Superfund Record of Decision Berks Landfill Spring Township PA


                                    EPA/ROD/R03-97/058
                                    1997
EPA Superfund
     Record of Decision:
     BERKS LANDFILL
     EPA ID: PAD000651810
     OU01
     SPRING TOWNSHIP, PA
     07/22/1997

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                                       RECORD OF DECISION

                                 BERKS LANDFILL SUPERFUND SITE
                                  SPRING TOWNSHIP, BERKS COUNTY,
                                           PENNSYLVANIA


                                            JULY 1997

                                           PREPARED BY
                           THE U. S. ENVIRONMENTAL PROTECTION AGENCY

                                        RECORD OF DECISION
                                  BERKS LANDFILL SUPERFUND SITE

                                            DECLARATION

    SITE NAME AND LOCATION

    Berks Landfill Superfund Site
    Spring Township, Berks County, Pennsylvania

    STATEMENT OF BASIS AND PURPOSE

This decision document presents the final selected remedial action for the Berks Landfill
Superfund Site  ("the Site").   The remedial action was selected in accordance with the
Comprehensive Environmental Response, Compensation, and Liability Act of 1980  ("CERCLA"), as
amended by the Superfund Amendments and Reauthorization Act of 1986  ("SARA") and the National
Oil and Hazardous Substances Pollution Contingency Plan  ("NCP"). This decision is based on the
Administrative Record for the Site.

Although the Commonwealth of Pennsylvania agrees with the approach of the Selected Remedy, it
has not concurred with 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 the public, health, welfare, or
environment.

    DESCRIPTION OF SELECTED REMEDY

The selected remedy described below is the only planned action for the Site.  This selected
remedy addresses on-site ground water contamination with natural containment through
institutional controls; natural attenuation and existing site specific hydrogeologic conditions
in conjunction with long term monitoring; continued existing leachate management system repair,
operation and maintenance; and repairs to the existing landfill caps.

The selected remedy includes the following major components:

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         1.)   Institutional Controls, including title restrictions, restrictive covenants, etc.
               to prevent future consumption of on-site ground water, restrict future
               development at the Site and limit future earth moving activities at the Site;

         2.)   Long-term Monitoring, including installation of a sentinel monitoring well
               cluster, sampling of residential wells, on-site monitoring wells, aguatic habitat
               and combustible gases;

         3.)   Leachate Management System Operation & Maintenance; and

         4.)   Cap Repair and Maintenance, to include, a minimum 1 foot in final cover
               thickness on the eastern landfill and non-forested portions of the western
               landfill. The eastern landfill and non-forested portions of Western Landfill will
               be maintained as wildflower/grass meadow (mowed once per year).   Forested
               portions of western landfill will remain and be maintained.

    STATUTORY DETERMINATIONS

The selected remedy is protective of human health and the environment and is cost effective.
EPA believes that the selected remedy will comply with all Federal and State reguirements that
are legally applicable or relevent and appropriate to the remedial action with the exception of
the Commonwealth of Pennsylvania's reguirements for closure of municipal waste landfills.
Therefore, in accordance with 40 C.F.R. ° 300.430(e)(9)(B),  I hereby waive the provisions of 25
PA Code ° 273 on the basis that EPA will achieve an Eguivalent Standard of Performance in the
protection of human health and the environment by the implementation of the Selected Remedy.
The selected remedy utilizes a permanent solution to the maximum extent practicable and
satisfies the statutory preference for a remedy that employs treatment that reduces toxicity,
mobility, or volume.

Because this remedy will result in hazardous substances remaining onsite above health-based
levels, a review by EPA will be conducted within five years after initiation of the remedial
action to ensure that the remedy continues to provide adeguate protection of human health and
the environment.

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                           BERKS LANDFILL SUPERFUND SITE
                    SPRING TOWNSHIP, BERKS COUNTY, PENNSYLVANIA

                                RECORD OF DECISION
                                 DECISION SUMMARY

                                 TABLE OF CONTENTS

I.    SITE NAME, LOCATION AND DESCRIPTION 	1

II.    SITE HISTORY AND ENFORCEMENT ACTIVITY 	2

III.  HIGHLIGHTS OF COMMUNITY PARTICIPATION 	3

IV.    SCOPE AND ROLE OF THE RESPONSE ACTION WITH SITE STRATEGY 	5

V.    SUMMARY OF SITE CHARACTERISTICS AND EXTENT OF
      CONTAMINATION 	5
      A.   Site Characteristics 	5
           1.    Topography 	5
           2 .    Surface Hydrology 	6
           3 .    Groundwater Use 	6
           4 .    Demography and Land Use 	7
           5 .    General Site Geology 	7
           6.    Regional Hydrogeology 	8
           7.    Local Hydrogeology  	8
      B.   Nature and Extent of Contamination 	9
           1.    Soil 	9
           2 .    Surface Water 	9
           3 .    Sediment 	10
           4 .    Air Monitoring 	11
           5 .    Leachate 	13
           6.    Leachate Collection/Management System	13
           7 .    Cap Conditions 	14
           8.    Groundwater 	16

VI.    SUMMARY OF SITE RISKS 	17
      A.   Human Health Risk Evaluation 	18
           1.    Selection of Chemicals of Potential Concern  	18
           2.    Exposure Assessment 	20
           3 .    Toxicity Assessment 	21
           4.    Risk Characterization 	22
                a.   Background Risks and Hazards 	22
                b.   Off-Site Residential Risks and Hazards  	23
                c.   On-Site Trespasser Risks and Hazards 	24
                e.   On-Site Residential Risks and Hazards 	25
      B.   Environmental Risk Evaluation 	26
           1.    Site Characterization 	26
           2 .    Exposure Assessment 	27
           3.    Risk Characterization 	28
                a.   Potential Risks from Exposure to Soil 	28
                b.   Potential Risks from Exposure to Sediment 	29
                c.   Potential Risks from Exposure to Surface Water  	29
                d.   Potential Risks from Exposure to Leachate 	29

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VII.   DESCRIPTION OF REMEDIAL ACTION ALTERNATIVES  	29
      A.   Alternative No.  1 - No Further Action 	30
      B.   Alternative No.  2 - Institutional Controls and Leachate Management System
           Operation 	30
      C.   Alternative No.  3 - Institutional Controls, Monitoring, Leachate
           Management System Operation, and Leachate Collection System Expansion
           	31
      D.   Alternative No.  4 - Institutional Controls, Monitoring, Leachate Management
           System Operation, and Landfill Cap Repairs  (Cap Repair Alternatives 4A,
           4B, 4C or 4D) 	32
           1.    Cap Repair Alternative 4A	33
           2 .    Cap Repair Alternative 4B 	35
           3.    Cap Repair Alternative 4C 	36
           4 .    Cap Repair Alternative 4D 	38
      E.   Alternative No.  5 - Institutional Controls, Monitoring, Leachate Management
           System Operation, Landfill Cap Repairs  (Cap Repair Alternatives 4A, 4B,
           4C, and 4D), Leachate Collection System Expansion, and Regrading Crown
           of Eastern Landfill 	39

      F.   Alternative No.  7 - Institutional Controls, Monitoring, Leachate Management
           System Operation, Landfill Cap Repairs  (Cap Repair Alternatives 4A, 4B,
           4C, and 4D), Leachate Collection System Expansion, and Limited Ground
           water Extraction and Treatment 	39

VIII.  SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES  	40
      A.   Overall Protection of Human Health and the Environment 	41
      B.   Compliance with ARARs 	42
      C.   Long-Term Effectiveness for Meeting Remedial Action Objectives and
           Permanence 	44
      D.   Reduction of Toxicity, Mobility and Volume  	45
      E.   Short-Term Effectiveness 	46
      F.   Implementability 	46
      G.   Cost 	46
      H.   State Acceptance 	47
      I.   Community Acceptance  	47

IX.   THE SELECTED REMEDY;  DESCRIPTION AND PERFORMANCE
      STANDARD (S)  FOR EACH COMPONENT OF THE REMEDY 	47
      A.   General Description of the Selected Remedy  	47
      B.   Description and Performance Standard(s)  of Each Component of the
           Selected Remedy 	48
           1.    Institutional Controls to limit options for future Site use	48
           2.    Long-term Monitoring 	49
           3.    Leachate Management System Operation & Maintenance 	51
           4.    Landfill Cap Repairs 	51

X.     STATUTORY DETERMINATIONS 	55
      A.   Protection of Human Health and the Environment 	55
      B.   Compliance with and Attainment of Applicable or Relevant and Appropriate
                Reguirements ("ARARs")  	56
           1.    Chemical Specific ARARs 	56
           2.    Location Specific ARARs 	56
           3.    Action Specific ARARs 	56
           4 .    To Be Considered ("TBC")  Standards 	57

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C. Cost-Effectiveness 57
D. Utilization of Permanent Solutions and Alternative Treatment Technologies
to the Maximum Extent Practicable 58
E. Preference for Treatment as a Principal Element 58
XI. DOCUMENTATION OF CHANGES FROM PROPOSED PLAN 59
A. 25 PA Code Chapter 273 (1988) 59
B. Air Monitoring 59

RECORD OF DECISION
BERKS LANDFILL SUPERFUND SITE

DECISION SUMMARY

I. SITE NAME, LOCATION AND DESCRIPTION

The Berks Landfill Superfund Site is located in Spring Township, Berks County, Pennsylvania,
approximately 2.3 miles southwest of the Borough of Sinking Spring and approximately 7 miles
southwest of the City of Reading. Figure 1 (Figures are located in Appendix A) presents the US
Geologic Survey ("USGS") Sinking Spring guadrangle map showing the Site location. The
coordinates for the approximate center of the Site are 405 17'41" North latitude and 76502'06"
We s t 1ongi tude.

The Site consists of two closed municipal refuse landfills and associated features located south
of Wheatfield Road, the areal extent of contamination which includes the ground water plume and
property necessary to implement the Selected Remedy set forth below. The two landfills are
referred to as the eastern landfill, which covers an area of approximately 47 acres, and the
western landfill, which covers an area of approximately 19 acres. There are two other disposal
areas associated with the Site which received mostly municipal waste when access to the eastern
and western landfills was impossible due to inclement weather. The northern disposal area is
located north of the access road at the toe of the eastern landfill. The area behind the
eguipment building is located just south of the Zerbe Auction House. There is an existing
leachate management system at the Site which consists of a series of collection pipes at the toe
of the eastern landfill and a small portion of the western landfill. Conveyance piping and
manholes carry leachate to three hyphalon lined gravity fed leachate collection lagoons.
Leachate is then pumped from these lagoons by an automated dual pump station to the Sinking
Spring Borough Publicly Operated Treatment Works. Figure 2 shows the main Site features.

Cover on the western landfill consists mainly of forested/maturing shrub tree areas except for
the crown, or south central portion of the landfill which is covered with a meadow type area.
Cover on the eastern landfill, northern disposal area and area behind the eguipment building
consists primarily of grasses, shrubs and small trees. The eastern landfill and the lagoon area
is fenced.

An unnamed tributary to Cacoosing Creek, and its associated wetlands and riparian zone,
approximately parallels Wheatfield Road north of the landfills and flows in an east to west
direction. This creek, which will be hereinafter referred to as the Cacoosing Creek tributary,
is a perennial stream which originates east of the Site. Surface water is carried from the Site
by the southern, central and western drainageways. These drainageways discharge to the
Cacoosing Creek Tributary. A Spring Township sewer main is aligned adjacent to the Cacoosing
Creek tributary channel.

Two private residences and a business are located along Wheatfield Road within the Site
boundary. The Property north of Wheatfield Road is primarily undeveloped and wooded along a
fairly steep southern facing slope on an east-west trending ridge. Former mine workings are

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located just north of Wheatfield Road within this wooded area and east of the Site.

II. SITE HISTORY AND ENFORCEMENT ACTIVITY

Landfilling of predominantly municipal refuse and demolition debris began in the 1950's and
continued through 1986 on the eastern landfill. From approximately 1975 to 1986, landfilling
was conducted under a Pennsylvania Department of Environmental Resources ("PADER") permit. The
southeastern portion of the eastern landfill is referred to as the Wood Dump due to the large
amount of trees, stumps, and other construction debris placed in this section of the landfill.
As reported by former landfill employees, industrial wastes including hazardous substances were
also disposed of at the Wood Dump. The northeastern portion of the eastern landfill covers the
abandoned Wheatfield Mine Workings which, as reported by former landfill employees, were filled
with low permeability soil prior to landfilling. The eastern landfill was closed in 1986, as
reguired by PADER, and covered with a vegetated soil cap. The soil cap consists of a compacted
low permeability graded soil cover with erosion control side slope benches and rip-rap lined
channels to convey surface water off of the landfill.

The western landfill, according to former landfill employees, received predominantly municipal
refuse. Landfilling activities occurred there from the 1960's until the mid 1970's. The
western landfill, in 1979 and 1980, also received some industrial waste and alkali sludges. The
sludges were stabilized and disposed of in the south central portion of the landfill, in an area
referred to as the Stabatrol area. Following closure during the 1970's, the western landfill
was covered with a graded, low permeability soil cap. The side slopes of the landfill, which
were closed in the early to mid 1970's, are currently covered by deciduous woodlands with trees
estimated to be up to 20 years in age. The crown of the landfill in the Stabatrol area, which
was capped in 1980, is currently covered with grass and brush vegetation.

Landfilling at the Site ceased in 1986 and the landfill was closed in accordance with a consent
order issued by PADER. Response systems constructed at the Site during landfill operations or
during landfill closure include the following: 1) a compacted low permeability soil liner
beneath the permitted portion of the eastern landfill; 2) a leachate collection system; 3) three
hyphalon lined leachate storage lagoons and one low permeability soil lined lagoon for
additional storage capacity; and, 4) a graded low permeability soil cap over each landfill (See
Figure 2.). Sampling of on-Site monitoring wells installed prior to and during closure of the
eastern landfill showed that on-Site ground water was contaminated with volatile organic
chemical ("VOCS") including, benzene, vinyl chloride, trichloroethene, 1,2 dichloroethene and
1,1 dichloroethene.

On June 24, 1988, the United States Environmental Protection Agency ("US EPA") proposed the
Site for inclusion on the Comprehensive Environmental Response, Cleanup and Liability Act
("CERCLA") National Priorities List ("NPL"), and it was formally included on the NPL on
October 2, 1989.

On August 7, 1990 US EPA issued a Unilateral Order for Removal Action (Docket No. 111-90-
39-D-C) ("Order) to potentially responsible parties ("PRPs") at the Site. The Order reguired
the PRPs to implement the following removal actions, which have been completed: construction of
an 8-foot high chain-link security fence and locking gates surrounding the eastern landfill and
lined leachate collection lagoons; repairs to approximately 1.5 acres of the existing landfill
cap on the eastern landfill which were damaged by erosion; installation, operation, and
maintenance of an automatic leachate management system which pumps leachate from the hyphalon
lined lagoons to the Spring Township sewerage system. The operation and maintenance of the
leachate management system will continue until a final remedy for the Site is selected and
implemented.

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On July 5, 1991, the US EPA and Sonoco Fibre Drum, Inc., Carpenter Technology Corporation, and
The Glidden Company  ("Respondents) entered into an Administrative Order on Consent  ("Consent
Order"), Docket No. III-90-32-DC, to conduct a Remedial Investigation/Feasibility Study
("RI/FS")  at the Site.  Under the Consent Order, the Respondents submitted a RI/FS Work Plan
after receiving notice of contractor acceptance from US EPA.  US EPA had approved Golder
Associates Inc. ("Golder") as the contractor to prepare and implement the RI/FS Work Plan  (Work
Plan).   US EPA approved the Work Plan on June 8, 1992, and work outlined within the Work Plan
proceeded.  The major objective of the RI for the Berks Landfill Site was to provide an
assessment of the nature and extent of chemical constituents for the various environmental
media.   On November 27, 1996, US EPA approved a baseline risk assessment for the Site prepared
by the Respondents, the findings of which are described below.  The Respondents submitted a
feasibility study  ("FS) which evaluated various remedial alternatives to address risks posed by
the Site in February, 1997; US EPA approved the FS, contingent upon inclusion of US EPA's
comment letter on April 24, 1997.

    III.  HIGHLIGHTS OF COMMUNITY PARTICIPATION

Community interest and concern about the Berks Landfill Site has been steady throughout US
EPA's involvement.  US EPA held a public availability session on January 29, 1990 at the
Wilson Southern Jr. High School to introduce US EPA staff, review the Superfund process and
update the community on upcoming Site activities.  US EPA issued a Fact Sheet in August 1990
discussing the Superfund process and removal actions planned by US EPA to address conditions
at the Site which US EPA felt posed an immediate risk to human health while Site-wide long-term
remedial actions were contemplated.

In January 1991 US EPA issued a Fact Sheet discussing the removal actions taken at the Site and
upcoming remedial actions to be taken to identify the nature and extent of contaminants at the
Site.

On August 28, 1991 US EPA completed a Community Relations Plan for the Site.  The Plan
highlighted issues, concerns and interests of the community located near the Site which were
raised during community interviews.

In July, 1992 US EPA issued a Fact Sheet announcing the approval of the Remedial
Investigation/Feasibility Study Work Plan.  The July 1992 Fact Sheet briefly outlined the work
to be performed during the RI/FS and gave a general time line for completion of the work.  The
July 1992 Fact Sheet also announced a public meeting which was held on July 27, 1992 at the
Southern Junior High School.  Questions regarding the RI/FS work plan and a draft Community
Relations Plan were discussed at the meeting.

In July 1996 US EPA issued a Fact Sheet to keep the community informed of Site related
activities.  The Fact Sheet briefly explained the findings of the RI, the Superfund Process, and
the nature and extent of Site contamination.

Pursuant to CERCLA ° 113(k)(2)(B)(I)-(v), US EPA released for public comment the final RI/FS
reports and the Proposed Remedial Action Plan setting forth US EPA' s preferred alternative for
the Berks Landfill Site on April 25, 1997.  US EPA made these documents available to the public
in the Administrative Record located at the US EPA Docket Room in Region Ill's Philadelphia
office, and at the Sinking Spring Public Library, Sinking Spring, Pennsylvania.  The notice of
availability of these documents was published in the Reading Eagle and the Merchandiser on April
25, 1997 and May 14, 1997, respectively.

A public comment period on the documents was held from April 25, 1997 to May 26, 1997.  In May,
1997 US EPA issued a Fact Sheet announcing the availability of the Proposed Remedial Action plan

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and public meeting. The May 1997 Fact Sheet discussed US EPA's Preferred Alternative, as well
as other alternatives evaluated by US EPA and solicited comments from all interested parties.
In addition, US EPA conducted a public meeting on May 14, 1997. At this meeting, US EPA
representatives answered guestions about conditions at the Site and the remedial alternatives
under consideration.

The responses to all comments received during the public comment periods are included in the
Responsiveness Summary, which is Appendix D of this Record of Decision ("ROD").

This decision document presents the selected remedial action for the Berks Landfill Site, Spring
Township, Berks County, Pennsylvania, chosen in accordance with CERCLA, SARA, and, to the
extent practicable, the National Oil and Hazardous Substances Pollution Contingency Plan (NCP),
40 C.F.R. Part 300. The selection of the remedial action for this Site is based on the
Administrative Record.

IV. SCOPE AND ROLE OF THE RESPONSE ACTION WITH SITE STRATEGY

The Selected Remedy described in this Record of Decision will comprehensively address the
threats posed by the release of hazardous substances at the Site. The threats posed by the Site
are due to VOC and metals contamination in on-Site ground water.

The preamble to the National Oil and Hazardous Substances Contingency Plan ("NCP") establishes
that US EPA can at its discretion as the lead Agency at a Site move the point of compliance away
from a waste management area based on Site-specific conditions. However, this alternate point
of compliance must also be protective of human health and the environment. The preamble also
states that "institutional controls... should not be used as the primary remedy when more active
remediation measures...provide greater reliability in the future." US EPA is using its
discretion based on Site-specific conditions established in the Remedial Investigation to
establish the point of compliance for ground water at the Site as the western, eastern and
southern Site property boundaries and Wheatfield Road to the north. This point of compliance
for ground water will be protective of human health and the environment.

The concentrations of contaminants in the ground water at the point of compliance do not exceed
Maximum Contaminant Levels ("MCLs") which are enforceable, health-based drinking water
standards established under the Safe Drinking Water Act ("SDWA"), 42 U.S.C. °° 300f to 300J-26,
or non-zero Maximum Contaminant Level Goals ("MCLGs"), compliance with which is set forth in
CERCLA.

The primary objectives of US EPA's remedial action at the Site are to prohibit future
consumption of on-Site ground water at the point of compliance; long-term monitoring to ensure
that MCLs, or MCLGs, continue to be maintained at the point of compliance; continued effective
collection of Site leachate; repair and maintenance of the existing landfill caps.

Natural containment through institutional controls, natural attenuation and existing Site-
specific hydrogeologic conditions in conjunction with long-term monitoring is preferred as the
primary ground water remedy at the point of compliance after having been evaluated against more
active remediation methods which will provide no greater long-term reliability.

V. SUMMARY OF SITE CHARACTERISTICS AND EXTENT OF
CONTAMINATION

A. Site Characteristics

1. Topography

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Topographically high ridges in the Site area range between 700 and 800 feet above Mean Sea
Level ("MSL"). Local ridges include Colonial Hills approximately one mile to the southwest
Mohn's Hill, approximately 3/4 of a mile to the south, and Laurel Ridge just north of Gelsinger
Road. Cushion Peak, the highest point in the Sinking Spring Quadrangle with an elevation of
1116 feet MSL, is located one mile to the west.

Topography at the Site ranges from approximately 660 feet above MSL to the south on the
northern face of Colonial Hills, decreases to approximately 470 feet above MSL along the
Cacoosing Creek tributary and rises again to approximately 680 feet above MSL north of the
Site. An east-west trending valley crosses the northern half of the Site (See Figures 1. & 2.).

2. Surface Hydrology

The major surface water body at the Site is the Cacoosing Creek tributary which flows from east
to west, cutting across the north central portion of the Site at the base of the east-west
trending valley. Surface water runoff discharges into drainage patterns and secondary
tributaries (southern, southeastern, and western drainageways) to the Cacoosing Creek tributary,
which in turn, flows northwestwardly approximately one mile off-Site and joins Cacoosing Creek.
Cacoosing Creek then flows in a northerly direction into Tulpehocken Creek, which in turn, joins
the Schuylkill River in Reading, about seven miles north of the Site.

Overall, the surface water flow data show that the Cacoosing Creek tributary gains flow (in
addition to contributions from drainageways which flow into the Cacoosing Creek tributary)
from the eastern edge of the Site to the western edge of the Site, notwithstanding local
variations. This gaining flow is attributed to the discharge of shallow groundwater as discussed
below.

3. Groundwater Use

Within a three mile radius of the Site approximately 26,495 people utilize either public or
private groundwater wells as water supply. Approximately 2,968 people are served by private
wells within the same three mile radius.

In the immediate vicinity of the landfill, along Wheatfield Road, water is supplied by private
groundwater well systems. The water from two local residential wells is also used for filling
in-ground swimming pools. A farm which is located southwest of the Site utilizes groundwater
for agricultural purposes (dairy farming). A residential well and a business well are located
on-Site.

It should be noted that no contaminants were detected in the five rounds of residential well
sampling conducted as part of the remedial investigation on or in the vicinity of the Site at
concentrations greater than the applicable Federal Maximum Contaminant Levels.

The Citizens Utilities Water Authority Well No. 23 is the closest public water supply well to
the Site. The well is located approximately 1/2 mile east of the Site at the intersection of
Grings Hill Road and Wheatfield Road. This well services Grings Hill Estates, Tallowyck,
Wheaton Heights, Shiloh Hills, and extended areas of Cumru and Spring Townships. This well is
hydrogeologically isolated from the Site.

4. Demography and Land Use

The 1987 estimate by the Bureau of Census for Berks County shows approximately 324,300 persons
within Berks County. The highest population densities occur in the larger towns and cities.

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The population for Berks County is projected to grow to 362,225 persons by the year 2000.

The 1988 Existing Land Use Map developed for the Berks County Comprehensive Plan designates the
majority of the Site for industrial use because the land was previously devoted to landfilling
activities. In addition, two residential properties and a business exist at the Site along
Wheatfield Road. The areas surrounding the Site are predominantly shown as agricultural/open
space and residential areas. Sparse residential properties occur along Wheatfield, Gelsinger,
and Chapel Hill Roads in the Site vicinity.

Aerial photographs of the Site also show that the area has historically been forested or farmed
with some residential development particularly east of the Site becoming more prevalent within
recent years.

5. General Site Geology

The Site is located within the Piedmont Physiographic Province which is characterized by the
presence of a system of rift grabens and half grabens, or basins. These features are associated
with extensional forces exerted on the continental crust during the early stages of the opening
of the Atlantic Ocean during the Mesozoic Era (70 to 240 million years ago). The basins are
infilled with Triassic sedimentary sandstones, siltstones and conglomerates. This deposition
was accompanied by massive intrusions of Triassic diabase.

The rock strata in the vicinity of the Site are composed of Triassic sandstones, siltstones,
mudstones and conglomerates of the Hammer Creek Formation (part of the Newark Group), and
Triassic age diabase associated with the Morgantown Sill. Also present are Ordovician age (440
to 505 million years old) phyllites and argillaceous sandstones of the Martinsburg Formation,
Cambrian (505 to 570 million years old) sandstones, and limestones of the Millbach Formation
and sandstones of the Hardyston Formation. Figure 3 presents a regional geology map and
cross-section.

As illustrated by Figure 3 the Triassic diabase outcrop almost entirely encircles the Site with
the exception of a small area to the southwest. Along the north edge of the Site is a thin
outcropping of Cambrian Millbach limestone and a small, fault-slice of the Ordovician
Martinsburg Formation.

The geologic investigation has identified the intrusive diabase mass at surface, which encircles
(except for the southwest corner of the Site), and lies beneath the Site as the most important
geologic feature at the Site. While the lithologies overlying the diabase at the Site have been
identified, they do not influence groundwater flow as significantly as the diabase which
hydraulically controls groundwater flow due to its orientation and low permeability. The
diabase and its orientation have been identified through regional geologic mapping performed by
the U.S. Geological Survey, Golder's surface geology mapping at and in the vicinity of the Site,
and subsurface exploration borings performed by Peffer and Golder.

6. Regional Hydrogeology

In the region of the Site, groundwater exists in both the shallow soil mantle overlying the
bedrock as well as within the fractured bedrock. Groundwater within the soil mantle overlying
bedrock, and the upper weathered bedrock, is under water table conditions and mimics
topography very closely. The water table aguifer discharges to surface water bodies
(drainageways and Cacoosing Creek tributary). In the deeper aguifer systems, the majority of
the flow occurs through the secondary porosity (bedding plane factures, joints and faults)
within the rock mass. As reported by Longwill and Wood (1965), groundwater flow within the
deeper bedrock is less influenced by the topography and flows under anisotropic conditions

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dictated by the strike of bedding.

7. Local Hydrogeology

Consistent with the regional hydrogeology, the Site hydrogeology is characterized by the
presence of three flow systems, a water table aguifer which extends to a depth of about 100
feet, a deeper semi-confined flow system which extends to the diabase contact, and an underlying
diabase confining unit. The shallow water table aguifer and the deeper semi-confined system,
much like the regional system, are topographically controlled. The shallow aguifer system very
closely mimics the topographic surface, while the deeper semi-confined system is not as
dramatically influenced. The transition between the shallow phreatic system and the deeper
semi-confined system is gradational across the Site. These two systems flow northward across
the Site toward the Cacoosing Creek tributary. As discussed above, the diabase, which
encompasses the Site, acts as a major hydraulic barrier that controls groundwater flow at the
Site and prevents downward migration of groundwater from the overlying units. The diabase
effectively acts as a confining unit beneath the Site and causes the shallow phreatic and deeper
semi-confined groundwater systems to merge and discharge to the Cacoosing Creek tributary
system (drainageways and tributary) at the northwestern portion of the Site and west of the Site
boundary (See Figures 4. & 5.).

B Nature and Extent of Contamination

1. Soil

Eleven (11) surface soil samples were collected and analyzed from the eastern and western
landfills from areas not impacted by leachate during the remedial investigation. Eight (8)
samples were collected and analyzed at locations which, based upon visual inspection, had been
impacted by leachate seepage. These samples were considered collected at worst-case locations.
Also, six soil borings were advanced in the Stabatrol area, and a total of three samples of
solid material were collected and analyzed by Toxicity Characteristic Leaching Procedure
("TCLP") for metals. Three background soil samples were collected from locations outside the
Site boundary on the landfills.

Figure 6 and Table 1, Table 2 and Table 3 (Tables are located in Appendix B) present the soil
and leachate seep sampling locations and a summary of the analysis results, respectively.

The majority of VOCS were detected in the soil samples which were collected at leachate-
impacted areas and hence are considered worst-case locations and are not representative of
overall Site conditions. In all cases, even the worst case locations, VOCS were detected at
concentrations less than 200 parts per billion ("ppb") and in most cases were less than 50 ppb.

Semivolatile organic chemicals ("SVOCs") were detected in background soils as well as
leachate, and non-leachate impacted soils mostly at concentrations less than 200 ppb and all
SVOCs were detected at mean concentrations of 333 ppb or less.

No pesticide compounds were detected in any of the twenty-two background and on-Site soil
samples. Only one PCB, Aroclor-1248, was detected at an estimated concentration of 270 ppb
(.27 parts per million ("ppm)) at one location, which is an order of magnitude less than the US
EPA cleanup level of 1 ppm.

