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Preliminary Close Out Report SDMS DoclD 2049187

ForMW Manufacturing Superfund Site

Valley Township, Montour County, PA.

I. Introduction

This Preliminary Close Out Report (PCOR) documents that the U.S. EnvironmentalProtection Agency (EPA) completed construction activities for the MW Manufacturing site(the Site) according to the Close Out Procedures for National Priorities List Sites(OSWER Directive 9320.2-09A-P).

EPA and the Pennsylvania Department of Environmental Protection (PADEP) conductedfinal inspections following completion of each Operable Unit (OU) and determined thatthe Potentially Responsible Parties (PRPs) have constructed the remedy according to theRemedial Design (RD) plans with no further response anticipated. EPA and PADEP haveinitiated activities to achieve performance standards and Site completion. The finalinspection of the last OU, OU-5, was performed on May 26, 2005.

II. Summary of Site Conditions

The Site, in Valley Township, Montour County, Pennsylvania, occupies approximately15 acres of land, about 4 miles northwest of Danville, Pennsylvania. The area around theSite is within the Valley and Ridge physiographic province, characterized by a series oflinear, northeast-trending mountains that form alternating valleys and ridges. The Site, inbroad stream valley created by Mauses Creek is about % mile east of the Site near StateRoute 54 (Washingtonville Road). Mauses Creek drains to the south and empties into theSusquehanna River at Danville.

The two small wetland areas are on the MW Manufacturing property, one is near thesouth fence line; the other is near the north fence line. On the east side, towards MausesCreek, larger discrete wetland areas are located outside the former MW Manufacturingproperty.

MW Manufacturing engaged in secondary copper recovery from scrap wire, using bothmechanical and chemical processes, until it ceased operations in the early 1970's. In1972, MW Manufacturing filed for protection under Chapter 11 of the United StatesBankruptcy Code, and Philadelphia National Bank (PNB) acquired the property. TheSite is currently inactive, partly due to legal actions by PADEP (formerly known as thePa Department of Environmental Resources). PADEP records indicate that Mr. AllanLevin of Doylestown, Pennsylvania, proprietor of MW Manufacturing, owned theproperty from about 1966 to 1972.

The chemical recovery process reportedly used a hot vegetable oil bath to melt thepolyvinyl chloride (PVC) plastic insulation away from the scrap copper wire. Chlorinated

MW Manufacturing Preliminary Close Out Report of 15

solvents such as tetrachloroethene (PCE) were then used to remove the residual oil fromthe separated copper. The mechanical recovery process consisted of the shredding ofwire and the generation of "fluff waste. The fluff waste consisted of fibrous insulationmaterial mixed with bits of plastic and copper. The spent chlorinated solvents weredumped at the Site resulting in soil and ground water contamination. The charred plasticinsulation sludge from the solvent process tanks, referred to as "carbon" waste, was piledup at the Site. The carbon waste contained high concentrations of contaminants, includingchlorinated solvents, polychlorinated biphenyls (PCBs) and lead.

Warehouse 81 Inc. acquired the Site in 1976. Subsequently, Warehouse 81 Inc. andDomino Salvage, Inc. formed a limited partnership to recover wire at the Site. Recordsindicate that the only activities conducted by the Warehouse 81/Domino Salvagepartnership were mechanical recovery operations.

The main plant building at the Site (demolished in March/April 2004) consisted of asingle, large building that occupied approximately one acre of the property. The mainplant building concrete floor and foundation remain. Additional Site facilities, includingsmall out-buildings and two above-ground storage tanks, were demolished and removed inMarch/April 2004. A smaller storage building (Butler Building), which occupiesapproximately 2,400 square feet to the south of the former Main Plant Building, wasretained and modified for use as a temporary chemical and material storage building. It ispart of the on-site ground water treatment system (GWTS), in operation as part of theOU-3 remedial action. The remainder of the Site, before implementation of the OU-3and OU-5 remedies, consisted of open land, debris (including exposed piping), piles offluff and a small surface water impoundment. The main portion of the Site is fenced withaccess restricted. The property deed records contain the Consent Decree (CD) betweenEPA and the current owners of the Site property, Michael G. Sabia and Michael G. Sabia,Jr., doing business as Warehouse 81, Limited Partnership. PADEP is currently workingon an order to enforce deed restrictions prohibiting any use of the contaminatedproperties that may affect the protectiveness of the remedy implemented.

