five-year review reportlindane dump superfund site harrison township allegheny county, pennsylvania...

Five-Year Review Report

Lindane Dump Superfund Site Harrison Township

Allegheny County, Pennsylvania

EPA ID#: 980712798

PREPARED BY: U.S. Environmental Protection Agency

Region III Philadelphia, Pennsylvania

Table of Contents

List of Acronyms .......................................................iiiExecutive Summary ......................................................iv Five-Year Review Summary Form ..........................................v I. Introduction .....................................................1 II. Site Chronology ..................................................2 III. Background .......................................................3

Physical Characteristics and History of Contamination.......3 Initial Response ...........................................3 Basis for Taking Action ....................................3

IV. Remedial Actions .................................................4 Remedy Selection ...........................................4 Remedy Implementation ......................................4 System Operation and Maintenance ...........................5

V. Progress Since the Last Five-Year Review .........................5 VI. Five-Year Review Process .........................................5

Administrative Components...................................5 Community Involvement ......................................6 Document Review ............................................6 Data Review ................................................6 Site Inspection and Interviews .............................9

VII. Technical Assessment .............................................11 VIII. Issues ...........................................................12 IX. Recommendations and Follow Up Actions ............................13 X. Statement on Protectiveness.......................................13 XI. Next Five-Year Review.............................................14

Tables Table 1 - Chronology of Site Events ....................................2 Table 2 - Treatment System Effluent Requirements .......................8 Table 3 - Issues .......................................................12 Table 4 - Recommendations ..............................................13

Attachment Attachment 1 - Table 5 - Applicable or Relevant and Appropriate Requirements

List of Acronyms

BHC Benzene Hexachloride

CERCLA Comprehensive Environmental Response, Compensation, and LiabilityAct CFR Code of Federal Regulations

COA Consent Order and Agreement EPA U.S. Environmental Protection Agency FS Feasibility Study GCL Geosynthetic Clay Layer GDL Geocomposite Drainage Layer HOPE High Density Polyethylene HMI Human-Machine Interface NCP National Contingency Plan NPL National Priorities List O&M Operation and Maintenance PADEP Pennsylvania Department of Environmental Protection PLC Programmable Logic Controller RA Remedial Action RAO Remedial Action Objective RD Remedial Design RI Remedial Investigation ROD Record of Decision TOC Total Organic Carbon TSS Total Suspended Solids VOC Volatile Organic Compound

Executive Summary

The remedy for the Lindane Dump Superfund Site in Harrison Township, AlleghenyCounty, Pennsylvania included: installation of a multilayer combination clayand soil cap on approximately 14 acres of the upper portion of the Site andapproximately 4 acres of the lower portion of the Site to reduce theinfiltration of water into the fill area, upgrading the existing leachatecollection and treatment system to provide better treatment of contaminatedleachate and shallow ground water, implementation of institutional controls,installing a security fence around the lower portion of the Site, monitoringground water, and implementing a Site maintenance program. The Site achievedconstruction completion status when the Preliminary Close Out Report wassigned on September 27, 1999. The trigger for this five-year review was theactual RA on-site construction start date May 5, 1998.

The assessment of this five-year review found that the remedy was implementedin accordance with the requirements of the Record of Decision (ROD) and thatthe remedy is protective of human health and the environment, and in theinterim, the offsite migration of contaminated leachate has been controlled bythe successful operation of the collection and treatment system. Effluent fromthe water treatment system also achieves the discharge standards. Theimmediate threats have been addressed and the remedy is protective of humanhealth and the environment.

Five-Year Review Summary Form

SITE IDENTIFICATIONSite name: Lindane Dump Site

EPA ID: 980712798Region: State: PA City/County: HARRISON TWP., ALLEGHENY

SITE STATUS

NPL status: / Final ^ Deleted ^ Other (specify).

Remediation Status (choose all that apply): ^ Under Construction ^Operating Complete

Multiple Ous?* ^ YES / NO Construction completion date: 9/27/99

Has site been put into reuse? /YES ^ NO (THE UPPER PORTION is A COMMUNITY PARK)REVIEW STATUS

Lead agency: / EPA ̂ State(specify)

Tribe ^ Other Federal Agency

Author name: Donna Santiago

Author title: Remedial Project Manager Author Affiliation: U.S. EPA RegionReview period: 2/02 • 9/03

Datefs) of site inspection: 2/22/02, 7/8/02,3/17/03

Type of review: Post-SARA / Pre-SARA ^ NPL-Removal onlyNon-NPL Remedial Action Site _^ NPL State/Tribe-lead

.-_ Regional Discretion

Review number: / 1 (first) 2 (second) ^ 3 (third) Other (specify).

