BERKLEY PRODUCTS SITE

RI/FS WORK PLAN

APRIL 1991

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BERKLEY PRODUCTS DUMP

RI/FS WORK PIAN

Table of Contents

S ' ' .' . "Executive Summary.................................i

I. Introduction................................... 1II. Site Background and Setting................... 2III. Initial Evaluation...........................3

A. Wastes PresentB. Potential Contaminant PathwaysC. Preliminary identification of

operable units and early responseoptions

D. Preliminary identification of .remedial actions

IV. Work Plan Rationale...........................6A. DQO's , ••B. Work Plan design

V. RI/FS Tasks....................................7

VI. Costs.........................................16

VII. Schedule.....................................16VIII. Project Management..........................16

A. StaffingB. Coordination

Appendix A - Scope of WorkAppendix B - Preliminary Health Assessment (ATSDR)Appendix C - Site Inspection Data

BERKLEY PRODUCTS - RI/FS WORKPIAN

Executive Summary

This Workplan includes a description of the SuparfundRemedial Investigation and Feasibility Study (RI/FS) planned forthe Berkley Products site. This site is approximately five acresin size and is located in West Cocalico Township, LancasterCounty, Pennsylvania (pleasa sea Maps #1, #2 and #3) . Thaproperty was operated as a landfill for household trash from the1930 «s to 1970. From 1965 to 1970, the site also received wastesfrom tha Lipton Paint Company, a subsidiary of tha BerkleyProducts Company.

EPA plans to conduct an RI/FS during 1990 and 1991. ThisWorkplan includes a brief history of tha sita, a summary of thaprevious investigation and a discussion of tha projectorganization, schedule and cost. Additional details on tha fieldactivities and sampling for tha Remedial Investigation will baavailable in the "Field Sampling Plan.1* Other related documentsincluda tha Health -and Safaty Plan and Quality Assurance Project .Plan (QAPP).

The objectives of tha project are to determine tha naturaand extent of contamination at the site, evaluate any potentialpublic health issues, identify any advarsa environmental effectsof tha sita, and salect an appropriate remedy that will protectpublic health and tha environment. This RI/FS is planned for 12months and is budgated at a cost of $475,000. Tha projectschedule calls for a proposed remedy in January 1993L.

Tha f ield work for the Remedial Investigation will include athorough examination of tha physical conditions of tha sita andtha chemical characteristics of tha waste materials depositedthere. This information will ba gathered by sampling the soil,leachate, ground water and air. A drilling program will ba usedto establish tha geological conditions at the sita and to installground water monitoring walls. Soil borings and test pits willba used to def ina tha lateral extent of waste materials and tocollect subsurface samples.

A repository for information generated during this projecthas been established at the West Cocalico Township office inReinholds. Project reports are available for public inspectionduring business hours. This repository will includa all of thematerial referred to as tha Suparfund "Administrative Record*1 forthis site. Any questions or comments about this project shouldba directed to Eric Johnson or Jim Feenay at tha EPA RegionalOffice in Philadelphia, (215) 597-8309.

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BERKLEY PRODUCTS SITE - RI/FS WORKPIAN

Section i* introduction

This sita was originally investigated by the PennsylvaniaDepartment of Environmental Resources in 1984. In March of thatyear, PA-DER completed a "Potential Hazardous Wasta SitaIdentification" form and tha sita was included on EPA's "CERCLIS"list of potential hazardous wasta sites. A "PreliminaryAssessment" was also completed in 1984 and tha sita was scheduledfor further investigation.

In July 1934, EPA collected field samples that werapresented in a "Site Investigation" report dated March 5, 1986.Tha information from tha Sita Investigation was used to scora thesita with tha Hazard Ranking System. The site was nominated fortha National Priorities List (NPL) of Superfund sites in 1936with a scora of 30.00 and was finalized as an NPL sita in March1990.

EPA conducted interviews with former owners, operators andemployees of tha sita in 1937 and 1938. Company records weraalso obtained and deed information was researched. Thatinformation has been compiled and EPA is now preparing tocomplete a Superfund Remedial Investigation and Feasibility Study(RI/FS) at this site.

This Workplan includes a description of the technicalapproach, organization and management of this project. ThisWorkplan has been prepared according to EPA's "Guidance forConducting Remedial Investigations and Feasibility Studies UnderCERCLA" (EPA/540/G-89/004) and tha National Contingency Planprovisions for RI/FSs (40 CFR 300.430) that implement Section 104of CERCLA, as amended.

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Section lit Site Background and Setting

The Berkley Products Dump is located one and a half milesnortheast of Denver, Pennsylvania, in West Cocalico Township,Lancaster County. Also known as Schoeneck Landfill, the site iseast of Wallups Hill Road, north of Swamp Bridge Road. Theformer dump covers about five acres within a larger tract of 21acres. EPA's knowledge of the site comes largely frominformation provided by former site owners and operators in 1987and 1988.

The site was used as a municipal waste dump fromapproximately 1930 until 1965. In 1965, the Lipton PaintCompany, a subsidiary of Berkley Products Company, purchased theproperty. The operation continued to receive household trashfrom neighboring communities as well as paint wastes from Lipton.The property was purchased by its current owner in September 1970after it was closed by Lipton.

During the period from 1965 to 1970, it is estimated thatthe dump received about 40,000 gallons of paint wastes fromLipton Paint Company. It is believed that these wastes includedprimarily pigment sludges and wash solvents. It has beenreported that the solvents were sometimes used to burn thehousehold trash and that the sludges were disposed of in fivegallon pails. Interviews with former operators and haulersindicate that the municipal trash was dumped to the south of theaccess road, toward the hillside, while the paint wastes weredeposited in the northern part of the dump.

Section Hit Initial Evaluation

A. Wastes Present

Prior to 1965, tha dump received paper, wood, cardboard andother domestic trash from tha northeastern corner of LancasterCounty. Tha only commercial wastes identified during that periodwere from two local shoa companies. Those wastes includedleather scraps and empty glua and dya pails.

Tha Lipton Paint Company produced paints and varnishes withsolvents, such as mineral spirits, ethyl cellulose resin andpigments with lead oxida and lead chrornate. Tha solventsincluded toluena, xylena, alaphatic napthas, mineral spirits,methyl ethyl ketones, methyl isobutyl ketones, ethyl acatata,butyl acatata, glycol ether, butyl calasol, methyl alcohol andisopropyl alcohol.

Tha EPA Site Inspection (March 5, 1936) noted severalpotential contamination problems at tha sita. Field instrumentsdetected organic vapors at tha seep location on the southeast toaof the landfill and laboratory analyses of samples showedcontaminants in the soil, ground water and leachata. Tha samplalocations and data summary from tha Sita Inspection ara includedas Appendix C.B. Potential Contaminant Pathways

Chemical contaminants at a sita can be transported by threa"pathways": ground water, surfaca water and air. This work planincludes procedures to examine all of these pathways and avaluataany current and potential transport of contaminants off-sita.In tha 1936 Sita Investigation Report, soma potential pathwayswara observed that will be investigated mora thoroughly duringthe Remedial Investigation. In 1936, observations includedground level readings of organic gases, leachata seeps on thasoutheastern edga of tha sita and ground water samples thatincluded traca amounts of organic chemicals.