The Site, proposed for National Priorities List (NPL) on October 1, 1984, was listed onJune 10, 1986. In August 1988, EPA began a Remedial Investigation (RI) andsubsequently divided the Site into three Operable Units (OUs) as follows:

• OU-1: Ground water cleanup• OU-2: Carbon pile waste• OU-3: Fluff waste and Site soils.

These OU numbers and their descriptions were adopted in the WasteLan. However,during the Remedial Design (RD) OU numbers were assigned in chronological sequenceand additional OUs were added to facilitate RD and Remedial Action (RA) activities.Thus OU numbers were reassigned as follows:

• OU-1: Carbon Pile Waste (completed in 1992; off-site treatment and disposal)

M W Manufacturing Preliminary Close Out Report of 15

• OU-2: Fluff waste and Site soils (Selected Remedy of incineration; OU-2 wasreplaced by OU-5 in 1995)

• OU-3: Ground water cleanup (construction completed in January 2005; operationand maintenance is ongoing)

• OU-4: Public Water Supply (completed in August 1996, and taken over by ValleyTownship 1996)

• OU-5: Fluff waste (previously addressed under OU-2), storage tanks, lagoon waterand sediments, and Site soils (previously addressed under OU-2) (constructioncompleted in June 2005)

• OU-6: Demolition of unsafe portions of the western third of the Main Plant Building(completed in 2001)

In this PCOR, chronological OU numbers are used.

In 1970 and 1971, MW Manufacturing was cited by PADEP for illegally dischargingcopper and waste oils to Mauses Creek. In November 1972, PADEP ordered PNB toremove fluff from the site, but nothing was done. In 1981-1982, PADEP inspected theSite, installed four monitoring wells, collected ground water samples and orderedWarehouse 81 to conduct an investigation. In late 1982, Warehouse 81 retained DunnGeoscience Corporation (Dunn) to evaluate conditions at the Site. Dunn installedadditional ground water monitoring wells and sampled soils and ground water as part ofthis preliminary investigation.

In February 1987, EPA signed a Removal Consent Order and the current owners of theSite, Michael G. Sabia and Michael G. Sabia, Jr., were directed to supply water to aperson living on-site and to keep records of the water supply for 5 years

A PRP search was conducted for the Site. As a result of this search, EPA determined thatthe previous owners and operators of the Site had gone out of business. EPA notified thecurrent owners of the Site, Michael G. Sabia and Michael G. Sabia, Jr., doing business asWarehouse 81 Limited Partnership, of their potential liability at the Site and offered themthe opportunity to conduct the Remedial Investigation/Feasibility Study (RI/FS), but theyelected not to participate. EPA conducted the RI/FS beginning in August 1988.

Following the completion of the RI/FS, EPA divided response actions at the Site into sixOUs. OU-1 addresses the carbon waste that has been left on-site from the copperrecovery process. In March 1989, EPA issued a Record of Decision (ROD), whichselected off-site incineration for the carbon waste as the remedy for OU-1. A specialnotice letter to conduct the RD/RA for OU-1 was sent to Warehouse 81 on March 6,1989. Again, Warehouse 81 declined to participate. The excavation and off-siteincineration of the carbon waste was completed by EPA in March 1992.

Additional PRP investigations in 1992 discovered records that led to identification ofNassau and Pennsylvania Power and Light (PP&L) as additional PRPs. A general noticeletter regarding their potential liability for the Site was sent to Nassau and PP&L on May19, 1992.


EPA issued the ROD for OU-2 in June 1990. This ROD addressed the fluff, impactedsoils and impacted lagoon water at the Site. In December 1992, Nassau petitioned EPAto reopen the OU-2 ROD. EPA reopened the public comment period in October 1993and Nassau submitted comments to supplement its petition to reopen the ROD. In March1994, EPA agreed to consider alternatives proposed by Nassau provided that Nassauconduct a treatability study and a Focused Feasibility Study (FFS) to reevaluate theremedial alternatives. Between 1993-1995, Nassau undertook a series of studies toevaluate an alternate remedy for the Site. During this period, EPA continued to pursuethe Remedial Design (RD) of the OU-2 remedy. During the RD for OU-2, a series oftreatability studies involving incineration of fluff and contaminated soils were conducted.The treatability studies, which were completed in November 1995, revealed that theselected remedy for OU-2 had the potential for adverse impacts on human health andenvironment. Ultimately, EPA abandoned the OU-2 remedy involving incineration andinstead selected the OU-5 remedy involving stabilization and solidification of fluff andcontaminated soils, a remediation technology similar to that proposed by Nassau. Thus,the OU-5 remedy addresses site contaminants previously addressed under OU-2.

