five-year review report modern sanitation landfill
TRANSCRIPT
SDMSDocID 2031911
FIVE-YEAR REVIEW REPORT
MODERN SANITATION LANDFILLSUPERFUND SITE
WINDSOR AND LOWER WINDSOR TOWNSHIPSYORK COUNTY, PENNSYLVANIA
PREPARED BY:
United States Environmental Protection AgencyRegion III
Philadelphia, Pennsylvania
February 2005
FIVE-YEAR REVIEW REPORT
For
MODERN SANITATION LANDFILL SUPERFUND SITE
WINDSOR AND LOWER WINDSOR TOWNSHIPS
YORK COUNTY, PENNSYLVANIA
FEBRUARY 2005
PREPARED BY:
United States Environmental Protection AgencyRegion III
Philadelphia, Pennsylvania
Approved by: Date:
Abraham Ferdas, DirectorHazardous Site Cleanup DivisionU.S. EPA, Region III
Table of Contents
List of Acronyms v Executive Summary v Five-Year Review Summary Form vi
I. INTRODUCTION 1
II. SITE CHRONOLOGY 2
III. BACKGROUND 4 Physical Characteristics 4
IV. GEOLOGY/HYDROGEOLOGY 5
V. LAND AND RESOURCE USE 6
VI. HISTORY OF CONTAMINATION 7
VII. INITIAL RESPONSE 8
VIII. BASIS FOR TAKING ACTION 8
IX. REMEDIAL ACTIONS 11
X. REMEDY SELECTION 11 Remedial Action Objectives 11 Remedy Implementation 12 Capping and Cover Systems 13 Landfill Slope Cap/Vertical Expansion Area 14 Twenty-Acre Plateau Area 14 Forty-two-Acre Side Slope Area 14 Four-Acre Highwall Area 15 Groundwater Remedial Actions 17
Groundwater and Leachate Treatment Facilities 20
Landfill Gas Extraction System 21 Groundwater and Surface Water Monitoring Systems 23 Groundwater Monitoring System 23 Surface Water Monitoring System 24 Sample Parameters and Monitoring Schedule 25 Data Evaluation, and Reporting 25
System Operations/O&M 25
ii
XI. SUMMARY OF PROJECT REMEDIATION COSTS 26
XII. PROGRESS SINCE LAST FIVE-YEAR REVIEW 26
XIII. FIVE-YEAR REVIEW PROCESS 27 Administrative Components 27 Community Involvement 27 Document Review 27 Data Review 28 Site Inspection 28 Site Interviews 28
XIV. TECHNICAL ASSESSMENT 28 Summary of Technical Assessment 30
XV. ISSUES 31
XVI. RECOMMENDATIONS AND FOLLOW-UP ACTIONS 31
XVII. PROTECTIVENESS STATEMENT 31
XVIII. NEXT REVIEW 31
XIX. REFERENCES 32
LIST OF TABLES
Table 1 Chronology of Remediation Activities Table 2 Summary of Engineering Construction Certificates Table 3 Groundwater Monitoring Wells, Constituent Assessment Wells, Extraction Wells
and Surface Water Monitoring Points Table 4 Monitoring Frequency and Parameters Table 5 Form 19 Quarterly Water Quality Analytes
LIST OF FIGURES
Figure 1 Site Location Map Figure 2 Site Topography and Property Map Figure 3 Landfill Development History Figure 4 Cap Construction Areas (66-Acre Landfill) Figure 5 2004 Site Conditions
LIST OF APPENDICIES
Appendix A Record of Decision Appendix B Consent Decree Appendix C Groundwater Modeling Update Report Appendix D Newspaper Announcement Appendix E Site Photographs
iii
List of Acronyms
ARARs Applicable or Relevant and Appropriate Requirements AOC Administrative Order on Consent CD Consent Decree CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CFR Code of Federal Regulations cm/sec centimeters per second CQA Construction Quality Assurance CQAP Construction Quality Assurance Plan EPA United States Environmental Protection Agency EWGCS Enhanced Western Groundwater Control System FS Feasibility Study HASP Health and Safety Plan HOPE High-density polyethylene HI Hazard Index IC Institutional Control MCLs Maximum Contaminant Levels mg/kg milligrams per kilogram (mg/kg) NCP National Oil and Hazardous Substances Pollution Contingency Plan NPDES National Pollution Discharge Elimination System NPL National Priorities List O&M Operations and MaintenanceOU Operable Unit PADEP Pennsylvania Department of Environmental Protection PADER Pennsylvania Department of Environmental Resources PCB Polychlorinated biphenyls PRP Potentially Responsible Party RA Remedial Action RAO Remedial Action Objective RD Remedial Design RI Remedial Investigation RI/FS Remedial Investigation/Feasibility Study ROD Record of Decision ROMP Remedial Operations and Maintenance Plan RP Responsible Party RPM Remedial Project Manager SAP Sampling and Analysis Plan SARA Superfund Amendments and Reauthorization Act of 1986 SDWA Safe Drinking Water Act SSMP Site-Specific Monitoring Plan VOC Volatile Organic Compound
