third five-year review report hellertown manufacturing ... · table 2: total system o&m costs,...

Third Five-Year Review Report

Hellertown Manufacturing Company Superfund Site

Hellertown Borough Northampton County, Pennsylvania

April 2010

PREPARED BY:

U. S. Environmental Protection Agency Region III

Philadelphia, Pennsylvania .

Date:

Hellertown Manufacturing Co. Superfund Site Third Five-Year Review Report April 2010

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TABLE OF CONTENTS List ofAcronyms.. : ................................................................ " .............v

Executive Summary ..............................................................................vi

Five-Year Review Summary Form .............................................................viii

I. Introduction........................................................................................ 1

II. Site Chronology ...... ;............................................................................2

III. Background....................... '.' .............................................................3 Physical Characteristics ......................................................................3 Land and Resource Use ...................................................................... 3 History of Contamination...................................................................................4 Initial Response ..................................................................................5 Basis for Taking Remedial Action .................... ~ .....................................5

IV. Remedial Actions ......................................................................................6 Remedy Selection ...................................................................... '.' ......6 Remedy Implementation ............................................................................................7 System Operation/Operation & Maintenance.....................................................................................8

V. Progress Since the Last Five-Year Review .................................................................9

VI. Five-Year Review Process ................·.........................................................12 Administrative Components ...................................................................12 Community Involvement. ......................................................................12 Document Review ................................................................................. 12 Data Review ......................................................................................13 . Site Inspection ......................................... '.' ....... :................................. 16 Interviews........................................................................................17

VII. Technical Assessment .......................................................................... 17

Question B: Are the exposure assumptions, toxicity data, clean-up levels, and Remedial

Question C: Has any other information come to light that calls into question the

Technical Assessment Summary .....................................................................20.

Question A: Is the remedy functioning as intended by the decision documents? ............. .17

Action Objectives used at the time of the remedy selection still valid? ............................. 18

protectiveness of the remedy? .............................................................................................20

VIII. Issues..............................................................................................20

III


IX. Recommendations and Follow-Up Actions ....................................................20

X. Protectiveness Statement ............................................ '" ........................21

XI. Next Review ......................................... ;...........................................21

Tables Table 1: Chronology ofSite Events Table 2: Total System O&M Costs, 0112005 - 1212009 Table 3: Actions Taken Since the Last Five-Year Review Table 4: Maximum 2009 Contaminant Levels in the Overburden Wells Table 5: Maximum 2009 Contaminant Levels in the Shallow Bedrock Wells Table 6: Maximum 2009 Contaminant Levels in the Deep Bedrock Wells Table 7: Maximum Surface Water Contaminant Concentrations, 2000 - 2008 Table 8: Issues Table 9: Recommendations and Follow-Up Actions

Figures Figure 1: Site Location Map Figure 2: Site Layout Figure 3: Property A - Sample Locations Figure 4: Property B - Sample Locations Figure 5: Former Manufacturing Building - Sample Locations Figure 6: Groundwater Quality Map Figure 7: Overburden Groundwater Contour Map Figure 8: Overburden TCE Isoconcentration Map Figure 9: Shallow Bedrock Groundwater Contour Map Figure 10: Shallow Bedrock TCE Isoconcentration Map Figure 11: Deep Bedrock Groundwater Contour Map

Attachments Attachment 1: Five-Year Review Site Inspection Checklist

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Hellertown Manufacturing Co. Superfund Site Third Five-Year Review Report Apri12010

l,l,l-TCA 1,2-DCE AOC ARAR CERCLA

CFR COC CSP EPA ESD FS GPM MC LTRA MCL MEK MSC MTBE NCP NPDES NPL OU PADEP PADER PAH ppb PRP RA RAO RCRA RD RIfFS ROD RPM SSC TCE UAO VOC VI.

List of Acronyms 1,1,1, -trichloroethane 1,2-dichloroethene Administrative Order on Consent Applicable or Relevant and Appropriate Requirement Comprehensive Environmental Response, Compensation, and Liability

. Act Code of Federal Regulations Contaminant(s) of Concern Champion Spark Plugs U.S. Environmental Protection Agency Explanation of Significant Difference Feasibility Study Gallons per Minute Methylene Chloride Long Term Remedial Action Maximum Contaminant Level Methyl Ethyl Ketone Medium-Specific Concentration Methyl tert-butyl Ether National Oil and Hazardous Substances Pollution Contingency Plan National Pollutant Discharge Elimination System National Priorities List Operable Unit Pennsylvania Department of Environmental Protection Pennsylvania Department of Environmental Resources Polyaromatic Hydrocarbon part per billion Potentially Responsible Party Remedial Action Remedial Action Objective Resource Conservation and Recovery Act Remedial Design Remedial InvestigationlFeasibility Study Record of Decision Remedial Project Manager State Superfund Contract Trichloroethene Unilateral Administrative Order Volatile Organic Compound Vapor Intrusion

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Executive Summary

The Hellertown Manufacturing Company Superfund Site (Site), located in Hellertown Borough, Northampton County, Pennsylvania is divided into two operable units: Operable Unit 1 (OU-l) - Installation of an impermeable cover over the former unlined drainage lagoons and Operable Unit 2 (OU-2) -:- Installation of a groundwater extraction and treatment system. The Site achieved construction completion status when the Preliminary Closeout Report was signed on September 26, 1996.

The trigger for this third Five-Year Review waS the completion date of the second Five-Year Review, April 29, 2005. As of this third 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 immediate threats have been addressed through the installation of the groundwater treatment system and the impermeable cover over the former lagoon areas.

The remedy is protective ofhuman health and the environment in the short term. In order to be protective in the long term the institutional controls identified in the Record of Decision need to be implemented, the groundwater cleanup standards need to be fmalized, and an evaluation to assess the potential for vapor intrusion should be completed.

The remedy for OU-l is protective ofhuman health and the environment in the short term. The placement of the impermeable cover over the former lagoon areas continues to protect on-Site receptors from direct exposure to Site contaminants and retard the downward migration of soil contaminants to the overburden, shallow bedrock, and deep bedrock aquifers. In order to be protective in the long term the institutional controls identified in the Record of Decision need to be implemented. In'the interim, exposure pathways that could result in unacceptable risks are being controlled.

The remedy for OU-2 is protective ofhuman health and the environment in the short term. The extraction and treatment system is effectively containing the contaminated groundwater plume and removing contan:tinants. In order to be protective in the long term the institutional controls identified in the Record ofDecision need to be implemented, the groundwater cleanup standards need to be finalized, and an evaluation to assess the potential for vapor intrusion should be completed. In the interim, exposure pathways that could result in unacceptable risks are being controlled.

Government Performance Review Act (GPRA) 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 Indicators Human Health: Current Human Exposure Controlled and Protective Remedy In-Place Groundwater Migration: Groundwater Migration Under Control

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Site-wide Ready for Anticipated Use (RAU) The Site is planned for Site-wide RAU on September 30,2011.

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Five-Year Re~iew Summary Form

SITE IDENTIFICATIO~

Site name: Hellertown Manufacturing Company Superfund Site

EPA ID: PAD002390748

EPA Region III Stat~: Pennsylvania City/County: Hellertown! Northampton County

SITE STATl'S

NPL status: X Final 0 Deleted 0 Other s

Remediation status: 0 Under Construction ~ Operating X Complete

Multiple OUs? X YES 0 NO Construction completion date: 09/27/1996

Has Site been put into reuse? DYES X NO

REVIE\V STATl :S

Lead a enc : X EPA 0 State 0 Tribe 0 Other Federal A enc Author name: Timothy M. Gallagher

Author title: Remedial Project Author affiliation: U. S. EPA - Region) Manager

Review period: 10/29/2009 to 4/2010

Date(s) of Site inspection: 1122/2010 and 2/19/2010

Type of rt:view: X Post-SARA 0 Pre-SARA 0 NPL-Removalonly o Non-NPL Remedial Action Site 0 NPL StatelTribe-lead

Review number: 0 1 (frrst) 0 2 (second) X.3 (third) Other

Triggering action: Previous Five-Year Review Report

Triggering action date (from WasteLAN):04129/2005

Due date (five years after triggering action date):04/29/2010

Vlll


Five-Year Review Summary Form, conunued

Issues: 1. Selection and implementation of institutional controls. 2. Determine groundwater cleanup standards. 3. Vapor intrusion.

Recommendations and Follow-up Actions: 1. Preparation of an environmental covenant for the property. 2. Issue decision document. 3. Complete the vapor intrusion evaluation.

Protectiveness Statement(s):

. The remedy is protective ofhuman health and the environment in the short term. In order to be protective in the long term the institutional controls identified in the Record of Decision need to be implemented, the groundwater cleanup standards need to be finalized, and an evaluation to assess the potential for vapor intrusion should be completed.

The remedy for OU-l is protective ofhuman health and the environment in the short term. The placement of the impermeable cover over the former lagoon areas continues to protect on-Site receptors from direct exposure to Site contaminants and retard the downward migration of soil contaminants to the overburden, shallow bedrock, and deep bedrock aquifers. In order to be protective in the long term the institutional controls identified in the Record of Decision need to be implemented. In the interim, exposure pathways that could result in unacceptable risks are being controlled.

The remedy for OU-2 is protective ofhuman health and the environment in the short term. The extraction and treatment system is effectively containing the contaminated groundwater plume and removing contaminants. In order to be protective in the long term the institutional controls identified in the Record of Decision need to be implemented, the groundwater cleanup standards need to be finalized, and an evaluation to assess the potential for vapor intrusion should be completed. In the interim, exposure pathways that could result in unacceptable risks are being controlled.

Other Comments:

Nothing noted.

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.I. Introduction

The purpose of the Five-Year Review is to determine 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 -identify recommendations to address them.

The U.S. Environmental Protection Agency (the Agency or EPA) is preparing this Five-Year Review report pursuant to the Comprehensive Environmental Response, Compensation, and

. Liability Act (CERCLA) §121.and the National Contingency Plan (NCP). CERCLA § 121 states;

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 [106 j, the President shall take or require such action. The President shallreport to the Congress a list offacilitiesfor 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 of Federal Regulations (CFR) § 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, has conducted this third Five-Year Review of the remedial actions implemented at the Hellertown Manufacturing Company Superfund Site (the Site) located in Hellertown, Pennsylvania. The triggering action for this review is the completion date of the second Five-Year Review, April 29, 2005, as shown in the EPA's WasteLAN database. This review was conducted· for the entire Site from October 2009 through April 2010 by the Remedial Project Manager (RPM). This report documents the results ofthe review.

This 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 hi e 1 ChronoI02Y 0 fSOt Even s ta .- 1 e Event

Plating and degreasing processes are performed at the Site. Pennsylvania Department of Environmental Resources (PADER) conducts the Preliminary Assessment of the property. Site Community Relations Plan is finalized. The potentially responsible party (PRP) and EPA enter into an Administrative Order on Consent (AOC). The Site is placed on the National Priorities List (NPL). Draft Remedial InvestigationlFeasibility Study (RIIFS) is complete and available to the public. The Proposed Plan, identifying EPA's preferred remedy is presented to the public; start ofpublic comment period. Public Meeting is held.

The Record ofDecision (ROD) is signed. Start of on-Site Remedial Action (RA).

Completion ofon-Site groundwater treatment system and impermeable cover.