On June 30, 1992, EPA issued the ROD for OU-3, which addresses ground watercontamination. On September 30, 1992, EPA sent special notice letters to Nassau, PP&Land Warehouse 81 and its general partner, Michael G. Sabia, Sr., which informed thosePRPs that the EPA was willing to enter into a Federal consent decree to conduct theRD/RA contemplated by the OU-3 ROD. Warehouse 81 and Michael G. Sabia, Sr. didnot respond to the special notice letter. On March 31, 1993, a unilateral administrativeorder1 (UAO) was issued to each PRP to conduct the'RD/RA for OU-3. Nassau andPP&L agreed to conduct the RD/RA for OU-3.

EPA conducted a removal action between April 1996 to September 6, 1996, to removeapproximately 25 55-gallon drums and more than 200 small containers stored in the mainplant building. Hazardous materials in these drums and containers were characterizedand over packed into 16 over pack drums and shipped off site for disposal. The total costof this removal action was $56,837.

The remaining discussions of Remedy Selection, Remedy Implementation and SystemOperation and Maintenance are organized by OUs.

Remedial Construction Activities

OU-1 - Carbon Waste Pile

Remedy Selection

EPA's selected remedy for OU-1 - Carbon Waste Pile consisted of completing thefollowing tasks:

1. Excavation and offsite incineration of the onsite carbon waste pile


2. Removal and offsite incineration of PCB contaminated waste

Remedy Implementation

The remedy, successfully completed on March 13, 1992, involved consolidation, loading,and off-site transportation and incineration of the carbon waste pile (approximately 875cubic yards), and approximately 800 drums of PCB contaminated waste.

c

System Operation and Maintenance

The EPA issued a Remedial Action Completion Report (RACR) on September 30, 1992,which stated that No Further Action (NFA) is required under OU-1. As all of the wasteaddressed under this OU was removed for off-site disposal this OU does not require anongoing treatment system or maintenance operations.

OU-2 - Fluff Waste and Site Soils (replaced by OU-5 in 1995)

EPA conducted a series of treatability studies, which revealed that the selected remedyfor OU-2 had the potential for adverse impacts on human health and environment.Therefore, EPA abandoned the OU-2 remedy involving incineration and instead selectedthe OU-5 remedy involving stabilization and solidification of fluff and contaminatedsoils, a remediation technology similar to that proposed by Nassau.

OU-3 - Ground Waste

Remedy Selection

From 1996 to 1998, a series of Pre-Design Investigation activities were conducted forOU-3 by Nassau. The principal objectives of the OU-3 Pre-Design Investigationactivities were to:

1. Acquire additional ground water quality and water level data at the Site and from thesurrounding areas to fill data gaps regarding the extent of ground water impacts andthe direction of ground water flow.

2. Further assess the hydrogeologic setting which influences ground water conditions at,and adjacent to, the Site.

3. Evaluate the anticipated ground water treatment efficiencies through bench-scaletreatability studies.

Based on the conclusions from the Pre-Design Investigations, as subsequentlydocumented in the December 2001 Pre-Design Investigation Report (O'Brien & Gere),an updated conceptual model of the Site conditions was-developed. This updatedconceptual site model (CSM) indicated the following:


1. The primary environmental impacts at the Site result from volatile organiccompounds (VOCs) in ground water of the overburden and shallow bedrock beneathand east of the Site.

2. The highest degree of. contamination is found in the overburden and shallow bedrockzones.

3. Ground water flow in the overburden generally has a downward component towardsthe more conductive shallow bedrock zone and an upward component from deeperbedrock towards the shallow bedrock zone.

4. The hydrogeologic setting effectively contains the impacted ground water to adefined area. Containment of impacted ground water is a function of topographicfeatures, the orientation of the bedrock strike, dipping beds, and hydraulic gradients(including upward vertical flow within the bedrock and the discharge of ground waterto the creek system). The ground water hydraulic gradient indicates that MausesCreek is functioning as a discharge barrier to ground water flow.