iv
Executive Summary
The remedy for the Modern Sanitation Landfill Superfund Site in the townships ofWindsor and Lower Windsor, York County, Pennsylvania included: 1) continued operation andmaintenance of all previous remedial actions conducted on-site, including the landfill cap,groundwater extraction system, on-site wastewater treatment facility, gas extraction system (forremoval and destruction of landfill generated methane gas), and groundwater and surface watermonitoring, 2) completion of the landfill cap system and final cover for the unlined 66-acrelandfill, 3) maintenance of site fencing and all access restrictions, 4) the addition of extractionwells to the eastern and western extraction systems to prevent contaminated groundwater frombypassing those systems, 5) the completion of additional monitoring and/or extraction wells asneeded to ensure protectiveness and to control groundwater flow, respectively, and 6) as a goal,restore contaminated groundwater to background quality.
The Site achieved construction completion with the signing of the Preliminary Close OutReport on October 20, 2000. The trigger for this five-year review was the actual start ofconstruction of the four-acre highwall area on February 11, 2000.
The assessment of this five-year review found that the remedies were constructed inaccordance with the requirements of the 1991 Record of Decision (ROD). The remedies arefunctioning as designed. The immediate threats have been addressed and the remedies areexpected to be fully protective of human health and the environment when RAOs have beenattained. In the interim, exposure pathways that could result in unacceptable risks are beingcontrolled.
v
Five-Year Review Summary Form
SITE IDENTIFICATION
Site name (from WasteLAN): Modern Sanitation Landfill
EPA ID (from WasteLAN): PAD980539068
Region: 3 State: PA City/County: York/YorkSITE STATUS
NPL status: • Final n Deleted n Other (specify)
Remediation status (choose all that apply) a Under Construction • Operating • Complete
Multiple OUs?* D Yes • No Construction Completion date: 10/20 2000
Has site been put into reuse? • Yes a NoREVIEW STATUS
Lead agency; • EPA a State a Tribe a Other Federal Agency
Author name: Frank Klanchar
Author title: Remedial Project Manager Author Affiliation: EPA Region 3
Review period:** 09/16/2004 to 2/11/2005
Date(s) of site inspection: 10/20/2004
Type of review:• Post-SARA n Pre-SARA a NPL-Removal only n Non-NPL Remedial Action Siten NPL State/Tribe-lead n Regional Discretion
Review number: first n second n third n other
Triggering action:D Actual RA Onsite Construction at OU#_n Construction CompletionD Other (specify)
• Actual RA Start at OU#1n Previous Five-Year Review Report
Triggering action date (from WasteLAN): 02/11/2000 (RA On-Site Construction Start)
Due Date (five years after triggering action date): 02/11/2005* "OU" refers to operable unit.•* Review period should correspond to the actual start and end dates of the Five-Year Review in WasteLAN
Vlll
Five-Year Review Summary Form, cont'd.
Issues:
• There were no issues identified during this five-year review that would affect thecurrent or future protectiveness of the response actions conducted at the Site.
Recommendations:
• There are no recommendations and follow-up actions at the Site.
Protectiveness Statement(s):
• The remedies for the Site are protective in the short-term because exposure pathwaysthat could result in unacceptable risks are being controlled. The Site will be fullyprotective when the RAOs have been attained.