Commencement of the operation of the groundwater treatment system.

Preliminary Closeout Report (PC OR) completed.

Groundwater treatment system taken off-line due to screen deterioration and pump malfunction. Groundwater treatment system considered operational and functional and commencement of Long Term Remedial Action (L TRA). Installation of new extraction well.

"Design Review Results and Recommendations" report completed.

Groundwater treatment system operation halted and modifications implemented. Groundwater treatment system re-started.

Initial Five-Year Review completed.

Final Remediation System Evaluation Report completed.

Transfer of operable unit 1 (OU-1) landfill cap O&M responsibility to PADEP. Soil gas survey conducted in the vicinity of monitoring well CSP-7.

Date 1918 - 1982 1984

June 1987 February 1988

March 1989 July 1991

July 1991

August 1991

September 30, 1991 May 1993

January 1996

March 1996

September 27, 1996

August 1997

September 26, 1997

March 1998

October 1998

May-July 1999

August 1999

April 21, 2000

November 14,2001

June 2002

November 2002

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Event Date

Soil sampling conducted in the vicinity of monitoring well CSP-7. August 2003

Data Evaluation/Cleanup Status Report. July 25, 2004

Remediation System Evaluation Follow-up report (Site Optimization January 24, 2005 Tracker).

Second Five-Year Review is completed. April 29, 2005

Completion of the L TRA and transfer of O&M responsibilities to the September 26, 2007 Pennsylvania Department ofEnvironmental Protection (PADEP).

Performance ofa Vapor Intrusion (VI) study on the former manufacturing June 2008 - March building and two adjacent private residences. 2009

Groundwater Treatment System ShutdownlRebound test April 2009 - October 2009

III. Background

Physical Characteristics

The Site is located at 1770 Main Street (route 412)in the borough of Hellertown, Pennsylvania (Figure 1). Hellertown is a community ofapproximately 6,000 residents located in Northampton County. The Site occupies an 8.64-acre property with a 124,000 square foot brick manufacturing building located at the east (front) end of the property, facing" Main Street. Behind the manufacturing building is the former lagoons area that has been capped. The Site (Figure 2) is bound by Interstate Highway 78 to the north, residential and commercial properties to the south, Main Street and undeveloped land to the east, and by the unused Norfolk Southern Railroad property to the west. Additionally, Saucon Creek is located approximately 600 feet to the west of, and downgradient from, the Site, beyond the Norfolk Southern property.

Land and Resource Use

The Site was developed in 1918 for use as a spark plug manufacturing facility. As part of the manufacturing process, chrome and zinc plating processes, machining operations, and degreasing processes were conducted on-:Site. The Site was acquired by Hellertown Manufacturing Company, a subsidiary of the Champion Spark Plug Company (CSP), in 1950. The manufacturing company ceased production in 1982. Paikes Enterprises, Inc. purchased the property in 1988 and remains the current owner.

The property is currently zoned "highway commercial" and contains the former manufacturing building, the groundwater treatment plant building, and the asphalt-capped former lagoons area. An 8-foot chain link fence is installed around the Site perimeter. The

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surrounding area land use is residential, commercial, and recreational. Saucon Creek, which runs through Saucon Park, is used for swimming and fishing. Saucon Park is located immediately west of Saucon Creek.

In 2003, new townhomes were constructed between the Norfolk Southern property and Saucon Creek along Ravena Road, downgradient of the Site. Potable water is supplied to these townhomes by the Bethlehem Department of Water and Sewer Resources. Both Hellertown Borough and the City of Bethlehem mandate connection to the public water supply system for new residential construction.

The groundwater aquifer underlying the Site has been classified as a Class IIA aquifer, a current source ofdrinking water. The groundwater flow pattern in the bedrock in the vicinity of the Site is complex. However, water level measurements in monitoring wells indicate that groundwater generally flows in a westerly direction across the Site, ultimately discharging into Saucon Creek.

History of Contamination

The Hellertown Manufacturing Company Site was developed in 1918 as a spark plug manufacturing facility. Site operations included chrome and zinc plating operations, machining operations, and degreasing processes using trichloroethene (TCE). To conduct these operations, the plant used five underground storage tanks for storing machine oil and fuel oil. Between 1930 and 1976, plating wastes and spent de greasing fluids were disposed in five on-Site lagoons with a total storage capacity of 500,000 cubic feet. The lagoons were unlined, allowing waste to seep into the soil and bedrock beneath the Site. According to the Pennsylvania Department of Environmental Resources (PADER, which subsequently changed its name to the Pennsylvania Department of Environmental Protection (PADEP)), as noted in their 1984 Preliminary Assessment, the waste disposed in the on-Site lagoons included waste solutions and sludges generated by the manufacturing facility, zinc plating waste, chrome dip waste, cleaners, and cutting oils.

The lagoons were phased out of use by 1976 and backfilled primarily with material imported from off-Site. Records show that 60,000 cubic yards of this imported material was excavated soil from the construction of the Bethlehem wastewater treatment plant. Other materials used as fill included undocumented quantities of sillment powder, spark plug insulators, reject spark plugs and core assemblies, crushed stone, sand, broken brick and block, . and asphalt surface and stone ballast from a street expansion.

In the course of Site operations, spills occurred adding to the groundwater contamination. Additionally, a gravel-filled area located near the southwest comer of the building was used as an equipment wash area. This area received spillage associated with deliveries of products to the adjacent Site underground storage tanks. EPA identified the equipment wash area as an additional source of volatile organic compound (VOC) contamination in groundwater. The former equipment wash area is located immediately east

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of monitoring well CSP-7.

Contamination at the Site was discovered during a region-wide inventory of disposal lagoons conducted by the Sanitary Water Board of the Pennsylvania Department of Health and the Delaware River Basin Commission in 1970. Contamination in the backfilled lagoon soils and underlying lagoon sediment consisted primarily ofVOCs, including TCE and breakdown products, polyaromatic hydrocarbons (PAHs), and metals. Groundwater contamination consisted ofVOCs and metals. The estimated volume of the contaminated groundwater plume at the time the September 30, ·1991 Record of Decision (ROD) was prepared was 49 million gallons, encompassing an area of approximately 7.5 acres.

Initial Response

The Hellertown Manufacturing Company was able to phase out the use of the disposal lagoons by 1976 in favor of treating their wastewater and discharging it to the municipal sewer system (after the construction of the new wastewater facility in Bethlehem, PA). In 1982, after

. the plant operations ceased, CSP initiated procedures related to the sale of the property. Based on the results presented in the Preliminary Assessment and groundwater data collected by CSP's environmental consultant, O.H. Materials Company, in December 1984 and January 1985, P ADER requested that CSP prepare a workplan for additional subsurface investigations at the Site. After conducting additional subsurface soil sampling activities, groundwater sampling from newly installed monitoring wells, surface water sampling of Saucon Creek, and domestic well sampling for the area surrounding the Site, it was determined that VOCs (methylene chloride, TCE, tetrachloroethylene (PCE), vinyl chloride (VC), and trans-l ,2dichloroethylene (trans-l,2-DCE)) were present at concentrations exceeding the EPA Maximum Contaminant Levels (MCLs) established under the Safe Drinking Water Act, in down gradient monitoring wells. Additionally, trace levels ofVOCs were detected in two domestic wells located downgradient of the Site.

In February 1988, CSP and the EPA entered into an Administrative Order by Consent (AOC) that required that CSP conduct a Remedial Investigation (RI) and Feasibility Study (FS). The purpose of the RI was to determine the full nature and extent of the threat to the public health and welfare or the environment caused by the release or threatened release of hazardous substances, pollutants or contaminants from the Site .. The purpose of the FS was to develop and evaluate appropriate alternatives for remedial actions to prevent, mitigate or otherwise respond to or remedy the release or threatened release ofhazardous substances, pollutants or contaminants from the Site. The Site was listed on the NPL in March 1989. A draft RIfFS was completed and made available to the public in July 1991. In September 1991, the ROD was signed.

Basis for Taking Remedial Action

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

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Hellertown Manufacturing Co. Superfund Site Third Five-Year Review 'Report April 2010

Groundwater

PCE, TCE, cis-I,2-DCE, trans-l,2-DCE, 1,1, I-trichloroethane (l,I,I-TCA), vinyl chloride (VC), benzene, acetone, beryllium, chromium, cyanide (total), nickel, selenium, and antimony.

Dueto the presence of TCE, PCE, VC, 1,2-DCE, and various metals, risks from exposure to groundwater were significant. In order to reduce the risk associated with exposure to Site groundwater, the ROD established groundwater cleanup standards for the following VOCs that have been identified as the contaminants ofconcern (COC) for the Site groundwater: benzene, PCE, TCE, VC, cis-l,2-DCE, and trans-l,2-DCE.

Lagoon Sediment/Soil

TCE, PCE, 1,2-DCE, Polyaromatic Hydrocarbons (PAHs), 4-methyl-2-pentanone, carbon disulfide, ethylbenzene, xylenes (total), chromium, cyanide (total), and cadmium.

IV. Remedial Actions

Remedy Selection

The ROD was signed on September 30, 1991. The selected remedy described the actions required to address the contaminated soil and groundwater associated with the Site. For administrative purposes, the impermeable cover was later designated as Operable Unit (OU) 1 and the groundwater extraction and treatment system as OU-2. The selec~ed remedy also required long-term groundwater monitoring and deed restrictions.

OU-I, Impermeable Cover. The former lagoon area encompasses an area of approximately 145,000 square feet. An asphalt and clay impermeable cover was required to be constructed over the entire former lagoon area. The cover was required to achieve a permeability ofno more than 1 x 10-7 centimeters per second (em/sec). Astormwater collection system, consisting of catch basins and drainage pipes, was required to convey stormwater from the installed impermeable cap. The associated performance standards for the impermeable cap and stormwater conveyance system are as follows:

• Placement of an impermeable cover over the entire former lagoon area. The impermeable cover shall be designed to achieve a permeability ofno more than 1 X 10-7 em/sec;

• Surface water runoff controls. The installed runoff controls shall effectively collect stormwater from the parking lot and former lagoon areas and convey it to an existing storm drainage pipe on the northern boundary of the Site.

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OU-2, Groundwater Extraction and Treatment. Contaminated groundwater is pumped to the treatment system through extraction well EW-1 R. Pumped groundwater is directed to a 2,100gallon equalization tank located within the treatment plant building, where it is collected until it is sent, via centrifugal pump, through two in-series water filters to remove particulates, prior to entering the air stripper. Treated effluent is discharged to the storm sewer system, eventually emptying into Saucon Creek. Air stripper off-gas passes through two 2,000-pound vapor phase carbon units prior to discharge to the atmosphere. The associated performance standard for the groundwater extraction and treatment system is described below:

• Extraction and treatment, by air stripping and solids removal, of Site groundwater with discharge to Saucon Creek. Extraction, treatment, and discharge shall continue until such a time as EPA and the PADEP determine that the performance standard (either the MCL for the contaminant or the background concentration of the contaminant (the Pennsylvania ARAR under 25 PA Code §§ 264.90 - 264.100), whichever is more stringent) for each contaminant in the groundwater has been achieved to the extent practicable throughout the entire area of groundwater contamination both on-Site and off-Site (an estimated period of 30 to 40 years).

