United Slates _
Environmental Protection
Agencv
Office o«
Emergency and
Remedial Response
EPA/ROO/R03-89/071
June 1989
SEPA
Superfund
Record of Decision
Douglassville Disposal, PA
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M4/3-1Q1
REPORT DOCUMENTATION
PAGE
t. REPOffTNO.
EPA/ROD/R03-89/071
3. Rttt&ntt AecMdon Mo.
SUPERFUND RECORD OF DECISION
Douglassville Disposal, PA .
Third Remedial Action - Final (Amendment)
June 30, 1989
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U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
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15.
18. Ao*»*c«lMt:200«oro*)
The Douglassville Disposal site is a 50-acre abandoned waste oil processing facility in
Union Township, Berks County, Pennsylvania. The area surrounding the site includes .
agricultural land, residences, and light industrial development. The site lies almost
entirely within the 100-year floodplain of the SchuylJcill River, which borders the site to
*-he north and east. The SchuylJcill River is used for municipal and industrial water
pply, recreational purposes, and waste assimilation. Further downstream of the site,
*>even public water supply users draw water from the Schuylkill River. From 1941 to 1979
the site operated as a lubrication oil and waste solvent recycling facility. Wastes
generated from the recycling processes were stored onsite in several lagoons. The site
consists of a former waste oil processing area and various waste disposal areas. Because
of the site's size and the complexity of the various onsite activities, the site has been
divided into 10 source areas of contamination. Disposal areas include two backfilled
sludge disposal lagoons (source areas 4 and 5), an oily filter cake disposal area (source
area 2), an oil drum storage area (source area 8), an area where waste oil sludge was
landfarmed into the soil (source areas 3 and 6), the former processing facility/tank farm
area (source area 1), a small backfilled lagoon (source area 9), an old incinerator
(source area 7), and an area of scrap metal and tanks (source area 10). In 1970 heavy
rain caused a lagoon to overflow and breach safety dikes; two to (See Attached Sheet)
17.
Record of Decision - Douglassville Disposal, PA
Second Remedial Action - Final (Amendment)
Contaminated Media: soil, gw
Key Contaminants: VOCS (benzene, toluene, vinyl chloride), other organics (PAHs,
PCBs, phenols), metals (lead)
b. U»iM«i»/e»i»ii tinted T
e. C06AHFMd«lroup
11
None
10. ••cutty CMM(ThtoP»«.)
None
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(SMANSUM.il)
(FonMrtyMTIMt)
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EPA/ROD/R03-89/071
DOUGLASSVILLE DISPOSAL, PA
Second Remedial Action - Final-(and Amendment) .
16. Abstract (continued)
seven million gallons of waste flowed into the Schuylkill River. Two years later, a
hurricane caused the SchuylJcill River to overflow its banks and inundate the entire site,
releasing:an estimated six to eight million gallons of waste. EPA subsequently drained
and backfilled the lagoons. Beginning in 1979 operations changed to refining waste oils
for use as fuel in industrial boilers. Oily wastewater sludge from the refining process
w»s landfarmed in the area until 1981, when the State mandated operational corrections to
the landfarming practices. All operations ceased in 1985. The 1988 Record of Decision
(ROD) addressed the risks associated with the former processing facility/tank farm area,
which were impediments to any future soil and ground water remediation. This second and
final response action addresses soil and ground water contamination remaining after the
former processing' facility/tank farm and associated wastes have been removed offsite.
This ROD also amends, in part/ the 1985 ROD, which outlined the remedial action for the
source areas designated as 2, 4, and 5 but deferred a decision regarding ground water
contamination. The primary contaminants of concern affecting the soil, sediment, and
ground water are VOCs Including benzene, toluene, and vinyl chloride; other organlcs
including PAHs, PCBs, and phenol; and metals including lead.
The selected remedial action for this site includes excavation and onsite thermal
treatment of 48,400 cubic yards of soil and sludges from source area 2, and 600 cubic
yards of oily sediment from the drainage ditch that runs from source area 9, followed by
backfilling ash residue into source area 2; covering the backfilled area with clean soil
followed by revegetation; capping of source areas 1, 4, and 5 with one foot of fly ash
and two feet of soil followed by revegetation; if ash residues exceed EP toxicity levels
solidification would be required prior to onsite disposal; capping source areas 3, 6, and
9 (approximately 10 acres) with 1 foot of clean soil followed by revegetation;
implementing institutional controls to prevent soil disturbance and well drilling; ground
water and surface water monitoring; and establishing ACLs for ground water. The
estimated present worth cost for this remedial action ranges from $39,430,000 to
$53,769,000 depending on whether ash residue requires solidification prior to disposal.
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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 presents the selected remedial action for
the Douglassviiie Disposal Site developed in accordance with the
Comprehensive Environmental Response, Compensation, and Liability
Act of 1980 (CERCLA), as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA), and, to the extent
practicable, the National Contingency Plan (NCP). This decision
is based on the administrative record for this site. The
attached index identifies the items that compose the
administrative record upon which the selection of the remedial
action is based..
The Commonwealth of Pennsylvania concurs on the selected remedy.
A copy of the Commonwealth's Letter of Concurrence is attached. *
DESCRIPTION OF THE SELECTED REMEDY
This operable unit is the final action of two operable units for
the site. The first operable unit at the site involves the
dismantlement of the former processing facility/tank farm area.
This second operable unit addresses the source of the
contamination by remediation of the onsite sludges and
contaminated soils. The remedy addresses the principal threats
at the site by (1) reducing the risks associated with exposure to
the contaminated materials identified as 10 Source Areas, and (2)
preventing exposure to contaminated ground water beneath the
site.
The major components of the selected remedial action include:
o Excavation and treatment, by onsite thermal treatment, of
approximately 48,400 cubic yards of contaminated soils and
sludge* from Source Area 2 and oily sediment from the
drainage ditch that runs from Source Area 9 to the
SchuylJcill River.
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o Disposal of thermally created materials by backfilling
into Source Area 2.
o covering the backfilled area with clean soil followed by
revegetation.
o . Capping Source Areas 1, 4, and 5 with one foot of flyash
and two feet of soil followed by revegetation.
o Capping Source Areas 3, 6, and 9 (approximately 10 acres)
with clean soil followed by revegetation.
o Imposing deed restrictions to prevent soil disturbance and
well drilling on the property.
o Establishing ACLs for ground water that would not cause
adverse effects on the Schuylkill River.
DECLARATION
The selected remedy is protective of human health and the
environment, attains Federal and State requirements that are
applicable or relevant and appropriate to this remedial action
and is cost effective. This remedy satisfies the statutory
preference for remedies that employ treatment that reduces
toxicity, mobility, or volume as a principal element and utilizes
permanent solutions and alternative treatment technologies to the
maximum extent practicable.
Because this remedy will result in hazardous substances remaining
on site above health-based limits, a review will be conducted
within five years after the start of remedial action to ensure
that the remedy continues to provide adequate protection of human
health and the environment.
Date Edwin B. Erickson
Regional Administrator
EPA Region III
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Site.Description and Summary of Remedial Alternative
Selection for the Douglassviiie Disposal Superfund Site
Berks County, Pennsylvania
INTRODUCTION
Tne'Superfund investigation of the Douglassviiie Disposal Site
addresses various environmental media and their potential
contamination with heavy metals and organic compounds. The site
was studied for its potential degradation of the Schuylkili River
which flows adjacent to the site; of area ground water,
particularly as it might affect neighboring residents; and of
site soils, the greater portion of which lie within the 100-year
floodplain. The site was also investigated for its potential to
produce adverse health effects because of exposure to site soils
through ingestion, inhalation, and direct contact.
This Record of Decision summarizes the results of a Remedial
Investigation/Feasibility Study which examines the site and the
surrounding area, and presents the selected remedial alternative.
COMMUNITY PPTATTQMS HISTORY
*
Pursuant to Section 300.67(c) of the National Contingency Plan
(NCP), a Community Relations Plan was developed for the Remedial
Investigation/Feasibility Study (RI/FS). A public meeting
regarding the initiation of the Phase II RI/FS activities was
held at the Union Township Building on September 9, 1987. In
compliance with Sections 113(Jc)(2)(i-v) and 117 of SARA, the
Administrative Record, including the Proposed Remedial Action
Plan, was placed for public consideration at the Union Township
Building, Center Road, Union Township, Pennsylvania. An
announcement of the availability of the Administrative Record was
placed in the Pottstown Mercury on May 24, 1989. The
Administrative Record included the Phase II RI/FS Report which
listed the alternatives developed as part of the Feasibility
Study. A period for public review and comment on the Proposed
Remedial Action Plan was held from May 25, 1989, to June 26,
1989. All documents relevant to the development and the
conduct of the RI/FS and the selection of the remedial
alternative were submitted by EPA to the Pennsylvania Department
of Environmental Resources (PADER) for review and comment during
the RI/FS process;
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SITE; NAME. LOCATIONt AMD DESCRIPTION
The--Douglassvilie Disposal Site occupies approximately 50 acres
of land in Union Township, southeastern Berks County,
Pennsylvania, along the southern bank of the Schuylkiii River
(Figure l). State Route 724 borders the southern edge of the
site, and a Conrail Railroad right-of-way extends through the
site in an east-west direction. 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 Schuylkiii 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 Borough of Pottstown, approximately 4 miles downstream
from the site on the Schuylkiii River, has an estimated
population of 35,000 people. The town of Douglassvilie 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 Schuylkiii 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 tne 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 Schuylkiii River is used extensively
for municipal and industrial water supply, recreation, and waste
assimilation. In the reach extending downstream of the
Douglassvilie Disposal Site to the confluence with the Delaware
River, seven public water supply users draw water directly from
the Schuylkiii River. The distance to the nearest public water
supply intake is 4 milts at Pottstown.
Geologically, the Douglassvilie Disposal Site is situated in the
Triassic Lowland section of the Piedmont province. Bedrock in
the general area 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 micaceous,
silty mudstones and shales. Structural deformation is not
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•AM MAP B A P«IITION Or TMf US.4S. 90TCMTOWM, M QCMUMAMOU (7.9 MINurfc ,eAlCS. 997, PHOTO«tviSCD
1971). CONTOiM INTCJtVAL 20'
LOCATION MAP
.ASSVILLE DISPOSAL SITE. UNION TWP. PA L
Pagt 3
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severe. Broad open dips of 25" 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 Q63 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 within
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 Douglassviiie 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 that were used for waste disposal. Tne complexity,
size, various activities that took place at the site, and the
nature and extent of contamination dictated the need for a
logical division of the site into 10 areas that could be sources
of contaminants and identified as source areas. Figure 2 snows
the approximate boundaries of these source areas and their
designations. Disposal areas included two large lagoon areas
that were once filled with waste oil sludge (Source Areas 4 and
5), an oily filter cake disposal area (Source Area 2), an oil
drum storage area (Source Area 8), an area where waste oil sludge
was landfarmed into tne soil (Source Areas 3 and 6), tne former
processing facility/tank farm area (Source Area 1), a small
backfilled lagoon (Source Area 9), an old incinerator (Source
Area 7), and an area of scrap metal and tanks (Source Area 10).
The filter cake disposal area (Source Area 2) is located just
north of tne former processing facility/tank farm area (Source
Area 1). Various trenches and impoundments nave been noted on
site. The lagoons formerly used for waste disposal nave been
backfilled.
A small drainage ditch extends eastward from the center of tne
site and eventually flows into the SchuylJcill 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 (Source Area 9), identified through historical aerial
photographsf lies between the ditch and the swale. The former
drum storage area (Source Area 8) is located just north of the
confluence of the ditch and the swale.
An inactive railroad line extends through the site in an east-
west direction, and the abandoned SchuylJcill Canal borders the
southwestern portion of the site.
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rOTfNTMi fOIMCf ARf Af
FIGURE 2
GENERAL SITE FEATURES AMD POTENTIAL SOURCE AREAS
OeUGLASSVILLE DISPOSAL SITE. UNIOM TWP.PA
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In 1941, Berks Associates, Inc., began lubrication oil recycling
operations at tne site. Site operations also included recycling
some, waste solvents in tne 1950's and 1960fs. Wastes generated
from tne 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 to 3 million gallons of wastes which flowed down the
Schuylkill River.
Federal decrees issued after the November 1970 event prohibited
the storage of waste materials in the lagoons. The decrees also
required the restructuring of the dikes. 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 to 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 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 refining process was
landfarmed in the area near 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 the Site
Investigation, the Schuylkill River (upstream and downstream of
the site), the facility discharge, the drainage swale sediment,
and a domestic veil (upgradient from the site) were also sampled.
Based on the results of the Site Investigation the site received
a Hazard Ranking System (HRS) Score of 55.18. The Douglassviiie
Disposal Sate was proposed for inclusion on the National
Priorities List in December, 1982. The site was promulgated 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/tanJc farm area which was still in operation
at the time. A Record of Decision (ROD) was signed in September,
1985 recommending containment of wastes in the area addressed by
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tne Phase I RI/FS. That Record of Decision deferred the
consideration of resolutions for ground water contamination to
the future RODs. The design vas not implemented due to changes
mandated by the reauthorization of Superfund, and no construction
has-been scheduled.
In late 1985, all oil recycling operations at the facility ver«
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. A Record of Decision
delineating the preferred alternative was signed in June, 1988.
The selected remedial action consists of removal of liquids and
sludges from the tanJcs at the former processing facility.with
treatment by offsite incineration, and the dismantling,
decontamination, and off-site disposal of the entire former
processing facility and tanJcfarm. Surface debris and refuse that
are found throughout the site will also be removed. The design
of the selected remedial action is currently underway and is
scheduled to be completed by July, 1989.
A Phase II Remedial Investigation/Feasibility Study was conducted
by EPA in 1987-88. This comprehensive RI/FS addressed all
aspects of the contamination at the Douglassviiie Disposal Site.
The final RI/FS report was completed in October, 1988.
All investigations at the site have been federally funded. Of
the approximately 125 potentially responsible parties identified
and offered an opportunity to conduct the studies and/or remedial
measures at the site, none has expressed a willingness and/or
ability to do so. An additional 25 parties were identified and
notified of potential responsibility for the first time
concurrently with the release of the Proposed Plan in May, 1989.
SCOPE AMD ROT.F OF QPERAJ^n; fTM^f Qfl BJjSTOMSP ACTION
WITHIN SITE STRATEGY
This response action is the second of two response actions
planned to address contamination at the site. The first response
action addressed risks associated with the former processing
facility/tank farm area. The buildings, tanks, tank wastes, and
processing equipment were impediments to any future soil and
ground water remediation. The ROD for that action was signed in
June, 1988.
The response action delineated in this Record of Decision
addresses soil and ground water contamination remaining after the
former processing facility/tank farm and associated wastes have
been removed from the site. This response action, therefore,
addresses the principal issues at the site, pursuant to EPA's
Phase II RI/FS (October, 1988).
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This Record of Decision, in part, amends a Record of Decision
dated September 27, 1985, which outlined remedial actions for the
portion of the site situated north of the processing
facility/tanJc farm area. That September 1985 Record of Decision
called for the covering of those areas now designated as Source
Areas' 2, 4, and 5 with RCRA caps; diking of the floodplain north
of the railroad right-of-way which runs east-west across the
site; and the excavation of contaminated sediments from the major
drainageway onsite with the inclusion of those sediments under
the RCRA caps. That Record of Decision deferred any decision
regarding ground water remediation. It also did not address any
remediation of the processing facility/tank farm area. The
processing facility completely discontinued operations in late
1985 or early 1986 and is currently considered to be an abandoned
facility containing hazardous substances under tne regulatory
authority of CERCLA.
Because the former processing facility/tanJc area is contaminated
with hazardous substances and is a major contributor to tne
ground water contamination at tne site, and because the
September, 1985 ROD deferred any decision regarding ground water*
remediation, it is necessary that these aspects of tne site be
addressed for remediation under CERCLA. Section 121 (b) of SARA
mandates, in part, that, "Any ROD signed before enactment of this
Act [SARA] and reopened after enactment of this Act to modify or
supplement the selection of remedy shall be subject to the
requirements of section 121 of CERCLA." Since tne addition of
the former processing facility/tanJc farm portion of the site and
the inclusion of a remedial alternative for ground water at the
site constitute modifications to tne remedy selected under the
pre-SARA September, 1985 ROD, this amended Record of Decision
must comply with the provisions of CERCLA as amended by SARA,
including Section 121, Cleanup Standards.
SUMMARY OF SITE
The Phase II RI confirmed the findings of previous studies
regarding the nature and extent of contaminants in soil, ground
water, surface water, and sediment at the Douglassviiie Disposal
site. Contaminants included volatile organics, (ketones,
monocyclie aroma tics, and chlorinated aliphatics), phenolic
compounds, phthalate esters, polynuclear aromatic hydrocarbons
(PAHs), polychlorinated biphenyls (PCBs) and various inorganic
constituents, especially lead.
^
The contaminated portions of the site can largely be described as
contaminated environmental media rather than as waste materials.
The exception to this is Source Area 2 which contains a large
pile of oily filter caxe wastes from the former oil re-refining
process. The wastes in Source Area 2 were deposited prior to
November 1980, and were, therefore, not subject to regulation
under RCRA. A modified Toxic Contaminant Leaching Procedure
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(TCLP) was performed during the Phase II RI on the various
contaminated media at the site. it is estimated from the resu'-s
of the TCLP analyses that the soils in Source Areas l 3 and I'
are EP toxic for lead (Pb).
Soil
Table 1 summarizes the major soil contaminant groups most
frequently detected in the 10 source areas. Included in this
table are weighted-average concentrations for classes of organic
compounds and average lead concentrations. Lead was included
because it is the only metal present at concentrations
significantly higher than background values. More than 50
surface soil and 180 subsurface soil samples were collected from
the various source areas that comprise the site.
