FINAL CLOSE OUT REPORT

For2071787

BERKLEY PRODUCTS COMPANY DUMP SUPERFUNDSITE

PAD980538649

WEST COCALICO TOWNSHIP

LANCASTER COUNTY, PENNSYLVANIA

September 2006

Prepared by:Environmental Protection Agency

Philadelphia, Pennsylvania

Approved by: Date:

>/dCDonald S. Welsh, Regional Administrator,U.S. EPA, Region III

Table of Contents

I. Introduction 1II. Summary of Site Conditions ?. 1

Background 1Remedial Investigations/Feasibility Study 3ROD Findings 4Remedial Construction Activities 5Community Relations Activities 8Site Redevelopment ..9

III. Demonstration of Cleanup Activity Quality Assuranceand Quality Control 9

IV. Monitoring Results 9V. Summary of Operation and Maintenance .10VI. Summary of Remediation Costs 11VII. Protectiveness 11VIII. Five Year Review 12XI. Bibliography 12

s

Final Close Out ReportBerkley Products Company Dump Superfund Site

West Cocalico Township, Lancaster County, Pennsylvania

I. INTRODUCTION

This Final Close Out Report (FCOR) documents that the U.S. Environmental ProtectionAgency (EPA) completed all response actions for the Berkley Products Company DumpSuperfund Site (Site) PAD980538649 in accordance with Close Out Procedures forNational Priorities List Sites (OSWER Directive 9320.2-09A-P).

II. SUMMARY OF SITE CONDITIONS

Background

The Berkley Products Company Dump Site (Site) is located one and a half milesnortheast of Denver, Pennsylvania, in West Cocalico Township, Lancaster County(Figure 1). Also known as Schoeneck Landfill, the Site is east of Wollups Hill Road,north of Swamp Bridge Road

The Site is approximately 1,000 feet west of Cocalico Creek. The headwaters ofCocalico Creek are in the valley south of South Mountain near Blue Lake. This valley islocated a few miles north of the Site. Conestoga Creek, along with its tributaries, MuddyCreek, Little Conestoga Creek, and Cocalico Creek, drains the northeastern and north-central portion of Lancaster County and eventually enters the Susquehanna River.Seasonally, wet springs located immediately north of the Site discharge into CocalicoCreek to the north. On the southern side of the Site, a seep was located on the slope ofthe landfill material. The seep was related to rain events.

The land use in the immediate vicinity of the Site is residential in nature. The Site is neardense woods and several single family homes. A few open areas have been convertedinto farm land by the local residents

The Site was used as a municipal waste dump from approximately 1930 until 1965. In1965, the Lipton Paint Company (Lipton), a subsidiary of Berkley Products Company,purchased the property. The operation continued to receive household trash fromneighboring communities as well as paint wastes from Berkley Products Company. Theproperty was closed by Lipton due to a lack of available fill area, and was covered withsoil. Then, in September 1970, the property was sold to private owners and has beenused as a residence since.

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

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REFERENCE:4000 BA5E MAP IS A PORTION OF THE U.S.G.S. 7.5

MINUTE TOPOGRAPHIC SERIES WOMELDORF, PAAND EPHRATA. PA QUADRANGLES. DATED: 1955

1956, PHOTOREVISED: 1969, 1977 & 1969.1974. PHOTOINSPECTED: 1984 & 1982. SCALE:1" = 2000', CONTOUR INTERVAL IS 20 FEET.

SCALE IN FEET

CONFIDENTIAL - ALL RIGHTS 3ESERVED - PROPERTY OF

0805

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URSPITTSBURGH. PENNSYLVANIA 15205

2004 ANNUAL REPORTSITE LOCATION MAP

BERKLEY PRODUCTS LANDFILL WEST COCALICO TWP.. LANCASTER CO.. PACLIENT; PA DEPT. OF ENVIRONMENTAL PROTECTION | JOB NUMBER: 41785883

AS SHOWNFIGURENUMBER 1

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XDuring the period from 1965 to 1970, different sources estimate that the dump receivedfrom 650 to 40,000 gallons of paint wastes from Berkley Products Company. Thesewastes included primarily pigment sludges and wash solvents. EPA has learned that thesolvents were sometimes used to burn the household trash and that the sludges weredisposed of in five gallon pails. Information gathered about the final years of operationof the Site indicates that the municipal trash was dumped to the south of the access road,toward the hillside, while the paint wastes were deposited in the northern part of thedump. '