Thus, the performance standard for each COC in the groundwater is· the lower of the MCL or the established background concentration. But because the individual COCs were not detected in the background sampling, the performance standard is the lower of MCL or the method detection limit for the cae.

Long-Term Groundwater Monitoring. A long-term groundwater monitoring program shall be implemented to evaluate the effectiv~ness of the groundwater pumping and treatment system.

Deed Restrictions. As soon as practicable, restrictions prohibiting excavation of contaminated soils and the use of on-Site groundwater for domestic purposes shall be placed in the deed to the Site.

Remedy Implementation

As a result of failed negotiations (conducted between November 1991 and March 1992) with CSP for implementation of the selected remedy, EPA assumed the responsibility for its design and construction.

Remedial Action activities were initiated in May 1993 and included the construction of the impermeable concrete and asphalt cap over the former lagoon area, installation of the Site surface water and runoff controls, installation of the groundwater extraction well and hydrogeologic testing of the aquifer, installation ofthe monitoring well network, and construction of the groundwater treatment system and associated treatment plant building.

The Site achieved construction completion status with the signing of the Preliminary Close-Out Report on September 27, 1996. The ROD estimated that groundwater cleanup

7


objectives would be reached in approximately 30 to 40 years. A Final Close-Out Report will be prepared when the groundwater cleanup standards are met.

The United States, the Commonwealth of Pennsylvania, and the Settling Defendants entered into a Consent Decree, dated September 7, 2001, for reimbursement of outstanding response costs incurred by the United States and the Commonwealth in connection with the Site.

System Operation/Operation & Maintenance

The primary activities associated with the O&M of the impermeable cover include the following:

• Visual inspection of the capped area with regard to cracks in the cap surface, settlement, and stability;

• Repaving of the capped area, as needed; and • Inspection and maintenance, as necessary, of the installed gas vents.

PADEP assumed the 0 & M responsibilities for the impermeable cover in June 2002.

The primary activities associated with the O&M of the groundwater treatment system include the following:

• Inspection of the extraction well and treatment system for proper operation; • Servicing and repair or replacement of the groundwater treatment system

components; • Quarterly effluent sampling to ensure.effective treatment system operation and

compliance with the discharge parameters; and • Semi-annual monitoring of the Site groundwater monitoring wells.

The ten-year duration of the Long Term Remedial Action associated with OU-2 was completed on September 26, 2007. On that date, a Site inspection was conducted by EPA, PADEP officials and EPA's contractor, CDM, to document any items requiring EPA's further attention. As a result of the inspection, CDM performed the following activities: replacement ofmissing downspouts on the groundwater treatment plant, replacement of damaged process pipe insulation, and repair of a minor process pipe leak. The responsibility for all further Site O&M activities was transferred to PADEP in accordance with the State Superfund Contract (SSC) for OU-2, dated December 17, 1992 and amended in 1994 and 2002.

In October 2008, EPA approved a PADEP request to discontinue Saucon Creek surface water and sediment sampling. The approval was granted based on historical analytical data indicating that neither the surface water nor the stream sediments have ever contained contaminants of concern (COCs) that were either over their respective MCLs or soil to groundwater pathway numeric values during the eight years of sampling (2000 - 2008). The

8


approval was contingent upon continued monitoring of the wells directly up gradient of the Saucon Creek (CSP-16, CSP-17, CSP-I8, CSP-19, and CSP-27). Any evidence of increasing cac concentrations in these wells shall constitute cause to reinstitute the surface water and stream sediment sampling program.

The Operation and Maintenance costs (for bothOU-l and OU-2) incurred by EPA and P ADEPduring the period from January 2005 to December 2009 are summarized in Table 2.

Table 2 - Total System Operation O&M Costs (OU-l & OU-2), 0112005 - 12/2009 Dates Total Cost Rounded to the

Nearest $1,000.00

From To January 2005 December 2005 $109,000 January 2006 December 2006 $163,000 January 2007 December 2007 $118,000 January 2008 December 2008 $100,000 January 2009 December 2009 $106,000

V. Progress Since the Last Five-Year Review

This is the third Five-Year Review for the Site and the second review performed under EPA's Comprehensive Five-Year Review Guidance (June 2001). Table 3 summarizes the progress at the Site since the last Five-Year Review. The issues and recommendations in Table 3 were generated from the second Five-Year Review Report for the Site (April 2005). The statement on protectiveness from the second Five-Year Review declared:

"The remedy is protective ofhuman health and the environment in the shortterm and is expected to be protective in the long term when the groundwater cleanup goals are achieved which is expected to require 20 - 30 years.

The remedy for OU-l is complete and fully protective of human health and the environment. The placement of the impermeable cover over the former lagoon areas continues to protect on

. Site receptors from direct exposure to Site contaminants and retard the downward migration of soil contaminants to the overburden, shallow bedrock, and deep bedrock aquifers. Deed restrictions will prohibit the excavation of contaminated soils and the use of on-Site groundwater for domestic purposes.

The remedy for OU-2 is expected to be protective of human health and the environment upon attainment of groundwater cleanup goals through continued pumping and treating of contaminated groundwater. In the interim, exposure pathways that could result in unacceptable risks are being controlled."

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

Follow-up Actions 1. Continue Continue semigroundwater annual monitoring; monitoring and consider determine cleanup implementation of levels. proposed cleanup

levels.

2. Evaluate capture Continue semizone, additional annual evaluation extraction or of capture zone; monitoring wells. install monitoring

well at stagnation point.

3. Implement Continue Institutional negotiations with Controls. property owner.

4. Evaluate Evaluate new data pretreatment area and determine

appropriate course of action.

Party Milestone Responsible Date EPA/RAe Monitoring:

on-going. GW cleanup levels: discussions w/PADEP continue.

EPAIRAC On-going; September 2005

EPAIRAC June 2005

EPAIRAC September 2005

Action Taken/Outcome Draft Explanation of Significant Difference (ESD) prepared. Discussions w/PADEP continue. Installation of new monitoring wen CSP-30.

A PA-512 Order was drafted but never completed. Preparation of an environmental covenant for the Site is now planned. Soil and soil gas sampling was conducted in the area of well CSP-7. The sample results precipitated the vapor intrusion evaluation.

Date of Action Draft ESD prepared in April 2006.

New well installation: November 2005.

Environmental Covenant drafted in January 2010; currently under review.

Sampling: September 2007. Vapor intrusion evaluation: 2008-2009.

As outlined above there were four issues identified in the second Five-Year Review report. The status of each of these issues is summarized below:

Groundwater Cleanup Levels. In 2006, EPA drafted an ESD that would remove benzene from the list of COCs and change the groundwater cleanup standard from background levels to the MCL. Issuance ofthe ESD was put "on hold" per a request from PADEP to wait until the levels of contamination in the Site groundwater approached cleanup standards.

Evaluate Capture Zone. In order to better define the area of groundwater capture, a new monitoring well, CSP-30, was installed between the northern site (fenced) boundary and the wells that monitor the groundwater immediately upgradient of the Saucon Creek. The well was installed at a depth to monitor the shallow bedrock on property owned by the Norfolk Southern railroad.

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Hellertown Manufacturing Co. Superfund Site Third Five-Year Review Report Apri12010

Institutional Controls. The ROD calls for institutional controls, in the form of land and groundwater-use restrictions, to be implemented at the Site. A PA-512 Order was initially considered by EPA but was never finalized. EPA is currently in the process of preparing an environmental covenant in lieu of the 512 Order.

Vapor Intrusion. In 2002 and 2003, EPA's contractor collected soil gas and soil samples from the grassy area immediately south of the former manufacturing building. An evaluation of the data, as it relates to vapor intrusion, was performed in 2007. Based on the results ofa 2007 report, entitled: Vapor Intrusion Evaluation/or Off-Site Residences, prepared by EPA's former contractor, CDM, a vapor intrusion study was performed by EPA's current Remedial Action Contractor, Hydrogeologic, Inc. (HGL) between 200S and 2009. HGL was tasked with conducting Ii limited sampling effort to. assess whether vapors possibly emanating from documented groundwater contamination at the Site were impacting either nearby (off-Site) residences or the former (on-She) manufacturing building. As part of the sampling effort, HGL collected sub-slab air, indoor air and ambient air samples from in and around the three structures that constituted the study (Figures 3 - 5).

The results of the sample analyses indicated that vapor intrusion was not occurring at the two residences located off-Site (property "A" and property '"B"). However, because two of the sub-slab samples collected from property "B" contained levels of TCE (1.61 micrograms per cubic meter (llg/m3) and 2.69 llg/m3) above the health-based value of 1.2 llg/m3, HGL recommended that EPA implement an indoor air monitoring program at the property. EPA has' evaluated HGL.'s recommendation and has decided to collect an additional round of indoor air and sub-slab samples from Property "B".

The sample results also indicated that vapor intrusion may be occurring within the former manufacturing building due to the fact that one of the indoor air samples collected within the former manufacturing building exhibited results for TCE at a concentration (4.5 Ilg/m3) that exceeds its health-based value. The former manufacturing building is currently unoccupied. EPA is currently in the process ofpreparing an environmental covenant for the property that will address, among other things, the possibility ofvapor intrusion at new and existing structures on-Site.

If groundwater concentrations increase significantly, then another round ofvapor intrusion sampling should be performed on all previously sampled properties. If the groundwater concentrations remain about the same or are reduced, the sub-slab/indoor air concentrations should also remain about the same or be reduced.

Well Abandonment. In order to facilitate the transition of O&M responsibilities from EPA to PADEP, in 2007 PADEP requested the abandonment of several monitoring wells associated with the Site. Abandonment ofwells CSP-9, CSP-23, CSP-2S, and CSP-29 was performed in September 2007 by CDM, under a contract with the EPA, in accordance with the Water Well Abandonment Guidelines contained within the P ADEP Groundwater Monitoring Guidance

11


Manual. One damaged well, CSP-22, was remediated in September 2007 to enable further sampling.

VI. Five-Year Review: Process

Administrative Components

The P ADEP, Hellertown Borough personnel, and the attorney representing the current property owner, Paikes Enterprises, Inc., were notified of the initiation of this Five-Year Review by letter from EPA in December 2009.

The Five-Year Review team was led by Tim Gallagher, the EPA Remedial Project Manager (RPM) for the Site. The Site team included Mindi Snoparsky, EPA Hydrogeologist, Nancy Rios-Jafolla, EPA Toxicologist, Sheila Briggs-Steutteville, Office of Regional Counsel, and Francisco Cruz, Community Involvement Coordinator.

Tim Gallagher established the review schedule, the components ofwhich included the following:

• Community involvement • Document review • Data review • Site inspection • Five-Year Review report development

Community Involvement

Notice of this Five-Year Review and solicitation of comments was published in a local newspaper, the Allentown Morning CalIon February 1,2010, by EPA Community Involvement Coordinator, Francisco Cruz. No comments have been received following the published notice.

Following signature of this Five-Year Review report a notice will be sent to the Allentown Morning Call 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 Hellertown Borough Municipal Building.

