FINAL CLOSEOUT REPORT

McAdoo Associates Superfund Site

McAdoo Borough, Schuylkiil County, Pennsylvania

I. INTRODUCTION

This Final Close Out Report documents that the U.S. Environmental Protection Agency(EPA) has completed all response actions for the McAdoo Associates Site in accordance withClose Out Procedures for National Priorities Sites (OSWER Directive 9320.2-09 A-P).

II. SUMMARY OF SITE CONDITIONS

Background

The McAdoo Associates Site consists of two operable units (OUs) that are locatedapproximately 3 miles apart from one another. Operable Unit 1 is known as the McAdoo KlineTownship (MKT) location and is located approximately 1,5 miles south of McAdoo Borough,due east of U.S.Route 309 in Kline Township, Schuylkiil County, Pennsylvania. Operable Unit2 is known as the McAdoo Blaine Street (MBS) location and is located in the Borough ofMcAdoo, also in Kline Township, Schuylkiil County, Pennsylvania.

The MKT location consists of approximately 8 acres and is situated at the site of an old(subsurface and surface strip) coal mine which operated sporadically from the 1880's to the1960's. In 1975 McAdoo Associates acquired the site property and installed two rotary kilnfurnaces and an upright liquid waste incinerator which were operated to reclaim metals fromwaste sludges, reportedly using waste solvents as fuel. The MKT location was ordered closed in1979 by the Pennsylvania Department of Environmental Resources (now known as thePennsylvania Department of Environmental Protection) as a result of numerous environmentalcompliance problems. At the time of closure in April, 1979 the MKT location was inventoriedand found to contain 6,790 drums of hazardous waste, four above ground 15,000 gallon storagetanks, three above ground 10,000 gallon storage tanks and miscellaneous debris. BetweenJanuary, 1981 and October, 1982 the Potentially Responsible Parties removed all of the drumsand all site features, with the exception of one 15,000 gallon storage tank from the MKTlocation.

The MBS location consists of a small lot (approximately 100* x 150') situated at theintersection of west Fourth street and north Harrison street in a residential area of McAdoo

Borough. Prior to 1972, the MBS location was the site of a heating oil and gasoline storagebusiness which utilized five underground storage tanks. From 1972 to 1979 the propertyallegedly was used by the owners of McAdoo Associates for temporary storage of various liquidwastes in the underground tanks. The waste was reportedly used as fuel to be burned at theMKT location. Operations at the MBS location were discontinued in 1979.

Because both locations were operated as one facility involving the same ownership andwaste, they were combined and collectively called the McAdoo Associates site for evaluation inthe Hazard Ranking System (HRS) scoring process. The site received a score of 63.03 and theMcAdoo Associates site was placed on the National Priorities List (NPL) in September, 1983.

Remedial Investigation/Feasibility Study

EPA conducted a Remedial Investigation (RI) at the MKT location in 1984. The resultsof the RI indicated elevated levels of metals in the mine pool underlying the site and in the sitefill. Aluminum, chromium, barium, beryllium, cobalt, copper, iron, nickel, manganese, zinc andarsenic were detected in the mine pool. In the site fill metals such as beryllium, nickel,chromium and zinc were detected in concentrations of 28,1720,1370 and 48,000 parts permillion respectively. Other metals including cadmium, lead and cyanide were found in site fillin higher concentrations typically found in soil.

Elevated levels of organic contaminants were also found at various depths in the site filland underlying mine pool. In addition, a one acre resin sheet was located on the surface in thenorthern section of the site. The resin sheet was approximately one to two inches thick andwhen sampled was found to contained numerous organic constituents including benzene,toluene, styrene, 1,1,1-trichloroethane and 1,2-dichloroethane. The final RI report summarizedall analytical results.

Following the RI, EPA released the Feasibility Study (FS) report in 1985. The FSidentified and evaluated numerous remedial action alternatives to address two site-specificremediation objectives. These objectives included preventing direct contact with on-site wastes(resin sheet and tank sludge) and contaminated soils and preventing off-site migration of wastesand contaminated soils. The FS provided a detailed analysis of contaminated soil excavation,filling and re-vegetation, capping, debris removal, surface water diversion and no actionremedial alternatives.