• Institutional controls are not required for the Site since it is an active municipal wastelandfill operating under PADEP Solid Waste Permit No. 100113. Under a permitmodification in April 1999, double-lined landfill cells were constructed on top of theSite. These cells will receive a composite capping system as a final cover when thecells are completed. The integrity of this action will be protected in the future by theimplementation of the PADEP-approved Closure Plan and Postclosure Land Use Planfor the facility.
Long-Term Protectiveness:
• Long-term protectiveness of the remedies will be verified by inspecting the Site toassess the condition of the physical attributes of the remedies, by monitoring thegroundwater and leachate treatment facilities, and by the routine sampling and analysisof groundwater and surface water.
Other Comments:
• Modern Landfill's diligence and cooperation in implementing the long-term responsehas been exemplary.
vii
1st Five-Year Review Report For
Modern Sanitation Landfill Superfund Site Windsor and Lower Windsor Townships
York County, Pennsylvania
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 inFive-Year Review reports. In addition, Five-Year Review reports identify issues found during the review, ifany, and recommendations to address them.
The United States Environmental Protection Agency (EPA) is preparing this five-year review reportpursuant to the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) §121 and the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). CERCLA § 121states:
If the President selects a remedial action that results in any hazardous substances, pollutants, orcontaminants remaining at the site, the President shall review such remedial action no less oftenthan each five years after the initiation of such remedial action to assure that human health and theenvironment are being protected by the remedial action being implemented. In addition, if upon suchreview it is the judgement of the President that action is appropriate at such site in accordance withsection [104] or [106], the President shall take or require such action. The President shall report tothe Congress a list of facilities for which such review is required, the results of all such reviews, andany actions taken as a result of such reviews.
The Agency interpreted this requirement further in the NCP; 40 Code of Federal Regulations §300.430(f)(4)(ii) states:
If a remedial action is selected that results in hazardous substances, pollutants, or contaminantsremaining at the site above levels that allow for unlimited use and unrestricted exposure, the leadagency shall review such action no less often than every five years after the initiation of the selectedremedial action.
EPA Region III has conducted a Five-Year Review of the remedial actions implemented at theModern Sanitation Landfill Site (Site) in Windsor and Lower Windsor Townships, York County,Pennsylvania. This review was conducted by the Remedial Project Manager (RPM) from August 2004 toFebruary 2005. This report documents the results of the review. Colder Associates, Inc., technicalconsultant for Modern Sanitation Landfill, provided an update to the groundwater flow model usinggroundwater level and extraction data collected in 2001 and 2003. This update is provided in Appendix C.
This is the first five-year review for the Modern Sanitation Landfill Superfund Site. The review wastriggered by the start of construction of the Four-Acre Highwall Area, as shown in EPA's WasteLANdatabase: February 11, 2000. This Five-Year Review was conducted consistent with the requirements of theComprehensive Five-Year Review Guidance, OSWER Directive 9355.7-03-B-P (USEPA, June 2001).
1
II. Site Chronology
A chronology of site-related events from discovery to the present is summarized in the table below:
Table 1: Chronology of Site Events Event Date
Two iron ore mine excavations Pre-1800s
Onsite disposal of municipal/residual wastes in central area of original 66-acreunlined landfill
Early 1940suntil 1952
Original landfill extended to south, southeast, east and west; waste disposal permitapplication submitted 1971
1952 to 1971
Original landfill extended to the south and northeast 1972 to 1979
First remedial activity study 1975
Design of Western Groundwater Interceptor Trench and lagoon treatment system 1976
Groundwater interceptor trench and surface impoundment treatment system installed 1977
Capping and landfill expansion activities 1980s
Pennsylvania Department of Environmental Resources (PADER) samples detectVOCs in groundwater and surface water
January to May1981
EPA Field Inspection Team conducts preliminary assessment and site investigation;recommends periodic groundwater and surface water sampling, effectivenessdetermination of leachate collection system, reactivation of on-site wastewatertreatment facility, and investigation of possible groundwater impact mitigation actions
1982
Installation of two monitoring wells, and deepening of two existing monitoring wells 1982
