K) TRUCK GARAGE
(T) TREATMENT PLANT
i
--J
i
LEGEND
O
- TANK OR EQUIPMENT
PROCESS EQUIPMENT
NOTE: SEE APPCNUX A FOR DESCRIPTION i.»
EQUIPMENT.
IDENTIFICATION OF AREAS AND COMPONENTS SURVEYED AT THE PROCESSING FACILITY
DOUGLASSVILLE DISPOSAL SITE. UNION TWR. PA
FIGURE 3 '
lMU
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-3-
area is grossly contaminated. Physically, the various structures
and tanks in the area are in a dilapidated condition and continue
to deteriorate presenting a potential hazard should they collapse.
Also, because much of the 200,000 gallons of wastes exhibit low
flashpoints or are combustible, a fire or tank explosion could
result in a release of hazardous substances to the environment.
This would further contaminate soils and would contribute addi-
tional burdens of contamination to ground and surface waters as
well as dispersing hazardous substances into the air.
The site access is unrestricted and there is a danger of
direct contact with lead and PCB-contaminated oils and sludges
by persons who might enter the area. Wastes remaining in the
tanks in the area of the operable unit display flashpoints as
low as 97 degrees and heating values ranging to 19,700 Btu/lb
(Table 1). Lead concentrations were detected as high as 15,800
mg/Kg (Table 2) and PCS levels range to 6,400 mg/Kg (Table 3).
Description of Alternatives
The major objectives of this operable unit include:
(1) minimize direct contact with contaminated oil sludge wastes;
(2) eliminate the various threats to public health and the envi-
ronment posed by the combustible wastes remaining in the tanks;
(3) eliminate the buildings and tanks as impediments to future
remediation of soils and ground water underlying the area.
Based on the above objectives, a number of control technolo-
gies were screened to provide a limited number of technologies
applicable for remedial actions relevant to the operable unit.
Some of these technologies were removed from further consideration
based on site-specific constructability, time requirements to
achieve cleanup, and physical and chemical suitability. The
candidate technologies that were dismissed from retention are pre-
sented below with a summary of the justification for elimination.
(An expanded discussion is in the FFS report.)
Technology Reason(s) for Elimination
- Solidification of Tank The volume and toxicity o'f
Wastes wastes would not be. reduced.
The high organic content of
the wastes makes permanent
solidification questionable.
- On-site Biodegradation Degradation of PAHs and PCBs
of Tank Wastes is suspect. Lead concentra-
tions would not be reduced.
Because EPA's April, 1988 Focused Feasibility Study is
concerned with the former processing facility/tank farm operable
unit, remedy considerations are limited to the operable unit and
are not intended to constitute remedial alternatives for the
site in its entirety. The alternatives that have been retained
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TABLE 1
PHYSICAL CHARACTERISTICS OF TANK WASTE
DOUGLASSVILLE DISPOSAL SITE *
Parameter
Flashpoint (°f)
Melting Point ("C)
Boiling Range (°C)
Viscosity (cST)
Heating Value
(BTU/lb)
Total Chlorine
<«g/kg)
Sulfur (« by wL. )
Moisture («)
Ash (« by wt. )
Specific Gravity
Oil-ElO, Fl,
F2. F3
205
-40
84->200
28.6
19.700
2.5/0
0.43
9.8
<0.1
0.89
Sludge ElO
Fl. F2. K3
135
-50
45.->200
>2.100
12.100
12.300
0.52
25.8
9.7
1.08
oil- i-:i-t:9
>215
-60
64->200
40.8
18,900
1.3/0
0.45
6.5
<0.l
0.89
Sludge-
El K9
>160
-65
84 >200
>2,100
12.000
10,100
0.67
28.3
5.6
1.02
Oil 02,
1)4 1)1 J
>215
-60
51->200
16.8
19,200
1.430
0.48
19.7
<0. 1
0.89
SI udijc
014. Nl, N2
>lbO
NA
100->200
NA
6,100
3/0
0.31
20.7
43.0
1.27
Sludge HI
-150
/5
37 ^200
-2, 100
7.900
64,400
0. 51
41.4
18.0
1.19
* The designations F3, DA, etc. refer to sampling locations as shown on Figure 3.
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TABLE 1
PHYSICAL CHARACTERISTICS OF TANK WASTE
DOUGLASSVILLE DISPOSAL SITE
PAGE TWO
Parameter
Flashpoint (°F)
Melting Point (°C)
Boiling Range (°C)
Viscosity (cST)
Heating Value
(BTU/lb)
Total Chlorine
(•gAg)
Sulfur (% by wl. )
Moisture (%)
Ash (» by wt. )
Specific Gravity
Sludge-AS,
A14
138
-85
84->200
>2.100
12,000
8.670
0.60
55.1
10.7
1.08
Sol vent A13,
Ol
97
NA
NA
2.34
NA
NA
NA
NA
NA
0.86
Sludge-M3
>200
-50
49->200
406
18,100
5,000
0.46
3.2
3.4
0.93
Oil 11,
12, 14 112
>190
-55
61-150
65.5
17,700
1.130
0.39
17.2
0.8
0.90
Oil Area 1 Pipe
Trenches
>160
-55
65 120
1.550
5,100
96/
0.29
50.4
2.0
0.99
Oi 1 Tankei
Trucks
200
-65
61 -200
44.4
19,100
2.520
0.46
6. /
0.9
0.90
NA: Not analyzed
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TABLE 2
METAL CONCENTRATIONS (mg/kq)
FACILITY AT IKMJGLASSVlLLE DISPOSAL SITE "
Parameter
Aluminum
Ant iiuony
Arsenic
Barium
Beryl 1 ium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Mickel
Potass ium
Selenium
Silver
Sod ium
Tha 1 1 i um
Vanadium
'i inc
Oil-ElO, PI,
F2, P3
--
--
-'-
1/4
--
--
--
4.9
--
14 .
329
1,680
--
3.0
0.1
--
--
__
--
-
197
Sludge-EiO,
PI, P2, F3
514
14
27
2,260
7.8
1,780
56
-- '
276
5.720
9.240
--
50
2.3
48
--
3.0
--
1,510
30
--
1,500
Oil E1-E9
87
-
--
76
--
--
--
--
71
263
785
--
12
--
--
. .. .
--
148
Sludue E1-E9
421
45
2.t6
550
--
12
4,860
97
--
872
3.330
15,800
1.500
K4
0.7
22
0.9
14
2.390
17
2.530
Oil 02,
U4-U1 1
1 1
1 15
--
--
--
19
174
941 .
--
3.7
0.1
--
--
9. /
14(»
SlmJ.je 1)14.