Document Review

This Five-Year Review consisted ofa review of relevant documents including:

• February 22, 1988 Administrative Order by Consent, U.S. EPA Docket No. 1II-88-11-DC

12


• September 30, 1991 Record of Decision • Remedial Action Report - Impermeable Cover, submitted by Ecology and

Environment, Inc., December 1994. • April 21, 2000 Initial Five Year Review Report • September 7,2001 Consent Decree, Civil Action No. 00-4977 & 00-4978 • April 29, 2005 Second Five Year Review Report • Vapor Intrusion Evaluation for Off-Site Residences, submitted by COM Federal

Programs. Corporation, August 14, 2007 • Revised 0 & M Plan, submitted by COM Federal Programs' Corporation, September

28,2007 • Monitoring Well Abandonment Report, submitted by COM Federal Programs

Corporation, September 28, 2007 • Final Technical Memorandum, Vapor Intrusion, submitted by HydroGeologic, Inc.,

May 29, 2009 • Semi-Annual Groundwater Monitoring and Operation and Maintenance Report,

submitted by AECOM Technical Services, Inc., December 2009 • Historical data (1990 - 2009) review ofVOC concentrations in each of the three

monitored groundwater zones: overburden, shallow bedrock and deep bedrock

Data Review

Operable Unit 2, Groundwater

Groundwater sampling is conducted for the extraction well (EW) and the (Overburden, Shallow Bedrock, and Deep Bedrock) monitoring wells ona semi-annual basis by PADEP. However, monthly groundwater sampling was conducted during a groundwater treatment system shutdown/rebound test conducted from April 2009 through October 2009. Tables 4 through 6 list the maximum 2009 groundwater contaminant levels reported for each of the monitored zones. A groundwater quality map, which shows the well locations and the associated October 19,2009 contaminant levels, is included as Figure 6.

Overburden Wells: CSP-1, CSP-2, CSP-3, CSP-4, CSP-7, CSP-to, CSP-16 and CSP-17 .

. The overburden groundwater flow direction is generally to the west, under static conditions, with an average hydraulic gradient of approximately 0.034 feet per foot (see Figure 7). Overburden wells are screened in the overburden with a screened interval shallower than 100' below ground surface (bgs).

Other than the minimal exceedance at CSP-4 (see Table 4), TCE-impacted groundwater in the shallow (overburden) aquifer appears to be concentrated in the general vicinity of the CSP-7 and CSP-10wells (both wells were installed at similar depths; approximately 40' bgs, and at similar screened intervals; approximately 30' - 40' bgs). CSP-10 is the only overburden well that exhibited an exceedance of the MCL for PCE. The 2009 contaminant concentrations in the overburden wells have remained relatively consistent with sampling results over the

13


previous 5 years with no significant increasing or decreasing trends. A TCE isoconcentration map for the overburden wells is provided as Figure 8.

4 aXlmum I' th b ' e Well TCE PCE cis-l,2- trans-l,2- VC Benzene

DCE DCE MCLIMDL 5/0.12 5/0.03 70/0.12 100/0.10 2/0,18 5/0.20 CSP-l ND ND ND ND ND ND CSP-2 3.1 ND ND ND ND ND CSP-3 2.4 ND 1.1 ND ND ND CSP-4 5.1 ND 3.3 ND 0.64 ND CSP-7 42.4 2.1 4.1 ND ND ND CSP-I0 32.1 9.4 37.3 0.7 ND ND CSP-16 0.51 ND ND ND ND ND CSP-17 ND ND ND ND ND ND All values reported in ppb. MDL - Method Detection Limit

Table ..M ' 2009 C ontammant L eve s m e 0 ver urden Mom'tormg W IIs

Shallow Bedrock Wells: CSP-6, CSP-8, CSP-II, CSP-12, CSP-B, CSP-14, CSP-18, CSP-19, CSP-21, CSP-22, and CSP-30.

The Site shallow bedrock groundwater flow direction is generally to the west, under static conditions, with an average hydraulic gradient of approximately 0.03 feet per foot (see Figure 9). However, in the southeast comer of the Site, shallow bedrock groundwater flows in a northwestern direction at approximately 0.02 feet per foot. Shallow bedrock wells are screened in bedrock with a screened interval shallower than 100' bgs.

Other than the minimal exceedance at CSP-II, TCE-impacted groundwater in the shallow bedrock aquifer appears to be concentrated in wells located immediately downgradient of the former lagoons: CSP-6,CSP-12, CSP-B, CSP-14, and CSP-30, which is located approximately ISO' west of CSP-14. These wells are all installed at similar depths; approximately 70' - 85' bgs and at similar screened intervals; approximately 60' - 85' bgs. The 2009 contaminant concentrations in the shallow bedrock wells have remained relatively consistent with sampling results over the previous five years with no significant increasing or decreasing trends .. A TCE isoconcentration map for the shallow bedrock wells is provided as Figure 10.

a t L eve s m e k M om ormg sT ble 5 M .. aXlmum 2009 C ontamman I' the ShaIIow B d roc 't ' WeII Well TCE PCE cis-l,2- trans-l,2- VC Benzene

DCE DCE MCLIMDL 5/0.12 5/0.03 70/0.12 100/0.10 2/0.18 5/0.20 CSP-6 19.9 1.2 8.7 ND 0.51 ND CSP-8 1.9 ND ND ND ND ND CSP-ll 7.5 ND ND ND ND ND

14

Hellertown Manufacturing Co. Superfund Site Third Five~Year Review Report April 2010

CSP-12 29.l 0.69 10.8 0.89 ND ND CSP-13 67.2 3.9 6.8Q ND ND ND CSP-14 24.5 1.1 3.9 ND ND ND

. CSP-18 ND ND ND ND ND NO CSP-19 ND NO ND ND ND ND CSP-21 ND ND ND ND ND ND CSP-22 ND ND ND ND ND ND CSP-30 23.8" 2.0" 6.9" ND ND ND All values reported in ppb. Q - Average of multiple results or average of averages of dual column analysis methods. " - Duplicate sample was collected; the higher value was reported. MDL - Method Detection Limit

Deep Bedrock Wells: CSP-20, CSP-24, CSP-25, CSP-27 and EW-IR.

The deep bedrock grourtdwater flow direction is generally to the northwest, under static conditions, with an average hydraulic gradient of approximately 0.005 feet per foot (see Figure 11). Deep Bedrock Wells are screened in bedrock with a screened interval deeper than 100' bgs.

The deep bedrock groundwater sampling results indicate that there is very limited impact to deep groundwater from the Site. The 2009 contaminant concentrations in the groundwater samples are consistent with sampling events over the previous five years and do not indicate the presence of any significant increasing or decreasing trends. .

.Tbl 6 M . on ammant L th eep Bd eI' D e rockWIIsa e . aXlmum 2009 C t eve s m e Well TCE PCE cis-l,2- trans-l,2- VC Benzene

DCE DCE MCLIMDL 5/0.12 5/0.03 70/0.12 100/0.10 2/0.18 5/0.20 CSP-20· 104 ND ND ND ND ND CSP-24 ND ND ND ND ND ND CSP-25 1.7 ND ND ND ND ND CSP-27 ND ND ND ND ND ND EW-IR 2 ND 1.1 ND ND ND All values reported in ppb. MDL - Method Detection Limit

Surface Water Data

Surface water samples were collected at five locations (SW-l through SW-5) on the Saucon Creek, located approximately 600 feet downgradient of the Site, on a semi-annual basis from July 2000 through April 2008. Because there were no exceedances of the MCLs for any of the contaminants of concern over the approximate eight-year duration of the surface water monitoring program, EPA approved PADEP's October 2008 request to discontinue further

15


surface water sampling. However, as contained in the approval letter, should there be any evidence of increasing contaminant concentrations in the monitoring wells that were installed upgradient of Saucon Creek (CSP;.16, CSP-I7, CSP-I8, CSP-I9, and CSP-27), the surface water sampling program will be reinstituted.

Table 7 - Maximum Surface Water Contaminant Concentration* 2000-2008

Sample TCE cis-l,2 MC Chloro- MTBE MEK Ethyl- Total Toluene Acetone Location DeE methane benzene Xylenes SW-l NO NO O.IIB 0.121 NO NO 0.31 NO 0.033B NO

(12/05l {I2/06) (6/02) (12/05) SW-2 0.041 NO 0.12B NO NO NO NO NO 0.0288 171

(12/05) (12/05) (12/05) (6/01) SW-3 0.84 0.151 0.11B 0.191 NO NO NO NO ·0.035B 4.2 .

(6/03) (6/03) (12/05) (6/03) (12/05) (4/08) SW-4 0.051 NO 0.12B 11 NO NO NO NO 0.038 6.5

(12/05) (12/05) (7100) (12/05) (4/08) SW-5 ND NO 0.118 21 NO NO ND NO 0.0338 6.4

(12/05) (7/00) (12/05) (4/08)

*Values reported in ppb with corresponding sampling date in parentheses. B-Analyte present. Reported value may be biased low. Actual value is expected to be higher. J-Analyte present. Result may not be accurate or precise. ND - Non-Detect MC - Methylene Chloride MTBE - Methyl tert-butyl Ether MEK - Methyl Ethyl Ketone

Air Monitoring Data

The vapor phase carbon units, located downstream of the groundwater treatment plant air stripper, are metered with a photo ionization detector during each routine O&M visit. No detectable concentrations of VOCs in the air stripper off-gas have been detected over the prior five years.

Site Inspection

Because the groundwater treatment system is monitored remotely, the Site is unoccupied a majority of the time. An intact, six-foot chain link fence with a lockable vehicle entry gate off Main Street surrounds the property and is the major means of security for the Site. The Site buildings are currently unoccupied and, other than the continuous groundwater pumping and treating operations, there is no current activity on-Site. The Site is visited on a relatively infrequent basis by either PADEP, their O&M contractor, or the EPA.

An initial inspection of the Site was conducted on January 22, 2010 by Tim Gallagher, EPA RPM, Meg Boyer, PADEP, James Kunkle, PADEP, and Ron Schock, PADEP. A second Site inspection was conducted on February 19,2010. The second inspection was attended by Mr. Gallagher, Ms. Boyer and Charles Luthar, Hellertown Township Manager. The Five-Year

16


Review Site Inspection Checklist is included as Attachment 1.

The purpose of the inspections was to assess the protectiveness of the remedy, including the operation of the groundwater treatment system and the integrity of the installed cap system. The inspection participants also visited the off-Site discharge point at the (downgradient) Saucon Creek to inspect for impacts from Site stormwater and treatment plant effluent.

No significant issues were identified during the Site inspection; the cap system appeared to be free of cracks or other defects and the groundwater treatment system and the individual treatment system components appeared to be operating as intended. However, as pointed out by the PADEP representative during the second Site visit, becauserestrictor plates' have been installed on the asphalt cap catch basin drainage pipes to control stormwater discharge to the Saucon Creek, the storm water drainage rate, during times of moderate to heavy rainfall, is low, causing undesirable ponding on the capped area. During the second Site inspection, it was also noted that water was collecting within the concrete secondary containment vault around the effluent tank. P ADEP is currently investigating the cause.

Interviews

The Hellertown Borough Manager, Mr. Charles Luthar, was interviewed for this FiveYear Review. Mr. Luthar indicated that, other than inquiries about the availability of the property, he was unaware of any outstanding issues, complaints, or any other problems associated with the Site.

Other than inquiries about the availability ofthe property, PADEP officials were also unaware ofcomplaints or other issues associated with the Site brought by the surrounding community.

lim Profeto, senior project manager for PADEP's O&M contractor, AECOM, was also interviewed. Mr. Profeto indicated that AECOM was currently investigating a potential leak associated with a treatment system vessel or piping. No other issues were raised.