Triggering action:/ Actual RA Onsite Construction ^ Actual RA Start at OU# ___

Construction Completion ^ Previous Five-Year Review Report______________•»• Other (specify) ________________

Due date (five years after triggering action date): May 2003* ("OU" refers to operable unit.)** (If a contractor writes the report, the author name should be written as, "RPM w/ (contractor name) assistance.)"* (Review period should correspond to the actual start and end dates of the Five-Year Review in WasteLAN.)

Lindane Dump Superfund SiteFive-Year Review September 2003 f l R 3 0 3 7 7 3

Lindane Dump Superfund Site Harrison Township

Allegheny County, Pennsylvania Five-Year Review Report

I. Introduction

The purpose of the Five-Year Review is to determine whether the remedy at asite is protective of human health and the environment. The methods, findings,and conclusions of reviews are documented in Five-Year Review reports. Inaddition, Five-Year Review reports identify issues found during the review, ifany, and identify recommendations to address them.

The Environmental Protection Agency ("the Agency" or "EPA") is preparing thisFive-Year Review report pursuant to the Comprehensive Environmental Response,Compensation, and Liability Act (CERCLA) §121 and the National ContingencyPlan (NCP). CERCLA § 121 states:

If the President selects a remedial action that results in any hazardoussubstances, pollutants, or contaminants remaining at the site, thePresident shall review such remedial action no less than each five yearsafter the initiation of such remedial action to assure that human healthand the environment are being protected by the remedial action beingimplemented. In addition, if upon such review it is the judgment of thePresident that action is appropriate at such site in accordance withsection [104] or [106], the President shall take or require such action.The President shall report to the Congress a list of facilities forwhich such review is required, the results of all such reviews, and anyactions taken as a result of such reviews.

The Agency interpreted this requirement further in the NCP; 40 Code of FederalRegulations (CFR) §300.430(f)(4)(ii) states:

If a remedial action is selected that results in hazardous substances,pollutants, or contaminants remaining at the site above levels thatallow for unlimited use and unrestricted exposure, the lead agency shallreview such action no less often than every Jive years after theinitiation of the selected remedial action.

EPA Region III conducted this Five-Year Review of the remedy implemented atthe Lindane Dump Superfund Site, ("Site") in Allegheny County, Pennsylvania.This review was conducted by the Remedial Project Manager for the entire Sitefrom February 2002 through September 2003. This report documents the resultsof the review.

This is the First Five-Year Review for the Lindane Dump Superfund Site. Thetriggering action for this statutory review is the actual remedial actiononsite construction start date of May 5, 1998. The Five-Year Review isrequired because hazardous substances, pollutants, or contaminants remain atthe Site above levels that allow for unlimited use and unrestricted exposure.

II. Site Chronology

The table below lists the chronology of events for the Lindane Dump Site.

Table 1: Chronology of Site Events

1850-1959 The Site was used by Pennwalt fordisposal of wastes from mining,chemical manufacturing and electricalgeneration.

1965 Property was sold to AlleghenyLudlum.

1965-1986 Allegheny Ludlum used the Site fordisposal of wastes from steelmanufacturing and buildingdemolition.

1972 Allegheny Ludlum donated the parkarea to Harrison Township.

1976-1977 The park area was developed into theALSCO Community Park.

1981-1983 Environmental studies were completedby Pennwalt.

Sept. 8, 1983 Site was placed on the NationalPriorities List (NPL).

1987-1989 Remedial Investigation was completedby Pennwalt in accordance with aPADEP consent order.

1990-1992 Feasibility Study completed by ElfAtochem.

March 31, 1992 EPA issued a Record of Decision.

April 1993 Elf Atochem entered into ConsentDecree for Remedial Design andRemedial Action.

1994-1997 Elf Atochem completed the RemedialDesign.

1998-1999 Elf Atochem completed construction ofthe approved Landfill Cap and theLeachate/Shallow GroundwaterCollection and Treatment System.

Sept. 27, 1999 Preliminary Close-Out Report signed.