Ground water investigations ara usually a major aspect ofSuperfund investigations and Figure II is a general diagram ofhow ground water can ba affected by wastes in a landfill. Figure12 shows a more complex system, with layers of bedrock beneaththa sita. Initial research for tha Berkley Products sitasuggests that tha subsurface conditions may ba similar to thosepictured in Figure 12. Tha layers of bedrock dip to tha north ata 45 degree angle, while tha surfaca of tha sita slopes to thasouth. Figure 13 shows how contaminants with different densitiescan move at different levels of tha aquifer. Issues such as thacharacteristics of tha bedrock and contaminants will ba used tosite the monitoring wells and other sampling locations.

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C. Oparabla Units and Early Response Action3

A sita tour and evaluation was held on March 26, 1990.Based on that visit and tha available sita information, thera areno current plans to divide tha project into "Operabla Units" orto conduct any "Early Responsa Actions." Plans hava been mada,however, to sampla local residential wells on April 26, 1990.This early sampling will ba compared to tha 1934 sampla resultsand will ba used as a first step in the ground water sampling fortha Remedial Investigation.

D. Preliminary Assessment of Human Health Impacts

A "Preliminary Health Assessment" for the Berkley site hasbeen completed by tha Agency for Toxic Substances and DiseaseRegistry (ATSDR) of tha U.S. Public Health Service. This reportis included with this Work Plan as Appendix B. ATSDR visited thasita and reviewed tha sampling data from 1984. They concludedthat thera ara no current adversa health effects from tha sitabut pointed to several potential problems. ATSDR recommendedadditional investigations and monitoring of site conditions.

B. Potential Remedial Actions

Tha Superfund program was created nearly ten years ago andhas addressed many old landfill sites across tha country. An EPAWorkgroup recently examined 98 landfill projects and compared tharemedies selected for cleanup. This work was intended to halpfocus new RI/FS projects at similar sites. Tha Workgroup lookedat fiva issues: soils/landfill contents, soils/hot spots, surfacawater and sediment, groundwater and leachata, and landfill gas.

Tha most common remedies at these 93 sites included claycaps, surfaca controls (such as grading and revegatation), andcollection and treatment systems for leachata and ground watar.The collection systems included extraction wells and frenchdrains and treatment included chemical, biological or physicalprocesses to address tha specific contaminants. Most of tharemedies also included access restrictions, such as fencing, andcontinued ground water monitoring. Only three parcent of thaprojects selected tha "no action" alternative.

Many other remedial action options wera also evaluated butultimately rejected at these sites. The main reason forrejecting other cleanup actions was tha risk associated withexcavating and handling tha landfill contents. Site excavationcreates the threat of fira and explosion, with sarious risks forlocal residents and sita workers. Tha cleanup options that wararejected because of thesa concerns included high and lowtemperature thermal treatment (such as incineration andvolatilization), off-sita disposal and synthetic landfill liners.All of these activities required the excavation and handling of

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the waste material'in the landfill.

Some other remedies that were considered, but not usuallychosen, included "insitu" processes such as biological treatment,vitrification (heat fusion) and solidification (chemicalfixation). These options were rejected for a variety of reasons,including extensive testing requirements (biodegradation) anddifficulties handling mixed wastes (vitrification). To theextent that they also required mixing with the landfill contents,these alternatives were also rejected due to the excavationproblems discussed above.

All of these approaches to landfill problems will beexamined during the Berkley Products RI/FS. The most commonlyselected remedies will be looked at most closely, since they havebeen shown to effectively reduce the public health andenvironmental risks associated with old landfills. EPA willpublish a "Proposed Plan" after the Feasibility Study isfinished. After a hearing and a public comment period, a finalremedy will be selected in a "Record Of Decision."

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Section IVt Work Plan Rationale

A. Data Quality Objectives

Tha purpose of tha Remedial Investigation is to dafina thaphysical and chemical characteristics of the sita. Ona of thaimportant aspects of this process is collecting samples of soils,air and ground grater for chemical analyses. These analysesprovide valuable information on tha amount, location and typa ofchemical contaminants that may ba at tha sita and in thesurrounding area.

To maka tha sample collection process mora efficient, DataQuality Objectives (DQOs) are identified in project work plans.This fiald investigation will use a variaty of sampla collectionand analytical procedures to generate data for specific purposes.Soma procedures will ba used to screen samples in tha fiald andother samples will ba sent for laboratory analysis.

Data ara grouped into five categories, or "levels,"depending on tha kind of analysis used to generate thainformation. "Level 1" is the most basic category and includes •qualitative data from field test kits. Tha accuracy, precisionand reliability of the test results increase through "Level 5."Levels 1 and 2 ara usually used for sita screening or monitoringduring construction. Levels 3, 4 and 5 are used for riskassessments and engineering design.

B. Work Plan Deaicm

Tha naxt chapter of this work plan includes a discussion oftha technical work that is planned for this site. Tha technicalapproach has been designed to take maximum advantage of existinginformation about tha sita and the wasta characteristics. Thafiald investigation includes a phased approach to sita samplingthat may result in work plan modifications based on data andobservations collected during tha field work. Already underwayfor this project ara aerial photography and topographic mappingof tha site, as well as the research needed to prepare this workplan.

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Section V; RI/FS Tasks

A, Remedial Investigation fRI) Tasks

The RI activities are divided into five sections: 1) Soils,Geology and Hydrology, 2) Air Characterization, 3) Human HealthRisk Assessment, 4) Ecological Assessment, and, 5) TreatabilityStudies. s

1. Soils, Geology and Hydrology

The first phase in this portion of the RI will be aerialphotography and site mapping. Aerial photographs will beanalyzed for historic changes at the site and for surfaceexpressions of seeps and fractures. Historic analysis will beconducted to determine the extent of fill, locate areas of wasteburning, and locate possible sites where 55-gallon drums and 5-gallon cans were stored and buried. Seep locations will be mappedto investigate the groundwater-surface water interface. Fracturetrace analysis will be utilized to locate bedrock fractures. Thedata generated by these analyses will be used to identify surfaceand subsurface sample locations. :

Two topographic base maps of the site will be generatedusing aerial photographs. One map will be a small-scale regionalmap of the site area. This map will be utilized in thebioassessment survey, home well survey and to plot groundwatercontamination. The second map will be a large-scale detailed sitemap. This map will be used to plot site specific samplingsurveys.

The second phase of this section includes field surveys andpreliminary screening activities. Home wells surrounding thesite will be sampled and the residents informed of the results.Well surveys will be conducted to determine home wellconstruction and zone of completion. USGS and PaGS well databases will be accessed for supplemental data. These data will beutilized in the hydrogeologic investigation.

A surface geophysical survey will be performed to locate thediabase dike and possible buried drums, cans and other debris.The survey will be conducted with a magnetometer and theinformation will be used in conjunction with the results of thesoil gas survey to identify soil sampling and monitoring welllocations.

A coil gas survey will be conducted to locate areas ofelevated VOC concentrations and enhance the knowledge of theextent of contamination. Data generated will be used tofacilitate the placement of soil sample and monitoring welllocations.