Metal detections, as expected, were freguent. Background and non-leachate impacted soils
showed very similar concentrations, while leachate impacted soil showed higher concentrations.
However, except for selenium, the metals detected in both background and on-Site soil samples
were within the range of typical background soils for the eastern United States.

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2. Surface Water

Surface water samples were collected from eleven locations along the Cacoosing Creek tributary
and the first order streams (drainageways) which drain through or adjacent to the Site. Three
sample locations were located upstream of the Site and eight sample locations were located
downstream of the Site.

In addition, surface water samples were collected as part of the benthic macroinvertebrate
survey conducted in May 1992, and were analyzed for conventional water guality parameters:
alkalinity, hardness, and total suspended solids, as well as field parameters: pH, temperature,
specific conductance, and dissolved oxygen.

A summary of the surface water sample locations and analyses results for detected constituents
are presented in Figure 7 and Table 4 and Table 5, respectively.

VOCs, SVOCs, pesticides, and PCBs were not detected in either upstream (background) or
downstream (on-Site) surface water samples collected during the RI. Cyanide was detected in
one of eleven surface water samples. Because cyanide was not detected in any other media at the
Site (except for one sample in groundwater) and because of its infrequent detection in surface
water, cyanide is believed to be an anomaly and not a concern in surface water.

Seven metals (barium, calcium iron, magnesium, manganese, potassium, and sodium) were
detected in surface water at both upstream and downstream locations. Copper and selenium were
only detected in upstream samples and aluminum and vanadium were only detected in
downstream samples. All metals were detected at concentrations less than the Federal and
Pennsylvania AWQS, except for iron and manganese. Both upstream and downstream detections
of iron exceeded the Federal AWQS and are attributable to naturally occurring magnetite which
was historically mined on-Site. Both upstream and downstream concentrations of manganese
exceeded the Federal AWQS, however, dissolved manganese was also detected in background
groundwater at concentrations above the AWQS strongly suggesting that its presence is not Site
related.

3. Sediment

Sediment samples were collected from eleven locations along the Cacoosing Creek tributary and
the drainageways which ran through or adjacent to the Site (Set Figure 7.). Four sample
locations are located upstream of the Site and eight sample locations are located downstream of
the Site.

US EPA, United States Fish and Wildlife Service ("US FWS"), and Golder jointly located field
sampling locations for sediment. Samples collected from these locations were analyzed for TCL
and SVOC and target analyte list ("TAL") metals. In addition, laboratory analyses of grain size
distribution and total organic carbon (TOG) were performed on each of the samples. Field
parameters (pH, temperature, specific conductance) were also monitored during sampling. A
summary of the sediment sample results for detected constituents is presented in Table 6 and
Table 7.

No VOCs, pesticides, or PCBs were detected in sediment during the RI.

The SVOCs detected in sediment were polynuclear aromatic hydrocarbons ("PAHs") and were
in most cases detected at higher concentrations in upstream samples than in downstream samples.
All PAH concentrations in sediment are less than the corresponding most conservative
environmental effects range low value ("ER-L") established by the National Oceanic and

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Atmospheric Administration ("NOAA"). An ER-L value defines the concentration at the low-
end of the range in which effects were observed.

Sixteen metals were detected in both upstream and downstream sediment samples at similar
concentrations. Two metals, cadmium, and mercury were only detected in downstream samples.
Only mercury (in two samples) and nickel (in one sample) were detected at concentrations above
the most conservative ER-L value. However, the results for both of these metals are less than
the effects range midway ("ER-M") values. An ER-M concentration defines a point midway in the
range of reported values associated with biological effects.

The sediment data were normalized for both TOG and particle size. The normalized data support
the trend that in most cases, downstream SVOC and metal concentrations are comparable to
and/or are less than the upstream concentrations. In every case (except for cadmium, calcium,
magnesium, mercury, and potassium), the normalized upstream metal concentrations are higher
than the normalized downstream metal concentrations. Of the PAH compounds detected, only
phenanthrene was detected at higher normalized downstream concentrations than the upstream
concentration.

4. Air Monitoring

The remedial investigation air screening program addressed ambient air, soil gas, and passive
vents. In addition to the air screening, a methane migration survey was conducted around the
perimeter of each of the landfills. Samples were collected from soil gas, passive vents, and
ambient air (See Figure 8.).

Methane Migration Survey

Methane was detected at concentrations less than or egual to six percent of the lower explosive
limit ("LEL") at the eastern landfill perimeter except at four locations where methane was
detected at 100 percent LEL. These four locations are at monitoring point 2 (southeast corner
of the eastern landfill), monitoring points 18 and 20 (between the eastern landfill and the
lagoons), and monitoring point 23A (southwest corner of the eastern landfill). Additional
on-Site sampling conducted radially outward from each of these four monitoring points detected
readings of methane at five percent or less LEL. All methane readings along the perimeter of
the western landfill were less than 6 percent LEL.

Six methane monitoring points were sampled around an on-Site residence. Methane readings
were not detected in this area.

Methane was either not detected or detected at levels less than six percent of the LEL at the
perimeter of the eastern and western landfills. The only exceptions were three small areas
around the perimeter of the eastern landfill exhibited methane readings at 100% LEL (southeast
corner, southwest corner, and between the landfill and lined leachate collection lagoons). At
each of these three areas, sampling radially away from the landfill showed levels less than six
percent LEL. All methane readings along the perimeter of the western landfill were less than
five percent LEL.

Soil Gas Sampling

Soil gas sample analyses within the Stabatrol area on the western landfill detected aromatic
hydrocarbons, but no chlorinated VOCS. In addition, soil gas sample analyses from the Wood
Dump detected both aromatic hydrocarbons as well as chlorinated VOCS and CFCs. These data
are consistent with the results of groundwater sample analyses which, as will be discussed
below, detected aromatic hydrocarbons in wells in the vicinity of the crown of the western

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landfill and chlorinated VOCS in wells in the vicinity of the Wood Dump on the eastern landfill.

The presence of low concentration CFCs in sample WDSG8B may be attributed to past disposal
of freon containers, aerosol cans, or other CFC containing canisters. Only trace levels of
xylenes were detected in the on-Site residence soil gas sample; the source of which is unknown.
In addition, xylene was not detected in the on-Site residential well (a shallow groundwater
well) or other nearby shallow groundwater wells.

Passive Vent Sampling

Samples from one passive vent on the western landfill and two passive vents on the eastern
landfill were sampled and analyzed during the remedial investigation. The VOCS detected from
each vent were similar and consisted of aromatic hydrocarbons, chlorinated VOCS, and CFCs. In
each case, over seventy-five percent of the VOCS detected (excluding methane and NMOC) were
composed of toluene, ethylbenzene, and total xylenes. The passive vent on the western landfill
exhibited the lowest VOC levels.

Hydrogen sulfide was detected in the two passive vents on the eastern landfill but not in the
western landfill passive vent. Methane and NMOCs were detected at each of the three passive
vents with the highest levels (570,000 ppmv and 1,600 ppmv, respectively) detected in passive
vent ELPV13 and the lowest levels (90,000 ppmv and 37 ppmv, respectively) were detected in
the western landfill passive vent. The lower methane and NMOC levels detected in the western
landfill passive vent are to be expected because municipal waste landfilling activities ceased
approximately 10 years before municipal waste landfilling ceased on the eastern landfill.

Ambient Air Sampling

A total of nine 8-hour and 24-hour composite ambient air samples were collected to assess the
potential impacts from the lined leachate collection lagoons and a leachate seep and also to
assess the potential for off-Site migration of VOCS from the Site. No VOCS were detected at the
leachate lagoons and only trace levels of toluene were detected at the leachate seepage
location.

No VOCS were detected in the the ambient air samples collected at the eastern landfill in the
vicinity of the Wood Dump. Only trace levels of one VOC were detected (2-hexanone) on the
western landfill. This VOC was not detected in any other media and therefore is considered an
anomaly. Only trace levels of acetone, toluene, and xylenes were detected in the three samples
collected in the vicinity of the on-Site residence.

5. Leachate

Leachate seepage samples were collected in apparent worst-case locations. Seven leachate
seepage samples and one leachate lagoon sample were analyzed.

Figure 6 shows the leachate seep sampling locations and Table 8 provides a summary of the
leachate sampling analysis results.

While several VOCS were detected in leachate, most of the concentrations were less than 25 ug/1.
Toluene and total xylenes were the only VOCS detected at concentrations slightly higher than the
aguatic life AWQS. In general, SVOCs were also detected in leachate at low concentrations less
than 20 ug/1. Phenol was the only SVOC to be detected at a concentration above the aguatic life
AWQS. Pesticides and PCBs were not detected in landfill leachate.

Seventeen metals were detected in leachate. Four of these metals (iron, cadmium, copper, and

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lead) were detected at concentrations above the aquatic life AWQS. It is notable that total
and/or dissolved concentrations of iron, cadmium, copper, and lead were detected at higher
concentrations in background groundwater samples above the aquatic life AWQS. Furthermore,
significant biological populations for which the AWQS were derived (e.g., fish) are not intended
to inhabit, nor should they inhabit the leachate seeps and leachate holding lagoons.

6. Leachate Collection/Management System

Leachate from the landfils is collected and conveyed through underground pipes and manholes
to a series of three lined leachate collection lagoons (See Figure 2.). Under the 1990 US EPA
removal order the PRPs have enhanced the system by which the leachate is conveyed from the
last of the three lined leachate collection lagoons to a township sewer main by installing new
piping, pumps, controls, and various safety mechanisms, such as an auto-dialer, if electrical or
mechanical problems arise. The following paragraphs discuss further details with respect to the
leachate collection and management system.

Drawings show piping interconnections between manholes identified during the remedial
investigation Site reconnaissance. These interconnections are consistent with observations of
the manholes and piping configurations made during the RI. The drawings and RI inspection
records indicate that four manholes art located at the toe of the slope of the eastern landfill
and were installed to convey the leachate to a junction manhole located along the Site access
road. This manhole also is believed to interconnect piping from the manhole located at the toe
of the slope of the western landfill. The western manhole appears to be collecting leachate
from a perimeter toe drain on the western landfill. The extent of the toe drain is unknown.
Leachate is conveyed from the western manhole via piping which is believed to pass under the
southernmost lagoon, which is currently filled with freshwater, and interconnects with the
junction manhole. Leachate is then conveyed into the first of three hyphalon lined leachate
collection lagoons. Leachate passes by gravity flow between the hyphalon lined lagoons and then
is pumped via an on-Site leachate management pumping station to the POTW manhole. As mentioned
above, the pumping station was installed as part of the removal action activities at the Site.

7. Cap Conditions

As previously discussed, landfill caps were constructed on both the eastern and western
landfills after closure. The materials used for capping of the landfills are believed to have
included on-Site borrow from excavations prior to landfilling, borrow from the southwest corner
of the Site, and borrow from the area immediately east of the southeast corner of the Site.

The existing condition of the landfill caps were investigated as part of the remedial
investigation. Initially, the landfill cap thickness was recorded at seventeen points on the
eastern landfill and six points on the western landfill. The landfill cap thickness was
determined by both hand excavation and power augering. Thickness was estimated to be the depth
at which refuse or refusal was first encountered. Cap thickness data for the western landfill
was also obtained from nine borings used to evaluate the extent of refuse and to locate the
Stabatrol area.

In-situ density and moisture content were measured using a Troxler nuclear density gauge at four
points on the eastern landfill and two points on the western landfill. Soil samples were also
collected at these six points for geotechnical laboratory testing.

During Site reconnaissance conducted as part of the remedial investigation, two cracks in the
landfill cap were observed near the crest of the northern slope on the eastern landfill. These
observations were reported to US EPA. In order to determine if these cracks could be caused by
settlements or slope instability, six settlement plates were installed at three locations with a

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settlement plate installed on both sides of the cracks at each location.

After considering the results of the initial cap investigation, US EPA decided that additional
information was needed to better describe the in-situ characteristics of the landfill caps and
the geotechnical properties of the cap soil.  The additional information would also be needed
for developing and evaluating landfill capping alternatives during the Feasibility Study and to
substantiate the use, possibly with enhancement, of the existing landfill caps as part of a
permanent capping remedy.

In order to accomplish these objectives, the cap investigation program was expanded and
designed to collect the following information:

Twenty-four additional sample locations on the eastern landfill and six additional sampling
locations on the western landfill were included in the investigation.  Samples could not be
collected on the northern portion of the western landfill due to the extremely thick vegetative
growth which limited access.

The following field tests were performed at each of the thirty additional sample locations:  a
power auger was used to estimate the thickness of the existing cap material; and a nuclear
density gauge was used to determine the field density and moisture content of the existing cap
material.

Nuclear density gauge readings could not be made at seven of the thirty points due to
obstructions such as gravel and cobbles preventing the proper setting of the nuclear density
probes or to insufficient cap thickness.  Soil samples were obtained at twenty-seven of the
thirty points for geotechnical laboratory testing.  Samples at three locations were not
collected for geotechnical testing due to insufficient thickness of the cap to yield sufficient
sample volume.

Also based on an evaluation of the grain size distribution and Atterberg Limits test results of
the initial cap investigation, and in conjunction with US EPA and its oversight contractor,
three additional sample locations representing the fine, medium, and coarse gradation of the
samples tested were selected for ftirther testing.  An additional soil sample was collected at
each of these three selected locations for the following geotechnical laboratory tests:  grain
size distribution and Atterberg Limits  (to confirm the similarity with the original sample);
Standard Proctor compaction for moisture-density relationship, and, permeability.

The Standard Proctor compaction tests were performed to establish the moisture-density
relationships that would be expected from the range of cap materials encountered.  Two
permeability tests were run for each sample, remolded to 90 and 95 percent of their maximum
Standard Proctor dry density at moisture contents approximately 3% wet of optimum.  These
densities correspond to densities easily obtainable through conventional field soil compaction
technigues.

Evaluations of the landfill cap thickness indicate that large areas of the eastern landfill have
a cap thickness of 24 inches or greater.  The southern and central portions of the western
landfill exhibit cap thicknesses also greater than 24 inches in five of seven samples.  More
than half of the Site is covered with cap material exceeding 12 inches in thickness although
there remain large areas that have limited cap thickness.  In addition, a thin lens (an
approximately 20 foot by 50 foot area of exposed refuse on the steep northern slope of the
eastern portion of the eastern landfill) was identified during the remedial investigation Site
reconnaissance.  (See Figure 10.)

Both landfill caps exhibit in place densities of about 89% to 90% of the Standard Proctor

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maximum dry density. This suggests that the cap material was compacted when put in place.
The grain size distribution for the cap materials indicates that the caps are constructed of
material containing about 38% to 43% clay or silt size particles. The eastern landfill cap
exhibits the higher clay percentage. The clay/silt portion of the cap material is of low to
moderate plasticity which would be capable of achieving low permeabilities and have a low to
moderate susceptibility to volume change due to changes in moisture content. The cap
investigation indicated that the in-situ permeability of the existing landfill caps is in the 10
-7 cm/sec to 10 -8 cm/sec range. However, local variations in the in place density may result
in a few localized higher permeability zones in the 10 -5 cm/sec range. Overall, the existing
cap material is of the guality and character appropriate for landfill caps.

Based on the evaluation of the settlement crack survey data, some landfill settlement is
occurring, as would be expected. The type of settlement is typical of conditions at clay capped
landfills where invariably some differential settlement of refuse occurs causing tension cracks
in the clay to form.

The eastern landfill is predominantly covered with grasses, shrubs and small trees which control
erosion, although them are some bare areas. Bushes, shrubs and small trees are scattered over
the landfill in isolated locations. The side slopes of the western landfill are covered by
deciduous woodlands with trees estimated to be up to and possibly older than 20 years in age.
The mature nature of these deciduous woodlands suggest well established root systems in the
existing cap as well as considerable cap thickness to support its growth.

8. Groundwater

Groundwater samples were collected from a total of fifty locations, including eight on-Site and
off-Site background locations (monitoring and residential wells), thirty-four on-Site
downgradient locations, and eight off-Site residential wells. Based on the hydraulic gradients
and direction of groundwater flow, the following monitoring wells are identified as being
upgradient of potential Site impacts: G-2, G-3, G-7, G-8, G-10.

Figure 9 and Table 9, Table 10, Table 11 provide the background, monitoring well and
residential well locations and a summary of the detected constituents in background, on-Site
(downgradient), and off-Site residential well groundwater, respectively.

Except for low concentrations of 1,2-dichloroedme, chloromethane, and bromomethane, VOCS
were not detected in background monitoring wells during the RI. Of the twenty VOCS detected
in on-Site wells, sixteen VOCS were detected at concentrations less than 40 ug/1. The four VOCS
which were detected at higher concentrations (total xylenes, trichloroethene, total-1,2-
dichloroethene, and vinyl chloride) were detected in only three monitoring wells, C-3D, MP-18S,
and MP-16. Total 1,2 dichloroethene was detected at 3,700 ppb, trichloroethene was detected at
2,000 ppb and vinyl chloride was detected at 370 ppb in well C-3D. Total 1,2 dichloroethene
was detected at 2,200 parts per billion ("ppb"), trichloroethene was detected at 3,100 and vinyl
chloride was detected at 180 ppb in well MP-18S. Total xylenes was detected at 110 ppb in well
MP-16. These wells exhibited the highest VOC concentrations on-Site which are believed to be
the result of localized rather than Site-wide conditions.

Only five VOCS (benzene, vinyl chloride, 1,1-dichloroethene, total 1,2-dichloroethene, and
trichloroethene) were detected at concentrations above the Federal Maximum Contaminant Level
("MCLs") in on-Site downgradient wells. The further downgradient on-Site VOC concentrations
were significantly less than those detected on or immediately adjacent to the landfill and,
except for one location (G-13) did not exceed tho MCLs.

Except for bis(2-ethylhexyl)phthalate, no SVOCs were detected at concentrations above the

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MCLs. However, the data suggest that bis(2-ethylhexyl)phthalate is not Site related as it was
not detected above blank levels during the remedial investigation. Pesticides and PCBs were not
detected in groundwater.

Metals were detected in background and on-Site monitoring wells, and in off-Site residential
wells. A statistical comparison of background and on-Site metal concentrations indicate that
ome metals are attributable to background conditions and some metals are Site-related. The
ubiguitous nature of metal detections was not surprising given the highly mineralized nature of
the native bedrock at the Site. Four total metals were detected above applicable MCLs in
on-Site wells and included beryllium, cadmium, lead, and nickel. Three of these four metals
(beryllium, cadmium, and lead) were also detected in background groundwater samples at
concentrations greater than the MCL. Only dissolved antimony concentrations exceeded Federal
MCLs on-Site.

Only trace levels of VOCS were detected in four of eight off-Site residential wells (excluding
the upgradient residences). All of the reported VOC concentrations were less than the MCLs. It
should be noted that no contaminants were detected in the five rounds of residential well
sampling conducted as part of the remedial investigation on or in the vicinity of the Site at
concentrations greater than the applicable MCLs.

VI. SUMMARY OF SITE RISKS

The Respondents prepared a Baseline Risk Assessment for the Site in order to identify and define
possible existing and future health risks and potential environmental impacts associated with
exposure to the chemicals present in the various media at the Site if no action were taken. The
baseline risk assessment provides the basis for taking action and indicates the exposure
pathways that need to be addressed by the remedial action. The entire July 1996 Baseline Risk
Assessment and the November 6, 1996 Addendum letter can be found in the Administrative Record.
The Human Health Baseline Risk Assessment is composed of four parts, including Selection of
Potential Chemicals of Concern (or, Hazard Evaluation); Exposure Assessment, Toxicity
Assessment and Risk Characterization.

A. Human Health Risk Evaluation

1. Selection of Chemicals of Potential Concern

Numerous chemicals, including VOCS, semivolatiles, metals, and PAHs were detected in the
environmental media (groundwater, surface water, air, soil, sediment, leachate and air) sampled
during the Remedial Investigation. Although many of the detected substances were found not to
contribute significantly to overall public health risks, the risk assessment considered risks
from all detected chemicals (i.e. all chemicals were considered of potential concern). The
complete rational for selection and listing of contaminants of potential concern can be found in
the July 1996 Baseline Risk Assessment a copy of which is in the Administrative Record for the
Site.

Groundwater

The following chemical constituents were selected as contaminants of potential concern
"COPCs") for the groundwater medium:

Background On-Site
Groundwater Groundwater

Aluminum Aluminum Benzene

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         Arsenic               Arsenic      Carbon Bisulfide
         Beryllium             Barium       Chlorobenzene
         Cadmium               Beryllium    Chloromethane
         Copper                Cadmium      1,4-Dichlorobenzene
         Lead                  Copper       1,1-Dichloroethane
         Manganese             Lead         1,2-Dichloroethane
         Nickel                Manganese    1,1-Dichloroethene
         Vanadium              Vanadium     Total- 1,2-Dichloroethene
                                            Hexachloroethane
                                            Trichloroethene
                                            Vinyl Chloride
                       Off-Site Residential Groundwater

                       Arsenic        Chloroform
                                      1,2-Dichloroethane
                                      1,1,2-Trichloroethane
    Surface Soil

    The following compounds were selected as COPCs for the surface soil medium:

           Background Soil           On-Site Soil

           Beryllium                 Arsenic
                                     Beryllium
                                     Manganese
                                     Benzo(a)pyrene

    Surface Water

None of the detected chemical constituents in surface water exceeded the calculated risk-based
screening concentrations.  Therefore, COPCs were not selected for the surface water medium at
the Site.

    Sediment

    The following chemicals were selected as COPCs for the sediment medium:

           Background Sediment       On-Site Sediment

           Arsenic                   Arsenic
           Beryllium                 Beryllium
           Manganese                 Manganese

    Leachate

No COPCs were selected for the leachate lagoon water or leachate seep water at the Site because
the detected chemicals in these media do not pose potential health risks.

    Air

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The following constituents detected in passive gas vents were selected as COPCs for the air
medium:

Benzene Trichloroethene
Chlorobenzene Vinyl Chloride
Chloroethane Total Xylenes
Ethylbenzene Dichlorodifluoromethane
Hydrogen Sulfide 1,2,4-Trimethylbenzene
Toluene 1,3,5-Trimethylbenzene
These COPCs were selected for ambient air in order to perform a very conservative assessment
of potential risks from exposure to airborne chemicals both on-Site and downwind of the Berks
Landfill. It should also be emphasized that none of the chemicals detected in ambient air,
either on-Site or at the property boundary, exceed Agency screening levels. Potential receptors
are also not expected to inhale pure landfill gas at the Site.

2. Exposure Assessment

The objective of the exposure assessment is to estimate the amount of each chemical of potential
concern at a site that is actually taken into the body (i.e. the intake level or dose). There
are three primary routes through which individuals may be exposed to site related contaminants:
incidental ingestion, inhalation and dermal contact.

Receptors can be either directly or indirectly exposed to site related contaminants via the
environmental media addressed in the Remedial Investigation - groundwater, surface water, air,
soil, sediment, leachate and air. Exposure routes involved include dermal contact, ingestion,
and/or inhalation.

Adult residents are assumed to ingest 2 liters of water per day, 350 days per year, over a
30-year exposure duration. Child residents are assumed to ingest 1 liter of water per day, 350
days per year for six (6) years. Bodyweights, are specified as 70 kg for adults and 15 kg for
children.

Inhalation exposures during showering are estimated using modeling technigues. The modeling
technigues account for inhalation during showering for adults as well as after the shower while
the receptor remains in the room. Dermal exposures during bathing for children are estimated
assuming total body contact for .2 hours per day, 350 days per year for six years.

Carcinogenic risks are calculated as an incremental lifetime risk, and therefore incorporate
terms to represent the exposure duration (years) over the course of a lifetime (70 years, or
25,550 days). Noncarcinogenic risks are calculated using the concept of an average annual
exposure.

The following discusses the potential human exposure routes at the Site which were evaluated in
the Baseline Risk Assessment.

a. Use of groundwater by an off-Site resident under both current and future land use
scenarios downgradient of the Site. Potential exposure is assumed to be via ingestion
of groundwater, dermal contact with groundwater, and inhalation of vapors from
groundwater while showering.

b. Use of groundwater downgmdient of the landfills by an on-Site resident at the Nein
property under a hypothetical future use scenario. Potential exposure is assumed to be

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via ingestion of groundwater, dermal contact with groundwater, and inhalation of vapors
from groundwater while showering.

c. Direct contact with surface soil by a child trespasser and a periodic maintenance
worker at the Site. Potential exposure for the on-Site child trespasser is assumed to
be via incidental ingestion of, and dermal contact with soil. These pathways are
assumed for both the current and future land use scenarios. Potential exposure for an
on-Site future maintenance worker is assumed to be via incidental ingestion and dermal
contact.

d. Potential exposures to constituents in the surface water, sediments, leachate lagoon
water, and leachate seeps. As stated above, no COPCs were identified for surface
water, leachate lagoon water, or leachate seep water. Conseguently, exposure pathways
for these media were not evaluated.

e. Potential exposures to vapor phase chemicals from leachate lagoon water, leachate seep
water and passive gas vents by an on-Site child trespasser, on-Site maintenance worker,
on-Site resident, and off-Site resident in the vicinity of the landfill. Potential
exposures to the on-Site child trespasser (current and future scenarios), on-Site
periodic maintenance worker (future scenario), on-Site resident (future scenario), and
off-Site resident in the vicinity of the landfill (current and future scenarios) were
evaluated.

There are currently no plans to develop the Site for future residential use, but because there
are currently no prohibitions in place, a future residential use scenario was considered in the
risk assessment

3. Toxicity Assessment

The toxicity assessment characterizes the inherent toxicity of a compound and helps to identify
the potential health hazard associated with exposure to each of the chemicals of concern.
Toxicological values, reference doses ("RfDs") for non-carcinogenic chemicals, and the non-
carcinogenic effects of carcinogens, and cancer slope factors ("CSFs") for known, suspected, and
possible human carcinogens, derived by US EPA were used in the Risk Assessment.

RfDs have been developed by US EPA for indicating the potential for adverse health effects from
exposure to chemicals exhibiting noncarcinogenic effects. RfDs, which are expressed in units of
mg/kg-day, we estimates of lifetime daily exposure levels for humans, including sensitive
individuals. Estimated intakes of chemicals from environmental media (e.g., the amount of a
chemical ingested from contaminated drinking water) can be compared to the RfD. RfDs are
derived from human epidemiological studies or animal studies to which uncertainty factors help
ensure that the RfDs will not underestimate the potential for adverse noncarcinogenic effects to
occur.

CSFs have been developed by US EPA' s Carcinogenic Assessment Group for estimating excess
lifetime cancer risks associated with exposure to potentially carcinogenic chemicals. CSFs,
which are expressed in units of (mg/kg-day) -1, are multiplied by the estimated intake of a
potential carcinogen, in mg/kg-day, to provide an upper-bound estimate of the excess lifetime
cancer risk associated with exposure at that intake level. The term "upper-bound" reflects the
conservative estimate of the risks calculated from the CSF. Use of this approach makes
underestimation of the actual cancer risk highly unlikely. CSFs are derived from the results of
human epidemiological studies or chronic animal bioassays to which animal to human
extrapolation and uncertainty factors have been applied.

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4. Risk Characterization

The July 1996 Baseline risk Assessment and November 1996 Addendum letter characterize the
potential health risks associated with both current and future exposures to affected
environmental media at the Berks Landfill Site.

Carcinogenic risk is presented as the incremental probability of an individual contracting some
form of cancer over a lifetime as a result of exposure to the carcinogen. For known or
suspected carcinogens, acceptable exposure levels are generally concentration levels that
represent an excess upper bound lifetime cancer risk to an individual of between 1.0 x 10 -4 (or
1 in 10,000), and 1.0 X 10 -6 (or 1 in 1,000,000) using information on the relationship between
dose and response. Risk standards for non-carcinogenic compounds are established at acceptable
levels and criteria considered protective of human populations from the possible adverse effects
from exposure. The ratio of the average daily doses ("ADD") to the RfD values, defined as the
Hazard Quotient, provides an indication of the potential for systemic toxicity to occur. To
assess the overall potential for non-carcinogenic effects posed by multiple chemicals, a Hazard
Index ("HI") is derived by adding the individual hazard guotients for each chemical of concern.
This approach assumes additivity of critical effects of multiple chemicals. US EPA considers
any HI exceeding one (1.0) to be an unacceptable risk to human health.

a. Background Risks and Hazards

Groundwater

Potential risks and hazards from the exposure to background-related inorganic chemicals are
estimated for potentially exposed human receptors to groundwater under both current and future
scenarios. Specifically, hypothetical exposure via ingestion of groundwater is evaluated for
potential adult and child receptors. A cancer risk of 3 x 10 -4 is postulated for the potential
ingestion of background groundwater. This risk estimate is entirely attributable to the
presence of arsenic and beryllium in groundwater. The estimated HI for the potential ingestion
of background groundwater is 6. Manganese concentradons in groundwater represent the major
contributor to this estimate. However, because manganese is considered an essential nutrient,
the true risk of adverse health effects is uncertain.

Surface Soil and Sediment

Potential risks are estimated for a child trespasser for hypothetical exposure to beryllium in
background surface soil under both current and future conditions. The estimated potential
cancer risk for incidental ingestion of beryllium in background soil is 2 x 10 -7 and the HI is
estimated to be 7 x 10 -5.