With regard to the MBS location, EPA conducted investigations in 1982 of theunderground tanks and their contents. Based on the results of these investigations EPA issued aRecord of Decision (ROD) for Interim Remedial Measures (IRM) on June 5,1984 calling forcleaning and removal of the underground tanks, the removal of contaminated soil and thesampling of subsurface soils.

Upon completion of the studies discussed above for the MKT and MBS locations, RODswere issued by EPA (the details of which are discussed below) for each location. The RODissued for the MKT location deferred selection of remedial action, if any, for the mine pool andsurface water. The ROD issued for the MBS location included provisions for further site action,if necessary, which would be addressed in a supplemental ROD. Because of these outstandingissues related to the MKT and MBS locations, a focused RI/FS was conducted by EPA in1990/1991. A subsequent ROD was issued to address these outstanding issues.

The scope of the focused RI/FS for the MKT and MBS locations was to evaluate thesurface water, sediment and groundwater at the MKT location and groundwater at the MBSlocation. Surface water samples collected from Lofty Creek (background) and the LittleSchuylkill River indicated low level concentrations of organic contaminants that appeared not tohave originated from the MKT location. Inorganic contaminants found at elevatedconcentrations in the surface water samples include aluminum, antimony, beryllium, calcium,cobalt, copper, iron, manganese, magnesium, nickel, and zinc. It was determined that theelevated concentrations of these metals in the surface water was likely a result of thecombination of Acid Mine Drainage (AMD) and leaching from the MKT location into the minepool. Although it is not possible to quantify the extent of inorganic contribution from the MKTlocation to the mine pool, and subsequently the surface water, based on available data, AMDremains the primary controlling factor for inorganics in the surface water.

The results of the associated surface water sediment sampling revealed the presence ofsome semi-volatile compounds (polynuclear aromatic hydrocarbons [PAHs]) in the sedimentsfrom nearly every station sampled. These compounds were also detected in the soils at the MKTlocation and in background samples. The presence of PAHs in some, but not all, of the samplescollected indicates the prevalence of these compounds in the environment from various sources.The source of the PAHs in the Little Schuylkill River may be from MKT location run-off as wellas run-off from other areas draining into this basin, including PA Rt. 309. High concentrationsof inorganics, similar to those found in the surface water, were detected in the sediment samplesfrom the Little Schuylkill River. Some of these metals were also detected in the soil at the MKTlocation. A comparison of these metals to inorganic background concentrations as related toformer mining activities showed that most of the inorganics present in the sediment are withinexpected background ranges for the area.

Groundwater samples were collected on two occasions from the seven on-site monitoringwells at the MKT location during the focused RI/FS. The results of these samples indicate thatlow level organic compounds are present in the mine pool groundwater beneath the MKTlocation. The MKT location is the most likely source of the contaminants detected as therewere no organic compounds detected in the upgradient monitoring wells. Inorganics detected inthe monitoring wells have been attributed to a combination of naturally elevated backgroundconditions, the effects of mining and AMD and former MKT location activities. Six residentialwells and the municipal water supply well were sampled during the investigation. Some organicand inorganic contaminants were detected in the residential wells at levels below the Maximum

Contaminant Level (MCL). The municipal water supply well did not contain any contaminants.

The focused RI/FS, as related to the MBS location, evaluated the results of confirmatorysoil sampling performed by EPA as part of the removal of the five underground tanks andcontaminated soils in 1985. The results of the sampling indicated that low levels of organic andinorganic compounds remained in the subsurface soils. The organic compounds (primarilyPAHs) have been determined to be constituents of petroleum products that were once stored atthe MBS location prior to the storage of liquid waste.

ROD Findings for the MBS Location

Response activities at .the MBS location began in 1982 when EPA ordered the PRPs topump 11,000 gallons of waste liquids from four of the underground tanks. The liquid waste wasdescribed as petroleum distillates and PAHs. Gasoline and water were reported to be containedin one tank, and oils and solvents were identified in the other tanks. On June 5,1984 EPAissued a Record of Decision for Interim Remedial Measures at the MBS location calling forcleaning and removal of the underground tanks, the removal of contaminated soil, and thesampling of subsurface soils.