Quarterly sampling of monitoring wells initiated August 1983
12 extraction wells installed in western area to augment Western Interceptor Trench 1984
Toxicological review study completed 1984
Consent Order and Agreement with PADER (superseded by Event 1986 ConsentOrder and Agreement)
September 1984
Proposed listing on NPL October 1984
Western Groundwater Extraction System on line January 1985
Design and construction of Eastern Extraction System (13 wells) 1985
Site placed on NPL June 1986
Consent Order and Agreement with PADER December 1986
Installation of landfill gas extraction system 1986 to 1989
Eastern Groundwater Extraction System on line November 1986
2
Event Date
PADEP issued NPDES Permit PA0046680 November 1986
Two extraction wells (W62 and W64) added to Western Groundwater ExtractionSystem
1987
Construction of Landfill Gas Management System 1987 to 1989
New wastewater treatment plant constructed April 1987
Temporary treatment plant and four surface impoundments decommissioned June 1987
Consent Order and Agreement with PADER November 1987
Cap construction on 66-acre landfill 1988 to 1991
Permit Modification to construct Northern Expansion granted by PADEP December 1990
Final Remedial Investigation completed 1990
Final Feasibility Study completed 1991
Well W60 connected to Eastern Extraction System 1991
Wells W23 and W34 removed from eastern extraction system and converted tomonitoring wells
1992
Cap construction on 66-acre landfill 1992 to 1994
Southwest Expansion permit granted by PADEP May 1993
Consent Decree for remedial action and cost recovery signed by USEPA, PADEP andModern Landfill
June 1993
Redesign of 4-acre highwall cap submitted to PADEP July 1993
Redesign of 4-acre highwall cap conditionally approved by USEPA September 1995
Conceptual design of Demonstration Project of Enhanced Western GroundwaterControl System (EWGCS) submitted
February 1996
Northwest Expansion permit application submitted to PADEP April 1996
EPA agrees to defer construction of 4-acre highwall cap pending results ofDemonstration project and PADEP review
July 1996
Demonstration Project of EWGCS installed and tested February toOctober 1997
Northwest Expansion permit modification submitted to PADEP April 1997
EPA concludes EWGCS is equivalent to Western Groundwater Extraction Systemand issued approval to construct EWGCS
July 1998
PADEP approves Northwest Expansion permit modification April 1999
Installation of additional landfill gas piping across 66-acre landfill May 1999
3
Event Date
Old candlestick gas flare replaced by enclosed gas flare 1999
Enhanced Western Groundwater Control System installed May toDecember 1999
Construction of Cells 12A, 12B, 13A and 13B of Northwest Expansion May 1999 toDecember 2000
Site Specific Monitoring Plan submitted to EPA and PADEP August 2000
EPA accepted Northwest Expansion design as meeting or exceeding 4-acre highwallcap redesign
September 2000
EPA conducts pre-final inspection of remediation of the 66-acre landfill September 2000
EPA and PADEP conduct final inspection of remediation of the 66-acre landfill February 2001
Continued operation and monitoring of groundwater, leachate, and landfill gascollection and treatment systems
On-going
III. Background
Physical Characteristics
The Modern Sanitation Landfill Superfund Site (Site) is a portion of what is referred to as the"Modern Landfill", an active landfill facility permitted by PADEP to accept municipal waste and a numberof non-hazardous industrial wastes. The Site is currently operated by Modern Landfill (Modern), which isowned and operated by Republic Services, Inc. The Site is located southwest of the Borough of Yorkana inthe townships of Windsor and Lower Windsor, York County, Pennsylvania. The Site location and Siteboundaries are shown on Figure 1, and Site topography is shown on Figure 2. The facility is adjacent to Mt.Pisgah Road, approximately one-half mile south of Pennsylvania Route 124.
Landfill development history is shown on Figure 3. Currently, the Site is an active municipal wastelandfill that operates under PADEP Solid Waste Permit No. 100113. The Site includes:
• An inactive, 66-acre natural renovation landfill (66-acre landfill) that was included on the NationalPriorities List (NPL) on June 10, 1986 as the "Modern Landfill Superfund Site." In addition to theunlined natural renovation landfill, the 66-acre landfill includes a 30-acre inactive and PADEP-approved single-lined (60-mil high-density polyethylene (HOPE)) slope cap/vertical expansion area;
• An inactive, PADEP-approved, contiguous 21-acre double-lined (60-mil HOPE) northern horizontalexpansion area (21-acre Northern Expansion);
• An inactive, PADEP-approved, contiguous 17-acre double-lined (60-mil HOPE) landfill area(17-acre Northern Expansion);
• An inactive, PADEP-approved, non-contiguous 67-acre double-lined (60-mil HDPE) landfill area(Southwest Expansion); and,
• An active, currently under construction, PADEP-approved, contiguous 67-acre double-lined landfillarea (Northwest Expansion).