Cumulative Risks and Hazards

The total lifetime excess cancer risk from combined potential exposures to the background
groundwater and surface soil pathways is 3 x 10 -4. The total HI value for the combination of
these pathways is 6. The potential ingestion of arsenic, beryllium, and manganese in affected
background groundwater contributes most of the estimated total excess cancer risk and
noncancer hazard for the potential receptors.

b. Off-Site Residential Risks and Hazards

Groundwater

In the case of the current and hypothetical future exposures to inorganic and organic chemicals

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in residential wells located downgradient of the Site, potential cancer risks and noncancer
hazards are estimated for off-Site residents. Specifically, potential exposures via ingestion,
dermal contact, and inhalation of volatiles while showering or bathing are evaluated.

The potential cancer risk for hypothetical exposure to off-Site groundwater is mainly
attributable to potential ingestion of arsenic. An estimated cancer risk of 2 x 10 -4 is
postulated for potential ingestion of affected groundwater by off-Site residents which is less
than the estimated risk due to exposures to background groundwater. However, the infreguent and
detected low concentrations of organic constituents in residential well water resulted in an
estimated potential excess cancer risk of 2 x 10 -6, which is well within the US EPA acceptable
risk range.

Air

In the case of potential exposure via inhalation of vapor-phase chemicals from passive gas vents
by an off-Site resident the estimated potential cancer risk is 2 x 10 -5, while the HI is 0.7,
under both current and future exposure conditions. The estimated cancer risk for potential
inhalation of vapor-phase chemicals is due primarily to the presence of vinyl chloride in
passive landfill gas vents while the esdmated hazard index is due primarily to the presence of
hydrogen sulfide in passive landfill gas vents.

Cumulative Risks and Hazards

For an off-Site resident, the total lifetime excess cancer risk from combined potential
exposures to groundwater and air pathways is 2 x 10 -4. The total HI value for combined
pathways associated with these media exceeds 1. The potential ingestion of arsenic in
groundwater contributes virtually all of the estimated total excess cancer risk for the off-Site
resident. It should also be particularly noted that arsenic is the primary contributor to
excess cancer risk for hypothetical exposure to background groundwater. Noncancer risk for the
off-Site resident is due primarily to ingestion of arsenic in groundwater and exposure to
hydrogen sulfide gas from passive landfill vents. Because arsenic and hydrogen sulfide have
different toxic endpoints and target organs, the addition of the individual His is not
appropriate. Neither HI individually exceeds 1.

c. On-Site Trespasser Risks and Hazards

Surface Soil and Sediment

Potential risks and hazards from exposure to on-Site surface soil are estimated for a child
trespasser under both current and future exposure scenarios. A cancer risk of 1 x 10 -6 is
estimated for the potential incidental ingestion of surface soil. This estimate is primarily
related to the presence of arsenic and beryllium in soils. The estimated HI for the potential
ingestion of surface soil by a trespasser is 0.01.

Air

Potential risks and hazards are estimated for an on-Site trespasser who is potentially exposed
to volatiles from passive gas vents under both current and future exposure scenarios. The
estimated potential cancer risk via inhalation of volatiles is 3 x 10 -8, while the HI is
estimated to be 4 x 10 -3.

Cumulative Risks and Hazards

The total lifetime excess cancer risk for a child trespasser from combined exposures to surface

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soil and air pathways is 1 x 10 -6 The total HI value from combined pathways associated with
these media is 0.01. The potential ingestion of arsenic and beryllium in surface soil accounts
for all estimated total cancer risk for the on-Site trespasser. Once again, arsenic and
beryllium are the primary contributors to the background soil risk estimates.

d. On-Site Worker Risks and Hazards

Surface Soil

The cancer risk and HI estimates for potential exposure to surface soil by future on-Site
maintenance workers are based on incidental ingestion of chemical constituents. The estimated
cancer risk for this exposure scenario is 5 x 10 -7, while the estimated HI is 0.002.

Air

Potential risks and hazards are estimated for a future on-Site maintenance worker who is
potentially exposed to volatiles present in passive gas vents via inhalation. The estimated
potential cancer risk is 1 x 10 -7, while the HI is estimated at .005.

Cumulative Risks and Hazards

The total lifetime excess cancer risk from combined soil and air exposure pathways is 6 x 10 -7.
The total HI value for these combined exposure pathways is 0.007. Most of the estimated total
cancer risk for the on-Site worker is attributed to the incidental ingestion of detected
chemicals in surface soil.

e. On-Site Residential Risks and Hazards

Groundwater

In the case of future hypothetical exposure to chemicals in selected on-Site monitoring wells,
potential cancer risks and noncancer hazards are estimated. Specifically, potential exposures
via ingestion, dermal contact, and inhalation of vapors while showering or bathing are
evaluated. An estimated cancer risk of 1 x 10 -3 is postulated for the potential ingestion of
groundwater by future on-Site residents. The estimated cancer risk for dermal exposure is 4 x
10 -6 and a cancer risk of 2 x 10 -4 is estimated for the inhalation of vapors while showering.
The potential excess cancer risk for hypothetical exposure to on-Site groundwater is mainly
attributable to ingestion of vinyl chloride, although the estimated risk from the potential
inhalation of this compound's vapors while showering is also significant. The estimated HI for
the potential ingestion of affected groundwater by future on-Site residents is 14. Manganese
concentrations in groundwater are primarily responsible for this value.

Air

In the case of hypothetical exposure via inhalation of volatiles from passive gas vents by a
future on-Site resident the estimated cancer risk is 1 x 10 -7, while the HI is 4 x 10 -3.

Cumulative Risks and Hazards

For a future on-Site resident, the total lifetime excess cancer risk from combined hypothetical
exposures to groundwater and air pathways is 1 x 10 -3. The total HI value for the combined
pathways is 15. The potential ingestion of vinyl chloride in groundwater, and the inhalation of
volatiles while showering contribute most of the estimated total cancer risk. The potential
ingestion of manganese is primally responsible for the estimated total noncancer hazard for the

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hypothetical future on-Site resident.

A summary of the cumulative risks and hazards posed by the Site by exposure route can be found
in Table 12. Toxicological Profiles of major contaminants of concern are located in Appendix
C.

B. Environmental Risk Evaluation

The principal purpose of the ecological risk assessment is to determine the likelihood that
biological species habitats in the Site area are exposed to unacceptable risks from Site
contaminants. The ecological risk assessment consisted of three primary components; site
characterization (ecosystem components), exposure analysis, and risk characterization.

1. Site Characterization

The site characterization briefly describes the major plant and animal species that comprise the
ecosystem components in the Site area. The majority of the area encompassed by the eastern
landfill, the southern portion of the top of the western landfill, and the majority of the
former borrow area to the west of the western landfill are early to mid succession old field.
Areas on the landfill surface generally exhibit only minor impacts resulting from landfilling
practices. Also, several localized areas of bare ground surface result from poor soil or steep
slopes; otherwise, vegetation is healthy and abundant. The primary plant cover species are
yellow and white sweet clover, crown vetch, and grasses utilized to stabilize the soil cover.
Meadow voles and sparrows were most freguently observed during the terrestrial habitat
assessment.

The majority of the western landfill is shrub/brush habitat. In addition, areas under the high
tension electric towers and cables to the east of the Site and areas further to the east of the
electric utility right-of-way are shrub/brush habitat. This habitat type provides good cover
for wildlife. Eastern cottontail and white-tailed deer were the most freguently observed
wildlife species in this habitat.

The majority of forested areas at the landfill are mesophytic second stand, mature forest.
Black locust, white ash, red maple, and honeylocust were commonly observed. Most forested areas
at the Site have a dense understory of shrubs and saplings. Also, on the eastern landfill,
multiflora rose and climbing bittersweet were commonly observed. These species also were
commonly seen on the western landfill, as were the bush honeysuckle and Japanese honeysuckle.

Wildlife diversity is typically higher in this habitat type than most others as a result of the
greater variety of forage habitats and feeding guilds. Species that utilize both hard and soft
mast (e.g., gray sguirrel) or cavity dwellers (e.g., sguirrels, raccoons, owls, bats or
woodpeckers) could occur in this habitat type. Raccoon, striped skunk, and gray sguirrel were
among the mammals observed at the Site. Also, birds seen at the Site include those species
utilizing both hard and soft mass, such as the hairy woodpecker and downy woodpecker.

Both wetlands and streams are located within stream corridors and floodplain areas of the Site.
Because the first order streams are upper headwater tributaries, only a few non-game fish
species are expected in such a habitat. During the terrestrial habitat-assessment, minnows were
observed at five of the six sample locations. Raccoons were also observed in this habitat.

Inhabitants of streambeds were gualitatively evaluated during the aguatic habitat assessment.
Diverse communities of benthic macroinvertebrate species were found throughout the six sample
locations, two of which were background sample points. In most cases, more than 100
organisms were collected at each of eight kick sample collection points per sample location.

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Notably, pollution intolerant species predominated, including those species that US EPA has
identified as pollution intolerant species, commonly referred to as "EPT" -- Ephemeroptera
(mayflies), Plecoptera (stoneflies), and Trichoptera (caddisflies). Furthermore, relatively low
levels of pollution tolerant orders, such as Diptera and Annelida, were observed at the Site.
Key receptors evaluated in this ecological assessment are the meadow vote for the soil medium,
and generic aguatic species for the sediment, surface water, and leachate media.

2. Exposure Assessment

For exposure characterization, the reasonable maximum exposure ("RME") concentrations for
detected chemicals are used as the basis for calculating chemical uptake by terrestrial plants,
soil intake for the meadow vole, and chemical exposure for aguatic species. It is assumed that
these concentrations are uniformly distributed in the sampled media, are biologically active,
and are available for transport into the biosphere.

For chemicals found in soil, the toxicity measurement endpoint used for evaluation is the median
lethal dose ("LD 50"). The LD 50s used in this ecological assessment are based on animal study
(rat or mouse) data listed in the Registry of Toxic Effects of Chemical Substances ("RTECS")
data base (NIOSH, 1994). Studies based on intraperitoneal administered doses are used only when
studies using oral administered doses are unavailable. The results of the rat and mouse studies
are scaled to the meadow vote to account for differences in body surface area by using the
methodology presented in Opresko et al. (1993). In addition, No Observed Adverse Effects
Levels ("NOAELs") for the meadow vole are derived from animal studies (rat or mouse) listed in
the Integrated Risk Information System ("IRIS") data base (US EPA, 1994b) to evaluate toxicity
of chemicals found in soil. Uncertainty factors are applied to the rat or mouse toxicity data
to modify lowest observed effects levels to NOAELs or to adjust subchronic values to chronic
values. The rat or mouse NOAELs are scaled to the meadow vole to account for differences in
body surface area

For chemicals found in sediment, the toxicity measurement endpoints are the effects range-low
("ER-L") and effects range-median ("ER-W") data from Long and Morgan (1991). An ER-L value
defines the concentration at the low-end of the range in which effects were observed. An ER-M
concentration defines a point midway in the range of reported values associated with biological
effects.

For chemicals found in surface water, leachate lagoon, and leachate seep, chronic toxicity
benchmarks are the lower of ambient water guality criteria ("AWQC") for aguatic life
established by US EPA in "Quality Criteria for Water Update #2 1987," (US EPA, 1987) and 40
CFR Part 131, or Pennsylvania Water Quality Standards for aguatic life established by PADER
in Pennsylvania Code, Title 25, Chapter 16.

For chemicals with no reported ER-L, ER-M or AWQC, both RTECs and the Hazardous
Substance Data Bank (HSDB, 1994) were examined for eguivalent toxicity information for
representative aguatic species (e.g., Notropis, spp.). For several constituents, no toxicity
information was available after an exhaustive search of appropriate data bases. As a result,
these constituents are not evaluated.

3. Risk Characterization

Potential risks to ecological receptors are characterized in this ERA by using the guotient
method (Suter, 1993). In this method, the environmental concentration or receptor dose is
divided by an appropriate toxicological endpoint. An environmental hazard guotient ("EHQ") less
than one (1) or unity indicates a negligible probability of adverse effects. If the EHQ is
greater than one, then there may be a possible ecological effect. As the magnitude of the

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quotient increases, the likelihood of possible effects is assumed to increase. EHQs of the same
order of magnitude are assumed to indicate equivalent risk as a result of the evaluation
methods. The environmental hazard index ("EHI"), which is the sum of EHQs for all chemicals, is
used to assess the potential adverse effect to a receptor from exposure to multiple chemicals.
The EHI assumes that the toxicity of chemicals to the receptors is additive, and does not
consider synergistic, antagonistic, or potentiating effects of chemicals. This risk
characterization is suitable for identifying possible organism-level effects. Effects to
higher ecological organizations may be extrapolated from these results.

Risk to Receptors

a. Potential Risks from Exposure to Soil

No chemicals found in soil samples collected at the landfill have an EHQ greater than one using
the LD 50 as the toxicity benchmark. If the NOAEL is used as the benchmark, both aluminum and
copper have an EHQ greater than one. However, concentrations of aluminum and copper found
in background soil samples result in EHQs of similar magnitude to those found at the landfill.

b. Potential Risks from Exposure to Sediment

None of the chemicals detected in on-Site stream sediments exceed an EHQ of one when
evaluated using the most conservative ER-L as the toxicity benchmark. The EHI exceeds one
when either the ER-L or the ER-M is used as the toxicity benchmark. Once again, the EHI for
background sediment is very similar in magnitude to the EHI for on-Site sediment. The
sediment samples collected on-Site exhibited a smaller grain size and higher total organic
carbon content than the off-Site samples, which would tend to magnify constituent concentrations
in the on-Site samples.

c. Potential Risks from Exposure to Surface Water

None of the chemicals in surface water has an EHQ greater than one. The EHI for on-Site
surface water is actually equivalent to the EHI for background surface water.

The aquatic habitat assessment results provide additional information in evaluating the health
of the aquatic habitat and potential risks to receptors in surface water. As stated in the
aquatic habitat assessment, all of the six benthic sample points (two background and four
on-Site) have a similar benthic macroinvertebrate community structure and diversity. This
structure shows an abundance of pollutant intolerant species.

d. Potential Risks from Exposure to Leachate

Chemicals are present either in the leachate lagoon or in leachate seeps at concentrations that

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may pose a potential risk to aquatic organisms. Most notably, iron concentrations both in the
lagoon and the seeps exceed water quality criteria. Other analytes detected in leachate that
exceed water quality criteria include phenol, toluene, and total xylenes in the leachate lagoon,
and cobalt in the leachate seeps. Although these chemicals represent a possible effect on
aquatic receptors leachate is not an important aquatic habitat and is only expected to support
limited aquatic life at the Site.

VII. DESCRIPTION OF REMEDIAL ACTION ALTERNATIVES

The Feasibility Study ("FS") Report discusses the alternatives considered for the cleanup of the
contaminants of concern identified during the RI for the Site and provides supporting
information leading to alternative selection by US EPA. The FS initially proposed eight
alternatives. These Alternatives were then evaluated in a two step process, first, initial
screening and then detailed analysis. The initial screening process evaluates all the
alternatives for 1) effectiveness in protecting human health and the environment, 2)
implementability, which is the alternatives technical and administrative feasibility to be
constructed, operated and maintained, and 3) Costs. Alternative 6 (Institutional Controls,
Monitoring, Leachate Management System Operation, Landfill Cap Repairs, Low Permeability Crown
on Eastern Landfill and Leachate Management System Expansion) and Alternative 8 (Institutional
Controls, Monitoring, Leachate Management System Operation, Landfill Cap Repairs, and Hydraulic
Ground Water Containment) were not carried forward to the detailed analysis in the FS, primarily
because they did not provide any additional effectiveness in protecting human health or the
environment and cost significantly more than other Alternatives which were carried forward. A
more detailed description of Alternatives 6 & 8, and the discussion of why they were not carried
forward to the detailed analysis can be found in Section 6 of the FS, a copy of which can be
found in the Administrative Record in the Site repositories. A brief description of the
Alternatives and the detailed analysis of each follows below.

BRIEF DESCRIPTION OF ALTERNATIVES:

A. Alternative No. 1 - No Further Action

Alternative No. 1 consists of performing no further action at the Site. The operation of the
existing leachate management system and pumping of leachate to the Borough of Spring Publicly
Owned Treatment Works ("POTW") for treatment will be discontinued. No further operation
and maintenance activities will be performed at the Site. This "No Further Action" alternative
is required to be evaluated by the National Oil and Hazardous Substances Pollution Contigency
Plan ("NCP") and represents the baseline for comparison of the other alternatives.

B. Alternative No. 2 - Institutional Controls and Leachate Management System
Operation

Alternative No. 2 consists of continuing the operation and maintenance of the existing leachate
management system and pumping of the collected leachate to the local POTW for treatment and
implementing institutional controls at the Site. In addition, Alternative No. 2 includes
performing necessary repairs to the leachate management system. Each of these additional
components is described below.

Institutional Controls

Title restrictions, restrictive covenants or other legal mechanisms, would be implemented to
prohibit the future consumption of on-Site ground water down gradient from the landfills, to
restrict future development at the Site and to limit future earth disturbing activities on the
capped portions of the Site.

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Leachate Management System Operation

Prior to repairing the leachate system, the leachate collection pipes will be inspected. The
inspection of the collection pipes may include the use of a downhole video camera to assess the
integrity of the piping, visual inspection about every 100 feet by excavating the pipe using a
backhoe to determine as-built conditions and the presence of bacterial or sediment build-up
and/or other appropriate means. The condition of the leachate system manholes, valves,
collection lagoon liners, and leachate conveyance system would also be inspected to determine
the need for repairs. The inspection of the leachate collection and management system would be
conducted during remedial design.

Following any necessary repair, the leachate collection and management system will continue to
be operated and maintained to ensure that the system remains effective in the future. Leachate
will continue to be pumped to the local POTW in accordance with the existing Agreement with
the Municipalities.

Alternative No. 2 Costs: Capital - $ 765,900
O&M - $ 74,100
Present Worth - $ 2,102,664

C. Alternative No. 3 - Institutional Controls, Monitoring, Leachate Management
System Operation, and Leachate Collection System Expansion

Alternative No. 3 consists of all of the components of Alternative No. 2 plus the following
additional components:
implementing ground water monitoring to provide an early warning precaution against off-
Site impacts; and, expanding the existing leachate collection system.

Ground Water Monitoring

This additional remedial component includes ground water sampling and analyses at existing
monitoring wells, residential wells, and a new sentinel monitoring well cluster, which will be
installed west of the Site property line centrally located within the Cacoosing Creek tributary
valley (See Figure 2.). This sentinel well cluster will provide a precautionary early warning
system against any possible residential well impacts west of the Site. In addition to the
sentinel well cluster, existing monitoring wells and residential wells will also be regularly
monitored.

Ground water monitoring is an important component of this alternative as it provides an early
warning system for potential upsets in the natural containment of landfill constituents in
ground water. It is also an important component to help ensure that the residences west of the
Site are properly protected and to assess compliance with chemical-specific applicable or
relevant and appropriate reguirements ("ARARs") west of the Site. All sample collection and
analyses will be performed in accordance with US EPA accepted procedures. Analytical results
will be validated as reguired and reported to US EPA annually as part of the Annual Report of
Post-Closure Monitoring and Maintenance.

Leachate Collection System Expansion

Expanding the existing leachate collection system would include lengthening the existing
collection system to surround more of the eastern landfill perimeter with the intent to collect
additional leachate. In addition to the investigations and repairs associated with the leachate
management system operation component, additional investigations would be performed during
remedial design to assess expanding the leachate collection system. It is estimated that the

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expansion could add up to approximately 700 feet of collection piping and two additional
manholes/cleanouts. An additional 6,000 gallons per day ("gpd") of leachate are expected to be
collected and ultimately discharged to the local POTW. This amount of additional leachate
discharge combined with the existing average annual daily discharge rate (22,000 gpd) and
anticipated seasonal variation is expected to be within the daily maximum (35,000 gpd) stated in
the Agreement with the Municipalities.

Alternative No. 3 Costs: Capital - $1,018,650
O&M - $ 142,200
Present Worth - $3,584,300

D. Alternative No. 4 - Institutional Controls, Monitoring, Leachate Management
System Operation, and Landfill Cap Repairs (Cap Repair Alternatives 4A, 4B, 4C
or 4D)

Alternative No. 4 consists of all of the components of Alternative No. 2 plus the following
additional components:

ground water monitoring (which is described above under Alternative 3); and repair and
maintenance of the existing landfill caps.

Alternative No. 4 Costs, not including cap repair: Capital - $ 873,100
O&M - $ 120,000
Present Worth - $ 3,037,900

As part of Alternative No. 4, four cap repair alternatives (i.e., subalternatives of No. 4) have
been evaluated that consider variations in final repaired cap thickness, final vegetative cover
seguence, and future operation, inspection and maintenance reguirements. These four cap repair
alternatives are variations of Site-wide Remedial Alternative No. 4 and therefore represent
Alternatives 4A, 4B, 4C, and 4D. A detailed description and evaluation of the four cap repair
alternatives as well as the comparative analysis and cost estimates of the alternatives are
presented below. The following discusses the landfill cap repair component of Site-wide
Alternative No. 4 in a general sense and incorporates common items associated with each of the
four cap repair alternatives as well as the range of attributes provided by the cap repair
alternatives.

Landfill Cap Repairs

All of the cap repair alternatives include the following common features: re-establishing
vegetation on bare areas of the cap; repairs to erosional areas and settlement cracks; repairs
to the existing surface water management system, as needed; covering the thin lens of exposed
refuse on the northern slope of the eastern portion of the eastern landfill; repairs to landfill
slopes, as needed; and, on-going inspection and maintenance of the landfill cap, surface water
management system, and passive landfill gas vents.

1. Cap Repair Alternative 4A

Final Repaired Cap Thickness: This cap repair alternative provides a minimum of a 1-foot cap
thickness over both landfills in areas that are not currently covered by a large contiguous area
of well-established vegetative cover. A cap thickness of less than 1 foot will be increased to
at least 1 foot in these areas using cover soils similar in nature to the existing cover soils.
The caps over the Area Behind Eguipment Building and the Northern Disposal Area are included in
this and all other cap repair alternatives (Set Figure 2.). Large contiguous areas that are
currently well vegetated, are reducing erosion and are preventing direct contact with refuse

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will not be disturbed, for the purpose of repairing the cap thickness, even if the cap thickness
in these areas is less than 1 foot.

Final Vegetative Cover:  Areas where the cap thickness is repaired in accordance to the above
criterion will be vegetated with wildflower/grassland species in accordance with a meadow seed
mixture, as defined by US EPA following consultation with PADEP.  Within the eastern landfill,
areas currently well covered with meadow plant species (wildflower/grasses/other herbaceous
species) would be allowed to remain as they are even if the cap thickness in these areas is less
than 1 foot.  Ultimately, natural succession of the existing vegetation and seeded areas will be
allowed to take place on both the eastern and western landfills, returning the area to its
natural state.

Operation, Inspection and Maintenance:  In general terms, operation and maintenance activities
for the four cap repair alternatives will include the following:  1)  operations - management of
inspection and maintenance activities; 2) routine inspection - regular, pre-scheduled
inspections that are typically annual; 3) additional inspections - area- or item-specific
inspections following a particular event such as a large storm or repair; 4) routine maintenance
- regular, pre-scheduled maintenance such as removing debris from surface water drainage
channels and mowing of cover vegetation  (if needed); and, 5) repair maintenance - performed as a
result of an inspection identifying a problem.  Repair maintenance could include repairs to the
security fence, eroded areas, excessive wear to access roads, surface water drainage system
washouts, etc.

Operation, inspection, and maintenance activities specific to Cap Repair Alternative 4A would
include all five of the above items.  Inspection and maintenance activities are particularly
important for Cap Repair Alternative - 4A because of the lower final cap thickness that would be
maintained and because the cover vegetation would be allowed to naturally succeed to the forest
stage.  During natural succession of meadow to forest, the intermediate stage  (shrub)  is
expected to result in reduced visibility for inspection and access for maintenance.  Any
reduction in visibility or access can be effectively overcome as described below.

Inspection trails would be established at about 100-foot intervals using painted "blaze" on
trees in maturing forested areas and cut and maintained access ways in shrub areas.  A "brush
hog" or other mechanical means can effectively cut and maintain access trails through the shrub
areas. As these shrub areas mature into the forest stage, the inspection trails would be off-set
from the maintained cut trails into blazed forest trails and the former maintained trails can be
allowed to naturally succeed to the forest stage.  This maintained system of inspection trails
would allow the landfill cover inspector to retain spatial orientation at the Site so that
complete and thorough coverage and inspection of the cap would be performed.

This system of annual inspection for Cap Repair Alternative 4A can be augmented by using
annual flyovers with low altitude photography performed in the late fall/winter as an additional
means to identify any cap repair maintenance needed, such as tree wind throw, eroded area, bare
areas of the cap, and damage to surface water management systems.  Additional inspections
would be performed as needed based on the inspection observations and repair maintenance
conducted.

Routine maintenance of the landfill cap will include maintaining the surface water drainageways,
access roads, and inspection trails for the intended purpose.  Surface water drainage systems
and access roads will be kept clear of debris and woody vegetation.  This routine maintenance
will be performed annually and will include the use of herbicide application, cutting and
digging to remove woody plants from these areas, as needed.  Maintenance of the inspection
trails will be performed by "re-blazing" and/or re-"brush-hogging" the trails.

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While the maturing vegetation on the eastern and western landfill caps may present some unigue
challenges to the routine inspection and maintenance of the landfill caps, these challenges can
be effectively met through the procedures described above. In fact, the maturing shrub areas
and forests will effectively retard access and use of the area by trespassers and will provide
an effective stabilizing vegetative cover to reduce erosion, i.e., will provide preventative
maintenance.

4A Cap Repair Costs: Capital - $1,128,690
O&M - $ 104,000
Present Worth - $3,004,862

Alternative No. 4 Costs, not including cap repair:

Capital - $ 873,100
O&M - $ 120,000
Present Worth - $3,037,900

Total Alternative No. 4 Costs, including Cap Repair 4A

Total Capital - $2,001,790
Total O&M - $ 224,000
Total Present Worth - $6,042,762

2. Cap Repair Alternative 4B

Final Repaired Cap Thickness: This cap repair alternative provides a minimum of a 1-foot cap
thickness over the entire eastern landfill and over the non-forested portions of the western
landfill. All large contiguous areas of the eastern landfill cap having a thickness of less
than 1 foot will be increased to at least 1 foot including the Area Behind Eguipment Building
and the Northern Disposal Area (See Figure 2.). Forested/maturing shrub areas of the western
landfill would be left as they are regardless of the cap thick. However, while conservative
estimates indicate that portions of the cap in the forested portion of the western landfill may
be less than 1 foot in thickness, greater thicknesses are actually expected and will be
evaluated during remedial design.

Final Vegetative Cover: Ultimately, the forested/maturing shrub areas on the western landfill
will be allowed to mature to the mature forest stage. The remainder of the vegetation on the
western landfill, which consists of a meadow species on the crown, and the entire eastern
landfill will be seeded, as necessary, and maintained as ameadow (wildflower/grass/other
herbaceous species as described in 4A above).

Disturbances of the existing cover vegetation will occur as a result of cap thickness repair.
In addition, the shrub and small tree vegetation on the eastern landfill will be removed by
herbicide application and/or flush cutting and these areas will then be seeded with the meadow
mixture.

The existing meadow vegetative cover on the eastern and western landfills and the areas seeded
with the meadow mixture will be maintained as a meadow through a program of regular mowing
of the cover vegetation and removal of hay. Hay removal may include mulching and spreading.
The forested/maturing shrub areas on the western landfill will beallowed to naturally succeed to
forest and more mature forest stages.

Operation, Inspection and Maintenance: Inspection of the existing and created meadow
vegetative cover will be accomplished by an annual walkover during the spring of each year.

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The mowing of the meadow will provide additional cover inspections during the summer period.

Inspection of the forested/maturing shrub areas of the western landfill will be accomplished in
a manner similar to the procedures described for Cap Repair Alternative 4A. However, given that
the majority of this area is already in the forest stage, less reduction of visibility and
access is anticipated. The existing forested areas will be easily inspected and routes with
good visibility into adjacent areas should be easily maintained. The maturing shrub areas will
naturally succeed to the forest stage thus continually improving visibility and access.

Routine maintenance of the wildflower/grass meadow will be accomplished through annual
mowing in mid to late-July. The mowing height will be about 6 inches or greater and the hay
will be periodically removed. Hay removal could include mulching and spreading on the cap to
retain the organic matter. The mowing contractor shall also be eguipped with pin flags to
locate potential problems which may have occurred on the cap such as erosion or signs of cap
damage due to trespassing or other items. Mowing provides a unigue opportunity to inspect a
large portion of the landfill cap surface during the performance of routine maintenance.

No routine maintenance of the forested/maturing shrub areas on the western landfill are
anticipated as these areas will be allowed to naturally succeed to more mature forest stages.

Repair maintenance of the landfill caps, surface water drainage channels, fencing, and access
roads and other features will be performed on an as-needed basis as determined by the results of
inspections.

