Superfund Record of Decision Berkley Products Company Dump Site Denver PA


                                    EPA/ROD/R03-96/221
                                    1996
EPA Superfund
     Record of Decision:
     BERKLEY PRODUCTS CO. DUMP
     EPA ID: PAD980538649
     OU01
     DENVER, PA
     06/28/1996

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Text:

RECORD OF DECISION
BERKLEY PRODUCTS

DECLARATION

SITE NAME AND LOCATION

Berkley Products Company Dump Site
Denver, Pennsylvania

STATEMENT OF BASIS AND PURPOSE

This decision document presents the selected remedial action for the Berkley Products Site (the Site) which
was chosen in accordance with the Comprehensive Environmental Response Compensation, and Liability Act of
1980 as amended by the Superfund Amendments and Reauthorization Act of 1986 (CERCLA) and, to the extent
practicable, the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). This decision is
based on the administrative record for this site.

The Commonwealth of Pennsylvania concurs with the Selected Remedy set forth in this Record of Decision.

ASSESSMENT OF THE SITE

Pursuant to duly delegated authority, I hereby determine pursuant to Section 106 of CERCLA, 42 U.S.C. §9606,
that actual or threatened releases of hazardous substances from this site, if not addressed by implementing
the response action selected in this Record of Decision (ROD), may present an imminent and substantial
endangerment to public health, welfare, or the environment.

DESCRIPTION OF THE SELECTED REMEDY

The elements of the selected remedy are described below and are the only planned actions for the Site.

1. Pre-design investigations

2. Site preparation and Consolidation of landfill wastes

3. Site grading

4. Cover system with the following components as determine necessary for
compliance with the relevant sections of Pennsylvania's Hazardous Waste
Regulations:
- Subgrade
- Gas vent system
- Barder layers
- Drainage layer
- Top layer (vegetated)

5. Security fencing

6. Erosion control measures

7. Institutional controls restrict new well installation in the contamianted zone

8. Long-term operation and maintenance

9. Groundwater, surface runoff, leachate spring and seep monitoring (annual),
residential well monitoring (semi-annual) and monitoring wells (guarterly)

10. Five-year reviews.

STATUTORY DETERMINATIONS

I hereby determine that the selected remedy is protective of human health and the environment, complies with
Federal and State requirements that are legally applicable or relevant and appropriate to the remedial
action, and is cost-effective. This remedy utilizes permanent solutions and alternative treatment
technology, to the maximum extent practicable, and satisfies the statutory preference for remedies that

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employ treatment that reduces the toxicity, mobility or volume as a principal element.

Because this remedy will result in hazadous substances remaining on-site, a review will be conducted within
live years after commencement of the remedial action to ensure that the remedy continues to provide adequate
protection of human health and the environment.

Thomas C. Voltaggio, Director Date
Hazardous Waste Management Division
U.S. EPA, Region III

RECORD OF DECISION
BERKLEY PRODUCTS SITE
DECISION SUMMARY

I. SITE NAME, LOCATION AND DESCRIPTION

The Berkley Products Superfund Site ("the Site") is located one and a half miles northeast of Denver,
Pennsylvania, in West Cocalico Township, Lancaster County (Figure 1). Also known as Schoeneck Landfill, the
Site is east of Wollups Hill Road, north of Swamp Bridge Road. The Site is a former "town dump" which covers
about five acres on the crest of a hill, within a larger tract of 21 acres. The Site includes the landfill,
areas where dumping occurred on the so southern slope and the groundwater affected by contamination leaching
from the landfill. The area surrounding the Site is primarily forested residential.

II. SITE HISTORY AND ENFORCEMENT ACTIVITIES

The Site was used as a municipal waste dump from approximately 1934 until 1965. In 1965,
the Lipton Paint Company ("Lipton"), a subsidiary of Berkley Products Company purchased the
property. The operation continued to receive household trash from neighboring communities as well
as paint wastes from Berkley Products Company. The property was closed by Lipton due to a lack of
available fill area and cover material, and covered with soil. Then, in September 1970, the property
was sold to private owners and has been used as a residence since.

Prior to 1965, the dump received paper, wood, cardboard and other domestric trash from the
northeastern corner of Lancaster County. The only commercial wastes identified during that period
were from local shoe companies. Those wastes included leather scraps and empty glue and dye pails.

During the period from 1965 to 1970, different sources estimate that the dump received from
650 to 40,000 gallons of paint wastes from Berkley Products Company. These vestes included
primarily pigment sludges and wash solvents. EPA has learned that the solvenl s were sometimes used
to burn the household trash and that the sludges were disposed of in five gallo pails. Information
gathered about the final yearn of operation of the Site indicates that the municipal trash was dumped
to the south of the access road, toward the hillside, while the paint wastes wer deposited in the
northern part of the dump.

The Berkley Products Company produced paints and varnishes with so vents, ethyl cellulose
resin and pigments with lead oxide and lead chromate. The solvents included oluene, xylene,
aliphatic naphthas, mineral spirits, methyl ethyl ketones, methyl isobutyl ketone ethyl acetate, butyl
acetate, glycol ether, butyl celasol, methyl alcohol and isopropyl alcohol.

This Site was originally investigated by the Pennsylvania Department of Environmental
Resources (PADER) in 1984. In March of that year, PADER completed a "Potential Hazardous Waste
Site Identification" form and the Site was included on EPA's CERCLIS, a list of potentially hazardous
waste sites. A "Preliminary Assessment" was also completed in 1984, by EPA, and the Site was
scheduled for further investigation pursuant to the Comprehensive Environmental Response,
Compensation and Liability Act, as amended, (CERCLA), 42 U.S.C. §§9601 - 9675.

In July 1984, EPA collected field samples that were presented in a "Site Investigation" report
dated March 5, 1986. The information from the Site Investigation was used to core the Site using the
Hazard Ranking System. The Site was nominated for the National Priorities List (NPL) of Superfund
sites in 1986 with a score of 30.00 and was finalized as an NPL site in March 1989. The regulations
enacted pursuant to CERCLA generally require that a Remedial Investigation and Feasibility Study
(RI/FS) be conducted at each NPL site and subsequently, a remedial response action selected to
address the problems identified.

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      During the search for parties potentially responsible for the Site ("Potentially Responsible
Parties" or PRPs),  EPA conducted interviews with former owners, operators ant employees of the Site.
Company records were also obtained and deed information was researched.  That information has
been compiled and reviewed to determine liability and also to estimate types atd quantities of wastes
disposed at the Site and to determine disposal practices during operations.  Based on the findings of
the PRP search, EPA sent Notice Letters to two parties, Berkley Products Company and the landowner
that had purchased the closed landfill.  These Notice Letters identified the parties as PRPs, but waived
the sixty day moratorium, established at CERCLA Sections 122 (a) and 122 (e), negotiate a Consent
Order to perform the RI/FS.  This waiver was issued pursuant to CERCLA Section 122(a).

      EPA initiated the RI/FS in 1990 to identify the types, quantities and locations of contaminants,
to evaluate the potential risks, and to develop and evaluate remedial action alternatives to address the
contamination problems at this Site.  A CERCLA removal action was taken at the Site in October 1991
to address some preliminary findings of the RI.   During the field investigation ot the RI, buried drums
containing paint wastes were uncovered in the northeastern portion of the Site.  This area was
excavated, and 59 drums were overpacked and removed.  Seven drums were overpacked and
removed from the southern slope of the landfill.  An additional 35-foot-long by 5-foot-deep exploration
trench uncovered no additional drums.  A total of 87 drums were removed from the Site.   The wastes
were classified as PCB flammable liquids, solids, and paint solvents.

      The field investigations, data analysis and evaluation of alternatives that comprise the RI/FS
have now been completed for the Berkley Products Site.

III.  HIGHLIGHTS OF COMMUNITY PARTICIPATION

      The information summarized in this Record of Decision (ROD) is available at the public
information repository for this project that has been established by EPA at the West Cocalico Township
Office located at the:

                          West Cocalico Township Office
                          156B West Main Street
                          Reinholds, Pennsylvania
                           (717) 338-8720

      EPA encourages the public to review these collected documents in order to get better understanding
of the Site end the Superfund activities that have been conducted there.

      EPA solicited input from the community on the cleanup plans and methods in the Proposed
Plan.  A formal public comment period for the Proposed Plan lasted from April 7, 1996 to May 7, 1996.
This comment period included a public meeting held on April 17, 1996 at the West Cocalico Township
Office.  At this meeting, EPA presented the results of the RI/FS and discussed EPA's Proposed Plan
and Preferred Alternative for remediation of the Site.

      EPA accepted written comments throughout the comment period and oral comments at the
public meeting.  The major and significant public comments that EPA received on the Proposed Plan
are summarized and addressed in the Community Acceptance discussion contained in Section VIII,
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES, and present and in more detail in the
Responsiveness Summary may included as Attachment 1 of this ROD.

IV.  SCOPE AND ROLE OF RESPONSE ACTION

      In 1991 a removal action was conducted at the Site to address the buried discovered
during the RI.  The drums were excavated and removed as a "principal threat", an area of highly
concentrated waste that could be removed to quickly reduce or prevent the continued migration of
contamination.

      The response action described in this Record of Decision will comprehesively address the
threats posed by the remainder of the Site.  This ROD addresses the landfill which is the source of
contamination and the potential migration of contaminants at the surface and in the groundwater to
provide overall protection of human health and the environment.  This response action is described in
Section IX, SELECTED REMEDY.

V.  SITE CHARACTERISTICS

      The Berkley Products Site is located on the United States Geologic Survery (U.S.G.S.) 7.5
minute series topographic map for Womelsdorf, Pennsylvania  (see Figure 1).   The topography of the
area is characterized by rolling plains, with elevations generally ranging between 400 and 700 feet

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above mean sea level (MSL). Higher ridge tops can reach 1,200 feet above MSL. The region is
dissected by a mature, dendritic drainage pattern. The Site is located on the tail of the east-west-
trending Furnace Hills ridge. Elevations on Site range between 540 feet above MSL along Swamp
Bridge Road to about 640 feet in the landfill area. Landfilling activities on Site have altered the original
topographic surface somewhat. These effects are most pronounced in the main dump area
approximately 400 feet east of Wallups Hill Road.

The ridge continues to rise west of the Site to 780 feet above MSL, approximately 0.8 mile west
of the Site. Topography falls rapidly south and east of the Site and more genlt to the north. The
elevation of Cocalico Creek, approximately 1,000 feet east of the Site, is about 435 feet above MSL
(U.S.G.S., 1977). Cocaiico Creek is a perennial stream that flows southward past the Site. The
stream's headwaters are approximately 1.5 miles west and north of the Site at gbout 580 feet above
MSL. In this upstream area, Cocalico Creek is classified by the Pennyslvania Department of
Environmental Protection (PADEP) as a high-guality, warm-water fishery (Pennsylvania Code, Title 25,1991).

The Berkley Products Site lies within the Triassic Lowlands Section of the Piedmont
Physiographic Province. This section is expressed as an uplifted plain formed of relatively soft, red
sandstone and shale. Higher ridges mark the locations of lenses of hard guartz conglomerate or of
sheets or dikes of define igneous intrusive rock (Geyer & Boles, 1987).

The Triassic age rocks of-the region lie within the Newark Gettysburg uesin. Sedimentary
rocks along the south end southeast margin of the Newark Gettysburg Basin rest on an erosionel
contact with the older structural complex of Lower Paleozoic guartzites and carbonates and locally
upon Precambrian gneiss, granite, and metabasalt. Sediments in the basin dip to the north and
northwest in a simple, homoclinal structure. A major fault system occurs along the northern margin of
the basin. Downward movement along this fault system formed the basin complex. Minor cross
faulting offset some of the rock layers.

Bedrock beneath the Site is composed of interbedded units of sedimentary rock including
conglomerate, sandstone, siltstone, and shale. Collectively, these units are referred to as the
Gettyburg Formation (Richardson, 1990; Glaeser, 1968). An intrusive diabase dike is also present in
the area. The various sedimentary layers of the Gettysburg Formation were laid down as sheets or
beds in ancient meandering stream, river, and lake environments and are differentiated into bedding
planes. These bedding planes have been rotated over time into an east-west orientation with an
approximately 35 degree dip to the north. Some of the bedding planes have separated into bedding
plane fractures. Oriented perpendicularly to the bedding planes are joint crack that interconnect the
bedding plane fractures. The degree of jointing is dependent on the thickness and brittleness of the
sedimentary beds.

Siltstone and sandstone are the dominant rock types regionally, although they underlie only
about 35 percent of the landfilled area of the Site. Grain size ranges from very fine to coarse. Color
varies from brown to light gray, with red and brown being the most freguently Encountered colors
during drilling at the Site. Siltstones and sandstones are composed principally of angular to
subrounded colorless guartz grains. The degree of sorting of the sandstones and Siltstones decreases
with increasing grain size. These units are moderately well bedded, with thin to flaggy beds. Joints
are moderately developed and abundant and are both open and filled with guartz, hematite, and
calcite. The joints have a blocky pattern and an uneven regularity and are closely spaced (Geyer &
Wilshusen, 1982).

The guartz conglomerate members of the Gettysburg Formation underlie approximately 60
percent of the landfilled portion of the Site, predominantly along the top of the ridge at the Site's
northern edge. The conglomeratic members are composed of pebbles and cobbles of guartz,
guartzite, and sandstone. The conglomerates are densely to sparsely distributed in bands and lenses
ranging from 1 to 2 inches to many feet in thickness. Cobbles up to 5 to 6 inches in diameter occur in
some of the thickest beds. The conglomerates are usually thick bedded and occasionally massive.
They are well cemented, with some interbedding with minor beds of sandstone. The sandstone beds
range in thickness from 1 to 2 inches to a foot or more. Joints in the conglomeratic members have a
blocky pattern, are moderately developed, moderately abundant, regularly spaced, open, and steeply
dipping.

The overall thickness of the Gettysburg Formation in the area is approximately 9,400 feet. The
thickness of individual lithologicai units (e.g., shale/mudstone, siltsone, sandstone, and conglomerate)
varies from 0 to more than 100 feet beneath the Site. The thickness and distribution of sandstone and
mudstone are variable throughout the Site. The top soil is composed of silty to sandy clay. The
thickness of top soil in the study area varies from 0 to 5 feel

A north-south-trending diabase dike cuts across the lithology underlying the Site, mostly west

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of the landfill area. This unit underlies approximately five percent of the known landfill area. The
diabase is dark gray to black, dense, and very fine grained. It consists of 90 to 95 percent labradorite
and augite minerals. Joints have a blocky pattern, are well developed, moderately abundant, regularly
and moderately space, open, and steeply dipping. Where the dike contacts the Gettysburg
Formation, the sedimentary rock have been thermally metamorphosed to a dark purple to black
argillite. Thermal metamorphism may extend to a distance of several feet (Geyer & Wilshusen, 1982;
Glaeser, 1966). Fracturing in the Gettysburg Formation may be locally enhanced by the intrusion of
the diabase.

The main tectonic feature in the vicinity of the Site is an east-west fault. This is a reverse fault
located approximately 0.3 mile north of the Site (Gleeser, 1966; Richardson 19g )). This tectonic
movement may have caused the displacement of the north-south diabase dike. An additional complex
of reverse faults are 1.0 mile west of the Site. EPA's Environmental Photograph c Interpretation Center
(EPIC) performed a fracture-trace analysis of aerial photographs in the Site vicinity. Fracture traces are
linear surface features that may represent the surface expression of large regional fractures systems.
No fractures traces were found to be on Site (Richardson, 1990).

Groundwater flow in the bedrock aguifer is primarily restricted to movement along the bedding-
plane fractures and joints. The intergranular porosity, where present, also contributes to groundwater
movement and storage but contributes more to the storativity of the aguifer than to flow. Wells in the
Gettysburg Formation in Lancaster County range in depth from 43 to 235 feet, with a median depth of
105 feet. In general, the well yields in the bedrock are a function of the density of joints penetrated by
the well. The yields of these wells range from 5 to 94 gallons per minute (gpm) with a median yield
of 16 gpm.

Although no known wells are installed in the diabase in the study area, data are available for
wells in the database in other areas of Lancaster County. Those wells range in depth from 27 to 400
feet, with a median depth of 122 feet. The well yields range from 3 to 15 gpm. The median well yield
is 10 gpm. The narrow metemorphosed zones directly adjacent to the diabase instrusion are anticipated to be
well fractured and may contribute to high yielding wells.

Groundwater flow in the Gettysburg Formation is believed to be controlled by the combination of the
bedding planes' fracture strike and dip directions. The horizontal flow direction in the bedrock aguifer at
the Site is along strike to the east toward Cocalico Creek. Vertically, the flow direction is downward
following the northern dip direction. These two combined flow directions impart an overall flow direction
downward from the Site to the northeast. Groundwater in the area discharges to Cocalico Creek.

The Berkley Products Site is approximately 1,000 feet west of Cocalico Creek. The headwaters of
Cocalico Creek are in the valley south of South Mountain near Blue Lake. The valley is located a few miles
north of the Site. Conestoga Creek, along with its tributaries, Muddy Creek, Little Conestoga Creek, and
Cocalico Creek, drains the northeastern and north-central portion of Lnacaster County and eventually enters
the Susguenhanna River. Regionally, significant amounts of groundwater may be discharging into Cocalico
Creek along the eest-west fault plain mentioned above. Seasonally, wet springs located immediately north of
the Site discharge into Cocalico Creek to the north. On the southern side of the Site, a seep is located on
the slope of the landfill material. EPA believes that flow within this seeps is related to rain events.