Tha preliminary work discussed above will ba used toidentify locations for tha soil survey activities and monitoringwells. Tha soil survey will includa soil borings and trenching.These investigations will ba used to charactariza the soil, thafill material, tha three dimensional extent of vadosa zonacontamination and tha areal extent of tha landfill. Trenchingwill ba employed where only qualitative information is necessary.Soil borings will be used whera quantitative data ara required.

Results of tha initial surveys will ba used to determine thaplacement of ground water monitoring walls. The generalconstruction of a deep wall is shown in Figure }4. Clusteredmonitoring walls will ba installed, logged and developed bafora theground watar is sampled. A diagram of clustered walls is shown inFigura 15. Hydrologic parameters will also ba measured. Thesatasks will ba performed to determine tha sita geologic andhydrologic characteristics.

Surface water and sediment samples will ba taken ofgroundwater seeps, leachata seeps and stream watars. Stream flowrates will also ba measured. Thesa samples will be taken to assesstha interaction of surfaca water with groundwater and to daterminathe extent of contamination to tha environment. Tha surfaca watarsamples ara also discussed the Ecological Assessment, below.

2. Air CharacterizationSampling stations will be established to assess the potential

for airborna contaminants. Meteorological information will bagathered for tha sita and air sampling stations will ba locatedaccording to local conditions. Tha information davaloped will baused for tha Risk Assessment (below) and for the on sita health andsafaty program.3. Human Health Risk Assessment

Tha Human Health Risk Assessment will evaluate the potentialhuman health affects associated with tha Berkley Products Sita ifthe "no-action" alternative is selected. Tha no-action alternativeassumes:that no remedial (corrective) actions will taka placa attha site. By conducting an assessment in this manner, tha EPA willba able to datermina if remedial actions ara required for any areaof the site.

Tha first step in the public health assessment is tha raviewof results from tha environmental sampling, as wall as tha reviewof other information, developed during tha RI. Thesa data will baused to identify chemicals of potential concern. In turn, thesechemicals will undergo detailed study during tha risk assessment.

A key element in this screening process is a comparison ofsita concentrations of contaminants to background levels of thesa

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chemicals in appropriate media. Naturally occurring chemicalspresent at background concentrations may not be considered to besite-related and will not be evaluated in the assessment. Inaddition, chemicals present in sample "blanks*1 at similarconcentrations (i.e., laboratory and field contaminants) will notbe selected for the detailed analysis. "Non-detects" will behandled according to Regional policy.

Depending on the number of chemicals detected at the site,selection of a subset of chemicals referred to as the "chemicalsof concern" or "indicator chemicals" may be necessary. If such aselection is needed, relative concentration, mobility, persistenceand toxicity of the contaminants in the environmental samples takenat the site will be considered.

Previous sampling of wastes and environmental media conductedby the EPA indicates that benzene, phthalate esters, and severalmetals (including lead) are the predominant contaminants of concernat the Berkley Products Site. On-site and off -site contaminationof ground water, surface water, soil, and sediments by theforegoing contaminants have been documented. Additionally,elevated HNU readings were recorded in the breathing zone on-.site. These chemicals will be included as chemicals of concernfor the site along with any other chemicals associated with adversepublic health impact.

The second step in the public health assessment is theidentification of .actual or potential routes of exposure and thecharacterization of the probable magnitude of exposure to humanreceptors. The following potential exposure pathways may beimportant under current or future land use at the Berkley ProductsSite:

- Ground Water- Ingest ion of contaminated ground water.- Inhalation of volatiles released from the groundwater.

- Skin absorption of ground water contaminants.

- Surface water • „ , • . •- Ingestion of contaminated surface water.- Skin adsorption of surface water contaminants.- Consumption of contaminated fish.

- Soils/Sediments- Direct contact.- Accidental ingest ion.

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- Air- Inhalation of on-sita vapors.- Inhalation of airborne contaminants migrating off-sita.

For each exposure scenario, concentrations in relevantenvironmental media (air, surfaca water, ground watar, and soil)at tha potential receptor locations will ba identified. Whereconcentrations hava not been measured at the exposure point,estimates of current concentrations may, in certain instances, bemada using models. Tha choice of models will ba based on thasampla results. They may ba simple partitioning models todetermine raleasa from soil or water to another medium (e.g., air)or mora complex transport models. It is not possible to identifytha specific modals that may ba selected hera, since it is notknown what tha data will raveal about tha distribution of chemicalsfrom the sita. Should tha modeling become necessary, thaappropriate modals will ba selected from tha available litaratura(i.e., EFA publications and reviewed journals). All modals andassumptions will ba documented in tha report and supplemented withappendices.

Chemical intakes for each human exposure scenario will baestimated based on frequency and duration of exposure and rata ofmedia intake (e.g., amount of water ingested per day). Humanexposure is expressed in terms of intake, which is tha amount ofa substance taken into the body per unit body weight per unit time.A chronic daily intaka (GDI) is averaged over a lifatima for ^carcinogens and over a 1 year exposure period for noncarcinogens,on tha assumption that chronic non-cancer affects could appearafter less-than-lifetime exposures. Tha GDI is calculatedseparately for each exposure pathway, since different populations-at-risk may ba affected by tha individual pathways. Thaassumptions used in thesa estimates will be stated clearly andwill ba thoroughly documented. Tha assumptions and contaminantconcentrations will ba selected so as to represent a ReasonableMaximum Exposure scenario.

Tha third step in tha public health assessment is tha toxicityassessment, which identifies the critical toxicity values for eachchemical of potential concern. For humans, toxicity data will bapresented in the following forms:

For carcinogens: tha carcinogenic potencyfactor, in units of (mg/kg/day) .For noncarcinogens: tha estimated riskreference dose (RfD), in units of mg/kg/day.For chemicals for which no critical toxicityvalues ara available: a semi-quantitative/characterization based on any pertinent

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information that is available (e.g.,subchronic toxicity studies or structuralanalogies).

Finally, the potential adverse effects on human health areassessed, where possible, by comparing contaminant concentrationsfound at or near the site with the Applicable or Relevant andAppropriate Requirements (ARARs), as identified by the RemedialProject Manager. Additionally, a quantitative risk assessment willbe performed for each of the chemicals of concern.

The evaluation of noncarcinogenic risks associated withcontaminants of concern considered in this report is basedprimarily on a comparison of the estimated daily intake of thechemicals of concern with appropriate critical toxicity values forthe protection of human health. For potential carcinogens, theestimated cancer risks associated with exposure are calculatedusing EPA-derived cancer potency factors. Specifically, excesslifetime cancer risks are obtained by multiplying the cancerpotency factor by the average daily intake of the contaminant underconsideration. This procedure is considered to be appropriate forlow doses, such as* would potentially result from this site. Inthis assessment, the effects of exposure will initially beconsidered separately.

Contaminants often occur together in the environment, andindividuals may be exposed to a mixture of the contaminants.Consequently, it is important to recognize the potential adverseeffects (i.e., synergistic effects) that these mixtures can havein humans. Often, however, suitable data are not available tocharacterize the effects of chemical mixtures. Therefore, ifinformation regarding the chemical mixtures present at the BerkleyProducts Site is unavailable, the excess cancer risks or calculatedhazard indices associated with this facility will be considered tobe additive, as suggested in EPA guidance for evaluating mixtures.

