United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R03-88/060
September 1988
$EPA
Superfund
Record of Decision
Berks Sand Pit, PA
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50272-1 1
'REPORT DOCUMENTATION ~1"1.-R£PORT NO.
. PAGE EPA/ROD/R03-88/060
.2.
3. Recipient's Ac;cession No.
4, Title and Subtitle
SUPERFUND RECORD OF DECISION
Berks Sand Pit, PA .
First Remedial Action - Final
7. Authol(s)
5. R~rgo729J~8 8
I.
8. Performin. Or.anization Rept. No.
- -- ----
-1
i
i
,
---j
g. Perform in. O,.anlzation Name and Address
10. Project/Task/Work Unit No.
11. Contrac.(C) or Grant(G) No.
CC)
(G)
12. Sponsorin. Or.anization Name and Address
U.S. Environmental Protection
401 M Street, s.w.
Washington, D.C. 20460
- - ----..--------- _..
Agency
13, Type 0' Report & Period Covered
800/000
14.
15. Supplementary Notes
II. Abstract (Limit: 200 words)
The three to four-acre Berks Sand pit site is located in Longswamp Township, Berks
County, Pennsylvania. There are at least 20 single family homes within the
investigation area, including one on top of the actual sand pit. The immediate vicinity
of the site is zoned for low density residential use. The Berks Sand Pit was created by
the removal of sand and gravel, but reportedly was used by area residents for refuse
disposal. Industrial waste also was alleged to have been disposed of in the area around
the pit. Houses were constructed and private wells installed at the location beginning
in 1978, after the pit was backfilled. The site first came to the attention of EPA in
January 1982 when area residents detected ground water contamination. Emergency actions
were undertaken by EPA in the summer of 1983. The pit was partially excavated and
backfilled with clean fill, but no pocket of contamination was discovered. The primary
contaminants of concern affecting the ground water, surface water, and sediments are
VOCs including l,l,l-TCA, l,l-DCA, PCE, and l,l-DCE.
The selected remedial action for this site includes: excavation
sediments with offsite treatment by incineration; ground water pump
air stripping and vapor phase carbon absorption with reinjection of
(See Attached Sheet)
of contaminated
and treatment using
treated water back
17,", Oocum."t A!1al~is .a. O..~rlptors
L'l.ecora Ol:lJeC1S10n
Berks Sand Pit, PA
First Remedial Action - Final
Contaminated Media: gw, sw, sediments
Key Contaminants: VOCs (l,l,l-TCA, l,l-DCA,
b. Identifiers/Open. Ended Terms
,
I
l,l-DCE, PC E)
c. COSATI Field/Group
Availability Statement
19. Security Class (This Report)
None
21. No. 0' Paces
33
- ---- --
20. Security Class (This Pale)
None
22. Price
(See ANSI-Z39.18)
See Instructions on Reverse
OPTIONAL FORM 272 (4-77)
(Formerly NTI5-3S)
Oepartment 0' Commerce
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EPA/ROD/R03-88/060
Berks Sand Pit, PA
First Remedial Action - Final
16.
ABSTRACT (continued)
. .
into the aquifer; provision of an alternate water supply system, surface and ground
water monitoring; and restrictions to prevent installation of drinking water wells in
the contaminated acquifei. The estimated present worth cost for this remedy is
$10,773,100, with annual O&M costs of $459,200.
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RECORD OF DECISION
Berks Sand pit Site
Longswamp Township
Berks County, Pennsylvania
Statement of Basis and Purpose
This decision document presents the selected final remedial
action for the Berks Sand pit Site in Berks County Pennsylvania,
developed in accordance with the Comprehensive Environmental
Response, Compensation Liability Act (CERCLA) of 1980, as amended
by the Superfund Amendments and Reauthorization Act (SARA) of 1986
and to the extent practicable, the National Contingency Plan. This
decision is based on the administrative record for this site. The
attached index identifies the items that comprise the administrative
record upon which the selection of the remedial action is based. The
Commonwealth of pennsylvania has concurred in the selected remedy.
Description of the Selected Remedy
This remedy will address all the contaminants of concern at the
Berks Sand pit Site and will be considered the final remedy after
implementation and operations of the groundwater treatment system.
The remedy will include:
excavation of contaminated sediments and offsite treatment
and disposal by incineration
installation and operation of a groundwater extraction system
to remove contaminants from the aquifer
construction and operation of an air stripper with vapor
phase carbon absorption and the discharge of the treated
water to the aquifer by injection wells.
construction of an alternate water supply system
chemical and biological monitoring of the surface and ground
water quality .
local restrictions to prevent any further drinking water
wells in the contaminated areas of the aquifer
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-2-
Declaration
The selected remedy is protective of human health and the
environment, attains Federal and State requirements that are
applicable or relevant and appropriate for 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.
.\.n~~i L-~
Acting Regional Administrator
~-;,2J-~?1'
Date
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THE DECISION SUMMARY
Site Location and DescriPtion
The Berks Sand Pit site is located in Longswamp Township,
Berks County, Pennsylvania (Figure 1). The site is approximately
15 miles northeast of Reading, near the Villages of Huffs Church,
Seisholtzville and Mertztown. The area of the site investigation
is approximately 3 to 4 acres and there are at least 20 single
homes within the investigation area. The actual sand pit was
located on one of the residential lots where a home is now'
built. Figure two shows a sketch Berks Sand Pit Site and the
area of the former sand pit.
The Berks Sand Pit originally was created by the removal
of sand and gravel from the area. The size of the pit was
approximately 100 feet in diameter and 30 feet deep. The pit
reportedly was used by area residents for refuse disposal.
Industrial waste also was alleged to have been disposed of in
the area around the pit. Houses were constructed and private
wells installed at this location beginning in 1978, after the
pit was backfilled. In fact one home was built directly on
top of the pit. During January 1982, groundwater contamination
was detected in the area by the residents, and despite emergency
actions taken by EPA, no pocket of contamination or burried
drums of liquid solvents were discovered even though the pit
was partially excavated and backfilled with clean fill.
Currently, two important land uses near the site are
agricultural and residential development. Fields and orchards
are located nearby in Longswamp Township, as well as in neigh-
boring Hereford and District Townships. The site and the
property in the immediate vicinity of the'site is zoned as
"R-2", which denotes a low density, residential district.