The land use in the immediate vicinity of the Site is rural in nature. The Site is near dense
woods and several single family homes. A few open areas have been converted into farm land by the
local residents. During the groundwater sampling of April 1993, two new houses immediately north of
landfill were sampled.

VI. NATURE AND EXTENT OF CONTAMINATION

Investigation

The nature and extent of contamination at the Berkley Products Site have been characterized
during the Remedial Investigation through soil sampling during a test pitting program, multiple rounds
of groundwater sampling, surface water and spring sampling, soil sampling, and leachate sediment
sampling. Samples collected in 1990 and 1991 were analyzed for the full-scan Priority Pollutant List
(PPL) compounds. Samples collected in 1993 were analyzed for the full scan a Target Compound List
(TCL) organic and Target Analyte List (TAL) inorganics. The TCL and TAL are nore inclusive than the
PPL, and all PPL compounds are included as part of a TLC/TAL analysis.

The test pitting program consisted of excavating eight test pits (TP-1 through TP-8) across the
Site in March 1991 (see Figure 2). The test pits were excavated to a depth of to 12 feet and were 19
to 22 feet long and 2 to 5 feet wide. Locations for the test pits were selected based on the results of
geophysical and soil gas surveys. Sets of samples were collected on each end of the test pits; at the

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surface, at depths of 5 feet and at the deepest point of the excavation. In addition, up to two
additional samples were obtained from each half of the test pit where special concerns or materials
were encountered. A total of 55 soil samples were obtained from the test pits; nd were analyzed for a
full scan of PPL. Sixteen of the 55 samples were surface soil samples. Also, two of the 55 samples
were background surface and subsurface soil samples.

Additional soil sampling, surface water and sediment sampling, and leachate sediment sampling also
occurred at the Site. Surface water/sediment samples were collected from seven locations (SW/SD-1 through
SW/SD-7) along Cocalico Creek and its tributaries north, northeast, and southeast of the Berkley Products
Site (Figure 3). Four additional surface water/sediment samples (SW-8/SD-8 through SW-ll/SD-11) were
collected from small springs located on the north-facing slope of the hill north of the landfill. Runoff
from these springs ultimately discharges to Cocalico Creek.

Surface soil samples were collected from the Berkley Products Site during three separate events. During
the first event, 11 soil samples (S-l through S-ll) were collected during the soil gas survey to confirm the
results of the soil gas survey (see Figure 4). One of the 11 samples was from the east leachate seep, and a
background soil sample was also obtained. These samples were collected from a depth of 1.5 to 3.0 feet below
ground surface and were analyzed in the field using a portable gas chromatograph (GC). The confirmation soil
samples were analyzed for selected volatile organics [trichloroethene (TCE), benzene, tetrachloroethene
(PCE), toluene, ethylbenzene, o-xylene, styrene, and m-xylene]. During the second event, 16 surface soil
samples were collected as part of the test pitting program as previously noted. The third event involved a
leachate sediement sample (LD-1) from the east leachate seep and two downgradient surface soil samples (SO-1
and SO-2) in the apparent surface drainage direction from the east leachate seep (see Figure 5). These
samples were analyzed for full-scan PPL.

Thirteen monitoring wells were installed in clusters at five locations during the RI at the Site (see
Figure 5) . Each well cluster consisted of shallow, intermediate, and deep wells (S, I and D) , except for
Cluster Nos. 3 and 4 which do not have a deep well. A total of 13 monitoring wells were installed.
Groundwater sampling consisted of three rounds of residential well sampling and two rounds of monitoring well
sampling. A total of 17 residential wells were sampled at least once during the three rounds of residential
well sampling (Figure 8).

The first round of groundwater sampling in 1990 consisted of 11 samples from residential wells that were
analyzed for the full-scan PPL. The second round of groundwater sampling in 1991 included 13 monitoring well
samples and 8 residential well samples that were also analyzed for the full scan PPL. The third round of
groundwater sampling in 1994 included 13 monitoring wellse and 11 residential well samples. The third round
of groundwater samples was analyzed for TCL and TAL substances. A copy of all analytical data is provided in
Appendix K (Volume III) of the RI Report. Prior to the last round of groundwater sampling in 1993, EPA
reguired that the sampling at monitoring wells at Cluster No. 4 include sampling for potential dense
non-agueous phase liguid (DNAPL). Both wells (MW-4S and MW-41) at this cluster were sampled prior to purging
for DNAPLs and after purging for routine sampling.

For evaluation and cost estimation purposes the volume of waste contained in the landfill was estimated.
Using the two elements of the landfill, the plateau and toe as outlined in Figure 2, separate
volumes were calculated and added together for a combined total volume estimate of 103,331 cubic yards. The
estimation of the extent of the two elements of the landfill was based on aerial photographic analysis, as
well as visual observations of trash on the surface, in the subsurface while auguring the boreholes for the
soil gas survey, and during the test pitting operations. The surface area of the plateau of the landfilled
area was estimated to be 17,055 sguare yards, and the southern slope - 4,700 sguare yards.

Results

Surface Soils

The first round of surface soil samples was analyzed for selected volatile organics (TCE, benzene, PCE,
toluene, ethylbenzene, o-xylene, styrene, and m-xylene). The soil sample S-ll, which is considered
background, did not show any of these parameters (see Table 1). Samples S-l, S-2, S-3, and S-7 indicated
detectable concentrations of volatile organics; the results from all other locations were below detection.
The locations of samples S-l, S-2, S-3, and S-7 correspond to the locations of test pits TP-4, TP-5, TP-6,
and TP-1, respectively.

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The highest levels of most of the organic compounds were detected at sample location S-l. This location
corresponds with TP-4, located in the north-central portion of the landfill. The contaminants found at S-l
included toluene (18,000 ug/kg), ethylbenzene (54,000 ug/kg), o-xylene and styrene (52,000 ug/kg), m-xylene
and p-xylene (14,000 ug/kg). Other locations yielded relatively lower levels of organic contaminants. These
results indicate agreement with the Site historical data and information that paint solvents were disposed in
the northern area of the landfill.

The second round of surface soil samples consisted of 16 surface soil samples collected during the test
pitting program and analyzed for full scan PPL. In the third round, two surface soil samples were collected
downgradient of the leachate seep during the same period the surface water and sediment samples were
collected and analyzed for full scan PPL.

The maximum concentrations from the 16 surface soil samples and two surface soil samples collected
downgradient of the leachate seep are presented in Table 2. The results from these analyses were similar to
those of the first round of sampling: Trace to low levels of volatile organics were detected in shallow soil
samples (0 to 6 inches) collected from the test pit areas. TAL analysis indicated the presence of a spectrum
of inorganic contaminants also present in the landfill materials.

Semivolatiles such as benz(a)anthracene, benzo(a)fluoranthene, benzo(g,h,i)perylene,
benzo(k)fluoranthene, bis(2-ethylhexyl) phthalate, and chrysene were observed only in the central
portion of the landfill.

Subsurface Soils

Subsurface soil samples were collected from eight test pits at depths of 5 feet or greater. From each
test pit, four or more subsurface soil samples were collected. Subsu face soil samples were collected from
each half of the test pit at a depth of 5 feet and 10 feet below ground surface. The collected samples were
tested for TCL and TAL contaminants. Detailed descriptions of detected organic parameters are provided in
Volume III, Appendix K of the EPA RI Report and are summarized in Table 3.

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                                                             TABLE 1
                                                 FIELD ANALYTICAL DATA SUMMARY;
                                                  SURFACE SOIL SAMPLES  (UG/KG)
                                                 BERKLEY PRODUCTS, PENNSYLVANIA

       Sample Location           S-l       S-2  (DL)    S-3  (DL)    S-4   S-5  S-6   S-7  (DL)  S-8   S-9    S-10    S-ll    Blank

    Analyte
    TCE
    Benzene                                                                           74.00
    PCE
    Toluene                   18,000.00                                              360.00
    Ethylbenzene              54,000.00        240        58.00
    o-Xylene and Styrene      52,000.00        280
    m-Xylene and p-Xylene     14,000.00       1200       240.00

See Appendix D in Volume II of the EPA RI report for the complete analytical data set with qualifiers.

(DL) - Diluted analysis see referenced RI report for complete database.

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                             TABLE  2
              SURFACE  SOIL  DATA EVALUATION (MG/KG)
                 BERKLEY  PRODUCTS,  PENNSYLVANIA
CHEMICAL
                     MAXIMUM ON-SITE
                          SURFACE
                                               MAXIMUM BACKGROUND
Aluminum ( 1 )
Arsenic (1)
Barium
Beryllium(l)
Cadmium
Calcium
Chromium ( 1 )
Cobalt
Copper
Iron
Lead
Magnesium
Manganese (1)
Mercury
Nickel
Potassium
Silver
Sodium
Vanadium
Zinc
Cyanide
4-Methyl-2-Pantanone
Xylenes
Ethylbenzene
2-Butanone
1,1,1-TCA
Toluene
14,600 4,080
3.3 07
275 36.5
1.4 *
0.06
4,000 NR
149 4.8
16 3.3
106 7
79,600 4,300
143 18.3
4,130 NR
1,970 150
0.53
33.1 4.6
1,890 NR
2.2
160 NR
29.9
328 19
10.7
1.6
.057
.009
.17
.047
1.1

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TABLE 2
SURFACE SOIL EVALUATION  (MG/KG)
BERKLEY PRODUCTS, PENNSYLVANIA

                  CHEMICAL
               PCE

               TCE

               Bis(2-ethylhexyl) phthalate

               Benzole acid

               Phenol

               Acenaphthylene

               Benz(a)anthracene

               Benzo(b)pyrene(1)

               Benzo(b)fluoranthene

               Benzo(g,h,i)perylene

               Benzo(k)fluorenthene
MAXIMUM ON-SITE
    SURFACE

     .007

     .007

      5.4

      .32

      1.8

      .11

      .44

      .58

      .48

      .39

      .34
                                                                    MAXIMUM BACKGROUND
.528

 1.6
               Chrysene

               Dibenz(a,h) anthracene

               Fluorathene

               Indeno  (1,2,3-c,d)pyrene

               Phenanthrene
       .5

      .18

      .34

      .29

     .099
               Pyrene

               Di-n-butyl phthalate

               4,4'-DOT

               Dieldrin(l)

               Aroclor 1254 (1)
      .69

     .036

     .049

     .049

     .027
 3.034
    *    Qualified; questionable qualitatively; unusable
    NR   Result not reported by laboratory
    (1)   Chemical of potential concern  (COPC)

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                               TABLE 3
                  SUBSURFACE SOIL DATA EVALUATION
                   BERKLEY PRODUCTS, PENNSYLVANIA
        CHEMICAL
                        MAXIMUM CONCENTRATION
                               (mg/kg)
Acetone                        2,400
2-Butanone                    19,000
1,1,1-TCA                       63
TCE                            490
1,1,2-TCA                       31
Benzene                         87
4-Methyl-2-pentenone          11,000
PCE                             450
Toluene                       20,000
Ethylbenzene                  1,100
Xylenes                        4,600
1,2-Dichloroethene             0.012
Benzyl alcohol                  13
2-Methylphenol                  7 . 3
Isophorone                      3.7
Naphthalene                     11
Dibutyl phthalate               28
Bis(2-ethylhexyt) phthalate    1,300
4-Methylphenol                  23
4-Chloro-3-methylphenol        0.84
Acenapthylene                  0.54
Chlorobenzene                  0.055
Phenanthrene                    4 .3
Anthracene                     0.88
Fluoranthene                    4 .5
LOCATION OF MAXIMUM
   CONCENTRATION

       TP1A5
         0
       TP1A5
       TP1B5
       TP1B5
       TP1A5
       TP1B5
       TP1B5
       TP1B5
       TP1B5
       TP1B5
       TP3B4
       TP1A4
       TP1A4
       TP1B3
       TP1A5
       TP1B3
       TPSA4
       TP6B3
       TP4A2
       TP7A3
       TP8B2
       TP7A3
       TP7A3
       TP7A3

-------
TABLE 3
SUBSURFACE SOIL DATA EVALUATION
BERKLEY PRODUCTS, PENNSYLVANIA

              CHEMICAL                MAXIMUM CONCENTRATION         LOCATION OF MAXIMUM
                                             (mg/kg)                   CONCENTRATION

        Pyrene                                 3.4                        TP7A3
        Butylbenzyl phthalate                 0.13                        TP7A2
        Benz(a)anthracene                      2.7                        TP2A2
        Chrysene                               2.4                        TP2A2
        Benzo(b)fluoranthene                   4.2                        TP2A2
        Benzo(k)fluoranthene                   1.6                        TP7A3
        Benzo(a)pyrene                         2.4                        TP2A2
        Indeno(l,2,3-c,d)pyrene                1.3                        TP2A2
        Benzo(g,h,i)perylene                   1.4                        TP2A2
        Phenol                                 3.9                        TP4B3
        1,4-Dichlorobenze                      1.9                        TP4A2
        Benzole acid                           1.4                        TP4B3
        2-Methylnaphthalene                    0.83                       TP4A2
        Dioctyl phthalate                      0.46                       TP8B2
        Diethyl phthalate                       4                         TP6B4
        Beta-HCH                               0.046                      TP1B5
        Dieldrin                               0.044                      TP5B2
        Endrin                                  14                        TP1A6
        Endosulfan II                           4                         TP1A6
        Endosulfan sulfate                     0.07                       TP1B2
        DOT                                    0.2                        TP8B3
        ODD                                    0.68                       TP3A2
        Aroclor 1254                           140                        TP1A6
        Aldrin                                 0.053                      TP4A2
        DDE                                    0.053                      TP6B4
        Methoxychlor                           0.35                       TP3B4

-------
TABLE 3
SUBSURFACE SOIL DATA EVALUATION
BERKLEY PRODUCTS, PENNSYLVANIA

                  CHEMICAL            MAXIMUM CONCENTRATION            LOCATION OF MAXIMUM
                                           (mg/kg)                        CONCENTRATION

        Endrin ketone                       0.02                             TP2A2
        Aroclor 1248                        4.6                              TP6A4
        Heptachlor epoxide                 0.056                             TP3B4
        1,1 -Dichloroethene                0.049                             TP8B2
        N-nitroso-diphenylamine             0.22                             TP6A2
        Dibenz(a,h)anthracene               0.31                             TP7A3
        Acenaphthene                        0.33                             TP7A3
        Dibenzofuran                        0.47                             TP7A3
        Fluorene                            0.6                              TP7A3
        Aluminum                          14,400                             TP5A3
        Arsenic                              8                               TP1A4
        Barium                              298                              TP5A3
        Beryllium                          11.9                              TP6B4
        Cadmium                            15.3                              TP5B2
        Chromium                            538                              TP5B2
        Cobalt                             20.5                              TP2B3
        Copper                             237                               TP5A2
        Iron                             101,000                             TP6B3
        Lead                               770                               TP2A3
        Manganese                         1,800                              TP2B3
        Mercury                            3.1                               TP5A2
        Nickel                             533                               TP6B4
        Silver                              5                                 TP6A4
        Vanadium                           76.6                              TP5B3
        Zinc                              1,950                              TP2A2
        Cyanide                            39.5                              TP1B5

-------
Measurable levels of volatile organics were detected in all test pits. Based on the review of
volatile organic data, it can be seen that the predominant area for solvent [volatile organiic compound
(VOC)] disposal appears to have occurred near TP-1 (northeastern corner of the landfill), and TP-6 and
TP-3 (center of the lendfill). TP-1 clearly indicates a "hot spot" area of a high concentration of VOCs.
TP-1 consistently provided samples with the highest level of VOCs and is the area where 59 drums
were excavated end removed from the Site.

The following summarizes the highest level of several VOCs (all highest levels found in TP-1):

Acetone 2,400 mg/kg
Benzene 87 mg/kg
Ethylbenzene 1,100 mg/kg
2-Butanone 19,000 mg/kg
1,1,1-TCA 63 mg/kg
1,1,2-TCA 31 mg/kg
4-Methyl-2-Pentanone 11,000 mg/kg
PCE 450 mg/kg
Toluene 20,000 mg/kg
TCE 490 mg/kg
Xylene (Total) 4,600 mg/kg

High levels of VOCs were also found in TP-3 and TP-6. However, the detected levels were generally a
magnitude or more lower than in TP-1.

Several semivolatile compounds were detected in subsurface soil samples at various locations
within the landfill. The highest and most freguent detections were observed at TP-1, TP-3, TP-6, and
TP-7. TP-1, TP-3, and TP-6 also have correspondingly high levels of volatile of organics. TP-1
consistently showed the highest levels of Semivolatiles, which correspond with the high level of VOCs
at that location. Polycyclic aromatic hydrocarbons (PAHs) were highest in TP-2.

Bis(2-ethylhexyl) phthalate is the most widespread semivolatile contaminant detected at the
Site, with significant concentrations in all the test pit locations. The detected concentration range up
to 1,300 mg/kg. The highest concentration of this compound were found in the south-central portion
of the landfill; the maximum concentration was detected in TP-8. Concentrations above 1,000 ug/kg
were detected at all test pit locations. Other phthalates (Dibutyl phthalate, Dioctyl phthalate, Diethyl
phthalate, and butyl benzyl phthalate) were also detected throughout the landfill. PAHs and phthalates
tend to adsorb onto soil end migrate slowly. Because of these factors and thei low solubility in water,
leaching to groundwater is usually less of a concern than with VOCs.