Risk assessments will be conducted separately for eachexposure pathway and for each source, when appropriate. Resultswill be presented in terms of a Reasonable Maximum Exposurescenario. The risk assessment for each exposure pathway willinclude a discussion of the uncertainties in the estimates.

4. Ecological AssessmentEcological Assessment is initiated with a characterization of

the ecosystem. This process begins with research on the generalecoregion, followed be narrowing to the specific communities,populations and organisms that comprise the habitats. Anexhaustive list of the flora and fauna of the four or five mainhabitat systems is not needed, but rather a qualitative andproportionate description of the species most commonly recognizedas comprising the ecosystem will be developed.

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Tha Berkley Products sita is located in tha rolling hills oftha piedmont area of Pennsylvania, in the West Cocalico Townshipof Lancaster County. Tha watershed is tha Cocalico Creek, asubsidiary, ultimately, of tha Susquehanna River. Tha immediatesetting is a sparsely populated rural area, with some small farmsand a limited number of residential dwellings. Open spaces aradevoted to pastureland, field and have crops, and residentiallawns. Wooded areas ara mainly mixed, second succession, uplandhardwoods. Tha sita itself is about fiva acres in siza, consistingof lawn and upland hardwood mix.

Tha ecological assessment will focus on data qualityobjectives (DQOs) involving identification of species and theirralativa abundance, species richness, community organization, andbiomass, if appropriate. Tha DQOs will also be the foundation oftha remedial and post-remedial evaluations and will ba adjustedaccording to tha ecosystem under study.

Tha investigation will davalop and contact a list of local,stata, and federal agencies, as well as individuals from theprivate sector, who may ba knowledgeable about the sita and itssurroundings. This list will includa, but not ba limited to, the-following:

- PA Dept. of Natural Resources- PA Fish Commission- Local Soil and Conservation District- Susquehanna River Basin Commission- USDA Soil Conservation Service- USDA Fish and Wildlife Service- EPA Division of Water Management- US Army Corps of Engineers (Baltimore District)

Information collected will ba analyzed in light of tha DQOsand incorporated onto maps and into tables for statisticalanalysis.

A reconnaissance tour will ba used to describe tha majorecosystem components and to determine relationships among them.It will also ba tabularized and compared with the historicalinformation. This tour will also establish tha generalhydrological picture and roughly define tha relationships amongecosystem, seeps, springs, wells and streams.

Tha contaminants of concern ara discussed above in SectionIII.A and Appendix C. Dead trees on site also show elevated levelsof manganese. Thesa dead trees are reportedly located near a seeptowards tha eastern boundary of tha site.

The media that ara to ba sampled will ba identified moraspecifically in tha Sampling Plan, but it appears they will basoils, seeps and sediments, wetlands and associated vegetation (if

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necessary) and soils, surface water and sediment, and stream biota.The appropriate sampling and analytical techniques and methods willbe taken from EPA guidance, Standard Methods and the ASTM manual.

The terrestrial, transitional and wetlands characterizationwill be carried out along a transect that runs northwest tosoutheast across the site. Impacts will be a major objective ofthe characterization, especially where it is suspected that drumsare located and where seeps are known to exist. Wetlandsvegetation along the transect will also be closely inspected forimpacts.

The stream will be investigated in at least four locations(reference, two in the impact zone, and downstream) formacroinvertebrates. Water and sediment samples will be collectedfrom these same locations for chemical analyses and toxicitytesting. The fish population will also be characterized and fishtissue will be collected for analysis if considered necessary.

A vital portion of this effort will be the determination ofexposure pathways and receptors. Based upon observations andinformation to date, it is expected that tissue samples will have.to be taken for analysis, unless it is determined thatobservational information will be adequate.

The biological and ecological information will be tabularizedfor statistical analysis. This will be cross-checked for spacialrelationships using maps and EPA'6 Geographical Information System.This information will also be analyzed in light of the chemicalinformation gathered during sampling activities. Environmentalmonitoring plans will also be developed to evaluate the effect ofsite cleanup activities.5. Treatability Studies

The purpose of treatability studies is to further assess thefeasibility or performance of a particular technology for thewastes or media at the Berkley Products site. Treatability studiesare often conducted to fill information gaps that exist followinga review of full and test-scale operations that may have beenperformed for other similar sites. .

Technical literature and information available frommanufacturers about the performance, costs, applicability andimplementability of candidate technologies will be assessed.Information available from EPA Region III and other RegionalOffices regarding treatability testing for similar sites will alsobe collected and assessed. It is anticipated that this task canbegin early in the RI as data becomes available from the samplingof the landfill contents.

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The need for treatability testing will be determined by thaproject team onca tha information described previously has beenassessed, and tha tima frama and approximate costs for pilot orbench-scale studies hava been determined. If it is determined thattreatability testing is needed, a work plan for such testing willba developed. A work plan would includa objectives, procedures,methods and conditions to ba tested.

Tha results of a treatability study would ba included in thaRI/FS report.

6. Remedial Investigation Report

Tha data and analyses developed during tha fiald studies willba presented and discussed in an RI Report. This Report willprovide tha technical basis for the evaluation of cleanupalternatives in tha Feasibility Study.B. Feasibility Study Tasks

1. Developing and Screening Remedial ActionsThis is tha first step in preparing cleanup options for the

Barklay Products sita. Many potential cleanup methods waradiscussed in Section III.D. (Preliminary Identification of RemedialActions) and these will be reexamined with tha informationdeveloped during tha RI. A final list of appropriate options willbe developed for detailed evaluation and cost estimates. ^

This development and screening process also includes a reviewof ARARs and closa coordination with PA-DER. Tha final list ofalternatives will meat tha initial screening criteria ofeffectiveness, implementability and cost. As a requirement of thaSuparfund program, a "No Action" alternative will be included asa baseline reference for comparison to tha other actions.2. Detailed Analysis of Remedial Alternatives

The cleanup alternatives that pass the initial screeningprocess will ba examined in detail for effectiveness, programrequirements and cost. The effectiveness evaluation includes anassessment of tha public health and environmental protectionafforded by tha alternatives. It also looks at the long and shortterm affects of tha alternatives and tha uncertainties of eachoption. The alternatives will ba compared on tha basis of theirability to reduce the risk of chemical exposure to tha public andthe environment. The "No Action" alternative will serve as thabasis for comparing the effectiveness of the other options.

The program requirements criteria include the provisions ofother environmental laws and Suparfund 'a goal of reducing themobility,, toxicity and volume of site waste material. The final

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issue, cost, will be addressed by preparing estimates of thecapital and operating expenses of each alternative for the next 20years.3. Feasibility Study (FS) Report

The FS Report will include a step by step discussion of thealternatives evaluation for the Berkley Products site. Theremedial alternatives will be presented and explained. Thismaterial will be used by EPA to select a "Preferred Alternative"and publish a "Proposed Plan" for cleaning up the site. The FSReport and the Proposed Plan will be distributed for public commentand a public hearing will be held near the site. Following areview of public comment, EPA will select a remedy for the site andproceed with design and construction.

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VI. Costs

This RI/FS has been budgeted for $475,000 (sea Table A). Theprincipal cost will ba the RI field work, which is expected to baapproximately $200,000.

