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SECOND FIVE-YEAR REVIEW REPORT

Berks Landfill Superfund Site

Spring Township Berks County, Pennsylvania

July 2010

PREPARED BY:

United States Environmental Protection Agency Regfonm

Philadelphia, Pennsylvania

Date:

• Borsellino, Director H dous Site Cleanup Division U.. EPA, Region In

Second Five-Year Review Berks Landfill Superfund Site Spring Township, PA

Table of Contents

List of Acronyms ............................................................................................................... iii Executive Summary ............................................................................................................ v Five-Year Review Summary Form .................................................................................... vi I. Introduction .............................................................................................................. 1 II. Site Chronology ......................................................................................................... 2 III. Background ....................................................................................................... .'....... 2 N. Remedial Actions ...................................................................................................... 6 V. Progress Since Last Five-Year Review ................................................................... 12 VI. Five-Year Review Process ...................................................................................... 14 VII. Technical Assessment ............................................................................................ 24 VIII. Issues ...................................................................................................................... 26 IX. Recommendations and Follow-Up Actions ............................................................ 26 X. Protectiveness Statement. ....................................................................................... 26 XI. Next Review .......................................................................................................... 27

Tables: Table 1: Chronology of Site Events Table 2: Site Construction Dates Table 3: Actions Taken Since the Last Five-Year Review Table 4: MCL Exceedances for VOCs in On-Site Groundwater Wells (2005-2009) Table 5: MCL Exceedances for Metals in On-Site Groundwater Wells (2005-2009) Table 6: MCL Exceedances for Metals in the Sentinel Well (2005-2009) Table 7: MCL Exceedances for Metals in the Residential Wells (2005-2009)· Table 8: MCL Exceedances for VOCs in the Residential Wells (2005-2009) Table 9: Landfill Gas Monitoring Results for % LEL (2006-2010) Table 10: April 2010 Daily Leachate Flow Volumes & Daily Rainfall Volumes

Figures: Figure 1: Site Location Map

Figure 3: Interpreted Phreatic Surface Contour Map, January 2007 Figure 4: Interpreted Potentiometric Surface Contour Map, May 2008

Figure 2: Site Layout Map

Figure 5: Site Parcel Map Figure 6: Site Features and Monitoring Points

Attachments: Appendix 1: Monitoring Schedule 2006 - 2010 Appendix 2: Advertisement in the Reading Eagle

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Second Five-Year Review Berks Landfill Superfund Site Spring Township, P A

List of Acronyms

ARARs Applicable or Relevant and Appropriate Requirements

AWQC Ambient Water Quality Criteria

BOR Bureau ofReclamation

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act

COPC Contaminant ofPotential Concern

CFR Code of Federal Regulations

EPA United States Environmental Protection Agency

HI Hazard Index

IC Institutional Control

MCLs Maximum Contaminant Levels

MCLGs Maximum Contaminant Level Goals

NCP National Oil and Hazardous Substances Pollution Contingency Plan

NPL National Priorities List

O&M Operations and Maintenance

PADEP Pennsylvania Department ofEnvironmental Protection

PAD Polyaromatic Hydrocarbons

PRP Potentially Responsible Party

RA Remedial Action

RAO Remedial Action Objective

RD Remedial Design

RIIFS Remedial InvestigationiFeasibility Study

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ROD Record ofDecision

RPM Remedial Project Manager

SARA Superfund Amendments and Reauthorization Act of 1986

UAO Unilateral Administrative Order

VOC Volatile Organic Compound

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Executive Summary

The remedy for the Berks Landfill Superfund Site (Site), located in Spring Township, Berks County, Pennsylvania included repair to the landfill cap, operation and maintt;mance of the leachate system, institutional controls, and long-term monitoring of groundwater. Construction of the selected remedy occurred between June and November 2000. The Site achieved construction completion status when the Preliminary Closeout Report was signed on December 22, 2000.

On November 14, 2008, EPA made the determination that all appropriate response actions under the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), other than operation, maintenance, and Five-Year Reviews, had been completed, and the Site was deleted from the National Priorities List (NPL).

The trigger for this second Five-Year Review was the completion date of the first Five-Year Review, August 2,2005. As of this second Five-Year Review, EPA has determined that the remedial actions taken at the Site are operating and functioning as intended by the decision documents.

The remedial action implemented at the Site is protective ofhuman health and the environment. The leachate collection system effectively conveys leachate to the Site storage ponds, the landfill caps prevent exposure to the Site wastes, long-term monitoring ensures that Site groundwater goals continue to be met and institutional controls have been implemented that effectively limit Site use activities to ensure continued protectiveness~

Government Performance Review Act (GPRAl Measure Review

As part of this Five-Year Review, the GPRA Measures have also been reviewed. The GPRA Measures and their status are provided as follows:

Environmental Indicaton

Human Health: Current Human Exposure Controlled and Protective Remedy In-Place Groundwater Migration: Groundwater Migration Under Control

Site-wide Ready for Anticipated Use (RAUl

The Site achieved Site-wide RAU on June 27, 2008.

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Five-Year Review Summary Form

..... 1 I I· III I·. '\ I 11-1 ( \ I I () '\

Site name Berks Landfill 'i;!l1..,....ti,nrl Site

EPAID PADOO0651810

Region: 3 State: PA

NPL status: 0 Final X Deleted 0 Other (specify)

City/County: Spring Township, Berks

Remediation status (choose all that apply) 0 Under Construction X Operating X Complete

Construction date: 1

Lead X EPA 0 State 0 Tribe 0 Other Federal

Author name:

Author tide: Remedial ilrn....... Author affiliation: U.S. EPA 3

Review period: 10/2009 to 07/2010

of site • S/17/2010 and S/26/2010

Type of review: X Post-SARA 0 Pre-SARA 0 NPL-Removal only 0 Non-NPL Remedial Action Site o NPL State/Tribe-lead 0 Regional Discretion

Review number: 0 first X second 0 third 0 other

Triggering action: o Actual RA Onsite Construction at OU# 0 Actual RA Start at OU# o Construction Completion X Previous Five-Year Review Report o Other (specify) _____________________

Triioo.~riI110 action date (from WasteLAN): 08/0212005

Due Date after tri.IJO .. ,riIlIO action 08/0212010

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Five-Year Review Summary Form, cont'd

Issue: No issues have been identified.

Recommendation: No issues have been identified.

Protectiveness Statement(s): The remedial action implemented at the Site is protective of human health and the environment. The leachate collection system effectively conveys leachate to the Site storage ponds, the landfill caps prevent exposure to the Site wastes, long-term monitoring ensures that Site groundwater goals continue to be met and institutional controls have been implemented that effectively limit Site use activities to ensure continued protectiveness.

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I. Introduction

The purpose of the Five-Year review is to detennine whether the remedy at a Site is protective ofhuman health and the environment. The methods, findings, and conclusions of reviews are documented in Five-Year Review reports. In addition, Five-Year Review reports identify issues found during the review, if any, and recommendations to address them.

The United States Environmental Protection Agency (EPA) is preparing this Five-Year Review report pursuant to Section 121 of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) 121 and the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). CERCLA Section 121states:

Ifthe President selects a remedial action that results in any hazardous substances, pollutants, or contaminants remaining at the site, the President shall review such remedial action no less often than each five years after the initiation ofsuch remedial action to assure that human health and the environment are being protected by the remedial action being implemented. In addition, ifupon such review it is the judgment ofthe President that action is appropriate at such site in accordance with section [104J or [106J, the President shall take or require such action. The President shall report to the Congress a list offacilities for which such review is required, the results ofall such reviews, and any actions taken as a result ofsuch reviews.

The Agency interpreted this requirement further in the NCP; 40 Code ofFederal Regulations 300.430(t)(4)(ii) states:

Ifa remedial action is selected that results in hazardous substances, pollutants, or contaminants remaining at the site above levels that allow for unlimited use and unrestricted exposure, the lead agency shall review such action no less often than every five years after the initiation ofthe selected remedial action.