Groundwater contamination persists to this day, and is
the major health threat at this site. The predominant organic
contaminants at the site are l,l,l-trichlorethane and
l,l-dichloroethene. These substances are used as indicators
of other organic compounds at the site. The groundwater
contamination does present a threat to drinking water at the
site for residential wells downgradient from the contaminant
plume. .
The main recreational use of the land in Longswamp
Township is fishing and hunting. The Berks Sand Pit area is
drained by the headwaters of three creeks: West Branch of
perkiomen Creek, perkiomen Creek and Swabia Creek. These creeks
are all classified for cold water fishes and trout stocking.
Ring-necked pheasants are the most abundant small game species
in Berks County, while cottontail rabbits are the second most
abundant. White-tailed deer also are plentiful. In addition to
the hunting and fishing in Berks County, approximately four
miles northeast of the site is the Doe Mountain skiing and
Recreation Area in Lehigh County.
3
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BERKS SAND PIT SITE
PROJECT LOCATION MAP
4
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T»ituTA»r TO mtrr AM«C«
or AfYMvewir* cucn
\
BERKS SAND PIT
NTS.
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Site History
Rittenhouse Gap, approximately one-fourth of a mile north-
west of the site, has been extensively mined for magnetite iron
ore and is believed to be one of the oldest ore-producing
districts in Berks County. The now abandoned iron mines consisted
of open cuts, tunnels, and shafts. The cuts generally are
elongated northeastward. The Cha Gery mine shaft is located
approximately 1,000 feet to the northwest of the site.
Residents reported tank trucks traveling Benfield Road
between September and November 1981, and that shortly thereafter,
in early 1982, their well water had a distinguishable odor and
obnoxious taste. Laboratory analysis conducted by The
Pennsylvania Department of Environmental Resources (PADER) in
1982 indicated that the following chemicals were detected in
the residential well for the home built over the sand pit:
1,1,1-trichloroethane > 45,000 ug/1
1,1-dichloroethene > 800 ug/1
1,1-dichloroethane > 300 ug/1
dichloromethane > 300 ug/1
1,2-dichloroethane > 150 ug/1
toluene > 150 ug/1.
The EPA conducted a removal action in the area of the pit
during the summer of 1983. Activities consisted of excavating
the area reported to be the sand pit and also installing a
water supply well for use by four families whose wells were
contaminated. The excavation did not encounter any buried
drums or other objects relating to the contamination.
Remedial Investigation Summary
The Remedial Investigation (RI) gathered information
through a site investigation of the groundwater, surface water,
sediment and soil and the laboratory analysis of these materials.
The purpose was to characterize the site to identify the level
of contamination and the physical boundaries of the contaminated
areas. The RI was conducted in 1987 and 1988 by PADER and its
contractor Baker, TSA Inc. A copy of the RI report is contained
in the Administrative Records for the site.
Onsite activities included air monitoring, surface and
borehole geophysical surveys, pump tests, sampling of surface
waters and local residential water supplies, subsurface soils,
and groundwater from the newly installed monitoring wells. A
second round of groundwater sampling and composite samples of
Rl-generated wastes were also taken. The sampling was performed
to: 1) determine the aerial extent of contamination, 2) deter-
mine groundwater quality, 3) provide additional subsurface
information, and 4) evaluate surface water and local well water
quality offsite. Ancillary field activities employed for
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the RI included site surveying and mapping, in order to provide
a current map of the site, and air monitoring to determine
levels of respiratory protection requirements for the site. An
outline of the activities conducted by the RI are highlighted
below. The results of the RI are discussed in subsequent
sections.
Geoloqy
May 1987 - Site Reconnaissance
1.
2.
3.
Air Quality Monitoring
Soil Gas Survey
Residential Wells
Fall 1987 - Groundwater Samplinq Round
1 .
2.
3.
4.
Air Quality Monitoring
Surface Water
Subsurface Soil Samples
Groundwater Monitoring Well
Samples (Deep)
Winter 1988 - Second Samplinq Round
1.
2.
3.
4.
5.
6.
Air Quality Monitoring
Surface Water
Groundwater Monitoring
Groundwater Monitoring
Residential Wells
Water Supply Wells
Well (Deep)
Well (Shallow)
The Berks Sand Pit is located in the Reading Prong Section
of the New England Physiographic Province. precambrain aged
metamorphosed igneous, sedimentary and volcanic rocks comprise
the highlands of the Reading Prong; the intermontane valleys
are comprise of Cambro-Ordovician sediments consisting of
limestone, dolomite, marble, and quartzite. Disseminated
magnetite, and Cornwall-type magnetite deposits occur throughout
the Reading Prong.
Magnetite ore is present near the surface west of the site,
at the Cha Gery Mine, and north of the site, at Rittenhouse
Gap. Magnetite rich pegmatites and massive magnetite was observed
in three boreholes.
In the vicinity of the site the saprolite consists of a
light brown, tan to orange clay with some silt and sand, and
quartz and feldspar fragments. The saprolite changes to clay
and sand with quartz and weathered granitic gneiss fragments at
depth. Some local zones in the saprolite show evidence of
foliation and relict structures.
The granitic gneiss is moderately to very closely fractured.
Many fractures encountered in the boreholes contained chlorite
filling and/or hematite staining on the fracture surfaces.
7
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Extensively weathered zones (possibly weathered fracture zones)
were observed the maximum expected depth of significant fracture
zones and weathered fractures, as determined from the cross-hole
seismic velocity measurements, is approximately 150 to 200 feet
below the ground surface.
The granitic gneiss is highly weathered throughout the area
and the thickness of the weathered overburden is quite variable.
There is, in general, no distinct boundary between the overburden
and the weathered bedrock. Rather, there is a gradual change
from saprolite to weathered granitic gneiss to fresh granitic
gneiss.
Hvdroloqv
Groundwater in the Berks Sand Pit area is encountered in
both the soil overburden and in the bedrock. The bedrock, a
granitic gneiss, has a low primary pOrosity and permeability
but has a significant secondary porosity and permeability due
to the presence of a complex fracture system.