PCBs were detected in all teat pits except TP-7. The highest levels of PCBs were 4.6 mg/kg
(Aroclor 1248) in TP4 and 140 mg/kg (Aroclor 1254) in TP-1. Several chlorinated pesticides were
detected throughout the landfill with no clear pattern of distribution. PCBs and pesticides tend to
adsorb onto soil and migrate slowly in this medium. They tend to bioconcentrate significantly in
environmental receptors.

Several inorganic were detected in several locations in all the test pits. The highest
concentrations were detected predominantly in TP-5 and TP-6. The highest concentrations of selected
inorganic substances are presented below.

Aluminum 14,400 mg/kg
Arsenic 8 mg/kg

Beryllium 11.9 mg/kg
Cadmium 15.3 mg/kg
Chromium 538 mg/kg
Manganese 1,800 mg/kg
Mercury 3.1 mg/kg
Nickel 533 mg/kg
Vanadium 76.6 mg/kg

Surface Water, Sediment, and Spring Samples

From each sample location designated in Figure 3, a surface water and a sediment sample was collected.
With the exception of sample locations 8, 9, and 10 (located springs immediately north of the landfill) all
surface water and sediment samples collected from the Berkley Products Site were tested for the full-scan
organic and inorganic analysis. At locations 8, 9, and 10, the solid (sediment) samples were collected for
full scan of inorganic and organic analysis but there were only sufficient sample volumes for volatile

-------
organics analysis of the water. The sample locations 6, 5 and 4 were determined to be upstream of the Site,
while the sample locations 3, 2, 7 and 1 are the downstream locations.

A comparison of maximum downstream surface water data to upstream data is included in Table 4. Cadmium
(1.2 ug/1), silver (2 ug/1), lead (3.6 ug/1), 2-Butanone (0.7 ug/1) and 1,1,1-TCA (0.7 ug/1) were detected in
downstream samples and not the upstream samples. Barium (82.3 ug/1) and manganese (139 ug/1) were also
detected in downstream samples at levels slightly above upgredient concentrations. All levels detected in
downgradient agueous samples were below risk-based concentrations. Risk-based concentrations are
concentrations corresponding to acceptable risks according to the NCP and are used to screen out chemicals
that would not contribute significantly to risk. Because the VOC chemicals tend to evaporate rapidly from
surface media, these limited findings are not unexpected.

A comparison of maximum downstream sediment data to upstream sediment data is included in Table 5.
Although 2-Butanone, indeno(1,2,3-c,d)pyrene, 4-methylphenol, Butylbenzyl phthalate, phenol, aluminum,
arsenic, barium, beryllium, chromium, cobalt, copper, manganese, nickel, vanadium, and zinc are at slightly
higher levels in the downstream sample, it was determined that downstream sediment concentrations were not
significantly higher than the upstream conditions. Additionally, the downstream levels are below the human
health risk-based concentrations.

The maximum surface water sample data from the four springs located north of the landfill are presented
in Table 6. VOC analysis from the four samples revealed 2-Butanone and carbon disulfide. All levels were
below risk-based concentrations.

A comparison of the maximum sediment data from the four springs to the background soil data and upstream
sediment data is included in Table 7. Aluminum (11,400 mg/kg), arsenic (4.4 mg/kg), beryllium (1.2 mg/kg),
and manganese (1,220 mg/kg) have been detected above background levels and at levels of concern. Organic
compounds detected at levels above background and upstream sediment samples are 2-hexanone, 2-butanone,
toluene, phenol, 4-methylphenol, 2-methylplenol, and acetone. The concentrations of organic compounds are
all below risk-based concentrations. These springs lie north of the landfill and between the landfill and
Cocalico Creek.

The sediment analytical data from the east leachate seep are included in Table 8. The inorganic
compounds arsenic (1.6 mg/kg), beryllium (0.59 mg/kg), and chromium (48.5 mg/kg) were detected above
background concentrations and at levels of concern. Also detected were 2-butanone, bis(2-ethylhexyl)
phthalate, chloromethane, and di-n-octyl phthalate, but at levels below risk-based concentrations.

-------
                            TABLE 4

               STREAM SURFACE WATER DATA EVALUATION  (ug/L)
                   BERKLEY PRODUCTS, PENNSYLVANIA
    CHEMICAL
                         MAXIMUM
                        DOWNSTREAM
                   RANGE
                  UPSTREAM
INORGANICS

barium
cadmium
calcium
copper
iron
lead
magnesium
manganese
mercury
potassium
silver
sodium
cyanide

ORGANICS
 82.3
  1.2
20,300
 19.4
1,310
 3.6
4,180
 139

1,720
  2
7,180
 11
  64.3 to 68.7

19,800 to 24,300
       19.7
   425 to 490

 3,170 to 3,990
  65.6 to 86.9
      0.21
1,1190 to 1,700

 5,600 to 8,270
    ND to 11.9
2-butanone
1,1,1-TCA
phenol
1,2,-dichloroethene
 0.7
 0.7
                     23
        ND = Not Detected
        No COPC  (Chemical of potential concern)

-------
                            TABLE 5
               STREAM SEDIMENT DATA EVALUATION  (mg/kg)
                  BERKLEY PRODUCTS, PENNSYLVANIA

       CHEMICAL             MAXIMUM             RANGE
                           DOWNSTREAM           UPSTREAM

INORGANICS

Aluminum                    13,600            1,380 to 5,130
Antimony                                          3.7
Arsenic                      1.9                    1.3
Barium                       196               27.7 to 93.4
Beryllium                    0.77               0.43-0.56
Calcium                     1,810               323 to 1,520
Chromium                    15.7                2.6 to 8.5
Cobalt                       9.2                1.2 to 4.2
Copper                       5 . 9
Iron                        13,800            2,240 to 6,030
Lead                        17.8                3.5 to 13
Magnesium                   2,280               282 to 1,650
Manganese                    335                 150 to 262
Nickel                      14.6                3.5 to 4.5
Potassium                   1,040               134 to 311
Sodium                      94.3                   68.5
Vanadium                    28.3                  4 to 13.6

Zinc                        52.4                 11 to 27.4
ORGANICS

2-butanone                  .019                   .018
Toluene                                        .002 to .048
Bis(2-ethylhexyl)phthalate  .078               .038 to 0.1
Benzo(a)anthracene          .062                   .09
Benzo(a)pyrene               .05                  .068
Benzo(b)fluoranthene        .079                   0.1

-------
TABLE 5

STREAM SEDIMENT DATA EVALUATION  (mg/kg)
BERKLEY PRODUCTS, PENNSYLVANIA

           CHEMICAL                MAXIMUM                RANGE
                                 DOWNSTREAM             UPSTREAM

    Chrysene                       .074                    .097
    Fluoranthene                   .055                    .180
    Index(l,2,3-c,d)pyrene         .052                    .050
    Phenanthrene                   .041                     .14
    Pyrene                         .082                     .12
    4-Methylphenol                   .44
    Butylbenzyl phthalate            .12
    Phenol                           .11

    No COPC  (Chemical of potential concern)

-------
                                   TABLE 6
                 SPRING SURFACE WATER DATA EVALUATION (ug/L)
                       BERKLEY PRODUCTS, PENNSYLVANIA

            CHEMICAL         SW8      SW9     SW10      SW11

 INORGANICS

Aluminum                      N/A      N/A      N/A     4,660
Antimony                      N/A      N/A      N/A
Arsenic                       N/A      N/A      N/A
Barium                        N/A      N/A      N/A       134
Beryllium                     N/A      N/A      N/A       1.6
Cadmium                       N/A      N/A      N/A
Calcium                       N/A      N/A      N/A     9,390
Chromium                      N/A      N/A      N/A      15.5
Cobalt                        N/A      N/A      N/A
Copper                        N/A      N/A      N/A      19.1
Iron                          N/A      N/A      N/A     6,500
Lead                          N/A      N/A      N/A
Magnesium                     N/A      N/A      N/A     3,460
Manganese                     N/A      N/A      N/A       109
Mercury                       N/A      N/A      N/A
Nickel                        N/A      N/A      N/A
Potassium                     N/A      N/A      N/A     1,090
Selenium                      N/A      N/A      N/A
Silver                        N/A      N/A      N/A
Sodium                        N/A      N/A      N/A     4,860
Thallium                      N/A      N/A      N/A
Vanadium                      N/A      N/A      N/A
Zinc                          N/A      N/A      N/A      37.5
Cyanide                       N/A      N/A      N/A
ORGANICS
2-Butanone                                       1
Carbon disulfide                       17

   N/A = Not analyzed
   No COPC  (Chemical of potential concern)

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                                    TABLE 7
                        SPRING SEDIMENT DATA EVALUATION
                         BERKLEY PRODUCTS, PENNSYLVANIA
                                     (MG/KG)
CHEMICAL

INORGANICS
Aluminum (1)
Arsenic(2)
Barium
Beryllium(2)
Cadmium
Calcium
Chromium
Cobalt
Copper

Iron
Lead
Magnesium
Manganese(3)
Nickel
Potassium
Sodium
Vanadium
Zinc
Cyanide
ORGANICS
2-Hexanone
2-Butanone
Toluene
Bis (2-ethylhrxyl)phthalate  .098
:iMUM SPRING
.EDIMENT

11,400
4.4
149
1.2

2,370
25.3
11.7
26.8
22,700
41.1
1,610
1,220
16.2
768
80
38.9
118
.004
.03
.21
MAXIMUM
BACKGROUND
SOIL.
4,080
0.7
38.5

0.06
NR
4.8
3.3
7
4,300
18.3
NR
150
4.6
NR
NR

19



MAXIMUM
UPSTREAM
SEDIMENT
5,130
1.3
93.4
0.56

5,520
8.5
4.2

6,030
13
1,650
262
4.5
311
68.5
13.6
27.4

.016
.048
.528
                .1

-------
TABLE 7
SPRING SEDIMENT DATA EVALUATION
BERKLEY PRODUCTS, PENNSYLVANIA  (MG/KG)
                        MAXIMUM SPRING
                          SEDIMENT
CHEMICAL

INORGANICS  (continued)

Enzoic acid
Phenol                      .140
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Chrysene
Fluoranthene
Indeno(1,2,3-c,d)pyrene
Phenanthrene
Pyrene
Di-n-butyl phthalate
4-Methylphenol              .83
2-Methytphenol              .83
Acetone                     .14
 MAXIMUM
BACKGROUND
  SOIL
  1.600
  3.034
MAXIMUM
UPSTREAM
SEDIMENT
                  .1
                  .04
                  .097
                  .18
                  .05
                  .14
                  .12
   NR = Result not reported by laboratory
    (1)    COPC SD-9
    (2)    COPC for all sediment simple locations
    (3)    COPC for SD-8 and SD-10
   COPC  (Chemicll of potential concern)

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                        TABLE 8
          LEACHATE SEDIMENT DATA EVALUATION  (mg/kg)
             BERKLEY PRODUCTS, PENNSYLVANIA

     CHEMICAL          LD-1        MAXIMUM BACKGROUND

INORGANICS
Aluminum
Arsenic (1)
Barium
Beryllium (1)
Cadmium
Calcium
Chromium ( 1 )
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Nickel
Potassium
Sodium
Vanadium
Zinc
ORGANICS
2-Butanone
7,120
1.6
209
0.59

4,240
48.5
8.4
8
64,000
17.8
2,180
393
16.4
1,200
247
18.4
112

.016
4,080
0.7
36.5

0.06
NR
4.8
3.3
7
4,300
18.3
NR
150
4.6
NR
NR

19


Bis(-ethylhexyl)       3.3              .528
phthalate
Chloromethane         .001
Di-n-octyl phthalate   .19

      NR= Results not reported by laboratory

      (1) Chemical of potential concern  (COPC)

-------
Groundwater Data

The groundwater analytical data are included in Tables 9, 10, and 11. The maximum groundwater
analytical data from on-site monitoring wells MW-2, MW-3, and MW-4 are compared to the background walls at
the MW-1 cluster from the two rounds of monitoring well sampling in Table 9. The data show the extensive
range of organic and inorganic compounds detected in the wells directly adjacent to the landfill. MW-4s and
MW-41 were sampled from the bottom of the well before they were purged to test for the presence of DNAPL
This analytical data set from the samples collected prior to purging is also presented in Table 10. A
suspected DNAPL sample was collected from the two wells.

The maximum groundwater analytical data set from the three rounds of home well sampling (1990,
1991, 1993) is included in Table 11. Results from the background monitoring wells (filtered) MW-1/91 and
MW-1/93 are also shown. Analytical results indicate that groundwater in residential water supplies appears
to be virtually free of any organic contaminants. Inorganics and metals were identified in all well
samples, including those hydrologically upgredient of the Site. However these results were found to be
inconsistent between rounds. In cases where notable levels were observed, follow-up sampling often failed
to confirm earlier results. EPA believes that some of the metals may be attributed to natural sources
(minerals), and others may be associated with the home well systems (piping, solder, pumps, etc.).

Considering the lack of organic compounde, the hydrogeology of the area, and the low level and
sporadic concentrations (i.e. observed during one sample round but not observed during another) of metals
recorded In the residential wells, EPA has determined that the residential wells are not being impacted by
the Site.

Contaminant Fate and Transport

At the Berkley Products Site, the past disposal practices have resulted in the release of
contaminants to the fill materials and soils throughout the landfill. These contaminants may be migrating
from the landfill into environmental media and pose potential threats. Using information
developed during the RI, an assessment of contaminant fate and transport was performed to identify
how potential contaminant migration could pose threats to human health and the environment.
Because the analytical and hydrogeologic information developed during the RI was limited, it is not
possible to prepare quantitative estimates of contaminant migration.

Based on landfill measurements, EPA has calculated that approximately 103,300 cubic yards
of materials are present in the landfill; these materials are contaminated by a variety of organic and
inorganic constituents. Contaminated soil and fill materials are continuing sources of VOCs, SVOCs,
PCBs, and metals to other environmental media.

Factors that influence the migration of major contaminant groups (VOCs, SVOCs, PCBs and
metals) include the contaminants chemical and physical properties (e.g., solubilities, adsorption
coefficients, vapor pressure, partitioning coefficients, etc.); site features (e.g., topography, geology)
that affect precipitation infiltration and runoff; and the contaminants' concentrations. Additional factors
such as groundwater pH and the presence of other contaminants that may alter contaminant solubilities can
also significantly influence contaminant transport.

-------
                                TABLE 9
                   MONITORING WELL DATA EVALUATION  (ug/L)
                       BERKLEY PRODUCTS, PENNSYLVANIA

          CHEMICAL             MAXIMUM                 MAXIMUM
                         CONCENTRATION FROM           BACKGROUND
                         ON-SITE WELLS MW-2,
                           MW-3, AND MW-4

INORGANIC FILTERED SAMPLE RESULTS

Aluminum                       1,030                      386
Arsenic(l)                      7.9
Barium(l)                     14,700                      230
Calcium                      1,090,000                   27,800
Chromium(l)                     27.8                      4.2
Cobalt                          61.9                      16.1
Copper                           27
Iron                           76,800                    5,650
Lead(l)                         7.6                       7.4
Magnesium                     172,000                    6,450
Manganese(1)                   69,800                    1,010
Mercury                         0.92                      2.5
Nickel(1)                       1340                      58.4
Potassium                      55,900                    5,640
Sodium                        284,000                    8,560
Vanadium                        23.4
Zinc                             587                      38.5

ORGANICS

Methylene chloride(1)            860
Acetone                          170
Chloroform(l)                     4
2-butanone(1)                    280
TCE(l)                            72
PCE(l)                            16
Toluene(1)                      4800                        1

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TABLE 9
MONITORING WELL DATA EVALUATION  (ug/L)
BERKLEY PRODUCTS, PENNSYLVANIA
              CHEMICAL
                                      MAXIMUM
                                 CONCENTRATION FROM
                                 ON-SITE WELLS MW-2,
                                   MW-3, AND MW-4
      Chlorobenzene                       3
      Ethylbenzene(1)                    170
      1,2-Dichloroethane(1)               2
      1,1,2-TCA(1)                       15
      4-Methyl-2-pentanone(1)            810
      Xylenes(l)                        1,200
      Diethyl phthalate                   8
      Bis(2-ethylhexyl) phthalate(1)     18
      1,4- Dichlorobenzene(1)            14
      Benzyl alcohol                      3
      2-Methylphenol                     28
      4-Methylphenol                      8
      Isophorone                          3
      4-Chloro-3-methylphenol            26
      Beta-hexachlorocyclohexane(1)     0.045
      Dieldrin                           0.1
      Endosuffan II                      0.69
      Vinyl chloride(1)                   22
      Carbon disulfide(l)                 3
      1,1-Dichloroethane                  5
      1,2-Dichloroethane(1)              40
      1,2-Dichlorobenzene                 2
      Naphthathene                        2
      Phenol                              2
      Gamma-hexachlorocyclohexane(1)     0.2
      Heptachlor epoxide(l)             0.098