The EPA Region III conducted the Five-Year Review of the remedy implemented at the Berks Landfill Superfund Site in Spring Township, Berks County, Pennsylvania. This review was conducted for the entire Site by the Remedial Project Manager (RPM) from October 2009 to July 2010. This report documents the results of the review,

This is the second Five-Year Review of the Berks Landfill Superfund Site. The triggering action for this statutory review is the signature date of the first Five-Year Review, August 2,2005. This second Five-Year Review is required due to the fact that hazardous substances, pollutants, or contaminants remain at the Site above levels that allow for unlimited use and unrestricted exposure.

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II. Site Chronology

.T bl e 1 Chrono ogy 0 fS·lte Eventsa . I

Event Date Disposal of waste in landfills 1950's to 1980's State permit oflandfill 1975 Closure of landfill 1986 Removal actions 1990 to 1993

Addition to the National Priorities List (NPL) lune 24, 1988 (proposed) October 4, 1989 (final)

Administrative Order on Consent July 5,1991 Remedial InvestigationiFeasibility Study completed April 24, 1997 Record ofDecision July 22, 1997 Unilateral Administrative Order (UAO) for RDIRA March 31, 1998 Remedial design start . May4,1998 Remedial design complete September 30L 1999 Start date for construction June 5,2000 Construction finished November 2000 Pre Close..()ut ~~rt Operation, Maintenance, and Monitoring Plan

December 22, 2000 May 2001

Remedial Action Construction Report August 17, 200 1 First Five-Year Review August 2, 2005 Final Close-Out Report March 31, 2008 Notice of Intent to Delete published in Federal Reaister September 15 2008 Deletion from the NPL November 14, 2008

m. Background

Physical Characteristics

The Berks Landfill Superfund Site is located between Wheatfield Road and Chapel Hill Road in Spring Township, Berks County, Pennsylvania, about seven miles southwest of the City ofReading, PA. (Figure 1, Site Location Map) The population of the Township is approximately 26,000. The Site consists of two closed municipal waste landfills and two separate disposal areas. The landfills are referred to as the eastern landfill, which covers an area of approximately 47 acres, and the western landfill, which covers an area ofapproximately 19 acres. The two disposal areas, which received municipal and demolition waste at times when inclement weather made the landfills inaccessible are called the "northern disposal area" which is located at the northwest toe of the eastern landfill, and the "area behind the equipment building" which is located at the northernmost toe of the eastern landfill (FigUre 2, Site Layout Map).

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

An unnamed tributary to Cacoosing Creek, and its associated wetlands and riparian zone, approximately parallels Wheatfield Road north of the landfills and flows in an east to west direction. This creek is a perennial stream that originates east of the Site. Surface water is . carried from the Site by three drainageways that discharge to the Cacoosing Creek tributary.

The Site hydrogeology is characterized by the presence of three flow systems, a water table aquifer which extends to a depth ofapproximately 100 feet, a deeper, semi-confined flow system which extends to a diabase contact, and an underlying diabase confining unit. The diabase; which encompasses the Site, acts as a major hydraulic barrier that controls groundwater flow at the Site and prevents downward migration ofgroundwater from the overlying units. The diabase effectively acts as a confining unit beneath the Site and causes the shallow phreatic and deeper semi-confined groundwater systems (Figure 3, Phreatic Surface Contour Map & Figure 4, Potentiometric Surface Contour Map) to merge and discharge to the Cacoosing Creek tributary system at the northwest portion of the Site and west of the Site boundary.

Topography at the Site ranges in elevation from approximately 720 feet above mean sea level (MSL) in the southeast comer to approximately 470 feet above MSL in the northwest comer of the Site.

Water usage for the majority ofpeople within the Township is provided by a public utility. In the immediate vicinity of the Site, along Wheatfield Road, water is supplied by private groundwater wells.

Land and Resource Use

The historical use of the Township has been agricultural. Presently, ther~ is a dairy farm nearby, but most of the area surrounding the Site is residential. The current zoning of the Site property is rural conservation.

Prior to being utilized as a property for waste disposal, the Berks Landfill property was mined for iron ore. The eastern and"western landfills were used for the disposal ofmostly municipal, demolition and industrial wastes from the 1950's until 1986 when landfilling at the Site ceased and the landfill was closed in accordance with a consent order issued by the Pennsylvania Department ofEnvironmental Resources (PADER). Two additional disposal areas, referred to as the "northetJl disposal area" and the "area behind the equipment building" exist at the Site. These areas were used when access to the eastern or western landfill was not

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available. Immediately adjacent to the landfills, and part of the Site property, is an area fonnerly used to weigh the disposal trucks. When this function was no longer required, an auction business, Zerbe's Auction House, used one of the Site buildings. Zerbe's no longer operates the auction house on-Site. Presently, there are structures on the property that are mainly used for storage by the current property owner.

There is a small unnamed tributary that runs north to south between the two landfills and discharges to the Cacoosing Creek tributary which travels east to west approximately parallel to Wheatfield Road. The Cacoosing Creek is part of the Schuylkill River watershed. Also running parallel to the Cacoosing Creek tributary is a Spring Township sewer main, which currently conveys the Site leachate to the local wastewater treatment plant for treatment. Originally, there was no management ofleachate from the landfills so the collected leachate either seeped into groundwater or discharged to the Cacoosing Creek tributary. Groundwater is used for drinking water in the immediate area of the Site and there are several residents downgradient of the Site that use groundwater as their primary source ofdrinking water.

History of Contamination

The landfill operations took place from the 1950's to the 1980's. Landfill operations consisted primarily ofmunicipal refuse, demolition debris, industrial wastes and alkali sludge disposal. Hazardous waste was also disposed at the Site according to fonner landfill employees. In 1975, the PADER (now the Pennsylvania Department ofEnvironmental Protection, PADEP) granted a pennit that allowed the eastern landfill to accept municipal and demolition refuse and to discharge leachate into the Cacoosing Creek tributary. In 1986, landfilling operations ended. The landfills were closed and covered with a soil cap and leachate was directed into and stored within three on-Site leachate ponds. Collected leachate is currently pumped to the Spring Township wastewater treatment plant.

Initial Response

The Site was added to the National Priorities List (NPL) on October 4, 1989 due to the potential for contaminated groundwater to affect residential drinking water. The following protective measures were implemented as a result ofclosing the landfills and removal actions:

• Low permeability soil caps; • Low permeability soil liner beneath a portion of the eastern landfill; • Passive landfill gas vents; • Surface water management systems including erosion control side slope benches, benns,

and rip-rap lined channels; • Leachate collection and management system; • Lined leachate collection ponds;

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• Automated dual pump leachate system; • Treatment of leachate by local wastewater plant; • Security fencing around the eastern landfill and leachate ponds; and • Access road installation

Basis for Taking Remedial Action

The following hazardous substances have been detected in groundwater and soil/sediment at the Site: .

Site Groundwater Benzene, carbon disulfide, chlorobenzene, chloromethane, l,4-dichlorobenzene, 1,1-dichloroethane, 1,2-dichloroethane, 1, I-dichloroethene, total 1,2-dichloroethene, hexachloroethane, trichloroethene, vinyl chloride, aluminum, arsenic, barium, beryllium, cadmium, copper, lead, manganese, and vanadium.

Surface Soil Arsenic, beryllium, manganese, benzo(a)pyrene.

Sediment Arsenic, beryllium, manganese.

Air (passive gas vents) Benzene, chlorobenzene, chloroethane, ethylbenzene, hydrogen sulfide, toluene, trichloroethene, vinyl chloride, total xylenes, dichlorodifluoromethane, 1,2,4-trimethylbenzene, 1,3,5-trimethylbenzene.