Source Area 1 is the former processing facility/tank farm area.
The principal surface soil contaminants were PAHs, PCBs, and
lead. Subsurface soil contamination was more extensive and was
detected at depths up to 20 feet. Subsurface soil contaminants
included volatiles, phenolics, phthalate esters, PAHs, PCBs, and
lead.
Source Area 2 is the backfilled lagoon and filter cake disposal
area. PCBs and lead were the primary contaminants detected in
surface soil. Subsurface soil is contaminated primarily with
volatiles, phthalate esters, PAHs, PCBs, and lead. Contamination
was detected at depths up to 20 feet.
Source Area 3 is a former landfarm area. Organic chemical
contamination is not extensive in the former landfarm. Except
for one phthalate ester, no organics were detected at depths
greater than 2 feet. PCBs and lead are the primary surface soil
contaminants. Subsurface soil in this area is not considered to
be contaminated.
Source Areas 4 and 5 are the sludge disposal and backfilled
sludge lagoon areas located near the Schuylkill River. Surface
soil in these areas is contaminated with PAHs, PCBs, and lead.
Subsurface soil is more heavily contaminated and was detected at
depths up to 20 feet. Subsurface soil contaminants include
volatiles, phenolics, phthalate esters, PAHs, PCBs, and lead.
Source Area 6 is a possible former landfarm area. PCBs and lead
are the primary constituents detected in surface soil.
Subsurface soil contaminants include PAHs, PCBs, and lead.
Subsurface soil contamination was detected only adjacent to
Source Area 5. Subsurface soil contaminants are believed to be
associated with the lagoon at Source Area 5 and not associated
with landfarm activities, which generally tend to affect only
surface soil.
\
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coBC««tr*t 4oB «t
By tMBUB) Of tlM 470l(BBp04MliB9 (teplha. fOi (ufthai *M|ll«IMII 1011 *nd drf ltf«t lOlia Ihc le-.ler i.-. itl.ned lo
-------
..11
No waste disposal- was known to occur at Source Area 7, the
incinerator area. Source Area 8 is a former drum and'tanJc area.
Contamination appears to be only slightly above background in
tnis area.
Source Area 9 is a backfilled lagoon area. Surface soil samples
from tnis area contained phenolics, phthalate esters, PAHs, and
PCBs. Similar compounds as well as various volatile organics,
vere detected in subsurface soil samples. Contamination was
detected at depths up to 10 feet.
Source Area 10 contains empty drums, empty tanks and general
refuse, (drum, tank and refuse area). Relatively low levels of
contaminants were detected in this area. Detections were more
prevalent in surface soil than in subsurface soil.
Tables 2a and 2b summarize the descriptions of the 10 source
areas.
Ground water
Volatile organic compounds constitute the predominant ground
water contaminants detected in onsite monitoring wells. Table 3
summarizes the nature of ground water contamination at the
Oouglassviiie Disposal Site from both the unconsolidated and the
bedrock water-bearing zones which were penetrated by the
monitoring wells, and from the residential wells located offsite.
Blank spaces within the table indicate that there are no positive
detections for the respective analytes.
Benzene, toluene, and vinyl chloride showed the highest
concentrations of the contaminants in ground water collected at
the site. Concentrations for these substances reached as high as
2,000 ppb (ug/1), 2,300 ppb, and 1,200 ppb, respectively. A
number of other volatile organic compounds were also frequently
detected in ground water samples. These included:
Ethylbenzene chlorobenzene
l, 2-dichlorobenzene 1,4-dichlorobenzene
1,1,1-trichloroethane l,l-dichloroethan«
l,2-dichloroethane tetrachlorethane
trichloroethane l,2-dichloroethane
These contaminants vere detected in at least 20 of the 83 ground
water samples collected during the Phase I and Phase II Rls.
Lead, the^predominant inorganic soil contaminant, was detected in
20 of 71 monitoring veil samples. Dissolved lead concentrations
reached as high as 227 ppb.
Ground water contamination is present in both the unconsolidated
deposits and bedrock, a fact which reflects the interconnection
between these ground water zones. Ground water flovs toward the
-------
TABLE
A DESCRIPTION OF THE 10 SOURCE AREAS AT Tilt
DOUGLASSVILLE DISPOSAL SITE
Souccd
•(•a
••MCC*
Octet iption
facility
Coooiot* ol coocfoio building*, (iiocckk •«|ui|»*«nl . S>
took* of various citcc. and «bovo-9found «nd uiideiqiound
pipioo, ***** «••• u««d IB I ho oil («cycling opeulion.
c«k«
€••»•!•• *
fclklck.
pile of fllt«( c*k« lh«l ik «liuut
litcads ovcc *n AIMA ot «t !««»• I acie «nJ
•••tf lot iMdfftraiag. Ml«liw«ly (l«t. cov«i«d with
•• p«fticul*t« ••ttci. And devoid ot
lalso
r«f«((«4 to •• tta •In4f« dlcpoaol
foe slud^O ditpok*! until !*!•. thon df*ined «nd
k*ckftllod im tk« oady !*?•'•.
|*Uo
r«fo((o4 to •• tfco Mckf Ulod
UOtii
U ttoO OAllf ISIt'S. Thl*
includck
••••i»lo loarftoca
foe loodfoiaiof. ltol«tiw«ly (l«t. cuwricd with
Cioo poitlculoto aottor oiid davoid of
loclud«« *• locloocotor ood «o«orol capty
•TIM ••< *••»•! •'•• !•••• '•(•(••4
to •• tho tfiuo) ood taokorool
• coacroto gorofO, tookor t(«iloi». «nd
••pty
oioo. iocludio« backfilled Uqoon «nd IMO
OOktMOrd floMiof dfOioofo choooolc which connect with die
CColto pood ouKoll ood aoot to for* on* d«, oopty
looorol cofyso. • poctioo of
«eil«nd.
-------
13
TA3LZ 2b
SOURCE AREAS
DOUGLASSVILLE DISPOSAL SITE
Source
Area
1
2
3
4
5
6
7
•
9
10
Description
Processing
facility
Backfilled
lagoon/filter .cake
Landfarm
Former sludge
disposal Area A
Former sludge
disposal Area B
Possible landfarm
Incinerator and
surrounding area
Drum and tanker
area
Backfilled lagoon
Drum, tank, and
refuse area
Area
(acres)
2.9
2.0
4.9
2.7
5.3
3.3
NC
1.4
1.3
0.9
NC - not calculated (not contaminated)
-------
14
occdutescs AND D:s?s:3c:7:3N o? ccNT
Csntaff -.riant
acetone
2-eutanone •
2-nei«aone
4-«etnfl-2-peAt*none
bensene
toluene
• triflBensene
total srleaes
cnloroMaseae
pfteael
2-Mtitrl»A«Ml
4-s»tftrlpJi«ae)L
2,4-4iMcnripA«>iKU
l,j-dicrUoroMtieae
l,3-41ealeroMas«ae)
1.4-dienloro6«asea4i
1,2. 4-er icnloroo*at4)84)
•atltae
I,l,2,3-e«eracnlor4f
l.l.l-cfienlac0«eMiM
1 . 1 , 2 • tr lcU«*MtftaM
1,1-dtcBlerMUMM
Kon;
No. at
2/13
1/13
3/13
2S/I3
10/M
21/13
7/93
24/13
4/71
1/71
1/71
35/71
«/7l
21/71
7/71
2/71
2/1)
as/is
ll/M
S4/I3
.»:», -ei:
Cone.
17
1.2
29
2.000
3,300
1*0
•40
17
7.1
29
10
74
4.1
IS
20
•3
2.4
130
a.)
470
s
Average
Cone.
0.33
0.10
0.43
J9.«
47.3
10.7
1C.O
2.2
0.32
0.41
0.14
t.O
0.22
1.9
1.2
1.1
0.03
4.3
0.09
24. •
»o. of
Detections/
No. oC
Staples
2/19
Cone.
0.12
Avtra^e
Cone.
0.01
-------
15
TA31S 3
;cc'jaaiNCZ AND 3:sTR:3cr::N
:OCGIASSV:LIS-D:S?OSAI sin
rwo
c? CCNTXMINANTS :N
, :•«"•»•«
1, 2-4icnloroacnana
en:. raocnan*
tttraenloroatnana
tr;caloroatnana
irans-1, 2-4ienloro-
aenana
en-l.2-4ieftloroaeft.aa
l.l-4icftloroaenaaa
vinyl cnlan4a
caroea tacracnlori4a
eniorafara
aacnylana cnlorida
cnloroawtnaaa
1 , 2-41enloropropaaa
cia-l,l-/
(to. of
1/X9
Cane.
<^9/l>
•4
Cane.
1.9
-------
15
TAair 3
:ir» O:SPOSAI srrr
C3*i«i*:.i*nc
di -n-0ueylpftt.i«4«tt
d i«c.rf ipntft«l4t«
•e»n«pne.-.fl»n«
ancnr«etn«
o«nio( • I «n cnractn*
o«nio(5)fluorant.>i«n«
o«aio( « ) f luor«ntft«««
b«nt«(f,n. i )p«rrl«n«
o«nt«(«)pf f»n«
eAryt«n«
fljortaenca*
fluor«n«
» nd«n« (1.3.3 -e< ) pf r •«•
n«pncn«l«n«
2-Melifln«pntful*a«
pn«n«acnr«n«
pyrta*
alplM-UC
9«MH-tK
n«pt««ni«r
4,4'>OOT
4.4--OM
«B4toattlfM IX
•(MlciulfM MifAM
Mo.r •.
HO. Of
P9tic:v«
0«e«e:;an*/
No. of
S«npl«*
i/n
2/T1
a/'i
•/'I
4/tl
a/ri
i/7I
J/7J
l/TJ
j/ra
iA»a
»/»a
i/ta
.0. •:.-.? .*«..
«««l.flua
Cone.
(49/1)
12
4. 7
30
JfO
300
4f
11
• .3
0.041
$.•
0.28
*
o.os
1
1
Av«r*4«
Cone.
(M«/i>
O.J3
0.11
o.sa
10.1
1.2
O.M
0.44
0.10
0.001
0.01
0.004
0.001
0.04
*««i««n-.:«i M«.II
Na. o<
Pot ic;v«
0«t«ee;on«/
No. a«
S4«pl««
«a«t.iiua
"a. ic.
(^1/1)
*v«r«7«
Cane.
<•*/!)
-------
17
TA31S 3
ccc'j^ai
rou-iAs
?AG2 "OUR
:s
•
.idr:«
•roelor-1242
•roeior-1241
•roelor-1234
•roelor-1240
vinyl «coc«ta
n»nieroiadipnaaf LMiM
ais( J-cniofooenyU
oenor
QORSOIC acid
D«at7l aieaaol
4iB«as4>fur«a
napnaroa*
2-enlaroacttyl viajrl
earooa disuifid*
aluaiaua
aacxMar
.r.ome
6«nua
ttcrfllioa
c*4aio.
ealeiua
enraaiua
Me.-.;
MO. 3<
No. af
S«apl«t
1/72
4/72
1/13
4/71
1/71
2/71
23/71
4/71
4/71
40/71
a/7i
3/n
3J/71
4/7i
Cane.
1.7
430
2.2
44
13
4
122,000
221
1M
1,010
at
12
3*7,000
131
•
Cane.
0.02
4.3
0.03
l.S
0.4$
0.14
2,120
f.4
3. a
134
0.4C
0.44
39.44S
a. 3
*«iid
NO. Of
0«e«et;on«/
NO. <3t
Saaplot
S/lt
$/»
1/lf
Cane.
(44/1)
110
14.400
ia
.
Avtrtf •
Cane .
•
49.4
10,014
0.43
»
-------
IS
^.s 3
cr.-iwzNCi AND srsTara
cvctASSv:tt« O:S?OSAI
AO£ ?:vr
s— *
IS
.
Cantimirtin:
cooele
copper
iron
load
Mfaesiua
m«fle«aese
Mireu«r
nic«ol
pacASttua
••loniufl
•il««(
•otfiua
tMUiua
v«n«4iu«
sine
Mom
No. at
Positive
Ootoecioni/
No. o(
S«aplot
lt/7t
«/7l
JO/71
JO/71
33/71
•3/71
J/71
J3/71
J«/7i
l/Tl
39/71
10/71
sa/7i
:af.-.q «•;;«
Naiinua .
Cone.
(iifl/i)
113
13>
133,000
227
141,000
113,000
3
•73
11,000
S
311,000
30
J.tlO
Avert**
Cone.
(M/l)
1».3
• .3
le.)0«
10.0
13.704
It.SfS
0.04
S3.«
1.331
0.07
33,J37
3.2
342
»»«:d«nt:«. K«lli
No. of
Positive
Oeeeetioni/
Me. of
Seaoles
13/1*
«/!•
s/n
VX»
•/It
4/H
S/tt
1/1*
1/lt
$/!»
13/1»
N«si>ua
Cane.
U4/:>
1,330
273
••
23.700
If)
114
3,S«0
l.<
7.J
31,100
t*0
Avorift
Cone.
<,i«/l)
131
27. •
7.4
3,f«0
30.4
11. *
317
0.4«
0.3*
3,*77
1M
-------
.19
Schuylkill River and discharges to the river. The ground water
contaminant plume begins beneath the former processing
facility/tank farm, which is a significant source of ground water
contamination, and extends across the site to the Schuylkili
River. The lateral extent of the plume is essentially within
the "site boundary. Other major sources of ground water
contamination are the backfilled lagoons designated in the Phase
II RI as Source Areas 4 and 5, which are near the Schuylkill'
River.
Table 3 also presents the results from residential well
sampling. Based on site hydrogeologic conditions and the
observed contamination at the site, no residential wells in the
area have been contaminated by the site. The hydrogeological
conditions at. the site dictate that ground water flows toward the
river. Therefore, the plume of contaminated ground water is not
affecting residential wells which are located hydraulically
upgradient from the site.
Surface Water and Sediment
Table 4 summarizes the nature of surface water and sediment
contamination at the site. This table combines the results of
the sampling of the onsite drainage ditch and of the Schuylkili
River as discussed in Section 4.4 of the October 1988 RI/FS.
•
Surface water samples contained numerous volatile organics as
well as phthalate esters, PCBs, and inorganic constituents.
Sediment contaminants include volatiles, PCBs, phthalate esters,
PAHs, and inorganics. The contamination is essentially confined
to onsite drainage channels. Based on the available data, site-
related contamination cannot be confirmed in either surface water
or sediments at offsite locations. The data collected during the
1987-1988 RI confirmed previous findings in this respect. While
relatively high concentrations of the PCS Aroclor 1260 (4,300
ppb) and lead (2,610 ppm) were detected in the river sediments,
these concentrations were detected only at the upstream location.
PCS and lead contamination in the Schuylkili River has been
previously documented (Stamer, et al., 1985).
Low levels of PAHs were detected in a sediment sample obtained
adjacent to the sit*. This contamination may be a result of
previous releases during flooding. However, the possibility of
alternate sources of this contamination cannot be discounted
because PAHs were detected upstream from the site and were not
detected i» the downstream sediment sample.
The data do not indicate that discharge of contaminated ground
water is affecting the river.
-------
20
TA3_I 4
::s7a:3::?::N or CONTAMINANTS
IN 51~.rACI WATSS AND SSDIMINT
svinr ::S?OSAI sirs
Car. -.».ii ;-«.-.:
«ea:ona
2-sutanona
2-nacanona
4-«at«7i-2-p«nt*ao«ti
aansana
:o.u.n.
at.trlaansana
total iflanaa
cnloroaaniana
pnaaol
3-MenylpAaMl
4-MtnflpAaaal
2,4-tf iavtftflpAaaal
1.2-41eaiara04>aaaa«
1, !-4ieftlaroMaiaM
1, 4-dtcnloroa«asaM
l,3.4-enchl«raa«as«M
aailiM
1, 1,3,3- taeruniara-
1,1,1 -tr icftlara«tiua«)
l,l,3-crt«ai«ifiw
-------
2i
TA31I 4
IS' S-T»FAC2 WA7IR AND S2::.M£N
rCCGLASSVILil DISPOSAL SI7I
?AGI TWO
. :,„..,,.,.,
CniQfOof'ntiflo)
t9C*ACA«O f 99 (fit A o)
:.-ienlara«tft«n«
•tfttn*
cii-l.2-4icnioro4.cAcm.
l,l-41eAloro4>eA4m4>
vinyl eniarid*
e«roon e«er»eniocid«
cniorofara
••cftflcn* eAlori44)
cAloroMtA«n4>
1.2-41cAloroprop«B4)
e 11 -1,1-4 leRloro-
prop«M
propvnc
bro*oa«eA4a«
broa*4ieAloro««tA«aa
eAl«ro4lttr«MMCA«M
{lu«racrieAleroa*OMac
4ienlorodi(laar«-
••eAaa*
^;iii:srUMn>
4 1 -a-MtyiffeUulAt*
s..-
NO. 3f
NO. 3f
S4*pl«t
2/21
9/21
5/21
2/21
2/21
2/2«
3/21
1/21
2/20
2/29
2/29
2/29
1/29
2/29
i/ao
a/2t
1/20
2/21
Cane.
9.2
13
20
11
0.9
41
0.7
0.7
29
0.3
11
0.4
0.1
0.)
0.7
4
O.S
ao
Cane.
0.01
1.0
l.i
0.75
0.04
2.2
0.04
0.02
1.9
o.oa
0.79
0.02
0.004
o.ot
0.02
0.42
0.02
1
S
-------
22
7A312 4 -
:c:'jsarNC2 AND srsraia
IN SwSFACS MATER AND 5
?AO£ TX3IS
. s:
Ot
Cane.
Cone.