VII. Technical Assessment

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

Based on a review of the decision documents, surface and groundwater analytical data, monthly O&M reports, and Site inspections, the selected remedial action appears to be functioning as intended. The impermeable cap over the contaminated lagoon soils appears to be sound: preventing exposure through inhalation, ingestion, and dermal contact, and minimizing the infiltration of stormwater. The groundwater extraction and treatment system is effectively containing the contaminated groundwater plume and removing contaminant mass.

17

Hellertown Manufacturing Co. Superfund Site Third Five-Year Review Report April 2010 .

Although the groundwater treatment system is effectively removing groundwater contaminants and meeting the identified performance standards, P ADEP personnel are currently in the process ofattempting to identify optimization measures that may be implemented to more effectively target the areas ofgroundwater with the highest concentration levels.

P ADEP has also raised the matter of the possible existence of another contamination source at the Site. By letter of March 16, 2010, PADEP stated that "the levels ofTCE in the (former manufacturing building) subslab soil gas (30,000 - 100,000 ug/m3) seem to be too highto be coming from groundwater". The overburden groundwater monitoring wells closest to the manufacturing building typically exhibit TCE contamination levels in the 35 - 45 ug/l range. However, there is no current exposure to contaminated groundwater or soils at the Site, groundwater contamination levels in the Site monitoring wells have remained relatively constant, and the former manufacturing building is currently unoccupied.

The ROD called for institutional controls which would prohibit: 1) the use of on-Site groundwater for domestic purposes, and 2) excavation of contaminated soils. In light of the elevated levels ofTeE found in recent sub-slab soil gas samples, additional controls may be warranted to prevent exposure via vapor intrusion. However, regular monitoring, maintenance, and Site inspections confirm that contaminated soils have not been excavated, Site groundwater is not being used for domestic purposes, and the existing Site structures are not beIng occupied. Furthermore, preparation ofan environmental covenant is planned that would impose certain use restrictions on the property.

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

There have been no changes in the physical conditions of the Site that would affect the protectiven~ss of the remedial actions or would suggest that the selected remedies forOU-l and OU-2 are not protective. 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 Site.

The current groundwater cleanup standards listed in the ROD are the MCLs for each contaminant of concern or the background concentrations per the Pennsylvania requirement under PA Code §§ 264.90 - 264.100, whichever is more stringent. However, because these cleanup standards, which are actually the method detection limit for each contaminant due to the fact that background levels were not identified at the time of the ROD, are unlikely to be achieved, P ADEP has petitioned the EPA to consider changing the cleanup standards to the MCLs. Discussions with P ADEP regarding this issue are on-going.

Because vapor intrusion is a potential exposure pathway at sites with VOC contamination, EPA, in 2008-2009, performed an evaluation of the on-Site former

18


manufacturing building and two off-Site properties that are adjacent to the Site. The results of the manufacturing building analyses included one indoor air sample that contained levels of TCE above its health based value indicating that vapor intrusion may be occurring. The results of the off-Site residence analyses indicate that vapor intrusion is not occurring. However, because one of the properties exhibited COC levels in the sub-slab that were over the health based values, EPA will perform an additional round of sampling.

Changes in Standards and To Be Considereds (TOCs)

The selected remedy was designed to achieve compliance with applicable or relevant and appropriate requirements (ARARs) related to groundwater, ambient air quality and surface water at the Site. The groundwater ARARs for the Site that still need to be met include the Safe Drinking Water Act, 42 U.S.C. §§ 300(f) et seq., or the background concentration of the contaminant (the Pennsylvania ARAR under P A Code §§ 264.90 - 264.100). ARARs that continue to be met through Site O&M include the National Pollution Discharge Elimination System requirements under the Clean Water Act, the Pennsylvania Clean Streams Law criteria as set forth in 25 PA Code §§ 93.1 - 93.9 and Section 112 ofthe Clean Air Act, 42 U.S.C. §

·7412. During construction, dual vapor phase carbon units were installed to ensure compliance with Section 112 of the Clean Air Act, 42 USC § 7412 National Emission Standard for Hazardous Air Pollutants.

Changes in Exposure Pathways, Toxicity, and Other Contaminant Characteristics

The previous Five-Year Review mentions an evaluation of a nearby off-Site residence (the residence is identified in this report as "Property B") for vapor intrusion. It is stated that "EP A has determined that the need for indoor air monitoring does not exist at the residence because the soil boring and soil gas sampling results closest to this residence were nominal and groundwater flow is toward the west, away from the residence." In 2007, EPA again evaluated the potential for vapor intrusion at the property, and it was recommended that further site-specific vapor intrusion analyses be performed. Based on the 2007 recommendation, and because contamination oflocal groundwater persists, EPA's contractor, in 2008-2009, performed a vapor intrusion assessment of not only the property that was the focus of prior studies, but also on an additional property located adjacent to the Site as well as the unoccupied former manufacturing building. The results of the assessment indicate that vapor intrusion is not occurring within the two residences immediately adjacent to the Site, although an additional round of sampling is scheduled for "Property B" because of a potential concern over the sub-slab air sampling results. However, the data does indicate that vapor intrusion may be occurring within the unoccupied former manufacturing building because one of the indoor air samples contained TCE concentrations above risk-based values.

Other than consideration of the possible vapor intrusion issue within the on-Site manufacturing building and pending the results of the scheduled re-evaluation of "Property B", there have been no changes in exposure pathways, toxicity or other contaminant characteristics since the last Five-Year Review.

19


Installation and continued maintenance of the impermeable cap and continued operation and maintenance of the groundwater extraction and treatment system has significantly reduced exposure to the nearby residential and environmental communities.

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

There is no other inform~tion that calls into question the protectiveness of the remedial action selected in the ROD.

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 and maintenance plans appear to be effective in maintaining all the elements of the selected remedy. However, there is a need to identifY the final groundwater cleanup standards in a decision document and the results generated from recent vapor intrusion evaluations performed on and off-Site may warrant the implementation of additional controls at the Site.

VIII. Issues

Table 8 - Issues Issue Affects Current Affects Future Protectiveness?

Protectiveness? (yIN) (yIN) 1. Selection and implementation of N Y institutional controls 2. Determine groundwater cleanup N Y standards 3. Vapor intrusion N Y

IX. Recommendations and Follow-Up Actions

T able 9 - R ecommenda t'Ions andFIIo ow-U'P At'c Ions Affects

Issue Recommendationsl Party Oversight Milestone Protectiveness? Follow-Up Actions Responsible Agency Date (YIN)

Currentl Future

1. Selection Preparation of an EPA, EPA, 12/3112010 N Y and Environmental PADEP, PADEP Implemen- Covenant for the PRP tation of property Institutional Controls

20


2. Determine Issue decision EPA, EPA, 6/30/2011 N Y groundwater document PADEP PADEP cleanup standards 3. Vapor Complete the vapor EPA EPA 12/31/2010 N Y Intrusion intrusion

evaluation

x. Protectiveness Statement .

The remedy is protective of human health and the environment in the short term. In order to be protective in the long term the institutional controls identified in the Record of Decision need to be implemented, the groundwater cleanup standards need to be finalized, and an evaluation to assess the potential for vapor intrusion should be completed.

The remedy for OU-l is protective of human health and the environment in the short term. The placement of the impermeable cover over the former lagoon areas continues to protect on-Site receptors from direct exposure to Site contaminants and retard the downward migration of soil contaminants to the overburden, shallow bedrock, and deep bedrock aquifers. In order to. be protective in the long term the institutional controls identified in the Record of Decision need to be implemented. In the interim, exposure pathways that could result in unacceptable risks are being controlled.

The remedy for OU-2 is protective of human health and the environment in the short term. The extraction and treatment system is effectively containing the contaminated groundwater plume and removing contaminants. In order to be protective in the long term the institutional controls identified in the Record of Decision need to be implemented, the groundwater cleanup standards need to be finalized, and an evaluation to assess the potential for vapor intrusion should be completed. In the interim, exposure pathways that could result in unacceptable risks are being controlled.

XI. Next Review

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

21

N

o Ci N

PENNSYLVANIA 2000' o 2000' ---- -APPROX. SCALE IN FEET

NOTE: MAP DERIVED HELLERTOWN,

FROM U.S.G.S. 7 .5 MINUTE PA., DATED 1965, REVISED

TOPOGRAPHIC 1992.

QUADRANGLE,

FIGURE 1

~ SITE LOCATION MAP q AaCOM:g HELLERTOWN MANUFACTURING COMPANY ~ HELLERTOWN, PENNSYLVANIA ~ FEBRUARY 2010 101566 ~----------------------------~~~~~~------------------~~~

\/IIELl lOTALDEPll-i ) SCREENm NTERVAL EW-1R 219.00 85 ~ 219

N CSP·' 34.21 24·34 CSP-2 ....30 34-'" CSP-3 49.16 39·49 CSP.. 49.56 39-49 CSP-SA 79.42 69-79 CSP-5B 100.-40 90-100 CSP-SC 120.40 110-120 CSN' CSP-7 CSP-8 CSP-Il CSP-10 CSP_11 CSP-12 CSP-13 CSP·'4 CSP-16 CSP-17 CSP-18 CSP-19 CSP-2Q CSP-21 CSP-22 CSP-23 CSP-24 CSP-2S CSP-27 CSP-28/-78 WEST BOUND IOVERHEAD) CSP-29 CSP-3(J PZ-3 PZ-S , PUI/-78 EAST BOUND IOVERHEAD) , N01E:

/ /

CSP-12"t CSP-3

I

BRICK AND BLOCK

......, 74-M ~.67 30-40 58.91 ~-58

98.09 88-98 39.53 29-39 81.95 71 _ 81

75.71 65-75 79.68 69-79 81.09 71_81

'4.05 04-14 11.27 1.11

88.31 78-88 83.56 73-83 89.68 79-89 25.16 15 -25 79.45 69-79 31.09 21-31

298.82 288 - 298 201.36 191-201 219.78 209 - 219 114.51 104-114 202.80 192 - 202 71.50 60-70 25.77 15-25 25.95 15 -25 27.93 17-27

"Tl-E SCREE"-EO INTERVALS ARE ESllMAlEO.

FACTORYrNAREHOUSEIOFFICE

i >

-$LEGEND CSP-6

CSP-3"

CSP-6 -$

CSP·20 4>

EW·1 R ®

~ ~

- • -

,.

• --

OVERBURDEN WELL LOCATION ....CADAM

SHALLOW BEDROCK WELL LOCATION P....RKING LOT

DEEP BEDROCK WELL LOCATION

EXTRACTION WELL LOCATION O' 150' 300'NOTE ~~!ii_.,~~_""!

LOCATION CSP-2B, AND CSP-29 ARE CLOSEO SCALE SURFACE WATER/SEDIMENT SAMPLE 1. MONITORING WELLS CSp-g, CSP-23,

BASEMAP DERIVED FROM COM FEDERAL PROGRAMS CORPORAnON, MONITORING WELL LOCATION MAP • 4128104.AND ABANDONED.