In general, the fractures and fractured zones provide
preferred avenues for groundwater movement; more specifically,
highly weathered and altered fracture zones tend to provide
preferred avenues for groundwater movement. Other avenues for
groundwater movement as indicated by the borehole visual and
geophysical logs include faults, mineralogical changes and
grain size changes.
Two groundwater flow regimes have been identified at the
site. A shallow flow regime occurs in the overburden and a
deep flow regime occurs in the fractured bedrock. The shallow
flow regime consists primarily of saprolite and highly weathered
bedrock. Water in this shallow aquifer may occur as perched
zones, generally above saprolitic layers, and under confined to
semi-confined conditions, generally beneath saprolitic layers. .
The amount of water that moves through the bedrock depends
on the hydraulic gradient and the hydraulic conductivity of the
fractures and their frequency of occurrence and orientation.
The hydraulic conductivity of the fractures depends on such
properties as dimension, interconnectedness, filling material,
etc. These properties are quite variable and as a result, a
highly complex flow field has developed at the site.
In general, there are a large number of interconnected
fractures oriented in both a northeasterly and northwesterly
direction. From plots of the extent of contamination it can be
seen that the northeasterly flow direction is dominant.
8
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.~."'¥,,,,.. ~
Nature and Extent of Contamination
This section describes the types of contaminants found at
the site and their distribution in the soil, surface sediment,
surface water and groundwater. The most serious threat to
public health and the environment identified is the introduction
of organic solvents into the groundwater through the disposal
of an unknown quantity of liquid wastes at the site. A second
exposure pathway of concern js groundwater discharge to surface
seeps and streams resulting in the contamination of surface
water.
The result of the sampling performed during the RI showed
four volatile organic compounds that pose a risk to human health
and/or the environment. The four constituents that were identified
as indicator parameters are:
*
*
*
*
l,l-dichloroethene
l,l-dichloroethane
l,l,l-trichloroethane
tetrachloroethene
These chemicals pose the greatest potential public health
risk at the site and were chosen because they represent the
chemicals which were ~he most toxic, mobile and in the highest
concentrations. The fOllowing sections describe the extent
of these contaminants in the various media at the Berks Sand
Pit Site.
SQ.il
SOil samples were taken during the drilling program from
several borings. None of the four indicator parameters
identified above were detected in the soils at the Berks Sand
Pit Site. The maximum depth of soil sampling was less than 20
feet. No significant contamination was detected in the soils
at the site.
Surface Sediments
Surface sediments were collected during November 1987. The
sediments were collected to determine the pO$sibility of chronic
surface waste contamination. Ten of 28 samples collected showed
some type of volatile or semi-volatile compound. The location of
the surface sediment sampling points is given in Figure 3.
However, only one sediment sample, SP-2, showed detectable
levels of l,l-dichloroethane at 240 ug/kg. The occurrence of
this compound in SP-2 indicates the possibility of chronic
contamination of the seeps east of the former sand pit. The
source of this contamination may be the accumulation of contam-
inants from the groundwater over the past several years. It
should be noted that l,l-dichloroethane is a possible degradation
product of l,l,l-trichloroethane. Surface sediment remediation
is partlof the Lecommendedalternative.
9
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r*/A/M«r TO mftr tutuc*
Of ft ****** CM ft
BERKS SAND PIT
NT.S.
SURFACE WATER AND SEDIMENT SAMPLING
LOCATIONS
9P-I LOCATION OF SURFACE WATER
AND SEDIMENT SAMPLING POINT
H-i RESIDENTIAL PROPERTY IDENTIFIER
ANALYTICAL RESULTS ARE PRESENTED
IN TABLES 9-3 AND 3-4 AND IN
APPENDIX £
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Surface Water
Surface water s~ples were collected at 12 sampling points
in November, 1987 and at 13 sampling points in March, 1988.
The locations of these sampling points are given in Figure 3.
For both rounds, three of the four indicator parameters were
detected: l,l-dichloroethane, l,l-dichloroethene, and
l,l,l-trichloroethane. These result are given in Table 1 .
Some elevated metals also were encountered in samples SP-2 and
SP-5.
The results of these analyses indicate that some contam-
ination by l,l-dichloroethene, l,l-dichloroethane and
l,l,l-trichloroethane occurs in all of the surface water samples
except SP-12 and SP-13. The highest levels of contamination
are in the seeps east of the former sand pit (see Figure 3).
This contamination is probably the result of the discharge of
contaminated groundwater to surface waters. The downstream
extent of the surface water contamination by volatile organic'
compounds has not been determined. Further sampling of the
surface waters is part of the recommended decision. The detection
of the elevated metals in SP-2 and SP-5 appears to be an isolated
occurrence; the source of these metals has not been determined.
In summary, the surface waters northeast of the former sand
pit exhibit the most significant contamination. The presence
of volatile organic compounds (VOCs) in site surface water is
believed to be related to localized discharge of contaminated
shallow groundwaters. Groundwater remediation should prevent
further discharge at these surface seeps. The metals are thought
to be derived from scattered surface dumping of scrap metals
which is prevalent in this area. The surface water west and
northwest of the site show very low levels of VOCs.
TABLE 1
SUMMARY OF ANALYTICAL RESULTS FOR SURFACE WATER SAMPLES TAKEN IN
NOVEMBER 1987
Chemical
SP-3
SP-4
SP-7
l.l-dichloroethene
19.00
38.00 .
17.00
l.l-dichloroethane
*
*
*
l.l.l-trichloroethane
64.00
120.00
62.00
tetrachloroethene
ND
ND
ND
ND - Not detected.
*Data did not pass QA/QC procedures.
All units in ug/l.
11
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Note:
All other surface water samples taken in November 1987
showed detectable levels of at least one of the four
indicator parameters. However, the analytical results
for these samples did not pass the'QA/QC procedures.
SP-13 was not sampled because it was frozen.
Groundwater
Groundwater samples were collected from May 1987 to March
1988. These samples can be divided into three categories:
residential well samples, monitoring well samples and packer
test samples. The residential wells were sampled in two rounds:
November 1987 and January 1988 through March 1988. The packer
test samples were taken in October 1987.