No. at
Mo. ot
M4I19UM
Cane.
Cane.
di
0.04
1/34
1/14
140
•ncitraecn*
1/14
140
l.t
2t«
31.4
a«nse( 0) f laoraatAcnc
4/J4
• 10
34.2
2/U
210
10.3
b«nto(f ,ft, i)p«ryl«n«
110
10.0
370
33.1
cnryttn*
2,400
100
J10
ST. 2
(laortnc
130
1.4
1/3C
130
4.2
5/J«
31,000
1.103
S/3«
SI, 000
1.9«0
1,100
13.1
2.200
•IpM-IK
4,4'-OOff
24
0.07
4,«'-
20
0.70
-------
TAS1E 4
CCV3RINC2 AMO 3:STH:3w7:CS :
IN Sc3»AC2 WAT'R AND SiSIMSNt
occLASSvrit« DISPOSAL s:rz
Acr rcoi
• RtfOtiUeM II
tndoiulfaa tulfaca
•Idrin
«raelar-1242
•roclor*1244
•raelor>l294
aroclof >1240
vinyl 4c«c«et>
n-ni era«odlpA«flylAauna
OIK 2-cAl0ra«tAyl)
• tAar
banioic acid
oantyl «leoRel
dib«ft««CUraa
iiopAoron*)
2-cniare«eftyi. vinyl
• eAar
earooa disulfid*
aluaiaua
•nciaanr
aricnte
oattua
D«rylllua
cadaiua
ealclua)
Su:
ffa. al
0«c0etiar.*/
No. a(
1/24
3/34
3/29
f/24
4/20
1/20
1/20
12/20
n/ao
1/20
21/20
Cane.
3.01
S.4
0.9
19
10
2
0.0
9. 90t
10S
4.4
40,000
Cane.
(fl/1 >
0.0004
0.32
0.09
1.2
0.44
0.07
0.03
1,210
34. S
0.24
10,014
S
«o. ,«
•o. at
Saaplai
2/34
2/34
22/34
2/34
1/34
2/37
30/30
1/30
31/30
30/30
11/30
30/30
31/30
.a., .a,
N«« i.iun
Cane.
30,000
130
3.709,000
200
1.200
30
24.370
44
44.2
4.910
3.4
144
14.000
Cane.
1,090
3.4
42,940 1
9.2
33.3
1.1
9,929
2.3
9.0
499
0.41
9.1
2.720
-------
24
:A2iz 4
:cr.-sȣNC2 AND =1573:3:;--s
:N srafAC£ WATER AND sso:vr
iif o:s?osAi sirs'
:i.-.:»m ;.-.».-.:
c-raeiu*
«oo«.t
eopp«r
iron
:•«*
iMfntiiua
m«n«,«n«i«
mercury
nieMl
p4)C«tSlUfl
••loaiua
silver
to4iu»
etialiiua
v«n«4iua
sine
S.c
!«0. Of
POIitlvt
Oot»c:ion«/
!<0. Of
SA*pl*i
4/24
1/24
1/24
24/24
S/24
21/34
24/34
4/20
21/30
21/30
7/30
J«eo w«etr
N««:au«
Cone.
<^9/U
14
» 3
4.9
4.410
473
12.400
1.410
20
4,000
23.000
333
Av«r«9«
Cone.
-------
25
Potential Exposure Pathways
3ased on current use and future use conditions, the potential
human exposure pathways associated with the site are as follows:
o Direct contact with contaminated soil
o Accidental ingest ion of contaminated soil
o Inhalation of contaminated fugitive dust
o Household use of ground water
o Ingest ion of water from the Schuylkill River
SUMMARY OF SITE RISKS
Utilizing data generated during the Phase I and Phase II RIs, a
risk assessment was conducted to evaluate the potential impacts
to human health and the environment posed by chemical
contaminants at, or originating from, the Douglassviiie Disposal
Site. The risk assessment was performed using the guidelines
established in the Superfund Public Health Evaluation Manual
(EPA, October 1986). The constituents that have been detected in
soil and ground water at the site and selected as indicator
chemicals (those having potential adverse health risks) are shown
in Table 5. Included among the constituents listed in the table
are those which are most commonly found as contaminants at the
site. Cumulative Hazard Indices and incremental cancer risks
associated with realistic scenarios involving direct dermal
contact, accidental ingestion of soil, and inhalation of fugitive
dust at the site are shown in Table 6. The rationale for these
realistic scenarios is presented in Section 6 of the October 1988
RI/FS. The highest excess cancer risk due to direct dermal
contact, accidental ingestion of soil and inhalation of fugitive
dust as shown in Table 6 is 5.9 x 10'5 while the highest hazard
index is 1.9.
Direct contact with Contaminated Soil
Estimated human doses from site contaminants were calculated for
each source area based on the arithmetic average indicator
chemical concentrations detected in surface soil. Trespassing
adolescent* and adult hunters and fishermen are considered to be
the most likely receptors through direct dermal contact. Hazard
indices were developed based on the estimated adolescent doses
and chronic reference doses. Incremental cancer risks were
estimated based on the assumption that an adolescent receptor
will be exposed for 10 years and that the sane receptor will be
exposed for 40 years as an adult. A 70-year lifetime was used.
Accidental Ingestion of Soil
Estimated human doses of site contaminants were calculated for
each source area based on the arithmetic indicator chemical
-------
TABLE
INDICATOR CHEMICALS
DOUGLASSVILLE DISPOSAL SITE
Quantitative Risk Assessment
Carcinogens
iMMttM
1,1*2, 2-t«tr«chloro«thaM
1 . 1 , J- fcr ickloi MtlMMM
l.l-dicbloro«tMM
1 , 2-4 ickl«r*«tkftM
t«tr«ckl«ro«tk«M
tf ickl*ro«tk«M
1 . l-4ickl«r««tk«M
vUyl cbI»rU«
c«(k«a t«ic«ckl«cltf«
ckloc«fora
MtkfUn* ckUcid*
chloi •*•»!»•«•
|»l»| 2-«tky lh«iy l|phth«Ut«
bamoUl pf»««*
b«i»ao|a| ••(!»••<:•«•
Noncarci nolens
•thylb«»*«a«
toIiMM*
•f !••••
chlorob*«s«n«
1,1.1-trichloioathan*
•utter •€•••
•c«aaptoth«n«
b*nao(9,h, i )p«ryl«M
fluoi»nth«ii«
(luov«a«
••phtb«I«n«
2-Mthrln«phth«l*M
ph*n«nthr«ne
py««n«
l««d
••rcury
Qualitative Risk Assessment i
Carcinogens
•Idcin
M-nitro«odiph«nyl*Mine
bist2-chloro«thfl|«thec
Noncdrcinogens
1 . 2-dichloi ultenzene
1 . )- dichlocoiienzene
1 ,4 dicliloi obenxene .
1 , 2-dichloroelhene
«ndosul(«n 11
baciu* 1
copper
zinc
1
-------
TABLE 5
INDICATOR CHEMICALS
DOUGLASSVILLB DISPOSAL SITE
PAGE TWO*
Quantitative Risk Assessment
Qualitative Risk Asscuuineiit
Carcinogens
Noncar c i nogens
Noncdrcinoqens
bM*o( b) f liw
iadcaofI.2.3-cd|pf*•••
-------
CUMULATIVE
5
Not available
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29
concentrations detected in surface soii. It is considered
possible (although unlikely) cnat young children may be'exposed
through accidental ingestion of contaminated soil. Exposure may
also occur as a result of adults and teenagers cracking mud into
their homes on their shoes, and to a much lesser extent as a
result of t.-.e deposition of fugitive dust. Hazard Indices wore
developed based on chronic reference doses. Incremental cancer
risks were estimated based on the assumption that a child
receptor will be exposed for 6.5 years. A 70-year lifetime was
used.
Inhalation of Fugitive Dust
Estimated human doses of site contaminants were calculated for
each source area based on a particulate emission model which was
used to generate downwind contaminant concentrations. Human
receptors reside downwind of the site, and the potential for
inhalation of fugitive dust exists in the vicinity of the site.
Noncarcinogenic risks to adolescents and adult cancer risks were
determined for the exposure route. The exposure duration for
carcinogenic risk was set at 35 years. A lifetime of 70 years
was used.
»
Household Use of Ground water
Future dose estimates of ground water contaminants that could
affect humans were generated based on the maximum observed
monitoring well concentrations. It is possible, although
unlikely, that the aquifer beneath the site would be developed
for potable use. Noncarcinogenic risks to children and adult
cancer risks were estimated for this exposure route. It was
assumed that -xposure duration and lifetime were equivalent. The
Hazard Index .;r this scenario was estimated to be 3.3 x 10" and
the incremental cancer risk was estimated to be 1.9 x 10 l.
There is currently no usage of this contaminated ground water as
a potable water source. (The ground water beneath the site is a
Class B-2 aquifer based on EPA's ground water classification
system. This means that it has the potential for use as a
potaible water source.)
Effects on the Schuylkill River
Intensive ground water modeling was conducted as part of the
Phase II RI/FS. The primary purposes of the modeling were to
determine if ground water contaminant concentrations would
increase in the future, and to estimate long-term concentrations
of contaminants in the SchuylJcill River based on ground water
discharges to the river. The model results indicate that
contaminant concentrations would decrease in the future through
natural flushing and attenuation. Discharge of contaminated
ground water to the river and dilution in the river were
considered in evaluating the effect on the Schuylkill River.
Results of the modeling show that concentrations of organic
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30
contaminants in the river'do not exceed l part per billion (ppt»
currently, and win not exceed l ppb at any time in the future.
Lead concentrations were estimated to attain a maximum
concentration of 3 ppb after 200 years. This indicates that the
effect of ground water discharge on the SchuyiJcill River is
insignificant at the present time and is expected to remain so ir
che 'future.
DESCRIPTION OF ALTERNATIVES
As part of the Phase II Feasibility study, a variety of
technologies for remediation of the 10 source areas were screened
and combined into the alternatives proposed for addressing soil
contamination at the site. The 10 source areas were grouped into
three remedial response units during the development of the Phase
II RI/FS to streamline report preparation and to reduce
repetitive discussions. These three groupings were based on the
results of the risk assessment, the chemical characteristics of
the individual source areas, and the vertical extent(s) of
contamination. A variety of remedial technologies for
remediating ground water contamination were also screened to
yield several viable alternatives.
Overall, 11 remedial alternatives for the source areas (soil)
were evaluated in the Phase II FS. Each of the alternatives
addressed 10 source areas, except Source Area 7, where no
contamination was detected. This approach allowed evaluation and
analysis of the most suitable remedy for each individual source
area, independent of the other source areas, that would be
protective of human health and the environment, cost-effective,
and in accordance with statutory requirements. In addition, four
remedial alternatives for ground water were evaluated and
analyzed. Another source area alternative, designated herein as
Source Area Alternative 12, was developed, based on the Phase II
FS, during the preparation and development of the Proposed
Remedial Action Plan. This alternative combines selected aspects
of the alternatives presented in the Phase II FS.
The twelve source area alternatives and four ground water
alternatives are described below. Table 7 presents approximate
costs for each of the source area alternatives.
source Area Alternative l: No Action
The NCP retires that the No Action alternative be considered.
For this alternative, no remedial measures would b« taken to
mitigate risks to human health and the environment. There are no
capital or operation and maintenance (0 & M) costs associated
with this alternative.
This alternative would not address the present and potential
adverse impacts to humans and the environment posed by the site.
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31
Much of the site is located in the 100-year flood plain and a
vet land area is located at Source Area 5. Talcing no action would
not adversely affect the flood plain or the wetland area.
Executive Order 11988, Flood Plain Management (40 CFR 6,'Appendix
A) requires Federal agencies conducting certain activities to
avoid, to the extent possible, adverse effects. Executive Order
11990 Protection of Wetlands (40 CFR 6, Appendix A) requires
Federal agencies conducting certain activities to avoid, to the
extent possible, the adverse impacts associated with the
destruction or loss of wetlands and to avoid new construction in
wetlands if a practicable alternative exists. No ARAfls would
apply because no remedial action would be taken.
Source Area Alternative 2: Minimal Action with Fencing
As part of this alternative, a 6-foot high chain-link fence, with
three-strand barbed wire, would be installed around the perimeter
of a source area, or adjacent source areas. This action would
reduce unrestricted access to the source areas and risks from
direct contact and ingestion of surface soil. Warning signs
would be posted at 100-foot intervals along the fence. Fenced
areas would be covered witn soil and revegetated. This action
would further reduce risks from direct contact and soil ingestion
and would also reduce risks from inhalation of fugitive dust and*
erosion. It may be possible to enhance the existing soil with
lime and nutrients to allow vegetation to grow, and topsoil would
not then be needed. Because contaminated soil would be left on
site, .long-term ground water monitoring would be required. Long-
term inspection and maintenance of the fence would also be
needed. This action could be implemented in 5 to 6 months for
all source areas. The estimated capital and annual 0 & M costs
for this alternative are presented in Table 7. Executive Orders
11988 (Flood Plain Management) and 11990 (Protection of Wetlands)
are applicable standards. Fencing would not adversely affect the
flood plain or the wetland areas at the site. Topsoil would not
be spread in the wetlands, which are already vegetated with
cattails. There are no action-specific ARARs associated with
fencing or revegetating the site.
Source Area Alternative 3: Capping
This alternative involves containment of contaminated materials
under a low-permeability cap. Approximately 600 cubic yards of
sediment from the drainage ditch that runs from the site to the
schuylkill River would be excavated and spread in an area to be
capped. The area would be graded, and a synthetic-membrane cap,
designed according to PADER requirements, would be installed.
The size (acreage) of each source area is presented in Table 2b.
The cap includes the following (from bottom to top): 1-foot soil
buffer layer, 50-mil synthetic membrane, 1-foot sand drainage
layer, filter fabric, 2-foot soil layer for vegetation, a gas-
venting system, and vegetation to prevent erosion. The cap
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32
system would remove the risks to humans posed by direct contact,
ingestion, and inhalation and would mitigate erosion of surface'
soil contaminants.
Because contaminated soil would be left onsite, long-term
ground water monitoring would be required. Long-term Inspection
and maintenance of the cap would also be needed. It 13 estimated
• that the entire site could be capped within 10 to 16 months.
Estimated capital and annual 0 & M costs are presented in Table
7. This alternative would cap soils that pose risks resulting
from direct contact, ingestion, and inhalation.
Much of the site is located within the 100-year flood plain.
Executive Order 11988 and 40 CFR 6 Appendix A require action to
avoid adverse effects, minimize potential harm, and restore and
preserve natural and beneficial values of flood plains.
Construction of the cap would reduce the potential for "washout"
of contaminants during a flood; this would be an improvement over
present conditions. Executive Order 11990 and 40 CFR 6 Appendix
A require action to avoid adverse effects, minimize potential
harm, and preserve and enhance wetlands. Wetlands located at
Source Area 5 would be covered by the cap and thereby eliminated,.
The cap, as described in this alternative, would meet the RCRA
closure requirements at 40 CFR, Parts 264.228, 264.258, and
264.310. The cap design would also meet PADCR requirements of 25
PA Code, Chapter 75, Subchapters C and 0. RCRA closure
requirements and the Pennsylvania requirements are relevant and
appropriate for Source Areas 1, 3 and 6 which contain soil
contaminants (lead) in concentrations which are probably EP
toxic. The other source areas do not contain either
"characteristic wastes" nor wastes otherwise defined as hazardous
under 40 CFR 261. These other areas do however, pose health and
environmental risks which could be addressed by capping. Post-
closure use of the property must be restricted as necessary to
prevent damage to the cap.
OSHA standards, especially those governing worker safety durir.g
hazardous waste operations at 20 CFR 1910, would have to be
followed during all site work.
During site work. Clean Air Act (CAA) and Pennsylvania air
requirements must be considered. If the total suspended
particulates limit is exceeded, dust suppressants must be
applied.*
Source Area Alternative 4: Excavation, Onsite Thermal Treatment
and Offsite Disposal
This alternative involves treatment of contaminated soils using
onsite thermal treatment. All contaminated soil, along with 600
cubic yards of sediment from the drainage ditch that runs between
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33 .. .
the site and the SchuylJc-iil River, would be excavated and hauled
to a mobile treatment unit that would be set up at the site. The
treatment unit should be set up in an area that is not within -rie
100-year flood plain, such as Source Areas 1 or 2. Excavated
areas would be backfilled with clean soil and revegetated.
Thermal treatment would remove at least 99.99 percent of the
organics in the soil; however, metals are not affected and would
remain in the treated material. The treated material would be
hauled to an offsite, EPA-approved landfill for disposal.
Thermal treatment would require test burns to determine optimum
operating conditions. Test burns could also be used to determine
inorganic (metal) contaminant levels in the ash. The thermal
treatment unit would include a wet scrubber to treat the exhaust
gas, and the water would require subsequent treatment/disposal.
The contaminant concentrations in the scrubber water would
determine the level of treatment required and could also be
determined during the test burns.
Because all contaminated materials would be removed from the
site, no long-term ground water monitoring or 0 & M would be
required. It is estimated that the entire site could be
remediated in 8.5 to 17 years. Estimated capital costs are
presented in Table 7. No annual 0 & M costs are associated with
this alternative.
Under this alternative, soils that pose health risks resulting
from direct contact, ingestion, and inhalation would be thermally
treated.
Executive Orders 11988 and 11990 (40 CFR 6 Appendix A), which
concern flood plains and wetlands, are applicable. Removal of
contaminants from the flood plain would reduce the potential for
"wash out" of contaminants during a flood; this would be an
improvement over existing conditions. However, the wetlands at
Source Area 5 would be destroyed during this action.