UTILITY POLE FIGURE 22. MONITORING WELL CSP-l 0 HAS BEEN

CHAIN LINK FENCE RECLASSIFIED AS AN OVERBURDEN WELL BASED ON A REVIEW OF HISTORICAL DATA SITE LAYOUT AND A MORE DETAILED REVIEW OF THE A:COMWELL LOGS FOR THE SITE.CREEK HELLE~~~~ENRT~~~F~~~~~a,A~?:PANY

~:L-___-_-__-__--_._-_-___O:V~E:R~H~EA::D~W~I~R:E:S________________________________________________________________________L-______________________________________~F~EEB~R~UA~R~Y~2~O~1~O__________________________~1~O~15~6~6~

HGL - Technical Memorandum, Hellertown Manufacturing Co. Site - Hellertown, PA.

LegendPrqicel: EPAOJO-OI3·01·01·0:!·0] Ren'/sed: 0811 l i08 ND Figure 3

Sample Location Property A o (TeE concentnn ion flg/m3) Sample Locations

U.S'. EPA R" ; ~ion 3

HGL- Technical Memorandum. Hellertown Manufacturing Co. Site - Hellertown. PA.

LegendProject: HPA010-013-01-01-02-02 Revised: 08!11)o..~ ND Figure 4

Property B Sample Location o (TeE concentration IJg/m3) Sample Locations

U.S', EPA Region 3

HGL - Technical Memorandum, Hellertown Manufacturin~ Co Site. - Hellertown, PA.

LegendJ>mjccl: b"PAO/(J·(JIJ·OJ·OI·O;·02 Figure 5 Rew.,wJ: 1J8! I] 1()6' ND

Former Manufacturing Sample Location Building(TeE concentration Ilg/rr ')

Sample Locations

u.s. l:P A Region 3

N

CSP.z1~ I \.~ NOlIS • " I CSP-20 0.71 c~~I> ", TCE

" ~~.\ ~~i-~\V

) I ) ) ~ CSP~-16Ii ~I

0.51

1-78 WEST BOUND (OVERHEAD)

1-78 EAST BOUND (OVeRHEA~)"·,,YHAlN U"jK<l~" FENCE CSP-11A eF " ". C~' CSP-17 0 CSP-14 r-~y-=: • ..:::. -.~.~.~

TCE 2.1 v>C NO TCE

! / / .. s~ ., NO PCECIS-1.2-DCE~+..

tis CSP-30

' TCE . .. PCE 16.4

MACADAM/ CIS _1 2 DCE 0.B6~ /

PARKING LOT

, ! e . - 6.S'

o '" ~ LEGEND BRICK AND BLOCK FACTORYIWAREHOUSEIOFFICE

CSP-3 .. OVERBURDEN WELL LOCATION TREATMENT

~ PtA'"

CSP-6 + SHALLOW BEDROCK WELL LOCATION ~ 4; CSP-20 I> DEEP BEDROCK WELL LOCATION CS.... +

tJ Nil EXTRACTION WELL LOCATION . -C::::ZJ'-'~

MACADAMlIS UTILITY POLE ~ ~G _____~'~=-----.~ t" PARKINGGIJl!>~GE LOT NOTE CAOAM CSP-22- • - • - CHAIN LINK FENCE , NO1. CONCENTRATIONS SHOWN IN BOLD EXCEED (.

-_ .. . _- CREEK (:!:~1',~:~, .. csp,?:!~THE PA ACT" STATEWIDE HEALTH STANDARD. O' 150' 300' '.;()"~T: ~'3 r-_OVERHEAD WIRES !2. ALL WELLS SHOWN IN GRAY WERE NOT SAMPLED.

SCALETCE TRICHLOROETHENE (uglL) 3. MONITORING WELLS CSP-9. CSP-23. CSP-2B. AND CSP-29 B.b.SEMAP DERNEO FROM COM FEDERAL PROGRAMS CORPORA llON, MONITORING WElllOCAnON MAP - 4128104,

6Tt 1.2 _DCE 6~~;~~~~~L'g':~~H~~~)(UglL) ARE CLOSED AND ABANDONED. FIGURE 6 TRANS -1.2 - DCE TRANS - 1.2 - DICHLOROETHENE (uglL) 4. MONITORING WELL CSP-10 HAS BEEN RECLASSIFIED AS AN GROUNDWATER QUAUIY MAPAaCOM

111 VC VINYL CHLORIDE (uglL) OVERBURDEN WELL BASED ON A REVIEW OF HISTORICAL _ OCTOBER. 19 2009 q B BENZENE (uglL) DATA AND A MORE DETAILED REVIEW OF THE WELL LOGS

NO FOR THE SITE.~~~~~~~~:e:;L~~~g~~~g~~g HELLE~~~~~RT~~~F~~~~~~~A~?,.MPANY HIGHER VALUE RECORDED FEBRUARY 2010 101566

N

'

/ . o <;..., 1//

.,';,. /

~

!i ~ LEGENDItl

CSN" OVERBURDEN WEll LOCATION

. . ' .• -." .~ SHALLOW BEDROCK WEll LOCAnoN

':";' ~u J OEEPBEOROCKWEULOCATtON

F~' ;I~.. EXTRACTIONWELLlOCATlON

;.·,V :;~IU:·~·_ i. SURFACE WA TERiSEDlMENT SAIAPLE LOCATION

• unUTYPOlE

CHAIN UN!( FENCE

CREEK

OVERHEAD WIRES

GROUNDWATER CONTOUR

,'1-W·:... ~t}-r-::

\:~ ~\\

) I ) ~~""'" HOUSE

;; :'? ':':(:i..~ ...:': )1 . /-78 WEST BOUND (""""HEAD)

~ ~ fI)

~ ~ ~

-if·

INFERRED GROUNOWATER ~~ :!-;<' .;; FLOW DIRECTION

WELlIDENTIFICATlON WCADAAI.. ~ GROUNDWATER EL£IiATiON (FT) ....... LOT

NM NOT MEASURED

NOTE o· 150' 300' ,. ELEVAnoNS ARE RElATIVE TO ACTUAl.

SURVEYED FEET ABOVE MEAN SEA LEVEL ---SCALE ~ OERN£O FJtOM COM FEDERAL PROGAAMS CORPOAATlON, lAONJTOR:JNG weLL lOC.ATlON...,.· 4I2l004.

2. MONITORING WELLS CSP-9. CSP-23. CSP-28. AND CSP-29 ARE CLOSED AND A8ANDONED. Filmre 7

OVERBURDEN GROUNDWATER CONTOUR MAP3. MONITORING WELL CSP-'O HAS BEEN

REClASSIAED AS AN OI!ER8URDEN WELL OCTOBER 19. 2009 BASED ON AREVIEW OF HISTORICAL DATA A:COM HELlERTOWN MANUfACTURING COMPANYAND A MORE DETALEO REV1eW OF THE HELlERTOWN. PENNSYLVANIAWELL LOGS FOR THE SITE.

FEBRUARY 20,0 ,0,566

III

N

~ >:i

esp.s+ ::'~~. ,"' . (;. <.

('.:to to' ."l; ~ l,

v~·.;·H~ .•:

<';'"(" ::, f:r~ · :t ...

•

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t;:!iT.·" \'~ ... ~.. \

) ): /

~,';V 'l.;:;/ ."j.

" ~ ~'-". C· ~ )1 1-78 WEST BOUND (0\1£ • .....,,)

~ ~ .. ;: ;

[-78 EAST BOUND (OYERHEAD)

/~~'l-/ Faa

.. ~C~ .·'" ...17 0 ./ ')jCO~~ . <O.5q

., / S~ .,/

.:.;~ !/ /I i

I!! LEGEND

OVERBURDEN WEll LOCAnON

SHAllOW BEDROCK WELL LOCAT10N

DEEP BEDROCK WELL LOCATION

EXTRACTION weLL LOCAnoN

SURFI>.CE WI>.TERlSEotMENT Sl>.MPLE LOCAnON

UTILITY POLE

CHAIN LINK FENCE

CREEK

OVERHEI>.D WIRES

CONCENTRAnON CONTOUR

.~-3 NS

TeE

.!:!Q!E

.... . ,. }',.

~ ~ c-,

~ ~ ~

'11'