1999-Present ATOFINA continues to perform theOperation and Maintenance (O&M), andmonitoring activities at the Site.

III. Background

Physical Characteristics and History of Contamination

The Lindane Dump Superfund Site (Site) is located on Spring Hill (Natrona)Road in Harrison Township, Allegheny County, Pennsylvania. This Site isapproximately 20 miles northeast of Pittsburgh. The Site encompasses twoareas: the Upper and Lower Project Areas. The Upper Portion of the Site is theAlsco Community Park which consists of 14.3 acres zoned as recreationalproperty and is owned and maintained by Harrison Township, Pennsylvania. Theproperty immediately to the south of the Park (designated as the "LowerProject Area") consists of approximately 47.5 acres, and is owned by theAllegheny Ludlum Corporation.

Industrial wastes from manufacturing operations were placed on the Site byvarious companies from 1850 to the mid-1980s. Pennwalt used the Site fordisposal of wastes from mining, chemical manufacturing and electricalgeneration. Allegheny Ludlum used the Site for disposal of wastes from steelmanufacturing and building demolition. The contaminants of concern at the Siteinclude volatile organic compounds (VOCs) and organic pesticide constituentsin groundwater and leachate.

Initial Response

Regulatory agencies performed initial Site investigations during the period of1976 through 1981. In 1983, the Site was included on the National PrioritiesList (NPL). Pennwalt completed environmental studies at the Site during theperiod of 1981-1983, and initiated an interim remedial action in 1984. Theinterim measure, a collection and treatment system for leachate and shallowgroundwater from the project area was constructed in 1984 and operated untilthe long-term treatment system came online in 1999. The interim treatmentsystem consisted of pH adjustment and activated carbon adsorption of organicconstituents.

Basis for Taking Action

After entering into a formal Consent Order and Agreement (COA) with thePennsylvania Department of Environmental Protection (PADEP), a supplementalremedial investigation (RI) and engineering feasibility study (FS) wereconducted and reports were subsequently approved by the EPA and PADEP. Basedupon the recommendations in the FS, the EPA issued a Record of Decision (ROD)which described the key components of the remedial action to be completed.

The risks posed by the Site came from potential exposure to contaminatedsoils, ground water and leachate. Based on the risk assessment analysis for

increased risk for cancer and the hazard index, there was no risk scenariowhich would warrant EPA to trigger a remedial action at the Lindane Dump Site.Under worst case scenario, the greatest increased risk for cancer at the Sitefor a child who ingests water from the seep flows at the Site, had acorresponding risk of 7x10- 5. This risk scenario did not exceed the lowestacceptable risk level which EPA generally used when determining if a remedialaction should be undertaken. However, if at any Superfund Site, it isdetermined that there is increased risk of cancer which falls between 1x10- 6and 1x10- 4 and human health could be threatened by any contaminants whichexceed other health based criteria, then EPA may determine that a remedialaction is warranted at a Site. For the Lindane Dump Site, potential healthbased threats to humans could occur as a result of Maximum Contaminant Level(MCLs) exceedences that were found in the ground water. During the RemedialInvestigation, MCL exceedences were observed in ground water for benzene andlindane (gamma-BHC). Based on these MCL exceedences, which EPA believed couldpose a threat to human health sometime in the future, a remedial action at theLindane Dump Site was considered warranted by EPA to remediate the threat.

IV. Remedial Actions

Remedy Selection

The ROD was issued March 31, 1992. In April 1993, the Consent Decree wasissued that summarized the actions to be taken by Elf Atochem (formerlyPennwalt) to complete the RD and RA phases of the project. The remedyconsisted of installation and maintenance of a multi-layer cap over portionsof the Site, restoration of existing park facilities, installation andmaintenance of a long-term leachate/shallow groundwater treatment system,installation of other institutional controls (including restricted Siteaccess, etc.), and long-term monitoring.

The specific objectives outlined in the ROD for cleanup of the Site were to:

1. Reduce or eliminate the infiltration of water through the fill area inthe upper portion of the Site and a part of the lower portion of theSite.

2. Eliminate any exposure to contaminants contained in the leachate fromthe seeps.

3. Prevent any intrusion or activity which may compromise the integrity ofthe cap and limit access to any area which is not capped.

4. Ensure the effectiveness of the cap and the leachate/shallow groundwater collection and treatment system and to monitor for MCLexceedences.