RCRA incinerator regulations at 40 CFR 264, Subpart 0 are ARARs
for this alternative and include performance standards and
operating, monitoring, and inspection requirements. The
treatment unit must be a RCRA-permitted or approved unit. The
state regulations for hazardous waste incineration at 25 PA code
Chapter 75, Part 264 are also ARARs. Thermal treatment of PCB
contaminated soil meets the Toxic Substances Control Act (TSCA)
regulations at 40 CFR 761 for disposal and storage of PCBs and
PCB itemsfr Lead emissions from the onsite treatment unit would >,
comply with CAA National Ambient Air Quality Standards (NAAQS)
and PADER air quality standards, both of which are 1.5 ug/m
quarterly average. In addition to thermal treatment unit air-
emission requirements, CAA and state standards limiting total
suspended particulates would apply during excavation. OSHA
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34
standards, specially standards governing worJcer safety during
hazardous waste operations at 20 CFR 1910, would have to be
followed during all site work.
Federal and State DOT regulations for offsite transport of
hazardous materials would have to be considered. The landfill
used" for disposal of the treated material must be permitted by
the state and/or approved by the EPA to accept hazardous
substances.
Source Area Alternative 5: Excavation, Onsite Thermal Treatment,
and Onsite Disposal
This alternative involves treatment of contaminated soil, along
with 600 cubic yards of sediment from the drainage ditch that
runs between the site and the Schuylkill River. These materials
would be excavated and hauled to a mobile thermal treatment unit
that would be set up at the site. The treatment unit should be
set up in an area that is not in the 100-year flood plain, such
as Source Areas 1 or 2. Excavated areas would be backfilled
using treated material, capped, and revegetated. The cap is the
same as discussed for Source Area Alternative 2. Thermal
treatment would remove at least 99.99 percent of the organics in
the soil; however, metals are not affected and would remain in
the treated material. If the treated material is determined to
be EP toxic, the material would be further treated using
solidification before it is used to backfill the excavations.
Thermal treatment would require test burns to determine optimum
operating conditions. The test burns could be used to determine
metal contaminant levels in the treated material. The thermal
treatment unit would include a wet scrubber to treat the exhaust
gas, and the water would require subsequent treatment/disposal.
Contaminant concentrations in the scrubber water would determine
the level of treatment required and could also be determined
during the test burns.
It is estimated that the entire site could be remediated in 8.5
to 17 years. Estimated capital and annual 0 & M costs are
presented in Table 7. This alternative would treat soils that
pose risk* via direct contact, ingestion, and inhalation.
Executive Orders 11988 and 11990 (40 CFR 6 Appendix A), which
concern flood plains and wetlands, are applicable, construction
of the cap, following backfilling with treated material, would
reduce the possibility for "wash out* of contaminants during a
flood; this would be an improvement over existing conditions.
The wetlands at Source Area 5 would be removed during excavation.
RCRA incinerator regulations at 40 CFR 264, Subpart 0 are ARARs
and include performance standards and operation, monitoring, and
inspection requirements. The thermal treatment unit must be
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35
RCRA-permitted or approved. The State regulations for hazardous
waste incineration at 25 PA Code Chapter 75 are also ARARs.
Thermal treatment of PCB-contajninated soil meets the TSCA
regulations at 40 CFR 751 for storage and disposal of PCBs and
PCS items. Lead emissions from the onsite thermal treatment unit
would comply with the NAAQS and PADER air quality standards (1.5
ug/nr quarterly average). In addition to thermal treatment unit
air emission requirements, CAA and state standards limiting total
suspended particulates would apply during excavation.
OSHA standards, especially standards at 29 CFR 1910 governing
worker safety during hazardous waste operations, would have to be
followed during all site work.
Source Area Alternative 6: Excavation and Offsite Thermal
Treatment
This alternative involves treatment of contaminated soils at an
offsite thermal treatment unit. All contaminated soil, along
with 600 cubic yards of sediment from the drainage ditch that
runs between the site and the Schuylkill River, would be
excavated and hauled to an approved offsite thermal treatment
facility. All excavations would be backfilled using clean fill.
material and revegetated. There would be no need for long-term.
monitoring because all contaminated materials would be removed
from the site. It is estimated that the entire site could be
remediated in 4.5 to 7 years. Estimated capital costs are
preserited in Table 7. There are no annual 0 & M costs associated
with this alternative.
This alternative would treat soils that pose risks from direct
contact, ingestion, and inhalation. Executive Orders 11988 and
11990 (40 CFR 6 Appendix A), which concern flood plains and
wetlands, are applicable. Removing contaminated materials from
the flood plain would prevent "wash out" of contaminated soil
during a flood; this would be an improvement over existing
conditions. The wetlands at Source Area 5 would be removed
during excavation.
Removal of all contaminated materials and eliminating the need
for further maintenance and control satisfy RCRA clean closure
requirements at 40 CFR 264.110.
Transportation of the waste to a commercial hazardous waste
thermal treatment unit would be in compliance with standards
applicable to generators of hazardous waste at 40 CFR 262 and 25
PA code (fhapter 75 and with Federal and State DOT regulations
pertaining to transportation of hazardous materials.
OSHA standards, especially standards at 20 CFR 1910 governing
worker safety during hazardous waste operations, would have to be
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36
followed during all site work. During excavation, CAA and State
air standards must be considered. If any limits are exceeded,"
dust and/or vapor suppressants would be applied.
Source Area Alternative 7: Landfarming
This alternative is applicable only to Source Areas 3 and 6. The
vertical extent of contamination at the other source areas would
preclude implementation in a timely manner. A flood-protection
dike would be installed around Source Areas 3 and 6 because they
are in the 100-year flood plain. Landfarming would include the
application of nutrients, moisture, and aeration to stimulate
naturally-occurring microorganisms. Aerobic conditions are
generally maintained by plowing, disking, or rototilling. The
effectiveness and detailed operations would need to be determined
by treatability studies. These studies are also needed to
determine the time to achieve cleanup. Long-term monitoring,
operation, and maintenance would be required until remediation is
completed. Estimated capital and annual 0 & M costs are
presented in Table 7. This alternative would treat soils that
pose risks from direct contact, ingestion, and inhalation.
*
Executive Order 11988 (40 CFR 6 Appendix A), which concerns flood
plains, is applicable. The flood plain may be adversely affected
because a flood dike would be installed; however, the area to be
diked is a small percentage of the flood plain area. This
alternative would not adversely affect wetlands at Source Area 5.
The landfarm would be designed to meet the substantive
retirements of 40 CFR 267 (interim standards for new hazardous
waste land disposal facilities) and 40 CFR 264, Subpart M (land
treatment). Closure of the landfarm would comply with the
substantive requirements of 40 CFR 264.280.
OHSA standards, especially those at 29 CFR 1910 governing worker
safety during hazardous waste operations, would have to be
followed during all site work. Clean Air Act and State air
standards would apply during excavation and soil aeration
activities.
Source Are* Alternative 8: Excavation, Onsite Extraction, and
Offsite Disposal
This alternative involves onsite extraction of contaminated soils
using the B.E.S.T. process. This alternative is not applicable
to Source Areas 3 and 6 because these areas contain only small
amounts of oil. The extraction process evaluated is particularly
suited to the oily waste found at the other source areas. All
contaminated soil, along with 600 cubic yards of sediment from
the drainage ditch that runs between the site and the SchuylJcill
River, would be excavated and hauled to an extraction plant that
would be set up at the site. The extraction plant should be set
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37
up in an area that is not within the flood plain. Excavated areas
would be backfilled with clean material and revegetated.
Reportedly, the B.E.s.T. process can reduce oil and grease to
less than 0.1 percent and PCBs to l ppm. Treatability testing is
required to determine the extent of heavy metal removal. Treated
material would be hauled to an EPA-approved, offsite Subtitle C
landfill for disposal if the residuals are classified as
hazardous following treatment.
Extraction would require treatability studies to determine
optimum operating conditions, the residual contamination that
cannot be removed by the extraction process, and the chemical
characteristics of the spent extraction fluid. These studies
would help to determine the ultimate treatment/disposal
requirements for wastes generated by the extraction process.
No long-term ground water monitoring would be required for these
areas because all contaminated materials would be removed from
the site. It is estimated that the entire site could be
remediated in 6.5 to 13 years. Estimated capital costs are
presented in Table 7. No annual 0 & M costs are associated with
this alternative.
*
This alternative would treat soils that pose risks from direct
contact, ingestion, and inhalation. Removal of all contaminated
materials and eliminating the need for further maintenance and
control satisfy RCRA clean closure requirements at 40 CFR
264.ill.
Executive Orders 11988 and 11990 (40 CFR 6 Appendix A), which
concern flood plains and wetlands, are applicable. Removal of
contaminated soil from the flood plain would reduce the potential
for "wash out" of contaminants during a flood; this would be an
improvement over existing conditions. However, the wetlands at
Source Area 5 would be destroyed during this action.
The spent extraction fluid may be a hazardous waste. Federal and
state regulations for generation and transportation of hazardous
materials would then have to be complied with. The offsite
facilities that receive the treated material and the spent
extraction fluid must have the required permits and be in
compliance with all applicable State and Federal regulations.
OSHA standards, especially standards at 29 CFR 1910 governing
worker safety during hazardous waste operations, would have to be
followed. During site work, CAA and State air standards would be
considered. If any limits are exceeded during excavation or
extraction, dust and/or vapor suppressants must be applied.
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38
Source Area Alternative 9: Excavation, Onsite Extraction and
Onsite Disposal
This alternative involves onsite extraction of contaminated soils
using the B.E.S.T. process. This alternative is not applicable '
to Source Areas 3 and 6 because these areas contain only small
amounts of oil. The extraction process evaluated is particularly
suited to the oily materials found at the other source areas.
All contaminated soil, along with 600 cubic yards of sediment
from the drainage ditch that runs from the site to the Schuylkiii
River, would be excavated and hauled to an extraction plant that
would be set up at the site. The extraction plant should be set
up in an area that is not in the flood plain. Excavated areas
would be backfilled using treated material, capped, and
revegetated.
Reportedly, the B.E.S.T. process can reduce oil and grease to
less than 0.1 percent and PCBs to 1 ppm. Treatability testing is
required to determine the extent of heavy metal removal.
Treatability studies would be required to determine optimum
operating conditions, the residual contamination that cannot be
removed by the extraction process, and the chemical
characteristics of the spent extraction fluid. These studies
would help to determine tne ultimate treatment/disposal
requirements for residual wastes generated by the extraction
process.
This alternative would treat soils that pose risks through direct
contact, ingestion and inhalation. It is estimated that the
entire site could be remediated in 6.5 to 13 years. Estimated
capital and annual 0 & M costs are presented in Table 7.
Executive Orders 11988 and 11990 (40 CFR 6 Appendix A), which
concern flood plains and wetlands, are applicable. Construction
of the cap, following backfilling with treated material, would
reduce the possibility of "wash out" of contaminants during a
flood; this would be an improvement over existing conditions.
However the wetlands at Source Area 5 would be destroyed during
this action. State solid waste disposal requirements at 25 PA
Code, Chapter 75, Parts 21 through 38 would also be considered.
The spent Extraction fluid may be a hazardous waste. Federal and
state regulations for generation and offsite transport of
hazardous materials would need to be complied with. Any offsite
facility receiving the spent extraction fluid must have the
required permits and be in compliance with all applicable State
and Federal regulations.
OSHA standards, especially those at 29 CFR 1910 governing worker
safety during hazardous waste operations, would have to be
followed. CAA and State air requirements would be considered
during excavation and treatment. If any standards are exceeded,
preventive measures must be implemented.
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39
Source Area Alternative 10: Excavation and Onsite Landfiiiing
This alternative involves excavation of contaminated materials
with containment within an onsite RCRA landfill. All
contaminated soil, along with 600 cubic yards of sediment from
the drainage ditch that runs from the site to the Schuylkili
River, would be excavated and placed in a double-lined RCRA
landfill that would be constructed at the site. Contaminated
soil from the landfill location would be excavated and hauled to
a temporary storage area. The storage area would have a liner
and runoff controls and may be covered to control the release of
volatile organics to the atmosphere, if required.
After all the contaminated soil from the landfill locations is
excavated and stockpiled, the excavation would be backfilled to
an elevation above the 100-year flood elevation. The landfill
liner would then be constructed over the backfilled area. The
liner would be designed according to PADER regulations and
includes the following from bottom to top: 20-mil synthetic
membrane (secondary liner), l-foot sand layer (leak detection
zone), 50-mil synthetic membrane (primary liner), 1-foot sand
layer (leachate flow zone), and filter fabric to separate the
leachate flow zone from the waste.
After^the liner is constructed, stockpiled waste would be
backfilled above the liner and compacted. All other areas of
contaminated soil would then be excavated and placed in the
landfill. After all contaminated materials have been placed, a
cap would be constructed and tied in to the liner. The cap would
be designed according to PADER regulations and is the same as
proposed for Source Area Alternative 3.
This alternative would contain soils that pose risks, through
direct contact, ingestion, and inhalation, in a double-lined RCRA
landfill. Because contaminated materials would remain onsite,
long-term monitoring and maintenance would be required. It is
estimated that this alternative could be implemented in 4.5 to 6
years. Estimated capital and annual 0 & M costs are presented in
Table 7.
Executive Orders 11988 and 11990 (40 CFR 6 Appendix A), which
concern flood plains and wetlands, are applicable. The area
where the landfill would be constructed would be filled to the
100-year flood elevation prior to landfill construction. This
action could adversely affect the flood plain by reducing the
flood water storage capacity provided by the flood plain. This
could cause increased water velocities and higher water levels in
offsite areas during a flood.
Design and construction of the onsite landfill under this
alternative would comply with the minimum technology requirements
at 40 CFR 264, Subpart N for RCRA landfills. The landfill design
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40
would also comply with state regulations for hazardous waste
landfills at 25 PA Code 75.264. The temporary waste stock
pile(s) must have a liner and leachate collection system as
specified at 40 CFR 264.251.
OSHA standards, especially those at 29 CFR 1910 governing worker
safety during hazardous waste operations, would have to be
followed. During site work, CAA and state air requirements must
be considered. If any limit or standard is exceeded, actions
must be taken to control air emissions.
Source Area Alternative 11: Excavation and Offsite Landfilling
This alternative involves excavation of contaminated materials
with disposal at an offsite landfill. All contaminated soil,
along with 600 cubic yards of sediment from the drainage ditch
that runs from the site to the Schuylkill River, would be
excavated and hauled to a RCRA-approved offsite landfill
facility. All excavations would be backfilled with clean fill
material and revegetated. There would be no need for long-term.
monitoring because all contaminated materials would be removed..
from the site. It is estimated that the entire site could be
remediated in 4.5 to 6 years. Estimated capital costs are
presented in Table 7. There are no annual 0 & M costs associated
with this alternative. This alternative would remove soils that
pose risks from direct contact, ingestion, and inhalation.
Executive Orders 11988 and 11990 (40 CFR 6 Appendix A), which
concern flood plains and wetlands, are applicable. Removing
contaminated materials from the flood plain would prevent "wash
out" of contaminants during a flood; this would be an improvement
over existing conditions. However, the wetlands at Source Area 5
would be removed during excavation. Removal of all contaminated
materials and eliminating the need for further maintenance and
control, satisfy RCRA clean closure performance standards at 40
CFR 264.110.
The facility receiving the contaminated materials must be in
compliance with applicable State and Federal permit requirements
relevant to hazardous waste disposal facilities.
Transportation of the contaminated soil to a commercial hazardous
waste landfill would be done in compliance with standards
applicable to generators of hazardous waste promulgated under
RCRA at 40 CFR 262 and State regulations at 25 PA Code Chapter
75, and Federal and State DOT regulations pertaining to the
transport of hazardous materials.
OSHA standards, especially those at 29 CFR 1910 governing worker
safety during hazardous waste operations, would have to be
followed. During site work, CAA and State air requirements
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41
must be considered. If any limit or standard is exceeded, act-c-
vould be taJcen to control air emissions.
Source Area Alternative 12: Onsite Thermal Treatment and Minimal
Action
This alternative combines selected aspects of the no action
alternatives, the minimal action.alternatives, and the onsite
thermal treatment with onsite ash disposal alternative. It was
formulated for consideration as part of EPA's Proposed Remedial
Action Plan and was developed from the various alternatives
presented in the RI/FS. This alternative was designed to
mitigate risks to human health and the environment associated
with each source area, and involves treatment of the highest ris)c
area of the site using onsite thermal treatment.
The pile of oily filter caJce waste at Source Area 2 (48,400 cubic
yards) would be excavated and hauled to a mobile incinerator that
would be set up at the site. Approximately 600 cubic yards of
oily sediment from the drainage ditch that runs from the site to
the SchuylJcill River would also be excavated and hauled to the
onsite thermal treatment unit. The unit should be set up in an*
area that is not in the 100-year flood plain.
Source Area 2 would be backfilled with the treated material
(ash), covered with soil, and revegetated. The ash would be a
"buffer zone" between contaminated subsurface soil that was not
removed and the top soil. Thermal treatment would remove at
least 99.99 percent of the organics; however, metals would not be
affected and would remain in the treated material. EP toxicity
leach testing would be conducted to determine if the ash is a
characteristic hazardous waste. If the ash exceeds EP toxicity
levels, solidification would be required to render the material
non-hazardous, and, therefore, suitable for disposal back into
Source Area 2.
Source Areas 1, 4 and 5 would be capped with one foot of
compacted flyasn followed by two feet of soil and revegetated.