STATEWlDE-MEAlTH STANDARD CONTOUR

~~~~) NOT SAMPLED

TRlCHLOROETHENE ":s~

NOTE 1

1. MONITORI«l weLLS csp-e. csp-n. csp~. I>.NO CSP.:.!9 ARE CLOSED AND AIW«IONEO.

Z. MONITORING WELL CSP-l0 HI>.S BEEN RECLASSFJB) M I>.N 0VER1lUIIOEN WELL BASED ON I>. REVIEW Of HISTORICAL DATA AND I>. MORE DETAILED REVIEW OF THE WELL LOGS FOR THE SITE.

-. ·-'-'lr~.~7._.u ...~ ~ ~I -...... -. ~-LOr

' :~ i:::&"" .1." ,. ':~f.:',;· O' 150' 300' p- !

......... oeR...ecFROMC""~PAOO...... CCRPO""TIOH. """""""'MU.LOCAT1ON ....... ......,.. SCALE

Figure 8 OVERBURDEN TCE ISOCONCENTRATION MAP

OCTOBER 19. 2009AaCOM HEl..LERTOWN Ml>.NUF'AClURING COIM'N/Y HEU.£RTOWN. PENNSYlVI>.NIA

F'EBRUtJ!Y 2010 101566

H

.. :.~ .: ., cw.4+

• fJ" •

.: ... ..." -:~.. ';: ,.r;~. .a

"

' \ \ " ,II • ,=~ ~i:.i ~::'~' .......

" , "\\ , ......)/, "" ~ ,.

! I ~ ... Q,

:- '·I~- · \ /-78 rEST BOUND ~ '

/~f,'f.//-:: Ci ,.' ~')..O

/'"./"'~c°0'.. t . .......,.'-\.

" st' ,,' ..

.' ! ,',/ ~: ~ ~///

/ '11 ~

~ rt 7" <::: /'-$+c:-OVERBURDeN WELL LOCAT1ON INFERRED GllOUNDWATER

FLOW DIRECTION 1~~\2206,23S>W..i.OW 8EDROCK WELL LOCATION

Y'Ia1. IOI;HTlI'ICATlOH+~DEEP BEDROCK WELL LOCATION 242.10 GI'IOUNCW..TER ELEV"TION (FT)

EXIlW:T1ON WELL LOCATION NM NOT LlE.\SUREO

SURF..cE WATERISEOIMENT SAW'\.E .I'!QTI; 0' 150' 300' LOCATION

" ELEIIATIONS ARE REL'-'T1IIE TO ACT\lAL ~ ! un./T'r POl£ SCALESURVEYED FEET toN:NE MEAN SEA LEVEL

J.A.SaWI' DEJl:t.tm RKN COM FmuuL PRC:lGR.tMS COIItP'ORAnoN. ~WEU. UJCA,..,.....,..~.

2. _TORING WEU.S ,CSf'.4I, CSP·23, CSP·28. AND CSP-2t ARE Q.OSEO ANO ABANOONEO,

c....... U><K FENCE i Fieure.9 SHAll.OW BEDROCK GROUNDWATER

CREEK 3. MONITORING W8..I. CSP·10 K.\S BEEN CONTOUR MAP

REcv.sstFleD -.s loll 0YERBIJfWEH WELLOVERHEAD WIlES OCTOBER 19. 2009 AECOMBASED ON .. REVIEW OF HISTORICAL MTA HEu.ER'TOWN _urACTVRINC COWPNn'AM)" WORE DETAoLED I\EV1EW OF THEGROUNDWATER CONfOVA HEllERTOWN, PEHNSYLV"'*WEll LOGS fOR THE SITE, FERRIJAR'( 20 1 0 I01se6

~i\":' ~t.'n~

'N

C8P-a1:\ \. <O.~ • \ +'\ \"".

"';;~(., .;;.~' .. , .'\.... \ )I )

. ! ..... -'5 ~ :;; '~

;,, :"~ ~ )1 /-78 WEST BOUND (OIIER"""",

./': j,~'i-, . . <~O~/:. . ,c~0 ~ !...-=.-/'7 ' c:;~••

... . . .,/ "

~:// ~ BRICK AND BLOCK

FACTORYIWAAEHOU$EIOFFlCE

~ /1/ ' f::1

II s c_

LEGEND """NS NOTt..2J •~, . . :.~ '. ".~- OVERBURDEN WEll LDCATION WEll (DENTIFlCATION.~

1'.0 CONCENTRATION (~) .. ca.... SHALLOW BEDROCK WEll lOCAnoN c....

NS NOT SAMPLED <030-'tr0'~'_'_'~"= ,.': ~ ,~ .. 2!) DEEP BEDROCK WELllDCATIDN

TCE TRiCHLOROETHENE C8NZ ~I -....... """""" !Tti ·H: ;., EXTRACTION WELl lDCAT10N ~ plOT

DUPLICATE SAMPlES COllECTED .:)('s- ~~o:\; :' .t SURFACE WATERlSEDlMENT SAMPlE HIGHER VALUE RECORDED " . ,. ""<ii]O

lOCATION (:!'if"-:z:~: ;<0. ••, ; :t o· 150' 300'

• UTILITY POLE NOTE ~ SCALECHAIN lINK FENCE 1. MONITORING WELLS CSP--6. CSP-23, CSP--28. BASEMAP OERNEO ~ COM FEDEML PROQI'tAMS CORP'OAAT1ON, MCINI1'OlUNGweu. L0CA1lOfoII IMP .,_/tU

CREEK AND CSP-29 ARE CLOSEDANO ABANDONED. Figure 10 2. MONITORING well C$P. l0 HAS BEEN SHAlLOW BEDROCK

~ - - _ •. - - OVERHfADWlRES RECLASSIAEDM AN OVERBURDEN WELL AEOOM TCE ISOCONCENTRATION MAP· BASED ON A REVIEW OF HISTORICAl DATA - OCTOBER 19 2009 CONCENTRATION CONTOUR AND A MORE DETAILED REVIEW Of' THE HElLERTOWN IWIUF'ACTURINC COMPANY

STATEWIDE-HEALTH STANDAAD CONTOUR WELL lOGS FOR THE S~. HELLERTOWN. PENNSYLVANIA - FEBRUARY 2010 101566

I

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~y. ' St-\)·

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/-78 WEST BOUND .,....HEAD)

I

1 I

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i, c_ 2....73.

·-----' . I INLET

I I i ~I

......., 1

"""'"""'"

....""'"""""

CURtI ~

Ii ~ "

-. .~ I.~/~/ l;~~ '.' ~g.,., LOT I

~ -. ;:.~? -: "", OVERBURDEN WELL LOCATION . ~I............. -.-GROUNDWATER CONTOUR >..: :-:'l' ~" .......SHALLOW BEDROCK WELL LOCATION ~

i I I

t

=--=::.!...~.-

ill

•

BR)CK ANO BLOCK FACTORYmAREHOUSEIOFF)cE

-'-'If.~.-._.U'': """""'"

LOT INFERRED GROUNOWATER ~'" U;V;"~Cl DEEP BEDROCK WELL LOCATION FLOW DtREcnoN

L i. ? ~ :~ / C)CSP.ztI1W.1Ite EXTRAcnON WELL LOCAnoN 0' 150' 300'WELL IDENTIAC...TION IliICl~

238.110 GROUNDWATER aev...TION (FT) NOTE 2 P-;; ! ,':I..~.~~(' G . ~ SURF...CE WATERJSEOIMENT SAMPLE

LOCATION SCALENM NOT MEASURED BASBAAP ~~ FROtot c:oM FEDERAl. PROGAAMS CORPOAAnoN, MONrTOIUNGWEUlOCATlONMAP-0MW

Figure 11U1lUTY POlE NOTE DEEP BEDROCK GROUNDWATER

~ -. -. - CHAlNLINKFENCE ~Al1ONSARERELAnveTOACTUAL CONTOUR MAPA:COM q SURVEYED FEET ABOVE MEAN SEA LEVEL. - OCTOBER 19. 2009"'I -- ... -- CREEK HEl.LfRTOWN IoWIUFACTURlNG COIIPAHY

RES 2. MONI~GWELlS CSP09, CSP-23, CSP-28, HELLERTOWN, PENNSYlVANIA _ - - - - - - OVERHEAl)WI ANDCSP-21lARECLOSeDANOAIIANOONED. FEBRIJ,I,R'( 2010 101566

II

OSWER No. 9355.7-03B-P

Please note that "O&M" is referred to throughout this checklist. At sites where Long-Term Response Actions are in progress, O&M activities may be referred to as "system operations" since these sites are not considered to be in the O&M phase while being remediated under the Superfund program.

Five-Year Review Site Inspection Checklist (Template)

(Working document for site inspection. Information may be completed by hand and attached to the Five-Year Review report as supporting documentation ofsite status. "NIA" refers to "notapplicable.")

I. SITE INFORMATION

Date of inspection:Site name: He.1le,lowl'l No" tli'aC/..'I"" SJ), '/.2.2/Z010 2/t,/2O/0 Location and Region:N"r"'fllll/pt,,. c""..1-",::f3' EPAID: r,fDtJ0237ot4-tf

I

Agency, office, or company leading the five-year ~ather/teniperature: review: u.sefA ~ Ke~Ld""iJI-. .I 'Z.zlto "{,'/~o.r 30 ~ Zp,j,il: C/~ .. (' > .Jl>.s

Remedy Includes: (Check all that apply) @!~ cover/containmeilD Monitored natural attenuation Access controls Groundwater containment

([n!)fifutlOnal controlb Vertical barrier walls ('Groundwater pump and treatment)

Surface water collection and treatment Other

Attachments: Inspection team roster attached Site map attached

II. INTERVIEWS (Check all that apply)

1. O&M site manager -.1, "'" f'r.o {eft:> 5e",c:> .r rJI.I .3/, b.D/o Name Title Date

Interviewed at site at office~Phone no. iii 7Cf6 go3S Problems, :~ge~ons; Report attac ed £#It.J~..., ~K' PI'D'/e.~· P0..5.S,J,Ie. Iec..Kc........... tZ /II,'"" L- 1/lA-v/f-Col'1fr4c.i~,..

{ook,a., (~to IIu-- ~t.J..1e... . ..., 2. O&M staff

Name Title Date Interviewed at site at office by phone Phone no. Problems, suggestions; Report attached

0-7


3. Local regulatory authorities and response agencies (Le., State and Tribal offices, emergency response office, police department, office of public health or environmental health, zoning office, recorder of deeds, or other city and county offices, etc.) Fill in all that apply.

Agency fADE/::. ,=>1 0

8(,/Contact M~ 8~ye r Ct'tV. S(.eC/..../,~f 1/z:4(0 12/1,/ID 201b

Name Title Date Phone no. p~blem~fugghtions; Report attached SkJ al'al?Q..Cj c.. I s.rv~ (tSC ".tlec/

iJ4])£ 11 '.[0 wO/IilJI'r cU-oJf ~ er-tSPrlc. e... d~ ~dcVl'e:.ol'Jql >CJIII"£:t:...

cc, ('eaIi.) On 5''' ('e... . Agency Contact

Name Title Date Phone no. Problems; suggestions; Report attached

Agency (j;;tler ~ Poroc.Jd~ Contact C ar7c-s-Z" ~Ir Q ... ~to~lt I4j r. ;../t fll;>

Name itle . Date 'Phone no. Problems; suggestions; Report attached tV0 i./))'l t!nI\.S ,-1...(J t~

I

Agency Contact

Name Title Date Phone no. Problems; suggestions; Report attached

4. Other interviews (optional) Report attached.

D-8


III. ON-SITE DOCUMENTS & RECORDS VERIFIED (Check all that apply)

1. O&M..D.ocuments CO&M manual) (Beadily availab~ N/A (As-built drawmgS') <..B.!tadilY availa.ble) ~ ate N/Altto Q1aintenance.l~ CRea<iily avallabl9 <1TPto~ N/A

Remarks , No leeo,d of o114;(~ I As -pel/If's- bt:l'(\ , U, -c/o -ro(<;:f ~

2. Site-Specific Health and Safety Plan ([eadilyavailiiSJD ~ N/A Contingency plan/emergency response plan Readily available Up to date N/A

Remarks

3. O&M and OSHA Training Records Readily available Up to date N/A Remarks

4. Permits and Service Agreements Air discharge permit '. Readily available Up to date ~ Effluent discharge <:Readilyavail~ Waste disposal, POTW Keaaily available poate N/A Other permits Readily available Up to date

Remarks = ~

5. Gas Generation Records Readily available Up to date @?) Remarks

6. Settlement Monument Records Readily available Up to date N/A Remarks

7. Groundwater Monitoring Records ( Readilya~ Qptod~ N/A Remarks

8. Leachate Extraction Records Readily available Up to date @) Remarks

9. Discharge Compliance Records Air R~dily available N/A Water (effluent) Q.eadily availab~ to a N/A~

Remarks

10. Daily Access/Security Logs Readily available Up to date C!!9Remarks

D-9


IV. O&M COSTS

I. O&M Organization (S~te in-hou~ CContractor for Sta§:)

PPm-house Contractor £or t'RP

Federal Facility in-house Contractor for Federal Facility Other

2. O&M Cost Records Readily available Up to date Funding mechanism/agreem1 in place

Original O&M cost estimate 10S; (20 0 Breakdown attached

Total annual cost by year for review period if available

From ILo S"' To /lJO) $/()~IOOO Breakdown attached .:; IotaI' cost 'D'6e

From (l0 To /2-_'iri0"e lfa 3 t 000 Breakdown attached

f Total cost • zate late From' '_D1 To 12-y7 /18, eoo Breakdown attached

$ Total cost lateateFrom t .J)3u To t1-yS "7,000 Breakdown attached -t Total cost

From I () To 2. 0 ID~, QOD Breakdown attached -4fJ- -4itate Date Total cost

3. Unanticipated or Unusually Hi~i~&M c~s During ReVjW perio~L sfJ Desc~be costsl,nd reasons: Ala (rt,,"\ r;;£l UlLcJ SVet tl 1-"..1 ,~.;4-( ~.l I

o rb. ~"l..

V. ACCESS AND INSTITUTIONAL CONTROLS (APplicab!.9 N/A

A. Fencing

1. Fencing damaged Location shown on site map (latessec~ @,NfC Remarks

B. Other Access Restrictions

1. Signs and other security measures Location shown on site map N/A Remarks

0-10


C. Institutional Controls (ICs)