HI , N^
9.700
25
5.6
819
7.0
14.MJU
--
--
240
7.SSO
8J2
J.ttJO
186
0. 1
1 J
1 ,1)00
1 ,2tiU
* The designations F3, M, etc. refer to sampling locations as shown on Figure 3.
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TABLE S
METAL CONCENTRATIONS (ing/kg)
FACILITY AT DOUGLASSVILLE DISPOSAL SITE
PAGE TWO
Parameter
Aluminum
Ant imony
Arsenic
Bar ium
Beryll ium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Thai 1 ium
Vanadium
Zinc
Sludge -HI
1,910
72
7.9
1.860
--
29 .
8.390
521
54
3.680
23.600
12.600
1.730
294
1.7
193
--
1 .6
15
1,460
3,410
Sludge-A5,
A14
906
92
6.6
4,310
__
15
3,060
77
14
1,400
16,400
8,610
--
119
0.4
28
--
5.2
2,940
6,880
Sludge M3
2,550
17
2.2
603
--
7.0
3,610
32
198
10,400
12,000
--
120
0.5
39
--
--
--
4.970
--
1,8)0
Oil-Il. 12,
14 112 '
441
--
--
352
--
1.7
36
586
662
--
17
0.3
--
--
--
--
--
--
--
294
Oil-Area 1
Pipe Tienches
75
--
--
105
--
--
--
34
264
78/
__
7.4
0.2
--
--
--
--
--
JO 2
Oil Tanket
Tiucks
tlti
-
1 .S
-
10
ttl
523
972
1 2
0. 1
--
--
1, 14
-------
TABLE 3
PCS CONCENTRATIONS
FACILITY AT DOUGLASSVILLE DISPOSAL SITE
Sample
Oil-EiO, PI, F2, F3
Sludge-ElO, Fl, F2, F3
011-E1-E9
Sludge-El-E9
Oil-02, D4-D13
Sludge-D14, Nl, N2
Sludge-Hi
Sludge-A5, A14
Solvent-A13, Dl
Sludge-M3
Oil-Il, 12, 14-112
Oil-Area I pipe crenches
Oil-Tanker trucks (K1-K3)
Concrete Floor - Bldgs. C3-C6
Concrete Floor - Bldgs. C3-C6
Concrete Floor - Bldgs. C3-C6
Concrete Floor - Bldgs. C3-C6
Process Equipment - Bldg. C5, C6
Process Equipment - Bldg. C5, C6
Concrete Floor-Area I
Concrete Floor-Area I
PC3-1260
(mg/kg)
17
500
1.5
68
9
51
6,400
56
—
140
32
2
17
180
27
35
82
69
18
11
46
The designations F3, D4, etc refer to sanpling locations
as shown on Figure 3.
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-14-
for further analysis for the operable unit are summarized as
follows:
- No Action
- Tank waste removal with on-site incineration of the tank
wastes, and facility dismantling with off-site disposal
of decontaminated and uncontaminated tanks and rubble.
- Tank waste removal with off-site incineration of tank
wastes, and facility dismantling with off-site disposal
of decontaminated and uncontaminated tanks and rubble.
To analyze these alternatives, an evaluation was conducted
that considered the requirements of the Comprehensive Environ-
mental Response, Compensation, and Liability Act of 1980 (P.L.
96-510) as amended by The Superfund Amendments and Reauthorization
Act of 1986 (P.L. 99-499), and the current version of the National
Contingency Plan (NCP) (40 CFR Part 300). To facilitate a compar-
ative analysis of the three alternatives and to provide the
rationale for the selection of the remedy for the operable unit in
compliance with Section 121 of SARA, nine criteria were considered.
These criteria are:
1. Short-term effectiveness;
2. Long-term effectiveness and permanence;
3. Reduction of toxicity, mobility, and volume;
4. Implementability;
5. Compliance with Applicable or Relevant and
Appropriate Requirements (ARARs);
6. Overall protection of human health and the environment;
7. State acceptance;
8. Community acceptance;
9. Cost.
A detailed evaluation of the alternatives is presented in
Section 4 of EPA1s April, 1988 Focused Feasibility Study. The
following is a narrative summary of the evaluation:
Remedial Alternative 1; No Action
The NCP requires that the No Action alternative be considered.
This alternative will not be effective in reducing the present
risks to human health and the environment posed by the former
processing facility/tank farm. The overall protection of human
health and the environment will decrease with time as the facility
continues to deteriorate. Toxicity, mobility, and volume of
hazardous substances will not be reduced. Implementation of the
No Action alternative would inhibit the remediation of contaminat
soils and ground water underlying the area as a part of the overa,
site remediation.
It is unlikely that the Commonwealth of Pennsylvania or the
local citizenry would accept No Action at the facility.
-------
-15-
This alternative does not have any capital expenditures or
operation and maintenance costs.
Remedial Alternative 2: Tank Waste Removal and On-site
Incineration; Facility Dismantling with Off-site Disposal
This alternative involves on-site incineration of the tank
wastes and dismantling and decontamination of tanks, equipment/
and buildings. Decontaminated tanks would be scrapped. Decon-
taminated building materials would be disposed of in an off-site
landfill for non-hazardous waste. There may be a small amount
of material that cannot be decontaminated. Such material will
be disposed of in an off-site landfill for hazardous waste. (A
more detailed description can be found in Section 3 of the April,
1988 Focused Feasibility Study.)
- Short-Term Effectiveness
This alternative would reduce the immediate risks
posed by the site. Dust and other air emissions may
result from material handling, dismantling, decontamin- •
ation, and on-site incineration activities. Dust controls
and incinerator air pollution controls will be required.
Air.monitoring will be performed to protect the commu-
nity from adverse air emissions. Air monitoring will be
performed in work areas. The following residuals will be
generated: incinerator ash, wastewater from air pollution
controls, and decontamination fluids. Ash will be drummed
and stored on-site to be remediated with the other source
areas at a later date. Wastewater will be temporarily
stored on-site pending laboratory analysis to determine
disposal requirements.
- Long-Term Effectiveness and Permanence
Incineration is a demonstrated treatment process for
the destruction of PCBs and other organic compounds.
There will be no remaining risks associated with the former
processing facility/tank farm because it will be completely
removed. Residual ash will be temporarily stored on-site
in a fenced, secure area. These actions will mitigate any
remaining direct contact risks. No long-term management
or operation and maintenance are required, because the
facility will be completely removed. It is estimated that
this alternative can be completed in 3-6 months following
the initiation of on-site activities.
Implementation of this alternative will allow access
to soils beneath the facility in order to investigate and
remediate contamination.
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-16-
- Reduction of Toxicity, Mobility, and Volume
Incineration will destroy almost all of the organic
constituents in the waste, including PCBs. The treatment
is irreversible. Toxicity, mobility, and volume will all
be reduced. Volume reduction of tank waste is expected to
be approximately 85 to 90 percent.