Source Areas 3, 6, and 9 would be revegetated or capped with top
soil followed by revegetation. Closure of source Areas
1,2,3,4,5,6 and 9 would be in accordance with the relevant and
appropriate requirements of 40 CFR 264.310. No action would be
taken at Source Areas 7, 8, and 10. Based on available data,
soil contamination, and, therefore, risk, at source Areas 7 and 8
are or below health-based levels, source Area 10 contains a
wooded wetfland which should not be disturbed. ^
- - * ™" -^"'
Thermal treatment would require tesT burns to determine optimum
operating conditions. The test burns could be used to determine
heavy metal concentrations in the treated material. The thermal
treatment unit would include a^wet scrubber to treat the exhaust
gas, and the water would requite subsequent treatment/disposals
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42
Contaminant concentrations in the scrubber water would determine
the level of treatment required and could also be determined
during test burns.
Hazardous substances would remain onsite at the completion of
remedial action; therefore the 5-year review requirement of
Section 121(c) of SARA would be implemented. It is estimated
that this alternative could be completed in 2 to 3 years. The
capital cost is estimated to be 339,280,000, If the ash from the
thermal treatment of Source Area 2 is hazardous thereby requiring
solidification, the capital cost would rise to approximately
353,619,000. No annual O & M costs are associated with this
alternative. However, the 5-year review procedure would cost
approximately 325,000.
This alternative would thermally treat oily wastes from Source
Area 2 that pose excess cancer risks exceeding 10-6 via direct
contact, ingestion, and/or inhalation; and cover and vegetate
other contaminated areas to reduce risks to human health and to
the environment.
Executive Orders 11988 and 11990 (40 CFR 6 Appendix A), which
concern flood plains and wetlands, are applicable. Covering
contaminated soil in the flood plain would reduce the possibility
for "wash out11 of contaminants during a flood; this would be an
improvement over existing conditions. The wetlands at the site
would be left undisturbed to the extent possible.
RCRA incinerator regulations at 40 CFR 264, Subpart 0 are
relevant and appropriate requirements and include performance
standards and operating, monitoring, and inspection requirements.
The thermal treatment unit must be RCRA-permitted or approved.
The state regulations for hazardous waste incineration at 25 PA
code Chapter 75 are also ARARs. Thermal treatment of PCB-
contaminated waste would meet the TSCA regulations at 40 CFR 761
for storage and disposal of PCBs and PCB items. Lead emissions
from the onsite thermal treatment unit would comply with the
NAAQS and PADER air quality standards (1.5 ug/m quarterly
average). In addition to incinerator air emission requirements,
CAA and State standards limiting total suspended particulates
would apply during excavation and thermal treatment operations.
Possible senarios for stack scrubber wastes generated during the
onsite thermal treatment process include:
l- the disposal of the scrubber wastes in an offsite
facility;
2- the disposal of those wastes, if non-hazardous, into
Source Area 2 without treatment;
3- the solidification of the scrubber wastes, if EP toxic,
with disposal in source Area 2.
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43
OSHA standards, especially standards at 29 CFR 1910 governing
worker safety during hazardous waste operations, would have to be
followed during all site work.
If it is determined that the treated material would not be-a
hazardous waste, as defined by RCRA at 40 CFR 261, the land
disposal restrictions at 40 CFR 268 would not be an ARAR. if the
created material is a characteristic hazardous waste as defined
by RCRA, land disposal restrictions would apply and the ash would
be solidified. The statutory deadline for establishing land
disposal restrictions for characteristic RCRA hazardous waste is
May, 1990.
Ground water Alternative 1: No Action with Monitoring
This alternative would not require implementation of remedial
actions to address ground water contamination. A long-term
monitoring program would be implemented. Administrative
controls, such as deed and land-use restrictions, would be
required to limit site ground water use and to alert future
property owners of potential site-related risks.
»
This alternative would not comply with contaminant-specific ARARs
(e.g. MCLs, MCLGs, etc.) based on ingestion of ground water
beneath the site. However, long-term monitoring could be used to
determine whether ground water discharges to the SchuylJcill River
are adversely affecting river-water quality. Taking no action
would not adversely affect the flood plain or wetland areas at
the site. No action-specific ARARs apply because no remedial
action would be taken.
There are no capital costs associated with this alternative.
Annual monitoring costs are estimated at $27,000.
Ground water Alternative 2: Minimal Action with an Alternate
Concentration Limit (ACL) Determination
This alternative would not require implementation of remedial
actions to reduce ground water contamination. An Alternate
concentration Limit (ACL) determination, pursuant to SARA,
Section 121 (d)(2)(B)(ii), would be used because hazardous
constituents detected in ground water do not pose risks to human
health or the environment. Administrative controls, such as deed
and land-use restrictions, would be required to limit site ground
water use.^ Long-term ground water monitoring would be performed.
The ACLs established as the ground water protection standard
would be the maximum concentrations listed in Table 3 for the
monitoring wells. If the ACL is exceeded, then some type of
remediation may be necessary. Surface water monitoring would
also be required.
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44
This alternative would meet contaminant-specific ARARs; however,
the ground water protection standards would be the ACLs that were
established, rather than MCLs, MCLGs, or background levels.
Appendix "A" to this Record of Decision includes a listing'of
MCLs and MCLGs. CERCLA allows the establishment of ACLs for
hazardous constituents in ground water that assumes a point of
human exposure beyond the site boundary only when three specific
conditions exist:
o There are known and projected points of entry of ground
water into surface water;
o On the basis of measurements or projections, there is
or will be no statistically significant increase of
hazardous constituents, from ground water, in surface
water at the point of entry or at any point downstream
where there is reason to believe that hazardous
constituents may accumulate; and
o The remedial action includes enforceable measures that
win preclude human exposure to contaminated ground
water at any point between the site boundary and all
known and projected points of entry of ground water
into surface water.
This alternative would not adversely affect the flood plain or
the wetland areas at the site. No capital cost is associated
with this alternative.
Ground water Alternative 3: Ground water Pumping and Treatment
(GAC Option)
This alternative involves installation of ground water recovery
wells equipped with pumps. Ground water from beneath the site
would be pumped to a treatment plant and, after treatment, would
be discharged to the SchuylJcill River. The two main areas of
ground water contamination that were detected during the Rl are
near the former processing facility/sludge disposal area (Source
Areas 1 and 2) and the former sludge lagoon areas near the river
(Source Areas 4 and 5). The flow rate from the pumping wells in
these areas vas estimated to be 300 gpm.
The process units for treatment of contaminated ground water
include tlfe following: equalization; oil/water separation;
precipitation and sedimentation to remove metals; filtration; air
stripping to remove volatile organics; and granular activated
carbon (GAC) to remove other organics that would be present. Air
stripping combined with GAC can remove most organic compounds to
below detectable limits.
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,45
Residuals generated include recovered oil. sludge from
sedimentation, and spent activated carbon. The sludge and oil
vould require offsite disposal. A sludge dewatering system would
be needed to reduce the volume of sludge for offsite disposal.
Spent activated carbon would be needed to reduce the volume of
sludge for offsite disposal. Spent activated carbon would have
to be regenerated.
Estimated capital costs for this alternative are $4,600,000.
Annual 0 & M costs are estimated at 3700,000. The total present
worth of this alternative is estimated to be $15,608,000.
Detailed modeling during the design phase would be needed to
determine the amount of time needed to achieve cleanup and to
refine the design of the pumping and treatment system. The
amount of time required and the effectiveness of this alternative
would depend, to a great extent, upon the degree of contaminant
source (soil and waste) remediation performed onsite.
The treatment system would meet contaminant-specific ARARs by
removing contaminants from ground water. Contaminant-specific
ARARs are shown in Table 10-40 of the October, 1988 RI/FS.
Discharge limits would be determined by the State, based on NPDES
requirements and considerations. Federal regulations at 40 CFR
122 and 40 CFR 136 establish rules for determining control
technology requirements, discharge limitations, and monitoring
requirements. All PADER requirements are also applicable.
This alternative would not adversely affect the flood plain or
the wetlands located at the site.
Ground vater Alternative 4: Ground water Pumping and Treatment
(Ozone/UV Option)
This alternative involves installation of ground water recovery
wells equipped with pumps. Ground water from beneath the site
would be pumped to a treatment plant and, after treatment, would
be discharged to the SchuylJcill River. The two main areas of
ground water contamination that were detected during the RI are
near the former processing facility/sludge disposal area (Source
Areas 1 and 2) and the former sludge lagoon areas near the river
(Source Areas 4 and 5). The flow rate from the pumping wells in
these areas was estimated to be 300 gpm.
The process units for treatment of contaminated ground water
include trte following: equalization; oil/water separation;
precipitation and sedimentation to remove metals; filtration; air
stripping to remove volatile organics; and ozone/ultraviolet
light (UV) to remove other organics that would be present. Air
stripping combined with ozone/UV can remove most organic
compounds to below detectable limits. Residuals generated would
include recovered oil and sludge from sedimentation. The sludge
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46
and oil would require offsite disposal. A sludge dewatering
system would be needed to reduce the volume of sludge for offsite
disposal.
*
Estimated capital costs for this alternative are $5,200,000.
Annual 0 4 M costs are estimated at $900,000. The total present
worth of this alternative is estimated to be $19,525,000.
Detailed modeling during the design phase would be needed to
determine the amount of time needed to achieve cleanup and to
refine the design of the pumping and treatment system. The time
frame and the effectiveness of this alternative would depend, to
a great extent, upon the degree of contaminant source (soil and
waste) remediation performed onsite. The treatment system would
meet contaminant-specific ARARs by removing contaminants from
ground water. Contaminant-specific ARARs are shown in Table 10-
40 of the October, 1988 RI/FS. Discharge limits would be
determined by the State, based on NPDES requirements and
considerations. Federal regulations at 40 CFR 122 and 40 CFR 136
establish rules for determining control technology requirements,
discharge limitations, and monitoring requirements. All PADER *
NPDES requirements are also applicable.
This alternative would not adversely affect the flood plain or
the wetlands located at the site.
This section provides a description of the nine criteria EPA uses
to evaluate alternatives and an analysis of the alternatives
under consideration at the Douglassviiie Disposal Site. The nine
criteria are delineated in Draft Interim Guidance On Preparing
Suoerfund Decision Documents: The Prooosed Plan and Record of
Decision. DecemberP 1988.
follows:
The evaluation criteria are as
Overall Protection of Human Health and the Environment
- addresses whether or not a remedy provides adequate
protection and describes how risks are eliminated,
reduced, or controlled.
Compliance with ARARs - addresses whether or not a
remedy will meet all of the applicable or relevant and
appropriate requirements of environmental statutes.
Long-Term Effectiveness and Permanence - refers to the
ability of a remedy to maintain reliable protection of
human health and the environment over time once cleanup
goals are achieved.
Reduction of Toxicity, Mobility, or volume - is the
anticipated performance of the treatment technologies
that a remedy might employ.
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47
o snort-Term Effectiveness - addresses the period of t;.-?.e
needed to achieve protection and-any adverse impacts ~cr.
human health and the environment that may be posed
during the construction and implementation period until
cleanup goals are achieved.
o Implementability - the technical and administrative
feasibility of a remedy, including the availability of
materials and services needed to implement a particular
option.
o Cost - includes estimated capital and operation and
maintenance costs.
o state Acceptance - addresses state comments.
o community Acceptance - summarizes the public's general
response to the alternatives described in the Proposed
Plan and the RI/FS Report. The specific responses to
public comments are addressed in the Responsiveness
Summary section of the ROD.
Overall Protection of Hunan Health and the Environment
Source Area Alternatives 4, 6, 8, and 11 would provide the most
protection because all contaminated materials and treatment
residuals would be completely removed from the site.
Source Area Alternatives 5 and 9 use treatment to remove organic
soil contaminants, but metals would remain in the residuals,
which would be backfilled on site and covered by a cap. The cap
would reduce the risks to human health from direct contact,
ingestion, and inhalation and would reduce the leaching of
residual contaminants to ground water.
Ground water Alternatives 3 and 4 use treatment to remove organic
and inorganic ground water contaminants. This would reduce risks
from ingestion and from the discharge of contaminants to the
schuylkill River.
Source Area Alternative 12 uses treatment to remove organic soil
contaminants from the source area at the site that poses the
greatest risk; however, metals would remain in the treatment
residuals, which would be used as backfill. The backfilled area
and sourc* areas having lesser amounts of contamination would be
capped with soil or with flyash and soil to reduce risks to human
health from direct contact, inhalation, and ingestion. Source
areas that pose minimal risks to human health or the environment
would receive no action. The leaching of contaminants to ground
water would not be significantly reduced. Restrictions on soil
disturbance and well drilling at the property would further
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48
reduce remaining risks to human health and the environment.
Wetland areas onsite would remain undisturbed.
Source Area Alternative 7 uses landfarming to biodegrade organic
compounds; however, treatability studies would be needed to
determine the contaminant reduction and overall protection
provided.
Source Area Alternative 10 provides protection by containing
contaminated materials within a double-lined landfill equipped
with a cap. This containment action would remove risks to human
health from direct contact, ingestion, and inhalation and would
reduce the leaching of soil contaminants to ground water.
Source Area Alternative 3 provides protection by covering
contaminated materials beneath a synthetic membrane cap. This
containment action would remove risks to human health from direct
contact, ingestion, and inhalation and would reduce the leaching
of soil contaminants to ground water.
Source Area Alternative 2 provides protection by reducing
unrestricted access with a fence. The area within the fence
would be covered with soil to further reduce risk to human health
from direct contact, ingestion, and inhalation. The leaching of
soil contaminants to ground water would not be reduced.
*
Ground water Alternatives 1 and 2 would protect human health by
placing restrictions on well-drilling activities at the site.
The ACL determination associated with Alternative 2 would be used
because existing ground water contaminant levels are not
adversely affecting the Schuylkill River.
Source Area Alternative 1, no action, would not be protective of
human health and the environment.
Compliance with ARARs
All alternatives for the source areas and ground water, except no
action, would meet all applicable or relevant and appropriate
requirements (ARARs) of Federal and State environmental laws.
Long-Term Effectiveness and Permanence
*
Source Area Alternatives 4, 6, 8, and 11 would result in the
removal of all contaminants and risks to human health and the
environment associated with contaminated soils and treatment
residuals. Alternatives 4 and 8 utilize treatment prior to
hauling the wastes offSite for disposal. No long-term monitoring
or 0 & N would be required. The source of ground water
contamination would be removed.
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49
Source Area Alternatives 5 and 9 would remove most of the organic
contaminants from the soil. The ash (treated soil) generated by
the incinerator, however, would be contaminated with heavy metals
not destroyed by incineration. There may also be residual
contamination in the soil following extraction. The treated son
for'these alternatives would be used as backfill and would be
covered with a cap to protect against risks from direct contact,
ingestion, inhalation and leaching of residual soil contaminants
to ground water. A potential source of ground water
contamination would remain at the site, but the bulk of the
organic contamination would be removed. Long-term monitoring
would be used to evaluate the effectiveness of these remedies.
Ground water Alternatives 3 and 4 utilize treatment to
permanently reduce the concentrations of organic and inorganic
ground water contaminants.
Source Area Alternative 12 would treat the highest risk source
area at the site using onsite thermal treatment. The risks to
human health at the site (direct contact, ingestion, and
inhalation) are associated with surface contaminants. The only.
risk associated with subsurface soil is ground water
contamination. Ground water beneath the site is not used as a
source of drinking water, and there are no known adverse effects
from ground water discharges to the Schuylkill River. Covering
lesser-contaminated (lover risk) areas and the areas where
incinerator ash is used as backfill would remove any remaining
risks associated with surface soil contaminants and metals
remaining in the incinerator ash. Deed restrictions would
prevent future soil disturbance and use of ground water at the
site. Long-term monitoring would be used to monitor the
effectiveness of the remedy, because hazardous substances would
remain at the site.
Treatability studies vould be needed to determine the
effectiveness of Source Area Alternative 7. Source Area
Alternative 10 vould reduce long-term risks from human exposure
to contaminants by sealing contaminated soils in a veil-designed
and maintained RCRA landfill that vould prevent migration of
contaminants to the environment. A source of ground water
contamination vould remain at the site; hovever, it vould be
contained within the landfill. Long-term monitoring vould be
used to monitor the effectiveness of the remedy. The landfill
would be constructed above the 100-year flood elevation.
The soil cover and cap to be used for Source Area Alternatives 2
and 3, respectively, vould remove risks to human health and the
environment associated vith surface soil contamination. Fencing
vas included for Alternative 2 to restrict access and exposure to
the site. The source of ground vater contamination vould remain
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50
at the site. Long-term monitoring would be used to monitor the
effectiveness of these remedies. A 100-year flood could damage
the soil cover or cap, exposing the covered wastes.
Ground water Alternatives 1 and 2 would not be effective in
reducing ground water contaminant concentrations. ACLs under
Ground Water Alternative 2 would be established at current
contaminant levels because ground water discharges to the
SchuylJcill River do not adversely affect river-water quality.
Source Area Alternative 1, no action, would not reduce existing
or future risks to human health and the environment associated
with contaminated soils and waste at the site.
Reduction of Toxicity, Nobility, or Voluune
Source Area Alternatives 4, 5, and 6 involve thermal treatment
that would permanently destroy organic contaminants, but the
treated material would still be contaminated with less mobile
metals. Treated soil would be disposed onsite and covered with a
cap or disposed in an offsite landfill.
Source Area Alternative 12 would also involve thermal treatment,
but only the highest risJc source area would be treated. This
would permanently destroy organic contaminants, but the treated
material would still be contaminated with less mobile metals.
Thermally treated material would be backfilled and covered with
clean soil. If thermally treated material (ash) is shown to be
EP toxic, it would be solidified to reduce the mobility of metals
thereby reducing toxicity.
Ground water Alternatives 3 and 4 would involve treatment of
ground water to reduce toxicity by removing organic and inorganic
contaminants. The volume of contaminated ground water would also
be reduced.