Remedy Implementation

In May 1998, actual onsite construction of the EPA-approved final remedybegan. Upon mobilization, the Alsco Park was officially closed and existingrecreational area facilities were dismantled and removed.

A key component of the RA consists of the installation and long-term operation

of a multi-layer, clay and soil cap over approximately 18 acres of the Site.The capping project also included installation of permanent stormwatermanagement features (both subsurface and surface drainage features) includinggrass-lined and rip rap swales, a retention basis, and stormwater piping andmanholes.

Once capping was completed, the park facilities were restored. Thesefacilities included installation of two new asphalt tennis courts, two newball fields, a utility building, pedestrian walk, an asphalt parking area, andplanting of 150 new trees.

The second key component of the RA consists of the installation and long-termoperation of a leachate/shallow groundwater collection and treatment system.The new treatment system consists of a new 9,100 square foot building justsouth of the landfill. Leachate from the landfill is collected via a series ofsubsurface trenches and pipes which discharge to a concrete sump. Treatmentsystem components include: equalization, pH adjustment, filtration, airstripping, and carbon adsorption. The treated leachate is discharged to theAllegheny River in accordance with Pennsylvania state discharge requirementspursuant to a National Pollutant Discharge Elimination System (NPDES) permitequivalent.

The Site achieved construction completion status when the Preliminary CloseOut Report was signed on September 27, 1999.

System Operation and Maintenance

ATOFINA (formally Elf Atochem) has performed O&M activities at the long-termtreatment system since it began operation in July 1999. O&M activities includelandfill cap maintenance, treatment system O&M, groundwater monitoring, andsystem inspections. The treatment system is maned 40 hours per week andmonitors the system around the clock via telemetry and a Human-MachineInterface (HMI) system installed in 2000. As part of the O&M of the system,the effluent water, groundwater, and other process stream samples arecollected for analysis.

Analytical and operational data for the system is tabulated and summarized ina monthly report that is submitted by ATOFINA to the EPA. ATOFINA alsoprepares the Annual Post-Remedial Action Monitoring Report that summarizes thesemi-annual landfill inspections, quarterly groundwater monitoring results,and operational data for the year.

V. Progress Since the Last Five-Year Review

This is the 1st Five-Year Review for the Lindane Dump Site.

VI. Five-Year Review Process

Administrative Components Members of the local government in Harrison Township, ATOFINA, and PADEP werenotified of the initiation of the Five-Year Review in February 2002. TheLindane Dump Five-Year Review Team was led by the EPA-Remedial Project Manager(RPM) for the Lindane Dump Site, and the Project Officer from PADEP.

The review team established the review schedule which included:

1. Community Involvement 2. Document Review 3. Data Review 4. Site Inspection, and 5. Local Interviews.

Community Involvement

Activities to involve the community in this five-year review were initiated byinterviewing local residents and businesses of Harrison Township regarding theSite. Interviews were conducted by EPA on February 22, 2002, July 8, 2002 andMarch 17, 2003.

During the interviews, EPA summarized the activities associated with theselected remedy identified in the Lindane Dump Site ROD, activities which haveoccurred at the Site to date and the findings of the Site Inspection.Interviewees were asked for any input on concerns or the protectiveness of theremedy. All residents indicated they were unaware of any problems with theLindane Dump Site. Overall, the community of Harrison Twp. appeared to besatisfied with the response of EPA at the Site.

Following signature on this five-year review, an ad will be placed in a localnewspaper announcing that the First Five-Year Review for the Lindane DumpSuperfund Site is complete, and that the results of the review and the reportare available to the public at the Harrison Township Municipal Building OneMunicipal Drive, Natrona Heights, PA 15065.

Document Review

This five-year review consisted of a review of relevant documents includingthe ROD, the Consent Decree, the Remedial Design documents, the First andSecond Annual Post-Remedial Action Monitoring Reports, monthly ProgressReports, treatment system O&M logs, quarterly groundwater monitoring reports,and semi- annual landfill inspection reports.

Data Review

Groundwater Quality

Groundwater monitoring consists of quarterly groundwater sampling for benzenehexachloride (BHC) and benzene compounds in six monitoring wells and waterlevel measurements in ten additional piezometers. There has been variation inthe concentrations of the BHC compounds in the monitoring wells during thefirst three years of operation of the system. Generally the concentrations ofall constituents have held steady or declined slightly. Of the benzenecompounds monitored, only chlorobenzene has been detected above the 5.0 µg/Ldetection limit in one well location,

Hydraulic Control

Continued monitoring of the water table elevations in the vicinity of theleachate collection system in December 1994, June 2000, and September 2001,

respectively indicates that the system is consistently capturing the leachateand shallow ground water.