- Implementability
The technologies proposed for facility removal,
dismantling, incineration, and off-site landfilling are all
demonstrated and commercially available. Several mobile
incinerators have permits for incinerating PCBs. This alter-
native should not adversely affect other source areas at the
site nor interfere with future remedial actions for these
areas. There would be no need to monitor the effectiveness
of the remedy, because the. former processing facility/tank
farm would be completely removed.
There may be some question concerning the availability of
mobile incinerators at this time. This problem is, however,
not considered to be insurmountable and is not expected to
prevent implementation of this alternative.
- Compliance with ARARs
Removal of the wastes from the facility tanks would
comply with the intent of the closure requirements of RCRA
Subtitle C regulations found at 40 CFR Section 26.4.197
regarding closure of tank systems. On-s.ite incineration of
the tank wastes would address 40 CFR Section 264.340 et. seq.
promulgated under RCRA, and of 40 CFR Part 761 promulgated
under the Toxic Substances Control Act (TOSCA). Lead
emissions from on-site incineration would comply with the
National Ambient Air Quality Standards and the Pennsylvania
Department of Environmental Resources lead concentrations
standard, both of which are 1.5 ug/m-* quarterly average.
The remedial action would also comply with the land disposal
restrictions designated at 40 CFR Part 268.
- Overall Protection of Human Health and the Environment
Facility contaminants and hazardous materials would be
completely removed from the facility. This will eliminate
the risks from collapse, fire, and direct contact with
hazardous materials associated with the facility. The ash
resulting from on-site waste incineration would be tempo-
rarily stored in drums in a secure area and would be handled
as a part of the overall site remediation.
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-17-
- State Acceptance
The Commonwealth of Pennsylvania would probably find
this alternative to be acceptable.
- Community Acceptance
Community interest in the site has been low. It is
probable that this alternative would be acceptable to the
communi ty.
- Cost
The capital cost estimate for this alternative is
$3,897,000. No operation and maintenance costs would be
incurred, because this is a permanent remedy. Additional
costs would be incurred in the future to remediate the
remaining ash residue.
REMEDIAL ALTERNATIVE 3 - TANK WASTE REMOVAL WITH OFF-SITE
INCINERATION; FACILITY DISMANTLING WITH OFF-SITE DISPOSAL
This alternative involves off-site incineration of the tank
wastes and dismantling and decontamination of tanks, equipment,
and buildings. Decontaminated building materials would be disposed
in an off-site landfill for non-hazardous waste. There may be a
small amount of material that cannot be decontaminated. Such
material will be disposed in an off-site landfill for hazardous
waste. (A more detailed description can be found in Section 3 of
the April^ 1988 Focused Feasibility Study.)
- Short Term Effectiveness
This alternative would reduce the immediate risks posed
by the facility. Dust and other air emissions may result
from material handling, dismantling, and decontamination acti-
vities. Dust controls will be required, and air monitoring
will be performed to protect the community from adverse air
emissions. Air monitoring will be performed in work areas.
- Long-Term Effectiveness and Permanence
Incineration is a demonstrated treatment process for the
destruction of PCBs and other organic compounds. There will
be no remaining risks associated with the processing facility,
because it will be completely removed.
No long-term management or operation and maintenance are
required, because the facility will be completely removed.
Implementation of this alternative will allow access to
soils beneath the facility in order to investigate potential
contamination. It is estimated that this alternative can be
completed in 3-6 months following the initiation of on-site
activities.
-------
-18-
- Reduction of Toxicity, Mobility, and Volume
Incineration will destroy almost all of the organic
constituents in the waste, including PCBs. The treatment is
irreversible. Toxicity, mobility, and volume will all be
reduced. Expected volume reduction of tank waste is approx-
imately 85 to 90 percent.
- Implementability
The technologies for facility removal, dismantling,
incineration, and offsite landfilling are all demonstrated
and commercially available. Several off-site incinerators
have permits for incinerating PCBs. This alternative should
not adversely affect other source areas at the site or inter-
fere with future remedial actions for these areas. There
would be no need to monitor the effectiveness of the remedy,
because the facility would be completely removed.
- Compliance with ARARs
Removal of the wastes from the tanks would comply with
the intent of the requirements of RCRA Subtitle C regulations
(regarding closure of tank systems) found at 40 CFR Section •
264.197. Transportation of the tank wastes to a commercial
hazardous waste incinerator would be done in compliance with
standards applicable to generators of hazardous waste promul-
gated under RCRA and found at 40 CFR Section 262.10 et. seq.;
the 25 PA Code Chapter 75 regulations governing the generation
and transportation of hazardous wastes; United States
Department of Transportation and Pennsylvania Department of
Transportation regulations pertaining to the transportation
of hazardous materials; and TOSCA regulations found at 40
CFR Part 761 regarding the transportation of PCBs. Materials
designated for reuse will be decontaminated as specified at
40 CFR Section 761.125(c)(3 ) {iv). In addition, the receiving
facility would be required to be in compliance with applicable
state and Federal permit requirements relevant to hazardous
waste treatment facilities. The remedial action would also
comply with the land disposal restrictions designated at 40
CFR Part 268.
- Overall Protection of Human Health' and the Environment
Facility contaminants and hazardous materials will be
completely removed from the facility. This will eliminate
the risks from collapse, fire, and direct contact with
hazardous materials associated with the facility.
- State Acceptance
The Commonwealth of Pennsylvania has expressed its acceptance
of this alternative. A letter addressing that acceptance has
been received by EPA.
-------
-19-
- Community Acceptance
Community interest in the site has been low. No
comments were received regarding this alternative as
published in the Pottstown "Mercury" in the form of a
Proposed Plan.
- Cost
The capital cost "estimate for this alternative is
$4,050,000. No operation and maintenance costs will be
incurred, because this is a permanent remedy.
Comparative Analysis
No environmental nor public health benefits would result
from implementing Alternative 1, No Action. This alternative
would not satisfy the requirement that remedial actions must
be protective of public health and the environment.
Alternatives 2 and 3 would result in conditions which
are protective of public health and the environment. Both
alternatives would result in the total removal of the former
processing facility/tank farm as a potential threat to human
health and the environment and are similiar when comparing
against implementability, short-term effectiveness, and the
reductions of mobility, toxicity, and volume. The cost of
Alternative 2 (on-site incineration of tank wastes) is esti-
mated to be only $153,000 less than the cost of implementing
Alternative 3 (off-site incineration of tank wastes). However,
Alternative 2 would result in the leaving of at least 300
drums of lead-contaminated incinerator ash stored on-site for
an indefinite time period pending remediation with other
source areas. The cost for this future treatment is unknown
at this time.