Cap Repair 4B Costs: Capital - $1,639,920
O&M - $ 78,000
Present Worth - $3,047,040

Alternative No. 4 Costs, not including cap repair:

Capital - $ 873,100
O&M - $ 120,000
Present Worth - $3,037,900

Total Alternative No. 4 Costs, including Cap Repair 4B:

Total Capital - $2,513,020
Total O&M - $198,000
Total Present Worth - $6,084,940

3. Cap Repair Alternative 4C

Final Repaired Cap Thickness: This cap repair alternative provides a minimum of a 2-foot cap
thickness over the entire eastern landfill and the non-forested/maturing shrub portions of the
western landfill. All large contiguous areas of the eastern landfill having a cap thickness of
less than 2 feet will be increased to at least 2 feet, including the Arm Behind Eguipment
Building and the Northern Disposal Area. Areas of the western landfill having a cap thickness
of less than 2 feet will be increased to at least 2 feet except in large contiguous areas of
forest/maturing shrub vegetation. As previously stated, while conservative estimates indicate
that portions of the forested cap in the western landfill may be less than 1 foot in thickness,
greater thicknesses are actually expected and will be evaluated during remedial design.

Final Vegetative Cover: Ultimately, the forested/maturing shrub areas on the western landfill
will be allowed to mature to the forest and more mature forest stage. The remainder of the

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western landfill and the entire eastern landfill will be seeded, as necessary, and maintained as
a meadow  (wildflower/grass/other herbaceous species as described in 4A above).

The existing vegetation on the eastern landfill and non-forested/maturing shrub areas of the
western landfill will be modified to provide a meadow consisting of wildflower, grasses, and
other herbaceous species as follows:  clear shrub and small trees via herbicide application
and/or flush cutting; remove the existing cover vegetation as a result of cap thickness repair,
and, improve areas not currently well covered by meadow vegetation.

In each of these areas, the soil cap surface will be seeded with the specified meadow mixture.
Existing meadow cover vegetation (wildflower, grasses and other herbaceous species),  if
overlying large contiguous areas having a cap thickness of at least 2 feet, will be left
undisturbed.

Large contiguous areas of forested/maturing shrub vegetation on the western landfill will be
left undisturbed.  These areas will be allowed to naturally succeed to more mature forest
stages.

Operation, Inspection and Maintenance:  Ultimately, two types of vegetative cover will be
maintained:  existing and created meadow cover consisting of wildflower/grasses and other
herbaceous species; and, forested areas on the western landfill.

Inspection, operation and maintenance of the repaired landfill caps in these areas will be
performed in a manner similar to that described for Cap Repair Alternative 4B.  The meadow
vegetative cover on the eastern and western landfills will be mowed and hay removed (or
mulched and spread) on an annual basis.  The forested and maturing shrub vegetation on the
western landfill will be allowed to naturally succeed to more mature stages of vegetative growth
and will therefore not reguire annual maintenance except for the maintenance of inspection
trails and access roads in these areas.

Cap Repair 4C Costs:              Capital            -   $3,504,660
                                  O&M                -   $   52,000
                                  Present Worth      -   $4,442,740

Alternative No. 4 Costs, not including cap repair:

                                  Capital            -   $  873,100
                                  O&M                -   $  120,000
                                  Present Worth      -   $3,037,900
Total Alternative No. 4 Costs, including Cap Repair 4C:

                        Total Capital Costs          -   $3,377,760
                        Total O&M Costs              -   $  172,000
                        Total Present Worth          -   $7,480,560

4.    Cap Repair Alternative 4D

Final Repaired Cap Thickness:  This cap repair alternative provides a minimum of a 2-foot cap
thickness over both the entire eastern and western landfills including the Area Behind Eguipment
Building and the Northern Disposal Area.  The cap thickness in all large contiguous areas of
both landfills that are less than 2 feet will be increased to at least 2 feet.  The forested and
maturing shrub vegetation on the western landfill and brush and small trees on the eastern

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landfill will be flush cut and maintained as a meadow (wildflowers/grass/other herbaceous
species).

Final Vegetative Cover: Ultimately, the final cover vegetation will be modified to provide a
meadow consisting of wildflower/grasses and other herbaceous species over both the entire
eastern and western landfills. The cover vegetation on the eastern landfill and non-
forested/maturing shrub vegetation on the western landfill will be modified as discussed for
Alternative 4C. The forested/maturing shrub vegetation on the western landfill will be flush
cut and seeded with the meadow mixture.

Inspection, Operation and Maintenance: Because the entire cap surfaces will consist of
meadow vegetation, the inspection and maintenance activities to be performed are as described
for the meadow areas in Alternative 4B. In summary, these include:

routine inspection:
annual walkovers, and,
annual mowing observations;
additional inspections, as needed;

routine maintenance:
annual mowing and hay removal and/or mulching/spreading,
clearing surface water drainageways, and
maintaining access roads; and,

repair maintenance as needed.

Cap Repair 4D Costs: Capital - $4,493,340
O&M - $ 39,000
Present Worth - $5,196,900
Alternative No. 4 Costs, not including cap repair:

Capital - $ 873,100
O&M - $ 120,000
Present Worth - $3,037,900

Total Alternative No. 4 Costs, including Cap Repair 4D:

Total Capital Costs - $5,366,440
Total O&M Costs - $ 159,000
Total Present Worth - $8,234,800

E. Alternative No. 5 - Institutional Controls, Monitoring, Leachate Management
System Operation, Landfill Cap Repairs (Cap Repair Alternatives 4A, 4B, 4C, and
4D), Leachate Collection System Expansion, and Regrading Crown of Eastern
Landfill

Alternative No. 5 consists of all the components of Alternative No. 4 plus the following
additional components:

expanding the existing leachate collection system; and, regrading the existing eastern landfill
cap crown.

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The crown of the eastern landfill would be regraded with the intent to further reduce
infiltration by creating steeper slopes to enhance runoff. The crown on the eastern landfill
has an average slope of about 4% and ranges from about 2% to 8%. These grades would be
increased to about 8% using soils of similar geotechnical characteristics to obtain similar
permeabilities. The newly constructed slopes would be vegetated with native grasses and
wildflowers. Runoff from the regraded area would flow onto the surrounding cap outside of the
crown and be collected and conveyed off of the landfill by the surface water management system.

Costs: Total Present Worth Range - $6,589,160 - $8,781,198 (depending
on cap repair alternative)

F. Alternative No. 7 - Institutional Controls, Monitoring, Leachate Management
System Operation, Landfill Cap Repairs (Cap Repair Alternatives 4A, 4B, 4C, and
4D), Leachate Collection System Expansion, and Limited Ground water Extraction
and Treatment

Alternative No. 7 consists of all the components of Alternative No. 4 plus the following
additional components:

expanding the existing leachate collection system; and, operation of ground water extraction
wells at select locations with treatment of the extracted ground water.

Limited ground water extraction would be performed by installing three 6-inch extraction wells
in the immediate vicinity of existing monitoring wells MP-18S and C-3S and C3-D designated
EWMP-18S, EWC-3S, and EWC-3D, respectively (See Figure 11.). These locations exhibited
the highest VOC concentrations detected in ground water samples collected during the remedial
investigation. Based on the hydraulic parameters identified at these well locations during the
remedial investigation the following pumping rates are believed to be able to be sustained at
each well: EWMP-18S - 1 gpm; EWC-3S-4 gpm; and, EWC-3D -4 gpm.

Collected ground water is expected to need on-Site treatment prior to discharge to surface water
or to the local POTW using the existing sewer tie-in. The combined flow of existing leachate
(approximately 22,000 gpd annual average), leachate from expanding the collection system
(estimated at 6,000 gpd), and the extracted ground water (approximately 13,000 gpd) would
exceed the maximum allowable daily flow specified in the Agreement with the Municipalities
(35,000 gpd). As a result, should the flows be combined with discharge to the local POTW, an
amendment to the Agreement would be reguired.

Costs: Total Present Worth Range - $12,554,261 - $14,746,299 (depending
on cap repair alternative)

VIII. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES

Each of the remedial alternatives described above was evaluated using nine criteria. The
resulting strengths and weaknesses of the alternatives were then weighed to identify the
alternative providing the best balance among the nine criteria. These nine criteria are:

Threshold Criteria

6 Overall protection of human health and the environment: Whether the remedy provides
adeguate protection and how risks posed through each pathway are eliminated, reduced
or controlled through treatment, engineering controls, or institutional controls.

6 Compliance with ARARs: Whether or not a remedy will meet all applicable or relevant

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and appropriate requirements ("ARARs") of Federal and State environmental statutes
and/or whether there are grounds for invoking a waiver. Whether or not the remedy
complies with advisories, criteria and/or guidance that may be relevant.

Primary Balancing Criteria

6 Long-term effectiveness and permanence: The ability of the remedy to afford long-
term, effective and permanent protection to human health and the environment, along
with the degree of certainty that the alternative will prove successful.

6 Reduction of toxicity, mobility or volume: The extent to which the alternative will
reduce the toxicity, mobility, or volume of the contaminants causing the site risks.

6 Short-term effectiveness: The time until protection is achieved and the short-term risk
or impact to the community, on-Site workers and the environment that may be posed
during the construction and implementation of the alternative.

6 Implementability: The technical and administrative feasibility of a remedy, including
the availability of materials and services needed to implement that remedy.

6 Cost: Includes estimated capital, operation and maintenance, and net present worth
costs. The present worth analysis is used to evaluate expenditures that occur over
different time periods by discounting all future costs to a common base year, usually the
current year. This analysis allows the cost of remedial action alternatives to be
compared on the basis of a single figure representing the amount of money that, if
invested in the basis year and disbursed as needed, would be sufficient to cover all costs
associated with the remedial action over its planned life.

Modifying Criteria

6 State Acceptance: Whether the Commonwealth concurs with, opposes, or has no
comment on the Selected Remedy.

6 Community Acceptance: Whether the public agrees with the Selected Remedy. This is
assessed in detail in the ROD responsiveness summary (Appendix D of this ROD)
which addresses public comments received on the Administrative Record and the
Proposed Plan

A. Overall Protection of Human Health and the Environment

Alternative No. 1 is considered to be the least protective. The operation of the leachate
management system would be discontinued, which might upset the existing equilibrium
established between landfill constituents and natural attenuation mechanisms, i.e., decrease
natural containment. As a result, constituent concentrations in ground water west of the Site
may increase in the future.

Alternative Nos. 2, 3, 4, 5, and 7 provide for the protection of human health and the
environment from the perspective of current and post-remedial risks. Indeed, each of these
alternatives feature nearly equivalest post-remedial risks which are well within US EPA's
acceptable range of 1 x 10 -4 to 1 x 10 -6. The maintenance of existing landfill caps and
operation of the existing leachate management system should continue, as they have in the past,
to control landfill constituent mobility such-that natural containment of landfill constituents
is maintained in the future. Alternative Nos. 3, 4, 5, and 7 are somewhat more protective than
Alternative No. 2 given the precautionary ground water monitoring provided. Future ground water

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monitoring will provide protection of residential use of ground water west of the Site outside
the point of compliance.

Furthermore, all of the alternatives, except Alternative No. 1, provide institutional controls
which will prohibit future consumption of on-Site ground water down gradient ftom the landfills
at the point of compliance.

The existing caps, which have existed ftom between 10 and over 20 years, and the existing
leachate management system, which has been in operation for 10 years, are expected to continue
to assist in providing protection of ground water west of the Site for residential use. The cap
repair component provided in Alternative Nos. 4, 5, and 7 is expected to provide a higher level
of assurance that future residential use of ground water west of the Site is protected because
these alternatives provide long-term maintenance of the landfill caps. Because the existing
caps are adequately reducing landfill constituent mobility, all of the cap repair alternatives
will, at a minimum, maintain the same magnitude of mobility reduction and, as a result, all four
cap repair alternatives are considered protective of human health and the environment.
Increasing the cap thickness via Cap Repair Alternatives 4C and 4D does not actually appear to
provide a higher level of protection. In addition, there are valid concerns that major
disturbances of the caps and flush cutting of the forest/maturing shrub vegetation on the
western landfill may result in sudden increases in infiltration that could potentially upset the
ground water quality equilibrium. Similarly, expanding the leachate collection system or ground
water extraction is not required for maintaining the current level of protection. However, cap
repairs that include long-term maintenance and continuing the operation of the existing leachate
collection system are believed necessary to provide maintenance of conditions at least equal to
that of the existing landfill cap and, as a result, provide a high level of protectiveness and
assurance that natural containment will be maintained in the future. As a result, Alternative
Nos. 2 and 3 (without cap repairs) are rated slightly less for protectiveness than Alternative
Nos. 4, 5, and 7 that contain cap repairs. Alternative Nos. 4 (including all cap repair
alternatives), 5, and 7 are rated essentially equally.

B. Compliance with ARARs

All of the alternatives except for Alternative No. 1 are expected to comply with
chemical-specific ARARs (MCLs and non zero MCLGs) for ground water west of the Site at the point
of compliance. As discussed above, Alternative No. 1 does not include operation of the leachate
management system and, as a result, ground water constituent concentrations west of the Site
may eventually increase and exceed chemical-specific ARARs for ground water in the future.

Alternative Nos. 2 and 3 do not include the future maintenance of the exiting landfill cap and,
as a result, conditions of the cap could theoretically deteriorate such that landfill
constituent mobility increases and natural containment decreases to the point where
chemical-specific ARARs for ground water are not met west of the Site. As a result, Alternative
Nos. 1, 2, and 3 (without cap repairs) are rated less than Alternatives 4, 5, and 7 that have
cap repairs. Furthermore, Alternative No. 2 is rated less than Alternative No. 3 because it does
not provide a means for measuring compliance to ground water ARARs west of the Site.

Alternative Nos. 2, 3, 4, 5, and 7 contain institutional controls which will prohibit the future
consumption of on-Site ground water down gradient of the landfills. As a result of these
institutional controls, there is no complete exposure pathway for on-Site ground water.

All of the alternatives, except Alternative No. 1, are expected to achieve potential location-
specific and action-specific ARARs.

The Pennsylvania Department of Environmental Protection (PADEP) identified 25 PA Code

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Chapter 273  (1988), as an applicable, or relevant and appropriate requirement for the Site.
Initially, US EPA did not consider Chapter 273 to be applicable, or relevant and appropriate as
discussed in the April 25, 1997 Proposed Remedial Action Plan.  After further consideration US
EPA recognizes the Pennsylvania Municipal Waste Management Regulations, 25 PA Code
Chapter 273  (1988) as an applicable requirement with regard to the alternatives including cap
repairs because the closure of the landfills was not officially approved by PADEP.  However,
EPA believes that a waiver of these requirements, in accordance with 40 C.F.R. ° 300.430(e) (9),
is appropriate because the cap repair alternatives will otherwise achieve equivalent standards
of performance in the protection of human health or the environment.  Currently, soil, sediment,
leachate, and air do not pose an unacceptable risk to human health, or the environment as a
result of the current conditions of the landfill caps.  For example, the remedial investigation
determined the following:

     1) Although there are variations in landfill cap thickness which will be addressed in all
     the cap repair portion of the Selected Remedy, the average current cap thicknesses of
     the western and eastern landfill are 24.7 and 18.7 inches, respectively;

     2) The existing landfill Caps generally exhibit low permeabilities in the 10 -7 cm/sec to
     10 -4 cm/sec range which effectively reduces infiltration and minimizes leachate
     generation.  In addition, modeling conducted for the feasibility study and reviewed and
     approved by EPA, indicates that there would be no benefit in reduction of infiltration if
     two feet of similar types of soils were used as final cover for the caps, as opposed to
     one foot of final cover;

    3)  the landfill caps exhibit in place densities of 89% to 90% of the Standard Proctor
    maximum dry density indicating compaction occurred during construction;
    4) the soils used to construct the caps are of the appropriate quality and character for
    landfill caps;

    5) the landfill caps are, in general, well graded, covered with a good stand of vegetation
    and overall do not exhibit signs of excessive erosion; and

    6) surface water management systems consisting of berms, benches, riprap lined
    channels and culverts have been constructed and generally are operating effectively.

    7) the leachate management system effectively collects Site leachate.

All the cap repair alternatives will insure that the landfill caps will continue to be
protective of human health and the environment in the future while effectively maintaining the
natural containment of on-Site ground water.  In addition, implementing the extensive grading
and final cover requirements of the regulations found at 25 PA Code ° 273.234 may pose a greater
risk to human health or the environment because to comply with such requirements might
jeopardize the natural containment of landfill constituents thereby creating greater risks to
downgradient receptors.

As a practical matter, all of the cap repair alternatives will achieve, at a minimum,
substantial compliance with 25 PA Code Chapter 75, the former landfill closure requirements.
All alternatives would at least meet and would likely exceed the stated performance objectives
of those closure requirements in that they will:  1) prevent direct contact with waste; 2)
provide a stable, well-vegetated soil cover, 3) minimize excessive erosion; and 4) protect
against environmental degradation (all of the cap repair alternatives provide a significant
level of reduction of landfill constituent mobility).

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In summary, Alternative Nos. 4, 5, and 7 provide an essentially equivalent level of ARAR
compliance that is significantly greater than that provided by Alternative No. 1 and somewhat
greater than that provided by Alternative Nos. 2, and 3.

C. Long-Term Effectiveness for Meeting Remedial Action Objectives and Permanence

Alternative Nos. 4 (including all cap repair alternatives), 5 and 7 provide the highest level of
long-term effectiveness since they meet all the primary and secondary remedial action objectives
equally. All of these alternatives include ground water monitoring and cap repair. Alternative
No. 3 provides the next highest level of long-term effectiveness because it meets all of the
primary objectives and also meets the secondary remedial action objective of ground water
monitoring. Alternative No. 2 meets all of the primary objectives but none of the secondary
objectives. Alternative No. 1 provides the lowest level of long-term effectiveness for meeting
remedial action objectives.

The greatest concern for long-term adverse impacts would result from disturbances of the
landfill caps associated with Cap Repair Alternative 4D, particularly on the western landfill.
The intense construction effort would cause a long-term elimination of the maturing forest
habitat on the western landfill. In addition, major disturbances of the cap surface soils and
vegetation could cause a sudden increase in infiltration, possibly resulting in increased risk
and non-compliance with ARARs west of the Site. These same disturbances also may cause
conditions where increased erosion cannot be adequately controlled which might have long lasting
effects on aquatic life.

None of the remedial alternatives considered provides a permanent remedy. All alternatives,
except for Alternative No. 1, rely on waste containment, institutional controls, natural
attenuation, and long-term monitoring and maintenance to provide the necessary level of
protection of human health and the environment. This is almost always the case when evaluating
remedial alternatives for closed municipal solid waste landfills.

D. Reduction of Toxicity, Mobility and Volume

Alternative No. 7 provides the most reduction of toxicity and volume through treatment as a
result of the limited collection and treatment of ground water and expanded collection and
treatment of leachate. Alternative Nos. 3 and 5 provide the next highest reduction of toxicity
and volume through treatment as a result of expanded leachate collection. Any additional
reduction of toxicity and volume afforded by Afternative Nos. 3, 5 and 7 may not be appreciable
and is not required to provide a high degree of long-term protection of human health and the
environment. The next highest degree of reduction of toxicity and volume is provided by
Alternative Nos. 2 and 4 as a result of continuing to operate the existing leachate management
system. On-going natural attenuation mechanisms that reduce toxicity and volume of constituents
are essentially equivalent for each of the alternatives.

Alternatives that include cap repairs (Alternative Nos. 4, 5, and 7) will result in a higher
level of reduction of constituent mobility than alternatives without cap repairs (Alternative
Nos. 1, 2, and 3). HELP model analyses have estimated that Cap Repair Alternatives 4B, 4C, and
4D provide an essentially equivalent level of reduction of constituent mobility in that they
reduce infiltration by about 97% to 99%. Cap Repair Alternatives 4C and 4D should provide a
slightly higher reduction of constituent mobility due to the slightly higher reduction in
infiltration (98 to 99%). Further reduction of constituent mobility is not required to provide
long-term protection of human health and the environment.

None of the cap repair alternatives address the reduction in toxicity or volume of leachate
constituents.

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E. Short-Term Effectiveness

All of the remedial alternatives, except for Alternative No. 7, are expected to be able to be
designed and constructed within 12 months. The alternatives are expected to have varying
degrees of adverse short-term impacts primarily as a result of the level of construction planned
for a given alternative, disturbances to the existing cap, impacts to terrestrial wildlife
habitat, and the potential for soil erosion to adjacent aquatic habitats. Accordingly, Cap
Repair Alternative 4A is rated best in that it is expected to have the lowest level of adverse
short-term impact. The remaining cap repair alternatives in order of increasing adverse
short-term impacts are 4B, 4C, and 4D. Cap Repair Alternative 4D has a much higher level of
adverse short-term impacts.

All of the alternatives are expected to have varying degrees of adverse short-term impacts
primarily as a result of the level of construction required for a given alternative.
Alternative No.7 and Cap Repair Alternatives 4C and 4D are expected to result in the most
adverse short-term impacts and Alternative No. 1 the least. Most of the short-term impacts to
human health, the environment, or community concerns are not expected to be major or
long-lasting.

F. Implementability

Similar to the criteria of short-term effectiveness, the implementability of the remedial
alternatives varies primarily as a result of the level of construction required. Alternative
No. 7 is expected to be most difficult to implement and Alternative No. 1 is essentially already
implemented. The components most difficult to implement are included with Alternative Nos. 3,
5, and 7 (potential modifications to the leachate agreement with the Municipalities) and
Alternative No. 7 (design and construction of a ground water treatment plant and obtaining
permit equivalencies for treated ground water discharge). Cap Repair Alternative 4B is the
easiest to implement followed by Cap Repair Alternative 4C. Cap Repair Alternatives 4A and
4D are expected to be the most difficult to implement, but for different reasons. Cap Repair
Allternative 4A includes conducting inspections and maintenance on the eastern landfill as
vegetation succeeds from the currently mostly meadow stage through shrub to forest stages.
While a comprehensive inspection and maintenance program can be utilized to adequately
conduct landfill inspections in these areas, implementing this inspection and maintenance
program will be more difficult for Cap Repair Alternative 4A than for the other alternatives.
Cap Repair Alternative 4D is considered to be the most difficult to implement due to the higher
level of construction complexity and the need to adequately prevent a sudden increase in
infiltration and to control erosion to surrounding aquatic habitats.

G. Cost

Alternative No. 1 (No Further Action) has the lowest overall cost. The remaining alternatives
in increasing overall cost are Alternative Nos. 2, 3, 4, 5, and 7. A summary of the estimated
cost for each alternative can be found in Table 13 and Table 14.

H. State Acceptance

PADEP has assisted EPA in the review of reports and Site evaluations for the Berks Landfill
Site. Although PADEP agrees with the approach of the Selected Remedy, it has not concurred
with this Record of Decision.

I. Community Acceptance

Pursuant to CERCLA ° 113(k)(2)(B)(I)-(v), US EPA released for public comment the final

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RI/FS reports and the Proposed Remedial Action Plan setting forth US EPA's preferred
alternative for the Berks Landfill Site on April 25, 1997.  US EPA made these documents
available to the public in the Administrative Record located at the US EPA Docket Room in
Region Ill's Philadelphia office, and at the Sinking Spring Public Library, Sinking Spring,
Pennsylvania.  The notice of availability of these documents was published in the Reading Eagle
and the Merchandiser on April 25, 1997 and May 14, 1997, respectively.

A public comment period on the documents was held from April 25, 1997 to May 26, 1997.  In
May, 1997 US EPA issued a Fact Sheet announcing the availability of the Proposed Remedial
Action plan and public meeting.  The May 1997 Fact Sheet discussed US EPA's Preferred
Alternative, as well as other alternatives evaluated by US EPA and solicited comments from all
interested parties.  In addition, US EPA conducted a public on May 14, 1997.  At this meeting,
representatives from US EPA answered guestions about conditions at the Site and the remedial
alternatives under consideration.

The responses to all comments received during the public comment periods are included in the
Responsiveness Summary, which is Appendix D of this Record of Decision ("ROD").

In summary, US EPA believes the selected remedy provides the best balance of trade-offs among
the alternatives evaluated with respect to the nine criteria above.

IX.  THE SELECTED REMEDY; DESCRIPTION AND PERFORMANCE
     STANDARD(S) FOR EACH COMPONENT OF THE REMEDY

A.   General Description of the Selected Remedy

US EPA carefully considered state and community acceptance of the remedy prior to reaching
the final decision regarding the remedy.

The Agency's selected remedy is set forth below.  Based on current information, this alternative
provided the best balance among the alternatives with respect to the nine criteria US EPA uses
to evaluate each alternative.  The selected remedy consists of the following components:

US EPA' s Selected Remedy for addressing contaminated ground water at the Berks
Landfill Superfund Site is Alternative No. 4 - Institutional Controls, Monitoring, Leachate
Management System and Operation, and Landfill Cap Repair Alternative 4B,  which includes:

            6     Institutional Controls
                        Title restrictions, restrictive covenants, etc. to prevent
                        future consumption of on-Site ground water, restrict
                        future development at the Site and limit future earth
                        moving activities at the Site;
            6     Long-term Monitoring, including
                        Installation of a sentinel monitoring well cluster,
                        Sampling of Residential wells,
                        Monitoring of on-Site wells, Combustible landfill gases
                        and Aguatic habitat,
            6     Leachate Management System Repair and Operation &
                        Maintenance
            6     Cap Repair and Maintenance, to include,
                        Minimum 1 foot final cover thickness on Eastern
                        Landfill and non-forested portions of the Western
                        Landfill; Eastern Landfill and non-forested portions of
                        Western Landfill will be maintained as wildflower/grass

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meadow (mowed once per year); Forested portions of
Western Landfill will remain and be maintained.
Estimated Capital Costs: $2,513,020
Estimated Annual O&M Costs: $198,000
Estimated 30 Year Total Present Worth Costs: $6,084,940

Each component of the Selected Remedy and its Performance Standards and Costs are described
below.

B. Description and Performance Standard(s) of Each Component of the Selected
Remedy

1. Institutional Controls to limit options for future Site use.

l.a. Description

Institutional controls will be used to identify the Site as property underlain by
contaminated groundwater, and to prevent the consumption of contaminated ground
water; to restrict future development at the Site and to limit future earth disturbing
activities on the capped portions of the Site.

l.b. Performance Standards

l.b.l No newly commenced or expanded ground water pumping in the aguifer shall be
implemented which will adversely affect the natural hydraulic containment and plume
migration.

l.b.2. Drinking water supply wells shall not be installed in the area of the contaminated
ground water plume.

l.b.3. No new development at or near the Site shall adversely affect the natural
hydraulic containment and plume migration.

l.b.4 Except as necessary to implement other portions of the selected remedy, no earth
moving activities shall be carried out on the capped portions of the western or eastern
landfill, the northern disposal area and the area behind the eguipment building locations.

l.b.5. Title restrictions along with other appropriate means shall be used to implement
the reguirements of l.b.l., l.b.2., l.b.3., and l.b.4., immediately above.

l.A.6. Title restrictions will be appropriately recorded with the Berks County Recorder
of Deeds.

2. Long-term Monitoring

2.a. Description

This portion of the remedy calls for a long-term sampling plan including sampling and
analyses at existing monitoring wells, residential wells, and new sentinel monitoring
wells, to be installed in a manner which will provide an early warning of potential
upsets in the natural hydraulic containment of the ground water plume, and to monitor
on-Site contaminant levels. In addition the long-term sampling plan will include

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surface water, sediment and benthic macroinvertebrate survey sampling of the
upgradient and downgradient drainage system to monitor effects the Site may have on
the drainage system.

2.b. Performance Standards

2.b.l. A long-term ground water monitoring program shall be implemented to evaluate
the effectiveness of the natural hydraulic containment mechanisms in maintaining Site
contaminant levels below MCLs and MCLGs at the point of compliance and to monitor
on-Site contaminant levels over time.

2.b.2. The plan for the long-term ground water monitoring program shall be included
in an operation and maintenance plan for the Site. This plan shall include the sampling
of a sufficient number of sentinel wells, residential wells and existing monitoring wells
to monitor the effectiveness of the natural hydraulic containment mechanisms in
maintaining Site related contaminant levels below MCLs and MCLGs at the point of
compliance and to monitor on-Site contaminant levels over time. As part of the
remedial design, US EPA, in consultation with PADEP, will determine the number and
location of wells necessary to verify the performance of the remedial action.

2.b.3. The installation of additional sentinel wells shall be reguired. The exact design,
number and location of these sentinel wells shall be determined by US EPA during the
remedial design, in consultation with the PADEP.

2.b.4. Sentinel wells and residential wells shall be sampled guarterly for Target
Compound List ("TCL") VOCs and semi-annual1y for Target Analyte List ("TAL")
metals for the first year of sampling. The sentinel wells and residential wells shall be
sampled no less than semi-annually for TCL VOCs and annually for TAL metals for the
second through fifth year of sampling. Based on the findings of the first five years of
sampling, the appropriate sampling freguency for subseguent years will be determined
by US EPA in consultation with the PADEP.

2.b.5. On-Site monitoring wells shall be sampled annually for TCL VOCs and TAL
metals for the first five years of sampling. Based on the findings of the first five years
of sampling, the appropriate sampling freguency for subseguent years will be
determined by US EPA, in consultation with the PADEP.

2.b.6. At least two rounds of surface water, sediment and benthic macroinvertebrate
sampling of the upgradient and downgradient surface water drainageways and the
tributary of the Cacoosing Creek shall be reguired. The first round shall be conducted
no less than six months after cap repairs are completed. The second round shall be
completed prior to the initial five-year review for the Site and the data included in the
initial five-year review for the Site. The surface water, sediment and benthic
macroinvertebrate sampling conducted as part of the Remedial Investigation shall be
used as a baseline for this reguired sampling, however, the exact sampling methods,
parameters, sampling locations and analytical methods will be determined by US EPA,
in consultation with PADEP, during the remedial design. US EPA, in consultation with
PADEP, will determine if additional surface water, sediment and benthic
macroinvertebrate sampling is necessary based on the findings of the first two rounds of
samples collected.