In addition to the ground-water samples that are taken quarterly, a watersample is taken from the influent to the Harrison Township Water Authorityplant to monitor for the presence of Gamma-BHC (Lindane). All the samplestaken during the three years of operation of the Leachate/Shallow GroundwaterTreatment system showed that the levels were below the detection limit of0.050 µg/L.

Treatment System Operation/Modification

Physical fouling of the activated carbon was determined to be the cause of thereduction of removal efficiency of the activated carbon during the first 18months of operation of the system. This reduction of efficiency was caused bythe reduction of adsorptive surface on the carbon granules and hydraulicchanneling through the beds caused by the fouling.

Laboratory analysis of the precipitation in the piping and on the activatedcarbon showed that the material fouling the carbon and the piping wasprimarily composed of calcium and phosphate. It was determined that the sodiumhexametaphosphate was changing its molecular form due to the air stripper andwas converting to ortho-phosphate. The ortho-phosphate was then precipitatingout of solution due to the high calcium concentration (hardness) of theinfluent water. The conversion of the hexametaphosphate to ortho-phosphatealso reduced the sequestering ability of the compound resulting in theprecipitation of iron hydroxide.

On July 31, 2000 a full-scale pilot test was initiated to test the result ofreducing the dosage of sodium hexametaphosphate in the system. The dosage wasreduced in steps from approximately 25.5 tons/year initially to 9.13tons/year.

A different sequestering agent, MSW-110, was proposed to be used in lieu ofthe sodium hexametaphosphate. Full-scale pilot testing of the system usingthis new sequestering agent began July 23, 2001. The system has been operatingsince this date at a dosage rate of MSW-110 of approximately 26 mg/L. Thisequates to 1.58 tons/year of MSW-110.

The system has operated since January 2000 without a third changeout ofactivated carbon. Since the last changeout, the BHC concentration in the waterbetween the lead and lag carbon adsorber has been sampled and analyzed on aweekly basis to monitor breakthrough of the bed and decrease the possibilityof the effluent concentration increasing dramatically as it did previously.Based on recent analytical results, it appears that the lead carbon adsorberis not near the breakthrough point.

In 2000, a Human-Machine Interface (HMI) system was installed at the plant toallow remote monitoring of the system. The HMI system consists of a computerrunning an HMI software package (RSView made by Rockwell Software). Thecomputer is attached to the main PLC and the Sand Filter PLC and can becontacted remotely by modem. The HMI software was customized to depict thetreatment system graphically and allow the operator to graphically monitor anyof the information monitored by the PLCs. An additional functionality has been

added to the HMI system to allow the operator to acknowledge and reset themain system shutdown alarm remotely. This has enabled the operator to restartthe system after an alarm call-out from home. The only cause of alarmcall-outs recently has been due to sporadic power outages.

No information concerning the annual costs of O&M was received from ATOFINA.

Treatment System Effluent Monitoring

The Leachate/Shallow Groundwater Treatment System at the Site dischargeseffluent water to the Allegheny River under an NPDES Permit Equivalent. Thewater enters the system, is treated, and is discharged around the clock. Acomposite sampling device collects a 24-hour composite sample of the effluenton a weekly basis. The following table is a summary of the parametersmonitored and the limitations set forth in the NPDES Permit Equivalent:

Table 2 - Treatment System Effluent Requirements

Parameter 24-Hour Maximum Limit Monthly Average MaximumLimit

pH Minimum 6 s.u. 6 s.u.

pH Maximum 9 s.u. 9 s.u.

Total Suspended Solids 40 mg/L 20 mg/L

Alpha-BHC 20 µg/L 10 µg/L

Beta-BHC 20 µg/L 10 µg/L

Delta-BHC 20 µg/L 10 µg/L

Gamma-BHC (Lindane) 20 µg/L 10 µg/L

4,4'-DDT 0.5 µg/L 0.3 µg/L

Benzene 20 µg/L 10 µg/L

BHC Compounds

The BHC concentrations have experienced two periods of higher-than-normalconcentrations since the treatment system came on line in 1999. The firstperiod was after approximately 10 to 12 months of operation. The cause of theelevated concentrations was attributed to the granular activated carbon (GAC)being loaded with organics thus allowing breakthrough of organics. In responseto this increase, the carbon in the lead adsorber was changed out and thefresh unit was put into service as the lag (polishing) adsorber.