There were no contaminants ofpotential concern (COPCs) selected for surface water, since there were no detections exceeding risk-based levels. Also, there were no COPCs selected for leachate because the leachate was being pumped to the local wastewater plant for treatment.

The risk assessment perfonned for the Site evaluated the following scenarios: off-site resident, on-site trespasser, on-site \:Vorker, and future on-site resident. A hypothetical residential use scenario was considered in the risk assessment even though there is no plan for residential use at the Site. Both cancer and non-cancer risks were evaluated.

Upon completion of the risk assessment a series of risks were identified (ROD pages 2226). Only future on-site resident triggered a non-cancer risk due to metals. On-site resident, onsite trespasser, and off-site resident triggered cancer risk due to a combination ofmetals and VOCs.

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An Ecological Risk Assessment (ERA) was also performed as part of the Remedial Investigation and Feasibility Study (RIfFS) (ROD pages 26-29) to determine the likelihood that biological species habitats in the Site area are exposed to unacceptable risks from Site contaminants. The ERA consisted of three primary components: site characterization, exposure analysis, and risk characterization. The ERA concluded that the leachate lagoon area and the areas containing leachate seeps posed a potential risk to aquatic receptors. None of the other exposure media evaluated (soil, surface water, and sediment) were found to contain contaminants at levels that posed a risk to ecological receptors.

IV. Remedial Actions

Remedy Selection

The Record ofDecision (ROD) for the Berks Landfill Superfund Site was signed on July 22, 1997. The Remedial Action Objectives (RAOs) were developed as a result ofdata collected during the RIlFS and were used in evaluating the remedial alternatives. The RAOs for the Site are listed below:

Remedial Action Objectives:

• To prohibit future consumption ofon-Site groundwater; • Long-term monitoring to ensure that Maximum Contaminant Levels (MCL) or Maximum

Contaminant Level Goals (MCLG) continue to be maintained'at the point ofcompliance; • Continued effective collection of Site leachate; and • Repair and maintenance of the existing landfill caps

The preferred groundwater remedy is natural containment with institutional controls, natural attenuation, and long-term monitoring rather than an active remediation ofgroundwater.

The prohibition on groundwater consumption is limited to the point ofcompliance. The boundaries of the point of compliance are the eastern, western, and southern Site property boundaries and the northern boundary is Wheatfield Road.

As a result of the remedial investigation activities (Le. soil borings, groundwater sampling), it was revealed that a geological formation, a diabase, almost entirely encircles the Site. The diabase acts as a hydraulic barrier that controls groundwater flow at the Site. The groundwater collects and discharges to the Cacoosing Creek tributary at the northwestern portion of the Site. Because of this uniquely confining hydrogeologic condition, the groundwater remedy consists ofnatural containment and natural attenuation that is monitored using a sentinel well cluster and on-Site wells. A remedial alternative with an active hydraulic groundwater

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containment component was considered, but was determined unnecessary and eliminated in the remedial alternative evaluation.

Remedy Description:

• Institutional controls to prevent future consumption of on-Site groundwater, to restrict future development, and to limit future earth moving activities at the Site;

• Long-term monitoring including installation of a sentinel monitoring well cluster; sampling of residential wells; and monitoring of on-Site wells, combustible landfill gases and the aquatic habitat;

• Operation and maintenance of the leachate management system; and • Repair of the eastern landfill cap and maintenance ofboth the eastern and western landfill

caps.

There is an extensive list ofperformance standards that were developed for each part of the remedy (ROD pages 48 - 54). Performance standards apply to all aspects of the remedy including institutional controls, long-term monitoring, the operation and maintenance of the leachate system, and landfill cap repairs. The performance standards, for example, describe the frequency ofmonitoring or the type ofvegetative cover.

Remedy Implementation

In 1998 EPA issued a Unilateral Administrative Order (UAO) (Docket No. III-98-071-DC, dated March 31, 1998) to a group of eighteen potentially responsible parties (PRPs) ordering them to design and construct the remedy described in the ROD. A subgroup of the eighteen PRPs complied with the UAO and developed a remedial design consistent with the ROD and performance standards that detailed the landfill cap and leachate collection system repairs. EPA approved this final design on September 30, 1999. Below is a table listing the key dates for the construction activities at the Site:

Table 2: Site Construction Dates Construction Event Date Approval ofRemedial Design September 30, 1999 Approval ofRemedial Action Work Plan January 13, 2000 Selected construction contractor March 16,2000 Approval ofConstruction Management Plan March 25, 2000 Construction start JuneS, 2000 Construction season June 2000 to November 2000 Pre-final inspection October 31, 2000 Final inspection November 14, 2000

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Preliminary Close-out R~rt December 22, 2000 Final Close-out Report March 31, 2008

The major components of the remedial action construction activities included the following:

• Access Roads - approximately 9,500 feet of access roads were either installed or improved upon to provide access to the two landfills;

• Western Landfill - installation of approximately 7,000 feet of inspection and access trails and verification of cover thickness;

• Eastern Landfill- cap repair, verification of cover thickness, re-vegetation of certain . areas and installation of erosion control features;

• Leachate Management System - inspection and repair ofleachate collection lines and manholes, regrading and relining of the three leachate collection ponds, and leachate pump installation;

• Monitoring - installation of the sentinel well to monitor the natural containment and natural attenuation groundwater remedy, installation ofeleven landfill gas monitoring probes, and closure of five on-Site groundwater wells;

• Wetland Enhancement - 300 wetland trees were planted between the eastern and western landfill as an ecological enhancement that was not required by the ROD.

EPA, the Bureau ofReclamation (BOR), and the PADEP provided oversight of the construction. On October 31, 2000, as the construction neared completion, EPA, in conjunction with the BOR and P ADEP, conducted a pre-final inspection. It was determined that the remedial activities were constructed in accordance with the final design. A final inspection was conducted by EPA on November 14, 2000. The Berks Landfill Superfund Site achieved construction completion when the Preliminary Close-Out Report (PC OR) was signed on December 22, 2000.

The Remedial Action Completion Report documented that the performance standards identified in the ROD were achieved during the remediation and was approved by EPA on August 17, 2001. Annual Reports, documenting the progress towards meeting the post remedial action construction performance standards specified in the ROD, are submitted by the PRPs. The May 2001 Operation, Maintenance, and Monitoring Plan (OM&M Plan) delineates the performance standards involved in the continued operation of the Site.

Implementation of Institutional Controls

The Site remedy requires the use of institutional controls. Institutional controls usually refer to non-engineering measures, such as legal controls, intended to limit human activity in such a way as to prevent or reduce exposure to hazardous substances and/or protect the integrity of the remedy. As stated in the ROD: "Institutional controls will be used to identify the Site as property underlain by contaminated groundwater and to prevent consumption ofcontaminated

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groundwater; to restrict future development at the Site and to limit future earth-disturbing activities on the capped portions of the Site." (ROD page 48).

In the ROD EPA selected six performance standards for institutional controls. Three of the performance standards provide specific restrictions on groundwater use in order to prevent drinking water uses and to protect the natural containment and attenuation remedy. One performance standard restricts earth moving activity in specified areas. The remaining two performance standards state that title restrictions, along with other appropriate means, shall be used to implement the first four performance standards and that the title restrictions should be recorded with the Berks County Recorder of Deeds.

The VAO further elaborates on the institutional controls in the ROD by including a series of specific restrictions to be placed on the four parcels (Parcels A through D) comprising the Site (Section VIII of the VAO - Access To and Vse of the Site). The VAO tailored the restrictions for each parcel based on the appropriate uses ofeach parcel, the extent ofremaining contamination and the nature ofengineered features for each parcel, and the performance standards in the ROD. For example, the VAO provides the most extensive restrictions on Parcel A (VAO pages 51-52), ranging from restrictions on groundwater use and land disturbance to restrictions on activities such as hunting, fishing, and tree removal.