VII. Schedule

Planning for this RI/FS started in February 1990. The RIreport is scheduled for Octobar, 1991 and tha FS is planned forDecember, 1991. The entire project, including selection, designand implementation of a remedy, is scheduled to last throughOctober 1993. Charts of tha RI/FS and project schedules areincluded in Tabla B and at tha end of the Statement of Work inAppendix A.

VIII. Proiect Management

A. Staffing

This project is being planned and carried out largely be EPApersonnel in the Region III Office in Philadelphia. A project teamhas been organized to prepare this work plan and to write theRI/FS. The team includes representatives of the remedial,technical support, legal and public affairs offices. A list oftha project team members is included in Table C.

EPA contractor support is being used for two main tasks during v—this RI/FS. Areal photography is being done by EPIC in Warrington,Virginia and field sampling will be performed by EPA's Region IIIField Investigation Team, NUS Corporation, Wayne, Pennsylvania.

B• Coordination

Overall project coordination is the responsibility of the twoproject managers assigned to this site, James Feeney and EricJohnson. They have organized the project team and will coordinatethe field activities scheduled for this summer. They will also beresponsible for writing the project reports and managing thaadministrative aspects of this project.

16

Table A

Project Budget

1. Project Planning....................................$60,000- Areal Photographs- Site Topographic Mapping- Work Plan- Health & Safety Plan- Sampling and Analysis Plan- Quality Assurance Plan

2. Community Relations.................................$60,000- community Relations Plan- Public Meetings- Administrative Record

3. Remedial Investigation..............................$280,000- Field Work

- Soil Gas Survey- Soil Boring- Well Installation- Test Pits- Sampling

- Field Work Subtotal....$200,000- Sample Analysis- Treatability Studies- Report Preparation

2. Feasibility Study...................................$75,000- Alternatives Evaluation- Report Preparation

PROJECT TOTAL......................$475,000

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Table C

Project Team Member^

Name Project Responsibilities

Loria Ackar FIT Coordinator

Cecil Rodrigues Attorney

David Byro Alternatives Evaluation

Bruce Rundell Geology and Hydrogaology

Robert Davis Environmental Assessment

Roy Smith Toxicology

Ann DeLong Project PlanningHindi Snoparsky Hydrogaology :

Alyca Fritz Natural Resources AssessmentWilliam Toffel Public AffairsDawn loven Toxicology ^Carrie Daitzel Public AffairsCesar Lee Field Work Oversight

Mike Towle Hydrogeology

Donna McCartney Treatability Studies

Diana Walker Project PlanningMarty Powell Emergency ResponseJack Kelly Areal PhotographyJames Feeney Project ManagerEric Johnson Project Manager

APPENDIX A - SCOPE OF WORK

BERKLEY PRODUCTS DUMP SITE

RI/FS STATEMENT OF WORK

Purpose

The purpose of this RI/FS is to investigate the nature andextent of the contamination at the Berkley Products Dump site andto develop and evaluate remedial alternatives. This RI/FS willbe prepared by EPA personnel, except as otherwise noted. TheField Investigation Team (FIT), for instance, will perform thefield activities for the RI/FS.

EPA will conduct the RI/FS in accordance with the Guidancefor Conducting Remedial Investigations and Feasibility StudiesUnder CERCLA (U.S. EPA October 1988). This Statement of Work(SOW) is based on that guidance and has been developed toinitiate project planning for tha site. A Project Team will beorganized to prepare a detailed work plan for the RI/FS.

Background

The Berkley Products Dump began operation as a smallmunicipal landfill in tha mid-1930's. From 1965 until itsclosing in 1969, the sita was also used for disposal of paintwastes, including wash solvents, resins, and pigment sludges.These wastes ware sent to tha sita from a paint manufacturingplant associated with Berkley Products.

Tha Berkley Products company filed a Superfund Notificationin 1981. During fiald investigations in 1984, EPA detectedbarium, lead, mercury, benzene, bis(2-ethylhaxyl) phthalate, anddiethyl phthalate in leachata seeping from tha sita and in anoff-site private well near the site. Walla serving 265 peoplewere taken out of service. No municipal supply is available intha area but residents reportedly use bottled watar because ofthe naturally poor taste of their well water.

This site was proposed for the NPL in June 1988 with an HRSscore of 30.00. The site was finalized in March 1989.II. Scope

The specific RI/FS activities to be conducted at the BerkleyProducts Dump site consist of eleven tasks.

Task 1- Project PlanningTask 2- Community RelationsTask 3- Field InvestigationsTask 4- Sample Analysis and Validation ,

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Task 5- Data Evaluation ^-,.:;<,;>.

Task 6- Risk Assessment

Task 7- Treatability Studies

Task 8- RI Report

Task 9- Remedial Alternative Development and Screening

Task 10- Detailed Analysis of Alternatives

Task 11- FS Report

These eleven tasks are included in the attached RI/FSschedule and are discussed in more detail below.Task 1: Project Planning

Several activities will be conducted prior to the fieldinvestigations, which are scheduled for this summer. An internalproject team will be established to complete project planning andprepare a Work Plan. EPA will compile existing information, suchas topographic maps, historical and current aerial photographs,and data collected as part of the NPL listing process. Thismaterial will be used to prepare a work plan for the RI.

\, Notice letters will also be issued and responses receivedduring this task. There are two PRP's but they are not capableof sponsoring an RI/FS. After negotiating site access with thecurrent owners, a site visit will also be conducted to becomefamiliar with site topography, access routes, and the proximityof potential receptors to the site contaminants. The need for aremoval or early response action will be evaluated during thisperiod.

Specific project plans will be prepared to meet theobjectives of the RI/FS. These plans will include: a work plan,a sampling and analysis plan, the quality assurance project plan(QAPP), a health and safety plan, and a community relations plan.Task 2: Community Relations

The community relations program will be integrated closelywith all remedial planning and response activities. A publicinformation program will be conducted to ensure communityunderstanding of actions being taken and to obtain communityinput on RI/FS progress. , .

Task 3: Field Investigations

The field investigations detailed in the Work Plan arescheduled for this summer. FIT, under the supervision of theEPA, will conduct those investigations. The objectives will beto characterize the site and to evaluate the actual or potentialrisk to human health and the environment posed by the site.Investigation activities will focus on problem definition andresult in data of adequate technical content to evaluatepotential risks and to support the development and evaluation ofremedial alternatives during the FS.The field investigations will include the following activities:

- Surveying and Mapping of the Sita

- Evaluation of Waste Characteristics

- Hydrogeologic Investigation

- Soils and Sediments Investigation- Surfaca Water Investigation- Air InvestigationInformation from this task will be summarized and included

in the RI/FS report.Task 4: Sample Analysis and Validation

In the Work Plan, EPA will develop a data management systemincluding field logs, sample management and tracking procedures,and document control and inventory procedures for both laboratorydata and fiald measurements to ensure that the data collectedduring the investigation are of adequate quality and quantity tosupport the risk assessment and the FS. collected data will bevalidated at the appropriate field or laboratory QC level todetermine whether it is appropriate for its intended use. Thisinformation will be incorporated into the RI/FS reportappendixes.Task 5: Data Evaluation

EPA will analyze all site investigation data and present theresults of the analysis in an organized and logical manner sothat the relationships between site investigation results foreach medium are apparent. A summary will be prepared thatdescribes (1) the quantities and concentrations of specificchemicals at the site and the ambient levels surrounding thesite; and, (2) the potential transport mechanism and the expectedfate of jbhe contaminant in the environment.