Source Area Alternative 7 may reduce toxicity. Source Area
Alternatives 8 and 9 would reduce toxicity using extraction.
Treat ability studies would be required to determine the toxicity
reductions achievable by these alternatives.
Source Area Alternatives 1, 2, 3, 10, and 11 and Ground water
Alternatives 1 and 2 do not use treatment to reduce the toxicity,
mobility, or volume of the contaminants.
Short-Tent Effectiveness
source Area Alternative 12 uses a combination of thermal
treatment, soil cover, and vegetation that reduces the
possibility of direct contact, ingestion, inhalation, and erosion
of contaminants more quickly than all the other source area
alternatives, except for Source Area Alternatives 2 and 3.
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In Source Area Alternatives 4, 5, and 12, air pollution controls
vould be re
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.52
Ground water monitoring could be implemented using previously
installed wells if they are not destroyed during remediation of
tne source areas.
Ground water treatment alternatives should not be implemented
until the source areas are remediated. The wells and piping
required would interfere with source area remediation.
Costs
Estimated capital and annual 0 4 M costs for the 12 source area
alternatives are presented in Table 7.
Approximate present-worth costs for the ground water alternatives
are as follows:
o Alternative 1 (No Action with $417,000
Monitoring)
o Alternative 2 (ACL $150,000
Determination)
o Alternative 3 (Pumping and $15,608,000
Treatment-GAC)
p Alternative 4 (Pumping and $19,525,000
Treatment - Ozone/UV)
state Acceptance
The commonwealth of Pennsylvania concurs on the selected remedy.
Community Acceptance
Responses to public comments are addressed in the Responsiveness
Summary section of the ROD.
THE SELECTED R.
Section 121 of SARA and the National Contingency Plan (NCP)
establish a variety of retirements relating to the selection of
remedial actions under CERCLA. Having applied the current
evaluation criteria to the remedial alternatives, EPA recommends
that Source Area Alternative 12 and Ground Water Alternative 2 be
implemented at the Oouglassviiie Disposal Site. The selected
remedy combines selected aspects of the no action alternative,
the minimal action alternative, the ACL determination
alternative, and the onsite thermal treatment with onsite ash
disposal alternative. The major components of the selected
remedy include the following:
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53
TABLE 7
Estimated Capital and Annual O&M Cost for tne
Twelve Source Area Alternatives
(costs in tnousands of dollars)
Alternative Capital Q&M Source Areas
1. No Action 0 o all
2. Minimal Action 1,155 64 1,2,3,4,5,6 s, 9
w/fencing
3. Capping 6,500 113 1,2,3,4,5,6 & 9
4. Excavation, onsite 236,300 to 0 1,2,3,4,5,6 & 9
incineration, 331,200
offsite disposal
5. Excavation, onsite 157,100 to 89 1,2,3,4,5,6 & 9.
incineration, 246,100
onsite disposal
6. Excavation, offsite 565,000 0 1,2,3,4,5,6 & 9
incineration
7. Onsite Landfarming 5,700 117 3,6
8. Excavation, 223,000 to 0 1,2,4,5 & 9
extraction, offsite 339,000
disposal
9. Excavation, 127,000 to 77 1,2,4,5 & 9
extraction, onsite 213,000
disposal
10. Excavation and 36,900 290 1,2,3,4,5,6 & 9
onsite Landfilling
11. Excavation and 228,500 0 1,2,3,4,5,6 s, 9
offsite Landfilling
12. Excavation, thermal 39,280 to 0 • 1,2,3,4,5,6 & 9
treatment, minimal 53,619
action
* No annual O&M costs would be incurred. However, the 5-year
review would cost approximately $25,000 for water sampling and
analysis and would have a present worth of approximately $150,000
considering a 30-year review period.
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54
o Excavation and treatment, by onsite thermal treatment:
of approximately 48,400 cuSic yards of contaminated
soils and sludges from Source Area 2, and oily
sediments from the drainage ditch that runs from the
site to the Schuylkill River. The wetland area at
Source Area 5 would be left undisturbed to the extent
possible.
o Solidification of the treated materials (ash) if it is
EP toxic (hazardous).
o Disposal of treated materials by backfilling into
Source Area 2.
o Capping the backfilled area with topsoil followed by
and revegetation.
o Capping Source Areas 3, 6, and 9 with one foot of
topsoil followed by revegetation.
o Capping Source Areas 1, 4, and 5 with one foot of
compacted flyash followed by two feet of soil with
revegetation.
o Imposing deed restrictions to prevent soil disturbance
and well drilling on the property.
o Establishing ACLs for ground water at concentrations
that would not cause adverse effects on the Schuylkill
River.
When the source area restoration goals are attained, the excess
cancer risk would be approximately 1 x 10*6 or less from human
exposure to surface soil from direct contact, ingestion, and
inhalation. The ACLs are established at levels that would not
adversely affect human or environmental receptors associated with
the SchuylJcill River (aquatic life, downstream users of river
water, etc.). The ACLs established are the maximum
concentrations listed in Table 3 for the monitoring wells.
Because hazardous substances win remain onsite following
completion of the remedial activities, a review will be conducted
within five(5) years of tne initiation of remedial activities in
compliance with Section 121(c) of SARA. For tne purposes of the
review, the monitoring w«ils labeled as MW-1, MW-2, MW-4, MW-5,
MW-6, MW-7ft MW-8, MW-12, MW-13, MW-14, MW-16, MW-18, MW-19, and
ww-20 on Figure 2-3 of the October, 1988 RI/FS document win be
sampled as the points of compliance. Additionally, all of tne
home ground water wells which were sampled during those
investigations as well as the waters of the SchuylJcill River will
be sampled where practicalle, and those samples analyzed.
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STATUTORY DETERMINATIONS
Protection of Hunan Health and the Environment
The .selected remedy will provide protection of human health and
the environment by using treatment to remove organic contaminants
from the highest risk source area at the site. Residual metals
may require additional treatment to reduce risks to acceptable
levels. The backfilled area, along with source areas having
lesser degrees of risk, will be capped with soil or with flyash
followed by soil and revegetated to reduce risks to human health
from direct contact, ingestion, and inhalation. Source areas
that pose minimal or no risks to human health and the environment
will receive no action. Wetland areas onsite will remain
undisturbed. ACLs for ground water are established at levels
that would not cause adverse effects in the Schuylkill River.
Restrictions on soil disturbance and well drilling at the
property will further reduce any remaining risks to human health
and the environment by eliminating exposure to contaminated
ground water. The selected remedy will not pose any unacceptable
short-term risks or cross-media impacts.
Compliance with Applicable or Relevant and Appropriate
Requirements
The selected remedy will attain the following ARARs of Federal,
or more stringent, promulgated State environmental and public
health laws:
1. Clean Air Act requirements at 40 CFR 50, which define
National Ambient Air Quality Standards. (Applicable)
2. Pennsylvania Air Pollution Control Regulations at 25 PA
Code, Chapters 121 through 143, which adopt Federal air
quality standards plus set forth additional State
Standards. Also provides requirements for the control
and prevention of air pollutants. (Applicable)
3. RCRA closure at 40 CFR 264.310 which addresses the
requirements for closing a hazardous waste landfill.
(Relevant and Appropriate)
4. RCRA incinerator requirements at 40 CFR 264.340 et
seq., which address requirements for hazardous waste
#.incineration. (Relevant and Appropriate)
S. TSCA PCS disposal requirements at 40 CFR 761. which
address requirements for disposal and storage of PCBs
and PCS items. (Relevant t Appropriate) Thermal
treatment of non-liquid PCBs will comply with the
substantive requirements of 40 CFR 761.70(b).
(Applicable)
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56
6. RCRA land disposal restrictions at 40 CFR 268 vhicn
address disposal of hazardous waste. (Applicable only
if thermally treated residuals are found to be EP
Toxic. The statutory deadline for establishing land
disposal restrictions for characteristic RCRA hazardous
waste is May, 1990.)
7. OSHA requirements at 29 CFR, Parts 1904, 1910, and
1926, which provide occupational safety and health
requirements for workers engaged in onsite field
activities. (Applicable)
8. The Comprehensive Environmental Response, Compensation,
and Liability Act of 1980 (CERCLA) as amended by The
Superfund Amendments and Reauthorization Act of 1986
(SARA). (Applicable)
9. The National Oil and Hazardous Substances Pollution
Contingency Plan (NCP). (Applicable)
»
10. Impacts on the flood plain and the onsite wetlands will
be minimized in consideration of Executive Orders 11988
and 11990 and 40 CFR Part 6, Appendix A. (Applicable)
In addition, the following was evaluated as "To Be Considered"
(TBO-:
1. Carcinogenic potency factors were used to determine
incremental cancer risks for exposure to contaminated
surface soils.
Cost Effectiveness
The selected remedy is more cost effective than the other
alternatives evaluated. It would provide the same level of
protection as alternatives that involve treatment of the entire
volume of contaminated soil at the site at a significantly lower
cost. Table 8 is a tabulation of the costs specific to this
remedy.
utilization of Permanent solutions and Alternative Treatment
Technologies to the Maximum Extent Practicable
As stated^previously, the selected remedy is a combination of an
ACL determination for ground water, no action, minimal action
(soil cover and revegetation), and onsite thermal treatment
incineration/onsite disposal. The following discussion explains
why other alternatives were not selected and why partial
treatment is preferred to treating the entire depth and area of
soil contamination.
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57
TABLE 8
Capital Cost Estimate
Onsite Thermal Treatment, Onsite Ash Disposal
Source Area #2
(Ash Non-Hazardous)
l - Excavate Contaminated materials 3112,700
2 - Hauling 92,904
3 - Mobilization/Demobilization 500,000
4 - Trial Burn 300,000
5 - Closure Testing 50,000
6 - Thermal Treatment 19,845,000
7 - Ash Hauling 92,904
8 - Backfill Ash 129,948
9 - Place, Spread & Compact Ash 131,124
*
10 - Topsoil (24") 104,200
11 - Place & Spread Topsoil 7,752
12 - Revegetation 3 .na
Subtotal Direct Cost (A) $21,369,650
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58
TABLE 8
(cone *d)
Capital Cost Estimate
12" Compacted Flyash; Two Feet Soil
Source Areas 1,4, and 5
l - Flyash Hauling $ 40,200
2 - Place, Spread, and Compact Flyasn 59,496
3 - 24" Soil 429,380
4 - Place and Spread Soil 31,944
5 - Revegetation 12 .474
Subtotal Direct Cost(B) $573,494
Capital Cost Estimate
12" Topsoil and Revegetation
Source Areas 3,6, and 9
1 - 12" Topsoil $247,273
2 - Place and Spread Soil 18,396
3 - Revegetation 14.380
Subtotal Direct Cost(C) $280,049
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59
TABLE 8
(cont»d)
Total Capital Cost Estimate
EPA's Preferred Alternative
(Ash Non-Hazardous *)
Subtotal (A) $21,369,650
Subtotal (B) 573,494
Subtotal (C) 280,049
Use of Level B protection 154,203
Burden g 13% of Labor Costs 59,421
Labor @ 15% of Labor Costs 68,563
Subcontracting @ 10% of Subcontracting 2.073 .520
Total Direct Cost 24,578,900
•
Indirects $ 75% of Labor TDC 342,815
Profit @ 10% Of TDC 2.457 .890
Subtotal 30,459,605
Health and Safety e 4% i .2ia.3as
Total Field Cost 31,677,990
Contingency € 20% of TTC 6,335,560
Engineering C 4% of TFC 1.267.120
Total Capital Cost $39,280,670
* If the ash is hazardous, it will be solidified thereby adding
approximately $14,339,000 to the Total Capital Cost. This would
bring the Total Capital Cost to $53,619,000.
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60
No Action is selected for only Source Areas 7, 8, and 10. Based
on available data, soil contamination, and therefore, risk, at
Source Areas 7 and 8 is below health-based levels. Source'Area
10 contains a wooded wetland which win not be disturbed. Ground
water beneath the site is polluted with site-related
contaminants; however, as stated previously, ground water
contaminant discharge to the Schuyikill River is insignificant
and immeasurable in the river itself. Deed restrictions would be
imposed to prevent future well drilling at the site.
Soil cover and revegetation is selected only for three lesser
contaminated areas, Source Areas 3, 6, and 9, which do not have
high levels of oil and grease. There are concerns about the
upward movement of oily material into clean cover materials by a
process called capillary action. This process occurred in the
former lagoon areas, Source Areas 4 and 5, which were flooded out
in the past and backfilled. The backfill material subsequently
was contaminated by the upward movement of oil. Under the
preferred remedy for Source Areas l, 4 and 5, the upward movement
of oil win be retarded by the application- of a one-foot layer of
compacted flyash followed by a two-foot layer of soil. Coveri$g
and revegetating the contaminated areas win reduce risks to
human health and the environment by preventing direct contact,
inhalation, ingestion, and erosion. The reduction of
infiltration is not an important concern, since it has been shown
that Reaching of contaminants to ground water has an
insignificant effect on the quality of river water. Deed
restrictions that prevent soil disturbance on the site will be
implemented to prevent damage to the soil cover.
Capping, as described for Source Area Alternative 3, would reduce
the same risks as a soil cover with vegetation (minimal action)
and would reduce infiltration and leaching of soil contaminants
to ground water. As stated previously, however, reduction of
infiltration is not an important concern. Therefore, capping, as
described for Source Area Alternative 3, is not selected because
it has the same effectiveness as a soil cover with vegetation,
but a higher initial cost and much higher costs for 0 & M.
Excavation, Onsite Incineration, and Offsite Disposal would be
effective in mitigating risfcs at the site, but would require
shipping the treated material to an offsite facility for
disposal. This alternative is more costly than onsite
incineration with onsite disposal but does not afford a
significantly higher degree of protection to human health and the
environment.
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61
Similarly, Excavation and Offsite Incineration would be
effective, but extremely costly, and would not offer a
significantly higher degree of protection.
Excavation, Onsite Incineration and Onsite Disposal is preferred
for'-the area of the site that poses the highest risks, i.e.,
Source Area 2, which has a relatively high oil content. The
backfilled ash will act as a medium, or buffer zone, to restrict
the upward migration of oil into the clean surface soil layer
from the contaminated soil below the ash. Excavation of the
entire depth of contamination would not achieve a greater
reduction of risks than would the proposed partial excavation.
The primary concerns (direct contact, ingestion, inhalation, and
erosion) are all associated with surface contamination. The
deeper soils probably contribute to ground water contamination,
but as previously stated, it has been shown that leaching of
contaminants to ground water has no effect on the river water
quality. Deed restrictions that prevent soil disturbance at the
site will be implemented to prevent damage to the soil cover or
backfilled ash.
Onsite Landfarming is applicable only to areas of the site that*
pose lesser risks to human health and the environment. It could
take a very long time to achieve the desired reduction of
contaminants. Source Areas 3 and 6 can be remediated using a
method with proven effectiveness (soil cover and revegetation) at
a lower cost.
Excavation and Onsite Extraction with Onsite or Offsite Disposal
is not selected because onsite thermal treatment would be equally
or more effective than extraction but at a lower cost.
Excavation and Onsite Landfill Disposal would be effective in
mitigating site-related risks. However, most of the site is
within the 100-year flood plain of the Schuylkill River;
therefore, tne landfill would have to be constructed within the
flood plain. This action could adversely affect the flood plain
by reducing the flood water storage capacity provided by the
flood plain. This could cause increased water velocities and
higher water levels in Offsite areas during a flood. Also,
landfilling alone does not meet the SARA mandated preference for
permanent solutions.
Excavation and Offsite Landfill Disposal would be effective, but
costly. This alternative does not meet EPA's preference of using
treatment *to reduce waste toxicity, mobility, or volume.
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62
Preference for Treatment as a Principa! EleBent
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RESPONSIVENESS SUMMARY
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Responsiveness Summary
Douglassvilie Disposal site
in compliance with Sections 113 (Jc) ( 2) (i-v) and 117 of SARA
the Administrative Record, including the Proposed Remedial Action
Plan'-, vas placed for public viewing at the Union Township
Building, Center Road, Union Township, Pennsylvania. An
announcement of the availability of the Administrative Record,
was placed in the Pottstown Mercury on May 24, 1989. The
Administrative Record included the Phase II RI/FS Report which
listed the alternatives developed as part of the Feasibility
study.
A period for public review and comment on the Proposed
Remedial Action Plan was held from May 25, 1989, to June 26,
1989. During that comment period, the Berks Associates Steering
Committee requested a one-month extension of the public comment
period. That request was denied and the Steering Committee was
notified of the denial both by telephone through EPA's case
attorney, and by letter from the Chief of the EPA Region III
Superfund Branch.
On June 26, 1989, EPA Region III received comments on behalf
of the Berks Associates Steering Committee/Administrative Fund
Participants. The comments addressed EPA's Proposed Remedial
Action Plan and were prepared for the Steering Committee by BCM
Engineers of Plymouth Meeting, Pennsylvania. In those comments,
BCM expressed its agreement with EPA's remediation scenarios
presented in the Proposed Plan for Source Areas 1,3,4,5,6,7,8,9,
and 10 and for onsite ground water. BCM does not agree that
there is sufficient difference between Source Area 2 and the
other Source Areas in concentration of the contaminants, exposure
pathways or risk to human health to justify a separate remedial
approach for Source Area 2. BCM expressed its opinion that
capping of Source Area 2 would provide the necessary protection
of human health and the environment, and presented a "Critique of
Detailed Analysis of Alternatives" in which it (BCM) compared the
capping alternative described as Remedial Alternative 1-3 in
Section 10 of the October, 1988 RI/FS with the excavation, onsite
thermal treatment, and onsite disposal alternative described as
Remedial Alternative 1-5 in Section 10 of the October, 1988
RI/FS. For the purposes of its critique, BCM used the nine
evaluation criteria which were used in the Phase II RI/FS
document to compare alternatives. A summary of this Critique and
EPA's responses follows:
Comment: In its discussion of the "Short-Term
Effectiveness" evaluation criterion, BCM agrees
that the capping scenario presented in Remedial
Alternative 1-3 would adequately address possible
short-term effects. BCM claims, however, that
protection of the community and site workers
-------
during remedial activities under Remedial
Alternative 1-5 has not been adequately addressed
in the RI/FS document.