A map delineating parcels A through D is attached as Figure 5 (Parcel Map) and a brief description of these parcels is provided as follows:

• Parcel A - parcel with the two landfills and the leachate lagoons. • Parcel B - parcel with the auction house, equipment building, and the portion of the

landfill referred to as the "area behind the equipment building." This parcel also provides access to the landfill parcel, Parcel A. This parcel is owned privately.

• Parcel C - former residential property now owned privately and kept as open space. • Parcel D - current residential property that contains the sentinel well.

A summary by parcel of the institutional controls status is described below.

Parcel A: The use restrictions required in the VAO for Parcel A include restrictions on limiting the use of the property, restrictions on groundwater use, restrictions on land disturbance, and restrictions on activities such as hunting, fishing, and tree removal. A notice containing a recitation of the restrictions in the VAO for Parcel A was filed by the parcel owner with the Berks County Recorder ofDeeds as an additional institutional control on February 19,2007.

Parcel B: An II-acre portion ofParcel B that is on the south side ofWheatfield Road directly adjacent to the landfills was purchased by the current owner in 2005. Prior to the 2005 sale, EPA issued a comfort letter to the prospective purchaser. EPA also sent a letter to the Township of

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Spring on the acceptable uses of the II-acre portion ofParcel B, infonnation about the remedy, and protections that were necessary to maintain the remedy. The current owner uses the II-acre portion ofParcel B for his business, mainly as storage. A deed dated March 18,2005 contains the appropriate use restrictions for the II-acre portion ofParcel B. The restrictions listed in the deed include restrictions on groundwater use, restrictions limiting the use of the property, restrictions on land disturbance, and limitations on activities to ensure protectiveness of the remedy. The deed containing the use restrictions is considered an institutional control.

Parcel C: The current owner of the II-acre portion ofParcel B also purchased Parcel C to maintain the property as open space. A deed dated July 10, 2006 contains restrictions on the use of the parcel consistent with the VAO. The restrictions listed in the deed include restrictions on groundwater use, restrictions limiting the use of the property, restrictions on land disturbance, and limitations on activities to ensure the protectiveness of the remedy. The deed containing the use restrictions is considered an institutional control.

Parcel D: The private owner ofParcel D signed a letter agreement dated August 14, 2002 with the VAO Respondents granting the Respondents access to install a sentinel well on the property and to collect groundwater samples. The letter agreement also provides for groundwater use restrictions and prohibitions on interfering with the sentinel well. The letter agreement is considered an institutional control.

System Operation/Operation and Maintenance

Operation and maintenance is being perfonned by the PRPs in accordance with the approved Operation, Maintenance, and Monitoring (OM&M) Plan (May 2001). The OM&M Plan was prepared in accordance with the VAO issued by EPA (Docket No. III-98-07I-DC, dated March 31, 1998). A schedule detailing the annual monitoring requirements was included in the original OM&M Plan. A request to modify the frequency of the ground~ater and landfill gas sampling schedule from semi-annually to annually was approved by EPA in July 2006. Inspections of the Site leachate collection ponds and leachate pump station occur on a monthly basis. Ambient air within on-Site buildings is sampled for combustible gases on a monthly basis as well (when accessible). Inspections of the landfill caps, surface water management system, and the site access controls (gates, fences) are conducted on an annual basis. Groundwater and landfill gas sampling is perfonned on an annual basis as well. In accordance with the ROD requirements, surface water, sediment and benthic macroinvertebrates were sampled within six months after the cap repairs were completed, and once more prior to the first Five-Year Revi~w. The ROD then allows for EPA, after consulting with P ADEP, to make a determination if future surface water, sediment and benthic macroinvertebrates sampling would be necessary, based on the findings of the first two rounds of sampling. This sampling was perfonned in 2009 with favorable results, according to the PRP's consulting finn, Blazosky, Associates, Inc. (Blazosky).

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The groundwater and landfill gas sampling results are reported to EPA annually in the OM&M Report. The results from the aquatic habitat assessment and residential groundwater sampling are submitted in separate reports to EPA.

Site operation and maintenance activities include the following:

• Control of vegetative growth - Mowing of the eastern landfill is scheduled once a year, usually in the late fall. The 0 M & M Plan allows for mowing either in the fall or spring. The eastern landfill cap was last mowed in November 2009.

• Monthly inspection - A monthly inspection is performed to check on the leachate collection system. Specifically, the leachate levels in the collection manholes, the leachate lagoons, and the pumping station are inspected. A checklist is completed and deficiencies are noted on the form. In addition to the monthly leachate collection system monitoring, the Site buildings are monitored for combustible gases. In the Annual Report all the inspection forms for the year are compiled. In calendar year 2009, one of the leachate pumps had ceased operating, requiring replacement.

• Environmental monitoring - Groundwater and landfill gas are monitored annually and the results are included in the Annual Report for the Site. The condition of each of the groundwater wells is inspected annually as well. The Annual Report checklist notes the conditions and any needed repairs to the groundwater and landfill gas wells.

• Site features - Once a year the landfill caps and surface water management features are inspected. Again, a standardized checklist is used to document conditions and note repairs to be made. This information is submitted in the Annual Report.

The OM&M is performed by Blazosky. Maintenance of the caps is subcontracted to a landscaping company. The estimated annual 0 & M cost included in the ROD is $198,000 but EPA is not provided with the actual cost information to operate, maintain, and monitor the Site.

The 2001 OM&M Plan only outlines the Site monitoring schedule for the first five years. The ROD allows for a change in monitoring frequency after five years of collecting data EPA received a proposal for an alternate schedule for OM&M in March 2006. The proposed monitoring schedule for years 2006 through 2010 was approved by EPA in July 2006 (Appendix 1). A proposal for the OM&M monitoring frequency for the years 2011 through 2015 has not yet been submitted by the PRP group. Upon receipt, it will be reviewed for adequacy.

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V. Progress Since Last Five-Year Review

The following table summarizes the recommendations and follow-up actions that were identified in the first Five-Year Review (2005). It also summarizes the actions taken to address the issue.

Table 3: Actions Taken Since the Last Five-Year Review Issues Recommendations/

Follow-Up Actions

Party Responsible

Milestone Date

Action Taken/Outcome

Dates of Action

Institutional controls not implemented

Develop and implement a plan for institutional controls including activities such as title search, filing ofUAO, and placement of restrictions on titles for Parcels A through Parcel D.

PRP September 2005

All institutional controls for Parcels A through C were filed with the deeds for these properties at the Berks County Recorder ofDeeds. A letter ofagreement was signed with the Parcel D property owner.

Parcel A-February 19,2007. Parcel B-March 18, 2005. Parcel C-July 10, 2006. Parcel D-August 14, 2002.

Deletion from the NPL

The Final Close-Out Report (FCOR) documents that EPA completed all response actions for the Site in accordance with the Close-Out Procedures for National Priorities List Sites (OSWER Directive 9320.2-09A-P). The FCOR was signed on March 31, 2008. The State of Pennsylvania concurred with the decision to delete by letter 'dated August 1,2008. The Notice of Intent to Delete (Nom) the Berks Landfill Site from the NPL was published in the Federal Register on September 15, 2008. The NOm indicated that EPA had determined that all appropriate response actions under CERCLA, other than 0 & M and Five-Year Reviews, have been completed. Comments to the Nom were solicited. EPA had also published the Direct Final Notice ofDeletion of the Site in the Federal Register on September 15,2008. Because no adverse comments regarding the proposed deletion of the Site were received, the Site was ultimately deleted from the NPL on November 14, 2008.

Re.pairs to the Storm Water Drainage Channel in the Northern Disposal Area

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In January 2009, a stone-lined drainage channel that runs through the northern disposal area was reconfigured and backfilled with geotextiles and riprap. The repairs to the drainage channel were necessary because excessive erosion had caused landfill wastes to become exposed within the drainage channel. The excavated waste material, consisting of crushed 55-gallon metal drums, soil and refuse totaled approximately 226 tons. The crushed drums were disposed at Modern Landfill as a non-hazardous residual waste. The excavated soil and landfill refuse were disposed at Environmental Recovery Corporation as residual waste.