The second period of elevated concentrations occurred in 2002. In response tothe elevated concentrations, the carbon in the lead adsorber was changed outand the fresh unit was put back into service as the lag adsorber.

Because the interval between the first and second carbon changeouts was muchshorter than the time leading to the first changeout, it was suspected thatthe adsorbers were not operating properly. After a thorough investigation, itwas determined that the cause of the second period of elevated concentrationswas caused by a combination of factors: physical fouling of the activatedcarbon in the adsorbers and incomplete removal of spent carbon during thefirst carbon changeout.

4.4'- DDT

The only non-BHC pesticide monitored is 4,4'- DDT. This compound was detectedone time in the first three years of operation of the treatment system abovethe method detection limit of 0.1 µg/L. On March 7, 2000, the concentration inthe effluent and the duplicate effluent samples were 0.11 and 0.15 µg/L,respectively. These concentrations are well below the NPDES Permit Equivalentmaximum 24-hour concentration of 0.5 ug/L and the monthly average limit of 0.3µg/L.

Benzene Compounds

Benzene is monitored on a weekly basis. The NPDES Permit Equivalent limitationfor Benzene is 40 µg/L maximum for the 24-hour composite sample and 20 µg/Lmaximum for the monthly average. Benzene has never been detected in thetreatment system effluent above the method detection limit of 5 µg/L.

Inorganic Parameters

The inorganic parameters that are monitored in the effluent on a weekly basisare total suspended solids (TSS) and pH. The NPDES Permit Equivalent limit forTSS is 40 mg/L maximum for the 24-hour composite and 20 mg/L for the monthlyaverage. The pH must be in the range 6.0 to 9.0. The effluent from the systemhas always been within the TSS and pH limitations given. The TSS has typicallybeen below the detection limit of 4.0 mg/L, except during the period wherecalcium phosphate precipitation was an issue. The pH of the system hastypically been between 7.0 and 7.5. The treatment system has not had to usethe pH adjustment system (caustic addition) to raise the pH since it beganoperation.

Flow Rate

The volume of water treated per day varies from approximately 20,000 gallonsper day (gpd) to 65,000 gpd. The periods of highest flow are in the spring,resulting from snowmelt and increased precipitation. When the volume ofleachate/shallow groundwater entering the system increases, the pH of thewater in the system decreases. This matches the expectations of the designersthat the material coming in contact with the water causes the pH to decrease.

Site Inspection and Interviews

Site Inspections were performed by EPA personnel on February 22, 2002, July 8,2002 and March 17, 2003. The purpose of the inspections was to assess theprotectiveness of the remedy, including the presence of a fence to restrictaccess, the integrity of the cap which includes the upper and lower projectareas, the integrity of the monitoring wells, and the overall condition of the

leachate collection and treatment system.

EPA made the following observations during the Site Inspection;

During the Site Inspections no surface depressions or burrow holes were notedon any portion of the landfill cap. The vegetative cover on the landfill capwas properly established, and there was no evidence of erosion. Sideslopeerosion rills which had in the past developed from surface runoff wereadequately filled in with soil and the disturbed areas were seeded and coveredwith erosion matting.

The riprap stone in a ditch which had in the past washed downstream and hadcollected at the entrance to a culvert was excavated from the washout area atthe bottom of the ditch and placed upstream in the washed out areas of theditch.

The main entrance gate to the landfill area was secure. There was no noteddamage to any of the fenced area. The fencing provides adequate protection todeter trespassers and was properly maintained.

There were signs indicating the main entrance to the landfill. Access to theSite is limited to authorized personnel.

All other areas including the air stripping towers and NPDES Discharge Areasappeared to be properly maintained and fully operational. No deficiencies wereidentified.

Additional observations made during the inspections include:

1. Patches of sparse vegetation had been reseeded and fertilized; 2. Dead or damaged trees had been replaced; 3. There was no excessive vegetation or debris in the drainage ditches

which could cause water to pond; 4. Animal burrow holes were filled; 5. Cracks in the tennis court surface and minor damage to the gate to the

tennis court had been repaired.