Recommended Alternative
Section 121 of SARA and the National Contingency Plan
(NCP) establish a variety of requirements relating to the
selection of remedial actions under CERCLA. Having applied
the current evaluation criteria to the three remaining
remedial alternatives, we recommend that Alternative 3 be
implemented at the Douglassville Disposal Site former pro-
cessing facility/tank farm.
This is an operable unit remedy for the site and as such,
does not attempt to ensure compliance with all ARARs for the
entire site. It will be consistent, however, with those
action-specific ARARs addressing the closure of hazardous
waste tank systems and transportation of hazardous wastes.
This operable unit remedy will not be inconsistent with a
final comprehensive remedy for the site.
-------
-20-
Th is alternative consists of removing the wastes from
the on-site tanks and transporting those wastes to a permitted
off-site facility for incineration. The incineration resid-
uals will become the responsibility of the incineration
facility and will be disposed of as required by the facility's
operating permits. Tanks, piping, processing equipment,
and building materials designated for salvage or reuse will
be decontaminated as necessary to a level not to exceed
lOOug/lOOcm2 PCBs on the surface as determined by wipe
sampling. Decontaminated building rubble will be disposed
of in permitted off-site sanitary or demolition debris
landfills. Tanks and other metal materials will be sold as
scrap. Concrete, asphalt and other materials which contain
PCBs and which cannot be decontaminated to less than 50 ppm
PCBs will be disposed of at a permitted off-site hazardous
waste landfill. Decontamination fluids generated during
the operation will be treated appropriately depending upon
the type and degree of contamination. Typical scenarios
include dewatering and incineration, and treatment by a
hazardous waste treatment facility.
Excavations created during the extractions of below-
ground tanks and piping will be backfilled with fill graded
from the area or otherwise backfille'd to eliminate physical
endangerment pending decisions on soil remediation for the
area.
Statutory Findings
The selected remedy is protective of human health and
the environment, attains all applicable, or relevant and
appropriate requirements for this operable unit, and is cost
effective. The selected remedy provides the best balance
among the evaluation criteria by achieving a long-term
effective and permanent remedy with no long-term management
for this operable unit (i.e., residuals would not be tempo-
rarily stored on-site). The remedy utilizes alternative
treatment technologies or resource recovery options to the
maximum extent practicable. The remedy also satisfies the
preference for treatment by reducing the toxicity, mobility
or volume of the hazardous substances.
Schedule
It is expected that a design contract will be awarded
in the summer of 1988 and that the design can be completed
in 10 months. Actual remedial activities are expected to
require 3 to 6 months for implementation.
-------
Douglassville Responsiveness Summary
On Sunday May 8, 1988, The Pottstown Mercury ran an EPA advertisement
announcing the preferred cleanup alternative for the Douglassville Superfund
Site. The comment period, May 8, 1988 to June 6, 1988 was also announced
in the ad. We stated that if a public meeting was requested, residents
should contact EPA, and a contact number was given. A copy of the ad is
attached.
During that time period, EPA Region III received no requests for a
public meeting, and no comments on the proposed alternatives. We telephoned
the Union Township Building to inform them of the alternative before the
ad was published. One news editorial in the Pottstown Mercury commended
EPA on the announcement.
Throughout the Superfund process, EPA never received more than one
or two comments from Douglassville residents regarding the site. However,
during this past comment period, no comments were received.
-------
ENVIRONMENTAL
f ^7 * PROTECTION AGENCY
V*^/ REGION 111
841 Chestnut Building
Philadelphia, Pennsylvania 19107
The United States Environmental Protection Agency (EPA) has com-
pleted a Feasibility Study which focused on the former processing area
and tank farm at the Douglassville Superfund Site on Route 724 in
Douglassville, where the former Berks Associates Inc. Oil Recycling
facility operated from approximately 1941 to 1985.
Listed below are the cleanup alternatives:
1. No action
2. Facility Dismantlement with On-Site Incineration of Tank Contents.
3. Facility Dismantlement with Off-Site Incineration of Tank Contents.
EPA's preferred cleanup method is alternative #3: Facility Dismantle-
ment with Off-Site Incineration of Tank Contents.
Under this alternative the contents of the tanks would be removed
incinerated at a permitted hazardous waste treatment facility off site. The
tanks, bui'dings and equipment would be dedcontaminated; the entire
former processing facility/tank farm area would be dismantled; and the
decontaminated rubble would be landfilled at a permitted facility off site.
These actions would eliminate the risks from collapse, fire, and direct
contact with hazardous substances presently associated with the facility.
The ash residue produced from the site incineration would be the
responsibility of the incineration facility. The capitol cost of this alternative
is estimated to be approximately $4,050,000.
Before the cleanup method becomes final, EPA is accepting com-
ments from the public on the preferred alternative. The public comment
period begins Sunday May 8, 1988 and ends Monday June 6, 1988.
Please send all written comments to:
Nanci Sinclair (3PAOO) Victor Janosik
U.S. EPA U.S. EPA
841 Chestnut Street 841 Chestnut Street
Philadelphia, PA 19107 Philadelphia, PA 19107
If a public meeting is requested, please contact Nanci Sinclair at (215)
597-4164 by May 22.
All reports and documents regarding the Douglassville disposal Super-
fund Site are available for public review at the local repository which is
located at:
Union Township Municipal Building
RD #1 Box 292 (Center Road)
Douglassville, PA 19518
-------
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF ENVIRONMENTAL RESOURCES
Poat Office Box 2063
Harrieburg. Pennsylvania 17120
Dtputy Secretary for
Environmental Protection
June 23, 1988
Mr. Stephen R. Wassersug, Director
Hazardous Waste Management Division (3HWOO)
US EPA, Region III
841 Chestnut Building
Philadelphia, PA 19107
Dear Mr. Wassersugi
The draft Record of Decision for an interim remedial
action addressing the former processing facility/tank farm
operable unit at the Douglaaville Disposal Superfund Site has been
reviewed by DBR staff members. The Department concurs with EPA's
assessment of the selected interim remedial action.
The selected interim remedial action consists oft
1.• Removal of the liquids and sludges remaining in
the tanks of the former processing facility.
2. Removal of liquids and sludges from Incidental
tanks and trucks on other portions of the
facility.
3. Transporting these liquids and sludges to an
offsite facility for incineration.
4. Decontamination of tanks, piping, and
structures.
5. Dismantlement of the entire former processing
facility.
6. Disposal of the uncontaminated tanks by sale as
scrap.
7. Disposal of the uncontaminated rubble in an
off-site disposal facility.
8. Disposal of rubble which cannot be
satisfactorily decontaminated in an off-site
permitted hazardous waste disposal facility.
I
-------
Upon completion of the comprehensive Phase II Remedial
Investigation/Feasibility study (Phase II RI/PS) which will
address all aspects of the contamination at the site and the
selection of a final remedial action/ another Record of Decision
will be required.