The excavated area was backfilled to design grade and compacted prior to placing the geosynthetics (geomembrane and geotextile) and riprap. All disturbed adjacent areas were seeded and monitored until acceptable growth was achieved. The work was inspected by EPA and P ADEP and considered complete in September 2009.

Central Drainageway Culvert Reconfiguration

The existing central drainageway culvert that passes underneath the access road between the eastern and western landfills was reconfigured in September 2009. The work was necessary to reduce both erosion of the downstream channel banks and the potential for overtopping of the drainageway banks during intense storm events. The work consisted of the replacement of the existing 36" corrugated metal pipe (CMP) with three new 36" CMP (see cut section from the approved design, below), raising the elevation of the banks upstream of the new CMP, and final regrading and stabilization of the disturbed area During the excavation of the existing 36" CMP, the western landfill's PVC leachate collection pipe was exposed and inspected prior to backfill.

_w.fIU. ......, r~-(W-(sa ND1I_')_~--->~__.....L_aa_.SOl' +/

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ED CHANNa CROSS SI!CTION ... 8 AT CULVERT I!NTR.ANCa 5 _1'0~

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.,...._31" _ ~ 1ID1IL .....

13


Landfill Sew RWair

On April 5, 2010 representatives ofPADEP and EPA collected water and sediment samples from three separate, suspected leachate seep areas that had been previously observed on the western flank of the eastern landfill. As a result of the sample analyses, on May 6, 2010; PADEP issued a Notice ofViolation (NOV) to the Berks Landfill PRP group, stating that the group was in violation of the Solid Waste Management Act and the Clean Streams Law. PADEP recommended that the seeps be mitigated within 45 days of the receipt of the NOV. The PRP group responded by letter on May 27, 2010 stating that although they agree that the seeps should be addressed, they were of the opinion that ''the seeps were fairly localized in nature, occur within the limits of the landfill dispOsal area, and therefore have little or no effect on the surrounding water bodies.'~ The letter also included the PRP's proposed plan to address the seep areas. The proposed scope ofwork was reviewed by the P ADEP and EPA and accepted. Work to address the seeps began on June 8, 2010. The PRP's consulting firm, Blazosky identified a total of 12 possible seep areas that required remediation. Identified seep areas were excavated with a backhoe and # 4 stone was backfilled within the excavated area to provide a high permeability zone that would promote downward drainage ofthe leachate to the collection piping at the landfill toe. Geotextile was placed over the drainage stone and the excavation area was backfilled with clay (and compacted) and topsoil to the original grade, prior to re-seeding. The work was completed on July 2, 2010. Several follow-up inspections to ensure the adequacy of the repair will be performed throughout the end of the year.

VI. Five-Year Review Process

Administrative Componen~

The Five-Year Review team was led by Tim Gallagher, the EPA Remedial Project Manager (RPM) for the Site. The EPA Site team includes Bruce Rundell, EPA Hydrogeologist, Nancy Rios-Jafolla, EPA Toxicologist, Michael Hendershot, Office ofRegional Counsel, and Ruth Wuenschel, Community Involvement Coordinator. Representatives from Spring Township and the PADEP also provided assistance in the preparation of this report.

Tim Gallagher established the Five-Year Review schedule, the components ofwhich included the following:

• Community involvement • Document review • Data review • Site inspection

14


• Five-Year Review report development

Community Involvement

Notice of this Five-Year Review and solicitation of comments was published on May 17, 2010 in a local newspaper, The Reading Eagle (Appendix 2), by EPA Community Involvement Coordinator, Ruth Wuenschel. The advertisement included a brief Site description, explained what a Five-Year Review consists of and the reaSon that EPA was conducting it, and provided contact information. No comments have been received following the published notice.

Following signature of this Five-Year Review report a notice will be sent to the Reading Eagle announcing that the Five-Year Review report for the Site is complete. The results of the review and the report will be made available to the public in the Administrative Record and at the Spring Township Municipal Building.

EPA sent information letters to the Manager of Spring Township, the P ADEP project manager assigned to the Site, and a representative of the PRP in May 2010 In order to inform them that the Five-Year Review process was underway and that copies of the completed report would be provided to them.

Document Review

The following documents were referenced during the performance of this Five-Year Review:

Golder Associates Inc., Remedial Investigation for Berks Landfill. Spring Township. PennsylvaniD, March 1995

Golder Associates Inc., Feasibility Study ReJ>Ort, Berks Landfill. Spring Township. PennsylvaniD, April 1997

U.S. EPA, Record ofDecision. Berks Landfill Superfund Site. Spring Township. Berks County. Pennsylvania. July 22, 1997

U.S. EPA, Unilateral Administrative Order (UAOl. Docket No. III-98-071-DC. March 31, 1998

Golder Associates Inc., Remedial Action Completion ReJ>Ort, Berks Landfill Superfund Site. Berks County. PennsylvaniD, February 2001

Golder Associates Inc., Operations. Monitoring. and Maintenance Plan. Berks Landfill Superfund Site. Berks County. PennsylvaniD, May 2001

15


u.S. EPA, First Five-Year Review for Berks Landfill Superfund Site, Spring Township, Berks County. Pennsylvani~ August 2, 2005

Golder Associates Inc., Annual Re,port - 2005, Berks Landfill Superfund Site, Berks County. Pennsylvani~ March 2006

Golder Associates Inc., Annual Re,port - 2006, Berks Landfill Superfund Site, Berks County. Pennsylvani~ September 2007

u.S. EPA, Final Close-Out Re,port. Berks Landfill Superfund Site, Berks County, Pennsylvani~ March 2008

Golder Associates Inc., Annual Re.port - 2007, Berks Landfill Superfund Site, Berks County, Pennsylvani~ September 2008

u.S. EPA, Direct Final Notice ofDeletion of the Berks Landfill Superfund Site from the National Priorities List, September 5, 2008

, Blazosky Associates, Inc. Annual Re,port - 2008, Berks Landfill Superfund Site, Berks County, Pennsylvani~ December 2009

Blazosky Associates, Inc. Annual Report - 2009, Berks Landfill Superfund Site, Berks County. Pennsylvani~ June 2010

Golder Associates, Inc. Construction Summary Report, Central Drainageway Reconfiguration. Berks Landfill Superfund Site, Berks County, Pennsylvani~ December 2009

Golder Associates, Inc. Construction Summary Report. Re,pairs to the Storm Water Drainage Channel in the Northern Disposal Area. Berks Landfill Superfund Site, Berks County. Pennsylvani~ January 2010

Data Review

Environmental data provides information to assess and demonstrate that the remedy is achieving the perfonnance standards described in the ROD. Sampling of the on-Site, Sentinel and Residential groundwater wells is perfonned for VOCs and metals on an annual basis. Landfill gas wells are also monitored for % LEL annually. Listed below is a summary of the monitoring events performed at the Site.

16


On-Site Groundwater Wells

Groundwater levels are measured in the on-Site groundwater wells in order to confirm groundwater flow contours. Groundwater wells (G-l, G-4, G-5, C-7S, C-7D, G-6, G-13, MP18S, GR-18D, and G-12) and the Sentinel Well (SMW-1) are sampled annually in the spring for VOCs and metals (filtered and nonfiltered) using a low-flow method. Wells C-3S, C-3D, and MP-16 are sampled for VOCs on alternate years. A map showing the groundwater well locations is included as Figure 6, Site Features and Monitoring Points. As previously stated, the monitoring schedule for years 2006 through 2010 is included as Appendix 1.