On February 22, 2002, July 8, 2002 and March 17, 2003, interviews wereconducted with citizens residing near the Site and with area business owners.All residents were notified of the five-year review. The following discussionsummarizes the interviews with the various individuals:

All residents indicated they were unaware of any problems with the LindaneDump Site. Several residents indicated they had resided near the Site for manyyears and were pleased with the Site conditions. Additionally, residentsindicated that the Alsco Community Park is properly maintained and widelyutilized by members of the community. All residents had an overall favorableimpression of the Site. All business owners and residents indicated they wereunaware of any police or fire department activities at the Site and unaware ofany illegal activity. There were no complaints and no identified problems ordifficulties which have impacted the community. Overall, the community ofHarrison Twp. appears to be satisfied with the response of EPA at the Site.

VII. Technical Assessment

Question A: Is the remedy functioning as intended by the decision documents?

Based on a review of decision documents, O&M documents, and groundwatermonitoring sampling results, the remedy is functioning as intended by the ROD.

Landfill Cap

The capping of landfill has achieved the remedial objectives to minimize themigration of contaminants to ground water and surface water and to preventdirect contact with contaminants in soil. Minor issues arise periodically withrespect to the landfill cap such as restricted flow in drainage swales, orsparse vegetation.

Groundwater Treatment System

The long-term leachate/shallow groundwater treatment system has beenoperational since 1999. The system consistently has met the dischargerequirements with two exceptions in 2000. These exceptions were minorexceedances and were due to fouling of the activated carbon. The situation wasidentified and corrected and has not been an issue since.

Modifications to the system have been made over the first four years ofoperation to enhance system performance, increase system monitoringcapabilities, reduce the frequency of alarm call-outs, and optimize chemicalconsumption, etc. These modifications include:

1. Addition of an HMI monitoring system to allow remote monitoring andremote acknowledgment and reset of alarms;

2. Addition of a local weather station to assist in correlation of weatherpatterns to groundwater and treatment system operations data;

3. Change of chemical and dosage rate for the sequestering agent used tominimize iron fouling in the system. MSW-110 made by ONDEO Nalco wassubstituted for the Sodium Hexametaphosphate included in the originaldesign. Chemical usage rates are considerably lower, sludge generationhas decreased greatly, problems caused by fouling in the system havebeen minimized, and operation of the activated carbon adsorbers has beenoptimized.

4. Miscellaneous piping modifications have been made to allow cleanout ofthe pipes and better manage water flow in the building.

Optimization Opportunities

There were no major opportunities for system optimization observed during thisreview.

Question B: Are the exposure assumptions, toxicity data, cleanup levels, andremedial action objectives (RAOs) used at the time of the remedy selectionstill valid?

There have been no changes in the physical conditions at the Site that wouldaffect the protectiveness of the remedy.

Changes in Standards and To Be Considered

There are no changes to note.

The standards outlined in the ROD are still valid. See Attachment I for theapplicable or relevant and appropriate requirements (ARARs) that were includedin the ROD.

Changes in Exposure Pathways, Toxicitv. and Other Contaminant Characteristics

There have been no changes in the exposure pathways, or in the toxicityfactors that could result in changes of the MCLs and therefore in theprotectiveness of the remedy.

Question C: Has any other information come to light that could call intoquestion the protectiveness of the remedy?

Additional information has not been revealed during the performance of thisfirst five- year review that calls into question the protectiveness of theremedy as specified in the 1992 ROD.

Technical Assessment Summary

According to the data reviewed, the Site inspections and the interviews, theremedy is functioning as intended by the ROD and Consent Decree. There havebeen no changes in the physical conditions of the Site that would affect theprotectiveness of the remedy. There have been no changes in the toxicityfactors for the contaminants of concern that were used in the baseline riskassessment, and there has been no change to the standardized risk assessmentmethodology that could affect the protectiveness of the remedy. There is noother information that calls into question the protectiveness of the remedy.The system is operating effectively and as designed.