2.b.7. Sampling and operation and maintenance shall continue until such time as US
EPA, in consultation with PADEP, determines that MCLs or MCLGs for each
contaminant of concern have been achieved to the extent technically practicable

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throughout the entire area of ground water contamination.

3. Leachate Management System Operation & Maintenance

3.a. Description

This portion of the remedy calls for the inspection, repair and continued operation and
maintenance of the existing leachate collection system at the Site.

3.b. Performance Standards

S.b.l. An initial inspection of the existing leachate management system, including but
not limited to, collection and conveyance piping, manholes, valves, lagoons and pumps
shall be conducted. The appropriate inspection method(s) will be determined by US
EPA in consultation with the PADEP during the Remedial Design.

3.b.2. Any deficiencies of the existing leachate management system identified under
3-b.l shall be repaired. Repairs may include, but shall not be limited to, hydrocleaning,
or replacing any collection system piping compromised by blockage, clogging, or
structural failure, replacing manholes, manhole covers, valves and/or conveyance
piping, repairing or replacing the collection lagoon liners and repairing/replacing the
pumping system. US EPA, in consultation with PADEP, will determine the type of
final repairs necessary to correct deficiencies identified under S.b.l.

S.b.S. A plan for the long-term operation and maintenance of the leachate management
system shall be included in an operation and maintenance plan for the Site. This plan
shall include routine inspections of the system of a sufficient freguency to monitor and
maintain the effectiveness of leachate management system over time. US EPA, in
consultation with PADEP, will determine the type and freguency of inspections
necessary to verify the performance of the system.

4. Landfill Cap Repairs

4.a. Description

This portion of the selected remedy calls for the repair of the existing landfill soil caps
in order to establish and maintain a minimum of one foot of soil cover, a stable,
maintainable well vegetated final cover, prevent direct contact with refuse and minimize
excessive erosion and seepage to protect the final cover over the eastern landfill,
western landfill, northern disposal area and the area behind the eguipment building.

4.b. Performance Standards

4.b.l. A comprehensive inspection of the western landfill, eastern landfill, northern
disposal area and the area behind the eguipment building cap conditions including, but
not limited to, cap thickness, vegetative cover, erosional areas and settlement cracks,
landfill slopes, surface water management systems and passive gas vents shall be
performed as part of the remedial design. The appropriate inspection method(s) will be
determined by US EPA in consultation with the PADEP during the remedial design.

4.b.2. All large contiguous areas of the non-forested portion of the western landfill, the
eastern landfill, the northern disposal area and the area behind the eguipment building
identified during 4.b.l as having less than one foot in final cover thickness will be
increased to a minimum of one foot of final cover material of a type similar to the

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existing cover material. The definition of a large contiguous area will be determined by
US EPA, in consultation with PADEP during the remedial design. The final cover material
shall prevent vectors, odors, blowing litter and other nuisances. The final cover shall
cover solid waste without change in its properties and without regard to weather. The final
cover shall be noncombustible. The final cover shall be capable of supporting the
germination of propagation of the vegetative cover under 4.b.3.

4.b.3. All areas where existing cover is disturbed for repairs in accordance with 4.b.2.,
4.b.4., 4.b.6., 4.b.7., 4.b.8. and 4.b.9. will be reseeded with the following
wildflower/grassland meadow seed mixture:

Big bluestem (Andropogon gerardii) 2.5 Ibs/acre
Switchgrass (Panicum virgatum) 1 Ib/acre
Indiangrass (Sorghastrum nutans) 2 Ibs/acre
Little bluestem (Andropogon scopadus) 1 Ib/acre
Sideoats grama (Bouteloua curtipendula) 1 Ib/acre
New England aster (Aster novae-angliae) 2 oz/acre
Gray-headed coneflower (Ratibida pinnata) 3 oz/acre
Round-headed bushclover (Lespedeza capitata) 3 oz/acre
Black-eyed Susan (Rudbeckia hirta) 6 oz/acre

Revegetation shall provide for an effective and permanent cover. Disturbed and bare
areas shall be seeded and planted when weather and planting season permit, however,
the seeding and planting of disturbed areas shall be performed by the first normal period
of favorable planting after final grading. The performance standard for successful
revegetation shall be the percent of ground cover of the vegetation which exists on the
Site. A minimum of 70% groundcover of the disturbed areas with the above permanent
ground cover shall be required. No more than 1% of the total disturbed area shall have
less than 30% ground cover. No single or contiguous disturbed area exceeding 3,000
sguare feet shall have less than 30% groundcover.

4.b.4. Existing shrub and small tree vegetation in areas identified in 4.b.l. with existing
cap thickness greater than one foot and not disturbed for any repair under 4.b.2., 4.b.6.,
4.b.7, 4.b.8. or 4.b.9. on the eastern landfill, northern disposal area and area behind the
equipment building will be removed by herbicide application and/or flush cutting and
then these areas will be seeded in accordance with 4.b.3.

4.b.5. The forested/maturing shrub tree areas of the western landfill shall be allowed to
naturally succeed to the mature forest stage. The existing meadow area on the crown of
the western landfill shall be addressed according to 4.b.4. and 4.b.6.

4.b.6. All bare areas with cover thickness greater than one foot shall be evaluated and
corrective measures taken, including but not limited to, surface water management
system repairs to prevent erosion; fertilizer and/or topsoil may be applied to rectify low
fertility; and passive gas venting can be used to establish and maintain an effective well
vegetated final cover. These areas shall be seeded in accordance with 4.b.3.

4.b.7. All existing cap areas identified during 4.b.l with side slopes greater than 33%
shall be repaired. No repaired area shall have a final side slope greater than 33%. The
grade of final side slopes shall ensure permanent slope stability; control erosion due to
rapid water velocity and other factors; and allow compaction, seeding and revegetation
of cover material place on the slopes. The grade of the final surface of the cap areas
shall not be less than 3%. For final slopes greater than 15% the necessity of horizontal
terraces shall be determined by US EPA in consultation with PADEP during the

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remedial design. If it is determined that existing horizontal terraces need repair or new
horizontal terraces are necessary, the final design characteristics of the terraces shall be
determined by US EPA in consultation PADEP. No slopes shall have a grade
exceeding 33% including slopes between benched terraces.

4.b.8. The existing thin lens (approx. 20 foot by 50 foot) of exposed refuse on the
northeastern portion of the eastern landfill and any other areas of exposed refuse
identified under 4.b.l shall be repaired in accordance with 4.b.2., 4.b.3, 4.b.7. and 4.b.9.

4.b.9. Soil erosion and sedimentation shall be prevented to the maximum extent
possible. The need for stabilization and reseeding under Section 4.b.3 will be
determined by US EPA in consultation with PADEP.

4.b.lO. Surface water management shall comply with the reguirements of The Dam
Safety and Waterway Management Act, 25 PA Code °° 105.1 - 105.3, 105.12, and
105.19.

4.b.ll. Routine sampling of combustible gas levels shall be reguired. US EPA in
consultation with PADEP will determine the freguency, location, sampling and
analytical methods for the combustible gas sampling during the remedial design. A
plan for the routine monitoring of combustible gas levels shall be included in the
operation and maintenance plan for the Site.

4.b.ll. All cap repair activities shall avoid, minimize and mitigate impacts on
floodplains and wetlands. The performance standard will be compliance with Executive
Order No. 11988 and 40 CFR Part 6, Appendix A (regarding avoidance, minimization
and mitigation of impacts on floodplains), and Executive Order No. 11990 and 40 CFR
Part 6, Appendix A (regarding avoidance, minimization and mitigation of impacts on
wetlands).

4.b.l3. A plan for the long-term operation and maintenance of the forested/maturing
shrub portion of the western landfill shall be included in an operation and maintenance
plan for the Site. This plan shall include routine inspections of the forested/maturing
shrub portion of a sufficient freguency to monitor and maintain the effectiveness of the
final cap over time. US EPA, in consultation with PADEP, will determine the type and
freguency of inspections and maintenance necessary to verify and maintain the
performance of the cap.

4.b.l4. A plan for the long-term operation and maintenance of the non-forested portion
of the western landfill, the eastern landfill, the northern disposal area and the area
behind the eguipment building shall be included in an operation and maintenance plan
for the Site. This plan shall include routine inspections of the system of a sufficient
freguency to monitor and maintain the effectiveness of the final cap over time. US
EPA, in consultation with PADEP, will determine the type and freguency of inspections
and maintenance necessary to verify and maintain the performance of the cap.

Worker Safety

During all Site work, Occupational Safety and Health Administration ("OSHA") standards set
forth at 29 C.F.R, Parts 1910, 1926 and 1904 governing worker safety during hazardous waste
operations, shall be complied with.

Five-Year Reviews

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Long-term monitoring, operation and maintenance of the leachate management system and
operation and maintenance of the landfill caps shall continue for an estimated 30 years or such
other time period as US EPA, in consultation with PADEP, determines to be necessary, based on
the statutory reviews of the remedial action which shall be conducted no less often than every
five years from the initiation of the remedial action in accordance with the US EPA guidance
document, Structure and Components of Five-Year Reviews (OSWER Directive 9355.7-02, May
23, 1991) . Five-year statutory reviews under Section 121 (c) of CERCLA will be reguired, as
long as hazardous substances remain on-Site and prevent unlimited use and unrestricted access to
the Site. Five-year reviews shall be conducted after the remedy is implemented to assure that
the remedy continues to protect human health and the environment. A Five-year Review Work Plan
shall be reguired and shall be approved by US EPA in consultation with the PADEP.

X. STATUTORY DETERMINATIONS

US EPA's primary responsibility at Superfund sites is to select remedial actions that are
protective of human health and the environment. Section 121 of CERCLA also reguires that the
selected remedial action comply with ARARs, be cost effective, and utilize permanent treatment
technologies to the maximum extent practicable. The following sections discuss how the
selected remedy for the Berks Landfill Site meets these statutory reguirements.

A. Protection of Human Health and the Environment

Based on the baseline Human Health Risk Assessment for the Berks Landfill Site, measures
should be considered to reduce potential risk from VOCs and metals in the ground water beneath
the Site. These contaminants in on-Site groundwater were selected because potential health
hazards for some exposure scenarios exceeded the US EPA target range of 1.0 x 10 -4 (or 1 in
10,000), and 1. 0 x 10 -6 (or 1 in 1,000,000) for lifetime cancer risk or a non-cancer Hazard
Index of one (1). The results of the Ecological Risk Assessment show that the Site does not
pose an unacceptable risk to ecological receptors.

The institutional controls called for in the selected remedy will prevent future human exposure
to on-Site ground water contaminants. US EPA is using its discretion based on Site-specific
conditions to establish the point of compliance for ground water at the Site as the western,
eastern and southern Site property boundaries and Wheatfield Road to the north. This point of
compliance for ground water will be protective of human health and the environment.

The long-term monitoring called for in the selected remedy will act as an early warning in the
event that on-Site contaminants move beyond the point of compliance.

The cap repairs called for in the selected remedy in conjunction with the repair and continued
operation and maintenance of the existing leachate management system will assist in maintaining
the natural containment of on-Site ground water contaminants. The cap repair, and operation and
maintenance portion of the selected remedy will insure that the caps will prevent direct contact
with waste; provide a stable, maintainable, well vegetated soil cover; and minimize erosion and
seeps in the future.

Implementation of the selected remedy will not pose any unacceptable short term risks or cross
media impacts to the Site, or the community.

B. Compliance with and Attainment of Applicable or Relevant and Appropriate

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Requirements ("ARARs")

The selected remedy will comply with all applicable or relevant and appropriate chemical-
specific, location-specific and action-specific ARARs. Those ARARs are:

1. Chemical Specific ARARs

PADEP has identified the Land Recycling and Environmental Remediation Standards Act, 95
Pa. Laws 2 ("Act II"), as an ARAR for this remedy; however, US EPA has determined that Act II
does not, on the facts and circumstances of this remedy, impose any requirements more strinqent
than the federal standards. Accordinqly, qroundwater cleanup Maximum Contaminant Levels
and non-zero Maximum Contaminant Level Goals are set forth in accordance with Section 300q-
1 of the Safe Drinkinq Water Act, 42 U.S.C. Section 1412, and its implementinq requlations at
40 C.F.R. Part 141 as relevant and appropriate to the Selected Remedy at the point of
compliance.

Compliance with qroundwater concentration limitations at the point of compliance required by
Section 121(d)(2)(A)(I) and (ii) of CERCLA and 40 C.F.R. Section 300.430(e)(2)(I)(B). Those
limitations are established at 40 C.F.R. Sections 141.11-16, 141.50-51 and 141.60-63.

2. Location Specific ARARs

The Pennsylvania Erosion Control Requlations, 25 PA Code °° 102.1 - 102.5, 102.11 - 102.13,
and 102.21 - 102.24, requlate erosion and sedimentation control. These requlation are
applicable to the qradinq and excavation activities associated with the selected remedy.

The Storm Water Manaqement Act of October 4, 1978, P.L. No. 167, as amended 32 P.S.
Section 680.13. is applicable with respect to control of storm water runoff durinq construction,

The Dam Safety and Waterway Manaqement Act, 25 PA Code °° 105.1 - 105.3, 105.12, and
105.19 are location-specific requlations for the surface water manaqement system as it is
considered waters of the Commonwealth.

3. Action Specific ARARs

Pennsylvania Municipal Waste Manaqement Requlation, 25 PA Code Chapter 273 apply to the
selected remedy. However, EPA is waivinq these requirements because the remedial action
selected in this Record of Decision will attain an equivalent standard of performance in the
protection of human health and the environment throuqh the cap repairs, continued leachate
manaqement system operation and lonq-term monitorinq.

With respect of the discharqe of water from the leachate collection system into a publicly owned
treatment works, Federal Water Pollution Control Act, 33 U.S.C. ° 1317; 40 C.F.R. °° 403.5 and
403.17; and 25 PA Code °° 97.1, 97.14-15 and 97.91-95.

Fuqitive dust emissions qenerated durinq remedial activities will be controlled in order to
comply with fuqitive dust requlations in the federally-approved State Implementation Plan
("SIP") for the Commonwealth of Pennsylvania, 25 PA Code °° 123.1 - 123.2. and the National
Ambient Air Quality Standards for Particulate Matter in 40 C.F.R. °° 50.6 and PA Code °° 131.2
and 131.3

25 PA Code °° 123.31 and 123.41 which prohibits malodors detectable beyond the Berks
Landfill property line is applicable to the selected remedial alternative.

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25 Pa. Code Chapter 107 is applicable to the drilling of any new wells at the Site. These
regulations are established pursuant to the Water Well Drillers License Act, 32 P.S. ° 645.1 et
seg.

4. To Be Considered ("TBC") Standards

OWSER Directive #9355.7-04, Land Use in the CERCLA Remediation Selection Process, is a
"to be considered" (TBC) reguirement.

Sediment and erosion controls and temporary covers will be installed to protect exposed soil
from the effects of weather in accordance with PADEP, Bureau of Soil and Water Conservation's
Erosion and Sediment Pollution Control Manual which is a "to be considered" (TBC)
reguirement.

40 C.F.R. ° 6.302 Subpart C (a) and (b) addressing wetlands and floodplains are "to be
considered" reguirements with regard to the cap repair portion of the selected remedy.

Any on-Site landscaping will be in accordance with Office of the Federal Executive; Guidance
for Presidential Memorandum on Environmentally and Economically Beneficial Landscape
Practices on Federal Landscaped Grounds, 60 Fed. Reg. 40837 (August 10, 1995) which is a "to
be considered" (TBC) reguirement.

C. Cost-Effectiveness

The selected remedy is cost-effective in providing overall protection in proportion to cost, and
meets all other reguirements of CERCLA. Section 300.430(f)(ii)(D) of the NCP reguires US
EPA to evaluate cost-effectiveness by comparing all the alternatives which meet the threshold
criteria - protection of human health and the environment and compliance with ARARS - against
three additional balancing criteria: long-term effectiveness and permanence; reduction of
toxicity, mobility or volume through treatment, and short-term effectiveness. The selected
remedy meets these criteria and provides for overall effectiveness in proportion to its cost.
The combined estimated present worth cost for the selected remedy presented in this Record of
Decision is $6,084,940.

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

None of the remedial alternatives considered provides a permanent remedy. All alternatives rely
on waste containment, institutional controls, natural attenuation, and long-term monitoring and
maintenance to provide the necessary level of protection of human health and the environment.
This is almost always the case when evaluating remedial alternatives for closed municipal solid
waste landfills. US EPA has determined that the selected remedy represents the maximum extent to
which permanent solutions and treatment technologies can be, utilized while providing the best
balance among the other evaluation criteria. Of those alternatives evaluated that are
protective of human health-and the environment and meet ARARs, the selected remedy provides the
best balance of tradeoffs in terms of long-term and short-term effectiveness and permanence,
cost, implementability, reduction in toxicity, mobility, or volume through treatment, State and
community acceptance, and preference for treatment as a principal element.

E. Preference for Treatment as a Principal Element

The selected remedy addresses the primary threat of future ingestion and inhalation of on-Site
contaminated ground water through the use of institutional controls while natural processes such
as dilution, dispersion, sorption and volatilization of contaminants are contributing to the

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natural treatment and reduction of contaminant concentrations in the ground water at the point
of compliance. To the extent that Site related contaminants are naturally treated and reduced
at the point of compliance the selected remedy satisfies, in part, the statutory preference for
treatment as a principal element.

As discussed above, an intrusive diabase mass is the most important geologic feature at the
Site. This diabase mass, at the surface, encircles the Site except for possibly a small area to
the southwest, and is present beneath the Site in a bowl-like configuration. The large diabase
mass acts as a low permeability hydraulic barrier, deflecting ground water flow to the west, to
its eventual discharge point, in the north west corner of the Site (See Figures 4. & 5.).
Ground water discharges into the tributary of the Cacoosing Creek in this area. Water guality
and aguatic organism sampling conducted in the tributary of the Cacoosing Creek and in the
on-Site drainage ways shows that ground water discharging to the Cacoosing Creek tributary is
not causing an increased risk to human health, or environmental receptors. It is believed that
natural processes such as dilution, dispersion, sorption and volatilization of contaminants are
contributing to the natural treatment and reduction of contaminant concentrations in the ground
water. These natural contaminant reducing processes when combined with the unigue diabase mass
which forces ground water to discharge to the Cacoosing Creek tributary provide natural
containment of the Site-related contaminants and does not allow them to move off-Site beyond the
point of compliance.

XI. DOCUMEMATION OF CHANGES FROM PROPOSED PLAN

A. 25 PA Code Chapter 273(1988)

The Pennsylvania Department of Environmental Protection (PADEP) identified 25 PA Code
Chapter 273 (1988), as an applicable, or relevant and appropriate reguirement for the Site.
Initially, US EPA did not consider Chapter 273 to be applicable, or relevant and appropriate as
discussed in the April 25, 1997 Proposed Remedial Action Plan. After further consideration US
EPA recognizes the Pennsylvania Municipal Waste Management Regulations, 25 PA Code
Chapter 273 (1988) to be an applicable reguirement because the closure of the landfills was not
officially approved by PADEP. However, EPA believes that a waiver of these reguirements, in
accordance with 40 C.F.R. ° 300.430(e)(9), is appropriate because the proposed remedy will
otherwise achieve an eguivalent standard of performance in the protection of human health or the
environment as discussed above in Section VII.B.

B. Air Monitoring

EPA received public comments on the April 25, 1997 Proposed Remedial Action Plan regarding
the effectiveness of the current landfill gas venting system as well as concerns regarding
strong methane odors from the Site. EPA carefully considered the comments and has added air
monitoring to the Long-term monitoring component of the selected remedy. Routine sampling
of combustible gas levels shall be reguired. US EPA in consultation with PADEP will determine
the freguency, location, sampling and analytical methods for the combustible gas sampling
during the remedial design. A plan for the routine monitoring of combustible gas levels shall
be included in the operation and maintenance plan for the Site.
Appendix A

Figures
Appendix B

Tables

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                                                  TABLE 1.

            SUMMARY OF DETECTED CHEMICALS IN BACKGROUND SURFACE SOIL SAMPLES 1
                                        BERKS LANDFILL
                                  BERKS COUNTY,  PENNSYLVANIA

                                                   Range Of
                                 Frequency         Detected        Arithmetic
          Constituents              Of         Concentrations 4      Mean 5
           Detected 2           Detection 3        (mg/kg)           (mg/kg)

       Butylbenzylphthalate             1/3           ND - 0.044         0.15
       Chrysene                          1/3           ND - 0.047         0.15
       Fluoranthene                      1/3           ND - 0.068         0.15
       Pyrene                            1/3           ND - 0.041         145
       Aluminum                          3/3        19,200 - 26,600      23,933
       Arsenic                           3/3           4.2-4.5          2.18
       Barium                            3/3           95.4 - 151         120
       Beryllium                         2/3            ND - 1.5          1.2
       Calcium                           3/3         2,720 - 5,740       4,030
       Chromium                          2/3           ND - 91.8          48.1
       Cobalt                            3/3          16.1 - 34.8         21.8
       Copper                            3/3           31.8 - 408         167
       Iron                              3/3        26,100 - 65,900      45,200
       Lead                              3/3          31.2-37.4          22
       Magnesium                         3/3         2,200 - 3,550        3,083
       Manganese                         3/3          712 - 1,350          537
       Nickel                            3/3          11.2-37.3         23.6
       Potassium                         3/3          619 - 3,130         1,552
       Vanadium                          3/3           67.6 - 152         96.9
       Zinc                              3/3           95.9 - 151          116

  Notes:
     The determination of frequency of detections and the calculation of mean concentrations are performed
  in accordance with the procedures outlined in Risk Assessment Guidance For Superfund (RAGS),  Volume 1
(USEPA, 1989a)  and Guidance for Data Usability In  Risk Assessment, Interim Final (USEPA,  1990).

     1 Based on chemical concentrations in surface soil samples Sl-BG,  S2-BG, and S3-BG.

     2 Constituent is listed if it was detected at a frequency of at least once in the
    environmental media.  Only constituents qualified with an A, J, K,  or L are considered detected.

     3 Frequency of Detection is the number of times a constituent is detected over the number of times a
    constituent was analyzed in each media subgroup.   Data qualified with an N, B,JN or R are not
counted in the determination of frequency of detection.

     4 ND = Not detected.

     5 Mean is the Arithmetic Mean where:
        Field duplicate and primary sample results are averaged for a given sample value
        The highest value of either the primary or reanalysis is used for a given sample
        One-half the SQL or CRDL is used as the result for data containing 'U' in its qualifier
        One-half the reported value is used for data qualified as K or L
        The full reported value is used for data qualified as A or J

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                                      TABLE  2.
SUMMARY OF DETECTED CHEMICALS  IN BACKGROUND  SURFACE SOIL SAMPLES 1
                            BERKS LANDFILL
                      BERKS COUNTY,  PENNSYLVANIA

Constituents
Detected 2
2-Butanone
4-Methyl-2-Pentanone
Acetone
Chlorobenzene
Chloroform
Ethylbenzene
Toluene
Total Xylenes
1, 4-Dichlorobenzene
2 -Methylnaphthal ene
Acenaphthene
Anthracene
Benzo (a) Anthracene
Benzo (a) Pyrene
Benzo (b) Fluoranthene
Benzo (g,h, i) Per yl ene
Benzo (k) Fluoranthene
Butylbenzylphthalate
Carbazole
Chrysene
Di-n-Octyl Phthalate
Dibenz ( a, h) Anthracene
Dibenzofuran
Fluoranthene
Fluorene
Indeno ( 1 , 2 , 3-cd) Pyrene
Naphthalene
Pentachlorophenol
Phenanthrene
Phenol
Pyrene
Aroclor-1248
Frequency
Of
Detection 3
4/19
1/19
1/3
1/18
1/19
3/19
3/19
4/18
1/19
2/19
2/19
2/19
2/19
2/19
1/18
1/19
1/18
2/19
1/19
2/19
1/19
1/19
2/19
7/19
2/19
1/19
2/19
1/19
4/19
1/19
5/19
1/6
Range Of
Detected
Concentrations
(mg/kg)
ND
ND
ND
ND
ND
ND
ND
ND
ND - 0.
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
4
- 0.014
- 0.004
- 0.11
- 0.002
- 0.006
- 0.037
- 0.18
- 0.073
12
- 0.12
- 0.38
- 0.655
- 1.85
- 1.21
- 0.15
-0.63
- 0.068
- 0.063
- 0.37
- 1.5
- 0.054
- 0.32
- 0.26
- 3.15
- 0.46
- 0.58
- 0.4
- 0.11
- 2.9
- 0.12
- 2.7
- 0.27
Arithmetic
Mean
(mg/kg) 5
0.007
0.006
0.041
0.006
0.006
0.008
0.015
0.01
0.2
0.191
0.202
0.217
0.285
0.249
0.199
0.224
0.194
0.192
0.21
0.267
0.2
0.208
0.196
0.326
0.206
0.221
0.208
0.483
0.333
0.202
0.312
0.04

-------
                               TABLE 2. Cont.

      SUMMARY OF DETECTED CHEMICALS IN BACKGROUND SURFACE SOIL SAMPLES 1
                               BERKS LANDFILL
                         BERKS COUNTY, PENNSYLVANIA
   Constituents
    Detected 2
 Frequency
    Of
Detection 3
    Range Of
    Detected
Concentrations 4
    (mg/kg)
Arithmetic
  Mean 5
  (mg/kg)
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Vanadium
Zinc
     19/19        5,430 - 33,400       20,731
      2/14           ND - 4.3           6.47
     14/14          1.6 - 30.9          6.32
     19/19               38.9 - 933
     14/19            ND - 2            1.09
  5/18            ND - 9.1           2.2
 19/19         2,040 - 20,600       6,896
     19/19         18.1 - 1,180         151
 19/19           10.9 - 55.4         19.8
 19/19           10.4 - 247          47.7
     19/19       21,800 - 200,000      43,621
     19/19          5.3 - 176.7         14.4
     19/19        2,800 - 37,500       10,964
     19/19          293 - 6,030         798
  7/19            ND - 0.26          0.08
 19/19           21.5 - 771           96
     11/11        266.5 - 2,140        1,058
      2/19           ND - 66.2          4.31
  1/19            ND - 0.67          1.15
  4/4           376 - 2,310        1,350
     19/19          25.7 - 137          65.9
     19/19          57.1 - 332          103
                              125

-------
  Notes:
The determination of frequency of detactions and the calculation of mean concentrations are
performed in accordance with the procedures outlined in Risk Assessment Guidance For Superfund
(RAGS) , Volume 1 (USEPA, 1989a) and Guidance for Data Usability In Risk Assessment, Interim
Final  (USEPA, 1900) .

     1 Based on chemical concentrations in surface soil samples SI-EL, Sl-WL, S2-EL, S2-WL,
       S3-EL, S3-WL,  S4-EL, S4-WL, S5-EL, S5-WL, S6-EL, S6-WL, S7-EL, S7-WL, S8-EL, S8-WL,
       S9-EL, S10-EL, and Sll-EL.

     2 Constituent is listed if it was detected at a frequency of at least once in the
     environmental media. Only constituents qualified with an A, J, K, or L are considered
     detected.

     3 Frequency of Detection is the number of times a constituent is detected over the number
       of times a constituent was analyzed in each media.  Data qualified with an N, B, JN or R
       are not counted in the determination of frequency of detection.

     4 ND =  Not detected.

     5 Mean is the Arithmetic Mean where:
         Field duplicate and primary sample results are averaqed for a qiven sample value
         The hiqhest value of either the primary or reanalysis is used for a qiven sample
         One-half the SQL or CRDL is used as the result for data containinq  'U' in its qualifier
         One-half the reported value is used for data qualified as K or L
         The full reported value is used for data qualified as A or J

-------
                                   TABLE 3.

     SUMMARY OF DETECTED CHEMICALS IN BACKGROUND SURFACE SOIL SAMPLES 1
                                 BERKS LANDFILL
                           BERKS COUNTY, PENNSYLVANIA
   Constituents
    Detected 2
 Frequency
    Of
Detection 3
Acetone                             1/3
Benzene                             2/6
Chlorobenzene                       3/6
Chloroethane                        1/6
Ethylbenzene                        2/6
Toluene                             3/6
Total Xylenes                       2/6
1,4-Dichlorobenzene                 1/2
2-Methylnaphthalene                 2/2
4-Chloro-3-Methylphenol             1/2
4-Methylphenol                      1/2
Naphthalene                         2/2
bis(2-Ethylhexyl)Phthalate     1/2
Aluminum                            2/2
Arsenic                             2/2
Barium                         2/2
Cadmium                             2/2
Calcium                             2/2
Chromium                            2/2
Cobalt                         1/1
Copper                         2/2
Iron                           2/2
Lead                           2/2
Magnesium                           2/2
Manganese                           2/2
Nickel                         1/1
Potassium                           2/2
Sodium                              2/2
Vanadium                            2/2
Zinc                           2/2
    Range Of
    Detected
Concentrations
     (mg/1)

         ND
         ND
         ND
         ND
         ND
         ND
        ND - 0.
         ND  -
        0.002
         ND -
        ND - 0
       0.011 -
    ND - 0.001
        0.41 -
      0.0091 -
  0.266 - 0.453
      0.0022 - 0.0034
          46 - 121
      0.0128 - 0.0249
 0.0313 - 0.0313
 0.0042 - 0.0202
        10.5 - 24.7
 0.0156 - 0.0174
         23.2 - 153
        0.88 - 2.26
 0.0997 - 0.0997
          49 - 345
         132 - 954
      0.0079 - 0.0203
        .0974 - 0.213
Arithmetic
; 4

0.016
0.008
0.0145
0.0155
0.087
0.005
).15
0.0085
- 0.002
0.002
J.001
- 0.013

- 4.04
- 0.0166
Mean 5
(mg/1)
0.009
0.006
0.006
0.007
0.019
0.004
0.035
0.007
0.002
0.004
0.003
0.012
0.003
2.23
0.006
                                     0.36
                                         83.5
 0.001

 0.009
 0.031
 0.012
17.6
                                     0.017
                                          197
                                        543
                                              1.57
                                              0.1
                                              0.014
                                              0.131

-------
  Notes:
      The determination of frequency of detections and the calculation of mean concentrations
are performed in accordance with the procedures outlined in Risk Assessment Guidance For
Superfund (RAGS),  Volume 1 (USEPA,  1989a)  and Guidance for Data usability in Risk Assessment,
Interim Final (USEPA,  1990).