Design Criteria

Prior to construction activities at the MBS location, a site survey was initiated inOctober, 1984. The survey included establishing site boundaries, locating all structures, roadsand vent pipes and defining the topography of the site. Deed research at the Schuylkil!Courthouse in Pottsville, Pennsylvania was performed and deeds for the site and adjoiningproperty were collected with a copy of the tax map for the area. A tank investigation was alsoperformed in October, 1984 to determine the size and orientation of the tanks. During the tankinvestigation an additional fifth tank was discovered and found to contain 10,300 gallons ofwaste liquids. This tank was emptied and the waste was disposed of in an off-site incinerator.

Remedial Construction Activities MBS Location

EPA awarded a contract to NUS Corporation to clean, remove and dispose of the tanksand excavate and dispose of contaminated soils at the MBS location. The remedial activitiestook place in two phases. Phase one activities began in March, 1985 and consisted of excavatingsoils from above and beside the tanks in order to facilitate tank removal. All excavated soilswere stockpiled on-site. The tanks were then purged prior to removal. Once removed, the tankswere found to have no leaks. All transportation and disposal was conducted in accordance withFederal and State regulations. The tank removal was completed on March 25,1985, After thetanks were removed from the site, confirmatory soil sampling was conducted from the bottomand sides of the excavation. These samples indicated that low levels of organic and inorganiccontaminants remained in the subsurface soils. As a result, additional soils were removed fromthe bottom and sides of the excavation pit. According to the final report, subsurface low level

contaminated soil remain at the site. Phase two activities consisted of the removal of stockpiledcontaminated soils from the site and began in May, 1985. During a two week period 1,000 cubicyards of contaminated soils were removed and taken off-site for disposal. In June, an additional93 truckloads of contaminated soils were removed from the site. Backfilling began on June 4and was completed on June 7,1985. The site was then restored to original grade and coveredwith 3 to 6 inches of coarse gravel. A Final Report for the Interim Remedial Measure at theMBS location was issued in July, 1986.

Community Relations Activities

EPA held a public meeting on the evening of Monday, March 11, 1985 to discuss theupcoming remedial activities at the MBS location. The object of public interest during thatmeeting was air quality monitoring. EPA had proposed to conduct round-the-clock air qualitymonitoring during remedial activities and this was accepted by the community.

ROD Findings for MKT Location

On June 28,1985 EPA issued a Record of Decision for the MKT location which selecteda remedial action alternative that included the following components:

* The implementation of a mine subsidence study (MSS) to determine the risk and magnitudeof mine subsidence;

* Removing and disposing of miscellaneous surface debris and the remaining 15,000 gallonabove ground tank;

* The implementation of a soil sampling program to define the extent of soil contamination;

* Excavation and offsite disposal of contaminated soils and backfilling of the excavated areaswith clean fill;

* Regrading, constructing a cap with surface water diversion and re-vegetation; and

* Performing operation and maintenance (O&M), including groundwater monitoring for up to30 years.

Design Criteria

A remedial action work plan to implement the 1985 MKT ROD was developed by thePRPs contractor and submitted to EPA in February, 1987. This work plan was incorporated intothe Consent Decree between EPA and the PRPs for the performance of the ROD remedy. TheConsent Decree was signed on June 3,1988.

Remedial Construction Activities MKT Location

The removal of the remaining storage tank, additional soil sampling, and the MSSrequired by the ROD were performed by the PRP'S contractor from October 1988 throughJanuary, 1989. The excavation of the contaminated soils in two areas defined by the soil,sampling program and the MSS was performed in May, 1990. The excavated soils weredisposed of offsite in a permitted RCRA facility. The 100% cap design was approved by EPAon January 10,1991. The cap construction was initiated on July 20,1991 and completed onNovember 14,1991. On March 10,1992, EPA notified the PRPs that all elements of theremedial action as described in the Consent Decree had been completed satisfactorily.