The Berkley Products Company produced paints and varnishes with solvents, ethylcellulose resin and pigments with lead oxide and lead chromate. The solvents includedtoluene, xylene, aliphatic naphthas, mineral spirits, methyl ethyl ketones, methyl isobutylketones, ethyl acetate, butyl acetate, glycol ether, butyl celasol, methyl alcohol andisopropyl alcohol.

This Site was originally investigated by the Pennsylvania Department of EnvironmentalResources (PADER) in 1984. hi March of that year, PADER completed a PotentialHazardous Waste Site Identification form, and the Site was included on EPA's CERCLIS,a list of potentially hazardous waste sites. A Preliminary Assessment (PA) was alsocompleted in 1984, by EPA, and the Site was scheduled for further investigation pursuantto the Comprehensive Environmental Response, Compensation and Liability Act, asamended, (CERCLA), 42 U.S.C. §§9601 et seq.

In July 1984, EPA collected field samples and the results were presented in a SiteInvestigation (SI) report dated March 5,1986. The information from the SI was used toscore the Site using the Hazard Ranking System. The Site was nominated for theNational Priorities List (NPL) of Superfund sites in 1986 with a score of 30.00 and wasfinalized as an NPL site in March 1989. The regulations enacted pursuant to CERCLAgenerally require that a Remedial Investigation and Feasibility Study (RI/FS) beconducted at each NPL site and subsequently, a remedial response action selected toaddress any problems identified.

Remedial Investigation/Feasibility Study

EPA initiated the RI/FS in 1990 to identify the types, quantities and locations ofcontaminants, to evaluate the potential risks, and to develop and evaluate remedial actionalternatives to address the contamination problems at this Site. A CERCLA removalaction was completed at the Site in May 1992 to address some preliminary findings of theRI. During the field investigation of the RI, buried drums containing paint wastes wereuncovered in the northeastern portion of the Site. This area was excavated, and 59 drumswere overpacked and removed. An additional seven drums were overpacked andremoved from the southern slope of the landfill. A 35-foot-long by 15-foot-deepexploration trench uncovered no additional drums. The wastes were classified asPolychlorinated Biphenyl (PCB) flammable liquids, solids, and paint solvents.

1 sThe field investigations, data analysis and evaluation of alternatives that comprise theRI/FS were completed in June 1996 for the Site.

ROD Findings

The major objectives of the remedy is to consolidate the landfill materials, contain theSite by capping the landfill to prevent direct contact and to significantly limitcontamination leaching into groundwater, thereby reducing contaminant migration. Theremedy includes monitoring wells between the landfill and downgradient residents to actas early warning system to ensure that the residential wells remain uncontaminated.Institutional controls to restrict any new wells in the contaminated zone are required.

On June 28,1996, EPA issued a ROD for the Site which required the followingcomponents:

• Pre-design investigations and activities• Site preparation• Consolidation of landfill wastes• Site grading• Cover system placement, with the following components as determined necessary

for compliance with the relevant sections of Pennsylvania's Hazardous WasteRegulations:

- Subgrade- Gas vent system- Barrier layers- Drainage layer- Top layer (vegetated)

• Security fencing• Removal actions as determined to be necessary during consolidation activities,

and to be conducted in compliance with all state and local laws, to the extent notinconsistent with federal laws

• Erosion control measures• Long-term monitoring to include groundwater, surface runoff, leachate spring and

seep monitoring (annual), residential well monitoring (semi-annual) andmonitoring wells (quarterly)

• Institutional controls to restrict new well installation in the contaminated zone• Long-term operation and maintenance of the remedy• Five-year reviews

The remedy involves containment of the landfill materials and long term monitoring ofthe groundwater. The wells are monitored once a year to ensure protectiveness of theremedy, but no specific clean up goals or standards were required in the ROD, because agroundwater restoration remedy was not selected.