        (1) Chemical of potential  concern  (COPC)
 MAXIMUM
BACKGROUND

-------
                                       TABLE  10

                       MONITORING WELL DNAPL  DATA COMPARISON  (ug/L)
                             BERKLEY PRODUCTS, PENNSYLVANIA
                           ON-SITE WELL
 DNAPL COMPARISONS            MAXIMUM            MW4SDN        MW41DN
                          CONCENTRATION          DNAPL          DNAPL
Methylene chloride(1)          860                                700
Acetone                        170
Chloroform(l)                   4
2-Butanone                     280                                140
TCE(l)                          72                                 1
Benzene(1)                      89                                 36
PCE(l)                          16                                 3
Toluene(1)                     4,800              1,900             95
Chlorobenzene                    3                                 3
Ethylbenzene(1)                 170                200             3
1,2-Dichloroethane(1)            2                                 5
1,1,A-TCA(1)                    15                                 3
4-Metthyl-2-pentanone(1)        810                                280
Xylenes(l)                     1,200              1,400             310
Diethyl phthalate                8                 63
Bis(2-ethylhexyl) phthalate(1)  18
1,4-dichlorobenzene(1)          14                 65
Benzyl alcohol                   3
2-Methylphenol                  26                 24
4-Methylphenol                   8                 21
Isophorone                       3                                 3
4-Choro-3-methylphenol           9
Beta-hexachlorocyclohexane(1)  0.045
Dieldrin                        0.1
Endosulfan II                   0.69
Vinyl chloride(1)                22                                3
Carbon disulfide(l)              3

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TABLE 10
MONITORING WELL DNAPL DATA COMPARISON  (ug/L)
BERKLEY PRODUCTS, PENNSYLVANIA
      DNAPL COMPARISONS
 ON-SITE WELL
    MAXIMUM
CONCENTRATION
                                                      MW4SDN
                                                      DNAPL
MW41DN
 DNAPL
     1,1-Dichloroethane
     1,2-Dichloroethene
     1,2-Dichlorobenzene
     Naphthalene
     Phenol
     Gamma-hexachlorocyclohexane(1)
     Heptachlor epoxide(l)
     Gamma-chlordane
     Arcolor 1254
     4-Chloro-3-methylphenol
     4,4'-DDE
5
40
2
2
2
0.2
0.098







3

0.21

0.1
11
13
0.4
                                      0.22
                                      0.087
       (1) Chemical of potential concern  (COPC)

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             CHEMICAL
                                                TABLE 11
                         HOME WELL DATA EVALUATION MAXIMUM CONCENTRATIONS  (ug/L)
                                       BERKLEY PRODUCTS, PENNSYLVANIA

                                                       SAMPLE LOCATIONS

                             HW-1    HW-2    HW-3    HW-4    HW-5    HW-6    HW-7
                                                                                     HW-E
                                                                                             HW-9
                                                                                                     HW-9N
 INORGANICS

Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Cobalt
Copper
Iron
Lead
Manganese
Mercury
Nickel
Selenium
Silver
Thallium
Vanadium
Zinc
Cyanide

ORGANICS

Butylbenzyl phthalate
Acetone
 2.1
78.7
11.3
       5.9

3.4    185
                         82.3
                                 180
                                         471
           9.6

           9.4
          17.6
                                                 316
                                                 1.5
                                                         153
                                                                 106
                                                                 158
                   4.5
                                          96.6
                                                  28.4
                                                                  4290
                                                                         93.6
71.4
180
104

0.67


14.3
50.5


0.54
34

114
98.7
15.2
3.4



80.2
199
24.9
6



8.7
15.9

3.1



539
111
39.7
12.7



121
4910 185
22.5
39.3
1.7
7.6
2.3
368
32.4
6.8
5.4



106
42.7
5.2

2


                                                                           570

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TABLE 11
HOMEWELL DATA EVALUATION MAXIMUM  CONCENTRATIONS (ug/L)
BERKLEY PRODUCTS, PENNSYLVANIA
               CHEMICAL
     INORGANICS
                               HW-10
                                         HW-11
                                                  HW-12
                                                          SAMPLE LOCATIONS

                                                           HW-13    HW-14
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Cobalt
Copper
Iron
Lead
Manganese
Mercury
Nickel
Selenium
Silver
1040 20.8
12.8
231 145 133
1.2
5.2 16 4.2

276 724
50.1 37000 117
2.9 74.4
454
14.2 24.4


19.5
2.4
174 300

4.4

213
263

1.5
26.3


                                                                             HW-15
                                                                                      HW-16
                                                                              251
                                                                                               HW-17
                                                                                                 184
                                                                                                         MAX F
                                                                                                          217
                                                                                                                  MAX F
                                                                                                                   386
                                                                                                                   230


17.1
37.6






19.1
1640
2.4
49.2


4.2
4.2

2750

260



16.1

5650
7.4
1010
2.5
58.4

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TABLE 11
HOME WELL DATA EVALUATION MAXIMUM CONCENTRATIONS  (ug/L)
BERKLEY PRODUCTS, PENNSYLVANIA

                                                          SAMPLE LOCATIONS

               CHEMICAL        HW-10     HW-11     HW-12     HW-13    HW-14    HW-15    HW-16    HW-17    MAX  F    MAX  F

  Thallium
  Vanadium                       3         42                                   4.6
  Zinc                         297       39.5                         11.7              6.4      7.8                38.5
  Cyanide

  ORGANICS

  Butybenzyl phthalate
  Acetone                                           23

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The geologic and hydrogeologic properties of the Site also influence migration of contaminants. The
aguifer beneath the facility consists of interbedded sedimentary rock units. The bedding planes appear to
have rotated over time into an east-west orientation and have an approximately 35-degree dip to the north.
Bedding plane fractures and joint cracks are present and may be preferential pathways for groundwater flow.
The overall groundwater flow at the landfill appears to be to the east and the northeast and is probably
discharging to Cocalico Creek from the shallow and deep portions of the bedrock aguifer. The RI report
concludes that the major groundwater flow direction from the Berkley Products Site is to the east, with the
predominan flow immediately beneath the fill area being a downward vertical flow. The eastward-flowing
groundwater at shallow and intermediate depths is predicted to discharge into Cocalico Creek. The deeper
bedrock groundwater may also discharge to the creek. The creek may be influenced by the presence of a fault
plain east-northeast of the Site.

Based on the groundwater flow direction and the chemical concentrations observed in monitoring wells
(MW-4S and MW-SS) at the eastern portion of the study area, contaminants are likely to be migrating outside
the boundaries of the landfilled area, into the deep bedrock portion of the aguifer.

A gualitative review of the Site features, geologic and hydrogeologic properties, and contaminants
identified to date indicates the following potential contaminant fate and migration conditions:

! The fill materials are poorly covered and are exposed to the ambient air. Numerous
organics present in the fill and soil materials can volatilize to the ambient air and
migrate beyond the Site boundaries. Soil gas results have indicated the presence of
volatile organic compounds at shallow depths (0 to 3 feet).

! The contaminated fill materials and soils are available to migration off site through
erosion by the action of precipitation runoff or by wind.

! Precipitation that infiltrates into the subsurface materials is leaching contaminants into
the underlying bedrock groundwater aguifer. Groundwater underlying the fill appears
to be contaminated by numerous contaminants and is likely migrating away from the
landfill eastward toward Cocalico Breek. The groundwater immediately beneath the fill
is flowing predominantly vertically downward and to the east. The shallow and
intermediate portions are thought to discharge to Cocalico Creek. The deeper
portions may also discharge or flow in an upward direction in the creek area.

! Seasonal seeps and springs have been identified in the vicinity of the landfill. The RI
indicated that those surface features north of the Site occur as the result of shallow
seasonal groundwater discharge. The seeps south of the Site occur immediately at
the base of the fill and appear to be closely related to rain events. Contaminated
groundwater and seeps that emerge at the ground surface can travel as runoff and
subseguently enter Cocelico Creek.

! Available data do not indicate that the Berkley Products Site is contributing to the
degradation of residential wells in the area; however, the hydrology of the area has not
been fully defined. While no significant Site-related contamination has been observed
to date in private wells, it is unclear what the impact of Site contaminants on those
wells may be in the future.

! Because solvent components have been detected in the fill materials of the landfill,

and based on past disposal practices, it is possible that non-agueous phase liguids
(NAPLs) are present in the landfill. These NAPLs, if present and not addressed, would
serve as continuing contaminant sources to groundwater and soil gases that would
likely migrate off-site.

! The gualitative assessment of Site contaminant fate and migration indicates that
organic and inorganic constituents can migrate off-site and affect other environmental
media and subseguently pose exposure risks to humans and biological receptors.

! The results of the Remedial Investigation indicate that the soils, and landfill materials
on the plateau reside above the water table. Therefore, precipitation infiltration would be
the principal driving force for leaching of contaminants into groundwater.

VI. SUMMARY OF SITE RISKS

The primary Site-related risks posed by the Berkley Products Superfund Site are derived from potential

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contact with, and migration of the contaminants contained in the landfill materials and soils. Contaminants
of concern in the Site soils ware determined from numerous soil samples collected from test pits in February
and March of 1991. Given the extremely high levels of the contaminants discovered in the test pits, as well
as the mobile natures, of several of the compounds, it is probable that the test pit soils continue to serve
as a source of contamination to the groundwater underlying the Site.

Human Health Risk Assessment

Baseline risk assessments are conducted for Superfund investigations to determine the health risk
presented by the Site conditions. Cancer and Non-cancer risks are calculated using anticipated exposure
assumptions, such as duration of exposure and combination of the various exposure pathways, e.g. inhalation
of dust, direct skin contact with contaminated materials, and drinking of contaminated water. All of these
variables are combined to generate an estimated risk level. The detailed assumptions may be found in the
baseline risk assessment, Section 5 of the Remedial Investigation Report. The cancer and non-cancer risk
levels are expressed in the formats of the following examples:

Cancer Risk Format - Reported in the format: 1 E-04, or 1 X 10-4 - both of which signify
one additional chance in 10,000 for a susceptible individual to contract cancer above the
normal cancer incidence in the general population. In general, EPA considers any calculated
environmental risk greater than 1 E-04 to be unacceptable.

Non-Cancer Risk Format - Chronic Hazard Index (HI) = 1; EPA believes that a Chronic HI
that exceeds 1 presents an unacceptable risk to human health.

The Baseline Risk Assessment presented in Section 5 of the RI report identified contaminants in the
environmentla media that pose cancer and non-cancer risks to human health through several potential pathways.

Direct Contact Risk.

Two potential scenarios were considered in assessing human exposure to surficial soils and landfill
materials; residential and recreational user. The hypothesized exposure pathways include incidental
ingestion and dermal contact and inhalation of fugitive dusts.

Under the residential scenario, the estimated excess lifetime cancer risk was 1 E-04, meaning that there
is the potential that one additional person for every 10,000 residential users would contract cancer due to
exposure to the landfill materials and contaminated soil and dust. Beryllium was the major cancer risk
contributor. The Hazard Index (HI) calculated for this scenario was less than 1 (approximately 0.8 for
children and 0.2 for adults) for non-cancer risks.

Under the recreational user scenario, the cancer risk was 2 E-05 and the HI was less than 1
(approximately 0.1 for children and 0.02 for adults) for non-cancer risks. Arsen and beryllium were the
primary contributors of cancer risk.

Inhalation of fugitive dusts was estimated to generate a 1 E-07 cancer risk and an HI of less than 1 for
children (0.04) and adults (0.01).

Subsurface soil data did not lend themselves to a guantitative risk evaluation. Because of the
heterogeneous nature of the landfill material and the varying depth of sampling locations, a semi-
guantitative analysis was performed. The analytical data indicated that the extent of contamination and
concentrations were generally greater than identified in the surface samples. A semi-guantitative evaluation
of the data, assuming a combined child and adult exposure scenario and assuming that the landfill material
was available for direct contact, resulted in cancer and non-cancer risks exceeding EPA
acceptable risk ranges. The calculated HQs for some of the compounds exceeded 1. Sample results of the
polychlorinated biphenyl compound Aroclor 1254 alone generated a HQ of 140 and an excess cancer risk of
3 E-03.

The evaluation assumed that the subsurface material became available for contact through erosion and/or
excavation. Although it cannot be assumed that the increase in risk from the future deterioration of the
landfill will be identical to the risks calculated from the subsurface soil samples, it is apparent that if
left unaddressed the risks from the landfill will increase as more subsurface materials become exposed.

Potential Risks from Ingestion of Contaminated Water

Monitoring Wells

Groundwater collected from monitoring well clusters situated at the landfill's perimeter was found to
contain volatile organic compounds (VOCs), semi-volatile organic compounds (SVOCs), and metals. Under a

-------
hypothetical scenario where groundwater from the MW-2, MW-3, and MW-4 well clusters is used for residential
water supplies, the estimated cancer risk was 1 E-03, and the HI is greater than 1 (approximately 926 for
children and 397 for adults) for non-cancer risks.

The major contributors of cancer risk include arsenic, beryllium, methylene chloride, and vinyl
chloride. Arsenic, barium, manganese, toluene, nickel, and benzene were signigicant contributors of
non-cancer risks.

MW-5 was considered separately because the types and concentrations of chemicals detected were fewer
than for the other three monitoring well clusters. The total cancer risk for potential use of the
groundwater from this well would be 2 E-04, and the HI would exceed 1 (53 for children and 23 for adults).
Beryllium is the primary contributor of cancer risk, and barium, manganese, and nickel posed excess
non-cancer His greater than 1.

Residential Wells

Residences in the vicinity of the landfill use groundwater drawn from the underlying bedrock aguifer.
One shallow hand-dug well in close proximity to and immediately downgradient from surface drainage patterns
from the Berkley Products Site was removed from service prior to the RI after it exhibited contamination.
This well was replaced with a drilled well that has not shown contamination related to the Berkley Products
Site.

Three rounds of residential well samples were collected during 1990, 1991, and 1993. Analytical results
indicate that groundwater in residential water supplies appears to be virtually free of any organic
contaminants. Metals were identified in all well samples, including those hydrologically upgredient of the
Site. The risk assessment asserts that some of the metals may be attributed to natural sources (minerals),
and others may be associated with the well systems (piping, solder, pumps, etc.).

The risk assessment determined that cancer risks from ingestion of residential well water were typically
within the acceptable risk range. In a few cases, the total non-cancer risks slightly exceeded
the HI of 1.0; however, in all but two cases the Hazard Quotients for the individual constituents separately
did not exceed 1.0. Lead was found to have exceeded the 15 • g/L Action Level in a few homes; these
residents have already been notified regarding the presence of lead in their water supplier. The two wells
with His greater than 1 (HW-9 and HW-11) are reported to be hydrogeologically upgradient of the Site, HW-9
has been replaced by a newer well.

Considering the lack of organic compounds, and the low level and sporadic concentrations (i.e. observed
during one simple round but not observed during another) of metals recorded in the residential wells, EPA has
determined that the residential well, are not being impacted by the Site.

Surface Water

One spring and several seeps have been identified at locations surrounding the landfill. The risk
assessment expected no significant contributions to human health risk fron exposure to contaminants present
in the spring and nearby stream since the concentrations were low.

Potential Risk from Exposure to Contaminated Sediments

The Cocalico Creek stream sediment sample concentrations were sufficiently low that the screening risk
assessment concluded no significant impact to human health from exposure to stream sediments.

The exposure to contaminants in spring and leachate sediments poses some risk but is generally within
the acceptable risk range.

Spring sediments samples were obtained from four locations. The estimated cancer risk for the spring
sediments ranged from the higher end of the acceptable risk range for residential users, 1 E-4, to well
within the acceptable range (E-05) for recreational users. Cancer risks are primarily attributable to
beryllium, with the presence of arsenic contributing to the overall total risk.

Cancer risks for exposure to leachate sediments were 7 E-05 and 1 E-05 for the residential and
recreational Lmar scenarios, respectively. Arsenic and beryllium were identified as the principal risk
contributors. Non-cancer risks were estimated to be less than 1.0.

Additive risk

It is possible that a single receptor could be exposed to more than one contaminated medium, therefore
increasing his or her total risk. At this site, for the pathways evaluated, it would be theoretically

-------
possible for a receptor to be exposed to a drinking water source and a soil source. For
residential on-site soil exposure, the drinking water source would be assumed to be water typical of the
monitoring well concentrations. Those risks exceeded 1E-4 (cancer) and 1 (noncarcinogenic HI). For
residents at the houses with existing sampled home wells, the major soil exposure would be to the soil
in their own yards. Therefore, the most appropriate scenario for additivity was assumed to be existing
residential wells as the water source, with recreational (occasional) contact with soil or sediment.

In this discussion home wells without COPCs were not included. For home well nos. 9 and 11 which are
both upgradient of the Site, His already exceeded 1 for each of these water sources in and of themselves.
Therefore, for risk assessment purposes, it wes unnecessary to add other pathways to these sources, since
exposure to contaminants in other media would only serve to further increase a risk that has already been
identified as potentially substantial.

Therefore, the potential drinking water sources were home well nos. 1, 3, 6, 7, 9N, 10, 13, 14, and 17;
the potential soil/sediment sources for recreational contact were surface soil, leachate sediment, and spring
sediment SD-8, SD-9, SD-10, and SD-11. For all combination of chemicals with similar target organs, the
total His are less than 1. The cancer risks were between 1E-4 and 1E-6, except for combinations including
HW-7, whose estimated cancer risk was at approximately 1 E-4 for the water alone.