ROD Findings for the MKT and MBS Locations

On September 30,1991 EPA issued a ROD based on the results of the focused RI/FScompleted in July, 1991. The ROD stated that no further actions beyond those alreadyimplemented at the MKT and MBS locations were required. At the same time, however, the1991 ROD required long-term groundwater monitoring at both locations. The majorcomponents of the monitoring program include:

* Expansion of the long-term water quality monitoring program as needed at the MKTlocation (originally included as part of the 1985 ROD) to include additional sampling of allexisting monitoring wells;

* Installation of four groundwater monitoring wells at the MBS location to be used for long-term monitoring of groundwater quality.

The Operations and Maintenance Plan, attached to the 1988 Consent Decree for the MKTlocation, was amended in June, 1998 to expand the groundwater monitoring program to includethe requirements of the 1991 ROD. Subsequently, annual groundwater monitoring was initiatedin October, 1998 at the MKT location.

The wells required by the 1991 ROD for the MBS location were installed by EPA inMay and June, 1992. Groundwater samples were then collected and the results indicated thatpetroleum-related organic compounds and semi-volatile organic compounds were present in themonitoring wells located down-gradient of the former tank location. Subsequent groundwatersampling was performed as part of a Focused Feasibility Study (FFS) conducted by EPA in theSpring of 1993. The results of the FFS sampling confirmed the presence of organiccontaminants in the groundwater as well as a free product (in one monitoring well) determinedto be weathered fuel oil and gasoline. Based on the results of the FFS, EPA issued a RODAmendment for the MBS location on September 30,1993. The major components of the RODAmendment are:

* Installation of new groundwater extraction wells at the MBS location and extraction ofcontaminated groundwater;

* Installation and operation of a free product removal system to extract the fuel and gasoline;

* Installation of a groundwater treatment system to include oil/water separation, air stripping,and polishing using granular activated carbon;

* Performance of groundwater monitoring; and

* The establishment of Performance Standards for Benzene, Ethylbenzene, 1,2-dichloroethaneBis(2-ethylhexyl)pthalatd and Manganese.

Design Criteria

On January 11,1994 EPA issued an Interagency Agreement for $71,000 to the U.S.Army Corps of Engineers (USAGE) to perform the Remedial Design (RD) for the MBSlocation. The Fund Lead RD was completed in August, 1994. The project was also a fund leadconstruction.The RD included the following phases:

* Product Recovery and New Well Installation;

* Groundwater Extraction System and Testing; and

* Treatment System Fabrication and Installation.

EPA issued an Interagency Agreement for $1,081,100 to the USACE in June, 1984 toperform construction activities at the MBS location. The USACE awarded a contract to DOWEnvironmental Inc. in 1994 to provide all the required labor and materials to clean up thecontaminated groundwater at the MBS location.

Remedial Construction Activities

Phase one of the Remedial Action (RA) at the MBS location was implemented on March28,1995 with the installation of five groundwater extraction wells and the recovery of freeproduct from an existing monitoring well. After installation of the groundwater extraction wellsit was determined, through groundwater extraction, that a pumping rate of 15 gallons per minutecould not be sustained by pumping these wells individually or collectively. The capacity of theaquifer to recharge the wells and produce the amount of water needed for treatment was notsufficient. As a result, the RA for the MBS location was terminated after Phase One.

Following the termination of the RA at the MBS location, EPA issued an Explanation ofSignificant Differences (ESD) on September 26,1995. The ESD identified several SignificantDifferences that warranted changes to the remedy presented in the 1993 ROD Amendment forthe MBS location. The Significant Differences presented in the ESD are as follows:

1) Mechanical pumping of the wells at the MBS location, on a continuous basis, wasdetermined not to be a viable option due to insufficient water volume as described above. Thecontaminated groundwater would have to be manually extracted by hand bailing the wells.

2) The small volume of ground water capable of being removed from the extraction wells didnot warrant the construction of a treatment system at the MBS location. The manually extractedgroundwater would be contained and taken off-site for treatment.

3) The extraction and treatment of groundwater from the MBS location would not beperformed on a continuous basis. Rather, the manual extraction would be performed on aperiodic basis.