XRemedial Construction Activities

A CERCLA removal action was completed at the Site in May 1992 to address somepreliminary findings of the RI. During the field investigation of the RI, buried drumscontaining paint wastes were uncovered in the northeastern portion of the Site. This areawas excavated, and 59 drums were overpacked and removed. An additional seven drumswere overpacked and removed from the southern slope of the landfill.

The RD included installation and sampling of nine (9) new multi-port monitoring(Westbay) wells for the development of the long term monitoring program. The welllocations are designated as MW-6 through MW-14. The well locations are shown inFigure 2. Soil borings and test pits were also conducted during the RD to determine theexact extent and volume of the Site wastes to be consolidated into the landfill portion ofthe Site.

During the design of the cap, it was determined that the volume of the waste to beconsolidated exceeded the total available volume of the final landfill when capped inaccordance with appropriate regulatory standards. Additionally, the naturally steepinclines of the surrounding terrain limited the ability to increase the elevation or extendthe area of the cap without exceeding final slope requirements. Therefore on August 20,1999 an Explanation of Significant Differences was issued which revised the remedy.

The potential for removing materials found on the Site had been contemplated in theROD, but because of the magnitude of the volume and associated costs, the offsitedisposal of the materials was considered a significant difference from the remedy, and anExplanation of Significant Differences (BSD) was issued August 20,1999.

Remedial Action (RA) commenced on September 30, 1999. Following work plandevelopment and approval, a request for bids was issued, the responses were evaluatedand the construction sub-contract was awarded on April 7, 2000 to Grace Industries Inc.On-Site construction presence started May 24, 2000, with mobilization, surveying, andclearing and grubbing activities. During construction of the cap for the landfill, EPA andPADEP decided not to extend the casing for wells MW-2S, MW-2I, MW-2D, MW-3S,MW-3I, MW-4S and MW-4I through the cover. These wells were decommissioned andremain under the landfill cover. Figure 3 shows the capped area, gas vents and locationof the sediment traps as constructed.

Unanticipated problems were encountered during construction causing additional work,and impacts to the schedule and budget. The presence of extensive deposits of largestone in the excavation areas caused work to be delayed until special equipment wasprocured to handle and break the stone into usable size. The wastes shipped off-site wereheavier than initially estimated, causing a significant increase in disposal costs. As thelandscape was changed from a rough, forested hillside to a smooth, denuded slope, thepeculiar local rainfall patterns (short thunderstorms that drop several inches per hour)caused the standard erosion controls to be overwhelmed, flooding the surroundingproperties. The design of the Site's southern slope was revised to minimize the impacts

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of the storms and additional erosion control matting was planned and installed acrossmost areas of the Site. Additionally, a new storm water management system wasdesigned and installed in the township road directly south of the Site to capture and directthe excess storm flow, and repairs were made to address those neighboring properties thatwere damaged. These additional tasks were.incorporated into the RA schedule andcompleted during the work period. Construction activity was virtually continuous duringthe construction period until the final vegetative layer was placed and seeded; seedingwas completed August 10, 2001.

Community Relations Activities

To announce the availability of and obtain public input on the proposed plan, EPA held apublic comment period from April 8, 1996, to May 7, 1996. During the comment period,on April 17,1996, EPA held a public meeting to provide citizens with information aboutthe Site and the proposed clean-up methods. The public meeting also provided anopportunity for citizens to ask questions about or comment on the Site and the proposedclean-up methods. EPA announced the public comment period and public meeting in anewspaper display advertisement placed in the April 8, 9, and 15, 1996, editions ofLancaster New Era and the Lancaster Intelligencer. EPA also announced the publiccomment period and meeting in a four-page fact sheet summarizing the proposedremedial action plan which was sent to those parties on EPA's site mailing list.

Interest in the Berkley Products Superfund Site was steady throughout its history. Theresidents most interested in the Site tend to be those living near the site. Most areacitizens are concerned primarily about the contaminants at the Site, previous Site workconducted by EPA, and the methods proposed to clean up the Site. Many citizens supportEPA's preferred clean-up method.

A Five Year Review was completed in August 2005 and a notice was published in theLancaster Intelligencer on May 31,2005 announcing that the review was to be conductedand that any comments and concerns that the community may have regarding the siteshould be submitted to EPA. EPA received one call from a local paper for informationabout the Site and plans for the Five-Year Review. No local residents or public officialssubmitted comments.