Ecologicigal Risk Assessment

A Tier 1 Ecological Risk Assessment (ERA) was prepared as part of the RI, in accordance with EPA Region
Ill's Interim Ecogogical Risk Assessment Guidelines (July 27, 1994) Summaries of the ERA conclusions are
presented in this section.

The ERA is based upon development of the most conservative Environmental Effects Quotients (EEQs). The
EEQ is defined as the reported environmental concentration divided by the chronic toxicity value derived from
literature, AWQC or other sources. Individual EEQs exceeding 1.0 indicate risk potential. Additive EEQ
values can be calculated and serve as a check. When the additive value for a medium (e.g., soil) is over
100, it can be safely concluded that a potential for risk exists. When the additive value is below 10, the
case for potential risk is not as clear. It is that area between 10 and 100 that is the gray area of
potential risk. For those habitats, it is best to assume that risk potential exists and that some action
should be taken, even if it is only monitoring. However, with some contaminants, e.g., organic compounds
that bioaccumulate, such as chlorinate hydrocarbons, and inorganic compounds that are transformed into
organic forms, such as lead an mercury, the lower additive value should still be viewed as representative of
a potential for risk.

A number of organic chemicals and metals have been detected in surface soils, seep sediments, leachate
groundwater at the Site. Flora and fauna can become exposed to these contaminants through a variety of
pathways. Species that reside or forage at the Site or species that prey on resident species can be exposed
through direct contact or incidental ingestion. Plants can become affected through uptake of contaminants by
their root system. In turn, the plants may be consumed by insects and animals and the contaminants
bioaccumulated through the food chain.

Surface Soils

The ERA concluded that Site soils constituted the primary source of contamination and were the medium to
which ecological receptors would have the most exposure. Contamination in Site soils posed potential threat
to vegetation, through uptake, and to resident insects and foraging and burrowing animals. Migratory fauna
and avians may use the Site for habitats or opportunity resting and feeding purposes and thus become exposed
to Site contaminants.

Table 12 shows those surface soils contaminants with EEQs greater than one (1) as well as the additive
EEQ for surface soil. Both individued end additive values determined for the surface soils
indicate environmental risk.

Seeps

Groundwater discharges to the surface occur intermittently at the seep locations. The ERA concludes
that seep leachates may attract insects and insect predators and promote plants' growth, which in turn
promotes the presence of foraging and root-eating animals. Flora and fauna would be exposed to groundwater
contaminants that emerge at the seep locations.

Leachate Sediments

The ERA concluded that, while seeps were intermittent, contaminants may accumulate and remain adsorbed
to the soils and sediments where leachate breaks out at the surface. The sediments are therefore probably

-------
long-term contaminant sources. As in the case of contaminated soils, flora can grow in these areas and
residing and foraging fauna become affected by contaminants.

VII. DESCRIPTION OF ALTERNATIVES

Remedial Action Objectives

As discussed in Section VI, Summary of Site Risks, the human health risk posed by the individual media
at the Site are currently within EPA's acceptable target risk range for the currently available expceure
pathways that were evaluated. Exposure to surface soil however was at the limit bordering unacceptable
risks. Evaluation of contamination in the monitoring wells and subsurface soils indicates that deterioration
of the landfill and potential use of groundwater in the immediate vicinity of the landfill would present
higher human health risks, outside the acceptable risk range, as well as increasing the availability of
contamination for uptake into plants and bioaccumulation in the ecological food chain.

The Remedial Action Objectives (RAOs) of the Feasibility Study conducted for this Site are to prevent
unaccepted human exposure and minimize the exposure of ecological receptors to contaminated soil and landfill
materials, minimize potential exposure to contaminants in landfill leachate, gas, and Site groundwater, and
minimize contaminant migration from the landfill into the environment.

The Superfund Law reguires that alternatives to address the contamination at hazardous waste sites be
assessed. The alternatives are to be designed to be protective of human health and the environment. The
alternative selected for implementation must be protective as well as cost-effective and in accordance with
statutory reguirements. Permanent solutions to contamination are to be achieved whenever possible. In
addition, emphasis is placed on treating waste on-site wherever possible; to reduce the toxicity, mobility,
or volume of Site-related contaminants, and on applying alternative or innovative technologies.

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                TABLE 12
SURFACE SOIL ENVIRONMENTAL EFFECTS QUOTIENTS
      INDIVIDUAL AND ADDITIVE VALUES

          Contaminant           EEQ

 Barium                        1.375
 Chromium                       7.45
 Cobalt                        1.067
 Copper                         3.53
 Lead                           3.88
 Mercury                         5.3
 Nickel                        1.655
 Silver                          1.1
 Zinc                            4.1
 Cyanide                        2.14
 Toluene                        11.0
 Phenol                         18.0
 Acenaphthene                    1.1
 Benz(a)Anthracene               4.4
 Benzo(B)Fluoroanthene           4.8
 Benzo(A)Pyrene                  5.8
 Benzo(G,H,I)Perylene            3.9
 Benzo(K)Fluoranthene            3.4
 Chrysene                        5 . 0
 Dibenz(A)Anthracene             1. 8
 Fluranthene                     3. 4
 Indeno l,2,3-c,d pyrene         2.9
 Pyrene                          8 . 9
 PCB                             2.7
 ADDITIVE VALUE                106.077

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Because the Berkley Products Site is similar to numerous other municipal landfills contaminated by
hazardous substances, the presumptive remedy approach can be applied in the development of remedial
alternatives. Presumptive remedies, as presented in EPA OSWER Directive No. 9355.0-49FS, are preferred
technologies developed to address sites with similar characteristics such as contaminant presence, types of
disposal practices, and impacts to environmental media. The use of presumptive remedies is meant to promote
focused data collection, resulting in streamlined site assessments and accelerated remedy selection that
achieve time and cost savings.

The Berlkley Products Site was operated as a municipal landfill for a number of years and subsequently
contaminated by industrial chemicals and by-products. The use use the presumptive remedy is appropriate for
this Site because of the Site's historical use and disposal history and because Site conditions are
consistent with the generic conceptual site model for a municipal landfill. Based on EPA's evaluation of all
NPL sites, municipal landfills contaminated by hazardous substances account for approximately 230 sites; as a
group, landfills comprise a large fraction of NPL sites. Because of the large volumes of municipal debris
mixed with hazardous substances, treatment is considered to be technically impracticable for municipal
landfills. The presumptive remedy for these sites, based on EPA's review of FSs and Records of Decision for
approximately 149 sites, is containment of the landfill contents and collection or treatment of landfill
gases. In addition, measures to control landlill leachate or affected groundwater may be required on a
sites-specific basis.

In accordance with the presumptive remedy approach, the alternatives presented in the FS end summarized
below have been directed toward containment of the landfill waste and evaluation of the measures to address
leachate and groundwater migration. The key components of the evaluated alternatives are identified in Table
13 and described in the following text.

Alterntives Summaries

Alternative 1: No Action

The no-action alternative is developed as a baseline case, as required by the National Oil and
Hazardous Substances Pollution Contingency Plan (NCP). The only activities conducted under this
alternative are monitoring to evaluate contaminant migration and a review of Site conditions and risks
every 5 years.

The purpose of this alternative is to evaluate the overall human health and environmental protection
provided by the Site in its present state. Under this alternative, no remedial actions would be taken to
protect human health and the environment. With contaminants present in the landfill's surface soils and
surface materials and no measures implemented to prevent exposures, potential exposures to humans and
biological receptors and contaminent migration would continue unabated.

Because no actions would be conducted under Alternative 1 to maintain or cover the landfill, the
landfill surface will continue to erode and expose more contaminated materials and allow greater potential
exposures, increased infiltration and attendant contaminant leaching and migration, and transportation of all
surficial materials through precipitation and wind erosion. Under the no-action alternative, contaminants
will continue to migrate unabated.

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                            TABLE 13
           DEVELOPMENT OF REMEDIAL ACTION ALTERNATIVES
                   BERKLEY PRODUCTS, PENNSYLVANIA
       ALTERNATIVE
                                      KEY COMPONENTS OF ALTERNATIVE
No Action
Limited Action with
Controls
Institutional
Consolidation, Capping,
Institutional Controls
    and
Groundwater, residential well, surface runoff,leachate
spring and seep monitoring (every 5 years).
Five-year reviews.

Fencing.
Institutional controls.
Groundwater, surface runoff, leachate spring and
seep monitoring (annual),  residential well monitoring
(semi-annual).
Five-year reviews.
Pre-design investigations.
Site preparation.
Consolidation of landfill wastes
Site grading.
Cover system
   Subgrade
   Gas vent system
   Barrier layers
   Drainage layer
   Top layer (vegetated)
Security fencing.
Erosion control.
Institutional controls.
Long-term operation and maintaince
Groundwater, surface runoff, leachate spring and
seep monitoring (annual),  residential well monitoring
(semi-annual)  and monitoring wells (guarterly).
Five-year reviews.

-------
Since contaminants remain on the Site, a review of Site conditions and risks would be conducted every 5
years, as required by CERCLA. The reviews would consist of evaluation of analytical and hydrogeologic data,
assessment of whether contaminant migration has increased, and determination as to whether human or
biological receptors or natural resources are at risk.

Alternative 2: Limited Action with Institutional Control.

The limited-action alternative would include the construction of a fence to restrict access to the
landfill and institution of deed restrictions and local ordinances to prevent futur uses of the property
that could result in additional exposures and to prevent the use of groundwater from under the Site.
Long-term, semiannual monitoring would be conducted to assess contaminant status and potential threats to
human health and the environment.

As in Alternative 1, Site conditions and risks would be reviewed every 5 years since wastes are
left in place. Under this alternative, no actions would be taken to reduce the toxicity mobility, or
volume of contaminants at the Site. With contaminants present in the landfill's surface and subsurface,
contaminant migration would continue unabated.

Alternative 3: Consolidation, Capping, and Institutional Control.

Alternative 3 is a containment option that would utilize capping to prevent potential human and
animal contact with contaminants in soils and landfill materials and significantly limit contaminant
leaching into groundwater, thereby reducing contaminant migration.

Prior to the remedial action implementation, a topographic survey and a geotechnical engineering study
would be conducted to obtain data necessary to design and construct the cover system. Based on the results
of these predesign studies, the design of components of the cover system for the landfill, as listed in Table
13, may be modified to more appropriately address Site-specific conditions. After data collection is
completed and design is underway, Site preparation would commence. The Site would be cleared of vegetative
growth to facilitate capping. Leachate sediments and materials end-dumped over the southern edge of the
landfill and currently located at the toe of the hillside would be consolidated back into the main portion of
the landfill. The consolidated soils and landfill materials would then be compacted and graded to achieve
desired slopes. The various layers of the low-permeability cover system, including a passive gas collection
and venting system, would then be placed. Institutional controls (e.g., deed restrictions and ordinances)
would be required to prevent damage of or intrusion into the cover system, as well as prohibit the
installation of new residential wells in contaminated portions of the aquifer. During consolidation
activities, it may be determined necessary to excavate uncovered wastes (e.g. drums) and arrange for off-site
disposal.

This alternative also provides for security fencing during active cap construction, erosion control, and
a long term operation and monitoring program that will incorporate residential well sampling twice a year and
monitoring well sampling quarterly. Surface runoff, leachate and spring samples will also be taken on a
yearly schedule.

The monitoring well program will include new monitoring wells that will be installed at locations
and depths bet the landfill and downgradient residents. These wells will be installed to act as early
warning well ensuring that any changes to the groundwater conditions will be made known well in advance of
the potential for any residential wells being contaminated. These new wells, in conjunction with the
existing monitoring wells and the residential wells, will serve to show any changes to the groundwater,
quality in the surrounding area as well as to identify any potential for contamination to spread in the
future.

Alternative 3 was originally developed and presented in the Feasibility Study for this Site. Upon review
of that document and in consideration of preliminary comments, this alternative was modified to include an
upgraded cap system that would conform to the requirements for a hazardous waste landfill, as opposed to the
capping requirements for a municipal waste landfill. A "hazardous waste cap" is similar to a "municipal
waste cap" except that an additional impermeable layer is included. Other components of this alternative
originally introduced as being pursuant to the municipal waste landfill regulations, have been revised to
reflect adherence to the analogous state hazardous waste landfill regulations.

Since contaminants will remain on Site, long-term monitoring and 5-year reviews would be required to
assess contaminant status and evaluate whether residential wells may have been affected. The number and
frequency of the samples and parameters for analysis will be evaluated for continued suitability during the
5-year reviews.

VIII. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES

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EPA uses nine criteria, described in CERCLA at Section 121 (b)(1), 42 U.S.C. §9621 (b)(1) and the
National Oil and Hazardous Substances Contingency Plan (NCP), 40 C.F.R Part 300.430(e) (9) to evaluate
remedial alternatives. These criteria include the statutory requirement of Superfund as well as other
technical, economic and practical factors used to assess the feasibility and acceptability of alternatives.
The nine criteria are listed below, divided into three groups:

A. Threshold Criteria 1. Overall protection of human health and the environment
2. Compliance with "Applicable or Relevant and Appropriate
Requirements" (ARARs)

B. Primary Balancing Criteria 3. Long-term effectiveness and permanence
4. Reduction of toxicity, mobility or volume through treatment
5. Short-term effectiveness
8. Implementability
7. Cost

C. Modifying Criteria 8. State Acceptance
9. Community Acceptance

Alternatives must meet the threshold criteria before they are evaluated any further detail. The primary
criteria are then used to compare benefits among the alternatives that pass the threshold tests. The final
considerations in the selection process include comments frort the public and the Pennsylvania Department of
Environmental Protection.

Analysis Against The Nine Criteria

1. Overall Protection of Human Health & the Environment

A primary requirement of CERCLA is that the selected remedial alternative be protective of human health
and the environment. A remedy is protective if it reduces current and potential risks to acceptable levels.

Alternative 1, No Action, would not provide long-term protection of human health and the environment.
Contaminants within the soils and landfill materials would not be remediated or isolated and would continue
to pose risk. Under current conditions, direct human exposure to Site surficial soil poses an estimated
carcinogenic risk of approximately 1 E-4, which is the upper limit of EPA's acceptable risk range. Exposure
to surficial soil is not expected to pose an unacceptable non-carcinogenic risk, as indicated by an HI of
less than 1. However, over time, as soil erodes from the landfill surface, more contaminated subsurface
materials may be exposed and become available for direct human contact, resulting in inreased risks. The
risk assessment estimated that contaminants are present at concentrations that may each pose carcinogenic
risks greater tha 1E-3, and an HI greater then 1 could result from human exposure to subsurface soils.

Because infiltration would continue to permeate the landfill, the contaminants remaining in landfill
soils would continue to leach into the groundwater and thereby continue to potentially affect downgradient
portions of the aquifer (including private residential wells), leachate seeps, and Cocalico Creek. The seeps
and springs at the base of the landfill would continue to discharge contaminated groundwater to the surface
and continue to drain into Cocalico Creek.

The ecological risk assessment shows that, under current conditions, the potential exists for impacts to
ecological receptors resulting from contact with Site surface soils and leachate seeps. As the landfill
surface erodes end more contaminated subsurface soils become exposed, potential ecological risks would be
expected to increase.

Subsequently, the No Action alternative does not meet this threshold criteria and is not considered
further in this comparative analysis.

In Alternative 2, the fencing and institutional controls proposed under te limited action alternative
would provide limited protection of human health by restricting human access to contaminated media. This
alternative would not be protective of the environment or most ecological receptors.

Because this alternative includes no controls to prevent deterioration of the landfill surface over
time, surface soils would erode, causing the more contaminated subsurface soils to be exposed. Direct human
contact with these soils would pose increase carcinogenic and non-carcinogenic human health risks. The
estimated future risks posed by direct contact with subsurface soils exceed a carcinogenic risk of 1E-3 end a
non-carcinogenic HI of 1. Fencing the landfill area would provide some protection from human exposure to
these soils. However, fencing is not likely to prevent all human access to the Site. Deed restrictions and
local ordinances, if enforced, would limit future use of the Site, deter intrusion into contaminated soils,
and restrict use of Site groundwater.

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     The long-term impacts to the ecological receptors and the environment would remain unchanged under this
alternative.  Because landfill material would not be remediated or covered, contaminated surface soils would
continue to migrate off Site in wind end surface runoff.  The contaminants remaining in landfill soils would
pose potential risks to plants and animals and would continue to leach into the groundwater.  Fencing would
have little influence on be protection of ecological receptor; large mammals may be barred from the Site by
the fencing, but small burrowing mammals, birds, and invertebretes would be unaffected.  Exposure to Site
contaminants could still occur through ingestion, direst contact,  and the food chain.  The contaminated
groundwater emanating from the Site would continue to potentially affect downgradient portions of the aguifer
and Cocalico Creek and would continue to discharge from seeps and springs at base of the landfill.

         Alternative 2, does not meet this threshold criteria and is not considered further in this
comparative analysis.

         Alternative 3 would provide short-term end long-term protection of human health and the environment
by preventing direct exposure (dermal contact, incidental ingestion, and inhalation) to
contaminated soils and landfill materials and minimizing contaminant migration from the landfill into the
environment.