      1 Based on chemical concentrations in leachate seep water samples LI-EL, Ll-WL, L2-EL,
        L2-WL,  L3-EL,  L3-WL.

      2 Constituent is listed if it was detected at a frequency of at least once in the
        environmental media.  Only constituents qualified with an A,  J, K, or L are considered
        detected.

      3 Frequency of Detection is the number of times a constituent is detected over the number
        of times a constituent was analyzed in each media.  Data qualiftd with an N, B, JN or R
        are not counted in the determination of frequency of detection.

      4 ND =  Not detected.

      5 Mean is the Arithmetic Mean where:
          Field duplicate and primary sample results are averaqed for a qiven sample value
          The hiqhest value of either the primary or reanalysis is used for a qiven sample
          One-half the SQL or CRDL is used as the result for data containinq  'U' in its
          qualifier One-half the reported value is used for data qualified as K or L
          The full reported value is used for data qualified as A or J

-------
                                            TABLE 4.

             SUMMARY OF DETECTED CHEMICALS IN BACKGROUND SURFACE SOIL SAMPLES 1
                                         BERKS LANDFILL
                                   BERKS COUNTY, PENNSYLVANIA

                                                   Range Of
                                 Frequency         Detected        Arithmetic
          Constituents              Of         Concentrations 4      Mean 5
           Detected 2           Detection 3          (mg/1)            (mg/1)

       Badum                             2/2         0.0224 - 0.0235           0.023
       Calcium                      3/3            29.2-35.9                   32.4
       Copper                       1/3           ND - 0.0042                  0.01
       Iron                              2/2          0.203 - 0.461       0.332
       Magnesium                         3/3            11-12.6         11.7
       Manganese                         2/2         0.0235 - 0.0673           0.045
       Potassium                         2/3               ND - 1.8         1.94
       Selenium                     1/3           ND - 0.0032        0.003
       Sodium                       3/3           6.21 - 7.53                  3.46

 Notes:
     The determination of frequency of detections and the calculation of mean concentrations are
     performed in accordance with the procedures outlined in Risk Assessment Guidance For
    Superfund (RAGS), Volume 1  (USEPA, 1989a) and Guidance for Data Usability In Risk
Assessment, Interim Final (USEPA, 1900).

     1 Based on chemical concentrations in surface water samples SW-1, SW-3, and SW-4.

     2 Constituent is listed if it was detected at a frequency of at least once in the
     environmental media.  Only constituents qualified with an A, J, K, or L are considered
     detected.

     3 Frequency of Detection is the number of times a constituent is detected over the number
       of times a constituent was analyzed in each media subgroup.   Data qualified with an N, B,
       JN or R we not counted in the determination of frequency of detection.

     4 ND = Not detected.

     5 Mean is the Arithmetic Mean where:
        Field duplicate and primary sample results are averaged for a given sample value:
        The highest value of either the primary or reanalysis is used for a given sample
        One-half the SQL or CRDL is used as the result for data containing  'U' in its qualifier
        One-half the reported value is used for data qualified as K or L
        The full reported value is used for data qualified as A or J

-------
                                           TABLE 5.

            SUMMARY OF DETECTED CHEMICALS IN BACKGROUND SURFACE SOIL SAMPLES 1
                                        BERKS LANDFILL
                                  BERKS COUNTY, PENNSYLVANIA

                                                   Range Of
                                 Frequency         Detected        Arithmetic
          Constituents              Of         Concentrations 4      Mean 5
           Detected 2           Detection 3          (mg/1)           (mg/1)

       Aluminum                          3/3           0.156-0.238         0.2
       Barium                            7/7         0.0114 - 0.0354       0.027
       Calcium                           8/8          27.4 - 50.7          40
       Cyanide                           1/8            ND - 0.0519            0.011
       Iron                              5/5          0.222 - 0.675        0.441
       Magnesium                         8/8          11.3-15.9              13.5
       Manganese                        8/8           0.0104 - 0.276       0.104
       Potassium                         8/8          1.11 - 4.09              2.27
       Sodium                            8/8          6.68 - 19.6         7.16
       Vanadium                          3/8            ND - 0.0048         0.017

 Notes:
The determination of frequency of detections and the calculation of mean concentrations are
performed in accordance with the procedures outlined in Risk Assessment Guidance For
Superfund (RAGS), Volume 1  (USEPA, 1989a)  and Guidance for Data Usability In Risk
Assessment,  Interim Final  (USEPA, 1990).

     1 Based on chemical concentrations in surface water samples SW-6,  SW-7, SW-8, SW-9, SW-10,
       SW-11, SW-12, and SW-13.

     2 Constituent is listed if it was detected at a frequency of at least once in the
       environmental media.  Only constituents qualified with an A, J,  K, or L are considered d
       detected.

     3 Frequency of Detection is the number of times a constituent is detected over the number
       of times a constituent was analyzed in each media. Data qualified with an N, B, JN or R
       are not counted in the determination of frequency of detection.

     4 ND = Not detected.

     5 Mean is the Arithmetic Mean where:
       Field duplicate and primary sample results are averaged for a given sample value
       The highest value of either the primary or reanalysis is used for a given sample
       One-half the SQL or CRDL is used as the result for data containing 'U' in its
       qualifier One-half the reported value, is used for data qualified as K or L
       The full reported value is used for data qualified as A or J

-------
                               TABLE  6.
SUMMARY OF DETECTED CHEMICALS  IN BACKGROUND SURFACE SOIL SAMPLES 1
                            BERKS LANDFILL
                      BERKS COUNTY,  PENNSYLVANIA


Constituents
Detected 2
Benzo (a) Anthracene
Benzo (a) Pyrene
Benzo (b) Fluoranthene
Benzo (k) Fluoranthene
Chrysene
Fluoranthene
Indeno ( 1 , 2 , 3-cd) Pyrene
Phenanthrene
Pyrene
Aluminum
Arsenic
Barium
Beryllium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Nickel
Potassium
Sodium
Vanadium
Zinc

Frequency
Of
Detection 3
1/4
1/4
1/3
1/3
1/4
1/4
1/4
1/4
1/4
4/4
4/4
4/4
2/4
4/4
4/4
4/4
4/4
4/4
4/4
4/4
4/4
3/4
1/4
1/1
4/4
4/4
Range Of
Detected
Concentrations
(mg/kg)
ND
ND
ND
ND
ND -
ND
ND -
ND
ND


Arithmetic
4

- 0.17
- 0.11
- 0.061
- 0.079
0.13
- 0.26
0.088
- 0.087
- 0.19
Mean 5
(mg/kg)
0.211
0.196
0.16
0.166
0.201
0.234
0.191
0.191
0.216
10,600 - 24,200 14,300
3.2 -
56.8 -
ND -
4,330
16.5 - 23.6
18 -
18.5 -
25,000 -
8.6 -
1,760
601
ND
ND - 1,430
904
62.6 -
61.8 -
10.7
102
1.5
- 7.040

21.6
69.6
36,000
31.4
- 4,250
- 1,650
- 17.5

- 904
134
90.5
5.28
75.7
1.03
5,525
19.8
19.5
46.1
31,175
17.1
2,733
915
14.0
873
904
108
74.7

-------
 Notes:
The determination of frequency or detections and the calculation of mean concentrations are
performed in accordance with the procedures outlined in Risk Assessment Guidance For Superfund
(RAGS) ,  Volume 1 (USEPA, 1989a)  and Guidance for Data Usability in Risk Assessment, Interim
Final (USEPA, 1990) .

     1 Based on chemical concentrations in sediment samples SED-1, SED-2, SED-3, and SED-4.

     2 Constituent is listed if it was detected at a frequency of at least once in the
     environmental media. Only constituents qualified with an A, J, K,  or L are considered
     detected.

     3 Frequency of Detection is the number of times a constituent a detected over the number of
       times a constituent was analyzed in each media.  Data qualified with an N, B, JN or R are
       not counted in the determination of frequency of detection.

     4 ND = Not detected.

     5 Mean is the Arithmetic Mean where:
         Field duplicate and primary sample results are averaqed for a qiven sample value
         The hiqhest value of either the primary or reanalysis is used for a qiven sample
         One-half the SQL or CRDL is used as the result for data containinq 'U' in its qualifier
         One-half the reported value is used for data qualified as K or L
         The full reported value is used for data qualified as A or J

-------
                              TABLE 7.

SUMMARY OF DETECTED CHEMICALS IN BACKGROUND SURFACE SOIL SAMPLES 1
                            BERKS LANDFILL
                      BERKS COUNTY, PENNSYLVANIA

Constituents
Detected 2
Benzo (a) Anthracene
Benzo (b) Fluoranthene
Chrysene
Fluoranthene
Phenanthrene
Pyrene
Aluminum
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Vanadium
Zinc
Frequency
Of
Detection 3
4/10
1/5
4/10
6/10
3/10
5/10
10/10
10/10
10/10
5/10
3/10
10/10
10/10
10/10
10/10
10/10
10/10
10/10
10/10
2/9
10/10
5/10
10/10
10/10
                                       Range Of
                                       Detected
                                   Concentrations 4
                                       (mg/kg)

                                             ND - 0.1
                                             ND - 0.067
                                      ND - 0.089
                                             ND - 0.18
                                             ND - 0.13
                                             ND - 0.11
                                   7,200 - 17,300
                                    1.55 - 4.4
                                        42.3 - 115
                                      ND - 1.3
                                      ND - 4.7
                                   3,350 - 12,400
                                         9.1 - 35
                                        11.2 - 30.7
                                        15.4 - 67.9
                                      16,500 - 36,300
                                         5.9 - 19.7
                                           ,020 - 6,920
                                            758 - 1,309
                                      ND - 0.24
                                        11.3 - 34.5
                                             ND - 1,250
                                        41.9 - 138
                                        50.4 - 110
Arithmetic
  Mean 5
  (mg/kg) TABLE 4.

          0.173
          0.204
             0.172
          0.162
          0.194
          0.162
   11,061
             2.64
      73.3
             0.91
             1.82
             6,505
        20
        16.6
        38.9
             27,290
        9.72
           4,299
           931.2
              0.1
        16.6
           778
        87.2
        72.6

-------
 Notes:
The determination of frequency of detections and the calculation of mean concentrations are
performed in accordance with the procedures outlined in Risk Assessment Guidance For Superfund
(RAGS) ,  Volume 1 (USEPA, 1989a)  and Guidance for Data Usability In Risk Assessment, Interim
Final (USEPA, 1990) .

     1 Based on chemical concentrations in sediment samples SED-5, SED-6, SED-7, SED-8, SED-9,
     SED-10, and SED-11.

     2 Constituent is listed if it was detected at a frequency of at least once in the
     environmental media. Only constituents qualified with an A, J, K, or L are considered
     detected.

     3 Frequency of Detection is the number of times a constituent is detected over the number
       of times a constituent was analyzed in each  media.  Data qualified with an N, B, JN or R
       are not counted in the determination of frequency of detection.

     4 ND = Not detected.

     5 Mean is the Arithmetic Mean where:
         Field duplicate and primary sample results are averaqed for a qiven sample value
         The hiqhest value of either the primary or reanalysis is used for a qiven sample
         One-half the SQL or CRDL is used as the result for data containinq 'U' in its qualifier
         One-half the reported value is used for data qualified as K or L
         The full reported value is used for data qualified as A or J

-------
                               TABLE  8.
SUMMARY OF DETECTED CHEMICALS  IN BACKGROUND  SURFACE SOIL SAMPLES 1
                            BERKS LANDFILL
                      BERKS COUNTY,  PENNSYLVANIA
Range Of
Frequency Detected Arithmetic
Constituents
Detected 2
1, 1 -Dichloroethane
1, 1 -Dichloroethene
2-Butanone
4-Methyl-2-Pentanone
Acetone
Benzene
Chlorobenzene
Ethylbenzene
Tetrachloroethene
Toluene
Total 1, 2-Dichloroethene
Total Xylenes
Trichloroethene
Vinyl Chloride
1, 2-Dichlorobenzene
1, 4-Dichlorobenzene
2 , 4-Dimethylphenol
2 -Methylphenol
4 -Methylphenol
Diethylphthalate
Isophorone
Naphthalene
Phenol
Barium
Calcium
Chromium
Cobalt
Iron
Magnesium
Manganese
Nickel
Potassium
Sodium
Of Concentrations 4
Detection 3
1/2
1/2
1/2
1/2
1/1
2/2
2/2
2/2
2/2
2/2
2/2 0.045
2/2
2/2
2/2
1/2
2/2
1/2
2/2
2/2
1/1
1/2
1/2
1/2 ND
2/2
2/2
1/2
1/1 .0118
2/2 9.61
2/2
2/2
1/1 0.0311
2/2
2/2
(mg/1)
ND - 0.004
ND - 0.012
0.16 - 0.19
ND - 0.028
0.1 - 0.1
0.014 - 0.021
0.003 - 0.01
0.054 - 0.079
0.003 - 0.0085
0.24 - 0.37
- 0.075
0.15 - 0.24
0.006 - 0.0165
0.007 - 0.011
ND - 0.003
0.003 - 0.0075
ND - 0.001
0.002 - 0.002
0.001 - 0.17
0.001 - 0.001
ND - 0.0015
ND - 0.003
- 0.03
0.384 - 0.623
124 - 173
ND - 0.0138
- 0.0118
- 35.4
63.2 - 86.5
4.45 - 5.83
- 0.0311
28.3 - 38.5
201 - 275
Mean 5
(mg/1)
0.008
0.011
0.175
0.02
0.1
0.018
0.007
0.067
0.006
0.305
0.06
0.195
0.011
0.009
0.004
0.006
0.003
0.002
0.091
0.001
0.006
0.004
0.018
0.503
149
0.009
0.012
22.5
74.9
5.14
0.031
33.4
238

-------
 Notes:
The determination of frequency of detections are the calculation of mean concentrations are
performed in accordance with the procedures outlined in Risk Assessment Guidance For Superfund
(RAGS) ,  Volume 1 (USEPA, 1989a)  and Guidance for Data Usability In Risk Assessment, Interim
Final (USEPA, 1990) .

     1 Based on chemical concentrations in lagoon water samples L1-MH1 and L2-MH1.

     2 Constituent is listed if it was detected at a frequency of at least once in the
     environmental media.  Only constituents qualified with an A, J, K, or L are considered
     detected.

     3 Frequency of Detection is the number of times a constituent is detected over the number
       of times a constituent was analyzed in each media subgroup.  Data qualified with an N, B,
       JN or R are not counted in the determination of frequency of detection.

     4 ND = Not detected.

     5 Mean is the Arithmetic Mean where:
         Field duplicate and primary sample results are averaged for a given sample value
         The highest value of either the primary or reanalysis is used for a given sample
         One-half the SQL or CRDL is used as the result for data containing 'U' in its qualifier
         One-half the reported value is used for data qualified as K or L
         The full reported value is used for data qualified as A or J

-------
                        TABLE 9.

SUMMARY OF DETECTED CHEMICALS IN BACKGROUND SURFACE SOIL SAMPLES 1
                            BERKS LANDFILL
                      BERKS COUNTY, PENNSYLVANIA

Constituents
Detected 2
1, 2-Dichloroethane
Bromome thane
Chi or ome thane
Aluminum
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Cyanide
Iron
Lead
Magnesium
Manganese
Nickel
Potassium
Sodium
Vanadium
Zinc
Frequency
Of
Detection 3
1/19
1/19
1/19
7/8
5/10
7/9
3/10
2/10
10/10
4/10
6/10
8/9
1/3
7/8
7/9
10/10
7/10
2/9
8/10
10/10
9/10
7/8
                                       Range Of
                                       Detected
                                    Concentrations
                                       (mg/l)4

                                          ND - 0.0005
                                          ND - 0.014
                                          ND - 0.02
                                          ND - 58.3
                                      ND - 0.008
                                      ND - 0.173
                                      ND - 0.006
                                      ND - 0.013
                                    20.2 - 62.7
                                          ND - 0.098
                                      ND - 0.028
                                      ND - 0.272
                                      ND - 0.045
                                          ND - 66.4
                                          ND - 0.017
                                        4.29 - 22.6
                                          ND - 1.24
                                      ND - 0.076
                                          ND - 4.09
                                    5.41 - 12.3
                                          ND - 0.156
                                             ND - 0.136
Arithmetic
   Mean
  (mg/l)5

        0.00216
        0.003
        0.003
            25.783
   0.006
   0.091
             0.003
             0.004
            37.65
        0.025
             0.024
             0.094
             0.018
      32.114
        0.007
      12.599
        0.499
             0.025
        1.99
             7.914
        0.07
          0.073

-------
Notes:
    The determination of frequency of detections and the calculation of mean concentrations are
performed in accordance with the procedures outlined in Risk Assessment Guidance For Superfund
(RAGS) ,  Volume 1 (USEPA, 1989a) and Guidance for Data Usability In Risk Assessment, Interim
Final (USEPA, 1990).

     1 Based on chemical concentrations in Monitoring Wells G-2, G-3, G-7, G-8, and G-10;
       Residential Wells CASS, REIFSNYDER, and HEINZ.

     2 Constituent is listed if it was detected at a frequency of at least once in the
     environmental media. Only constituents qualified with an A, J, K, or L are considered
     detected.

     3 Frequency of Detection is the number of times a constituent is detected over the number
       of times a constituent was analyzed in each media.  Data qualified with an N, B, JN or R
       are not counted in the determination of frequency of detection.

     4 ND = Not detected.

     5 Mean is the Arithmetic mean where:
         Field duplicate and primary sample results are averaged for a sample value
         The highest value of either the primary of reanalysis is used for a given sample
         One-half the SQL or CRDL is used as the result for data containing 'U' in its qualifier
         One-half the reported value is used for data qualified as K or L
         The full reported value is used for data qualified as A or J

-------
                                   TABLE 10.

        SUMMARY  OF  DETECTED CHEMICALS IN ONSITE GROUNDWATER SAMPLES
                                BERKS LANDFILL
                          BERKS COUNTY, PENNSYLVANIA
    Constituents
      Detected  1
1,1,1-Trichloroethane
1,1,2-Trichloroethane
1,1-Dichloroethane
1,1-Dichloroethene
1,2-Dichloroethane
1,2-Dichloropropane
2-Butanone
Acetone
Benzene
Carbon Disulfide
Chlorobenzene
Chloroethane
Chioromethane
Ethylbenzene
Tetrachloroethene
Total 1,2-Dichloroethene
Total Xylenes
Trichloroethene
VInyl Chiori de
cis-1,2-Dichloroethene
1,2-Dichlorobenzene
1,3-Dichlorobenzene
1,4-Dichlorobenzene
2,4-Dimethylphenol
3-Nitroanline
4-Methylphenol
4-Nitroaniline
Butylbenzylphthalate
Di-n-Octyl Phthalate
Di-n-butylphthalate
Diethylphthalate
Hexachloroethane
Isophorone
N-Nitroso-di-n-propylamine
Naphthalene
bis(2-Ethylhexyl)Phthalate
Frequency
Of
Detection 2
1/43
1/43
17/43
2/43
3/43
2/43
2/38
3/37
10/43
1/43
14/43
6/42
1/43
2/43
1/43
14/38
2/43
11/43
11/43
6/7
2/41
1/41
13/39
1/38
1/37
1/38
1/37
3/37
1/37
1/24
1/24
2/37
2/37
1/37
4/39
4/12
Range Of
Detected
Concentrations 3
(mg/1 )
ND -
ND -
ND -
ND -
ND -
ND -
ND -
ND -
ND -
ND -
ND -
ND -
ND -
ND -
ND -
ND -
ND -
ND -
ND -
ND -
ND -
ND -
ND -
ND -
ND -
ND -
ND -
ND -
ND -
ND -
ND -
ND -
ND -
ND -
ND -
ND -
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
3.
0.
3.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
.006
.001
.009
.014
.002
.002
.039
.019
.013
.003
.022
.027
.006
.023
.001
.7
.11
.1
. 37
.007
.002
.009
.010
.004
.001
.001
.007
.002
.004
.001
.022
.006
.002
.001
.005
.095
Arithmeti
Mean 4
(mg/1)
0.
0 .
0.
0.
0.
0.
0 .
0 .
0 .
0 .
0 .
0 .
0.
0 .
0.
0.
0.
0.
0.
0 .
0 .
0 .
0 .
0 .
0.
0 .
0 .
0.
0.
0.
0.
0 .
0 .
0 .
0 .
0 .
.010
.009
.010
.010
.010
.010
.012
.011
.010
.010
.011
.010
.010
.011
.009
.208
.015
.140
.021
.002
.004
.005
.005
.005
.012
.005
.012
.005
.005
.005
.006
.005
.005
.005
.005
.005

-------
                                           TABLE 10.

            SUMMARY OF DETECTED  CHEMICALS IN ONSITE GROUNDWATER SAMPLES
                                    BERKS LANDFILL
                              BERKS  COUNTY,  PENNSYLVANIA


                                                               Range Of
                                      Frequency                Detected                Arithmetic
        Constituents                     Of                 Concentrations  3             Mean 4
          Detected 1                  Detection 2                 (mg/1)                  (mg/1)
           Aluminum                     17/17                 0.618 -  147                 20.121
           Arsenic                      19/38                  ND - 0.028                 0.007
           Barium                       36/37                   ND - 1.37                 0.220
           Beryllium                     7/38                  ND - 0.006                 0.002
           Cadmium                       6/29                  ND - 0.014                 0.003
           Calcium                      39/39                 13.4 - 476.5               164.699
           Chromium                     10/39                  ND - 0.085                 0.012
           Cobalt                       15/39                  ND - 0.034                 0.022
           Copper                       27/34                  ND - 0.248                 0.033
           Iron                         34/34                 0.126 -  119                 14.837
           Lead                         18/35                  ND - 0.233                 0.013
           Magnesium                    39/39                  4.97 -  153                 49.941
           Manganese                    38/38                 0.016 -  27.6                3.302
           Mercury                       1/35                 ND - 0.00025                0.0001
           Nickel                       13/37                  ND - 0.104                 0.025
           Potassium                    33/39                   ND - 32.6                 6.207
           Selenium                      1/11                  ND - 0.004                 0.003
           Silver                        1/35                  ND - 0.003                 0.005
           Sodium                       39/39                  3.45 -  429                47.591
           Vanadium                     14/39                  ND - 0.111                 0.026
           Zinc                         23/23                0.016 - 0.919                0.133
    Notes:
     The determination of  frequency of detections and the calculation of mean  concentrations are performed in
accordance with the procedures outlined in Risk Assessment Guidance For Superfund (RAGS),  Volume 1  (USEPA,
1989s)  and Guidance for  Data  Usability in Risk Assessment, Interim Final  (USEPA,  1990).

    1 Based on chemical  concentrations in Monitoring Wells C-l, C-2,  C-3,  C-4,  C-5,  C-6,  C-7, G-l, G,5, G-6,
G-ll, G-12,        G-13, GR-18,  GR-19, MD-2, MP-3, MP-6, MP-11, M-15, M-16,  M-17,   MP-18,  and MP-19;
Residential Wells NEIN,  and         Auction House.
    3 Frequency of Detection  is  the number of times a constituent is detected over the number of times a
             constituent was  analyzed in each media.  Data qualified with  an  N,  B,  JN or R are not counted in
the                  determination of frequency of detection.
    5 Mean is the Arithmetic  Mean  where:
        Field duplicate  and primary sample results are averaged for a  given  sample value
        The highest value  of  either the primary or reanalysis is used  for  a  given sample
        One-half the  SQL or CRDL is used as the result for date containing 'U1  in its qualifier
        One-half the  reported value is used for date qualified as K or L
        The full reported  value is used for data qualified as A or J

-------
                                            TABLE 11.

     SUMMARY OF DETECTED  CHEMICALS IN OFFSITE RESIDENTIAL GROUNDWATER  SAMPLES  1
                                    BERKS LANDFILL
                              BERKS COUNTY,  PENNSYLVANIA
        Constituents
          Detected 2
   1,1,2-Trichloroethane
   1,2-Dichloroethane
   Chloroform
   Toluene
   Arsenic
   Barium
   Calcium
   Copper
   Magnesium
   Nickel
   Potassium
   Sodium
   Zinc
   Range Of
   Detected
Concentrations 4
     (mg/1)
   ND - 0.0006
    ND - 0.002
   ND - 0.0006
   ND - 0.0009
    ND - 0.006
 0.0233 - 0.028
   51.7 - 70.7
   ND - 0.0311
  0.857 - 2.47
   ND - 0.0418
    ND - 0.466
   27.9 - 37.9
   0.01 - 0.01
Arithmetic
  Mean 5
  (mg/1)
   0.001
   0.001
   0.001
   0.001
   0.005
   0.026
    64.2
  0.0218
    1.92
   0.027
    1.82
    28.9
    0.01
Notes:
     The determination  of  frequency of detections and the calculation  of mean  concentrations are performed in
accordance with the procedures  outlined in Risk Assessment Guidance  For Superfund (RAGS),  Volume 1  (USEPA,
1989a) and Guidance for Data  Usability in Risk Assessment, Interim Final  (USEPA,  1990).
    3 Frequency of Detection  is  the number of times a constituent is  detected over the number of times a
             constituent was  analyzed in each media.  Data qualified  with  an  N,  B,  JN or R are not counted in
the                  determination of frequency of detection.

    4 ND = Not detected.
    5 Mean is the Arithmetic  Mean where:
        Field duplicate  and primary sample results are averaged  for a  given  sample value
        The highest value  of  either the primary or reanalysis is used  for  a  given sample
        One-half the  SQL or CRDL  is used as the result for date  containing 'U1  in its qualifier
        One-half the  reported value is used for date qualified as K or L
        The full reported  value is used for data qualified as A  or J

-------
                         Table 12.





  Summary of Cumulative Risks Posed by Exposure Route





                                 Cancer Risk                Hazard Index





Background                        3 x 10 -4                     6.00





Off-Site Residential              2 x 10 -4                      <1





On Site Trespasser                1 X 10 -6                      <1





On Site Worker                    6 x 10 -7                      <1





Future On-Site Residential        1 x 10 -3                    15.00

-------
                                      Table 13.

                                     Summary of
                         Remedial Alternative Cost Estimates
                                   Berks Landfill
Alternative
No
1
2
3
4(4)


5(4)


7(4)


Capital
Cost (1)
$
$
$
$

$
$

$
$

$
-
765,
1,018
2,001
to
5,336
2,147
to
5,511
3,300
to
6,664

900
,650
,790

,440
,340

,990
,090

,740
Annual Operations and
Maintenance Cost (2)
$
$
$
$ 159,000
to
$
$
to
$
$
to
$
-
74,100
142,200


224,000
181,200

246,200
447,980

512,980
Present***
Worth (3)
$
$
$
$
to
$
$
to
$
$

$

-
2,102
3,584
6,042

8,234
6,589

8,781
12,554
to
14,746,


,664
,300
,762

,800
,160

,198
,261

299
(1)  The Capital Cost includes a 20% Design/Administrative Cost and a 30% Construction
Contingency.
(2)  The Annual Operations and Maintenance (O&M)  Costs include a 30% Contingency.
(3)  The Present Worth is based upon a 3% rate of inflation and a 6% discount rate, for a 30 year
    O&M period.
(4)  Because these alternatives contain cap repairs, the costs vary in accordance with the
individual cap repair alternative.  Therefore, the costs in this table are expressed as a range
that includes the cap repairs with the least and highest cost as defined in Attachment C.  The
range in costs between cap repair alternatives are capital $1,128,702 to $4,314,840; annual O&M
$39,000 to $104,000; and present worth $3,004,862 to $5,018,400.

                                            Golder Associates

-------
        Table 14.