Thirty-eight constituents were detected in the groundwater:
eight VOCs, six semi-volatile compounds (SVOCs) and 14 inorganics.
Only the extent of the four primary indicator chemicals,
l,l,l-trichloroethane, l,l-dichloroethane, l,l-dichloroethene,
and tetrachloroethene will be discussed in detail since they
exhibit the greatest risk to the community and the environment.
No metals were detected above the National Primary Drinking
Water Standards (NPDWS) in the groundwater.
Residential Well Samples
Two rounds of water samples were taken from the residential
wells in May 1987 and in January 1988 through March 1988. The
location of these wells are shown in Figure 4. Eleven residential
wells were sampled during the first sampling round (May 1987).
As shown in Table 2 five had detectable levels of at least one
of the four indicator parameters. Only RW-4 was above the
Maximum Containment Levels (MCLs) established by EPA for drinking
water for both l,l,l-trichloroethane and l,l-dichloroethene.
Nineteen residential wells were sampled during the second
round (January ~o March 1988). As shoWn in Table 3, six had
detectable levels of at least one of the four indicator parameters.
RW-2 exceeded the MCL for l,l-dichloroethene and RW-3 exceeded
the MCL for l,l,l-trichloroethane. Five additional residential
wells (RW-4, RW-S, RW-7, RW-9 and RW-IO) showed detectable levels
of at least one of the indicator parameters. However, data for
these wells did not pass QA/QC procedures.
12
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\- If'l'sr .".NCN
-rlll.Ur"",OY::" CIKlIt
OF ,. "It
->t'1
fiGURE 3-5
lOC ATTOI~~~f ~~~~SNDWA T E R
MONI
MONITORING WELL
8MW-1 DEEP ONITORING WELL
Q SW-I SHAllOW M Ell
ENTIAl W
. RW-I RUID NITORING WELLS
X EIIT. I OTHER MO E (SEE
A' CROSS - SECTION UN
~ AND 5-14)
/'
'I!J
j'
~
SAND PIT
BERKS
N.T.S.
"".
"
fiGURES 3- jj
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TABLE 2
SUMMARY OF ANALYTICAL RESULTS FOR RESIDENTIAL WELL SAMPLES
TAKEN MAY 1987
Chemical
1 Pl-dichloroethene
1 , 1-dichloroethane
1,1, 1-trichloroethene
Tetrachloroethene
RW-4
540
ND
6.800
ND
RW-6
ND
ND
13
ND
RW-7 RW-10 RW-11
ND
ND
21
ND
ND
ND
12
ND
ND
ND
27
ND
MCL
7
200
ND - Not detected.
All units in ug/1.
MCL - EPA's maximum contaminant level for drinking water
TABLE 3
SUMMARY OF ANALYTICAL RESULTS FOR RESIDENTIAL WELL SAMPLES
TAKEN JANUARY 1988 THROUGH MARCH 1988
Chemical
1 , 1-dichloroethene
1 , 1-dichloroethane
1 . 1 f l-trichloroethane
Tetrachloroethene
RW-2 RW-3
8.7 ND
ND ND
47 1.400
* ND
RW-6
*
ND
16
ND
RW-8 RW-11
ND *
ND ND
6.5 21
ND ND
RW-12
ND
ND
6.1
ND
ND-Not detected.
*Data did not pass QA/QC procedures.
All units in ug/1.
Monitoring Wells
Three types of monitoring wells are located at the site.
In 1983, the Emergency Response Team (ERT) installed three wells
to collect groundwater samples. In the RI conducted by Baker/TSA,
Inc., deep monitoring wells (MW) and shallow monitoring wells (SW)
were also installed to further define the groundwater contamination
plume. All locations are shown in Figure 4. The ERT wells were
sampled in May 1987 and again in January 1988 through March 1988.
The MW wells were sampled in November 1987 and again in February
1988 through March 1988. The SW wells were sampled in February
1988 through March 1988.
14
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> ,,',., "
For the May 1987 sampling of the ERT wells, all three
wells had detectable levels of l,l,l-trichloroethane, as shown
in Table 4. l,l,l-trichloroethane also was detected for the
January through March 1988 sampling round. Water samples from
. the 1988 sampling round also contained l,l-dichloroethene and
tetrachloroethene. These concentrations are shown in Table 4.
The MW monitoring wells were sampled in November 1987 and
again in February 1988 through March 1988. The analytical
results for the 1987 sampling round did not pass QA/QC
procedures and will not be discussed here. For the February
1988 through March 1988 sampling round, at least one of the
indicator parameters was detected in all of the MW wells as
shown in Table 5. l,l-dichloroethene was detected in all of
the MW monitoring wells above the MCL of 7 ug/l.
l,l,l-trichloroethane was detected in MW-3 through MW-9 above
the MCL of 200 ug/l. Additionally, tetrachloroethene was
detected in MW-7 at a concentration of 25 ug/l.
The SW monitoring wells were sampled in February 1988
through March 1988. As shown in Table 6, wells SW-l through
SW-5 exceed the respective MCLs for l,l-dichloroethene and
l,l,l-trichloroethane. The analytical results for SW-6 did not
pass the QA/QC procedures.
PaGker Tests
Water samples were taken during the packer tests in
October 1987 to give an indication of the vertical extent
of contamination. These samples were analyzed for both
volatile and semivolatile organic compounds. Only one packer
test sample passed the QA/QC procedures: MW-2 at the 44 to 54
foot depth. This sample showed a l,l,l-trichloroethane
concentration of 19 ug/l.
15
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"jo.
TABLE '4
SUMMARY OF ANALYTICAL RESULTS FOR ERT MONITORING WELL
SAMPLES TAKEN MAY 1987 AND JANUARY 1988 THROUGH MARCH 1988
Checical
BRT-l
~( 1 98 7 ~
BRT-2
(1987)
ERT-3
(1987)
ERT-l
(1988)
ERT-2
(1988 )
ERT-3
(1988)
HCL
l.l-dichloroethene
UD
ND
~
250.00,
~
250.00
7
l.l-dichloroethanc
ND
ND
~
ND
ND
ND
-I
1.1.1-trichloroethanQ
5.00
19.00
Tetrachloroethene
UD
ND
2.900.00
ND
98.00
26.00
98.00
200-
ND
. ND
6.40
ND - Not detected.