     Consolidating and capping the contaminated soils and landfill materials would reduce human health risks
posed by direct exposure to within EPA's acceptable risk levels (less than 1E-6 for carcinogenic risks and
less than an HI of 1.0 for non-carcinogenic risks).   The cover system, which includes a biotic barrier to
prevent animal intrusion into the barrier layer and waste materials, would also reduce the ecological risk
posed by contaminated soils to acceptable levels.

     The cover system would significantly reduce infiltration of precipitation into the landfill, thereby
greatly reducing contaminant leaching from the soil and landfill materials to the underlying groundwater.
Because the contaminated soils and landfill materials are situated above the water table, reducing the
contaminant leaching caused by infiltration would ultimately result in a decrease in contaminant
concentrations in groundwater beneath the landfill and a decrease in off-site migration of contaminants in
groundwater.  The potential risks to downgradient users of the aguifer, as well as to ecological receptors
that could be exposed to Site groundwater discharging from spring and seep locations, would be reduced by
implementation of this alternative.

     Deed restrictions, and local ordinances would provide additional long-term protection by limiting access
to the capped area and restricting activities that could damage or intrude into the cover system and
contaminated media.

     The long-term monitoring program would allow the responsible agency to monitor the guality of
groundwater leaving the Site, assess potential impacts to downgradient receoptors (especially residential
wells),  and determine whether additional remedial actions are necessary.

     Use of engineering controls to minimize generation of fugitive dusts and vapors, and proper use of PPE
by Site workers would effectively minimize short-term risks to the local community and workers posed by
implementation of this alternative.

2.   Compliance with ARARs

     Under Section 121 (d) of CERCLA, 42 U.S.C. Section 9621  (d),  and EPA guidance,  remedial actions at
CERCLA sites must attain legally applicable or relevant and appropriate federal and promulgated state
environmental standards,  reguirements,  criteria, and limitations (which are collectively referred to as
"ARARs")  unless such ARARs may be waived under CERCLA Section 121 (d).

     ARARs fall into three general categories: chemical-specific,  and location-specific.  Chemical- specific
regulations include through reguirements that established allowable concentrations or discharge limits
specific to identified chemicals, such as Maximum Contaminant Limits  (MCLs) under the Safe Drinking water Act
or chemical-specific discharge limits developed under the National Poilulie Discharge Elimination System of
the federal Water Pollution Control Act.  Action-specific reguirements include municipal and hazardous waste
disposal reguirements of RCRA and authorized regulations of the Commonwealth of Pennsylvania, safety and
construction regulations, and other regulations related to the action being taken.  Location-specific
regulation include those that deal with archeological or historical aspects of the Site area as well as
endangered species that may be located within of neer the Site; there are no location-specific ARARs
indentified for the Berkley Products Superfund Site.

     Alternative 3's compliance with federal and state reguirements is summarized in the following
paragraphs.

Federal reguirements - Alternative 3 would comply with RCRA 40 CFR §264.31C (a) since a final cover

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system would be installed over the landfill. Alternative 3 would also comply with the requirements for
post-closure care (40 CFR §264.310 (b)) through the long-term maintenance and repair program. Long-term
monitoring requirements (40 CFR §258.80) would be met through the sampling and evaluation of groundwater,
springs and seeps, and residential wells.

Alternative 3 would be consistent with the TSCA PCB storage and disposal regulations applicable to the
disposal of PCBs at concentrations greater than 50 ppm, because the soils and landfill materials would be
contained by a cover system in accordance with 40 CFR §761.75. However, the following requirements will be
waived pursuant to requirements found at §761.75 (c) (4): construction in low-permeable clay conditions [40
CFR §761.75 (b) (1)]; use of a synthetic membrane liner [40 CFR §761.75 (b) (2)]; requirements for no hydraulic
connection between the Site and flowing surface water and the height of the bottom of the landfill above the
historic high water table [40 CFR §761.75 (b) (3)]; and installation of a leachate collection system [40 CFR
§761.75 (b)(4)]. Waivers are allowed if evidence is presented that the operation of the landfill will not
present an unreasonable risk of injury to health or the environment from PCBs. At the Site, current risks
from exposure to PCBs in surface soil fail within EPA's acceptable risk range. PCBs were not detected in
residential wells and even the levels detected in monitoring wells immediately adjacent to the site would not
generate an unacceptable risk. However, exposure to the highest level of PCB in sub-surface soil determined
during the test-pitting operations would generate a hazard Index of 140 if this route of exposure were
available. Capping of the landfill would eliminate the potential for direct contact, exposure to PCBs form
the Site as well as eliminating the percolation of rainwater through the landfill materials, the driving
force for potential PCB migration to the groundwater. The above specific d requirements of TSCA are
therefore waived.

The alternative would be consistent with the OSWER Directtve No. 9335.4-01, which directs action toward
containment remedial actions.

Under §300.430 (f) of the NCP, ARARs may be waived if "The (selected) alternative will attain a
standard of performance that is equivalent to that under the otherwise applicable standard, requirement
or limitation through use of another approach". At the Berkley Products Site the attainment of Maximum
Contaminant Levela (MCLs) enacted under the Safe Drinking Water Act, 42 U.S.C. §§300 f to 300 j-26, are
considered to be Relevant and Appropriate standards; however, for this remedy they will be waived under this
provision of law for the following reasons:

The residential wells surrounding the Site are not currently contaminated with Site-related
contamination. This is because the rock strata are naturally aligned so as to direct any leaching
contamination downward at such a steep angle that any potentially contaminated groundwater is
rapidly removed from surface availability.

The capping of the landfilled area will eliminate or severely reduce the infiltration of rainfall,
which is the main driving force behind the production of leachate and migration of contaminants.

The monitoring program as envisioned would install new wells that will serve to further
characterize the aquifer beyond the perimeter of the Site and monitor the concentrations in the
groundwater of any Site-related contamination. These wells will also serve to indicate the
effectiveness of the cap in reducing the migration of contaminants.

Because hazardous substances remain on-site, reviews of the remedy will be conducted at
least every five years. These "Five-Year Reviews" will utilize the information gathered in the
monitoring program to confirm that no resident is subject to unacceptable Site-related risks
and ensure that the remedy remains protective of human health and the environment. Five-
Year Reviews can also trigger further response actions if unacceptable risks are discovered.

In view of the above paragraphs, this alternative will attain an equivalent standard of
performance to that achieved by attainment of MCLS. Therefore the requirement for attainment
of MCLs is waived.

State requirements - Alternative 3 would comply with the specific provisions of the state hazardous waste
regulations PA Code §624, set forth below, because a final cover system would be installed and closure and
post closure activities will be implemented. Specifically, during the construction of the cover system,
measures would be implemented under Alternative 3 to comply with the relevant and appropriate state hazardous
waste landfill regulations concerning closure and post-closure activities found at §264.111, §264.112,
§264.114, §264.117 and §264.118, as well as the design requirements and construction of the cap, §264.301,
§264.310 and those requirements of §264.302 that are specific to the cap construction and operation.
Groundwater monitoring requirements under §264.97 and §264.98 will be met by the monitoring program. As the
landfill is no longer active, the security requirements under §264.14 will be followed through completion of
the construction of the cap, however the requirement for an artificial barrier required under §264.14(b) (4)
may be substituted with natural barriers, such as hedges surrounding the landfilled portion of the Site.

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Currently there are steep forested inclines surrounding three sides of the landfill; these may be utilized in
combination with other natural or artificial measures such as locking gates at the entrance to the landfill
to provide security and control vehicular access. The components to be used as barriers will be decided in
the design phase of the project. During active construction a temporary fence will be installed to provide
the security for the period when waste may be exposed and construction eguipment present.

Alternative 3 would implement measures to control fugitive dusts in compliance with PA Code 25 §123.1
(c). If objectionable odors are identified after completion of the remedial action, an active gas vent and
treatment system would be installed and operated in compliance with PA Code 25 §123.31. Emissions from an
active system would have to meet the relevant and appropriate reguirements of PA Code 25 §127.1 and §127.11.

Measures to minimize soil erosion and sedimentation that may result from Site consolidation, grading
and contouring activities would conform with PA Code 25 §§102.2 through 102.24 to prevent the potential
pollution from surface wastes. An erosion and sedimentation control plan would be prepared, submitted for
approval, and implemented upon approval. Stormwater runoff management during the cover system construction
would be consistent with the county watershed management plan's construction criteria, per the state Storm
Water Management Act.

3. Lone-Term Effectiveness and Permanence

Long-term effectiveness and permanence addresses the long-term potection of human health and the
environment once the remedial action goals have been achieved. This comparison focuses on the residual risk
that will remain after completion of the remedial action and the adeguacy and reliability of controls used to
manage the untreated waste and treatment residuals.

Capping of contaminated soils would reduce the human health risk posed by direct exposure to
contaminated soils and landfill materials to within EPA's acceptable risk range (less than 1E-6 carcinogenic
risk; the HI would be reduced to less than 1.0). The cover system, which includes a biotic barrier to
prevent animal intrusion into the barrier layer and waste materials, would also reduce the ecological risk to
acceptable levels by inhibiting access to contaminated soils. By greatly reducing the leaching of
contaminants to groundwater and the subseguent downgradient migration of contaminants, capping would also
reduce the potential risks to downgradient users of the aguifer, as well as to ecological receptors that
could be exposed to Site groundwater discharging from spring and seep locations.

Because contaminated soils and landfill materials would remain in place beneath the cover system,
long-term maintenance of the cover system and natural or artificial perimeter boundaries and adeguate
enforcement of institutional controls would be reguired to ensure the long-term protectiveness of this
alternative. Routine maintenance and repair of the cover system would be reguired to ensure that the
effectiveness of the cap as a barrier is maintained.

The annual monitoring of groundwater, leachate seeps and springs, and residential wells would allow the
responsible agency to monitor the guality of groundwater leaving the Site, assess potential impacts to
downgradient receptors (especially residential wells), and determine whether additional remedial actions are
necessary. The monitoring program, in combination with the cover system, should be effective in minimizing
the risks to downgradient recaptors. Five-year reviews would be reguired to assess whether the cover system
continues to be effective in preventing direct exposures and reducing contaminant leaching. These review
would be based in large part on analytical data collected during annual monitoring events. Review of the
effectiveness of deed restrictions and ordinances in preventing damage to the cover system and exposure to
Site contaminants would also be reguired.

No difficulties or uncertainties are anticipated in performing the long-term maintenance or monitoring.
All materials used in construction of the cover system, fencing and barriers are readily
available and can be replaced. In the event of damage to the cap system, repairs could be performed
without many difficulties. Groundwater monitoring wells would reguire replacement if sedimentation or
vandalism were to occur; the wells would be readily replaceable.

Because maintenance of the cover system would be continual, catastrophic failure is unlikely. In the
event of failure or damage of the cover, existing access restrictions, institutional controls, and monitoring
would be expected to provide adeguate short-term protection of human health until the cover system was
repaired.

4. Reduction of Toxicity Mobility, or Volume Through Treatment

This evaluation criteria addresses the degree to which a technology or remedial alternative reduces
toxicity, mobility, or volume of hazardous substance at the Site. Section 121 (b) of CERCLA, 42 U.S.C.
Section 9621 (b), establishes a preference for remedial actions that have as a principal element treatment
that permanently and significantly reduces the toxicity, mobility, or volume over remedial actions which

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would not.

Alternative 3 would not reduce the toxicity, mobility, or volume of contamination through treatment
because no treatment is used to address the contaminated soil and landfill materials. However, mobility of
contaminants from the soil and landfill materials would be minimized by the cover system. The chemicals in
the soil and landfill materials and underlying soils would not be treated or destroyed and would remain at
the facility. Alternative 3 would not satisfy the statutory preference for treatment to reduce risks posed
by contaminated soil and landfill materials.

5. Short-Term Effectiveness

This criteria refers to protection of workers and the community, the potential environmental effects
of the remedial action, and the time needed to implement the proposed activity. Implementation of
Alternative 3 is not expected to pose any significant risks to the local community. Increased truck and
heavy eguipment vehicular traffic would occur as the result of Site preparation and the import and
placement of capping materials. Coordination and scheduling of truck and hear eguipment traffic on
public roads would be reguired to manage increased vehicular activity.

During Site preparation and placement of the cap system, risks posed by fugitive dust (bearing adsorbed
contaminants) to off-site residents would be minimized by appropriate engineering control measures such as
dust suppressants. Workers who implement Alternative 3 would be adeguately safeguarded by using appropriate
personal protective eguipment (PPE) to prevent exposures to contaminated soils and landfill materials,
contaminant-laden dusts, and airborne VOCs. OSHA standards would be followed and proper PPE would be used
during all remedial activities.

No permanent adverse impacts to the environment are anticipated to result from construction of the cap
system. Erosion control measures such as hay bales and silt fences would be used to prevent damage to the
environment from sediment runoff. Following excavation of landfill wastes from the southern hillside slope,
this area would be stabilized to prevent erosion.

The cap system placement would reguire approximately 18 months to implement, including pre-design and
design activities. Upon completion of the cap, Alternative 3 would achieve the RAO for protection of human
health by preventing exposure to contaminated soils and the RAO for minimizing leaching of contaminants.
Deed restrictions and local ordinances may take a year or longer to implement, depending on the level of
cooperation by Site owners and municipal officials.

6. Implementability

This evaluation criteria addresses the difficulties and unknowns associated with implementing
technologies, the ability and time necessary to obtain reguired permits and approvals, the availability of
services and materials, and the reliability and effectiveness of monitoring. Alternative 3 is implementable.
No anticipated difficulties or uncertainties exist in consolidating landfill wastes and
constructing the cover system because only common construction technigues are reguired.

Long-term monitoring (sampling and analyses) only reguires readily available resources. Deed
restrictions and ordinances may or may not be difficult to implement and enforce depending on the level of
cooperation by Site owners and municipal officials.

Since long-term monitoring is included under Alternative 3, contaminant presence and migration could be
assessed. Monitoring of groundwater would be effective for detecting, changes in groundwater guality that
may indicate landfill failure and for identifying potential impacts to downgradient receptors.

Permits would not be reguired under Alternative 3 because all activities would be conducted on the Site;
however, the substantive reguirements of all ARARs would be met as described previously. Permits for the
ultimate discharge of storm water runoff to off-site locations may be reguired. Coordination with other
agencies may be reguired for the five-year review process and for implementation of local ordinances.
Coordination with the property owner would be reguired to implement deed restrictions.

There are ample companies with the trained personnel, eguipment, and materials to perform Site
preparation, construct the cover system, install fencing, and perform maintenance and long-term monitoring.
Regulatory personnel and environmental specialists are readily available to perform effective 5-year reviews.

7. Cost

CERCLA reguires selection of a cost-effective remedy that protects human health and the environment and
meets the other reguirements of the Statute. The capital costs for Alternative 3 total $4,336,000. The
average annual O&M costs are $306,200, and 5-year reviews cost $28,000 per event. Over a 30-year period, the

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net present worth cost is $8,200,000 (at a seven percent discount rate).

8 .   State Acceptance

     PADEP has been consulted throughout the investigation of the Berkley Products Site and supports the
selection of Alternative #3 as the Preferred Alternative.

9.   Community Acceptance

     The Proposed Plan was available for public review and comment from April 8, 1996 to May 4, 1996.  A
public meeting for the Proposed Plan presenting Alternative #3 as the Preferred Alternative was held on April
17, 1996, at the West Cocalico Township Building.

     Four written comments were received during the comment period.  Oral comments were accepted at the
public meeting and a transcript of that public meeting is included in Attachment 1 of this Record of
Decision, the Responsiveness Summary.  The significant comments are summarized and addressed in this
attachment.

IX.  SELECTED REMEDY

     Based on consideration of the information available for the Berkley Products Site, including the
documents available in the administrative record file, an evaluation of the risks currently posed by the
Site, the requirements of CERCLA, the detailed analysis and comparison of evaluated alternatives and public
comments received, EPA has selected Alternative 3; Consolidation, Capping and institutional Controls as the
remedy to be implemented at the Berkley Products Site.

     As described in the description of Alternative 3, the selected remedy, shall include the following
components:

    !  Predesign investigations,
    !  Site preparation
    !  Consolidation of landfill wastes,
    !  Site grading,
    !  Cover system consisting of Subgrade, Gas vent system, Barrier layers, Drainage layer and
      Top layer (vegetated) ,
    !  Security fencing,
    !  Erosion control,
    !  Institutional controls,
    !  Long-term operation  and maintenance,
    !  Groundwater, surface runoff, leachate spring and seep monitoring  (annual), residential well
      monitoring  (semi-annual) ,  and
    !  Five-year reviews.

X.   PERFORMANCE STANDARDS

Pre-Design Investigations and Activities

     Prior to the remedial action implementation, a topographic survey and a geotechnical engineering
study will be conducted to obtain data necessary to design and construct the cover system.  Potential
subsidence of the landfill materials and soils will need to be investigated to estimate settling rates in
different areas of the landfill and whether actions would be required to minimize future problems associated
with differential settlement.  Differential settling could damage the cover system and promote possible human
and animal exposures and contaminant migration.  The geotechnical investigation may include load tests in
discrete portions of the landfill to identify the rate of waste materials consolidation under loading.  The
load test data could be used in the cover system design;  however, test results may not provide reliable
information for the entire landfill,  which is very heterogeneous.  Alternatively, the waste materials may be
surcharged,  causing settlement,  so that future settling is minimized.   After settlement has reached the
desired goal base on field observations, the surcharge materials could be used as the subgrade for the cap
system.