5. Migration of contamination has been further reduced by the installation of a publicwater supply in 1996 (completed under OU-4) that effectively eliminated knownground water withdrawal for potable use in the vicinity of the plume.

6. Concentrations of VOCs in ground water are expected to slowly decrease in futureyears as a function of ground water remediation in conjunction with naturalattenuation, including degradation and dilution within the aquifer, and volatilizationin the surface water environment.

EPA issued an Explanation of Significant Difference (BSD) dated September 27, 2000 toexplain the different approach for ground water cleanup. The major differences to OU-3remedial objectives, as explained by the September 2000 BSD, are summarized below:

1. On-site extraction of impacted ground water from the VOC plume at the Site,utilizing an overburden interceptor trench, in addition to vertical bedrock extractionwells in the source area. The original OU-3 ROD called for ground water extractionusing only vertical extraction wells.

2. Ground water cleanup levels were changed from background to MaximumContaminant Levels (MCLs) promulgated as the EPA drinking water standards, orMedium Specific Concentrations (MSCs) set forth in the Pennsylvania LandRecycling and Environmental Remediation Standards Act (Act 2), whichever is morestringent.

Based on preliminary modeling conducted in 1999, the September 2000 BSD conceptualremedial design utilized an overburden interceptor trench, with additional ground waterextraction from bedrock wells, where beneficial. The BSD also documented that morerefined ground water modeling (during remedial design) would be conducted to evaluatethe ability of trench design to meet the remedial objectives. Therefore, consistent withthe BSD, the ground water flow model was refined during the Preliminary (30%) RDbased on the 2001 Preliminary Design Investigation (PDI) activities. The refined groundwater model incorporated additional Site data such as wetland topography, depth ofbedrock, hydraulic parameters, and evaluated alternative ground water extraction optionsin addition to the overburden interceptor trench.


As detailed in the December 2001 30% RD Report, based on the CSM; EPA decided thatthe OU-3 remedy would move forward utilizing shallow bedrock extraction wells toimplement on-site hydraulic control of overburden and bedrock ground water with thehighest VOC concentrations. This represented a modification to the remedial design,while maintaining consistency with the OU-3 ROD/BSD RA objectives. The rationalefor this modification is summarized as follows:

» Under natural conditions, a downward hydraulic gradient exists from the overburdento the shallow bedrock. Therefore, the natural flow conditions will be enhanced byshallow bedrock extraction to capture overburden ground water. Shallow bedrockextraction can be designed to provide the same measure of overburden hydrauliccontrol as the overburden extraction scenarios evaluated.

• With any practical on-site ground water extraction scheme, the majority of water isextracted through the shallow bedrock zone. Vertical extraction wells are the mostpractical and economical means to extract bedrock ground water. Also, the flexibilityof the vertical well ground water extraction system, in terms of extraction locations,and adjustment to these locations, is greatly improved over a horizontal well or trenchsystem.

• The updated CSM indicates that ground water from the shallow bedrock zonerepresents the greatest contribution to discharge and VOC mass flux to MausesCreek. By performing extraction from the shallow bedrock zone, the reduction inVOC migration loading can be optimized.

Remedy Implementation.

The OU-3 Pre-Final (90%) RD Report was divided into two separate submittals tofacilitate the fast-track, turnkey (design/build) construction of the OU-5 ConstructionWater Treatment System (CWTS)/OU-3 GWTS to support the OU-5 RA. Accordingly,the Pre-Final (90%) GWTS Design, presenting the detailed design of the OU-5CWTS/OU-3 GWTS and relevant hydrogeologic aspects of the remedy, was completedin December 2003. Early approval of this portion of the 90% design allowed the OU-5GWTS/OU-3 GWTS turnkey construction to take place. The second part of the OU-390% RD Addendum Report, was completed on July 30, 2004, and provided the remainingrequired supporting detailed hydrogeologic information and performance assessmentcriteria as part of the overall OU-3 90% Remedial Design. Thus the 90% Final RD wascompleted on July 30, 2004. The 90% Final RD was also approved as the 100% FinalRD on July 30, 2004.