Response: Excavation, onsite thermal treatment, and onsite
disposal activities as proposed by EPA are
commonly used methodologies in hazardous waste
remediation and can be conducted without
endangerment to the. community. The various
controls retired such as dust control, runoff
control and stack emissions control would be
adequately implemented using currently available
and proved technologies. Onsite worker safety
would conform to OSHA standards for hazardous
waste workers. The types and degrees of pollutant
controls, and the exact requirements for worker
safety would be fully addressed during the design
phase of the project prior to implementation of
any remedial action. It is important to emphasize
that the RI/FS document presents remedial concepts
and is not intended to tie used as a remedial
design document.
»
Comment: In its discussion of "Long-Term Effectiveness,"
BCM agrees that thermal treatment will
irreversibly eliminate a source of risk but notes
that solidification of the thermally-treated
materials might be necessary to reduce the
toxicity of heavy metals. BCM expresses the
opinion that the capping alternative will provide
effective long-term protection if proper
maintenance is provided to insure that the cap
remains intact.
Response: One of EPA's primary goals in the selection of
remedial alternatives is to substantially reduce,
or to eliminate totally, ttte uncertainties
inherent to any remediation which might involve
perpetual operation and maintenance (O&M) costs
and activities. EPA's proposed alternative for
Source Area 2 would eliminate the otM entirely and
would, along with the remedies proposed for the
other Source Areas, leave tne site in a condition
which would require only the 5-year review
monitoring as mandated by Section 121(c) of SARA.
* SARA mandates that remedial actions utilize
permanent solutions and alternate treatment
technologies or resource recovery technologies to
the maximum extent practicable. EPA believes that
the thermal treatment of Source Area 2 is
practicable and that capping does not fulfill the
statutory preference expressed in Section
I2l(b)(l) of SARA.
-------
Comment: In its discussion regarding "Reduction In
Toxicity, Mobility, or Volume," BCM indicates that
the reduction of organics in Source Area 2 by
thermal treatment would increase the concentration
of heavy metals in the treated material.
Response: If the concentrations of heavy metals in the
treated material should result in that material
being categorized as EP Toxic, and, therefore, a
characteristic hazardous waste under RCRA, the
treated material would be solidified prior to
disposal into Source Area 2. Solidification has
been demonstrated to be an effective treatment
method to prevent the leaching of metals.
Comments: In its discussion regarding "Implementability",
BCM agrees that both capping and thermal treatment
technologies are demonstrated and commercially
available technologies.
Response: The filter cake material of which Source Area 2 is
comprised is a highly plastic, highly credible, "
concentrated source of contamination that presents
the highest risk of the ten Source Areas
identified for the purposes of the Phase II RI/FS.
The existing material and berms might not support
the heavy equipment required for the construction
of a cap.
Comment: In its discussion of "Cost-Effectiveness," BCM
contends that the levels of human health and
environmental protection achieved through capping
and through thermal treatment are similar,
therefore the cost differential involved is not
justified.
Response: EPA does not agree that a similar level of
protectiveness will be achieved by capping source
Area 2. This Source Area presents the greatest
endangennent of all the Source Areas and this
endangerment would be essentially eliminated
through the thermal treatment process. In
contrast, the wastes which comprise this area
would remain onsite should the capping alternative
be implemented. The capping, as discussed in
* EPA's responses above, would require presently
unknown design considerations and would, if
implemented, result in perpetual O&M expenditures
and a potential for release of contaminants from
failure of the cap.
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When evaluating alternatives for the remediation
of the remainder of the site, it vas evident that
great costs would be incurred if treatment of the
other Source Areas were implemented. The filter
cake sludge material (Source Area 2) is well-
suited to thermal treatment.
Comment: In its discussion regarding "Compliance with
ARARs," BCM expresses its concern that standards
that would apply to heavy metal and organic
chemical emissions are not clearly stated for the
thermal treatment alternative in the RI/FS
document.
Response: Thermal treatment onsite would comply with Clean
Air Act requirements at 40 CFR 50 which define
National Ambient Air Quality Standa.-ds; and with
Pennsylvania Air Pollution Control Regulations at
25 PA Code, Chapters 121 through 143 which adopt
Federal air quality standards and set forth
additional State air quality standards. The
thermal treatment unit and the thermal treatment .
process would comply with RCRA incinerator
requirements at 40 CFR 264.340 which address
hazardous waste incineration; and with the TOSCA
requirements regarding the thermal treatment of
non-liquid PCB materials at 40 CFR 761.70(b). In
addition, onsite workers would be safeguarded per
the requirements of OSHA as found at 29 CFR Parts
1904, 1910, and 1926 which provide occupational
safety and health requirements for workers engaged
in hazardous waste field activities. These
requirements would be incorporated into the design
of the thermal treatment process and would assure
that the process does not pose an endangerment to
human health or the environment.
Comment: In its discussion regarding "Overall Protection of
Hunan Health and the Environment," BCM contends
that the discussion in the October 1988 RI/FS
document regarding the thermal treatment of Source
Area 2 does not adequately address the potential
short and long-term risks associated with the
possible release of airborne contaminants during
the thermal treatment process or possible
* increases in toxicity of the thermally-treated
material.
Response: As has been expressed in EPA's response to BCM's
comment regarding "Compliance with ARARs" above,
all required and necessary standards and
precautions would be implemented to assure that
the thermal treatment process would not pose an
-------
endangerment to human health or to the environmen-
because of the potential release of air&orne
contaminants. Also, in the event that the treated
material would be EP Toxic for heavy metals, it
would be solidified prior to disposal into Source
Area 2.
Comment: In its discussion regarding "State and Community
Acceptance," BCM expresses its opinion that it is
possible that the area residents and the community
would have a stronger adverse reaction to thermal
treatment than to the capping of Source Area 2.
Response: The Commonwealth of Pennsylvania has expressed its
agreement with the proposed remedial action. No
response to EPA's Proposed Remedial Action Plan
has been offered by the area residents nor by the
local governments. In addition, after review of
the BCM comments, DER restated its concurrence
with EPA regarding thermal treatment of the waste.
»
Comments: In its "Summary" regarding the above Comments, BCM
restates its contention that Source Area 2 can be
adequately remediated with a synthetic cap and
vegetative cover.
Response: EPA believes that the thermal treatment of Source
Area 2 is the alternative that offers the highest
degree of protectiveness to human health and to
the environment and that it is a cost-effective
means to achieve that protectiveness. The
implementation of thermal treatment, as proposed,
would essentially eliminate tne necessity for
perpetual operation and maintenance expenditures.
The technologies required to safely implement the
thermal treatment are demonstrated and
commercially available. Also, the implementation
of thermal treatment would satisfy the statutory
preference expressed in SARA for remedial actions
that use alternative technologies or resource
recovery to the maximum extent practicable, and .
for permanent solutions for cleanups of hazardous
substances.
On Thursday, June 29, 1989, representatives of EPA Region
III met with members of the Berks Associates Steering Committee
and discussed the Comments presented by BCM Engineers on behalf
of the Steering Committee.
No other comments were received by EPA Region III regarding
EPA's Proposed Remedial Action Plan.
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LETTER OF CONCURRENCE
-------
Deputy Secretary for
Environment*! Protection
COMMONWEALTH Of PENNSYLVANIA
DEPARTMENT OF ENVIRONMENTAL RESOURCES
Pott Office toi 2063
Herrieburg, Penneylvenie 17120
June 29, 1989
717-787-5028
Mr, Edwin B. Irickson
Regional Administrator
OSBPA Region III
841 Chestnut Building
Philadelphia, PA 19107
Re i Letter of Concurrence
Douglassville Disposal Site, drift Record of Decision (ROD)
Deer Mr. Brickaoni
The dreft Record of Decision (dated June IS, 1989) for
the final action tddreesing the remediation of the on-site
•ludgee and contaminated toils haa been reviewed by the
Department, it ie ay understanding that this Record of Decision
will be submitted to you for your approval.
includet
ial action
The major components of the selected
Excavation and treatment, by oasite thermal
of approximately 48,400 cubic yards of contaminated
soils and sludges from Source Area 2 and oily sediment
from the drainage ditch that runs from Source Area 9 to
the Schuylkill River.
Disposal of thermally treated materials by backfilling
into the Source Area 2.
Covering the backfilled area with viable soil and
followed by revegetation.
Covering Source Areas 1, 4, and S with one foot of
flyash and two feet of soil followed by revegetation.
Covering Source Areas 3, 6, and 9 (approximately 10
acres) with viable soil followed by revegetation.
Imposing deed restrictions to prevent soil disturbance
and well drilling on the property.
-------
Mr. Edwin B. Srickson - 2 - June 29, 1989
I h«r«by concur with the BPA's proposed remedy, with
the following conditional
*
• The Department viewt the remedy selection by IPA in
this matter to be an exercise of its authority to
preserve funds available to it under CSftCLA and not to
establish limitations of legal liability for any
responsible party.
We assume the actions associated with this remedy will
include testing of the residual from the thermal
treatment process and associated controls for
appropriate disposal in accordance with DIR ARAR*.
The Department assumes that 1PA, pursuant to section
121 (c) will at least every 5 years review the need to
take future enforcement actions or remedial actions at
the site. Selection of the remedy in no way limits
BPA's or the Department's right to require any
responsible party to take action to adequately protect
•public health or the environment.
SPA will assure that the Department is provided an
opportunity to fully participate in any negotiations
with responsible parties.
The Department will be given the opportunity to concur
with decisions related to the design of the remedial
action, to assure compliance with DO design specific
ARARs.
The Department's position is that ita design standards
are ARAR* pursuant to SARA Section 121, and we will
reserve our right to enforce those design standards.
The) Department will reserve our right and
responsibility to take independent enforcement actions
pursuant to state and federal lav.
Thia concurrence with the selected remedial action ia
not intended to provide any assurances pursuant to SARA
Section 104(c)(3).
-------
Mr. Edwin B. Irickaon
- 3 -
June 29, 1989
ThanJc you for the opportunity to concur with chia EPA
draft Record Of Decision. If you have any queationa regarding
rhia natter pleaae do not heaitate to contact me.
Sincerely
Deputy Secretary
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APPENDIX A
SUMMARY OF MCLs AND MCLC«
-------
DRINKING WATER STANDARDS
AND HEALTH ADVISORIES
QUICK LOOK LIST
December. 1988
'Source: EPA. Office of Drinking Woter
Contact: EPA. Region III. Drinking Woter Section
(215)597-3427 for further information
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ADMINISTRATIVE RECORD INDEX
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DOUCLASSVILLE DISPOSAL SITE - PHASE I*
ADMINISTRATIVE RfCORD** ••*—
ISDP OF DOCUMENTS '
SITS IDE.VTIFICATIOH
Noelfleatlon/Sice Discovery
1) Potential Hazardous tfa*ta Slta Idantlfic*cton, 10/21/80. P. l-l.
2) Verification of Hazardous V«ate Sitt, 6/81. P. 2-2.
Prcliainary Asaeaament/Site Investigation Reports
1) Potential Hazardous tfaate Sice Identification and Preliminary Assessment
9/9/81. P. 1-5.
2) Poctneial Hazardous tfaata Sic* Identification and Preliminary Assessment
3/5/82. P. 6-12.
3) Potential Hazardous Waaca Site Identification end Preliminary Assessment.
5/6/82. P. 13-22.
e»
4) Report: A Site Inspection of Berke Aaaociatee. prepared under TDD Ho.
F3-8303-02. prepared 67 Mr. David A. Mickeraon and Mr. Joaeph C.
Ecolofjr and Environment, Inc., 8/3/82. P. 23-118.
5) Report: field Trip Suamary Report (no author cited), (undated). P. 119-121
Correspondence
1) Letter to Mr. Michael Steiner, Pennsylvania Department of Environaental
Resources, frosj Ms. tathryn Hodfkise, O.S. EPA, ret transsiittal of the
Site Inspection Report for the Berk* Associates Site, 8/15/83. P. l-l.
2) Letter to Mr. Bruce Beitler, Pennsylvania Oepertvent of Environmental
Resources, from (to. KAChryn Hodfkias, U.S. EPA, re: transmittal of the
Site Inspection Report for the Berk* Assoclatee Site, 8/15/83. P. 2-2.
* For further documentation on chit site, pleece refer to the Ptuee II
administrative record.
** Administrative record available 3/21/88, updated 4/5/88.
*•• Supporting Sampllot Deta it stored at the Ufiom III Centrel Regional
Laboratory in Aanapolii, Maryland.
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REMEDIAL EHfORCEMENT PLANNING
Potentially Responsible Party" Search Correspondence
I) L«ccer co Mr. R. L. Noland, Aatcek, Inc., from Mr. Stephen R. V*ssersug,
._ C.S. EPA, re: I04(e) information request, 9/19/85. P. 1-3.
2) L«c:er co Mr. Vtlttr Williams, Bethlehem Steel Corporation, from Mr. Seephen
R. Vassersug, U.S. EPA, re: I04(e) information request, 9/19/85. p. 4-6.
3) Leeeer co Mr. Al Clmino from Mr. Seephen R. Wassersuf, U.S. EPA, re: L04(e)
information request, 9/19/85. P. 7-9.
M Letter to Mr. William Cox, City Waste Oil Service, from Mr. Stephen R.
Vassersuf. U.S. EPA, re: 104(e) information request, 9/19/83. P. 10-12.
5) Letter to Mr. Cl«m«ne A. Revelti, Dana Corporation, from Mr. Seephen R.
Vassersuf, U.S. EPA, re: I04(e) information request, 9/19/8S. p. 13-15.
6) Leeter eo Ms. Lorraine Sxyman, J4L Industries, Inc., fro* Mr. Stephen t.
Vassersuf, U.S. EPA, re: 104(e) information request, 9/19/8S. P. 16-18.
e»
7) Letter to Mr. V. R. Grlftbr, from Mr. Stephen t. tfacearsuf, U.S. EPA,
re: 104 (e) information rcquot, 9/19/8S. t. ls-21.
8) Leeeer eo Mr. A. S. Huechcraft, Jr., Kaiser Altamlnum « Chemical Corporation,
from Mr. Stephen R. Vaaaersuf, U.S. EPA, re: 104(e) infonueion request.
9/19/85. P. 22-24.
9) Leteer to Mr. John Laval* from Mr. Seephen t. Vassersuf, O.S. EPA, re:
106(e) Information request, 9/19/83. P. 23-27.
10) Leeeer eo Mr. Joseph Lorens fro* Mr. Seephen t. tfassersug, U.S. EPA, re:
104(e) information request, 9/19/83. P. 28-30.
11) Leeeer eo Mr. tf. V. Wilson, Lukeu, Inc., fro» Mr. Seephen t. Ucssersuf,
U.S. EPA, re: 104(e) information request, 9/19/83. P. 31-33.
12) Leeter co Mr. Joh» I. Carcio, M«ek Trucks, Inc., fresi Mr. Seephen t.
Vasserstaj, O.S. IFA. r«: 104(•) informaeioti rtqumct, 9/19/83. P. 34-36.
13) Leee«r e« Mr* I. N. Ret* from Mr. Seophoa t. tf«o«or«uf. O.S. WA, re:
104(o) imformmelos roqu«se, 9/19/83. P. 37-39.
14) Letter eo Mr. VilllM SchlaTanl from Mr. Stephen t. Vassersuf, O.S. EPA.
re: 104(o) laform«tioo request, 9/19/8S. P. 40-42.
IS) Lector eo Mr. Uonard Tofuncxn from Mr. Seephoo t. Vassorsug. O.S. EPA,
re: 104(o) laforaacloa roquaae, 9/19/8S. P. 43-45.
16) Loccor co Mr. ThoaM Lewis, Total tocovory, Zae.. from Mr. Stoahaa 1.
Vassersuf, U.S. EPA, rat 104(o) iafocvatloa raquaac, 9/19/83. P. 46-48.
17) Lottor to Mr. Kevin Ooaalgaa, Thomas 4 taeta Carforatloa. from Mr.
Seophoa t. Vassersu«, O.S. CPA, ro: I0*(o) iaformatioa re^uese, 9/19/83
P. 49-31.
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18) Letter co-Mr. James w. Yerger from Mr. Stephen R. Vassersug u s EPA
r«: 10*(e) Information request, 9/19/85. P. 52-54. '
L9) Letter to Mr. Lee Welter from Mr. Stephen R. Wassersug, U.S. EPA, re:
Information request, 9/19/85. P. 55-57.
:0): Letter to Mr. James H. McNeil, The Sudd Company, from Mr. Stephen R.
Vassersug, L'.S. EPA, re: I04(e) information request, 10/11/85. P. 58-60.
21) Letter to Mr. Denial Davall, Midland Roes Corporation, fro* Mr.
Stephen R. Vassarsuf, 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. Weasersuf, U.S. EPA, re: 10* (e) Information request, 10/11/85.
P. 64-66.
23) Letter to Mr. Paul R. tflklnson, E. I. OuFone de Nesiours, fro* Mr. Stephen
R. Vasaersuf, U.S. EPA, re: 10*(e) Information request, 11/13/85.
P. 67-69.
24) Leecer eo Mr. John R. Welch, Jr., General Electric Company, frosi Mr.
Stephen R. Wasearsuf, U.S. EPA, re: 104 (e) infonucion requeee, 11/13/85.