     Borings,  sampling,  and analyses may be required as part of a pre-design to more fully delineate the
extent of the landfill materials on the plateau of the hill, the extent of landfill materials east of the
plateau, and the thickness and extent of materials on the southern slope of the landfill.  This information
is necessary to design the cover system and refine estimates of the volume of materials to
be removed from the southern slope.  Additional soil gas sampling may also be needed to assess the types of
soil gases present and whether there are gas pockets.   This information can assist in the gas vent layer
design.

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A topographic survey of the Site will be performed so that survey results can be used in the cover
system design. A traffic management plan will need to be developed and submitted to the Pennsylvania
Department of Transportation (PennDOT) for review and approval.

Site Preparation

During all phases of the site activities, preparation through construction and maintenance, erosion and
sedimentation control measures will be taken in accordance with PA Code 25 §102.2 through 102.24.

The Site has been unused for a number of years and is heavily overgrown by vegetation. Site preparation
will reguire the clearing and grubbing of the vegetative growth that currently covers much
of the landfill. The central portion of the landfill appears to have been cleared of trees and large brush
in the past, and only low-lying bushes and grasses are present. The perimeter of the landfill (east of the
plateau) has a number of trees that may need to be cleared so that the cap can cover all waste
materials and debris. The southern slope of the Site will need to be cleared of trees and vegetative
growth so that debris, landfill materials, and possibly contaminated soils could be removed by excavators for
consolidation back into the landfill.

Silt fences, staked hay bales, or other appropriate measures will be reguired to minimize erosion
effects while the trees and vegetation are being removed. Silt barriers will be placed at the perimeter of
the level portions of the landfill and at the toe of the landfill area to prevent silt and soil
movement to downslope areas and properties.

Site utilities will need to be established prior to the start of Site remediation. Electric and
telephone lines are available along Wallups Hill Road, which abuts the landfill property. Water will have
to be obtained from an off-site source for dust-control purposes. Filled tankers could be brought on
Site and the water could be used as needed.

Staging areas will be established to stockpile cover system materials, temporarily excavated soil and
landfill materials, or eguipment. Construction of access roads may be reguired to support the anticipated
truck and heavy eguipment traffic and to prevent erosion, per PA Code 264.301(1). Fencing will be installed
at key entry points (roads, large open areas) to limit unauthorized access to the Site during construction.

Consolidation

An estimated 18,056 cubic yards of materials (contaminated soils and leachate sediments and the landfill
materials that had been end-dumped from trucks) are deposited on the southern face of the hillside. Once the
southern slope is cleared and grubbed, the soils and materials will be excavated using truck-mounted dragline
excavators, power shovels or other appropriate eguipment. Because of the steep slopes, the safest
positioning of heavy eguipment would be on the relaltively level portions of the landfill (plateau area).
The excavated materials would be lifted to the level portion of the landfill
and emptied into dump trucks or temporary stockpiles. The excavated materials would then be dumped or
backfilled on the landfill, graded, and compacted.

As necessary, engineering controls will be implemented during consolidation and backfilling to prevent
airborne emissions of fugitive dusts in accordance with PA Code 25 §12 3.1 (c). Temporary covers may be
applied to soils and landfill materials storage areas, and dust suppressants and water would be applied to
wet down materials, as appropriate, to minimize fugitive dust emissions. The delineation of actual areas to
be addressed and the guantities to be consolidated and compacted will be made after evaluation of the results
of the predesign investigation.

Site Grading

After the soils and landfill materials from the hillside are consolidated at the landfill, grading will
be reguired prior to placement of the cover system. Compaction and grading of the soils and landfill
materials will be performed as needed to conform to the reguirements specified in §264.301 (5) and
§264.301 (6). The appropriate slopes for the base of the cover (to facilitate drainage) will be
determined as part of the cover system design.

Cover System

A low-permeability cover-system will be designed and installed to prevent it human and animal exposures
to soil and landfill material contaminants and to minimize infiltration and resulting organics
and metals leaching into groundwater. The cover system will be designed and installed in accordance
with the sections of the Commonwealth of Pennsylvania Hazardous Waste Regulations PA Code, Title 25, Article
VII, Chapter 264 specified below.

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For the purpose of this analysis, a composite multi-media cover system described as the likely
representative capping option. The exact design of the landfill capping system may be modified during design
to address Site-specific features. The cover system will be installed over the entire 5 acre landfilled area
of the Berkley Products Site. Descriptions of the individual cover layers are summarized ns follows from
bottom to top:

Subgrade - The base layer of the cover system conforming to §264.302 (a)(6) should be a well-
compacted and smooth surface of sufficient thickness to prevent puncture of the barrier layer
by landfill materials. The subgrade may be a well-graded sand and grabel. A geotextile
material may be used above the subgrade to separate the sand and gravel from the gas vent layer.

Gas Vent System - The objective of this layer is to vent methane, carbon dioxide, hydrogen
sulfide, and other VOCs to the ambient air. Without provision for venting, the placement of a
low-permeability barrier over the landfill materials could cause accumulation of undesirable soil
gases that could permeate upward and disturb the cover system or migrate laterally outside
landfill boundaries. The gas collection/venting layer will conform to 25 §264.301 (12) and may
be made of gravel, coarse sand, or geosynthetic materials. During design, it will be
determined whether an active gas venting system, with a blower and appropriate pollution
control device (e.g., flare, biofilter, activated carbon, etc.), is necessary or if a passive vent
system will be adeguate.

If passive venting system is installed, landfill gases will be monitored (periodically, following
completion of the cover system) to ensure that the passive gas collection system is adeguately
controlling gas emissions. If problems such as landfill gas migration or excess odors are
detected, then an active vapor collection system may be warranted to control gas emissions.
A passive venting system will be designed to be easily modified to an active system.
Treatability testing would be reguired to design an active vapor control system to effectively
manage the landfill gases.

Barrier Lavers - These layers will be designed to minimize precipitation infiltration into the
underlying soils and landfill materials and will conform to §264.302 (a)(6). A minimum of 2
foot of compacted clay or a geomembrane of at least 50 mil thickness will be used for each
layer. The clay or the geomembrane barriers will have a maximum permeability of 1 x 10-7 cm/s.

It is likely that geomembranes will be selected as the appropriate barrier layers for this landfill.
Geomembranes can be installed more efficiently than a compacted clay layer. The
geomembrane may be a flexible membrane liner (FML) composed of low-density synthetics for
tolerating subsidence-induced strains.

Drainage Layer - A drainage layer conforming to §264.302 (a)(6) will be installed to prevent the
accumulation of water above the barrier layers. Ponded water could damage the
geomembrane or cause erosion of the top layer. The drainage layer will promote the removal
of water to areas outside' the cover. The drainage layer can be a geosynthetic material or
coarse sand/gravel (less than 3/8"). A geotextile filter fabric may be placed over the drainage
layer to prevent the entry of fine-grained particles into the drainage layer. Precipitation
infiltration that reaches this layer will be channeled to a toe drain and would ultimately be
discharged to Cocalico Creek.

Top layer - The objective of this layer is to protect the cover from erosion by rain or wind and
from burrowing animals. A minimum of 2 feet of uniform, compacted soil conforming to PA

Code 25 §264.310 (1) will be placed over the drainage layer. A biotic barrier layer (5 to 10
inches) comprised of stones or cobbles may be installed under the compacted soil layer to
prevent animal intrusion into the cover or underlying waste materials.

The final surface slope of cover system in the plateau area shall have a slope of not less than
three percent (3V:100H), but not exceeding 15 per cent, per PA Code 25 §264.301 (5), to
ensure slope stability control erosion, and allow compaction, seeding, and revegetation of the
cover materials. A final slope in excess of 15 percent is allowable if horizontal terraces are at
least 10 feet wide for every 20 feet maximum rise in elevation of the slope. The terrace would
be sloped one percent into the landfill. The final slope would also promote precipitation runoff
while inhibiting erosion or infiltration. The slope of the cover system in the plateau area will be
approximately five percent, which conforms to the existing topographic rade. It is anticipated
that the cover system in the eastern portion of the landfill would have anal slope of about 20
percent (20V:100H). It is also expected that two terraces will be constucted (10 feet wide
minimum) at an approximate 20 foot change in elevation. A 20 feet change was assumed so
that the terraces would be more evenly spaced on the eastern slope of the landfill.

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Surface run-on and run-off controls will be required, given the large surface area the cover
system is anticipated to encompass. Surface runoff will be channeled, via drainage swales or
trenches, to surface drains, located on the perimeter of the cover system, and ultimately
discharged to Cocalico Creek. The cover system will be designed to manage surface water
and control soil erosion and sedimentation based on a 24-hour precipitation event for a 25-year
storm, per PA Code 25 §264.301 (8).

In accordance with PA Code 25 §264.310(4), the top layer will be vegetated with permanent
plant species (excluding trees, woody shrubs, or deep rooted plants) to minimize erosion and
soil loss of the final cover.

Final determination of the materials to be used in the cover system will be determined during
the engineering design. The capped area is expected to encompass all contaminated soils
and landfill materials. Routine maintenence and repair of the cover system will be required to
ensure its long-term effectiveness.

Security Fencing

During construction, security fencing will be installed to deter or prevent unwanted human and animal
entry into the landfill area, in accordance with PA Code 25 §264.14(b)(4). Permanent security barriers,
either natural or artificial, or a combination, will be determined during design.

Removal Actions

If, during the consolidation, grading and capping activities, it is determined necessary to remove
materials from the Site, all excavation, handling, transportation and disposal activities will be conducted
in compliance with all state and local laws to the extent not inconsistent with federal laws.

Erosion Control

Erosion control measures will be taken during consolidation, grading and construction activities. After
contaminated soils and landfill materials have been removed from the southern hillside slope, this area will
be stabilized to prevent erosion. Measures such as planting new vegetation or placing rip-rap will be taken
to minimize erosion effects. The slope may be graded or terraced to reduce the grade, thereby minimizing
surface water runoff that may erode the hillside. All actions taken will be in accordance with PA Code 25
§§102.2 through 102.24.

Long-Term Monitoring

The groundwater monitoring program will be designed to meet the requirement of §264.97 and §264.98. The
groundwater, surface runoff, and springs and seep leachate will be sampled to monitor the quality of
groundwater leaving the Site and assess the potential impacts to downgradient areas. It is anticipated that
the cover system will greatly reduce precipitation infiltration into the landfill, resulting in reduced
leaching of chemicals into groundwater. The frequency of monitoring and the number of wells and analytical
parameters may be decreased if the 5-year reviev determines that significant contaminant leaching reduction
or improvement of groundwater quality has been attained.

Groundwater samples will be collected quarterly from approximately five existing and ten new monitoring
wells to be installed during the remedial action and analyzed for the list of chemicals identified in PA Code
25 §273.284 and for Site-specific contaminants. Water levels will be measured
during each sampling round to compile data to more fully define the hydrogeology of the landfill and
adjacent properties.

Initially, approximately 30 residential wells situated primarily downgradier of the landfill will be
sampled semiannually for VOCs and annually for SVOCs, pesticides/PCBs, and metals. Current data suggest that
the residential wells do not appear to be affected by Site contamination. The sampling results will be used
to assess whether contaminated groundwater has affected drinking water supplies and whether additional
remedial or removal actions would be necessary.

Stormwater runoff from the landfill will be sampled and analyzed annually for VOCs, SVOCS,
pesticides/PCBs, and metals. It is anticipated that the discharge will be sampled during one storm event.

The monitoring program will be conducted for the purpose of assuring that unacceptable risks do not
develop in the future. The information generated in the monitoring program will be analyzed individually and
collectively to identify trends. This information will be incorporated into the five-year review process to
assure that the remedy remains protective of human health an the environment.

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Institutional Controls

After the cover has been constructed, deed restrictions and local ordinaces will be used to
significantly limit the future activities that could result in intrusion into and possible damage of the
cover and accidental exposure to-the landfill wastes. Use of underlying contaminated groundwater as a
potable water supply, without treatment, would be prohibited.

Operation and Maintenance

To ensure the proper functioning and protectiveness of the cover system, routine maintenance and repairs
of the security barrier, runoff and drainage systems, gas vent system and the cover system will be reguired.
Routine mowing and repair of the cover will minimize th effect of erosion.

Five-Year Reviews

Since contaminants remain on the Site, a review of Site conditions and risks will be conducted every 5
years or less, as reguired by CERCLA. The reviews will consist of evaluation of analytical and hydrogeologic
data developed in the monitoring program, assessment of whether contaminant migration has increased, and
determination as to whether human or biological receptors or groundwater resources are at risk. If the
monitoring program reveals unacceptable Site-related risks, such as exceedance of MCLs or risk based levels
in the early warning monitoring wells, the Site will be evaluated and appropriate action will be taken.
Exceedance of MCLs or risk based levels in the residential wells would be cause for provision of alternate
water supplies. If it is determined that there is unacceptable risk to ecological receptors, further
remedial actions will be available.

XI. STATUTORY DETERMINATIONS

EPA's primary responsibility at Superfund sites is to develop remedial actions that achieve protection
of human health and the environment. Section 121 of CERCLA, 42 U.S.C. §9621, also establishes several other
statutory reguirements and preferences for EPA to consider when selecting a Superfund remedy, including the
following:

The Selected Remedy must comply with applicable or relevant and
appropriate environmental standards established under federal and
state environmental laws, unless there are grounds for a statutory waiver.

The Selected Remedy must be cost effective and should use
permanent solutions, alternative treatment technologies and resource
recovery methods, to the maximum extent practicable.

CERCLA mandates a preference for treatment remedies that
permanently and significantly reduce the volume, toxicity and mobility
of hazardous wastes.

The discussion below describes how the Selected Remedy meets these statutory reguirements and
preferences.

A. Protection of Human Health and the Environment

The Selected Remedy protects human health and the environment by installing a cap system that will
minimize the potential for direct contact with contaminated materials, the potential for infiltration and
resultant contaminant leaching to groundwater and the potential for migration of contaminants off-site. The
long-term groundwater monitoring program and five-year reviews will ensure that no resident is at risk of
future exposure to contaminated groundwater.

B. Compliance with Applicable or Relevant and Appropriate Reguirements (ARARs)

As described in Section VIII, Summary of Comparative Analysis of Alternatives, and in Section X,
Performance Standards, the Selected Remedy shall attain all action and chemical-specific ARARs identified for
this Site. There are no location-specific ARARs identified for the Berkely Products Superfund Site.

The Commonwealth of Pennsylvania has identified The Land Recycling and Environmental Remediation
Standards Act, the Act of May 19, 1995, P.L. 4, No. 1995.2, 35 P.S. §§ 6018.101 et. seg. ("Act 2") as an ARAR
for this Site, however, EPA has determined that Act 2 is not an ARAR for the Berkley Products Superfund Site.

C. Cost Effectiveness

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The selected remedy is cost effective because it has been determined to provide overall effectiveness
proportional to its costs in reducing the risks associated with direct contact with contaminated materials
and potential off-Site migration of contaminants.

D. Utilization of Permanent Solutions and Alternative Treatment
Technologies to the Maximum Extent Practicable

EPA has determined that the selected remedy represents the maximum extent to which permanent solutions
and alternative treatment technologies can be utilized while providing the best balance among the other
evaluation criteria. The contaminated materials will be consolidated and capped in place, and the cap will
be maintained through a long term Operation and Maintenance Program. This remedy provides the best balance
of long-term and short-term effectiveness and permanence; cost; implementability; reduction in toxicity,
mobility or volume of hazardous waste through treatment; state and community acceptance; and, the statutory
preference for treatment as a principal element.

E. Preference for Treatment as a Principal Element

The Selected Remedy does not satisfy the statutory preference for remedies that employ treatment as a
principal element to permanently reduce the toxicity, mobility or volume of hazardous substances. The
Selected Remedy will not reduce the toxicity, mobility, or volume of contamination through treatment because
no treatment is used to address the contaminated so and landfill materials. The chemicals in the soil and
landfill materials and underlying soils wil not be treated or destroyed and would remain at the facility,
however, mobility of contaminants from the soil and landfill materials will be minimized by the cap system.

XII. DOCUMENTATION OF SIGNIFICANT CHANGES FROM PROPOSED PLAN

EPA reviewed all written and verbal comments received during the Proposed Plan Comment Period. Upon
review of these comments, and especially the comments from the Commonwealth of Pennsylvania, it was
determined that the landfill shall be closed pursuant to the state hazardous waste regulations specified in
the Section VIII, Summary of Comparative Analysis of Alternatives and Section X, Performance Standards. The
Proposed Plan for this Site indicated that the landfill would be closed pursuant to the relevant state
municipal waste regulations but with the cap system to be designed to meet the higher standard of the
hazardous waste regulations specification. Most of the remaining standards of the municipal waste
regulations are analogous to the corresponding hazardous waste regulations and as such there is no
significant change in the actual reguirements for the remedy, but the appropriate legal citations have been
substituted.

Additionally, the Proposed Plan included a permanent security fence to protect the landfill from
unwanted human and animal entry. Following the evaluation of comments, this component of the remedy was
modified to provide a temporary security fence which will provide security for the period when the waste will
be exposed and construction eguipment present; this temporary fence will be removed upon completion of
construction. Appropriate components of a permanent security barrier, either natural (e.g. hedges) or
artificial (Locking gates), or a combination, will be determined during design.