One community interview was conducted by EPA and PADEP at the West CocalicoTownship offices with Ms. Debbie Schultz, the administrative assistant to the TownshipAdministrator. EPA began by discussing the Five-Year Review process and purpose ofthe review. EPA presented the findings of the most recent round of samples taken fromthe groundwater monitoring and residential wells and the conclusion that the residentialwells are free of any contamination from the Site but for a few low level detections ofthree contaminants in the sentinel wells between the Site and the residences. There hasbeen little concern about the Site generated from the ad in the local newspaper about theFive-Year Review, but EPA discussed concerns raised by one resident about the overflowfrom the sediment pond No.l. PADEP reconstructed the overflow drains in the spring of

2006 and reassured the Township that it would continue to monitor the overflow duringheavy rainfall events.

Ms. Schultz was pleased that EPA and PADEP were making the effort to keep the localgovernment informed and expressed interest in reading and providing copies of the Five-Year Review to local officials and residents.

Site Redevelopment

The Site areas have been capped and do not allow for future development. Institutionalcontrols required in the ROD have been implemented by an Access Order established onJune 8, 2001 which requires that the property owner shall not interfere with the operation,alter or disturb the integrity, of any structures or devices now or hereinafter built,installed or otherwise placed by EPA and/or its Representatives on the .Site or Property.

III. DEMONSTRATION OF CLEANUP ACTIVITY QUALITY ASSURANCEAND QUALITY CONTROL

Activities at the Site were performed consistent with the ROD, the BSD and therespective RD and RA work plans, reviewed by EPA and PADEP and approved by EPA.The RD reports included appropriate EPA and State quality assurance/quality control(QA/QC) procedures and were followed by the contractor during construction.

The QA/QC program used throughout the RA was sufficiently rigorous and inconformance with EPA and PADEP standards. EPA and PADEP determined that allanalytical results are accurate to the degree necessary to assure satisfactory execution ofthe RA and consistency with the ROD, the ESD and RD plans and specifications. This isdocumented in the Berkley Products RA Report - Submitted September 2002 by TetraTech NUS, Inc. and approved by EPA on September 27, 2002.

IV. MONITORING RESULTS

Groundwater Quality Monitoring

Since the remedy was constructed, residential wells have been sampled multiple times forvolatile organic compounds (VOCs), semi-volatile organic compounds (SVOCs), andpolynuclear aromatic hydrocarbons (PAHs). The 2004 and 2005 groundwater data showno concentrations above MCLs or at risk levels of concern (cancer or hazard index) inresidential wells.

Conventional monitoring wells, MW-1S, MW-1I, MW-5S, MW-5I, and MW-5D werealso sampled for VOCs, SVOCs, and PAHs. The 2004 and 2005 groundwater data showno concentrations above MCLs or at levels of concern in these monitoring wells.

Westbay wells, which are constructed to isolate discrete water bearing fractures, weresampled during the spring of 2004 and the spring of 2005. Monitoring wells 6, 7, and 8showed organic chemicals above MCLs [bis(2-ethylhexyl)phthalate in MW-6

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trichloroethene (TCE) in MW-7, and benzene in MW-8]. Wells 6, 7, and 8 are betweenthe landfill and residential wells. Table 1 summarizes this data.

TABLE 1

Chemical

TCE

benzene

biz(2-ethyhexyl)phthalate

Well

MW-7

MW-8

MW-6

ConcentrationSpring. 2004

5.5ug/L

15ug/L

13ug/L

ConcentrationSpring 2005

4ug/L

15 ug/L

not sampled forSVOCs

MCL

5 ug/L

5 ug/L

6 ug/L

Lead in MW-9 slightly exceeded its Action Level in spring 2005, but it is not Site relatedbased on concentrations of lead found in landfill monitoring wells during the RI/FS.Even though most of the monitoring wells exceed initial risk-based screeningconcentrations for some metals, these are believed to be naturally occurring.