I wish to thank you and your staff for your cooperation
with the Department. Again this concurrence demonstrates our
spirit of commitment to continue to protect our environment.
Very truly yours,
Mark M. McClellan
Deputy Secretary
Environmental Protection
Department of Environmental Resources
co Mr. McClellan
Mr. Boardman
Mr. Snyder
Ma. Hofman
Mr. Becker
Mr. Lynn
Attorney Calder
Attorney Brennan
Ms. Dekona
Mr. Klinikovski
Mr. Voltaggio (EPA)
Mr. Graham (EPA)
(EPA)
Mr. Janosik
Pile ~/^
Chron .s
Chron .-
RMB i JPS i BH i DMBI jcb
-------
DOUGLASSVILLE DISPOSAL SITE - PHASE I*
ADMINISTRATIVE RECORD** ***
INDEX OF DOCUMENTS
SITE IDENTIFICATION
Notification/Site Discovery
1) Potential Hazardous Waste Site Identification, 10/21/80. P. 1-1.
2) Notification of Hazardous Waste Site, 6/81. P. 2-2.
Preliminary Assessment/Site Investigation Reports
1) Potential Hazardous Waste Site Identification and Preliminary Assessment,
9/9/81. P. 1-5.
2) Potential Hazardous Waste Site Identification and Preliminary Assessment,
3/5/82. P. 6-12.
3) Potential Hazardous Waste Site Identification and Preliminary Assessment,
5/6/82. P. 13-22.
4) Report: A Site Inspection of Berks Associates, prepared under TDD No.
F3-8303-02, prepared by Mr. David A. Nickerson and Mr. Joseph G. McGovern,.
Ecology and Environment, Inc., 8/3/82. P. 23-118.
5) Report: Field Trip Summary Report (no author cited), (undated). P. 119-121
Correspondence
1) Letter to Mr. Michael Steiner, Pennsyl»«mia Department of Environmental
Resources, from Ms. Kathryn Hodgkiss, U.S. EPA, re: transmittal of the
Site Inspection Report for the Berks Associates Site, 8/15/83. P. 1-1.
2) Letter to Mr. Bruce Beitler, Pennsylvania Department of Environmental
Resources, from Ms. Kathryn Hodgkiss, U.S. EPA, re: transmittal of the
Site Inspection Report for the Berks Associates Site, 8/15/83. P. 2-2.
* For further documentation on this site, please refer to the Phase II
administrative record.
** Administrative record available 3/21/88, updated 4/5/88.
*** Supporting Sampling Data is stored at the Region III Central Regional
Laboratory in Annapolis, Maryland.
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REMEDIAL ENFORCEMENT PLANNING
Potentially Responsible Party Search Correspondence
1) Letter to Mr. R. L. Noland, Ametek, Inc., from Mr. Stephen R. Wassersug,
U.S. EPA, re: 104(e) Information request, 9/19/85. P. 1-3.
2) Letter to Mr. Walter Williams, Bethlehem Steel Corporation, from Mr. Stephen
R. Wassersug, U.S. EPA, re: 104(e) information request, 9/19/85. P. 4-6.
3) Letter to Mr. Al Cimino from Mr. Stephen R. Wassersug, U.S. EPA, re: 104(e)
information request, 9/19/85. P. 7-9.
4) Letter to Mr. William Cox, City Waste Oil Service, from Mr. Stephen R.
Wassersug, U.S. EPA, re: 104(e) information request, 9/19/85. P. 10-12.
5) Letter to Mr. Clement A. Revelti, Dana Corporation, from Mr. Stephen R.
Wassersug, U.S. EPA, re: 104(e) information request, 9/19/85. P. 13-15.
6) Letter to Ms. Lorraine Szyman, J&L Industries, Inc., from Mr. Stephen R.
Wassersug, U.S. EPA, re: 104(e) information request, 9/19/85. P. 16-18.
7) Letter to Mr. W. R. Grlgsby, from Mr. Stephen R. Wassersug, U.S. EPA,
re: 104(e) information request, 9/19/85. P. 19-21.
8) Letter to Mr. A. S. Hutchcraft, Jr., Kaiser Aluminum & Chemical Corporation,
from Mr. Stephen R. Wassersug, U.S. EPA, re: 104(e) information request,
9/19/85. P. 22-24.
9) Letter to Mr. John Lavala from Mr. Stephen R. Wassersug, U.S. EPA, re:
104(e) information request, 9/19/85. P. 25-27.
10) Letter to Mr. Joseph Lorenz from Mr. Stephen R. Wassersug, U.S. EPA, re:
104(e) information request, 9/19/85. P. 28-30.
11) Letter to Mr. W. W. Wilson, Lukens, Inc., from Mr. Stephen R. Wassersug,
U.S. EPA, re: 104(e) information request, 9/19/85. P. 31-33.
12) Letter to Mr. John B. Curcio, Mack Trucks, Inc., from Mr. Stephen R.
Wassersug, U.S. EPA, re: 104(e) information request, 9/19/85. P. 34-36.
13) Letter to Mr. E. M. Note from Mr. Stephen R. Wassersug, U.S. EPA, re:
104(e) information request, 9/19/85. P. 37-39.
14) Letter to Mr. William Schiavani from Mr. Stephen R. Wassersug, U.S. EPA,
re: 104(e) information request, 9/19/85. P. 40-42.
15) Letter to Mr. Leonard Tohanczn from Mr. Stephen R. Wassersug, U.S. EPA,
re: 104(e) information request, 9/19/85. P. 43-45.
16) Letter to Mr. Thomas Lewis, Total Recovery, Inc., from Mr. Stephen R.
Wassersug, U.S. EPA, re: 104(e) information request, 9/19/85. P. 46-48.
17) Letter to Mr. Kevin Oonnigan, Thomas & Betts Corporation, from Mr.
Stephen R. Wassersug, U.S. EPA, re: 104(e) information request, 9/19/85.
P. 49-51.
2
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18) Letter to Mr. James W. Yerger from Mr. Stephen R. Wassersug, U.S. EPA,
re: 104(e) information request, 9/19/85. P. 52-54.
19) Letter to Mr. Lee Walter from Mr. Stephen R. Wassersug, U.S. EPA, re:
104(e) information request, 9/19/85. P. 55-57.
20) Letter to Mr. James H. McNeil, The Budd Company, from Mr. Stephen R.
Wassersug, U.S. EPA, re: 104(e) information request, 10/11/85. P. 58-60.
21) Letter to Mr. Danial Davall, Midland Ross Corporation, from Mr.
Stephen R. Wassersug, U.S. EPA, re: 104(e) information request, 10/11/85.
P. 61-63.
22) Letter to Mr. Thomas H. Cifelli, Wagner Electric Corporation, from Mr.