A summary of the results of the 2005 - 2009 annual groundwater sampling events indicate that eight on-Site monitoring wells had detections ofVOCs: cis-l,2-dichloroethene (cis-1,2-DCE), trichloroethene (TCE), vinyl chloride (VC) and tetrachloroethene (PCE) above EPA's Maximum Contaminant Levels. (See Table 4) The remaining wells in the groundwater' monitoring program had either no detections or low-level (below MCLs) detections ofVOCs.

Table 4: MCL Exceedances for VOCs in On-Site Groundwater Wells (2005 - 2009) MW Year Cis-l,2-DCE TCE VC PCE

MCL 70ppb Sppb 2ppb Sppb C-3D 2005 120 38

2007 96 C-7S 2006 5.3 G-l 2006 5.3 G-4 2006 5.4 G-S 2005 53

2006 62 2007 65 2008 65 2009 61

MP-18S 2005 290 470 2006 470 480 31 36 2007 360 310 25 2008 338 27 25 2009 317 142 22

G-13 2006 3 GR-18D 2005 35

Seven Site monitoring wells had detections ofmetals (aluminum, iron, manganese, and silver) above their respective MCLs. (See Table 5)

17


Table 5: MCL Exceedances for Metals in On-Site Groundwater Wells (2005 - 2009) MW Year Aluminum Iron Man2anese Silver

MCL 50-200 ppb 300 ppb 50ppb 100 ppb C-7S 2005 1920 4070 4500

2006 253 4370 2007 6690 8970 5130 2008 5300 7100 6100 2009 360 440 5000

G-5 2005 344 826 138 2006 394 399 110 2007 108 2008 1700 810 120 2009 530 440 160

MP-18S 2005 625 2006 419 2007 710 2008 980 2009 3000 140

GR-18D 2006 76 2007 94 2008 61

G-l 2005 323 2006 117 104 2007 202 2008 820 2009 240 1100

G-4 2005 819 245 2006 694 229 2007 370 130 2008· 920 150 2009 210 470 130

G-12 2005 2790 1820 1990 2006 310 1840 2007 254 1600 2008 790 1800 . 2009 620 510 1900

18


Units- ugll US EPA secondary MCLs Total metals (nonfiltered)

Sentinel Well

The Sentinel Well was installed as part of the remedy in order to monitor the natural containment and natural attenuation groundwater remedy. The Sentinel Well, located on a property west of the Site, is downgradient of the Site in the direction ofgroundwater flow at the point where groundwater discharges to the Cacoosing Creek tributary (See Figure 6, the Sentinel Well is identified as SMW-1). The Sentinel Well is sampled annually for VOCs and total metals.

There have been no exceedances of the MCLs for VOCs in the Septinel Well. Metals detections above the MCLs are summarized in Table 6 below. The Site was historically an ironore mine so there are naturally occurring metalsin the groundwater.

Table 6: MCL Exceedances for Metals in the Sentinel Well (2005 - 2009) Metals MCL 2005 2006 2007 2008 2009 Aluminum 50-200 264 193 247 2000 1500 Iron 300 2630 2100 Umts-ugll USEP A secondary MCL Total metals (nonfiltered)

Residential Groundwater

EPA and the PRPs have sampled the nearby residential groundwater drinking water wells for many years. The wells are sampled for VOCs and total metals. The residents selected for the sampling are downgradient of the Site in the general direction of groundwater flow. None of the residents have treatment systems installed on their groundwater wells as a result of the Site. Results of the groundwater sampling are sent directly to the property owners and are included in the annual report. In general, iron was the only metal detected above the EPA's MCL in four of the residential wells (See Table 7). In 2006, four residential wells exhibited results for PCE above the MCL of 5 ppb (See Table 8). However, validation of the laboratory data indicated that PCE results were also detected in the laboratory blank; therefore, it was likely that the result was due to laboratory contamination. PCE was not detected in any of these wells in the subsequent three years ofmonitoring.

19


One residence, located at the intersection ofWheatfield and Chapel Hill Roads, identified as "RES 09", was added to the residential monitoring program in 2007 following a written request from the property owner dated December 20, 2006.

Table 7: MCL Exceedances for Metals in the Residential Wells (2005 - 2009) Metals MCL RESOI RES02 RES04 RES06 Iron 300 2005 995 439

2006 370 1000 480 2007 860 809 311

Umts-ugll USEPA secondary MeL Total metals (nonfiltered)

RES07 5.4

Landfill Gas Monitoring

Landfill gas is monitored for % Lower Explosion Limit (LEL) at 11 locations at the Site on an annual basis per the approved OM & M Plan prepared by Golder Associates, Inc.

Historically, there have been detections ofcombustible gases near the former auction house building and equipment buildings. In response to the detections, monthly ambient air monitoring is conducted inside the buildings and continuous monitors for combustible gases have been installed. While, there were detections of landfill gases outside the buildings above 25% LEL, the interior monitoring has not detected landfill gases and there have been no alarms from the interior monitors. The results of the landfill gas monitoring program for 2006 - 2010 are summarized below in Table 9.

Table 9: Landfill Gas Monitorinll Results for % LEL_(2006-2010) LFG Monitor

2006 2007 2008 2009 2010

GMP-l 0 0 0 4 0 GMP-2 0 0 0 6 0 GMP-3 > 75* >75* 0 32 18 GMP-4 1 0 0 4" 0 GMP-5 0 0 0.1 4 0 GMP-6 0 0 0 0 0 GMP-7 0 0 0 NS NS

20


GMP-8 4 0 NS 36 0 GMP-9 4 0 NS 51 1 GMP-I0 0 0 NS NS NS GMP-ll > 75* 0 NS 6 1 LEL-Lower Explosive Limit NS-Not sampled due to access issues Reading exceeded maximum reading on the meter (> 75 % LEL)

Vapor Intrusion

Vapor intrusion is not considered a pathway of concern at the Site. As stated in the Final Notice of Deletion: "Vapor intrusion is not considered a pathway ofconcern based on Site conditions and monitoring results. The sentinel well and residential wells have not detected VOCs. The diabase naturally contains the groundwater and discharges the groundwater to the local stream prior to the residential properties, so there is no hydraulic connection to the Site. The landfill is covered, the on-Site groundwater concentrations have demonstrated degradation and declining levels, there are restrictions on use of the property, and landfill gases are monitored inside and outside the buildings on-Site."

Site Inspection

EPA conducted two Site inspections for this Five-Year Review. The first inspection, performed by the EPA RPM on May 17, 2010, consisted ofwalking the eastern landfill cap, the perimeter of the eastern landfill, inspection of the leachate ponds, northern drainage area, and inspection of the area behind the equipment building. The second inspection was conducted by EPA and PADEP representatives on May 26,2010. During the May 26th inspection, the EPA and P ADEP inspected the western landfill, the perimeter road around the western landfill, the Site monitoring wells, the central drainageway area and the eastern landfill cap area.

Below is a summary of the items noted during the inspections that will require follow-up action(s). However, none of the items noted currently prevent the response action from being considered protective ofhuman health and the environment (nor would they affect the future protectiveness). EPA will forward the results of the inspections to the PRP with a request that a schedule, listing a date for the completion of each noted item, be provided.

The following is a list of items identified during the May 17th and May 26th Site inspections: 1. A poplar tree (approximately 20' tall), growing on the western side of the eastern landfill,

needs to be removed (The tree was completely removed by the PRP during the week of June 13,2010);

2. Minor erosion damage to the access road at the SW comer of the eastern landfill needs to be evaluated and repaired, if necessary;

21


3. Several minor leachate seeps on the eastern landfill require repair (Work to repair the seep areas was performed from June 8, 2010 to July 2,2010);

4. The drainage swale along the east side access road of the eastern landfill needs to be evaluated for effectiveness and repaired, if necessary;

5. The central drainageway culverts were blocked by debris at the time of the inspections; 6. The rip-rap stone placed around the newly installed drainage pipes in the central

drainageway has experienced some recent erosion; 7. Inspect and repair, as necessary, the landfill gas vents on the eastern landfill; 8. Evaluate the persistent landfill gas odor in the area of the shed adjacent to the leachate

ponds and monitoring well MP-18S; 9. Several monitoring wells identified during the Site inspection(s) could not be located on

the current Site maps (i.e. the "Site Features and Monitoring Point Locations" map that is included in the Annual Report). Site maps need to be evaluated and updated as necessary;

10. Maintain the overgrowth on the access road around the western landfill to make the road more accessible; and

11. Permanent identification is needed on all of the Site monitoring wells and gas probes

Interviews

The following interviews were conducted for the Five-Year Review.