Alternative Cost Summary
Cap Repair Alternatives
     Berks Landfill
   ESTIMATED COST OF
 REMEDIAL ALTERNATIVE
ESTIMATED COST OF CAP
  REPAIR COMPONENT
  TOTAL ESTIMATED COST
FOR REMEDIAL ALTERNATIVE
ALTERNATIVE
NUMBER
4A
4B
4C
4D
LESS
Capital
O&M
$873,100
$873,100
$873,100
$873,100
CAP REPAIR COMPONENT
Annual
Present Worth
$120,000
$120,000
$120,000
$120,000
Total
$3,037,900
$3,037,900
$3,037,900
$3,037,900
Capital
O&M
$1,128, 690
$1, 639,920
$3,504,660
$4,493,340
Annual
Present Worth
$104,000
$78,000
$52,000
$39,000
Total
$3,004,862
$3,047,040
$4,442,740
$5,196,900

$2,
$2,
$4,
$5,
Capital
O&M
001,790
513,020
377,760
366,440
Annual
Present Worth
$224
$198
$172
$159
,000
,000
,000
,000
Total
$6,042,762
$6,084,940
$7,480,560
$8,234,800

-------
Appendix C

Toxicological Profiles

Vinyl Chloride is a gas used to manufacture polyvinyl chloride (PVC) which is contained in
many plastic and vinyl products. It is recognized by the EPA as a class A carcinogen. Chronic
exposure to vinyl chloride has been shown to cause angiosarcoma of the liver, a form of cancer.
Increased risk of cancer of the brain, lungs, other organs as well as possible miscarriages have
also been associated with inhalation of vinyl chloride. In humans, acute inhalation exposure to
0.8 to 2.0% vinyl chloride has been associated with central nervous system depression
resembling mild alcohol intoxication.

Arsenic is a naturally occurring metal that is present in the environment as a constituent
of many organic and inorganic compounds. Arsenic is a known human carcinogen implicated in skin
cancer in humans. Inhalation of arsenic by workers is known to cause lung cancer. Arsenic
compounds cause chromosome damage in animals, and humans exposed to arsenic compounds
have an increased incidence of chromosomal aberrations. Arsenic compounds are reported to be
teratogenic, fetoxic, and embryotoxic in some animal species. Dermatitis and associated lesions
are attributable to arsenic coming into contact with the skin, with acute dermatitis being more
common than chronic. Chronic industrial exposures may be characterized by hyperkeratosis, and
an accompanying hyperhidrosis (excessive sweating usually of the palms and soles of the feet).

Manganese is a steel-gray, hard, brittle metal that is naturally-occurring in the earth's
crust. Manganese is used in the iron and steel industry, and in the manufacture of dry cell
batteries, paints, dyes, matches and fireworks. Although manganese has a relatively low order
of toxicity, chronic exposure can cause degenerative changes in the central nervous system.
Symptoms of manganese toxicity include apathy, anorexia, headache, weakness of the legs,
irritability, mental confusion, and aggressiveness. As manganese exposure continues, the
symptoms of toxicity become indistinguishable from classical Parkinson's disease.

Beryllium is a grey, light weight, naturally occurring metal that possesses a high tensile
strength. Because of its physical properties beryllium is used extensively in manufacturing
electrical components, chemicals, ceramics, and x-ray tubes. Soluble beryllium salts as may be
found in ground water are primary irritants; that is, these compounds can cause contact
dermatitis to areas of exposed skin. Beryllium exposure may also cause inflammation of the
conjunctiva of the eyes. Additionally, chronic exposure to beryllium via the inhalation route,
which occurs also exclusively in an occupational setting, has been associated with respiratory
distress, weakness, fatigue, joint pain, weight loss, and liver dysfunction. Because there is
evidence that exposure to beryllium may cause cancer in some strains of laboratory animals, this
metal has been classified by the US EPA as a Group B - Probable Human Carcinogen. It is
important to note, however, that there is no conclusive evidence that exposure to beryllium has
ever caused cancer in humans.

-------
APPENDIX D

RESPONSIVENESS SUMMARY
FOR THE
PROPOSED REMEDIAL ACTION PLAN
AT THE
BERKS LANDFILL SUPERFUND SITE
SPRING TOWNSHIP, BERKS COUNTY, PENNSYLVANIA

Public Comment Period
April 25, 1997, through May 26, 1997
Berks Landfill Superfund Site

Responsiveness Summary
for the
Proposed Remedial Action Plan

TABLE OF CONTENTS
Overview 1
Background 2

Part I: Summary of Commentors' Major Issues and Concerns
A. Sampling 4
B. Leachate 6
C. Land Use Issues 7
D. Landfill Capping 7
E. The Cleanup 9
F. The PRPs and Their Role 10
G. Site Contamination 11
H. Surface and Ground Water 12
I. The Site 12
J. The Soil 13

Part II: Comprehensive, Technical, and Legal Response to Comments
A. Comments of the Pennsylvania Department of Environment Protection 14
B. Comments of Ms. Vivian Faust on behalf of the Concerned Citizens of Western
Berks County 20
C. Comments of Resident 24
D. Comments of Golder Associates, Inc. on behalf of the members of the Berks
Landfill PRP Group 25
E. Comments of Kittredge, Donley, Elson, Fullem & Embrick, LLP on behalf of the
group of defendants in litigation initiated by the members of the Berks
Landfill PRPGroup 26

-------
Overview:
                             Responsiveness Summary
                         Berks Landfill Superfund Site
                 Spring Township,  Berks County,  Pennsylvania

This Responsiveness Summary is divided into the following sections:

   This section discusses the U.S. Environmental Protection Agency's (US EPA)
   preferred alternative for remedial action.
Background:  This section provides a brief history of community interest and concerns raised
             during remedial planning at the Berks Landfill Site.

Part I:      This section provides a summary of commentors'  major issues and concerns, and
             US EPA's responses to those issues and concerns.  "Commentors" may includelocal
             homeowners, businesses, the municipality, and potentially responsible parties
             (PRPs).

Part II:     This section provides a comprehensive response to all significant comments and is
             comprised primarily of the specific legal and technical guestions raised during the
             public comment period.  If necessary, this section will provide technical detail to
             answers from Part I.

          Any points of conflict or ambiguity between information provided in Parts I and II of
          this Responsiveness Summary will be resolved in favor of the detailed technical and
          legal presentation contained in Part II.

Overview

          On April 25, 1997, US EPA announced the opening of the public comment period and
published the Proposed Remedial Action Plan  (Proposed Plan)  for the Berks Landfill Superfand
Site (the Site),  located in Spring Township, Berks County, Pennsylvania.  The Proposed Plan
details US EPA's preferred clean-up alternative for the Berks Landfill Site.  US EPA screened
several possible alternatives to clean-up the Site contamination, giving consideration to the
following nine evaluation criteria:

Threshold Criteria
6      Overall protection of human health and the environment
6      Compliance with Federal, state,  and local environmental statutes

Balancing Criteria
6      Long-term effectiveness and permanence
6      Reduction of mobility, toxicity, or volume of contaminants
6      Short-term effectiveness
6      Ability to implement
6      Cost

Modifying Criteria
6      State acceptance
6      Community acceptance
       US EPA carefully considered state and community acceptance of the clean-up alternative
before reaching the final decision regarding the clean-up plan.  The Record of Decision (ROD)
details US EPA's final clean-up decision.

-------
US EPA's preferred clean-up alternative is outlined below. Based on current
information, this alternative provides the best balance among the alternatives with respect to
the nine evaluation criteria US EPA used to evaluate each alternative. The selected
alternative, Alternative 4: Institutional Controls, Monitoring, Leachate Management System
Operation, and Landfill Cap Repair Alternative 4B, consists of the following components:

1.) Institutional Controls, including title restrictions, restrictive covenants, etc. to
prevent future consumption of on-site ground water, restrict future development at
the Site and limit future earth moving activities at the Site;

2.) Long-term Monitoring, including installation of a sentinel monitoring well
cluster, sampling of residential wells, on-site monitoring wells, aguatic habitat and
combustible gases;

3.) Leachate Management System Operation & Maintenance, and,

4.) Cap Repair and Maintenance, to include, a minimum one foot in final cover thickness
on the eastern landfill and non forested portions of the western landfill. The
eastern landfill and non-forested portions of Western Landfill will be maintained as
wildflower/grass meadow (mowed once per year). Forested portions of western landfill
will remain and be maintained.

Background

Community interest and concern about the Berks Landfill Site has been steady throughout US
EPA's involvement. US EPA held a public availability session on January 29, 1990 at the
Wilson Southern Jr. High School to introduce US EPA staff, review the Superfund process and
update the community on upcoming Site activities. US EPA issued a Fact Sheet in August 1990
discussing the Superfund process and removal actions planned by US EPA to address conditions at
the Site which US EPA felt posed an immediate risk to human health while Site-wide long-term
remedial actions were contemplated.

In January 1991 US EPA issued a Fact Sheet discussing the removal actions taken at the Site and
upcoming remedial actions to be taken to identify the nature and extent of contaminants at the
Site.

On August 28, 1991 US EPA completed a Community Relations Plan for the Site. The Plan
highlighted issues, concerns and interests of the community located near the Site which were
raised during community interviews.

In July, 1992 US EPA issued a Fact Sheet announcing the approval of the Remedial
Investigation/Feasibility Study Work Plan. The July 1992 Fact Sheet briefly outlined the work
to be performed during the RI/FS and gave a general time line for completion of the work. The
July 1992 Fact Sheet also announced a public meeting which was held on July 27, 1992 at the
Southern Junior High School. Questions regarding the RI/FS work plan and a draft Community
Relations Plan were discussed at the meeting.

In July 1996 US EPA issued a Fact Sheet to keep the community informed of Site related
activities. The Fact Sheet briefly explained the findings of the RI, the Superfund Process, and
the nature and extent of Site contamination.

Pursuant to the Comprehensive Environmental Response, Compensation, and Liability Act
("CERCLA") ° 113(k)(2)(b)(i)-(v), US EPA released for public comment the final RI/FS reports
and the Proposed Remedial Action Plan setting forth US EPA' s preferred alternative for the

-------
Berks Landfill Site on April 25, 1997.  US EPA made these documents available to the public in
the Administrative Record located at the US EPA Docket Room in Region Ill's Philadelphia
office, and at the Sinking Spring Public Library, Sinking Spring, Pennsylvania.  The notice of
availability of these documents was published in the Reading Eagle and the Merchandiser on
April 25, 1997 and May 14, 1997, respectively.

A public comment period on the documents was held from April 25, 1997 to May 26, 1997.  In
May, 1997 US EPA issued a Fact Sheet announcing the availability of the Proposed Remedial
Action plan and public meeting.  The May 1997 Fact Sheet discussed US EPA's Preferred
Alternative, as well as other alternatives evaluated by US EPA and solicited comments from all
interested parties.  In addition, US EPA conducted a public meeting on May 14, 1997.  At this
meeting, US EPA representatives answered guestions about conditions at the Site and the
remedial alternatives under consideration.

Part I:  Summary of Commentors' Major Issues and Concerns

      This section provides a summary of commentors'  major issues and concerns and US EPA's
responses to those issues and concerns.  "Commentors" may include local homeowners,
businesses, the municipality, and PRPs.  The major issues and concerns about the proposed
clean-up plan for the Berks Landfill Site received during the public meeting on May 14, 1997,
and during the public comment period are grouped into the following categories:

         A.   Sampling
         B.   Leachate
         C.   Land Use Issues
         D.   Landfill Capping
         E.   The Cleanup
         F.   The PRPs and Their Role
         G.   Site Contamination
         H.   Surface and Ground Water
         I.   The Site
         J.   The Soil

A.   Sampling

1.   How often will EPA test residential wells?

EPA Response:  US EPA understands and shares citizens concerns regarding regular monitoring
of residential wells to insure that human health and the environment continues to be protected
in the future.  As a result, residential wells will be sampled guarterly for Target Compound
List ("TCL") Volatile Organic Compounds ("VOCs")  and semi-annually for Target Analyte List
("TAL") metals for the first year of sampling.  The Residential wells will be sampled no less
than semi-annually for TCL VOCs and annually for TAL metals for the second through fifth year of
sampling.  Based on the findings of the first five years of sampling, the appropriate sampling
freguency for subseguent years will be determined by US EPA in consultation with the PADEP.

2.   How many residential wells did EPA test?

EPA Response:  As part of the Remedial Investigation for the Berks Landfill Superfund Site, US
EPA reguired the testing of a total of eleven residential wells.  However, as a result of the
information collected during the Remedial Investigation three residential wells were determined
to be background wells because they were found to be hydrogeologically isolated from the Site.
Therefore, a total of eight downgradient residential wells were sampled on five different
occasions as part of the Remedial Investigation.

-------
3. Do sampling results vary from day to day?

EPA Response: There may be natural fluctuations in the levels of contaminants in wells,
although levels do not tend to fluctuate from day to day. Over time there may be minor
fluctuations resulting from seasonal conditions.

4. Will EPA accept well sampling results from a private lab?

EPA Response: Yes, US EPA will consider sampling results submitted by residents. However,
if a resident has a sample tested independently, US EPA at its discretion will typically take an
additional sample to verify the results. If the resident wishes, the sample would be split
between the resident's chosen lab and US EPA's chosen lab for analysis to ensure that the sample
was taken at the same time and from the same location. The results would then be compared.

5. Why are the wells on the western landfill not being tested? When were these wells last
sampled?

EPA Response: As part of the Remedial Investigation US EPA reguired all on-Site monitoring
wells to be tested, including the wells on the western landfill. US EPA last reguired wells on
the western landfill be sampled during the remedial investigation activities in approximately
1993. As part of the Selected Remedy set forth in the Record of Decision, on-Site monitoring
wells are reguired to be sampled annually for the first five years of sampling. Based on the
findings of the first five years of sampling, the appropriate freguency of subseguent sampling
will be determined by US EPA, in consultation with PADEP.

6. What materials were found in the wells upgradient of the Site?

EPA Response: Arsenic, manganese, and beryllium were found in upgradient background wells
as well as low concentrations of 1,2-dichloroethane, chloromethane, and bromomethane. EPA
has determined that arsenic, manganese and beryllium are the result of naturally occurring
geologic conditions on and near the Site since similar concentrations were found upgradient and
downgradient from the Site. EPA has determined that the VOCs are not Site related since the
same compounds were not found in wells sampled on and downgradient of the Site.

7. How far below the surface were ground water samples taken?

EPA Response: The depth of the ground water samples taken during the Remedial Investigation
varied depending upon the location of the well being sampled. The deepest wells sampled were
between 200 and 250 feet deep. Near the Cacoossing Creek tributary, the wells were very
shallow since the ground water was so near the surface.

8. Would it be more cost-effective to connect residents to the public water supply than to
continue testing residential wells?

EPA Response: US EPA has determined that there is no risk to human health and the
environment outside the point of compliance, which is the western, eastern and southern Site
property boundaries and Wheatfield Road to the north, due to ground water contamination.
Therefore, US EPA does not have the authority under CERCLA to take an action such as
connecting residents to the public water supply since no risk to human health and the
environment has been demonstrated. However, US EPA will reguire that sufficient monitoring
be done to insure that human health and the environment continue to be protected in the future.

B. Leachate

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1. Why has EPA not proposed to remove the leachate collection lagoons?

EPA Response: The leachate management system currently collects and discharges Site
leachate to the Spring Township publicly owned treatment works. Additionally, US EPA has
determined that the leachate collection lagoons pose no risk to human health or the environment.
Therefore, US EPA does not have the authority under CERCLA to take an action such as
removing the leachate collection lagoons. The Selected Remedy calls for the repair and
continued operation and maintenance of the leachate collection system so that the current Site
conditions will be maintained in the future.

2. Are the leachate collection lagoons in a floodplain and is that allowable?

EPA Response: The leachate collection lagoons are at least partially in a floodplain. Although
there are certain restrictions for placing lagoons in a floodplain, it is allowable. The
Selected Remedy will comply with all applicable or relevant and appropriate reguirements for the
leachate collection system.

3. Could EPA use the money allocated for the landfill caps to cover the lagoons?

EPA Response: US EPA has determined that the leachate collection lagoons pose no risk to
human health or the environment. Therefore, US EPA does not have the authority under
CERCLA to take an action such as removing the leachate collection lagoons. However, the
leachate management system currently collects and discharges Site leachate to the Spring
Township publicly owned treatment works. The Selected Remedy calls for the repair, and
continued operation and maintenance of the leachate collection system so that the current Site
conditions will be maintained in the future.

4. Is leachate flowing from the landfill into the stream?

EPA Response: US EPA has not detected any leachate flowing from the landfill into the on-Site
drainageways or into the Cacoosing Creek tributary.

5. Could there be a naturally-occurring fracture completely through the underlying rock that
would allow leachate to enter the ground water?

EPA Responses: While drilling on-Site monitoring wells, fractures were encountered in the first
several feet of the diabase mass. However, fewer and fewer fractures, were encountered the
farther the wells were advanced into the diabase due to the extreme natural density of the
diabase. Therefore, since the diabase mass is typically several hundred feet thick in the Site
area it is highly unlikely that naturally occurring fractures could exist completely through the
diabase mass.

C. Land Use Issues

1. A resident reguested information concerning the actions EPA proposes to take regarding
use of the Nein property. Will the PRPs purchase the property? If so, will the PRPs turn
the property over to the township?

EPA Response: The Selected Remedy reguires institutional controls which will be used to
identify the Site as property underlain by contaminated groundwater; to prevent the consumption
of contaminated ground water; to restrict future development at the Site; and to limit future
earth disturbing activities on the capped portions of the Site. The Nein property would be
affected by these institutional controls. It is US EPA's understanding that certain PRPs are

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investigating the purchase of the Nein property. Regardless of the final disposition of the
Nein property, the Selected Remedy must be implemented and maintained to protect human health
and the environment. US EPA will continue to routinely update interested parties as
implementation of the Selected Remedy progresses.

2. What are EPA's intentions with respect to the landfill property and those properties
adjacent to the western landfill?

D. Landfill Capping

1. A resident inguired about a possible crack in the cap covering the Stabatrol area.

EPA Response: As part of the Remedial Investigation of the Site reguired by US EPA, detailed
investigations of the existing landfill cap conditions were reguired. A study of settlement
cracks was carried out as part of the Remedial Investigation. US EPA is not aware of cracks in
the cap in the Stabatrol area. Based on the evaluation of the settlement crack survey data,
some landfill settlement is occurrmig, as would be expected. The type of settlement is typical
of conditions at clay capped landfills where invariably some differential settlement of refuse
occur's causing tension cracks in the clay to form.
2. Why is-EPA permitting the use of a one-foot thick cap while PADEP regulations state
that there must be at least a two-foot thick cap?

EPA Response: The Pennsylvania Department of Environmental Protection (PADEP) identified
25 PA Code Chapter 273 (1988), one component of which reguires a minimum of two feet of
final cover thickness, as an applicable, or relevant and appropriate reguirement for the Site.
Initially, US EPA did not consider Chapter 273 to be applicable, or relevant and appropriate as
discussed in the April 25, 1997 Proposed Remedial Action Plan. After further consideration US
EPA recognizes the Pennsylvania Municipal Waste Management Regulations, 25 PA Code
Chapter 273 (1988) to be an applicable reguirement because the closure of the landfills was not
officially approved by PADEP. However, EPA believes that a waiver of these reguirements, in
accordance with 40 C.F.R. § 300.430(e)(9), is appropriate because the cap repair alternatives
will otherwise achieve an eguivalent standard of performance in the protection of human health
or the environment. Currently, soil, sediment, leachate, and air do not pose an unacceptable
risk to - human health, or the environment as a result of the current conditions of the landfill
caps. For - example the remedial investigation determined the following:

1) Although there are variations in landfill cap thickness which will be addressed in
all the cap repair portion of the Selected Remedy, the average current cap
thicknesses of the western and eastern landfill are 24.7 and 18.7 inches,
respectively;

2) The existing landfill caps generally exhibit low permeabilities in the 10' cm/sec to
10' cm/sec range which effectively reduces infiltration and minimizes leachate
generation. In addition, modeling conducted for the Feasibility Study and reviewed
and approved by EPA, indicates that there would be no benefit in reduction of
infiltration if two feet of similar types of soils were used as final cover for the
caps, as opposed to one foot of final cover,

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3) the landfill caps exhibit in place densities of 89% to W/o of the Standard Proctor
maximum dry density indicating that compaction occurred during construction;

4) the soils used to construct the caps are of the appropriate guality and character
for landfill caps;

5) The landfill caps are, in general, well graded, covered with a good stand of
vegetation and overall do not exhibit signs of excessive erosion; and

6) surface water management systems consisting of berms, benches, riprap lined channels
and culverts have been constructed and generally are operating effectively.
All the cap repair alternatives will insure that the landfill caps will continue to be
protective of human health and the environment in the future while effectively maintaining the
natural containment of on-Site ground water. In addition, implementing the extensive grading
and final cover reguirements of the regulations found at 25 PA Code ° 273.234 may pose a greater
risk to human health or the environment because complying with such reguirements might
jeopardize the natural containment of landfill constituents and thereby create greater risks due
to the migration of contaminants to downgradient receptors.

3. How can EPA supersede PADEP's regulations for a two-foot cap?

EPA Response: See answer to D.2. above.

4. A citizen noted that EPA's regulations and guidelines for landfill capping also reguire
two feet of cap cover.

EPA Response: See answer to D.2. above

E. The Cleanup

1. How long will it take to complete the cleanup?

EPA Response: The Feasibility Study estimates that the Selected Remedy can be designed and
implemented in twelve to eighteen months.

2. What happens if site conditions change between now and when the cleanup is completed?

EPA Response: Long-term monitoring, operation and maintenance of the leachate management
system and operation and maintenance of the landfill caps shall continue for an estimated 30
years or such other time period as US EPA, in consultation with PADEP, determines to be
necessary, based on the statutory reviews of the remedial action which shall be conducted no
less often than every five years from the initiation of the remedial action in accordance with
the US EPA guidance document, Structure and Components of Five-Year Reviews (OSWER Directive
9355.7-02, May 23,1991). Five-year statutory reviews under Section 121(c) of CERCLA will
be reguired as long as hazardous substances remain on-Site and prevent unlimited use and
unrestricted access to the Site. Five-year reviews shall be conducted after the remedy is
implemented to assure that the remedy continues to protect human health and the environment.
If US EPA, in consultation with PADEP, determines that the Selected Remedy is no longer
protective of human health and the environment US EPA will take the appropriate actions to
ensure that conditions at the Site are protective. Further, US EPA retains its emergency
removalauthority which it can invoke if an emergency situation arises.

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    3.   Can EPA guarantee that the contaminants will remain under control in the future?

EPA Response:  See Response to E.2. above.

    4.   What happens if Site conditions change after EPA has completed the cleanup and left the
         area?

EPA Response:  See Response to E.2. above.

F.   The PRPs and Their Role

    1.   A resident reguested the names of the potentially responsible parties ("PRPs').

EPA Response:  A list of the PRPs was not available at the public meeting.  However, the names
of the PRPs for the Berks Landfill Superfund Site are available upon reguest.

    2.   Do the PRPs have a choice concerning whether or not they want to participate in the
         cleanup?

EPA Response:  US EPA sends each PRP a General Notice letter notifying them of their
potential liability for response actions at the Site.  US EPA then issues a Special Notice
letter to PRPs following signing of the Selected Remedy inviting the PRPs to implement the
design and construction of the Selected Remedy.  However, PRPs do not have to enter into a
consensual agreement with US EPA.  US EPA has other enforcement authority to address situations
where PRPs do not agree to implement the Selected Remedy.  Specifically,  US EPA can issue a
Unilateral Administrative Order to PRPs reguiring them to implement the design and
construction of the Selected Remedy, or US EPA can conduct the implementation of the design
and construction of the Selected Remedy using funds from the Superfund Trust Fund and then
seek reimbursement of the costs of implementing the remedy from the PRPs through litigation.

    3.   Do the PRPs have an input in the clean-up decision?

EPA Response:  As members of the public, the PRPs may comment on the Proposed Plan during
the public comment period and at the public meeting.  US EPA will take into account all
comments received during the public comment period and from the public meeting,  including those
of the PRPs.  However,  US EPA, in consultation with PADEP, makes the final decision regarding
the Selected Remedy.

    4.   A resident asked how the costs of the cleanup are distributed among the PRPs.

EPA Response:  The Superfund statute establishes that all liable parties under Superfund are
jointly and severally liable.  In other words, each liable party is egually liable and each is
liable for the entire clean up costs at the Site.  However, all the PRPs or a group of PRPs may
decide among themselves how to distribute the costs or work at the Site,  although each PRP
remains jointly and severally liable.

G.  Site Contamination

    1.  One resident asked if beryllium was naturally occurring at the Site.

EPA Response:  Yes.  US EPA has determined that the beryllium encountered in well sampling at
the Site is naturally occurring.  Similar levels of beryllium were detected in off-Site wells,
both upgradient and downgradient of the Site.

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2. How does EPA determine the difference between naturally-occurring contaminants, such
as beryllium, manganese, and arsenic, and those that are the result of the landfill?

EPA Response: When similar levels of a compound are detected in off-Site wells, both
upgradient and downgradient of a Site the compounds can be considered naturally occurring. If
the levels of these contaminants were elevated in the downgradient wells, those results could
indicate the increased levels of the compounds were the result of contamination emanating from
the Site.

3. Is it possible that someone dumped contaminants on-Site without anyone's knowledge?

EPA Response: It is likely that contaminants were dumped at the Site without the knowledge of
PADEP and US EPA during its period of operation. However, US EPA believes that the findings of
the Remedial Investigation sufficiently describe the nature and extent of contamination at the
Site to allow US EPA to select the remedy set forth in the Record of Decision.

4. What would EPA have done if contaminants that posed a risk to human health or the
environment were found in off-site residential wells?

EPA Response: If EPA had found contaminants in off-site residential wells that posed a risk to
human health or the environment, US EPA would have taken actions to protect human health and
the environment such as the installation of carbon filtration units or the provision of bottled
water, etc while alternatives for a permanent remedy were evaluated.
5. If EPA found any contaminants in off-site residential wells, did they come from the
Site?

EPA Response: EPA has not found any Site related contaminants in off-Site residential wells.

6. If EPA discovered new information at the present time about the Site contamination,
would EPA change the Proposed Plan?

EPA Response: Five-year statutory reviews under Section 121 (c) of CERCLA will be required,
as long as hazardous substances remain on-Site and prevent unlimited use and unrestricted access
to the Site. Five-year reviews shall be conducted after the remedy is implemented to assure
that the remedy continues to protect human health and the environment. If US EPA, in
consultation with PADEP, determines that the Selected Remedy is no longer protective of human
health and the environment US EPA will take the appropriate actions to ensure that conditions at
the Site are protective.

H. Surface and Ground Water

1. Are there underground rivers below the Site?

EPA Response: No. Ground water is defined as fresh water found underground that fills in gaps
between soil, sand, and gravel, and often is a major source of drinking water. Generally,
ground water does not flow in an underground river. Ground water flows small through spaces
between sand grains, or bedrock. When the bedrock fractures, water flows through these cracks.
The amount of water flowing through cracks depends upon how many cracks are present and the size
of these cracks.

2. One resident suggested that EPA had not proposed an alternative to address the water
that runs over the surface of the landfill after a rainfall.

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EPA Response: The cap repair portion of the Selected Remedy includes provisions to ensure that
the surface water management system works properly. The Selected Remedy will ensure that
surface water is directed off the landfill properly.

3. One resident informed EPA that there were deformed fish in the pond at the end of
Wheatfield and Chapel Hill Roads. The resident requested that EPA examine the fish and
determine what contaminants in the pond are causing the deformities.

EPA Response US EPA does not believe that Site-related contaminants are causing risks to surface
water or sediment off-Site as evidenced by the results of the Remedial Investigation and
Baseline Risk Assessment. However, US EPA takes this report of deformed fish seriously and
has referred the information to PADEP for further investigation.

I. The Site

1. How did EPA determine the boundaries of the Site?

EPA Response: The Berks Landfill Superfund Site consists of two closed municipal refuse
landfills and associated features located south of Wheatfield Road and the areal extent of
contamination which includes the ground water plume. The Site boundaries as shown on figures
in the Remedial Investigation reflect only the property boundaries on which the two landfills
and associated features are located.

2. One resident commented that he was disturbed that so many EPA personnel had been on
the job in just a few years, and that there had not been one constant person involved
with the Site. He also commented that he had offered information about the Site to EPA
personnel involved with the Site cleanup, but no one ever responded to his offers.

EPA Response: While there has been turn over of US EPA Remedial Project Managers since the
Site was listed on the National Priorities List, sufficient information was gathered during the
Remedial Investigation to determine the nature and extent of contamination at the Site and to
allow the US EPA to evaluate alternatives to address risks posed by the Site in the Feasibility
Study. The Selected Remedy set forth in the Record of Decision is protective of human health
and the environment and provides the best balance among the alternatives with respect to the
nine criteria US EPA uses to evaluate each alternative. US EPA encourages interested parties to
provide US EPA with any information they feel is relevant to the Berks Landfill Superfund Site.
US EPA will evaluate any information regarding the Site which is provided by concerned parties.

J. The Soil

1. One resident commented that her backyard is under water several times during the year
and had requested several times that EPA test her soil. Since the soil has never been
tested, she is afraid to put a garden there.

EPA Response: While US EPA understands citizens concerns regarding off-Site contamination
emanating from the Site, the Remedial Investigation and Baseline Risk Assessment which were
required by US EPA did not identify increased risks to human health or the environment from
contaminants in surface water Or sediment in the Cacoosing Creek tributary downgradient of the
Site. Therefore, since it is highly unlikely that Site-related contaminants arc present in the
soils adjacent to the tributary US EPA determined that it was not necessary to conduct off-Site
soil sampling.