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                          RESPONSIVENESS SUMMARY

                     BERKLEY PRODUCTS SUPERFUND SITE

                  West Cocalico Township, Pennsyilvania

                         RESPONSIVENESS SUMMARY
                    BERKLEY PRODUCTS SUPERFUND SITE
                          DENVER, PENNSYLVANIA

     This responsiveness summary is divided into the following sections:

Overview:      A summary of EPA's proposed remedy for the site

Background:    A brief history of community interest and concerns raised during
               remedial planning at the Berkley Products Site.

Responses:     A summary of the commentors'  issues and concerns and EPA's
               responses to those concerns and issues.  "Commenters" may include
               local homeowners, businesses, the municipality, and potentially
               responsible parties  (PRPs).

OVERVIEW

               EPA completed two studies in October 1995 and September 1995.  The first study, called a
remedial investigation, was conducted to charaterize the Site, identifying the physical and geological
features in and around the site, the characteristics of surface and groundwater, and the types and amounts of
contamiation at the site. The second study,  called a feasibility study, used the information gathered in the
remedial investigation formulate and compare clean-up methods ar EPA to evaluate as possible remedies for the
site.  As a result of the remedial investigation, EPA discovered high levels of the following contaminants in
the soils and ground water at the site: lead, benzene, trichloroethylene (TCE),  tetrachloroethylene  (PCE),
hydrocarbons, and polychlorinated-byphenyls  (PCBs).   EPA believes that people could come in contact with
these substances through the soft or the ground water, if the site is not cleaned up.

                 As part of the process to address the contaminated soil under the landfill area and the
ground water beneath the site,  EPA issued the proposed remedial action plan  (proposed plan) on April 8, 1996.
The proposed plan outlined the clean-up alternatives described in the feasibility study and discussed in
discussed EPA preferred clean-up method.  Before issuing the proposed plan, EPA compared the proposed
clean-up methods to a series of evaluation criteria.  These criteria serve as clean-up standards
for all Superfund sites.  EPA's preferred alternative is the best combination of the evaluation criteria
listed below:

                      Threshold criteria

                          Overall protection of human health and the environment
                          Compliance with applicable or relevant and appropriate
                          requirements  (ARARs)

                      Balancing criteria

                          Long-term effectiveness and permanence
                          Reduction of toxicity, mobility, or volume through treatment
                          Short-term effectiveness
                          Ability to implement
                          Cost

                      Modifying criteria

                          State acceptance
                          Community acceptance

                  After considering state and community acceptance of the clean-up method, EPA issued its
preferred alternative in a document called the record of decision. EPA's preferred clean-up method satisfies
the criteria for remedy selection and meets the clean-up objectives for the site.  As outlined in the
proposed plan and the record of decision, EPA's preferred alternative - Consolidation, Capping, and Deed
Restrictions - includes the following measures to address the soil and ground water contamination at
the site:

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                          Pre-design investigations
                          Site preparation
                          Consolidation of landfill wastes
                          Site grading
                          Cover system
                                Subgrade
                                Gas vent system
                                Barrier layers
                                Drainage layer
                                Top layer  (vegetation)
                          Security fencing
                          Erosion control
                          Institutional controls
                           Long-term operation and maintenance
                           Surface runoff,  leachate spring and seep  monitoring (annual),
                           residential  well monitoring (semi-annual)  and quarterly monitoring
                           well  monitoring.
                           Five-year reviews
BACKGROUND
            To announce the availability of and obtain public input on the proposed plan, EPA held a public
comment period from April 8, 1996, to May 7, 1996.  During the comment period, on April 17, 1996, EPA held a
public meeting to provide citizens with information about the site and the proposed clean-up methods.  The
public meeting also provided an opportunity for citizens to ask guestions about or comment on the site and
the proposed clean-up methods.  EPA announced the public comment period and public meeting in a newspaper
display advertisement placed in the April 8, 9, and 15, 1996, editions of Lancaster New Era and the Lancaster
Intelligencer.  EPA also announced the public comment period and meeting in a four-page fact sheet
summarizing the proposed remedial action plan which was sent to those parties on EPA's site mailing list.

             Interest in the Berkley Products Superfund Site has been steady throughout its history.  The
residents most interested in the site tend to be those living near the site.  Most area citizens are
concerned primarily about the contaminants at the site, previous site work conducted by EPA, and the methods
proposed to clean up the site.  Many citizens support EPA's preferred clean-up method.


RESPONSES:  SUMMARY OF COMMENTORS' MAJOR ISSUE AND CONCERNS

            This section provides a summary of the commentors'  major issues and
concerns and expressly acknowledges and responds to those raised by the local
community.  The major issues and concerns on the proposed remedy for the Berkley
Products Site received at the public meeting on April 17, 1996, and through comments
received by EPA representatives by mail and telephone can be grouped into five
categories:

            A.  Extent and Type of Contamination
            B.  Clean-Up Activity
            C.  Possible Discovery of Additional Waste During Proposed Clean-Up
                Activities
            D.  Consideration of Other Alternatives
            E.  Results of Previous Sampling Activities
            F.  Cost Associated with the Proposed Remedy

The guestions, comments, and responses are summarized below.

A.          Extent and Type of Contamination

(1)         A citizen wrote to EPA asking about the extent of the contamination in
            the site area.

EPA Response:  The Berkley Superfund Site consists of the approximately five acre
               landfill where wastes were buried, along with dumping and spillage over
               the area extending down the southern slope.  Leaching of the
               contaminants from the waste have contaminated the groundwater
               directly beneath and adjacent to the landfill.  The contaminated
               groundwater flows in a northeasterly direction alot the rock strata at
               such a steep angle that it is rapidly removed from surface availability.

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The extent of contamination is described in more detail in the text of the ROD.
(2)
At the public meeting, a citizen inquired about dead vegetation in a 50-
foot area along Penny Hill Road. This citizen inquired as to whether
contamination from the site had caused the vegetation to die in this
particular area.
EPA Response: Vegetation in the area along Penny Hill Road has been affected by
contamination from the site. EPA found a small leachate seep in this
area that has exposed local vegetation to contaminants from the site.

The leachate seep is caused by rainwater entering into the landfill,
collecting contamination, and then seeping out of the hill in this area.
However, it appears that a significant amount of new plants, such as
briars, are growing in this area. This leads EPA to believe that the
contantination leaching from the site has reduced over the past few
years. As part of the Selected Remedy EPA will collect the
contaminated mud and soil from around the leachate seep and
consolidate it with the rest of the waste at the site. The proposed cap
will stop rain water from entering the landfill, and is expected to stop
the leachate seep.

(3) A citizen asked EPA about the contents of the drums as removed from the site.

EPA Response: Analysis conducted prior to disposal led to classification of drums as
containing "flammable liquid/solid and PCB flammable liquid/solid
wastes. Further description of the drum excavation can be found in the
Federal On-scene Coordinator's Report for the Berkely Products Site,
which can be found in the Administrative Record for his Site.
(4)
A township official asked EPA if the contaminants it the site are more
dangerous now that they have been buried for numerous years.
EPA Response: Many contaminants degrade to less hazardous compounds, however
there are some chemicals that have more hazardous intermediate
degradation products. EPA does not know exactly what went into the
landfill during its active life. However, all of the sampling and analysis
was conducted to evaluate its present condition. The concentrations
and associated risks described in the ROD and the Remedial
Investigation Report as well as the Selected Remedy reflect the current situation.

(5) A citizen asked EPA to discuss the types of contaminants found in the monitoring wells.

EPA Response: In response, EPA described some of the compounds found in
Monitoring wells 2, 3, and 4, which are immediately adjacent to the site,
indicating file presence of: chlorobenzene; ethylbenze; 1,2-
dichloroenthane; xylene; Bis(1-ethylhexyl)phthalate; 1,4-
dichlorobenzene; benzyl alcohol; dieldrin; and vinyl chloride. A further
summary of contamination can be found in the ROD and in the
Remedial Investigation Report located in the Administrative Record for this Site.
(1)
Clean-Up Activity

A citizen asked if the soil already covering the top of the landfill would
be disposed of or included in the materials to be covered by the proposed cap.
EPA Response: EPA considers the soil covering the landfill to be part of the landfill
wastes. The Selected Remedy calls for consolidating (combining) all
landfill wastes, including the current cap, leveling the landfill surface,
and then placing a multi-layer cap over the surface of the landfill.
(2)
A citizen inquired whether EPA plans to install additional monitoring
wells at the site.
EPA Response: The proposed remedy calls for installing "sentry" wells between the site
and nearby residences, in the path of the ground water flow. The
contaminated ground water migrates to the northeast, rather than to

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the south, due to a natural bedrock formation which slopes downward
in a northerly direction. EPA plans to place new monitoring wells
north of the site and use them to determine if contamination from the
site has spread after the site is capped. These wells will also serve as
"early warning" wells to identify if any contamination is heading in the
direction of the residential wells near the Site.
(3)
A citizen expressed concern about drums that may ave been dumped
over the side of the landfill. This citizen asked how EPA planned to
address these drums.
EPA Response: EPA considers the area mentioned by this citizen as part of the site.
During the proposed remedy, EPA will uncover waste from this area
and consolidate it with theother materials in the landfill. If additional
drums are uncovered in this area, EPA will evaluate the materials
contained in the drums and then make a proposal to EPA management
on how to address the drums. Consolidation into the landfill with the
rest of the wastes or removal from the Site are two possible approaches
that may be evaluated.

(4) A citizen asked if deed restrictions would be placed on the site property.

EPA Response: Yes. EPA plans to place deed restrictions on the site property to
prevent the drilling of wells in the immediate vicinity of the site and on
the site itself.

At the public meeting, a citizen asked about the possibility that the
activities of the proposed clean-up plan will increase environmental
problems in the area rather than correcting the current ones?

EPA Response: EPA evaluates all potential risks during the design phase of the remedy.
In this phase, EPA outlines every action that the Agency will conduct in
cleaning up the site. Also during the design phase, EPA will look at
the wastes at the site and determine what procedures are necessary to
address the wastes. In the unlikely event that unexpected contaminants
are discovered during the remedy, EPA will take a all necessary
precautions to protect workers, citizens, and the environment. Some of
the precautions EPA takes include working on small areas at a time,
placing temporary covers on the areas being workel on, and monitoring
and controlling the amount of dust caused by excavation activities. All
potential risks are considered in the design and are addressed further in
the Health and Safety Plan developed specifically for the activities
planned for the Site.

The final disposition of the Site will be as a capped landfill, with all of
the waste consolidated under the cap. The disturbed areas will be
stabilized and revegetated. The effect of the capping of the landfill will
be to minimized or eliminate the potential for contaminants leaching into
the groundwater. All of this points to an improved condition for the
environment.

(6) A citizen asked if there would be additional risk to the ground water
during clean-up activities.

EPA Responde: It is not likely that Site activities would add to the risk to groundwater.
Currently the landfill has only a patchy cover and little protection
against infiltration of rainwater. Site activities will necessarily disturb
that cover but will guickly replace it with an improved impermeable cap.

C. Possible Discovery of Additional Waste During Proprosed Clean-Up Activities
(1) Several citizens asked what measures EPA would take if additional
wastes or waste containers were discovered during the clean-up activities.

EPA Response: EPA takes many precautions prior to conducting any action at a site.
EPA does not expect to encounter additional waste or waste containers

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during the proposed clean-up activities. However, if additional wastes
are found at the site, EPA will take appropriate measures to evaluate
the kinds and amounts of wastes found. Once EPA determines what
the wastes consist of, the Agency will determine whether it is feasible to
consolidate those wastes in the landfill or to have those wastes removed
from the site.

(2) A citizen asked what actions EPA would take if contamination is found
in residential wells in the area several years after the remedy is completed?

EPA Response: A feature of all the clean-up methods discussed in the Proposed Plan is
the five-year review. This measure reguires EPA to review the site at
least every five years after the clean-up actions are completed to ensure
the effectiveness of the remedy as well as the safety of area citizens.
Additionally, part of the remedy EPA prefers for the Berkley Products
Site includes installing several monitoring wells between the site and
nearby residences and guarterly testing of these wells. These wells
would indicate the presence of contamination befor it reaches
residential wells. EPA also plans to sample the residential wells semi-
annually. EPA also explained that if contamination from the site is
found in the monitoring program, the Agency wouk take immediate
action to address the matter.
D.
Consideration of Other Alternatives
(D
EPA Response:
(2)
EPA Response:
(3)
A citizen asked why EPA's preferred alternative is ot the "no action" alternative:

As described in the text of the ROD, the no action alternative would
not provide adeguate protection to humans, animals, or the
environment. No action would be taken to reduce or prevent potential
direct exposure to contamination from the site. Additionally, this
alternative does not prevent further contamination of soils and ground
water from occurring. As the no action alternative does not protect
human health or the environment or prevent the further spread of
contamination from the site, EPA did not select this alternative as the
preferred clean-up method for the site.

A citizen asked why EPA does not dispose all the landfill waste off-site.

Implementability and Cost are the primary criteria that influenced EPA
not to select removing the landfill waste and disposing it off-site. Of all
expenses involved with removing landfill waste, the largest expense is
paying for disposal. EPA has found that a significant amount of
material in the landfill is contaminated with organics and would be
classified as hazardous waste. Wastes classified as hazardous must be
taken to a hazardous waste landfill, while non-contaminated waste could
be taken to a municipal landfill. EPA estimates that 164,800 tons of
soil and waste would have to be removed from the site. This could
result in costs ranging from $44 million to $164 million for excavating,
testing, and disposing of material from the landfill.

In addition to removing the landfill material, EPA would have to bring
in approximately three trucldoads of clean soil ever day to fill in the
hole left by the removed landfill waste. Additional!, site workers
would be reguired to wear self-contained breathing apparatus, air tanks,
or air lines. In sum, there are extraordinary costs associated with
removing materials from landfills. When considering clean-up methods,
EPA reviews the associated costs and attempts to select a plan that
primarily protects human health and the environment, but that also is
implementable and cost efficient. On-Site capping satisfies those considerations.

The Borough of Denver, in a letter, asked that EPA consider cleaning
up the Site completely, rather than the plan currently proposed. The
basis for their concern is that in dryer seasons, Denver must take a
significant portion of its water supply from the Cocalico Creek. The
Cocalico Creek, upstream of the water intake for Denver, passes within
approximately 1,200 feet of the Site.

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EPA Response:
E.

(1)
EPA has evaluated water samples of the creek both upstream and
downstream of the Site.  The results have shown that no Site-related
contaminants are present at levels that would present unacceptable risk.
The upstream and downstream results are in fact very similar making it
difficult to attribute anything in the stream to the site.  The Selected
Remedy will serve to minimize the potential pathways for Site
contaminants to enter the creek.  The cap will serve to cover any
surface contaminant that would have been available for erosion and
transport to the creek, and will also minimize contaminant leaching to
groundwater which could then eventually discharge to the creek.  The
monitoring program will be designed to show any spread of
contamination in the groundwater long before it would reach the creek,
and will also include sampling of the creek's surfac water.  In
summation, EPA feels that, with the Selected Remedy implemented,
there is negligible risk to the Cocalico Creek.

Results of Previous Sampling Activities

Several citizens asked EPA about the nature of the wastes found in the
drums removed from the site.
EPA Response:  See answer to guestion about drums presented above
(2)
Several citizens asked EPA for the results of the well sampling of
residences near the site.
EPA Response:  EPA sent out the results of all residential sampling to the residents.
               The ROD text contains summaries of this information, and the full data
               packages can be found in the Remedial Investigaticn Report located in
               the Administrative Record for this Site.
(3)             A citizen asked if natural springs on the side of the mountain bordered
               by Greenville Road had been sampled.

EPA Response:  EPA has sampled most of the natural springs around the site.   Sampling
               results do not show a significant presence of site-related contamination
               in the natural springs and exposure risk has been shown to be negligible.

F.             Cost Associated with the Proposed Remedy

(1)             A citizen asked EPA to explain how the $8.3 million for the proposed
               remedy was broken down.

EPA Response:  The Total estimated cost for the Alternative 3 is $8,325,000.  This is
               broken down into the $4,461,000 initial capital cost necessary to
               prepare the Site and construct the cover system as well as install the
               monitoring wells.  The remaining 3,864,000 is the estimated present
               worth value of 30 years of Operation and Maintenance of the remedy
               including maintenance of the landfill and monitoring wells to be
               constructed and sampling and analysis costs of the monitoring program.

(2)             A citizen asked where EPA gets the money to fund the site clean-up.

EPA Response:  EPA can receive money for clean-up activities from two sources.  The
               first is from the potentially responsible parties (PRPs).   PRPs are those
               parties potentially responsible for the contamination at a site.  If the
               PRPs can afford to pay for cleanup at the site or to conduct the
               cleanup themselves, EPA will reguest that the companies do so.
               Otherwise, EPA can use money from the Superfund trust fund to pay
               for cleaning up the site.  The money in Superfund comes from a special
               tax on the chemical and petroleum industries.  EPA plans to use
               Superfund money to pay up front for the cleanup a the Berkley
               Products Site.  At a later date, the Agency expects to take legal action
               against the PRPs to recover costs of the cleanup at the site.

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