Interview # 1 - Tim Gallagher interviewed the Spring Township Manager, Leon Mazurie, on May 19, 2010. Mr. Mazurie stated that the Township has not received any complaints or inquiries regarding the Site nor have there been any police response actions regarding the Site. Mr. Mazurie also informed the EPA that Spring Township had recently purchased 120 acres of land immediately adjacent to the Site with plans to construct a township park: on the space and that the only recent subdivision in the area around the Site is Wheatfield Run, which is located west of the Site on Wheatfield Road. Mr. Mazurie had no further comments or questions regarding the Site.

Interview # 2 - Tim Gallagher interviewed Kevin Bitz, Spring Township Environmental Waste Coordinator, on May 20,2010. The discussion essentially revolved around Mr. Bitz's skepticism regarding the volume ofleachate that the township treatment plant receives from the Site. Mr. Bitz indicated that it is not uncommon for the township treatment plant to receive leachate volumes of 50,000 gallons in a single 24-hour period from the Site and, he feels, that it is possible that a significant percentage of the received leachate may actually be a combination ofleachate, groundwater and stormwater. Mr. Bitz then indicated that installation ofa flow meter within the leachate collection manhole would help identify the percentage ofactual leachate that flows into the collection ponds. The information listed in Table 10 was provided by Mr. Bitz and summarizes the daily volume ofleachate in April 201 O.

22


, ~p: eac ow &Dil am a o asTable 10 A , ril2010 Daitly L ha e t Fl V I oumes a IY R'fllTtl

Date landfill Site Dally Flow

, Total

landfill Site Dally Rainfall

Total Date

Landflll Site Dally Flow

Total

landfill Site Dally Rainfall

Total 1-Apr-10 47832 0.00 18-Apr-10 0 0.00 2-Apr-10 47828 0.00 19-Apr-10 0 0.00 3-Apr-10 47,776 0.00 20-Apr-10 0 0.00 4-Apr-10 47,812 0.00 21-Apr-10 32584 0.01 5-Apr-10 . 47888 0.00 22-Apr-10 25276 0.00 6-Apr-10 47940 0.00 23-Apr-10 25276 0.00 7-Apr-10 48120 0.00 24-Apr-10 25276 0.32 8-Apr-10 48,280 0.43 25-Apr-10 25,276 1.10 9-Apr-10 48608 0.00 26-Apr-10 50,632 0.36

1 0-Apr-1 0 48704 0.00 27-Apr-10 50 512 0.00 11-Apr-10 48,604 0.00 28-Apr-10 50,392 0.00 12-Apr-10 48900 0.00 29-Apr-10 50,228 0.00 13-Apr-10 49040 0.08 30-Apr-10 40632 0.00 14-Apr-10 49,056 0.00 15-Apr-10 49,080 0.03 Minimum 0 0.00 16-Apr-10 18248 0.00 Maximum 50,632 1.10 17-Apr-10 34,672 0.61 Average 38,482 0.10

Total 1,154,472 2.94

Interview # 3 - Tim Gallagher interviewed the current owner ofParcels B and C, on May 25, 2010. The owner noted several items during the interview; 1) It appears that there have been instances of illegal dumping occurring on the property north ofWheatfield Road, specifically, five"containers ofwaste oil have been placed on the property; 2) The contractor who is tasked with performing the annual mowing of the eastern landfill is not only taking too long to cut the grass but may be causing damage to the cap area, evidenced by rutting and other tire marks in the capped area during and after the mowing; and 3) The owner indicated that at least one of the leachate pumps was not operating properly, requiring contractor personnel to be on-Site more often than is usual (The pump was replaced on June 7, 2010). EPA infonned the owner that these items would be noted in the report and also discussed with the current PRP consulting finn, Blazosky.

Interview # 4 - Tim Gallagher interviewed Dave Hrobuchak, P ADEP Project Manager for the Site, on several occasions between March and June 2010 regarding the Site. Mr. Hrobuchak's familiarity with both the Site history and the Site features were very useful to EPA during this Five-Year Review preparation. Mr. Hrobuchak's main concerns with the Site involve the eastern

23


landfill leachate seepage and the frequent partial blockage of the central drainageway. Mr. Hrobuchak also asked that the minor erosion across the eastern landfill access road be evaluated further.

Interview # 5 - Tim Gallagher interviewed Ed Layton, Blazosky Project Manger, on May 27th•

Mr. Gallagher relayed to Mr. Layton the concerns (noted above) brought by both, the Parcel B and C property owner and Spring Township Environmental Waste Coordinator, Kevin Bitz. Mr. Layton responded by addressing several of the individual items discussed, stating that 1) the inoperable leachate pump was scheduled for replacement in June 2010 (this work was performed), 2) Mr. Layton will discuss the property owner's concern regarding the damage to the eastern landfill cap as a result of the annual mowing with the landscaping contractor, and 3) the volume ofleachate generated will be investigated by Blazosky. Mr. Layton also stated that in the coming months, a new environmental monitoring schedule, for years 2011 through 2015, will be proposed to EPA.

Vll. Technical Assessment

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

The review ofrelevant documents and reports along with the Site inspection results indicate that the remedy is functioning as intended by the ROD. The landfill caps and drainage structures are functioning properly with some minor deficiencies, for example, minor seepage through the eastern landfill cap that required repair (The seep repair work was performed by the PRP consultant, Blazosky, between June 8, 2010 and July 2, 2010). The eastern landfill vegetative growth is sufficient to prevent erosion and to protect the cap system. The western landfill has been kept as forest. At the time of the Site inspection, the access road around the eastern landfill was sufficient for passage with only minor erosion damage that may require repair. The access road around the western landfill was passable although some overgrowth requires removal. The leachate collection system is being operated and maintained. The capacity of the three lagoons is sufficient; the liners appear to be intact; and the Spring Township treatment plant is capable of treating the leachate. Annual residential groundwater monitoring is performed and the data shows that federal drinking water standards are being met. The groundwater data supports the natural containment and natural attenuation remedy. An aquatic habitat survey was completed in 2009 but was not ready for EPA review at the time of this submission. However, the survey did reach the following conclusion: "Overall, in-stream macroinvertebrate communities at the sampling stations contained a large number and diverse benthic community ...The in-stream habitats sampled contained a relatively diverse and abundant aquatic community that is able to support a healthy and functioning population of aquatic life."

The ROD-required institutional controls have been legally implemented and the controls are being adhered to. The use restrictions on the properties have been placed into the claims of

24


title for these properties. The regular monitoring, maintenance, and site inspections confirm that on-Site groundwater is not being consumed; there have been no earth moving activities on-Site that are not associated with the maintenance of the remedy; and the land use changes have not affected the remedy.

Question B: Are the exposure assumptions, toxicity data. cleanup levels, and RAQs used at the time of the remedy still valid?

Applicable or relevant and appropriate public health or environmental standards are identified in the ROD. Many of these standards were met during construction of the remedy and the remaining standards are being achieved through the continued operation and maintenance at ~~~ .

The RAOs identified in the ROD have either been met or continue to be met: Institutional controls prohibit consumption of Site groundwater; long-term monitoring ensures that MCLs or MCLGs continue to be maintained at the point of compliance; Site leachate continues to be effectively collected; and the landfill caps continue to be maintained.