Subsequent to completion of the onsite dewatering activities associated with the OU-5RA, during December 2004 and early January 2005, the OU-5 CWTS was cleaned andchanged in service to that of the longer-term OU-3 ground water treatment system. TheOU-5 CWTS is largely identical to the OU-3 GWTS, except two additional watertreatment unit processes not required for the OU-3 GWTS (chemical enhancedprecipitation and granular activated carbon adsorption) were provided for treatment ofOU-5 generated construction waters that were removed. These two unit operations were


bypassed during the retrofit. Specifically, the final OU-3 GWTS consists of the followingunit processes:

• Flow equalization• Bag and cartridge filtration• pH Adjustment and/or sequestering agent addition• Ultraviolet/chemical enhanced (with hydrogen peroxide) oxidation (UV/Chemox)• Counter current air stripping• Final pH adjustment• Solids conditioning• Solids dewatering with a plate and frame filter press, until processing with the filter

press is no longer needed.

As detailed in the OU-3 Final Design, ground water extraction is being implemented withfive ground water collection/recovery wells: shallow bedrock wells Dunn-8 and EX-1,and overburden/weathered bedrock wells OEX-1, OEX-3 and OEX-4.

In December 2004, a National Pollutant Discharge Elimination System (NPDES)Equivalency Permit for the OU-3 treatment system discharge was issued by PADEP. Asof August 31, 2005, in excess of 6.9 million gallons of ground water were collected,treated, and discharged to Mauses Creek in compliance with the OU-3 NPDESEquivalency Permit.

Startup and operation of the OU-3 recovery wells and GWTS commenced on January 17,2005 and will continue to operate as planned. Preliminary pumping rates, likely to beadjusted during the Performance Assessment period, for the ground watercollection/recovery wells are as follows:

Dunn-8: 15 gpm OEX-1: l.Sgpm OEX-4: 1.5 gpmEX-1: 10 gpm OEX-3: l.Sgpm

Currently, it has been observed that Dunn-8, EX-1, OEX-1 and OEX-3 pumps typicallyoperate continuously, whereas the pump for OEX-4 typically operates cyclically due toevacuation and recharge of this well (set at its minimum pump withdrawal rate).

On February 17, 2005 EPA, PADEP, Nassau and O'Brien & Gere performed a joint start-up and precertification inspection. All parties determined that the OU-3 treatment systemwas functional, operational and performing as designed.

System Operation and Maintenance (O&M)

Subsequent to commencement of full-scale OU-3 ground water collection and treatmentsystem operations on January 17, 2005, the OU-3 remedy moved from a completed RAphase into a long-term O&M phase. The O&M manual for the OU-3 GWTS identifiesroutine operation and maintenance tasks that must be performed to continue efficientoperation of the OU-3 ground water collection and treatment system. This includesequipment maintenance, data logging and routine and non routine tasks associated with


operation and maintenance of a system of this nature. The OU-3 GWTS O&M manualwas reviewed by EPA during the February 17, 2005 joint start-up and precertificationinspection. It is maintained onsite and is continually being updated as found necessaryby ongoing operations.

The treatment system effluent is sampled twice per month as required by PADEP for theparameters specified in the OU-3 NPDES Equivalency Permit. Discharge MonitoringReports (DMRs) are submitted to EPA and PADEP on a monthly basis.

Intra process sampling is also being conducted to further optimize unit processefficiencies and to be used in development of Best Available Technology (BAT)discharge limitations with PADEP near the end of the first operating year.

Effectiveness of the treatment system operations under the OU-3 NPDES EquivalencyPermit has been clearly demonstrated. Treated discharge samples collected on January24, 2005 (and twice per month since) were analyzed for VOCs, semi volatile organiccompounds (SVOCs), total and dissolved metals, polychlorinated biphenyls (PCBs), totalsuspended solids (TSS), and pH. These results, and daily average flow, have all beenwell within the discharge limits specified by PADEP in the NPDES OU-3 EquivalencyPermit.

Long-term OU-3 Performance Monitoring activities will be conducted pursuant to theJuly 2004 Final (100%) RD, while the long-term OU-3 GWTS O&M activities will be

. completed pursuant to the Final (100%) RD and Site O&M Manual. In accordance withthe July 2004 Final (100%) RD Nassau will be completing a Performance EvaluationPlan (PEP) in April 2007. The PEP will document key performance evaluation activitiesand assess the OU-3 remedy.

