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
                                                                  «. Pwtoontag Orgmlnflon Rtpt Ho.
 8. Performing OraaMaHon Nwn* and
                                                                  10. Prol.cVT.Jk/Wor* UnH No.
                                                                  11. ContmcKQ or OwH(Q) No.

                                                                  (C)
 12. Sponsoring Orga
   U.S. Environmental Protection Agency
   401 M Street, S.W.
   Washington, D.C.  20460
                                         11 Typt of Report* Period Co»md

                                              800/000
                                                                  14.
 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	
                                                                             n.
                                                         101
(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
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                     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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B*cB«lll*4l i«B4M *•« till**
C*t* •••••••I At** |B*. )|
*«••<•«• At** |B*. l|
•*f**i ClMBa* B,t**»**l A«** A
|B». 41
•4>f**4 •!•••* BI*B***I Ai** B
IB*. »t
•••4IBI* t***t*«*> »«•• !•*. »l
lMt*«i«l*( **i SiMi*«a4t*t
•<•« !•*. »|
MUM M4 V*^ At** !••. •!
*M»litl*« !*<»»» A*** (•*. »l
•*»». t**A *•« A*!*** Ai**
!•*. *•!

t*l*l
•*!••••
IM^CI
•B - «.»•»
«.« - i.m
•»
•» - •»
M - !.!••
••
	
.. .
W - «.«
•B »

f«l»l
••••cyclic
Ai**«lit;*
IM/»«I
•B - 1 !>.•>•
• 1 - U.IM
•B - •
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M • II.MA
•B at
- • •
—
IM • Ilk
BB - III

T«l*l
Chi*! 4*»l«4
•ll*fc«llc«
lM/k«l
BB - IM.IM
» 1.411
BB
It - «»4
• .I - IB.1M
BB - 1
	
	
BB - II
BB

f«l«l
V*lh»l*t«
••(•l*
4
BB 114
1.4*4 - «l.*ll
44 • 4I.4K
BB - 111
...

1.4I1 t.4ll
BB • !.*•!
Total
•M**l«
lM/*4»
M - It. lift
«• 1.144
B* 11
•B - 1.411
•U •*.!<»
Mt • 1*


II ««•
•B • 44
Tul..
Vwlyt:lllt.i i*t«l«i«l
4l|il»«iif 1 »
<*.»/»•*»
•B Ik. Ml
>*J 14.141
•• '•»
I.I II It.ltO
•U li.J*^
•II 1*4


I.IJi 1.-.OI
II lk.4J*
L**4
l*4/k«l |
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14 1 1 . •••
'• I.IUI
1*1 •».*•.!
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J.4'i4 /.%y*

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• U
tut
NO    Not
Ho*  ••tirlf-f- viBMAl  obBB(v*ttonB
I4*tnltt*5 A«BfA4jB
                t.
           BOjUBlB
                                     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

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i/ta
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«««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)
























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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











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-------
             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
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42,940 1



9.2

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9,929
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499
0.41
9.1
2.720

-------
                                    24
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                                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


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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*•••

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    CUMULATIVE
                          5

Not available

-------
                                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

-------
                                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

-------
                                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

-------
                                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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                         .  •-     51

 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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                          .55

     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

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          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.

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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

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               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

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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.

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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).

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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«

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           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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