~Data did not paaa QA/Qc procedurea.
All unita in uS/I.
MCL - Haxiaua Contacinant Level.
TABLE 5
....
0\
SUHMARY OF ANALYTICAL RESULTS FOR DEEP HONITORING WELL SAHPLES
TAKEN JANUARY THROUGH HARCH 1988
Cheaical H\-1-l HW-2 HW-3 HW-4 HW-5 HW-6 HW-7 HW-8 HW-9
1.1-dichloroethene 48 48 860 3,500 120 340 I ,300 4 I 1,100
l.l-dichloroe'thane ND NO NO NO NO ND NO ND ND
1. I. I-trichloroethane 180 90.00 2,200 7,300 300 940 3,700 * 3,100
Tetrachloroethane NO NO ~ ~ ND NO 25.00 NO .
NO-Not detected.
*Oata did not paaa QA/QC procedures.
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TABLE 6
SUMMARY OF ANALYTICAL RESULTS FOR SHALLOW MONITORING WELL SAMPLES
TAKEN JANUARY THROUGH MARCH 1988
Chemical SW-l SW-2 SW-) SW-4 SW-5 SW-6 SW-7
l.l-dichloroethene 850 220 100 270 280 * NO
l.l-dichloroethane NO NO NO NO NO NO NO
1. 1. I-trichloroethane 1.900 6.500 240 490 600 * NO
Tetrachloroethene NO * NO * NO NO NO
NO - Not detected.
.... *Oata did QA/QC procedures.
~ not pass
All units in ug/l
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A review of the historical data, as shown in the RI,
indicates that although the contamination at the site has
decreased somewhat over the past five years (1983 to 1988), it
is still present in significant quantities. The decrease in
concentration is probably best illustrated by the historical
l,l,l-trichloroethane concentrations recorded for RW-2, RW-3 and
ERT-3. The data shows some large fluctuations in
l,l,l-trichloroethane concentrations over relatively short
(months) periods of time. Some downgradient residential wells
(RW-6, RW-7 and RW-ll) also show Slightly increasing 1,1,1-
trichloroethane concentrations. These time-concentration
relationships indicate that the contaminant plume
(l,l,ltrichloroethane) is migrating, dispersing and become
more dilute with time. The remedial action selected in this
Record of Decision address the groundwater contamination and
the public health threat by extracting contaminated ground
water and removing the organic chemicals and will prevent any
further migration of the contaminant plume.
The contaminant plume is elongated in an east-northeasterly
direction and is centered around MW-4 with a maximum
concentration of 7,310 ug/l of l,l,l-trichloroethane and
3,500 ug/l of l,l-dichloroethene. Higher concentrations
extend from the R-2 property as far as the tributary to the
West Branch of Perkiomen Creek. Lower levels of contamination
appear to extend north and northwest of the east-northeast
plume axis towards Benfield and Walker Roads. The area of
contamination, both high and low, potentially extends into
residential properties R-2 through R-12. The contamination
appears to have sunk and are being carried to deeper depths
within the aquifer by vertical gradients. The maximum depth
of contamination, based on the geophysical investigation and
the packer tests, is thought to be 250 to 300 feet below the
surface.
Public Health Evaluation and Environmental Concerns
The groundwater at the Berks Sand Pit Site has a significant
potential adverse health impact on receptor populations. There
were two complete exposure pathways identified in the RI. One
pathway is the groundwater exposure via inhalation, ingestion,
and dermal contact by receptors on residential wells, and the
other is the surface water/sediment exposure pathway from the
seepage of groundwater to the surface.
The air pathway is not a health hazard in regard to the
volatilization of organics from the surface waters, from the
surface soils or from the groundwater exposure pathway. In
addition, the surface soils are not a health hazard from
dermal contact or ingestion.
18
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~ .
The groundwater exposure pathway had significant chronic
health index values and projected risks values above the target
risk values for carcinogens. The compounds most responsible
for the potential adverse health impact were l,l-dichloroethene
and l,l,l-trichloroethane.
The residential wells having~levels of these two compounds
of concern were RW-2, RW-3 and RW-4. The monitoring wells
also showed concentrations capable of having a potential adverse
health effect. The migration of the plume toward the northeast
could bring the elev~ted concentrations found in the monitoring
wells to human receptors. J
The surface water and sediment exposure pathway is not a
significant chronic health risk for human receptors but is
directly in line with the migrating plume and further defines
the extent of contamination. These surface water and sediments
indicate a potential for the contaminants to affect aquatic
life and the environment. Removal of the contaminated sediments
and subsequent monitoring should help to determine the
effectiveness of the groundwater extraction system.
Community Relations
The Community Relations Plan for this site was developed
by the Pennsylvania Department of Environmental Resources and
has been implemented over the past two years. All site related
documents and the Administrative Record have been placed in the
Longswamp Township Municipal Building. The public~otice of
EPA's proposed plan, which included the preferred-remedial
action alternative, was published on August 30, 1988. A thirty
day public comment period began from that dated and ended on
September 28,1988. A formal public meeting was held on
September 12, 1988 at the Township Building to discuss the
proposed plan. The transcript from that meeting represents the"
only comments received by EPA and PADER. All questions and
comments preSented at that meeting were addressed at that time.
These are discussed in detail in the transcript which is
attached.
In addition
selection, local
field activities
sampled.
to the public participation in the remedy
residents were continuously.informed of the
and the occasions when residential wells were
19
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Applicable. Relevant and Appropriate Recruirements (ARARs)
The Remedial Action Alternative chosen for the Berks Sand
Pit Site must meet all applicable or relevant and appropriate
requirements (ARARs) in accordance with Section 121 of CERCLA,
42 U.S.C. Section 9621.
The primary regulatory considerations at the site apply to
the treatment of groundwater. According to EPA's guidance for
groundwater classification, this is a Class 1 aquifer which is
currently in use. Therefore two contaminant specific levels
for protection of human health must be met under the Safe
Drinking Water Act (SDWA). l,l,l-trichloroethane has a Maximum
Contaminant Level (MCL) of 200 ug/l and l,l-dichloroethene has
an MCL of 7 ug/l (see 40 C.F.R. Section 141.12). These health
based levels indicate the clean up standards for groundwater
which the remedy must reach before clean up has been achieved.