I. Implementation and enforcement Site conditions imply ICs not properly implemented Yes <1W N/A Site conditions imply ICs not being fully enforced ®J No N/A

Type of monitort.g (e.g. ')elf-reporting, drive by) 6: f..,J s.." -tfl/4111. c, 2.X/v(lQ r t ~ Frequency z.. .....u>-S VPQ.I' 'A bG-P c1h.fr'4.c-ic:i/ Responsible party/~enCy 14 bt-f> Contact 14 ~ 0 t.qr ell v. Sfltc/q (1,1- 6108'1 2<J76

. Name Title Date Phone no.

Reporting is up-to-date No N/A Reports are verified by the lead agency ~ No N/A

Specific requirements in deed or decision documents have been met Yes N/A Violations have been reported Yes ~ N/A Other problems or suggestions: Report attached ~

RoC> !!kj{e s iC-s · ~~ever. ~t-~ !<€'~ /--t-1 !!.7p 2~' ~C==d~ ~O'1V:rt7Q=== v~ ~r.

I J I c..v1feafl1- ~tl:~ IPr£Ic.Y~d.

2. Adequacy ICs are inadequate./N/AI Cs are ade~:t~ Remarks ()H. e. l!.- f...., p/e~.. env/r~A~.n,t'; J CDv'f"-z<~ ~~v 14.- D<' q 'd ~." c.J II 1-'",

,

f.)

D. General

I. Vandalism/trespassing Location shown on site map ~nd;lism~ Remarks

2. Land use changes on site@) Remarks

3. Land use changes off site ~ Remarks

VI. GENERAL SITE CONDITIONS

A. Roads App~icable N/A

I. Roads damaged Location shown on site map 60adsade~ N/A Remarks

D-ll


B. Other Site Conditions

Remarks

VII. LANDFILL COVERS Applicable N/A

A. Landfill Surface

1. Settlement (Low spots) Location shown on site map ~ement not evi~ Areal extent Depth

Remarks

2. Cracks Location shown on site map CCr;clcing not·e~ Lengths Widths Depths

Remarks

3. Erosion Location shown on site map, <:::: Erosion not evid~ Areal extent Depth Remarks

4. Holes Location shown on site map C§ies not evic§i.!:> Areal extent Depth Remarks

5. Vegetative Cover Grass Cover properly established No signs of stress Trees/Shrubs 'ndicate size and locations on a diagram)

Remarks AliA

rG!i)6. Alternative Cover (armored rock, concrete, etc.) Remarks

7. Bulges Location shown on site map ~ulgeS not evident Areal extent Height Remarks

D-12


8. Wet Areas/Water Damage Wet areas/water damage not evident Wet areas Location shown on site map Areal extent

Q~ Location shown on site map Areal extent Seeps Location shown on site map Areal extent Soft sUbgp,de Location shown on s~map Areal extent

Remarks o,!)" d",,"\ oc..c o,.jJ' J -eJ u I'tn "\. ~.f 0+ ~U"4..tL {-,,,

X;~V'1 rei I" (-4f( ),p(!.q£JS'~ resf'rt ....IQf r/.,'hf wue ""J/dud.... wr{'J:"lIt" 'lli5' ~ rCUOil u ... .r •

9. Slope Instability Slides Location shown on site map o ;vluC;:lI~t 0 s one mstatJll1tl\ Areal extent Remarks

B. Benches Applicable ~ (Horizontally constructed mounds of eart placed across a steep landfill side slope to interrupt the slope in order to slow down the velocity of surface runoff and intercept and convey the runoff to a lined channel.)

l. Flows Bypass Bench Remarks

2. Bench Breached Remarks

3. Bench Overtopped Remarks

Location shown on site map (N/A~okay

Location shown on site map @rokay

Location shown on site map @orokay

C. Letdown Channels Applicable ® (Channel lined with erosion control mats, riprap, grout bags, or gabions that descend down the steep side slope of the cover and will allow the runoff water collected by the benches to move off of the landfill cover without creating erosion gullies.)

I. Settlement Areal extent Remarks

2. Material Degradation Material type Remarks ~i/A

3. Erosion Areal extent Remarks

Location shown on site map Depth

Location shown on site map Areal extent

Location shown on site map Depth

cFo':evidence of settle~

No evidence of degradation

~vidence of erosiO'ib

D-13


4. Undercutting Location shown on site map No evidence of undercutting Areal extent Depth Remarks 4

5. Obstructions Type No obstructions Location shown on site map Areal extent

Size· I

Remarks r#A 6. Excessive Vegetative Growth Type

No evidence of excessive growth Vegetation in channels does not obstruct flow Location shown~n site map Areal extent

Remarks . Ai_~ I

D. Cover Penetrations Applicable N/A

I. Gas Vents Active Passive Properly secured/locked Functioning Routinely sampled Good condition ~ce of leakage at penetration Needs Maintenance

N/A Remarks

2. Gas Monitoring Probes Properly secured/locked Functioning Routinely sampled . Good ~n Evidence of leakage at penetration Needs Maintenance N/A:

Remarks

3. Monitoring Wells (within surface area oflan~ Properly secured/locked Functioning sutinely sam-pieo Good condition Evidence of leakage at penetration Needs Maintenance N/A

Remarks

4. Leachate Extraction Wells Properly secured/locked Functioning Routinely sampled Good ~ Evidence of leakage at penetration Needs Maintenance NIA

Remarks

5. Settlement Mi!~ents Located J.. Routinely surveyed eN/A:Remarks Sf' p~ ~f ~t o(ecl.

D-14

OSWER No. 9355.7-038-P

E. Gas Collection and Treatment Applicable eN/A)

I. Gas Treatment Facilities Flaring Thermal destruction Collection for reuse Good condition Needs Maintenance

Remarks NL~

2. Gas Collection Wells, Manifolds and Piping Good conditiol . Needs Maintenance

Remarks Ar 3. Gas Monitoring Facilities (e.g., gas monitoring of adjacent homes or buildings)

Good condit~n Needs Maintenance N/A Remarks ttJA

I

F. Cover Drainage Layer Applicable N/A

I. Outlet Pipes Inspected Functioning ~ Remarks

2. Outlet Rock Inspected Functioning e:BJRemarks

,

G. Detention/Sedimentation Ponds Applicable .G0) 1. Siltation Areal extent Depth G;J

Siltation not evident Remarks

2. Erosion Areal extent Depth Erosion not eVident/

Remarks N ...(

3. Outlet Works Functioning N/A Remarks .4JLA.

4. Dam Functioning N/A Remarks tJ[4

0-15


H. Retaining Walls Applicable (N/K) 1. Deformations Location shown on site map Deformation not evident

Horizontal displacement Vertical displacement Rotational displacement Remarks

2. Degradation !ViA. Location shown on site map Degradation not evident Remarks

I. Perimeter Ditches/Off-Site Discharge (APplicab!J N/A

1. Siltation Location shown on site map @Itation not evid~ Areal extent Depth Remarks

2. Vegetative Growth Location shown on site map GiP Vegetation does not impede flow

Areal extent Type Remarks

3. Erosion Location shown on site map GroSiO~ not ev~ Areal extent Depth Remarks

4. Discharge Structure CFunctioniilb N/A Remf.ks'f>I.sC.4-~ ... e o'{ S',r4!.- Si-o')/'mwc:~r /.5 4'h<4Pt!:.-.,L t y ("1$ ~I/ed Cit .:..4- haJr,,'- Y"rsh,c.£o.r P/q-ft'r 0" e {'.f/uf"7f rIPe.

VIII. VERTICAL BARRIER WALLS Applicable @ 1. Settlement Location shown on site map Settlement not evident

Areal extent Depth Remarks

2. Performance MonitoringType of monitoring tJ(A Performance not monitored

Frequency Evidence of breaching Head differential Remarks

D-16


IX. GROUNDWATER/SURFACE WATER REMEDIES (ApPlicab~ N/A

A. Groundwater Extraction Wells, Pumps, and Pipelines CApplic:ble) N/A

I. ~~ ead Plumbing, and Electrical Good condition All required wells properly operating Nhds Mai:nancef, N/A

TItS' jt/..;;r~ (j ,,""'1 LSSc.ltl.s e~ c,..J.,J.-J (re.cL t/,.. .e.... •

2. ExtraL'fion SV!ltem Pipelines, Valves, Valve Boxes, and Other Appurtenances (9ood conditiOi!:> Needs Maintenance

Remarks

3. S ...... " P .....~ ....iI Equipment , {Seadily availab"jy Good condition Requires upgrade Needs to be provided

Remarks

B. Surface Water Collection Structures, Pumps, and Pipelines CAPplic;bI;J N/A

1. Collection Structures, Pumps, and Electrical Good conttion Needs Maintenance

Rem!t-~~s S. YO,.-t'-'A!'t!r c;Jrtt.{"" .... , c.... IS s/o.....; '~Ctl.c.J~L 'Of- I'\.J·fc:./I ~cl ('f!...!t- r("'or ,pl.ff.f. 0,.. J'5Ct..C::-"t-- PIf"-f!!.S· ,s,,-. ~end.,,, .. 0,., c_,> OCGI/I"J

2. Surface Water Collection System Pipelines, Valves, Valve Boxes, and Other Appurtenances Good condition Needs Maintenance "4

Remarks 5ee. r-.e nA.q.. 1( a. (";;::..f"L. - ,. ,\ J:I'L.I ...;)" c.....> ,II ~<-loofr~d. ta/-v 6.7- ov'uro;:} , t o~ l"'(.~ c:.s

3. Spare Parts and Equipment Readily available Good condition Requires upgrade Needs to be provided

Remarks IJ L.A I

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C. Treatment System N/A

1. Bioremediation

2. Electrical Enclosures a Panels (properly rated and functional) NIA Good condition Needs Maintenance

Rem~ks____________________________________~__________________________

3.

4. Discharge Structure and Appurtenances NIA . Good condition Needs Maintenance

Rem~ks See..... l'e~K 4. '0.,1-<-

Treatment Building~s,-____________5. N/A Good condition (esp. roof and doorways) Needs repair Chemicals and equipment proper y store

Rem~ks._________________________________________________________________

6.

D. Monitoring Data

1. Monitoring =:O::::a:!.:ta~________ s routinely submitted on time Is of acceptable quah

2. Monit~o[Jril!Jnlg..cI.aULS1Igg,e£t£.:-----___ rOUhdwater plume is effectively containe Contaminant concentrations ~e dec lin .

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D. Monitored Natural Attenuation

I. Monitoring Wells {natural attenuation remedy) Properly secured/locked Functioning Routinely sampled Good~ All required wells located Needs Maintenance ~

Remarks

X. OTHER REMEDIES

If there are remedies applied at the site which are not covered above, attach an inspection sheet describing the physical nature and condition of any facility associated with the remedy. An example would be soil vapor extraction.

XI. OVERALL OBSERVATIONS

A. Implementation of the Remedy

B. Adequacy ofO&M

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C. Early Indicators of Potential Remedy Problems

Describe issues and observations such as unexpected changes in the cost or scope of O&M or a high frequency of unscheduled repairs, that suggest that the protectiveness of the remedy may be comvrvised in the fu~re. /V~-?j. ,t..cJtfd-.

D. Opportunities for Optimization

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third five-year review report hellertown manufacturing ... · table 2: total system o&m costs,...

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