2. One citizen questioned the results of the permeability tests on the soil and sediments
in the landfills.

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EPA Response: The landfill cap investigation portion of the Remedial Investigation reguired by
US EPA included sampling to determine the permeability of the existing landfill caps. The
sampling conducted during the Remedial Investigation was conducted under US EPA oversite.
The results of the Remedial Investigation sampling shows that the existing landfill caps
generally exhibit low permeabilities in the 10 -7 cm/sec to 10 -8 cm/sec range which effectively
reduces infiltration and minimizes leachate generation. In addition, modeling conducted for the
feasibility study and reviewed and approved by EPA indicates that there would be no benefit in
reduction of infiltration if two feet of similar types of low permeability soils were used as
final cover for the caps, as opposed to one foot of final cover.

Part II: Comprehensive, Technical, and Legal Responses to Comments

This section provides technical detail in response to comments or guestions on the
Berks Landfill Site. EPA received these comments or guestions by mail during the public comment
period. These comments or guestions may have been covered in a more general fashion in Part I
of this Responsiveness Summary. The following specific comments are addressed:

A. Comments of the Pennsylvania Department of Environmental Protection
("PADEP")
B. Comments of Ms. Vivian Faust on behalf of CCWBC
C. Comments of Resident
D. Comments of Golder Associates, Inc. on behalf of the members of the Berks
Landfill PRP Group
E. Comments of Kittredge, Donley, Elson, Fullem & Embrick, LLP on behalf of the
group of defendants in litigation initiated by the members of the Berks Landfill
PRP Group

A. Comments of PADEP

In a five-page document dated May 19,1997, PADEP submitted comments on the Berks
Landfill Site Proposed Plan.

1. PADEP received the Proposed Plan on April 28, 1997, while the public comment period
began on April 25, 1997. In addition, PADEP was not given a review period as provided
for in the National Oil and Hazardous Substances Pollution Contingency Plan (NCP),
Section 300.515(h)(3), under the Comprehensive Environmental Response,
Compensation, and Liability Act ("CERCLA").

EPA Response: Section 300.515(h)(3) of the National Oil and Hazardous Substances Pollution
Contingency Plan ("NCP") states: "The lead agency shall provide the support agency an
opportunity to review and comment on the RI/FS, proposed plan, ROD, and remedial design and
any proposed determinations on potential ARARs and TBCs. The support agency shall have a
minimum of 10 working days and a maximum of 15 working days to provide comments to the lead
agency on the RI/FS, ROD, ARAR/TBC determinations and remedial design. The support agency shall
have a minimum of five working days and a maximum of 10 working days to comment on the proposed
plan." US EPA, as the lead agency, as stated in PADEP comment No. 1 provided PADEP, the support
agency, with the Proposed Plan on April 28, 1997. The comment period on the Proposed Plan was
open until May 26, 1997. PADEP therefore was given 20 working days to comment on the Proposed
Plan. PADEP provided US EPA comments on the proposed plan in a letter dated May 19, 1997, 15
working days after receipt of the proposed plan.

2. PADEP did not receive for review a draft copy of the Final Risk Assessment Report.

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EPA Response:  US EPA believes that PADEP received a copy of the July 1, 1996 Final Risk
Assessment Report for the Berks Landfill Site prepared by Golder Associates Inc.  As can be
shown from Proof of Delivery documentation provided by Federal Express to Golder Associates,
Inc., D. Hammock and J. Straub of PADEP signed for delivery of the July 1, 1996 Final Baseline
Risk Assessment Report on July 3, 1996 at PADEPs Reading field office and 1 Ararat Blvd.
Regional office, respectively.  Subseguently on October 31, 1996, US EPA provided comments to
Golder Associates, Inc. on the July 1, 1996 Final Risk Assessment which are reflected in the
November 6, 1996 Addendum to the Final Baseline Risk Assessment submitted by Golder Associates,
Inc.  The November 6, 1996 Addendum was signed for by representatives of PADEP on November 8,
1996 at both the Reading field office and 1 Ararat Blvd. Regional office.  US EPA received no
comments from PADEP on either the July 1, 1996 Final Baseline Risk Assessment Report or November
6, 1996 Addendum.

    3.   PADEP's Municipal Waste Guidance #21 states that landfill areas not closed according
         the Chapter 75 or in accordance with an approved closure plan before April 9, 1988,
         must be closed in accordance with the new municipal waste regulations, 25 PA Code
         Chapters 271-285.  Therefore, areas of the Site which do not have two-foot soil covers,
         or where refuse is intermixed with soil cover, are not in compliance with Chapter 75.

EPA Response:  The Pennsylvania Department of Environmental Protection  (PADEP) identified 25 PA
Code Chapter 273  (1988), one component of which reguires a minimum of two feet of final cover
thickness, as an applicable, or relevant and appropriate reguirement for the Site. Initially, US
EPA did not consider Chapter 273 to be applicable, or relevant and appropriate as discussed in
the April 25, 1997 Proposed Remedial Action Plan.  After further consideration US EPA recognizes
the Pennsylvania Municipal Waste Management Regulations, 25 PA Code Chapter 273  (1988) to be an
applicable reguirement because the closure of the landfills was not officially approved by
PADEP.  However, EPA believes that a waiver of these reguirements, in accordance with 40 C.F.R.
° 300.430 (e) (9), is appropriate because the cap repair alternatives will otherwise achieve an
eguivalent standard of performance in the protection of human health or the environment.
Currently, soil, sediment, leachate, and air do not pose an unacceptable risk to human health,
or the environment as a result of the current conditions of the landfill caps.  For example the
Remedial Investigation detemiined the following:

         1) although there are variations in landfill cap thickness which will be addressed in
            the cap repair portion of the Selected Remedy, the average current cap thicknesses
            of the western and eastern landfill are 24.7 and 18.7 inches, respectively;

         2) the existing landfill caps generally exhibit low permeabilities in the 10 -7 cm/sec
            to 10 -8 cm/sec-range which effectively reduces infiltration and minimizes leachate
            generation.  In addition, modeling conducted for the Feasibility Study and reviewed
            and approved by EPA, indicates that there would be no benefit in reduction of i
            infiltration if two feet of similar types of soils were used as final cover for the
            caps, as opposed to one foot of final cover;

         3) the landfill caps exhibit in place densities of 89% to 90% of the Standard Proctor
            maximum dry density indicating compaction occurred during construction;

         4) the soils used to construct the caps are of the appropriate guality and character
            for landfill caps;

         5) the landfill caps are, in general, well graded, covered with a good stand of
            vegetation and overall do not exhibit signs of excessive erosion; and

         6) surface water management systems consisting of berms, benches, riprap lined channels

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and culverts have been constructed and generally are operating effectively.

All the cap repair alternatives will insure that the landfill caps will continue to be
protective of human health and the environment in the future while effectively maintaining the
natural containment of on-Site ground water. In addition, implementing the extensive grading
and final cover reguirements of the regulations found at 25 PA Code ° 273.234 may pose a greater
risk to human health or the environment because complying with such reguirements might
jeopardize the natural containment of landfill constituents and thereby create greater risks to
downgradient receptors.

4. Constructing a lower permeability cap on the eastern landfill would lessen the current
risk of exposure to leachate seeps on the eastern landfill.

EPA Response: The July 1, 1997 Baseline Risk Assessment for the Berks Landfill Superfund
Site did not identify increased risks to human health and the environment as a result of
leachate seeps on the eastern landfill. US EPA believes that the Selected Remedy set forth in
the Record of Decision will be protective of human health and the environment. In addition, see
answer to PADEP Comment No. 3 above.

5. PADEP's Municipal Waste Guidance #21 states that landfill areas closed before April 9,
1988, do not have to be reaffected and meet current regulations unless one or more of the
following problems are present: (a)final cover; (b)leachate seeps; (c) ground water
degradation; (d)landfill gas problems; or (e)erosion and sedimentation problems.
The Site does not meet final cover reguirements because extensive leachate seeps are
present, volatile organic compounds (VOCs) are present in the ground water in both the
shallow and deep aguifers indicating ground water degradation, strong methane odors are
present around the eastern landfill, and the Remedial Investigation Report did not
include an evaluation of the current gas venting system.

EPA Response: In response to this comment, the Selected Remedy, as set forth in the Record of
Decision, does reguire monitoring of landfill gases. In addition, see response to PADEP
Comment No. 3 above.

6. The purpose of maintaining vegetation is to prevent the natural succession of this
vegetation from disrupting the soil cover and/or the cap. The proposed clean-up
alternative does not adeguately address present or future site conditions relative to
vegetation on the landfills.

EPA Response: US EPA believes the Selected Remedy adeguately addresses maintenance of
vegetation on the forested/maturing shrub tree portion of the western landfill and the non-
forested portions of the western landfill, eastern landfill, northern disposal area and area
behind the eguipment building. See Section IX.B.4.b.l3. and Section IX.B.4.b.l4. of the Record
of Decision.

7. The Proposed Plan states that the northern slope of the landfill behind the auction
house is no more than a "thin lens of exposed refuse." In reality, it is a 20 to 25
foot vertical wall of exposed refuse that will reguire extensive leveling.

EPA Response: As set forth in Section IX.B.4.b.8. of the Record of Decision, the approximate
20 foot by 50 foot thin lense of exposed refuse shall be repaired.

8. PADEP also provided a list of applicable or relevant and appropriate reguirements
(ARARs) and reguirements to be considered (TBCs) which were not included in the
Proposed Plan.

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a.   Land Recycling and Environmental Remediation Standards Act of May 19, 1995,
     P.L.4, No. 1995-2, 35 P.S. Section 6026.101 et. seq.  (Act 2).  Chapter 3, Sections
     301, 302, and 303.  Chapter 1, Section 106 (A)  states "the remediation standards
     established under this act shall be considered as applicable, relevant and
     appropriate requirements for this Commonwealth under the Comprehensive
     Environmental, Response, Compensation, and Liability Act of 1980 (Public Law
     96-510, 94 Stat. 2767) and the Hazardous Site Cleanup Act."

b.   25 PA Code Chapter 250, Revision R (Administration of the Land Recyclinq
     Program).  The Maximum Contaminant Level and/or Health Advisory Limit for
     VOC contaminants in the shallow and deep aquifers are chemical ARARs.

c.   The Solid Waste Management Act of July 7, 1980, P.L. 380, No. 97, as amended,
     35 P.S. Sections 6018.101 et.seq.

d.   Municipal Waste Management Regulations (Article VIII, Chapters 271 - 285).
     Chapter 273,  Landfills
           Section 273.151:  Soil erosion and sedimentation control plan
           Section 273.234:  Final cover and grading, Table 1 (page 273 - 48 of
           Section 273.256)
           Sections 273.235 - 273.236:  Revegetation
           Sections 273.241 - 273.245:  Water quality protection
           Sections 273.271 - 273.277:  Leachate treatment
           Sections 273.281 - 273.288:  Water quality monitoring
           Sections 273.292 - 273.293:  Gas management
           Sections 273.321 - 273.322:  Closure

e.   Bureau of Waste Management Municipal Waste Guidance #21, "Closure of
     Municipal Waste Landfill", July 11, 1989.

f.   The Air Pollution Control Act of January 8, 1960, P.L. 2119, 35 P.S. Sections
     4001,  et.seq.

g.   Air Resources Regulations (Article III, Chapters 121 - 143)
     Chapter 131:   Ambient Air Quality Standards
     Chapter 139:   Sampling and Testing
     Section 139.11:  General requirements for stationary sources
     Section 139.14:  Emissions of VOCs

h.   Guidance Manual, "Air Quality Permitting Criteria for Remediation Project
     Involving Air Strippers and Soil Decontamination Units"

I.   "Air Quality Criteria Including Best Available Technology Criteria for Municipal
     Waste Landfills"

j.   The Clean Streams Law of June 22, 1937, P.L. 1987,  as amended, P.S. Sections
     691.1 et. seq.

k.   Water Quality Regulations, Chapters 97 and 101
     Chapter 97: Industrial Wastes
           Section 97.1:  General Provisions
           Sections 97.14 and 97.15:  Standards
           Sections 97.91 - 97.95:  Standards for discharge of industrial flows to
           POTWs

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Chapter 101: Special Water Pollution
Section 101.2: Incidents causing or threatening pollution
Section 101.3: Activities utilizing polluting substances
Section 101.4: Impoundment
Section 101.5: Algicides, herbicides, and fish control chemicals

1. "Acceptable Risk/Human Health Environmental Protective Levels for Ground
Water Protection and Remediation"

m. "Technical Guidance for NPDES Permitting Landfill Leachate Discharges"

n. "Toxics Management Strategy"

o. "Soil Erosion and Sedimentation Control Manual"

p. The Storm Water Management Act of October 4, 1978, P.L. 1840, 32 P.S.
Sections 645.1 et.seg.

g. Chapter 105: Dam Safety and Waterway Management
Section 105.17: Wetlands
Section 105.18: Activities in wetlands
Section 105.20: Wetland replacement criteria

r. The Water Well Drillers License Act of May 29, 1956, P.L. 1840, 32 P.S.
Sections 645.1 et. seg.

s. Chapter 107: Reguirements for Water Well Drillers

t. The Pennsylvania Safe Drinking Water Act of May 1, 1984, P.L. 206, 35 P.S.
Sections 721 et. seg.

u. Chapter 109: Water Supply and Community Health Regulations
Sections 109.201 - 109.203

v. Pennsylvania Department of Transportation Act of June 1, 1945 (P.L. 1242, No.
421) (36 P.S. Sections 670 - 411, 670 - 420, 670 - 421, and 670 - 702)

w. Pennsylvania Hazardous Transportation Regulations, Pa. Code Titles 13 and 15

EPA Response: US EPA evaluated all potential applicable or relevant and appropriate
reguirements identified by PADEP and believes that the Selected Remedy will comply with all
necessary applicable or relevant and appropriate reguirements and TBCs as set forth in Section
X.B. of the Record of Decision.

B. Comments of Ms. Vivian Faust on behalf of CCWBC

In a three-page letter dated May 22, 1997, Ms. Vivian Faust provided a written copy of the
statement she read during the May 14, 1997, public meeting on behalf of CCWBC.

1. How could the different Remedial Project Managers know what was happening with the
Site if no notes or minutes were taken during meetings with the PRPs?

EPA Reponse: While there has been turnover of US EPA Remedial Project Managers since the Site
was listed on the National Priorities List, US EPA performed adeguate oversight and sufficient

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information gathering during the Remedial Investigation to determine the nature and extent of
contamination at the Site and to allow the US EPA to evaluate alternatives to address risks
posed by the Site in the Feasibility Study. The Selected Remedy set forth in the Record of
Decision is protective of human health and the environment and provides the best balance among
the alternatives with respect to the nine criteria US EPA uses to evaluate each alternative.

2. EPA claimed that the stream acts as a barrier to contaminants moving offsite. If this
is correct, why did sampling results indicate vinyl chloride in the Nein well across
the stream?

EPA Response: As discussed in the Proposed Plan and the Record of Decision, the diabase rock
mass, which encompasses the Site, acts as a major hydraulic barrier that controls groundwater
flow at the Site and prevents downward migration of groundwater from the overlying units. The
diabase effectively acts as a confining unit or barrier beneath the Site and causes the shallow
phreatic and deeper semi-confined groundwater systems to merge and discharge to the Cacoosing
Creek tributary system (drainageways and tributary) at the northwestern portion of the Site and
west of the Site boundary. The Nein well is a shallow hand dug well in the shallow aguifer
immediately north of the eastern landfill on-Site which explains why vinyl chloride was detected
in the well. Because the diabase mass pinches to the surface northwest of the Site it acts as a
barrier to the migration of contaminants off-Site to the west.

3. EPA claimed that the rock layer underlying the Site would prevent contaminants from
moving off-Site. However, EPA's own tests indicated fractures in that layer. Since
EPA conducted the studies, there have been many earthguakes which CCWBC believes have
enlarged these fractures. CCWBC reguested that EPA take these fractures into account
when deciding on the clean-up alternative.

EPA Response: While drilling on-Site monitoring wells, fractures were encountered in the first
several feet of the diabase mass. However, fewer and fewer fractures were encountered the
farther the wells were advanced into the diabase due to the extreme natural density of the
diabase. Therefore, since the diabase mass is typically several hundred feet thick in the Site
area it is highly unlikely that naturally occurring fractures could exist completely through the
diabase mass. US EPA believes that it is highly unlikely that earthguakes in the Site area have
affected the hydrogeologic conditions at the Site.

4. When making a final clean-up decision, CCWBC reguested that EPA take into account
the unstabilized sludges, referred to as the Stabatrol area.

EPA Response: US EPA believes that the Remedial Investigation gathered sufficient information
to determine the nature and extent of all contamination at the Site and to allow the US EPA to
evaluate alternatives to address risks posed by the Site in a Feasibility Study. US EPA
believes that the Selected Remedy addresses all risks to human health and the environment
identified in the Baseline Risk Assessment for the Berks Landfill Site. EPA believes the
Selected Remedy is protective of human health and the environment.

5. CCWBC commented that a former PADEP hydrogeologist told the group that ground
water flows at the Site are unpredictable due to the Site's geologic and hydrogeologic
conditions. CCWBC reguested that EPA clarify why the group was told that the eastern
portion of the Site is the most contaminated if ground water flows to the west.

EPA Response: US EPA believes that site specific hydrogeologic conditions were thoroughly
delineated in the Remedial Investigation for the Berks Landfill Superfund Site. The Remedial
investigation, Proposed Plan and Record of Decision all state that the area of most highly
contaminated groundwater on-Site is directly beneath the Eastern Landfill. As discussed above,

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an intrusive diabase mass is the most important geologic feature at the Site. This diabase
mass, at the surface, encircles the Site except for possibly a small area to the southwest, and
is present beneath the Site in a bowl-like configuration. The large diabase mass acts as a low
permeability hydraulic barrier, deflecting ground water flow to the west, to its eventual
discharge point, in the north and north west portions of the Site. Shallow ground water
discharges into the tributary of the Cacoosing Creek in this area. Water guality and aguatic
organism sampling conducted in the tributary of the Cacoosing Creek and in the on-Site drainage
ways shows that ground water discharging to the Cacoosing Creek tributary is not causing an
increased risk to human health or environmental receptors. It is believed that natural
processes such as dilution, dispersion, sorption and volatilization of contaminants are
contributing to the natural treatment and reduction of contaminant concentrations in the ground
water. These natural contaminant reducing processes when combined with the unigue diabase mass
which forces ground water to discharge to the Cacoosing Creek tributary provide natural
containment of the Site-related contaminants and does not allow them to move off-Site.

6. CCVBC also reguested the following information about the cluster wells:
a. How many extra wells will be added?
b. How often will they be tested?
c. Will there be replacement wells closer to the decommissioned wells?
d. Will the stream also be tested and how often?
e. CCWBC reguested that EPA continue testing residential wells since
pollution may surface a mile from the source.

EPA Response: US EPA understands and shares citizens concerns regarding regular monitoring
of sentinel and residential wells to insure that human health and the environment continues to
be protected in the future. As set forth in the Record of Decision, the installation of
additional sentinel wells shall be reguired. The exact number and location of these sentinel
wells shall be determined by US EPA during the remedial design, in consultation with the PADEP.
The Record of Decision also reguires that a plan for a long-term ground water monitoring program
shall be included in an operation and maintenance plan for the Site. This plan shall include
the sampling of a sufficient number of sentinel wells, residential wells and existing monitoring
wells to monitor the effectiveness of the natural hydraulic containment mechanisms in
maintaining Site related contaminant levels below MCLs and MCLGs at the point of compliance and
to monitor on-Site contaminant levels over time. US EPA, in consultation with PADEP, will
determine the number and location of wells necessary to verify the performance of the remedial
action. Sentinel and residential wells will be sampled guarterly for Target Compound List
("TCL") Volatile Organic Compounds ("VOCs") and semi-annually for Target Analyte List ("TAL")
metals for the first year of sampling. The Sentinel and Residential wells will be sampled no
less than semi-annually for TCL VOCs and annually for TAL metals for the second through fifth
year of sampling. Based on the findings of the first five years of sampling, the appropriate
sampling freguency for subseguent years will be determined by US EPA, in consultation with the
PADEP. On-Site monitoring wells shall be sampled annually for TCL VOCs and TAL metals for the
first five years of sampling. Based on the findings of the first five years of sampling, the
appropriate sampling freguency for subseguent years will be determined by US EPA, in
consultation with the PADEP. At least, two rounds of surface water, sediment and benthic
macroinvertebrate sampling of the upgradient and downgradient surface water drainageways and the
tributary of the Cacoosing Creek shall be reguired. US EPA in consultation with PADEP will
determine if additional surface water, sediment and benthic macroinvertebrate sampling is
necessary based on the findings of the first two rounds of samples collected.

7. Can the open leachate collection lagoons be eliminated? If not all of them can be
eliminated, can some of the lagoons be eliminated?

EPA Response: The Baseline Risk Assessment reguired by US EPA determined that the leachate

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collection lagoons pose no risk to human health or the environment. Therefore, US EPA does not
have the authority under CERCLA to take an action such as removing the leachate collection
lagoons. However, the leachate management system currently collects and discharges Site
leachate to the Spring Township publicly owned treatment works. The Selected Remedy calls for
the repair and continued operation and maintenance of the leachate collection system so that the
current Site conditions will be maintained in the future.

8. EPA found that the soil permeability was not as expected. The leachate reaction on the
limestone can cause further problems as the limestone deteriorates.

EPA Response: The landfill cap investigation portion of the Remedial Investigation reguired by
US EPA included sampling to determine the permeability of the existing landfill caps. The
sampling conducted during the Remedial Investigation was conducted under US EPA oversite. The
results of the Remedial Investigation sampling show that the existing landfill caps generally
exhibit low permeabilities in the 10 -7 cm/sec to 10 -8 cm/sec range which effectively reduces
infiltration and minimizes leachate generation. In addition as discussed above, the leachate
management system currently collects and discharges Site leachate to the Spring Township
publicly owned treatment works. The Selected Remedy calls for the repair, and continued
operation and maintenance of the leachate collection system so that the current Site conditions
will be maintained in the future.

9. Why were replacement wells placed so far from the decommissioned wells?

EPA Response: During the Remedial Investigation it was determined that the condition of
certain existing monitoring wells were such that they were unsalvageable for future use.
Therefore, these wells were decommissioned and replacement wells were installed. The
replacement wells were located by US EPA, in consultation with PADEP, in such a way to allow
US EPA to determine the nature and extent of contamination at the Berks Landfill Site.

10. CCWBC reguested that additional cluster wells be placed around the perimeter of the
landfill in all directions due to the unpredictable ground water flows.

11. CCWBC reguested that EPA take action to eliminate the foul odors which come from the
landfill. These odors are particularly offensive during damp periods, in the early
morning, and on cloudy days.

FPA Response: US EPA believes that the Selected Remedy, specifically the cap repair portion of
the Selected Remedy set forth in the Record of Decision, will help to reduce the odors
emanating from the Site.

C. Comments of Resident

In a three-page handwritten letter dated May 23, 1997, a resident submitted comments on EPA's
proposed clean-up alternative.

1. The old landfill outside the fence on the west side contains many contaminants,
possibly more than the eastern portion on which EPA is concentrating. The western
landfill needs to have enough new soil placed over the top to allow proper surface

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water drainage. Although this resident discussed this issue with PADEP and agreed that
the soilplacement would be appropriate, the soil never was placed over the landfill.

EPA Response: The Selected Remedy as set forth in the Record of Decision requires that all
large contiguous areas of the non-forested portion of the western landfill, the eastern
landfill, the northern disposal area and the area behind the equipment building identified as
having less than one foot in final cover thickness will be increased to a minimum of one foot of
final cover material of a type similar to the existing cover material. Also, Section IX.B.4.b.7
of the Selected Remedy set forth in the Record of Decision requires that the landfills meet
certain grading requirements.

2. The west side of the western landfill has no leachate collection system. The resident
and PADEP also discussed the implementation of a leachate collection system in this
area, although the system never was implemented.

EPA Response: The Baseline Risk Assessment required by US EPA determined that leachate seeps
pose no risk to human health or the environment. Therefore, US EPA does not have the authority
under CERCLA to take an action such as expanding the existing leachate collection system.
However, the leachate management system currently collects and discharges Site leachate to the
Spring Township publicly owned treatment works. The Selected Remedy calls for the repair, and
continued operation and maintenance of the leachate collection system so that the current Site
conditions will be maintained in the future.

3. Brush and wildflowers covering the western landfill do not constitute a healthy or
proper final capping for any landfill.

EPA Response: US EPA, in consultation with the US Fish and Wildlife Service and PADEP, has
determined that the meadow seed mixture proposed in the proposed plan and required by the
Record of Decision for non-forested portion of the western landfill, eastern landfill, northern
disposal area and the area behind the equipment building is an appropriate final vegetative
cover for the landfills and that this seed mixture will provide beneficial wildlife habitat on
the landfills in the future.

4. Sediment control has been neglected. Gravel build-up has changed the flow of the
stream resulting in problems for many properties downstream. The gravel needs to be
cleaned out.

EPA Response: The Baseline Risk Assessment required by US EPA determined that sediment in the
Cacoosing Creek tributary pose no risk to human health or the environment. Therefore, US EPA
does not have the authority under CERCLA to take an action such as excavating sediment from the
tributary. However, the Selected Remedy set forth in the Record of Decision requires that soil
erosion and sedimentation be prevented to the maximum extent possible.

5. All leachate collection lagoons should be removed and the leachate collection system
should be updated. The leachate should be collected in steel or fiberglass tanks.

EPA Respose: The Baseline Risk Assessment required by US EPA determined that the leachate
collection lagoons pose no risk human health or the environment. Therefore, US EPA does not
have the authority under CERCLA to take an action such as removing the leachate collection
lagoons. However, the leachate management system currently collects and discharges Site
leachate to the Spring Township publicly owned treatment works. The Selected Remedy calls for
the repair, and continued operation and maintenance of the leachate collection system so that
the current Site conditions will be maintained in the future.

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D. Comments of Golder Associates, Inc. on behalf of the members of the Berks Landfill PRP Group

In a two-page document dated May 23, 1997, Mr. Randolph S. White of Golder Associates, on
behalf of the members of the Berks Landfill PRP Group, submitted comments on the Berks Landfill
Proposed Plan. The Berks Landfill PRP Group concurred with the conclusions EPA made in the
Proposed Plan, as well as with EPA's preferred clean-up alternative for the Site. The comment
letter also stated that the Proposed Plan appropriately recognized the unigue hydrogeologic
conditions, natural ground water containment processes, and the protectiveness of the existing
landfill cap.
1. The PRP Group reguested that EPA ensure that the ROD is sufficiently flexible to allow
consideration of alternative operation and maintenance procedures if alternative
methods are identified during the remedial design.

EPA Response: EPA believes that the Selected Remedy set forth in the Record of Decision allows
for sufficient flexibility in all long-term operation and maintenance plans reguired. US EPA,
in consultation with PADEP, will determine the final reguirements of all long term operation and
maintenance plans.

2. The PRP Group reguested that EPA ensure that the ROD is flexible enough to allow for
the following:
a. the selection of appropriate monitoring points (including the appropriate
location of the sentinel well cluster)
b. the freguency of and parameters for monitoring, and
c. annual reviews to allow adjustments in the monitoring program as the data
is collected.

EPA Response: US EPA believes that the Selected Remedy set forth in the Record of Decision
addresses each of the concerns raised. See Sections IX.B.2.b. and IX.B.4.b.

4. Continuing to monitor all the residential wells which have been sampled previously is
not necessary because some are hydrogeologically isolated from the Site or are
upgradient or far downgradient of the Site. Monitoring on-site wells (except those in
the far western; downgradient portion of the Site) is not necessary if compliance wells
also are monitored.

EPA Response: US EPA believes that the Selected Remedy set forth in the Record of Decision
addresses the concern raised. See Sections IX.B.2.b.
5. The PRP Group guestions the need for future aguatic monitoring. However, if EPA
reguires aguatic monitoring, the PRP Group suggests that the ROD be flexible enough to
allow for the development of the aguatic monitoring program during the remedial design.

EPA Response: US EPA believes that the Selected Remedy set forth in the Record of Decision
addresses the concern raised. See Sections IX.B.2.b.
E. Comments of Kittredge, Donley, Elson, Fullem & Embrick, LLP on behalf of the
group of defendants in litigation initiated by the members of the Berks Landfill PRP
Group

In a two-page letter dated May 29,1997, Kittredge, Donley, Elson, Fullem & Embrick, LLP

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commented on the Proposed Plan on behalf of the Berks Landfill PRP Group. Although EPA received
this letter after the comment period closed, EPA will respond to the issues brought forth as
follows:

1. The group of defendants believes that the information obtained during the remedial
investigation and feasibility study activities confirm that no landfill cap repairs are
necessary. Alternative No. 4, excluding any cap repairs, is fully protective of human
health and the environment and is a common-sense, effective, and cost-effective
alternative. The lack of identifiable risks from the Site in its present condition; the
existing, unique hydrogeologic conditions at the Site; the existence of natural ground
water containment and attenuation processes; and sufficiency of the existing landfill
cap, all strongly support the choice of Alternative No. 4 without the landfill cap
repairs.

EPA Response: The cap repairs called for in the selected remedy in conjunction with the repair
and continued operation and maintenance of the existing leachate management system will assist
in maintaining the natural containment of on-Site ground water contaminants. The cap repair,
and operation and maintenance portion of the selected remedy will insure that the caps will
prevent direct contact with waste; provide a stable, maintainable, well vegetated soil cover;
and minimize erosion and seeps in the future. The cap repair portion of the selected remedy
will also insure that the landfill caps will continue to be protective of human health and the
environment in the future while effectively maintaining the natural containment of on-Site
ground water.

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