On May 23, 2005, EPA approved the Interim Remedial Action Report for OU-3 datedApril 15, 2005, submitted by O'Brien & Gere on behalf of Nassau. Nassau will continueto operate and to maintain GWTS as required by UAO dated March 31, 1993 (DocketNo. III-93-27-DC).

OU-4 - Public Water Supply

Remedy Selection

EPA's selected remedy for OU-4 public water supply consisted of the design andinstallation of a public water supply for residences and businesses which had potential forexposure from potable use of contaminated groundwater.


Construction of a 17,400-foot 12-inch diameter water transmission main throughoutValley Township was completed in 1996, providing water to 39 residences and 133commercial establishments.



The public water supply system is operating as designed, providing safe drinking water tothe residences and commercial establishments. The O&M of the public water system hasbeen taken over by the Valley Township Water Authority and it is being operated incompliance with the Commonwealth of Pennsylvania Drinking Water Regulations.

OU-5 - Fluff Waste, Storage Tanks, Lagoon Water/Sediments and Site Soils

Remedy Selection

For OU-5, Nassau conducted a Focused Feasibility Study and treatability study from1993 to 1995 to demonstrate the viability of other remedies. EPA reviewed this work andissued a ROD on December 22, 1997, revising the 1990 decision document. This newROD called for the ex-situ (removed from the ground) stabilization of the fluff, lagoonsediment and surface soils and the backfilling of the excavated areas with the stabilizedmaterial. The remedy called for stabilized areas to be graded to prevent ponding andpromote drainage of precipitation away from and off the stabilized mass. The OU-5ROD calls for the stabilized material to be covered with two feet of clean soil, comprisedof an 18-inch thick vegetative support layer and six inches of topsoil. The topsoil will beseeded, with the resulting vegetation being used to anchor and prevent erosion of thesurface soils. The final OU-5 remedy provides for unsaturated soils contaminated withNon-Aqueous-Phase Liquid (NAPL) to be excavated, characterized and disposed of off-site at a permitted facility. Additionally, OU-5 provides for tank and drum contents andother debris remaining at the Site to be transported off-site to appropriate facilities.Implementation/enforcement of ICs including, but not limited to deed restrictions(institutional controls to prohibit interference with the remedial actions and to preventexposure to soil and ground water contamination) and fencing, as well as continuedmonitoring and implementation of a long-term OU-5 O&M program, will provide forSite security and long-term protectiveness. During the initial remedial activities, EPAobserved that soils under the fluff pile were very clayey and did not seem to be impactedby fluff. In September 2004, EPA issued ESD#1 to modify the requirement of excavating2 feet of soil under the fluff pile and mixing with the stabilization mass. The changerequired excavating only the soils where core samples or test pits of the soils underneathfluff indicated its presence.


The Final (100%) RD for OU-5 was completed in October 2003. Construction of a newwater treatment building was initiated in November 2003 and substantially completed inJanuary 2004. Construction of the OU-5 CWTS, being housed in the new water treatmentbuilding, was initiated in February 2004 and was completed with system commissioningand startup in May 2004. Construction of the buried treated discharge line, running fromthe treatment plant to Mauses Creek, was also accomplished during this construction


period. Installation of a chemical bulk storage area in the existing Storage Building(Butler Building) to support the OU-5 CWTS/OU-3 GWTS was completed in June 2004

The OU-5 CWTS was built, in part, to provide for the treatment of construction waterderived during implementation of the OU-5 RA. Construction waters treated includedpotentially impacted storm water as well as waters collected from performance of OU-5RA from de watering and decontamination activities.

The OU-5 RA Contractor (Weston Solutions, Inc.) was awarded the RA contract inFebruary 2004 for performing the remediation of the fluff, soil, sediment and remainingdebris associated with the OU-5 remedy. The OU-5 RA Contractor mobilized to the Sitein May 2004 and substantially completed construction (except final grading, topsoil andseeding) of the OU-5 RA activities by the time of winter shutdown in December 2004.Upon remobilization in the spring of 2005, remaining OU-5 RA activities werecompleted. These activities consisted of performing final grading, installing a six-inchlayer of topsoil over the already installed 18-inch thick vegetative support layer (VSL),seeding, and transition from temporary to final erosion and sediment control measuresonce the vegetative cover was established.