Task 6: Risk Assessment ;<•:,:?

EPA will conduct a baseline risk assessment to assess thepotential human health and environmental risks posed by the sitein the absence of any remedial action. This effort will involvefour components:

- Contaminant Identification- Exposure Assessment

- Toxicity Assessment- Risk Characterization

Task 7: Treatability Studies

EPA will arrange for bench and/or pilot studies as necessaryto determine the suitability of remedial technologies to siteconditions and problems. Technologies that may be suitable tothe site will be identified as early as possible to determine .whether there is a need to conduct treatability studies to betterestimate costs and performance capabilities. If treatabilitystudies are determined to be necessary, a testing planidentifying the types and goals of the studies, the level ofeffort needed, a schedule for completion, and the data managementwill be prepared.Task 8: RI Report

Activities conducted and the conclusions drawn during theremedial investigation (Task 3 through 7) will be documented inan RI report. Supporting data and information will be includedin the appendixes of the report.Task 9: Remedial Alternatives Development and Screening

EPA will develop a range of distinct hazardous wastemanagement alternatives that will remediate or control anycontaminated media (soil, surface water, ground water, sediments)remaining at the site to provide adequate protection of humanhealth and the environment. The potential alternatives willencompass a range of alternatives which will reduce the toxicity,mobility, or volume of wastes. The alternatives will vary in thedegree to which long term management of residuals or untreatedwaste is required.

Preliminary remediation goals will be established based onreadily available information (e.g. Rfds) or chemical-specificARARs (e.g. MCLs). General response actions will be developedfor each medium of interest defining contaminant, treatment,

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excavation, pumping, or other actions, singly or in combinationto satisfy remedial action objectives. Volumes or areas of mediato which general response actions may apply will be identified,taking into account requirements for protectiveness as identifiedin the remedial action objectives and the chemical and physicalcharacteristics of the site.

Based on the developed general response actions, hazardouswaste treatment technologies will be identified and screened toensure that only those technologies applicable to thecontaminants on site, the physical matrices, and other sitecharacteristics will be considered. This screening will be basedprimarily on a technology's ability to effectively address thecontaminants at the sita, but will also take into account atechnology's implementability and cost. Representative processoptions will be selected to carry forward into alternativedevelopment. The need for treatability testing for thosetechnologies that are probable candidates for considerationduring the detailed analysis will be evaluated.

The alternatives will be screened on a general basis withrespect to their effectiveness, impiementability, and cost:.

Task 10: Detailed Analysis of AlternativesEPA will conduct a detailed analysis of alternatives

consisting of an individual analysis of each alternative againsta set of evaluation criteria and a comparative analysis of alloptions against the evaluation criteria with respect to oneanother.

The evaluation criteria are as follows:- Overall Protection of Human Health and the Environment

- Compliance with ARARs- Long-Terra Effectiveness and Permanence _- Reduction of Toxicity, Mobility, or volume- Short-Term Effectiveness- Implementability

- Cost- State Acceptance- Community Acceptance

Task 11: FS Report

A FS report will present the results of Task 9 and 10.Support data, information, and calculations will be included inappendixes to the report.Conclusion

This SOW is intended to guide the project team in finalizingthe Site Management Plan and RI/FS Work Plan. The initial RI/FSand project schedules (attached) incorporate the elements of thisSOW.

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APPENDIX B - PRELIMINARY HEALTH ASSESSMENT (ATSDR)

THE ATSDR HEALTH ASSESSMENT: A NOTE OF EXPLANATION

Section 104(1)(7)(A) of the Comprehensive Environmental Response,Compensation, and Liability Act of 1930 (CERCLA), as amended, states"...the term 'health assessment' shall include preliminary assessments ofpotential risks to human health posed by Individual sites and facilities,based on such factors as the nature and extent of contamination, theexistence of potential pathways of human exposure (including ground orsurface water contamination, air emissions, and food chain contamination),the size and potential susceptibility of the community within the likelypathways of exposure, the comparison of expected human exposure levels tothe short-term and long-term health effects associated with Identifiedhazardous substances and any available recommended exposure or tolerancelimits for such hazardous substances, and the comparison of existingmorbidity and mortality data on diseases that may be associated with theobserved levels of exposure. The Administrator of ATSDR shall useappropriate data, risk assessments, risk evaluations and studies availablefrom the Administrator of EPA."

In accordance with the CERCLA section cited, the Agency for ToxicSubstances and Disease Registry (ATSDR) has conducted this PreliminaryHealth Assessment using the data available to ATSDR. Additional HealthAssessments may be conducted for this site as more information becomesavailable to ATSDR.

Use of trade names is for identification only and does not constituteendorsement by the Public Health Service or the U.S. Department of Healthand Human Services.

SUMMARY

The Berkley Products Dump, an Update 7 site on the National PrioritiesList, is located in Denver, Lancaster County, Pennsylvania. The landfillwas previously used for the disposal of municipal trash, wash solvents,waste paints, resins, and pigment sludges. Landfilling operations wereterminated in 1969. A private residence is currently located on thewestern, nonfilled portion of the site. Other private residences arelocated adjacent to and downgradient from the site. Low concentrations oforganic chemicals and high concentrations of inorganic chemicals weredetected in water samples from private wells near the site. Although theuse of this water for potable purposes could be of potential healthconcern, water from contaminated wells is reportedly not being used forpotable purposes. Nonpoteble use of the water would not be expected topose a significant health risk. The potential health impacts resultingfrom contact with other environmental media -- such as ambient air,surface soils, and surface waters •- could not be assessed because of theabsence of supporting analytical data.

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BACKGROUND

A. SITE DESCRIPTION AND HISTORY

The Berkley Products Dump, an Update 7 site on the National PrioritiesList, is located 1.5 miles northeast of Denver, Pennsylvania, in LancasterCounty. The dump, which covers about 2 acres, is currently inactive.

SFrom the 1930s to 1965, the dump was privately owned and acceptedmunicipal trash, which was buried or burned. In 1965, Lipton Paint andVarnish Co., a subsidiary of Berkley Products Co., purchased the site.Lipton used the site for the disposal of municipal wastes, organicsolvents, paint wastes, resins, and pigment sludges. Some of the paintwastes were burned in a 15-foot deep pit. The rest was mixed withmunicipal refuse and covered with soil. •

Disposal operations at the landfill were halted in 1969 when room forexpansion and the availability of cover material were depleted. The dumpwas covered and seeded and sold to a private individual in September 1970.The owner has lived there since then.

B. SITE VISIT

The sita was visited by representatives of the Agency for Toxic Substancesand Disease Registry (ATSDR), the Pennsylvania Department of Health, andthe Pennsylvania Department of Environmental Resources on March 21, 1939.

The only entrance to the site is a private driveway that leads fromVallups Hill Road to the landfill. The owner of the site resides on thewestern side of the property, which, according to the owner, was not partof the original landfill area. The owner salvages junk automobiles, andthere were numerous junk automobiles in the former landfill area.

The landfill was covered with heavy brush and briars. In some areas,patches of domestic trash and scraps of rubber were observed at thesurface of the landfill. No fences surrounded the landfill.