VIII. Issues

Table 3 - Issues

Issue Currently AffectsProtectiveness (Y/N)

Affects FutureProtectiveness (Y/N)

Minor depressions orfurrows in landfill capdue to channeling wateror small animal burrows

N Y

Loss of vegetation anddegradation of landfillcap

N Y

Excessive vegetation ordebris in the drainageditches caused water topond. Debris is removedand the excessivevegetation is cut backor removed on a regularbasis as needed toaddress this problem

N Y

Animal burrow holes N N

Clogging of the leachatecollection pipingresulting in reducedcapture ofleachate/shallowgroundwater

N Y

IX. Recommendations and Follow Up Actions

Table 4 - Recommendations

Issue ResponsibleParty

Recommendationsand Follow-up

Affects FutureProtectiveness

Current Future

Potential fordevelopmentof patches ofsparsevegetation

ResponsibleParties

Continue toregularlyinspect Sitefor patches ofsparsevegetation, asidentifiedreseed andfertilize

N N

Animalburrows holes

ResponsibleParties

PRPs shallcontinueregularinspection ofcap area foranimal burrowholes have beenidentified andfilled

N N

Potentialcracks in thetennis courtsurface andminor damageto the gate

ResponsibleParties

Perform regularinspections ofthe tenniscourt area andrepair asneeded

N N

Excessivevegetation ordebris in thedrainageditches whichcould causewater to pond

ResponsibleParties

On a regularbasis removedebris and keepexcessivevegetation cutback or removedas needed

N N

X. Statement on Protectiveness

The assessment of this five-year review found that the remedy was implementedin accordance with the requirements of the Record of Decision (ROD) and thatthe remedy is protective of human health and the environment, and in theinterim the offsite migration of contaminated leachate has been controlled bythe successful operation of the collection and treatment system. Effluent fromthe water treatment system also achieves the discharge standards. Theimmediate threats have been addressed and the remedy is protective of humanhealth and the environment.

XI. Next Five-Year Review

The next Five-Year Review will be completed no later than five years after thesignature date of this Five-Year Review.

Attachment One

Attachment 1

Applicable or Relevant and Appropriate Requirements (ARARS) and To BeConsidered Material (TBDs) for the Lindane Dump Superfund Site

The Safe Drinking Water Act, 42 U.S.C. §§ 300f to 300J-26, MaximumContaminant Levels (set forth at 40C.F.R. §§141.61(a) and 55 Fed. Reg.30370) These are enforceablestandards for public water supplysystem.

This requirement is applicable andextraction of groundwater willcontinue until the MCLs are achieved.

40 C.F.R. 61.110-.112 NationalEmissions Standards for Hazardous AirPollutants (Clean Air Act, 42 U.S.C.§§7401) Emission standard for benzenefor equipment leaks relevant andappropriate to air stripping if airstripping produces 1000 megagrams ofbenzene per year or more.

Vapor phase off-gas sampling of theair stripper is conducted on anannual basis. Samples are tested forchemicals of concern to ensure thatair standards are being met.

25 PA Code §§93.1 - 93.9. Dischargelimits for the final effluentdischarge from the leachate treatmentsystem.

Groundwater and leachate are beingtreated to ensure that theserequirements are being met.

25 PA. Code §§93.1 - 93.9.Requirements for treatment anddischarge of contaminated leachateand ground water.

Groundwater and leachate are beingtreated to ensure that theserequirements are being met.

25 PA. Code §§102.1 - 102.24.Establishes standards for thedevelopment, implementation, andmaintenance of erosion andsedimentation control measures toeffectively minimize acceleratederosion and sedimentation.

ARAR met when remedial action wascompleted and will continue to be metthrough O&M.

25 PA. Code §§264.310. Establishescriteria for closure and post closurefor landfills including final soilcover, grading, vegetation,maintenance and monitoring.


25 PA. Code Part 262 Subpart A, B andC. Establishes criteria for offsiteshipments of spent carbon or otherhazardous wastes


25 Pa. Code 263. Establishes criteriafor hazardous waste transporters.


25 PA. Code 264 Subpart B- E, F, Jand K. Establishes criteria formanagement of generated hazardouswaste in containers.


40 C.F.R. Part 268 Establishes landdisposal restrictions including spentcarbon filters from air strippingoperation.


29 C.F.R. §§ 1910.170 Establishescriteria for worker safety in thehandling of hazardous waste.


49 C.F.R. §§171.1-171.16. Establishescriteria for offsite transportationof hazardous waste.


Air Emission Standards for Processvents Subpart AA and Air EmissionStandards for Equipment leaks (40C.F.R. §§264.1032 and 264.1052)


five-year review reportlindane dump superfund site harrison township allegheny county, pennsylvania...

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