The OU-5 CWTS was utilized to treat OU-5 derived construction waters from June untilDecember 2004. During that time, approximately 2.25 million gallons of contaminatedwater were treated and discharged to Mauses Creek under an NPDES equivalency permitissued by PADEP for the OU-5 CWTS. No violations of the NPDES equivalency permitconditions occurred during the OU-5 CWTS operational period.

The following is a summary of the remedial actions that have been completed for OU-5(Fluff Waste, Storage Tanks, Lagoon Water/Sediments and Site Soils). A more detailedsummary of the remedial actions completed for OU-5 will be included in the RemedialAction Report (RAR), which is scheduled for completion in October 2005.

• Approximately 2.25 million gallons of water were treated and discharged to MausesCreek under an NPDES equivalency permit issued by PADEP for the OU-5 CWTS.No violations of the NPDES equivalency permit conditions occurred during the OU-5CWTS operational period.

• The excavation, stabilization and onsite placement of approximately 35,566 cubicyards of lagoon sediments and fluff material. v

• Off-site transportation and disposal of impacted materials (including approximately1,243 tons of hazardous soil/sediment containing NAPL) as an alternative to onsitelow temperature thermal disorption (LTTD) treatment.

• Removal and offsite disposal of both above-ground and below-ground tanks anddrums, metal scrap and other miscellaneous debris encountered on the Site(approximately 18 tons of non hazardous scrap metal from the above-ground andbelow-ground tanks, and approximately 159 tons of non hazardous debris).

• Removal of approximately 35,168 gallons of hazardous liquid associated with theabove-ground and below-ground tanks.


Removal of approximately 21,000 pounds of hazardous liquid associated with theNAPL removal activities.Installation of a soil cover system over approximately 9 acres of the Site (includingplaced stabilized material). The soil cover consisted of the following per the OU-5Final Design:

6-inches of topsoil18-inchesofVSL

Abandonment of some ground water monitoring wells, extension of well casings, andinstallation of additional ground water monitoring wells in conformance with the OU-3 remedy requirements.Construction water collection, controls and management.Air monitoring (work zone and perimeter).•Fence repair/replacement.Completed wetland replacement of approximately 3,200 square feet of wetlandsvegetation disturbed during soil cover construction.


The OU-5 O&M basically consists of ongoing, periodic inspections for E&S controls andto confirm growth in the vegetative cover in the short term, and inspections/repairs asneeded to maintain the soil cover/site controls and inspections to observe for animalsburrowing/holes per the OU-5 O&M Plan for the long-term maintenance.

Nassau will continue to perform O&M according to O&M plan as required by CD (No4:CV-99-2042) signed by EPA on September 27, 1999 and entered by the court onFebruary 11,2000.

OU-6 - Building Demolition and Debris Removal

Demolition of unsafe portions of the western third of the Main Plant Building andremoval of debris was done under a removal CD with current Site property owners.

Demolition of unsafe portions of the western third of the Main Plant Building by thecurrent Site property owners was conducted in the fall of 2000 and was completed inFebruary 2001. In April 2004, the property owners razed the remainder of the Main PlantBuilding and disposed of the demolition debris offsite due to safety concerns for RAcontractor workers.

III. Demonstration of Cleanup Activity Quality Assurance andQuality Control

Activities at the Site were consistent with the RODs, ROD Amendments and ESDs. EPAapproved design documentation included a Quality Assurance Project Plan (QAPP),which incorporated all appropriate quality assurance and quality control (QA/QC)procedures and protocols to achieve remediation objectives given in the RODs and


associated data collection objectives. Amendments to the QAPP were made to adoptlatest scientific procedures and protocols. Before implementation of any new proceduralrequirements, approved addenda to the QAPP were made.

A rigorous QA/QC program was used throughout the RA to ensure that remediationactivities were performed according to QAPP. Independent audits were made by the RPthroughout the remediation activities.

Construction oversight was performed by O'Brien & Gere (PRP's Consultant), EPA andPADEP. Bhupi Khona, the EPA RPM, was on-site to oversee critical constructionactivities. In addition Bhupi Khona and John Angevine the PADEP project manager,participated in bi-weekly progress meetings at the Site throughout the constructionactivities. EPA Biological Technical Assistance Group (BTAG) was also consultedduring the RD/RA activities.