The southern edge of tha landfill sloped steeply to a wooded area below.Along tha southern slope wera leachata breakouts, which had an oily sheenand a petroleum-like odor. Tha leachata seeps extended for 5-10 featbefore disappearing back into tha ground. Savaral rusted-out 55-gallondrums vara at tha bottom of tha slope.

Several private residences wera located south of tha landfill along SwampBridga Road. A farm with several sheep in a pasture was located south ofSwamp Bridga Road across from the landfill.

C. COMMUNITY HEALTH CONCERNS

Residents in tha area have complained about tha taste of tha ground waterbecause of its high iron content. However, during the ATSDR Site Visit,

Page 1 IR30QQ97

no health complaints were received from area residents or from officialsof the Pennsylvania Department of Environmental Resources or thePennsylvania Department of Health.

DEMOGRAPHICS, LAND USE, AND NATURAL RESOURCE USE

The site is located in a rural area. The area is wooded except for areasthat have been cleared for farmland or for single- family homes.Approximately 25 private homes border the site (1). Assuming that thereare 3.8 people per home, an estimated 570 people live within 1 mile of thesite (2).

No public water supply is available in the area. The residents rely onprivate wells or bottled water for their potable water supply.

Cocalico Creek is located about 1,500 feet east of the site. About2 miles downstream of the site, the town of Denver maintains a surfacewater intake on Cocalico Creek for its public water supply. This surfacewater intake is used during periods of low water reserves in the Adams townReservoir. This spring- fed reservoir, which is the primary water sourcefor the municipal water system, is located 5 miles east of the site..

ENVIRONMENTAL CONTAMINATION AND OTHER HAZARDS

A. ON- SITE CONTAMINATION

A Site Inspection of the Berkley Products Dump was conducted by av— U.S. Environmental Protection Agency (EPA) contractor on July 25-26, 1984.

During this investigation, water and sediment camples were collected fromleachate seeps on the southern and eastern faces of the landfill.Analyses of these samples revealed the presence of the followingchemicals.

TABLE 1: ON-SITE LEACHATE - AQUEOUS PHASE

Chemical Concentration (ug/1) :

benzene 63ethyl benzene 67xylenes 163toluene 4.41,4-dichlorobenzene 2.4carbon disulfide 23manganese 1,500barium 905iron 150,000chromium 305lead 300

These results were obtained for the aqueous phase of a leachate seepcollected on the couth side of the landfill.

Page 2

TABLE 2: ON-SITE LEACHATE - SEDIMENT

Chemical Concentration (ug/kg)

1,4-dichlorobenzene 704bis(2-ethylhexyl)phthalate 7,440diethyl phthalate 1,030dioctyl phthalate 69polychlorinated biphanyl-1254 230

These results were obtained for a sediment sample collected from aleachate seep on the south side of the landfill.

B. OFF-SITE CONTAMINATION

A Site Inspection of the Berkley Products Dump was conducted by an EPAcontractor on July 25-26, 1934. During this investigation, water sampleswere collected from seven private wells near the site. Tha maximumconcentrations of contaminants detected in these samples are listed below.

TABLE 3: OFF-SITE GROUNDWATER

Chemical Concentration (ug/1)

benzene 0.91,4-dichlorobenzene 1.6toluene 0.8trans-l,2-dichloroathylene 1.2 ,dichlorofluoromethane 1.2bis(2-ethylhexyl)phthalate 23manganese 3,700barium 2,700iron 2,700

C. QUALITY ASSURANCE AND QUALITY CONTROL

In preparing this Preliminary Health Assessment, ATSDR relies on theinformation provided in tha referenced documents and assumes that adequatequality assurance and quality control measures wera followed with regardto chain-of-custody, laboratory procedures, and data reporting. Thevalidity of tha analyses and conclusions drawn for this Preliminary HealthAssessment is determined by tha availability and reliability of thereferenced information.

D. PHYSICAL AND OTHER HAZARDS

The presence of numerous junk automobiles may pose a physical hazard toon-site trespassers.

PATHWAYS ANALYSES

A. ENVIRONMENTAL PATHWAYS (FATE AND TRANSPORT)s

Walls in tha area of tha landfill draw from tha underlying GettysburgFormation. During tha Site Inspection, a survey of private wells in the

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area indicated that they ranged in depth from 70 to 110 feet. Analyses ofwater samples from these wells indicated the presence of site-relatedorganic chemical contaminants. Water samples from some wells alsocontained high concentrations of metals, but it is not known if thepresence of these metals is site-related or naturally-occurring.

Groundwater flow in the area is believed to be eastward, toward theCocalico Creek. No data were available to indicate whether the river hasbeen impacted by the discharge of contaminants from the site.

Since the landfill area is elevated, surface water runoff from the siteand leachate may flow onto residential properties that are contiguous tothe landfill. However, no data were available to indicate whetheroff-site surface waters or soil had been impacted by contamination fromthe site.

During the Site Inspection, which was conducted in July 1984, ambient aircontamination was detected on-Bite at ground level and in the breathingzone by using a photoionization field instrument (HNU meter). However,no ambient air samples were collected to specifically identify thecontaminants present or their concentrations.

B. HUMAN EXPOSURE PATHWAYS

1. Since there is no municipal water system in the area, residents livingnear the site have private wells. Although the residents use well

, water for washing and other household uses, most of them use bottledwater for potable purposes. Residents have complained of a metallictaste in the water and have reported that a brown precipitate forms inthe water upon standing. These complaints may be due to the highconcentrations of iron and manganese (Table 3) that are present ingroundwater from wells near the landfill. Bacterial contamination ofone private well with fecal colifon&s has also been documented.

2. Analyses of on-site leachate samples indicated the presence ofnumerous contaminants (Tables 1 and 2). Although it is unlikely thatanyone would directly ingest the leachate, human contact with it couldresult in exposures by inhalation or by dermal absorption. Suchexposures would likely be of short duration and would occur on aninfrequent basis.

Following closure of the landfill, the landfilled area was coveredwith soil and seeded. Although most of the wastes are buried, someexposed trash at the surface of the landfill was observed during theATSDR Site Visit. Human contact with contaminated surface soils couldresult in exposures by ingestion, dermal absorption, or inhalation.Data to assess these potential exposure pathways were not available.

3. The presence of contaminants in off-site surface soils or surfacewaters could also result in human exposures by direct ingestion,inhalation, or dermal contact. However, no data for off-siteenvironmental media were available to indicate whether these exposure

- pathways pose a public health concern.

Page 4

4. The presence of contamination in off-site areas used for growing cropsor raising animals could result in bioaccumulation in consumable ,,plants or animals. No data were available to indicate if this pathwayposes a public health concern.

5. Results of on-site ambient air monitoring showed the presence ofelevated concentrations of volatile organic chemicals (VOCs). Thepresence of VOCs at the site was substantiated by the detection ofVOCs in leachate samples and by historical accounts that described thedisposal of paints, solvents, sludges, and the like. On-sitepersonnel and off-site residents could be exposed to VOCs that escapefrom the landfill to the ambient air. Monitoring of on-site andoff-site ambient air samples is needed to identify and quantitate thepotential air contaminants.