Changes in Standards and To Be Considereds (TBCs)

There are a series ofApplicable or Relevant and Appropriate Requirements (ARARs) identified in the ROD. Many of the ARARs were met during construction of the remedy (e. g. the Pennsylvania Erosion Control Regulations, 25 PA Code 102.1 - 102.5, 102.11 - 102.13, and 102.21-102.24.) and the remaining ARARs are being achieved during the operation and maintenance of the Site (e. g. Compliance with groundwater concentration limitations at the point ofcompliance required by Section 121(d)(2)(A)(i) and (ii) ofCERCLA and 40 C.F.R. Section 3oo,430(e)(2)(i)(B). Those limitations are established at 40 C.F.R. Sections 141.11 - 16, 141.50 - 51, and 141.60 - 63). There have been no changes to the standards that would affect the protectiveness of the remedy.

There have been no changes in the physical conditions of the Site that would affect the protectiveness of the remedial action or would suggest that the selected remedial action is not protective. Ownership of Parcels B and C were transferred to a private purchaser in 2005 (Parcel B) and 2006 (Parcel C). The property deeds include the respective use restrictions consistent with the UAO for the Site.

Changes in Exposure Pathways, Toxicity, and Other Contaminant Characteristics

There have been no changes in exposure pathways, toxicity or other contaminant characteristics since the last Five-Year Review.

25


Vapor intrusion is usually considered a potential exposure pathway at sites with VOC contamination. However, vapor intrusion is not considered a pathway of concern at this Site based on Site conditions and monitoring results. The sentinel well and residential wells have not detected VOCs. The underlying diabase naturally contains the groundwater and discharges the groundwater to the local stream prior to the residential properties, so there is no hydraulic connection to the Site. The landfill is covered, the on-Site groundwater concentrations have demonstrated degradation and declining levels, there are restrictions on use of the property, and landfill gases are monitored inside and outside the Site buildings.

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

There is no other information that calls into question the protectiveness of the remedy.

Technical Assessment Summary

According to the data reviewed and the results of the Site inspections, the remedial action is functioning as intended. The approved Operation, Maintenance and Monitoring Plan appears to be effective in maintaining all the elements of the selected remedy and institutional controls are in place that effectively restrict the land use. The RAOs have either been met or continue to be met and vapor intrusion is not considered a potential exposure pathway ofconcern.

vm. Issues

There have been no issues identified at the Site that currently prevent the response action from being considered protective. A series ofitems identified during recent inspections will require follow-up but are not expected to impact the protectiveness of the remedy.

IX. Recommendations and Follow-Up Actions

No issues have been identified.

x. Protectiveness Statement

The remedial action implemented at the Site is protective ofhuman health and the environment. The leachate collection system effectively conveys leachate to the Site storage ponds, the landfill caps prevent exposure to the Site wastes, long-term monitoring ensures that Site groundwater goals continue to be met and institutional controls have been implemented that effectively limit Site use activities to ensure continued protectiveness.

26


XI. Next Review

The next Five-Year Review will be completed no later than five years from the signature date of this Five-Year Review.

27

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FIGURE 6

Monitoring Schedule 2006-2010

Annual Monitoring Events Berks Landfill Superfund Site

Monitoring Point 10 Year 6 (2006) Year 7 (2007) Year 8 (2008) Year 9 (2009) Year 10 (2010)

WL, VOCS, Metalsl , WL, VOCS, Metalsl

, WL, VOCS, Metalsl , WL, VOCS, Metalsl

, WL, VOCS, Metals\G-l, G-4, C-75, C-70, G-6, G-13, MP-l85, GR-l80, G-5, G-l2

Field, NA Field, NA Field, NA Reid, NA Field, NA

WL, VOCS, Metalsl , WL, VOCs, Metalsl

, WL, VOCs, Metalsl , WL, VOCS, Metalsl

, WL, VOCs, Metalsl ,

Sentinel Well Field, NA Field, NA Reid, NA Field, NA Field, NA

C-35, C-30, MP-l6 VOCS, Field, NA VOCs, Field, NA G-ll,MP-l6, MP-145, MP-140, MP-ll, MP-l95, GR-l90, C-65, C-60, MP-l55, MP-l50, C-5, C-45, C-40, C-35, C-30, G-2, G-3, WL WL WL WL WL

G-S. G-7. G-lO

VOCS, Metals2, FieldThompson, Buller (2), Remp, Bino, Bishop, Cremer, Faust 10 VOCS, Metals2

, Field VOCS, Metals2, Field VOCs, Metals2

, Field

Pti+Ytull'f&M*¥tW*.li'wa""""""'hw,ttrrrtte,trt,••,.,.,:,tyet=t__,.,fflBWmffl\ifIt". GMP-l through GMP-ll %LEL %LEL %LEL %LEL %LEL

liN1@bU¥?t#iiumitf.'~#.f:*,.,.",.,lftt+r"\t;tt1l$77:'t ·'''WlfttriWtt.'M':rrM,,,MtfttntBWlmleltfMt'tiNfi'+&r4 VOCS, Metals3, Field,

5WOl through 5W08 9 Hardness, TS5

H:~f:_tnti_4jMa~k8tlfii1{ii&tttwejw••ft"@rt';••'_"""li*t'f""mse*tWftrnM,.tmiliw:f¥F%,\(Mrfi&6liiiitim r j

VOCS, Metals2, TOC, % 5EDOl through 5ED08 9 Moist., %50lids, Grain

5ize

Identification andMIDl through MID8 9 Enumeration

Notes: 1. Metals include total (unfiltered) and dissolved (filtered).

2. Total (unfiltered) metals only. 3. Dissolved (filtered) metals only.

4. WL indicates water level measurement. 5. "Field" indicates field parameters of: Temperature, pH and SpecifIC Conductance. 6. NA indicates natural attenuation parameters consisting of: Dissolved Oxygen, Redox Potential and Turbidity. 7. Equipment building will be monitored monthly for combustible gas at the time of the monthly leachate system inspections. 8. "Other" includes: BOD, Suspended Solids, NH3, N02, N03, TKN, en, Phenols. 9. The Aquatic Bioassessment is to be performed the year prior to the next five-year review period (Le., 2009). Surface water, sediment and rnacroinvertebrate sampling and analysiS procedures will be

in accordance with the USEPA-approved Aquatic Assessment Work Plan (Golder, March 1999) modified based on the subsequent monitoring year1s results.

10. Added to monitoring schedule in 2007 at request of resident.

Blazosky Associates, Inc. Appendix 1

EPA Reviews Cleanup at Berks Landrdl Superfund Site

The U.S. Environmental Protection Agency (EPA) is conducting a Five-Year Review of the 60-acre Berks Landfill Superfund Site located in Spring Township, Berks County,Pa. The Berks LandfUI was closed in 1986 and EPA began its cleanup in 1988. This will be the second Five-Year Review of the site. The review will consist of inspecting the landfill caps, the groundwater monitoring systems, the leachate collection systems, and the institutional controls that ensure the integrity of these protective systems. The review will be completed by. the end of August 2010 and will be available for public review.

What is a Five-Year Review?

EPA inspects Superfund sites every five years to ensure that cleanups remain fully protective of human health and the environment. These regular review's, which are required by law when contaminants remain at a site, include~

• Inspection of the site and cleanup technologies • Review of monitoring data, operating data, and main

tenance records

To review the S-year . review document visit:

http://cfpub~epa.gov/

fiveyearl

Or visit: EPA's Reading Room 1650 Arch St. Philadelphia 215-814-3157 for appt.

To Comment on the Cleanup:

You may e-mail or maO. EPA Region 3

1650 Arch 8tJ:"eet (3H852) Philadelphia, PA 19103

Ruth Wuenschel Community I~volvement

Coordinator 215-814-5540

[email protected]

1 • .-____ "

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Appendix 2

second five-year review report berks landfill … · berks landfill superfund site in spring...

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