Stephen R. Wassersug, U.S. EPA, re: 104(e) information request, 10/11/85.
P. 64-66.
23) Letter to Mr. Paul R. Wikinson, E. I. DuPont de Nemours, from Mr. Stephen
R. Wassersug, U.S. EPA, re: 104(e) information request, 11/13/85.
P. 67-69.
24) Letter to Mr. John R. Welch, Jr., General Electric Company, from Mr.
Stephen R. Wassersug, U.S. EPA, re: 104(e) infoTiation request, 11/13/85.
P. 70-72.
25) Letter to Mr. Frank Umbriac, Hazleton Oil Salvage, from Mr. Stephen R.
Wassersug, U.S. EPA, re: 104(e) information request, 11/13/85.
P. 73-75.
26) Letter to Mr. Stanley Pace, TRW Inc., from Mr. Stephen R. Wassersug,
U.S. EPA, re: 104(e) information request, 11/13/85. P. 76-78.
27) Letter to Mr. Joseph Mooney, Monsey Products Company, from Mr.
Stephen R. Wassersug, U.S. EPA, re: 104(e) information request, 11/13/85,
P. 79-81.
24) Letter to Mr. Bernard Jaffe, Sun Chemical Corporation, from Mr. Stephen
R. Wassersug, U.S. EPA, re: 104(e) information request, (undated).
P. 82-84.
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REMEDIAL RESPONSE PLANNING
Work Plans
1) Report: Remedial Action Master Plan, Douglassville Disposal Site, Union
Township, Berks County, Pennsylvania, prepared by NUS Corporation, 11/83.
P. 1-96.
2) Report: Work Plan, Remedial Investigation/Feasibility Study, Douglassville
Disposal Site, Union Township, Berks County, Pennsylvania, prepared by NUS
Corporation, 4/84. P. 97-185.
3) Report: Site Operations Plan, Douglassville Disposal Site. Union Township,
Berks County, Pennsylvania, prepared by NUS Corporation, 10/84. P. 186-266.
Remedial Investigation/Feasibility Study Reports
1) Report: Remedial Investigation Report/Feasibility Study of Alternatives,
Volume I, Berks Associates, Douglassville Disposal Site, Union Township,
Berks County, Pennsylvania, prepared by NUS Corporation, 6/86.P. 1-376.
2) Report: Remedial Investigation Report/Feasibility Study of Alternatives,
Volume II, Appendices A-D, Berks Associates, Douglassville Disposal Site,
Union Township, Berks County, Pennsylvania, prepared by NUS Corporation,
6/86. P. 377-635.
3) Report: Remedial Investigation Report/Feasibility Study of Alternatives,
Volume III, Appendices E-F, Berks Associates, Douglassyille Disposal Site,
Union Township, Berks County, Pennsylvania, prepared by NUS Corporation,
6/86. P. 636-876.
Correspondence
1) Letter to Ms. Kathy Hodgkiss, U.S. EPA, from Mr. Michael R. Steiner,
Commonwealth of Pennsylvania Department of Environmental Resources, re:
comments of the Department of Environmental Resources in regard to the
draft work plans, 6/16/83. P. 1-1.
2) Letter to Mr. Michael Steiner, Commonwealth of Pennsylvania Department
of Environmental Resources, from Mr. William A. Hagel, U.S. EPA, re:
transmittal of the Final Remedial Action Master Plan for the
Douglassville Disposal Superfund Site, 2/27/84. P. 2-2.
3) Letter to Mr. Michael Steiner, Commonwealth of Pennsylvania Department
of Environmental Resources, from Mr. William A. Hagel, U.S. EPA, re:
transmittal of the final Work Plan for Remedial Investigation/
Feasibility Study (RI/FS) for the Douglassville Disposal Superfund Site,
5/4/84. P. 3-3.
4) Letter to Mr. William A. Hagel, U.S. EPA, from Mr. Michael Steiner,
Commonwealth of Pennsylvania Department of Environmental Resources, re:
approval of the Remedial Investigation/Feasibility Study Work Plan for
the Douglassville Disposal Site, 5/29/84. P. 4-4.
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5) Letter to Ms. Judy Dorsey, U.S. EPA, from Mr. Marc E. Gold, Wolf,
Block, Schorr and Soils-Cohen, re: negotiations with potentially
responsible parties, 12/12/85. P. 5-6.
6) Letter to Ms. Judith Dorsey, U.S. EPA, from Mr. Marc E. Gold, Wolf,
Block, Schorr and Solis-Cohen, re: alternative clean-up plan for
the Berks Associates Site, Douglassville, Pennsylvania, 3/11/86.
P. 7-46. A report entitled "Corporate Review and Select Test Data"
is attached to the letter.
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Record of Decision/Enforcement Decision Document (ROD/EDO)
1) Letter to Mr. Thomas C. Voltaggio, U.S. EPA, from Mr. Dwight D. Worley,
Commonwealth of Pennsylvania Department of Environmental Resources, re:
second Draft of the Record of Decision, Remedial Action Alternative
Selection for the Douglassville Disposal Site, 9/24/85. P. 1-2.
2) Record of Decision, Remedial Action Alternative Selection, (undated).
P. 3-45.
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COMMUNITY INVOLVEMENT
Community Relations Plan
1) Report: Community Relations Plan for Douglassville Disposal Site. Union
Township, Berks County, Pennsylvania, prepared by NUS Corporation, L2/8A.
P. 1-23.
Fact Sheets, Press Releases, Public Notices
1) Press Release from U.S. _?A Environmental News entitled "EPA Schedules
Public Meeting for Douglassville Superfund Site," 6/21/85. P. 1-1.
2) Press Release from U.S. EPA Environmental News entitled "EPA Approves
Cleanup Alternative for Douglassville Disposal Superfund Site," 10/11/85.
P. 2-3.
3) Report: Douglassville Disposal Site (no author cited), (undated).
P. 4-6.
Meeting Summaries, Trip Reports, Correspondence with Public
1) Memorandum to Mr. D. R. Brenneman from Mr. R. E. Stecik re: public meeting
notes, 3/28/84. P. 1-2.
2) Agenda of a public meeting, 7/10/85. P. 3-3.
Interagency Meeting Notes, General Correspondence
1) Letter to Mr. Donald Gutekunst, Union Township Supervisors, from Mr.
William A. Hagel, U.S. EPA, re: public review of the draft Work Plan for
Remedial Investigation/Feasibility Study for the Douglassville Disposal
Site, 3/19/84. P. 1-1.
2) Memorandum to Mr. Thomas C. Voltaggio, U.S. EPA, from Mr. William Hagel,
U.S. EPA, re: public meeting on the Douglassville Disposal Site, 4/1/84.