6. Historical accounts indicated that municipal wastes were disposed ofin the landfill. Since these wastes probably contained biodegradablematter, the anaerobic decomposition of .these materials could generatemethane gas that could migrate off-sita through tha soil intoresidential homes. Tha accumulation of methane in residentialbuildings could causa a fire or explosion hazard. No data orinformation was available to indicate whether any such off-sitemigration had occurred.

PUBLIC HEALTH IMPLICATIONS

Several VOCs (benzene, dichlorobenzene, toluene, dichloroethylene) weredetected in water samples from private walls surrounding tha landfill(Table 3). Tha concentrations of VOCs detected wara below drinking waterstandards recommended by the EPA and would not be expected to causeadverse health effects if the water were used for potable or nonpotablapurposes. However, tha continued migration of contaminants from the sitecould increase off-site groundwater VOC concentrations to levels in excessof acceptable health-based standards.

Bis(2-ethylhexyl)phthalate (BEHP) was detected in a water sampla from oneprivate well and in leachata from tha landfill. BEHP is readily absorbedthrough tha gastrointestinal tract, and it may be absorbed to a limitedextent through tha skin. Oral ingestion of large doses of BEHP bylaboratory animals has produced liver toxicity, developmental toxicity,and reproductive toxicity. Tha proliferation of hepatic peroxisomes inhuman patients who undergo chronic hemodialysis for kidney disease hasbeen attributed to exposure to BEHP that has leached from tha dialysisequipment (3). Tha carcinogenic affect on tha liver of animals that havebeen fed larga doses of BEHP is believed to be related to thisproliferation of hepatic peroxisomes (4).

The concentration of BEHP that was detected in tha watar sampla from aprivate wall would not ba expected to causa any non-carcinogenic toxiceffects. However, long-term use of water from this wall fox potablepurposes could ba of concern because of its potential carcinogenic

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( ' • • .;'-i» ft'»'•'effect. However, this well is reportedly not being used for potablepurposes because of its high metal content and the resulting objectionableodor and taste.

Water samples from private wells also contained elevated concentrations ofmetals, including iron, manganese, and barium. It was not determined ifthe metals were naturally occurring or whether they were derived from thesite. *»

Both iron and manganese are essential nutritional elements in humans, andthey are constituents of a wide variety of foods. Although the ingestionof large doses of these elements may cause toxic effects, this is notlikely to occur through potable water use. Elevated concentrations ofthese metals in water cause an objectionable odor and taste. In addition,high concentrations of these metals also form objectionable precipitatesin water and cause reddish or brownish staining of laundry items.Undesirable aesthetic effects, such as these, have prompted the residentsto use bottled water instead of well water for potable purposes.

An elevated concentration of barium was detected in a water sample fromone private well. Results of experiments in laboratory rats haveindicated that chronic oral exposure to high doses of barium may result inhypertension. However, this effect may be related to a calcium deficiencyin the rats, since no alteration in cardiovascular risk factors was notedin humans exposed to high doses of barium in drinking water (5). Theelevated concentration of barium (2.7 mg/1) that was detected in oneprivate well water sample would not be expected to cause adverse healtheffects because (1) water from this well is not being used for potablepurposes because of taste complaints and (2) the reported concentration ofbarium is below the Maximum Contaminant Level Goal of 5 mg/1 that wasrecently proposed by the EPA (5).

It was reported that residents near the landfill may still be using theirprivate wells for nonpotable, residential uses such as washing, toiletflushing, etc. The concentrations of contaminants that were detected inwater samples from private wells would not be expected to pose asignificant health risk for such nonpotable water uses.

As discussed above in the Human Exposure Pathways Section, human contactwith other on-site and off-site environmental media could result inpotential exposures to chemical contaminants. However, the potentialhealth impact of such exposures can not be assessed at this time becauseof the absence of environmental sampling data.

CONCLUSIONS

This site is of potential health concern because of the risk to humanhealth resulting from possible exposure to hazardous substances atconcentrations that may result in adverse health effects. As noted above,human exposure to chemical contaminants may occur through the use ofcontaminated groundwater for potable purposes. However, residents with

Page 6 i02

contaminated wells are reportedly using bottled water for potable ~purposes. Nonpotable, residential use of water from the wells does not ,,pose a significant health risk. Elevated concentrations of aircontaminants have been detected near the site with field monitoringinstruments, but data are not available to evaluate the potential healthimpact of the inhalation exposure pathway. Other environmental media havenot been adequately characterized for health assessment purposes.

RECOMMENDATIONS

1. A well inventory should be conducted in the area. Wells locateddowngradient of the site should be regularly monitored for organic andinorganic chemical contamination. If contaminants at concentrationsin excess of acceptable health-based standards are detected, the ownershould be advised to obtain an alternate water source or implementsuitable removal treatment.

2. Additional testing of on-site and off-sita environmental media isneeded to determine their potential impact on public health. Themadia that should ba tested includa on-sita and off-sita ambient air;surfaca soils from the landfill, contiguous residential areas, andfarmland; and off-site surface waters.

3. Soil gas probes should be installed at tha periphery of the landfilland regularly monitored to determine if methane and other landfillgases ara migrating off-sita toward residential areas.

In accordance with tha Comprehensive Environmental Response, Compensation,and Liability Act of 1980 (CERCLA), as amended, tha Berkley Products Dumpsita has been evaluated for appropriate follow-up with respect to healtheffects studies. Although there is some indication that human exposuremay have occurred through the consumption of contaminated drinking water,this sita is not being considered for follow-up health studies at thistime because tha magnitude of tha possible exposures is not defined, andno population using tha contaminated water has been determined.

PREPARER OF REPORT

Environmental and Health Effects Assessor: Kenneth G. Orloff, Ph.D.Senior ToxicologistDivision of Health Assessmentand Consultation

ATSDR REGIONAL REPRESENTATIVE

Regional Representative: Charles J. WaltersPublic Health AdvisorFiald Operations BranchRegion III

fl«300103

REFERENCES

1. U.S. Environmental Protection Agency Hazard Ranking System packet,October 14, 1987.

2. NUS Corporation, Site Inspection of Berkley Products Dump,March 5, 1986.

3. Agneta E. Canning, Ulf Brunk, and Gustav Dallner, Phthalate Esters andTheir Effect on the Liver, Hepatology, 4(3) pages 541-547 (1984).

4. D. Turnbull and J. V. Rodricks, Assessment of Possible CarcinogenicRisk to Humans Resulting from Exposure to Di(2-ethylhexyl)phthalate,Journal of the American College of Toxicology, 4(2) pages 111-145(1985).

5. Federal Register, Volume 57, Number 97, pages 22073-22074, Monday,May 22, 1989.

peg°8 fltsoo i oc,

APPENDIX C -SITE INSPECTION DATA

At 3 00106

BERKLEY PRODUCTS DUMP - SI DATA SUMMARY

MAPPED SAMPLING LOCATIONS

Map Number Location Description

1 Rudisill Well

2 Background (soil)

3 Charles Bewley Sr. Well

4 Wet Area

5 Burn Pit

6 Barren Area

7 ' South Seep - soil

7 South Seep - leachate

3 Bast Seep

9 Sawyer Well

10 Dead Tree

11 Charles Bewley Jr. Well

12 Dennis Bewley Well

13 Shupp Well

14 Dennebecker Well

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