4) The free product recharge rate was extremely slow and as a result a free product recoverysystem was not warranted. Instead the free product was manually removed on the same scheduleas the manual removal of the contaminated groundwater.

The ESD for the MBS location was implemented in 1996. Between 1996 and June, 2001the wells at the MBS location were purged and sampled 4 times. A review of the monitoringdata indicates the presence of PAHs which are constituents of gasoline and fuel oil. Benzeneand ethylbenzene are present at concentrations above the performance standards. Thesecontaminants have been determined not to be compounds of concern, but instead residuals of thegasoline and fuel oil once stored at the MBS location. Bis(ethylhexyl)pthalate is a suspectcontaminant present at concentrations slightly above the performance standards.

Based on a thorough evaluation of the results of the groundwater data collected from thewells at the MBS location, EPA has determined that the volatile organic compounds being foundin the groundwater are constituents of gasoline and fuel oil and are not compounds of concernrelated to the past storage of waste liquids at the MBS location. Also, there are no threats toresidents who use groundwater in the area of the MBS location, as the source of potablegroundwater is located approximately 3 miles away and the wells are several hundred feet deep.There is no hydraulic connection between the shallow groundwater at the MBS location and thepublic water supply wells. As such, EPA has discontinued the manual extraction of groundwaterfor treatment but continues to monitor the groundwater at the MBS location.

Community Relations Activities

EPA held a public meeting on the evening of Thursday, August 8,1991 to discuss theProposed Remedial Action Plan for the MBS and MKT locations. PADEP was also present atthe meeting. EPA and PADEP answered questions about the Proposed Plan and the status of thesite. All comments received during the public comment period, including those expressed at themeeting, were addressed in the Responsiveness Summary.

HI. DEMONSTRATION OF QUALITY ASSURANCE/QUALITY CONTROL(QA/QQ FROM CLEANUP ACTIVITIES

The remedial action objectives of the 1985 ROD issued for the MKT location consistedof: 1) reducing the concentrations of contaminants in the on-site soils to acceptable soil criteriafor 15 constituents or classes of constituents, and 2) installing a cap over the MKT location tomeet the intent of RCRA and provide for the diversion of surface water. These remedial actionobjectives were achieved in November, 1991.

In accordance with the criteria specified during the design phase of the remediation, thecap consisted of 18 inches of select low permeability compacted soil underlain by beddinggeotextile fabric and overlain by a layer of geotextile acting as a drainage layer. A 24 inch thicklayer of compacted common borrow material, and 12 inches of topsoil suitable for re-vegetationto overlay the low permeability soil layer was also specified in the design.

The work performed during the cap construction was done in accordance with theapproved Construction Quality Assurance (CQA) Plan. The CQA Plan outlined the protocols tobe used during monitoring and documenting the quality of materials used and the constructionpractices employed in their placement. These protocols were sufficient for ensuring successfulremediation at the MKT location.

All elements of the RA conducted at the MBS location, prior to its termination, wereperformed in accordance with an approved Contractor Quality Control Plan.

IV. MONITORING RESULTS

Groundwater monitoring at the MKT location is being performed in accordance with theOperation and Maintenance (O&M) obligations which are part of the Work Plan attached to the1988 Consent Decree as Appendix 7. O&M requires the PRPs to collect samples semi-annualyduring the first five years following the completion of the RA. The semi-annually groundwatermonitoring began in September, 1992 and was completed in October, 1997 Annual groundwatermonitoring of the expanded groundwater monitoring program, required by the 1991 ROD wasinitiated in October, 1998 and will continue for 25 years. To date, fifteen rounds ofgroundwater monitoring samples have been collected from the MKT location. The monitoringprogram includes:

* Monitoring of all seven monitoring wells for Volatile Organic Compounds (VOCs) andnine metals including beryllium, cadmium, chromium, cobalt, cyanide, lead, nickel, silverand zinc.

* Monitoring of three designated monitoring wells, six lysimeters and the Silverbrookdischarge for Total Organic Carbon, Total Organic Halides and Base Neutral and Acidextractable organics.