However, EPA and PADER will have to evaluate the effectiveness
of the treatment system on a periodic basis to determine if
these standards can be met or exceeded.
In addition to these contaminant level requirements, EPA
and PADER must comply with all Federal Resource Conservation
and Recovery Act (RCRA) requirements for onsite water treatment
including air emissions site and offsite transportation,
incineration and related air emissions. Also the State
requirements would include the Pennsylvania Solid Waste
Management Act (PSWMA), the PennsYlvania Clean Streams Law
(PCSL), and the Pennsylvania Air POllution Control Act (PAPCA).
For the alternative proposing water discharge to surface
streams the National Pollutant Discharge Elimination System
(NPDES) requirements and PCSL must be met. Likewise for the
proposals to reinject the treated groundwater, the Underground
Injection Control (UIC) requirements must be met. The specific
chemicals standards will be defined in the design
specifications stage. Regulations for the selected remedial
actions are further specified in the recommended alternative
section.
20
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Summary of Alternatives
Seven feasible Remedial Action Alternatives (RAAs) were
developed to remedy the site conditions. The seven
alternatives (RAA No.1 through RRA NO.7) were developed to
address four levels of cleanup as described below. A list of
the seven alternatives and the cleanup categories they satisfy
is provided below. A more detailed discussion of these RAAs
contained in the Feasibility Study for the site.
Cleanup Cateqorv I:
RAA No.1
RAA No.2
No Action
Continued monitoring of existing wells
(groundwater) and surface water
Surface and groundwater monitoring, including
the installation"of additional monitoring wells
Cleanup Cateqorv II:
To Human Health
RAA No.3
Alternatives That Prevent A Risk Increase
Surface and groundwater monitoring, including
the installation of additional monitoring wells,
and installation of an alternative water supply
which will be defined in the design specification
stage
Cleanup Cateqory III:
Human Health
RAA No.4
RAA No.5
Alternatives That Meet Or Exceed ARARs for
Surface and groundwater monitoring, including
the installation of additional monitoring wells,
installation of an alternative water supply
system which will be defined in the design
specifications, groundwater extraction,
groundwater treatment by air stripping with
vapor phase carbon absorption, discharge of
treated water to the watershed (stream), and
excavation and disposal/treatment of
contaminated sediments by landfarming or
incineration
Surface and groundwater monitoring, including
the installation of additional monitoring wells,
installation of an alternative water supply
system which will be defined in the design
specifications, groundwater extraction,
groundwater treatment by carbon adsorption,
discharge of treated water to the watershed
(stream), and excavation and disposal/treatment
of contaminated sediments by landfarming
or incineration
21
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Cleanup Cateqorv IV: Alternatives That Meet Or Exceed ARARs
For Human Health And The Environment
RAA No.6.
RAA No.7
Surface and groundwater monitoring, including
the installation of additional monitoring wells,
installation of an alternative water supply
system which will be defined in the design
specifications, groundwater extraction,
groundwater treatment by air stripping with
vapor phase carbon absorption, discharge of
treated water by reinjection into aquifer,
excavation and disposal/treatment of contaminated
sediments by landfarming or incineration
Surface and groundwater monitoring, including
the installation of additional monitoring wells,
installation of an alternate water supply
system which will be defined in the design
specifications, groundwater extraction,
groundwater treatment by carbon adsorption,
discharge of treated water by reinjection,
excavation and disposal/treatment of contaminated
sediments by landfarming or incineration
Table 7 provides a summary of the cost evaluation performed
for the RAAs. All costs are presented in 1988 dollars.
Table 7
REMEDIAL ACTION ALTERNATIVES COST SUMl9.RY
BERKS SAND PIT SITE
RAA No. Capital Cost Annual O&M Present Worth Cost
($1,000) ($1,000) ($1,000)
1 0 101. 0 952.4
2 941.3 109.9 1,977.6
3 2,227.3 180.5 3,975.4
4 5,543.8 455.0 9,833.6
5 5,614.2 1,033.3 15,355.2
6 6,443.7. 459.2 10,773.1
7 6,514.1 1,037.5 16,294.7
The following tables address the nine areas of concern which
EPA considers for each RAA. Basically, there are two treatment
alternatives (air stripping and carbon) and two disposal options
(surface discharge and groundwater reinjection) for the water.
22
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TABLE 8
BERKS SAND PIT
SUMMARY OF THE ALTERNATIVE EVALUATION
Alternative Number
ARAR
Compliance
Toxicity. Mobility
or Volume
Reduction
Short-Term
Effectiveness
Long-Term
Acceptance and
Performance
RAA 1
No Remedial Action
Does not
comply with
contaminant-
8pecific ARARs
Does not reduce
toxicity, mobility
or volume
Does not reduce
risks
Does not reduce
risks
RAA 2
No R~medial Action with
Groundwater Monitoring
Does not
comply with
contaminant
specific ARARs
Does not reduce
toxicity, mobility
or volume-
Does not
reduce risks
,"~
RAA 3
Alternative Water
with groundwater
monitoring
Supply
Does not
comply with
contaminant-
specific' ARARs
Does not reduce
toxicity, mobility
or volume
Reduces only a
portion of the
health risks
Does not
reduce risks
Reduces only a
portion of the
health risks
RAA 4
(Air Stripping>
Alternative Water Supply.
Sediment and Groundwater
Treatment, Disp08al to
Stream'
Complies with
known ARARs
Volume reduced,
mobility reduced,
toxicity reduced
Reduces risks
to public
health
Reduces a
majority of
the risks
RAA 5
Alternative Water
Supply, Sediment and
Groundwater Treatment,
Carbon Adsorption,
Stream Disposal
Complies with
known ARARs
Volume reduced,
Mobility reduced,
Toxicity reduced
Reduces risks
to public
health
Reduces a
majority of the
risks
-------
BERKS SAND PIT
SUMMARY OF THE ALTERNATIVE EVALUATIONS
Iaplementability
Community
Acceptance
State
Acceptance
Present Worth
Cost
Protection of
Human Health
1.