P. 2-2.
3) Letter to Mr. William A. Hagel, U.S. EPA, from Mr. Davis L. Allebach, Jr.,
Reynier, Crocker, Allebach 4 Reber, P. C., re: well water testing in the
area of the Berks Associates property, 6/22/84. P. 3-3. .
4) Letter to Mr. Lester Schurr, Berks Associates, Incorporated, from Mr.
William A. Hagel, U.S. EPA, re: sampling and drilling at the Berks
Associates property, 6/27/84. P. 4-4.
5) Letter to Mr. David L. Allebach, Jr., Reynier, Crocker, Allebach & Reber,
P. C., from Mr. William A. Hagel, U.S. EPA, re: EPA's activities at the
Berks Associates Site in Douglassville, Pennsylvania, 7/2/84. P. 5-5.
6) Letter to Mr. Donnell Marshall, Laurel Locks Farms, from Mr. Richard L.
Zambito, P. E., U.S. EPA, re: installing a monitoring well on the
property directly adjacent to the Berks Associates, 8/22/84. P. 6-6.
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7) Handwritten letter to Ms. Nanci Sinclair, U.S. EPA, from Mr. Donald Weber re:
public meeting at the Douglassville Superfund Site, 7/16/85. P. 7-7.
8) Letter to Mrs. Pat Hobbs from Mr. Bruce P. Smith, U.S. EPA, re: status of
of the Berks Associates Site, 3/12/86. P. 8-9.
9) Fact Sheet from U.S. EPA and Pennsylvania Department of Environmental
Resources (PADER) entitled "Preferred Remedial Alternative for the Berks
Associates, Douglassville Disposal Superfund Site," (undated). P. 10-11.
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GENERAL GUIDANCE DOCUMENTS *
1) "Promulgation of Sites from Updates 1-4," Federal Register, dated 6/10/86.
2) "Proposal of update 4," Federal Register, dated 9/18/85.
3) Memorandum to U. S. EPA from Mr. Gene Lucero regarding community relations
at Superfund Enforcement sites, dated 8/28/85.
4) Groundwater Contamination and Protection, undated by Mr. Donald V.
Feliciano on 8/28/85.
5) Memorandum to Toxic Waste Management Division Directors Regions I-X from
Mr. William Hedeman and Mr. Gene Lucero re: Policy on Floodplains and
Wetlands Assessments for CERCLA Actions, 8/6/85.
6) Guidance of Remedial Investigations under CERCLA, dated 6/85.
7) Guidance on Feasibility Studies under CERCLA, dated 6/85.
8) "Proposal of Update 3," Federal Register, dated 4/10/85.
9) Memorandum to Mr. Jack McGraw entitled "Community Relations Activites
at Superfund Sites - Interim Guidance," dated 3/22/85.
10) "Proposal of Update 2," Federal Register, dated 10/15/84
11) EPA Groundwater Protection Strategy, dated 9/84.
12) Memorandum to U.S. EPA from Mr. William Heckman, Jr. entitled
"Transmittal at Superfund Removal Procedures - Revision 2," dated 8/20/84.
13) "Proposal of Update 1," Federal Register, dated 9/8/83.
14) Community Relations in Superfund: A Handbook (interim version), dated
___
L5) "Proposal of first National Priority List," Federal Register, dated
12/30/82.
16) "Expanded Eligibility List," Federal Register, dated 7/23/82.
17) "Interim Priorities List," Federal Register, dated 10/23/81.
18) Uncontrolled Hazardous Waste Site Ranking System: A User's Manual
(undated) .
19) Field Standard Operating Procedures - Air Surveillance (undated).
20) Field Standard Operating Procedures - Site Safety Plan (undated).
* Located in EPA Region III office.
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DOl'GLASSVILLE DISPOSAL SITE - PHASE' II*
ADMINISTRATIVE RECORD** ***
INDEX OF DOCUMENTS
REMEDIAL RESPONSE PLANNING
Work Plans
1) Report: Final Work Plan, Phase II Remedial Investigation/Feasibility Study,
Douglassville Disposal Site, Berks County, Pennsylvania, prepared by NUS
Corporation, 8/87. P. 1-183. References are listed on P. 147-148.
2) Letter to Mr. Vic Janosik, U.S. EPA, from Mr. Richard C. Evans, P. E.,
EBASCO Services Incorporated, re: Douglassville Disposal Site - Phase II
Remedial Investigation/Feasibility Study Amendment to Final Work Plan,
8/24/87. P. 184-185.
3) Report: Final Field Operations Plan (FOP), Phase II Remedial Investigation/
Feasibility Study, RI/FS, Douglassville Disposal Site, Union Township,
Pennsylvania, prepared by NUS Corporation, 10/87.P. 186-348.References
are listed on P. 318.
4) Report: Amendment 1 to Final Field Operations Plan (FOP), Phase II
Remedial Investigation/Feasibility Study, Douglassville Disposal Site,
Union Township, Pennsylvania, prepared by NUS Corporation, 11/87. P.
349-370.
5) Report: Draft Work Plan, Phase II Remedial Investigation/Feasibility
Study, Douglassville Disposal Site, Berks County, Pennsylvania, prepared
by EBASCO Services Incorporated, 6/17/87. P. 371-555. References are
on P. 528-529.
6) Report: Hydrogeologic Investigation, Douglassville Disposal [Site] ,
prepared by NUS Corporation, 2/29/88.P. 556-601.References are listed
on P. 586-587.
7) Report: Field Trip Report for Douglassville Disposal Site, prepared by
NUS Corporation, 3/17/88. P. 602-670.
8) Report: Final Focused Feasibility Study/Facility Removal, Douglassville
Disposal Site, Berks County, Pennsylvania, prepared by NUS Corporation,
4/88.P. 671-781.References are listed on P. 747.
9) Report: Superfund Program Fact Sheet/Proposed Remedial Action Plan,
Douglassville Disposal Site, Douglassville, Pennsylvania, prepared by
EPA, Region III, 5/4/88.P. 782-786.
* For further documentation on this site, please refer to the Phase I
administrative record.
** Administrative record available 3/21/88, updated 5/6/88.
*** Supporting Sampling Data is stored at the Region III Central Regional
Laboratory.
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Correspondence
1) Memorandum to the file from Mr. E. Sonnenberg and Mr. M. Hlavacik, NUS
Corporation, re: facility dismantling and disposal, and additional surface
capping in drainage ditch area, 8/19/85. P. 1-6. A table regarding
estimated cost Summary and a site map are attached to the memorandum.
2) Memorandum to the file from Mr. E. Sonnenberg, NUS Corporation, re:
quantities and costs estimates [sic] for additional excavating in the
drainage ditch area, 8/30/85. P. 7-11. Three standard calculation
sheets are attached to the memorandum.