The results of the monitoring are reported to EPA, as required by the Consent Decree, inan annual report submitted by the PRPs.

Monitoring at the MBS location is being performed by EPA pursuant to the 1991 ROD.As discussed above, the results of monitoring at the MBS location indicate that the volatileorganic contaminants detected during the monitoring are constituents of fuel oil and gasolinerelated products and are not contaminants related to the liquid waste storage activities.Groundwater monitoring at the MBS location will continue on an annual basis.

V. SUMMARY OF OPERATION AND MAINTENANCE

Operation and Maintenance activities at the MKT location are being performed inaccordance with the Work Plan attached to the 1988 Consent Decree as appendix 7, O&Mobligations include semi-annual inspection of the site for the first five years and annualinspections for the next 25 years. The inspections include cap maintenance and grass cuttings asnecessary.

There are no O&M requirements for the MBS location.

VI. SUMMARY OF REMEDIATION COSTS

The original capital cost estimate to implement the remedial action described in theoriginal ROD for the MKT location (June, 1985) was $2,410,000. The final estimate of theproject costs as provided to EPA by the PRPs was approximately $4,901,308. which included allcosts associated with the design and construction of the cap, surface debris removal, soilexcavation and disposal and the MSS study. A breakdown of these cost can be found in theRemedial Action Report for this project.

The original cost associated with the ROD for the MKT and MBS locations (September,1991) was $503,540. Since this ROD selected a no further action alternative, these cost areassociated with the groundwater monitoring component of that ROD.

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The original cost estimate to implement the remedial action described in the RODAmendment for the MBS location (September, 1993) was $1,876,000. The final cost of thework performed at the MBS location, including the manual groundwater extraction that tookplace after the original RA was terminated was $308,381.37.

VII. PROTECTIVENESS

The MKT location of the McAdoo Associates Site meets all the completion requirementsas specified in OSWER Directive A-P, Close Out Procedures for National Priorities List Sites.The MKT location has achieved the ROD objectives, and no further action is required. As statedin Section V. above, groundwater will continue to be monitored to ensure protectiveness andsupport future five year reviews.

As discussed above, the manual groundwater extraction will be discontinued at.the MBSlocation. A thorough evaluation of the groundwater data collected to date indicates that thevolatile compounds remaining in the groundwater are residuals of fuel oil and gasoline and arenot related to liquid waste stored at the MBS location during site operations. With the exceptionof low concentrations of Bis(2-ethyl-hexyl)pthlate, which is a suspect contaminant at the site, noother site related contaminants have been identified. The geologic characteristics at the MBSlocation are such that there is no hydrologic connection between the shallow groundwater andthe deep public water supply wells located away from the site. In addition, there are nogroundwater exposure pathways in the area of the MBS location as everyone is supplied withpotable water from the public water supply wells. Groundwater monitoring will continue at theMBS location.

VIII. FIVE YEAR REVIEW

CERCLA, as amended, requires a five year review of all sites with hazardous substancesremaining above health based levels for unrestricted use of the Site. Since soil and groundwatercontamination remain at the MKT and MBS locations, the five-year review process will be usedto ensure that the selected remedy continues to be protective of human health and theenvironment. EPA completed the first five-year review of the McAdoo Associates Site onJune 27,2000. In that five year review, EPA determined that the remedy implemented at theMKT location has eliminated all immediate threats to human health and the environment thatwould warrant a response in accordance with 40 C.F.R. §300.415. EPA will continue to reviewO&M activities at the MKT location and review the annual O&M reports. Should these reviewsindicate that additional action is necessary, EPA will take the appropriate action before the nextfive-year review.

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EPA will terminate the manual groundwater extraction at the MBS location, butgroundwater monitoring will continue. Should the groundwater monitoring results indicate thatadditional action is necessary at the MBS location, EPA will take appropriate measures beforethe next five-year review. EPA plans to complete the next five-year review at the McAdooAssociates Site before June 27,2005.

MJO 1 *niomas C. Voltaggu?Acting Regional AdministratorU.S. EPA Region III

Date

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