P. 70-72.
25) Letter co Mr. Prank Uabriac, Ha*lecon Oil Salra««, freej Mr. Stephen R.
v«ssersuf, U.S. EPA, re: 104 (e) information request, 11/13/85.
P.. 73-75.
26) Letter to Mr. Stanley Pace, TtW Inc., fro* Mr. Stephen R. Vaaearsuf,
U.S. EPA, rt: 104 (e) information request, 11/13/85. P. 76-78.
27) Letter eo Mr. Joseph Moons?, Monser Products Cosjpaay, frosj Mr.
Stephen R. Wassersuf, U.S. EPA, re: 104(e) informaeion request, 11/13/85.
P. 79-81. .
24) Latter to Mr. B«nurd Jafft, Sun Cheaieal Corporation, frosj Mr. Stephen
R. Wassersuf, U.S. EPA, rt: 10* (e) information rtquMt, (undated).
P. 82-8*.
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REMEDIAL RISPOHSE PUfWIMC
Work Plana
1) Report: Reaedial Action Master Plan. Douglassville Disposal Sice. L'nion
Township, Berks County. Pennsylvania, prepared bv VUS Carporjgian n/
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5) Letter Co M«. jujy Dorstv r s FP» f
"
: »: r «-
,.ltet
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Record of D«ci«ioo/gnforee«ent Decision Document (ROD/EDO)
1) Letter to Mr. Thomas C. Voltaggio, U.S. EPA, from Mr. Dvlght D. tforley,
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.
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COMMUNITY IHVOLVEMENT
Coaaunlty Relations Plan
1) Report: Community Relations PUn for Douglassville Disposal Site. Union
Tovmship. Berks County. Pennsylvania, prejpared by SUS Corporation 12/84
P. J.-23.
Fact Sheets. Press Releases. Public Sotiees
1) Press Release from U.S. EPA Environmental News entitled "EPA Schedules
Public Meeting for Douglassville Superfund Site," 6/21/85. P. l-l.
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. Correspondsnca with Public
1) Memorandum to Mr. D. R. Breanemaa from Mr. t. E. Staclk ra: public maattaf
notss, 3/28/84. P. 1-2.
2) Agenda of a public meeting, 7/10/83. P. 3-3.
laterafcency Masting Notes. Cenarsl Correspondence
1) Letter to Mr. Donald Gutekunst, Onion Township Supervisors, from Mr.
William A. Hagel, O.S. EPA, re: public review of the draft Work Plan for
Remedial Investigation/Feasibility Study for the Douglassville Disposal
Site, 3/19/84. P. l-i.
2) Memorandum to Mr. Thomas C. Voltaajio, U.S. EPA, fro* Mr. William Ragel,
U.S. EPA, re: public aeetiog on the Douglassville Disposal Site, 4/1/84.
P. 2-2.
3) Letter to Mr. William A. Hagel, O.S. EPA, from Mr. Davis L. Allabach, Jr.,
Revnler, Crocker, Allabach 6 tabar, P. C., ra: well vatar testing In the
area of the 8*rka Associates property. 6/22/84. p. 3-3.
4) Letter Cm Mr. Leatar Schurr, Berks Asaociates, Incorporated, from Mr.
William A. lagel, O.S. EPA, ra: sampling and drilling at the Barks
Assoeiataa property, 6/27/84. P. 4-4.
3) Letter*co Mr. David L. Allabach, Jr., Urnier, Crocker, Allebach 4 taber,
P. C., from Mr. William A. Hagel, O.S. EPA. ra: EPA's activities at the
Berks Assoeiataa Sita la Douglassville, Psnaaylvanis, 7/2/14. P. 3-5.
6) Laeear to Mr. Donnall Marshall. Laursl Locks Psrms), from Mr. tichard L.
Zambito, P. E., O.S. EPA, ra: iostsllinf a smieorlns wall on the
prepare? diracely adjacane to tha Barka Assoclstss, 8/22/84. P. 6-6.
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7) Handwritten l.tt.r co Ms. Manet Sinclair, U.S. EPA
public —tin, at eh. Oou,U..vili. Sup.rfund Siel.'
3) i.ec.r to Mrs. Pac Hobbs from Mr. Bruce P. Smith u s EPA r
of ch« B«rks Assoclaces SUt, 3/12/86. P. 8-9. ' scacu»
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GENERAL GUIDANCE DOCUMENTS •
i) ;?ramulgation of Site* from Updates 1-4,- Federal Rentacar, dattd 6/10/86.
2) 'Proposal of update 4," Federal Ragiatar. datad 9/18/85.
3) Mcaorandua eo (7. S. EPA from Mr. Gene Lucero regarding community relations
at Superfund Enforceaent sites, dated 8/28/8S.
4) Groundvater Contamination and Protection, undated by Mr. Donald V.
Feliciano on 8/28/85.
S) Memorandum to Toxic Waste Management Division Directors Regions I-X fro*
Mr. William Hedeaan and Mr. Gene Lucero re: Policy on Ploodplains and
Wetlanda Aaaessaenta for CZRCLA Actlone, 8/6/8S.
6) Guidance of Reaedial Inveatljationa under CZ1CLA. dated 6/05.
7) Guidance oa Feasibility Studiee under CEtCLA. dated 6/8S.
MMMHMM^M^MMMMMMHMWWMMiM«^M^HMn^M^M^M«M^BM«MMMMHaM^l^BM^HMMM» ^
8) "Proposal of Update 3," Ftderal Retl«ter. dated 4/10/85.
9) Meaorandiai to Mr. Jack McGrav entitled "Coaewnity Ulatioae Aetivitee
at Superfund Sltee - Interim Guidance," dated 3/22/83.
10) -Propoaal of Update 2," Federal latHter. dated 10/13/84
11) gPA Croundvater Protection Strategy, dated 9/*«i.
12) MeaorandiM to U.S. EPA fro* Mr. Vllliaa Heekaan, Jr. entitled
"Tranaaittal at Suparfund leaoval Procedurea - tatriaioa 2," dated 8/20/84.
13) ~Propoaal of Opdate 1." fedaral taglatar. dated 9/8/83.
14) Coammity telatiooa in Soperfund; A Handbook (lataria version), dated
9/83.
IS) -Propoaal of first fational Priority Use," Federal Utistar. datad
12/30/82.
16) 'Expanded lllflbility List,* Federal tatlater. datsd 7/23/82.
17) -lotarla Prlorltias List,' Federal tagieter. datad 10/23/81.
*
18) Uneontrollad Haxardoua Waete Sits Unking Systaat 4 Pssr's Manual
(undated).
19) Piald Standard Ooorstina Procedurea • Air Sunroillango (oadated).
20) Field Standard Oporatina Proceduree • Sits Safaty Plan (undated).
* Located in EPA lagioa ill offies.
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lvJLCJLABi\. :-L3 -S
.--=.'.5
. > report Final fccrk Plan. Phass II Rstnsdial Investigation/Feasibility Study,
Icugias&vUie Disposal" Sit*. osrks County. Pennsylvania, prepared ty SLS —
Lcrpcraticr.. b/o7. P." 1-183. fi«f«rences arc Ust.«d on P. 147-146.
i) Letter tc >ar. Vic JarvcsiX, U.S. EPA, from Mr. Richard C. Evan*. P. £.,
i-oASCO bervices Ir.oorporatad, r« Couglassvillc Disposal Sits - Phass II
Rtrvoial Investigauon/FsasiJaility Study Anfcndmsnt to Final Work Plan,
fa/ 24/87 P. 184-185
j ) Rfeoort Final Fisld Ctasrations Plan (FOP), Phass II Rsrosdial Investigation/
/tS,
par
on P.
tfe&3ibilit> atudy, RL/tS, DTK KJ! a ssvills Disposal Sits, Urxicrt Township,
Pennsylvania, prsparsd by MJS Corporation, 10/87. P. 186-348. Rsf
t) Import Anandmsnt 1 to Final Fisld Ctasrations Plan (FOP), Phass II
Ksmsdial lnvsstacatj.on/Fsasxbility Study/ DnurTlassvills Disposal Sits
Union Township, Pennsylvania, prsparsd by NUS Cbrporation, 11/87. p7
5) R«|x>rt. Craft Work Plan. Phass II RsrasdUl Invsatigation/Fsasibility
study, Couglafcsvills Disposal Si>s. Bsrks County, Psnnsylvyua, prsparsd
c> t-bASOD s*rvicss Iiioorporatsd, 6/17/87. P. 371-555. Bsfsrsncss ars liatsd
en P. 5^-529.
o) Report. Hydrogsologic Invsatigation, Douglassvills Disposal [Sits],
£.rbf*rsd by Nt6 Corporation, 2/29/88. P. 556-601" Rafsrsncss ars listsd
ui P. 566-567.
7) report.. Fisld Trip Rscort for Doinlassvins Disposal Sits, prsparsd by
:.t* rrin% baopling Cat* U «tor«d at th« Rsgion 111 Gantrml Baglcnal
Labcratury.
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CENTRAL GUIDANCE DOCLMENT5 •
;; "Prooilgation 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 fron Mr. Gene Lucero regarding community relations
at Superfund Enforcement sites, dated 8/28/85.
4) Qroundvater 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 Ploodplains and
Wetlands Assessments for CERCLA Actions, 8/6/85.
6). Guidance on Remedial Investigations under COCA, dated 6/85.
7) Guidance on Feasibility Studiee under CPCLA, dated 6/85.
8) 'Proposal of Update 3," Federal Register, dated VI0/85.
9) Memorandum to Mr. Jack McGraw entitled •Ccaemjnity Relations Activitaa
at Superfund Sitea - Interim Guidance,' dated 3/22/85.
10) 'Proposal of Update 2,* Federal Regiatar, datad 10/15/84
11) EPA Qroundvater Protection Strategy, dated 9/84.
12) Memorandum to U.S. EPA from Mr. William Hecknan, Jr. entitled
"Transmittal at Superfund Removal Procedures - Raviaion 2,* dated 8/20/84.
13) 'Proposal of Updata 1,' Federal Register, datad 9/9/93.
14) Community Relations in Superfundt A Handbook (interim version), datad
15) 'Proposal of First National Priority List," Federal Regiatar, dated
12/30/B.
16) 'Expanded fUoibility List," Federal Register, datad 7/23/12.
17) 'Intaria Prloritiaa List," Padaral Ragistar, datad 10/23/81.
18) Uhoontrollad Haaardoua Meat! Sita Ranking Svatami A Qaar's Manual
(undated).
19) Field Standard Cpantino pppoa»"** * A Survaillanea (undated).
20) Field Standard Operating Procedurea - Sita Safety Plan (undated).
• Located in EPA Region ZZZ offica.
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ai*dial_ Investigation/ Feasibility Study ?ecorr:s
; F.«frCrt . Einai Rfcreclial Ir.vest.isacj.cn/ Feasibility Stuciy Report, Phase * '
voluH» I-Narrativfe, Lcuciassviile Cispcsal Site. Berks CounJyT - " — ^
preparuu by MS Ccrpcrau.cn. 10/68'. P. 1-493. References
are ;.stfed en P. 488-492.
Report.. Final ftemeaial Ir.vgatigatu.cn/Faaaifcility Study Rcpcrt, Phase ::
Voiune I I -Appendix A, Couclassville Disposal Site, Becks CountyT ="
prepared ay MLS CorporatJ.cn, 10/88. P. 494-52fT~
j) Sfc^crt; Final RMmtdial Inv««tlgat3.on/F«a«viil< Diapoaal Sita,
pr«par«Q by MJS Corporation. 10/89. P. 1125-1250.
6) Raport. Final Ranndial Invt«tig«tion/P«Mibility Study Raport, Pha«< II,
Volur» VI-App«ndic«« G fc H, DpuqlMivilla Diapgaal Sit«, Barkj County,
Pcnnaylvaraa. pr«par«d by NUS . Corporation^ 10/88. P. 1251-1645.
7) tvipcrt. Final RanadUI InvMtig«ticn/F«Mibility Study t^port, Pfra<« II,
Voluaia VII-Appandix I, DouglaMvill* Diapoaal Slta, Barka County^
. pr«p*r^d by NUS CozporatAon, 10/88. P. 1646-1768.
r >
corrcspondanc^ and Supporting Decmantation
i) >vncranaun to th« File fron Mr. E. Sonnnterg and Mr. M. KUvacik, NUS
Corporation. r«s facility dlamntling and rli«rr»«l, and additional surface
casing in clninagi ditcn ar«a, 8/19/85. P. 1-6. A table regarding
eatunated ooet •uonury and a site nap are attached.
HhOonndUB to the file from Mr. E. Scmenberg, NUS Cdrporaticn, re:
and co«tc eetinatee C«ic] for additional eaomvatin? in the
ditdi area, 8/X/85. P. 7-11. Three etandard n lad at inn
3) homonndUB to the File fron Mr. C. Somentoerg, NUB Corporation, rex
ccet eaxiMtec for Alternative No. 4, 9/5/8S. P. 12-14. Tfco tablee
regirding badof> coex estimate* are attached.
4) Meoerandun to the File fron Mr. E. Sonnenberg, NUB Corporation^ rez
Additional coats to Feasibility Study Alternatives 2-9 due to
excavation in drainage ditoh area* 9/9/85. P. 15-28.
Lata regarding backup cost estonates are attached.
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to'the Hit iron >JT. £. Sonnenberg. XL'S Ccrpcratian. re:
LeeChate production tstira^ca, 9/12.'e5. ?. 29-39. Zaiia
prcducticr. escrraces are
d; >*ffcrancuni to th*. file, frcn Mr. Erich Sonnenberg, .'.L'S Corporation, re:
_*.sign considerations in the event of a 500-year flood, iC/3/S5.
.-. -.wo. -a.culaticrs regarding 500-year flood protection design are
7) Letter tc Ms. Judy Corsey, U.S. EPA, fron Mr. Mare E. Gold, Wolf, Block,
Sciiorr and Solis-Cohien, re; Lack of data contained in the Remedial
Investigation/feasibility Study prepared for the Berks Associates Site
cy NLS Corporation, 4/21/66. P. 44-48. Technical concerns regarding
Lcuglassville Remedial Investigation/Feasibility Study are attached.
by Letter to Mr. Jeffrey A. Pike, U.S. EPA, fron Mr. George V. Gartseff,
:,US Corporation, re: Remedial Investigation/Feasibility Study Test Pit
Logs tor the Louylassville Disposal Site, 6/24/86. P. 49-49.
S) Utter to Mr. Jeffrey A. Pike, U.S. EPA, fron Mr. George V. Gartseff,
NLS Corporation, re: Tranamittal of file msnos supporting Feasibility
study and Record of Decision calculations for the Douglassville Disposal
Site, 6/24/L6. P. 56-50.
lu) Letter to Mr. Jack Kelly, U.S. EPA, and Mr. Victor J. Janosik, U.S. EPA,
tram Mr. Edgar P. DeVylder, General Signal Corporation, re: Critique of
Lrart Phase II Remedial Investigation/Feasibility Study Mbrk Plan, 8/7/87.
P. 51-59. The critique is attached.
11) Letter to Mr. Jack Kelly, U.S. EPA, and Mr. Victor Janosik, U.S. EPA, fron
NX. Layar P. DeVylder re: Critique of Draft Phase II Remedial Investigation/
tfeasibility Study Mbrk Plan, 8/19/87. P. 60-63. A memorandum regarding
estimated cost savings is attached.
12) Letter to Mr. Edgar P. DeVylder, General Signal Corporation, from Mr.
Victor J. JanosiX, U.S. EVA, re. Barks Associates Steering Conmittee
letters of August 7, 1987 and August 19, 1987, 9/8/87. P. 64-70. A report
entitled Tbxicity Characteristic Leading Procedure" is attached.
13) Letter to Mr. Jens Hsenehan, U.S. EPA, fron Mr. Ed DeVylder, General Signal
Corpoation, re; Critique of Phase) II Remedial Investigation/Feasibility
Study flml Mack Plan. 9/18/87. P. 71-78. the) critique is attached.
1) Record of Decision. 6/24/88. P. 1-42.
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Design
£«a£ety, health, and Srergency Response "for Pre-Ctesicn Field
^-ac-cn ac ICLclassviile Disposal Super fund Site, Douclassvilie,
.-ferrj»jf--.ar-ia. prepared b> Ccnohue & Associates, 2/87. ?. 1-97.
Cx^ality Centre 1 Plan for Fre-D«sign Field Invgarlcaticn at
iiu.* Lispofcal Sup^rfund Sit*. Dou^laa«vill«, Pgnnsyivarua.
ty Ccnohue & Associates, 3/23/G7. p. 98-381. A tranamittal
report is attached to th« report.
Rfeport. Sanpling and Analysis Plan for Pr«-D««ign Field Inveatj.qau.or at
Louglassvillt Disposal Suparfund Site. Dougl«a«vall«,
{.relaxed ty Donoi'.ue & Associate, 3/23/87. p. 382-420. A tranonittal
report, is attachcc to the report.
•*) Ffeport. Fredeaign Report, Dougla<«ville Diapoaal Super.fund Site,
Ccugiaasvxlie, Pennsylvania, Volun» I, prepared by U.S. Army Corps of
£ngin*«rs, 3/88. P. 421-767. RefercncM are listed on P. 518-522.^
5} P*pcrt. f redesign Report/ Douglajsville Dispoaal Scperfund Site>
Locc,laa«ville. Pennsylvania, Voltne II, prepared by U.S. Army Corpe of
3/bb. P. 768-987"
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uamuruty
Cartnur.ity ?e'av-r«: -•*„ ^-» -
Jj
Sut^rfund Program Fact Sh~
^ UlaPoUTS..,. t
undatad). P. 341 -3
R«»dial Actlcc Plan.
prepared Ey
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