3) Memorandum to the file from Mr. E. Sonnenberg, NUS Corporation, re:
cost estimates for Alternative No. 4, 9/5/85. P. 12-14. Two tables
regarding backup cost estimates are attached to the memorandum.
4) Memorandum to the file from Mr. E. Sonnenberg, NUS Corporation, re:
additional costs to Feasibility Study Alternatives 2-9 due to
additional excavation in drainage ditch area, 9/9/85. P. 15-28.
Data regarding backup cost estimates are attached to the memorandum.
5) Memorandum to the file from Mr. Erich Sonnenberg, NUS Corporation, re:
leachate production estimates, 9/12/85. P. 29-39. Data regarding
leachate production estimates are attached to the memorandum.
6) Memorandum to the file from Mr. Erich Sonnenberg, NUS Corporation, re:
design considerations in the event of a 500-year flood, 10/3/85.
P. 40-43. Calculations regarding 500-year flood protection design are
attached to the memorandum.
7) Letter to Ms. Judy Dorsey, U.S. EPA, from Mr. Marc E. Gold, Wolf, Block,
Schorr and Solis-Cohen, re: lack of data contained in the Remedial
Investigation/Feasibility Study prepared for the Berks Associates Site
by NUS Corporation, 4/21/86. P. 44-48. Technical concerns regarding
Douglassville Remedial Investigation/Feasibility Study are attached to
the letter.
8) Letter to Mr. Jeffrey A. Pike, U.S. EPA, from Mr. George V. Gartseff,
NUS Corporation, re: Remedial Investigation/Feasibility Study Test Pit
Logs for the Douglassville Disposal Site, 6/24/86. P. 49-49.
9) Letter to Mr. Jeffrey A. Pike, U.S. EPA, from Mr. George V. Gartseff,
NUS Corporation, re: transmittal of file memos supporting Feasibility
Study and Record of Decision calculations for the Douglassville Disposal
Site, 6/24/86. P. 50-50.
10) Letter to Mr. Jack Kelly, U.S. EPA, and Mr. Victor J. Janosik, U.S. EPA,
from Mr. Edgar P. DeVylder, General Signal Corporation, re: critique of
Draft Phase II Remedial Investigation/Feasibility Study Work Plan, 8/7/87.
P. 51-59. The critique is attached to the letter.
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11) Letter to Mr. Jack Kelly, U.S. EPA, and Mr. Victor Janosik, U.S. EPA, frr
Mr. Edgar P. DeVylder re: critique of Draft Phase II Remedial Investigat
Feasibility Study Work Plan, 8/19/87. P. 60-63. A memorandum regarding
estimated cost savings is attached to the letter.
12) Letter to Mr. Edgar P. DeVylder, General Signal Corporation, from Mr.
Victor J. Janosik, U.S. EPA, re: Berks Associates Steering Committee
letters of August 7, 1987 and August 19, 1987, 9/8/87. P. 64-70.
A report entitled "Toxicity Characteristic Leaching Procedure" is
attached to the letter.
13) Letter to Mr. James Heenehan, U.S. EPA, from Mr. Ed DeVylder, General Signal
Corporation, re: critique of Phase II Remedial Investigation/Feasibility
Study Final Work Plan, 9/18/87. P. 71-78. The critique is attached to
the letter.
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REMEDIAL IMPLEMENTATION
Remedial Design
1) Report: Safety, Health, and Emergency Response for Pre-Design Field
Investigation at Douglassville disposal Superfund Site, Douglassvilie,
Pennsylvania, prepared by Donohue & Associates, 2/87. P. 1-97.
2) Report: Quality Control Plan for Pre-Deslgn Field Investigation at
Douglassville Disposal Superfund Site, Douglassville, Pennsylvania,
prepar : by Donohue & Associates, 3/23/87. P. 98-381. A transmittal
recorc .s attached to the report.
3) Report: Sampling and Analysis Plan for Pre-Deslgn field Investigation at
Douglassville Disposal Superfund Site, Douglassville, Pennsylvania,
prepared by Donohue & Associates, 3/23/87. P. 382-420. A transraittal
record Is attached to the report.
4) Report: Predeslgn Report, Douglassville Disposal Superfund Site,
Douglassville, Pennsylvania, Volume I, prepared by U.S. Army Corps of
Engineers, 3/88.P. 421-767.References are listed on P. 518-522.
5) Report: Predeslgn Report,.Douglassville Disposal Superfund Site,
Douglassville, Pennsylvania, Volume II, prepared by U.S. Army Corps of
Engineers, 3/88. P. 768-987.
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COMMUNITY INVOLVEMENT
Community Relations Plan
1) Report: Community Relations Plan for Douglassvllle Disposal Site. Union
Township, Berks County, Pennsylvania, prepared by EBASCO Services
Incorporated, 1/13/88. P. 1-21.
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GENERAL GUIDANCE DOCUMENTS *
1) "Promulgation of Sites from Updates 1-4," Federal Register, dated 6/10/86.
2) "Proposal of update 4," Federal Register, dated 9/18/85.
3) Memorandum to U. S. EPA from Mr. Gene Lucero regarding community relations
• at Superfund Enforcement sites, dated 8/28/85.
4) Groundwater Contamination and Protection, undated by Mr. Donald V.
Feliclano on 8/28/85.
5) Memorandum to Toxic Waste Management Division Directors Regions I-X from
Mr. William Hedeman and Mr. Gene Lucero re: Policy on Floodplains and
Wetlands Assessments for CERCLA Actions, A/6/85.
6) Guidance of Remedial Investigations under CERCLA. dated 6/85.
7) Guidance on Feasibility Studies under CERCLA, dated 6/85.
8) "Proposal of Update 3," Federal Register, dated 4/10/85.
9) Memorandum to Mr. Jack McGraw entitled "Community Relations Activites
at Superfund Sites - Interim Guidance," dated 3/22/85.
10) "Proposal of Update 2," Federal Register, dated 10/15/84
11) EPA Groundvater Protection Strategy, dated 9/84.
12) Memorandum to U.S. EPA from Mr. William Heckman, Jr. entitled
"Transmittal at Superfund Removal Procedures. - Revision 2," dated 8/20/84.
13) "Proposal of Update 1," Federal Register, dated 9/8/83.
14) Community Relations in Superfund: A Handbook (interim version), dated
9/83.
'15) "Proposal of first National Priority List," Federal Register, dated
12/30/82,.
16) "Expanded Eligibility List," Federal Register, dated 7/23/82.
17) "Interim Priorities List," Federal Register, dated 10/23/81.
18) Uncontrolled Hazardous Waste Site Ranking System: A User's Manual
(undated).
19) Field Standard Operating Procedures - Air Surveillance (undated).
20) Field Standard Operating Procedures - Site Safety Plan (undated).
* Located in EPA Region III office.
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