Eaaily .
illplementable
Probably
unacceptable
Probably
unacceptable
952
Nonprotective
2. Eaaily Probably Probably 1,978 Nonprotective
illplellentable unacceptable unacceptable
.~
3. Easily Favorable Favorable 3,975 Partially
iaple.entable accepta~ce acceptance protectlve
4. Illple.entable Generally. Favorable 9 , 834 Generally
favorable acceptance protective
acceptance
5. I.ple.entable Generally Favorable 15,355 Generally
favorable acceptance protective
acceptance
-------
Alternative Number
RAA 6
Alternate Water
Supply, Sediment and
Groundwater Treatment,
Air Stripping,
Reinjection
.~
RAA 7
Alternate Water
Supply, Sediment
and Groundwater
Treataent, Carbon
Ad8orption, Reinjection
BERKS SAND PIT
SUMMARY OF THE ALTERNATIVE EVALUATIONS
ARAR
Coapliance
Toxicity, Mobility
or Volume
Reduction
Short-Term
Effectiveness
Lo ng -Te rm
Acceptance and
Performance
Complies with
known ARARs
Volume reduced,
Mobility reduced,
Toxicity reduced
Reduces risks
to public
health and
environment
Reduces most ot
the risks
Complies with
Known ARARs,
Voluae reduced,
Mobility reduced,
Toxicity reduced
Reduces risks
to public
health and
environment
Reduces most of
the risks
",-
-------
BERKS SAND PIT
SUMMARY OF THE ALTERNATIVE EVALUATIONS
Implementability Community State Present Worth P rote.c t ion of
Acceptance Acceptance cost Human Health
($1.000) and
Environment
6. Implementable Favorable Favorable 10.773 Protective
7.
Iapleaentable
Favorable
acceptance
Favorable
acceptance
16.294
Protective
~
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Recommended Alternative
After extensive technical review and cost evaluation, EPA
and PADER have selected RAA No.6 as the appropriate remedial
action for the Berks Sand Pit Site.
RAA No.6 includes:
excavation of contaminated sediments and offsite
'treatment and disposal by incineration
installation and operation of a groundwater extraction
system to remove contaminants from the aquifer
construction and operation of an air stripper with
vapor phase carbon absorption and the discharge of the
treated water to the aquifer by injection wells
construction of an alternate water supply system
chemical and biological monitoring of the surface and
groundwater quality
restrictions to prevent any further drinking water
wells in the contaminated areas of the aquifer
Groundwater remediation targets must meet or exceed the
Maximum Contaminant Level (MCL) for both l,l,l-trichloroethane
(200 ug/l) and l,l-dichloroethene (7 ug/l) as required by the
Safe Drinking Water Act. The groundwater contamination levels
will be reduced by the extraction, treatment and reinjection of
:lean water. The facility must meet hazardous waste
requirements of RCRA Subtitle C 40 C.F.R. Part 264 and the
Pennsylvania Solid Waste Management Act. This remediation may
require up to thirty years of operation, but will be
periodically evaluated to determine the effectiveness and
technical feasibility of reducing groundwater contamination
JY this method. Based on this evaluation, the Agencies will
jetermine to continue the extraction and treatment program or
to cease treatment when the aquifer no longer presents a
potential health risk.
Secondary target levels, which will be used as guidelines,
:0 determine when the groundwater is no longer a risk are based
)n published Unit Cancer Risk (UCR) information.
l,l-dichloroethene is a possible human carcinogen and
:etrachloroethelene is a probable human carcinogen. The
;econdary target will be to decrease the concentration of these
:ontaminants to below 1.0 ug/l which would approximate
ietection limits by standard EPA analysis.
27
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The groundwater will be treated to levels established by
the Underground Injection Control (UIC) regulations 40 C.F.R.
Parts 144,145,146 and 147.
When a decision is made to discontinue the extraction and
reinjection program a close out sequence will be initiated to
decommission the wells and treatment facilities.
The alternative water supply source has not been resolved.
Three options to be investigated in the design stage will
include: extention of Mountain Village Community Water Supply,
extention of Topton Public Supply, and a new.well field with
extention of the existing Longswamp Well Association. The
local residents expressed a clear preference for the extention
of the Topton Wat~r Supply.
The contaminated sediments must also be excavated and sent
to a permitted or interim status facility which is compliance
with all hazardous waste requirements of RCRA Subtitle C
40 C.F.R. Part 264.
When comparing the remedial alternatives for this site,
EPA was limited to RAAs 4, 5, 6 and 7 because these alternatives
were the only ones which met ARARs. The Agency selected the
air stripping treatment rather than the carbon absorption because
they are equally effective at removing the groundwater .
contaminants and the air stripping is five million dOllars less
expensive than the carbon. Basically, replenishing the carbon
is the major expense. The Agency also selected the reinjection
alternative rather than surface water discharge because
reinjection treatment requirements would be more stringent and
reinjection may help to flush out the contaminated groundwater
in a shorter period of time. Also there may be residences who
would continue to use their private wells and reinjection would
help to maintain the current level of the water table in the
vicinity of the site. As shown in Table 8 the selected remedy
reduces toxicity, wobility and volume of the contaminant plume
by the extraction of the contaminated groundwater and treatment
by air stripping. This alternative is protective of the public
health and the environment and will provide a permanent remedy
for the site.
Figure 5 shows the general process for RAA No.6. Figure 6
shows the details of how an air stripper works and Figure 7 shows
the new recovery and reinjection wells.
28
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1t....C8Dd
CIa -fa ~
:P.
N~
~CD
,U1
p.~.r*Mt
..
~
~
If
..... '
'n ~mf:-
'1 Aac*I
=-w:a
Ail
ID~
WeD
BERKS SAND PIT
GENERALIZED PROCESS DIAGRAII FOR BAA NO. a
-------
WATE R FLOW
BLOWER
-
AIR IBLOW
-
AIR OUTFLOW
AIR
AIR
AIR
SPRAY NOZZLE
WATER
PACKING MATERI~L
WATER
WATER OUTfLOW
Figure 6
30
PACKED TOWER AIR STRIPPER
-------
w
....
/
EXTRACTION
WELLS
~"""\"-
..,
." MlAII&JI
'''''''''0 &M6.:::::"" /" .