IV. Activities and Schedule for Site Completion

The following activities will be completed according to the following schedule:

Task

Complete OU-5 RemedialAction Report (RAR)Post One Year NPDES Eq.Permit ReviewState Order enforcing deedrestriction on use of theaffected propertiesComplete OU-3 2-YrPerformance Evaluation PlanFive-Year Review (and everyfive years after)Complete Operation of OU-3Complete OU-3 RARComplete Final Close OutReport (FCOR)Delete Site from NPL

Estimated Completion

October 2005

March 2006

December 2006

April 2007

July 20 10

203520362037

2038

ResponsibleOrganization

Nassau

PADEP

PADEP

Nassau

EPA

NassauNassauEPA/PADEP/Nassau

EPA/PADEP

V. Summary of Remediation Costs

As discussed above, 5 OUs (OU-1, 3, 4, 5 and 6) at the Site have undergone an RA. TheROD estimate of capital costs and annual O&M costs, and final RA and O&M cost forOUs 1, 3, 4, 5 and 6 are summarized below.

OU-1 - Carbon Waste Pile

ROD Estimate of Capital Costs and Annual O&M Costs


The original cost estimate to implement the remedial action described in the ROD forOU-1 was $2,061,000 (net present worth). Since onsite remediation activities wereexpected to require less than 1 year to complete, no O&M costs were included in theoriginal cost estimate.

Final RA Cost

The final RA cost for OU-1, was $486,993.

OU-3 - Ground Water


The original cost estimate to implement the remedial action described in the June 1992ROD for OU-3 was $13,234,181 (capital cost) and $37,402,000 (net present worth),which includes 30 years of annual costs for O&M.

Final RA and O&M Costs

The final RA cost for OU-3 was $2,600,000. Most of the cost associated with theconstruction of the ground water treatment system was included with the OU-5 RA costincurred for the Construction Water Treatment System, which was subsequentlyretrofitted for OU-3. The contracted cost for the OU-3 two-year performance evaluationis $630,000. The estimated annual O&M cost for OU-3 is $250,000. As end of the year2004, total EPA oversight cost was $30,337.

OU-4 - Public Water Supply


The original cost estimate to implement the remedial action described in the ROD forOU-4 was $1,200,000 (net present worth), as documented in the OU-3 ROD datedSeptember 1992. O&M for the public water supply was not included in the original costestimate, as O&M for the public water system will be passed on to the users of thesystem, estimated to be $36 per quarter for the average homeowner.

Final RA Cost

The final RA cost for OU-4 was $1,933,000.

OU-5 - Fluff Waste, Storage Tanks, Lagoon Water/Sediments and Site Soils



The original cost estimate to implement the remedial action according to the December22, 1997 ROD for OU-5 was $6,924,062 (capital cost) and $8,752,530 (net presentworth), which includes 30 years of annual cost for O&M.

Final RA and O&M Costs

The final RA cost for OU-5 was $10,000,000. The estimated annual O&M cost for OU-5is $12,000.

OU-6 - Building Demolition and Debris Removal

Estimate of Capital Costs and Annual Q&M Costs

The original cost estimate to implement the remedial action described in the CD for OU-6was $46,700 (net present worth). Since onsite remediation activities were expected torequire less than one year to complete no O&M costs were included in the original costestimate.

Final RA Cost

The final RA cost for OU-6 was not reported by the PRP (Mr. Sabia, the current propertyowner).

VI. Five-Year Review

Hazardous substances will remain at the Site above levels that allow unlimited use andunrestricted exposure after the completion of the remedial action. Therefore, EPA willconduct a review every five years, as required by CRCLA Section 121(c) and as providedin OSWER Directive 9355.7-03B-P, Comprehensive Five-Year Review Guidance of June2001.

The purpose of the Five-Year Review is to determine whether the remedy at a Site isprotective of human health and the environment. The methods, findings, and conclusionsof reviews are documented in Five-Year Review reports. In addition, Five-Year Reviewreports identify issues found during the review, if any, and recommendations to addressthem.

The EPA recently completed the third Five-Year Review report for the Site in August2005. The first and second Five-Year Review reports for the Site were completed inOctober 1995 and June 2000, respectively. The next Five-Year Review for the Site isscheduled for completion in July 2010.

Abraham Ferdas, Director DateHazardous Site Cleanup DivisionU.S.'EPA, Region III


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