V. SUMMARY OF OPERATION AND MAINTENANCE

The first round of surface water and groundwater monitoring occurred in October 2002.After this sampling event, sampling the surface water and springs was discontinuedbecause no contaminants were detected in the seeps and creek north of the landfill andupgradient from the Site. Sampling the leachate seep from the landfill was alsodiscontinued because the cover eliminated the seep.

Operation and Maintenance (O&M) activities were transferred to the PennsylvaniaDepartment of Environmental Protection (PADEP) after this sampling event since therewas no responsible party for the Site. URS Corporation (URS) was contracted in June2003 by the PADEP to complete the post-closure operations and maintenance. Quarterlysite inspections and monitoring were initiated in 2003.

A number of monitoring wells are located at the Site and between the landfill and theresidential wells. There are approximately 14 residential wells that are also monitoredunder the O&M plan.

Groundwater monitoring and sampling was conducted during the spring of 2004, the fallof 2004, the spring of 2005 and the spring of 2006. Activities performed by URS alsoinclude inspections of both sediment basins.

These wells are monitored once a year by PADEP to insure protectiveness of the remedy,but no specific clean up goals or standards were required in the ROD or BSD because agroundwater restoration remedy was not selected. The purpose of the monitoring is toassure that unacceptable risks do not develop in the future.

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\Mowing the vegetation on the cap is conducted under a separate contract issued by *PADEP on a yearly basis.

VI. SUMMARY OF REMEDIATION COSTS

The ROD and BSD estimates of remediation costs were: •

Record of Decision

Capital Cost: $4,336,000Annual O&M Cost: $306,200Total Present Worth: $8,200,000 over 30 years

Explanation of Significant Differences

Capital Cost: $1,100,000 (in addition to the ROD costs)

The actual total cost of the Remedial Action contractor for the Fund Lead RemedialAction when completed was:

$7,253,305.43

VII. PROTECTIVENESS

This Site meets all the completion requirements as specified in OSWER Directive9320.2-09-A-P, Close Out Procedures for National Priorities List Sites.

The Site remedy is protective of human health and the environment in the short-termbecause the remedial action as outlined in the ROD and BSD was implemented and allimmediate threats at the site have been addressed.

Long-term protectiveness of the remedial action will continue to be verified by PADEPthrough the long-term monitoring program to fully evaluate possible migration of thecontaminant plume from the Site towards the creek and residential areas. Current dataindicates that contamination is primarily contained on-site. Downgradient monitoringwells display low levels of contamination which are expected to continue to diminish,and residential wells remain uncontaminated.

Institutional Controls

The institutional controls to restrict new well installation in the contaminated zone wereestablished on June 8, 2001 by an Access Order issued during the construction phase ofthe remedial action and are still in effect. The Access Order required that the propertyowner shall not interfere with the operation, alter or disturb the integrity, of any structuresor devices now or hereinafter built, installed or otherwise placed by EPA and/or itsRepresentatives on the Site or Property. This effectively prevents any well installationthrough the cap, which covers the contaminated zone. Maintenance of the institutional

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control is part of the O&M activities conducted by PADEP pursuant to the StateSuperfund Contract (SSC).

VIII. FIVE YEAR REVIEW

EPA has already conducted a statutory Five-Year Review for the BerkleyProducts Company Dump Site in August 2005. Since the remedies selected forthe Site allow hazardous substances, pollutants, or contaminants to remain onsiteabove levels that allow for unlimited use and unrestricted exposure, statutoryFive-Year Reviews are required. These reviews will be conducted pursuant toCERCLA section 121 (c) and as provided in the current guidance on Five-YearReviews. The next Five-Year Review will be completed by August 2010.

IX. BIBLIOGRAPHY

U.S Environmental Protection Agency (June 1996). "Superfund Record ofDecision: Berkley Products Company Dump Superfund Site."

U.S Environmental Protection Agency (August 1999). "Explanation ofSignificant Differences: Berkley Products Company Dump Superfund SiteOperable Unit Two."

U.S Environmental Protection Agency (September 2001). "SuperfundPreliminary Close-Out (PCOR) Report Berkley Products Company DumpSuperfund Site."

U.S Environmental Protection Agency (August 2005). "Five-Year ReviewReport: Berkley Products Company Dump Superfund Site."

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