IN 116..ItMIIII 7 ~l
... i~~~\
~ " .
." '" .. t...
" +. ..\
/ + '1'\,
'If . ~..."""
~ """~"'...
~ ""...,
~ '~,
~ "
':' "",
~ ,..
" ','..
,~ ..
"
,,..
~
"
~
"
~
"
INJECTION
WELL'
.,." -"'«II
''''''''An '0 UIU.
IN l16""IOMIII
.
.
MEDIAL ACTION .
RE WELL CLUSTER
EXTRACTION
WELL
INJECTION
. .'~.:,! .
\
PIT
t'igure 7
. . CTION WELLS
. REIN.JI
RACTION AND
LOCATION" or EXT
-------
Responsiveness Summary
The only response from the public during the comment
period was obtained from the public meeting which was held
September 7, 1988 and the minutes from the meeting are
attached. To summarize, the citizens asked many questions
about the remedy and the technical aspects of the differences
between the air stripping technology and the carbon absorption
method. We were able to show them some diagrams of the air
stripper and described the approximate size and noise level of
the system. The carbon absorption was compared to their own
type of water softening system and they understood. We also
explained that they were both effective in the treatment
capabilities and that we chose the air stripping because the
cost was five million dollars cheaper because we did not have
the carbon to dispose or regenerate.
They were in agreement with the approach the Agencies had
chosen to do groundwater remediation, but were somewhat
concerned that the extraction and reinjection wells would not
collect all the contaminated groundwater or that some of the
reinjected water may cause further spread of the contaminant
plume. We explained how the extraction and reinjection wells
would have to be monitored, especially in the initial start up
phases and that the treated water would have to be analyzed to
be sure the contaminants were removed before the water could be
reinjected. They did express concern about the frequency of
our monitoring and we restated that beginning stages would have
to be closely controlled.
When they asked about the source of the alternate water
supply, we told them that it was not specified at this time and we
mentioned that we would have to look into several alternatives. They
immediately state, in unison, that they did not want to have the
trailer park as the source of the water supply because they felt
it would be used for personal gain rather that protection of
their health. They expressed a clear preference to be hooked
up to the Topton water supply which is approximately six miles
away. They did not want to set up additional wells which they
would have to maintain and operate under the current homeowners
association because of the problem already encountered
in operating the system which is currently supplying four
residences.
Overall the citizens seemed to be in agreement with the
proposed plan as presented and were happy to have their chance
to ask questions and have an explanation.
32
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-~~:;r<- .
~~.'.'~II"""
I,' ~
"~
COMMoNwEALTH OF PENNSYLVANIA
DEPARTMENT OF ENVIRONMENTAL REsouRCES
.-0" 0HIa. 10. 2083
H8rrteburg, P8nneytylnla 1'120
S8pt8mb8r 21, 1988
Deputy '.orwt8ry fOt
Invlronm8ntll Protwtlon
(717) 787-5028
Stephen R. W...enuQ, Director
Ra..rdou. W..te X&nag...nt Divi.ian
DA Aeg10n III
841 Che.tnut Building
Philadelphia, PA 11107
Re,
Letter of Concurrence
Berk. Sand Pit SUPerfund Site, Record of Dec1.1on (ROD)
Dear xr. "a"8r.ug'
The Record of Dec1.1on for the Berk. Sand P1 t SUPerfund
lite ba. been revi8ftd ):)y the Department.
The .elected final r888dial action will include the
fo11ow1ng8
*
Ixcavation of oontaminated .8d1m8nt. and off-.1te
treatment and di.po.al ):)y incineration.
In8tallat1on and. operation of a oroundwater extraction
.y.t.. to r8lDOV8 contaainant. fraa the aquifer.
Con8truct1on and operation of an air .tripper w1th
vapor pha.e carbOn ab.orpt1on and the cu..char;e of the
treated Water to the aquifer by 1n,ection ..11.. .
*
.
.
Con.truction of an alternate water .upply 'Ylt8m.
Ch8m1cal and biological aonitoring of the .urface and
groundwater quality.
Local ra.tric~iaft. to prevent any further drinkln9
water ..11. in the contaminated area. of the aquifer.
.
.
I hereby concur with the DA'. propo.8d r888dy with the
following caftdi~iOft81
I
*
The Department will be 9iven the opportunity to concur
with deci.iona related to the d.a19n of the remedial
act10n. to ..aure coaplianc. with 8tate de.ign .pecific
AMR. . .
33
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St.ph.n R. .a...r.uv, Director
2
Sept88b8r 29, 1988
.
The D8partMnt "ill be given the opportUD1 ty to
d.tem1ne, vith DA, whether oontinuec1 ope~.tJ.on of the
groundwater utraot1on and treatment Iylt- v111 reduo.
groundwat.r eont88!nat1on to ...t ~ed.ral and State
ARM. and when to cu.. treat88nt a. the aqu1f.r no
10nge1' pre.ent. a potential health ri.k.
,
.
Th.D.partm8nt vill be viv.n the opportunity to concur
with deci.ion. related to the chemical and biolo;1cal
monitorin9 requirement. for .urface and vroundwat8r
quality.
IPA vill a..ure that th. Department i. provided an
opportunity to fully part1c1pat. in any n89otiation.
wi t.h r..pon.ible parti...
.
.
. .
Th.'Department will r..erYe our rivht and
re.pon.ibility to take indep8ftd8nt enforc...nt action.
pur.uant to 8ta~e and r8CSe~~l, ~'aW8. .
. . 1 . i." "
'l'hi. concurrence with the" .el8ct8d r~ial action i.
'not int.nded to pz:cvid. any'a..urana.. pur.uant to SARA
Section 104 (c}('~,~:'
.
,.
w. r.c0mD8nd that the in.tallation of the alternative
public vater .upply proceed ~iCklY a. po..ibl. and
ind.pendently of th8 oth.r r 1al action.. Thank you for the
opportunity to concur with thi8 SPA Record ot Dec1.1on. If you
have any que.tion. reqarding thi. matter, plea8e do not h..1tate
to contact... .
8m:Y1iJ/~
~~~lan
D8puty S.cretary
In,,lromD8ntal Protection
34
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