4
The Site also includes:
• PADEP-approved low permeability final cover systems over the inactive landfill areas (except theSouthwest Expansion);
• PADEP-approved borrow areas;
• A PADEP-approved wastewater treatment plant;
• A USEPA and PADEP-approved eastern groundwater extraction system consisting of 12 activeextraction wells;
• A USEPA and PADEP-approved Enhanced Western Groundwater Control System (EWGCS);
• A PADEP-approved landfill gas extraction system, an enclosed flare, a gas-to-energy plant; and
• A PADEP-approved erosion and sedimentation control system.
IV. Geology/Hydrogeology
The Site is located within the Conestoga Valley Section of the Piedmont Physiographic Province.The Piedmont Province is a broad plateau sloping gently eastward from the Blue Ridge Province to theCoastal Plain Province. The Conestoga Valley Section is characterized by a series of alternating elongated,low ridges and broad valleys trending southwest to northeast. This province is also characterized by tightlyfolded and faulted metamorphic and plutonic rocks that have been uplifted and subsequently eroded.
The geology at the Site was interpreted using data collected from various investigation phases,including: regional geologic mapping; site geologic mapping derived from outcrops and more than 60trenches; and data from more than 500 boreholes and coreholes. The results of this work have contributed tothe current geologic model, and show that Modern Landfill is underlain by low-grade metamorphic rocks ofCambrian age, including (from oldest to youngest): Harpers Formation phyllite, Antietam Formationmeta-sandstone, and Vintage Formation crystalline dolostone. Regional rock foliation strike is N70/ E. Thebedrock materials are isoclinally folded in a synform structure dipping 60/-80/ to the south-southeast withan overturned southern limb, and having a low angle axial dip to the east-northeast. In addition to foliationand associated small-scale isoclinal folds, cleavage and kink folds are observed in outcrops and rock cores.Fracture systems recognized at the Site are parallel, perpendicular and diagonal to the foliation strike. Amantle of weathered in-place saprolite is prevalent at the Site, and can attain significant thicknesses in areasof converging subsurface discontinuities and increased calcite content of the rock mass where extensiveweathering has occurred.
The understanding of the Site hydrogeology is based on extensive monitoring and testing.Groundwater elevation data have been collected at the Site since 1985 on a quarterly basis and occasionallyon a monthly basis in 30 monitoring wells or more per event. Constant rate pumping tests, slug tests anddrill stem packer tests (about 260 hydrogeologic tests) have provided a comprehensive three-dimensionalunderstanding of hydraulic conductivity beneath the Site.
Groundwater flow beneath the Site is generally from south to north, with recharge occurring fromprecipitation in the south and discharge to streams flowing to the north. The rocks in the area have a lowprimary porosity. Consequently, the flow of groundwater is controlled by the rock mass discontinuities. The
5
most important structural features which control groundwater flow are: (i) the main fracture systemsidentified by drilling, trenching, interpretation of aerial photographs, and lineament analysis; (ii) thegeologic contacts between different rock units; (iii) the foliation within the Harpers Formation phyllitewhich causes the anisotropic flow patterns; and (iv) the alternating low and high permeability zones withinthe dolostone strata which also cause anisotropic flow conditions. In all geologic units beneath the Site, therange of hydraulic conductivity is greatest above a depth of 100 feet. Below this depth, the range of thevalues decreases for any given depth with at least one order of magnitude as a result of a decrease offracture frequency and fracture porosity with depth. Based on the trends noted, the aquifer is estimated to belimited to a maximum depth of about 200 feet below ground surface. The generalized relationships betweenhydraulic conductivity and main fracture systems for the upper 100 feet of the aquifer are: (i) 10-3
centimeters/second (cm/sec) at the intersection between main fracture systems; (ii) 10-4 cm/sec along themain fracture systems; and (iii) 10-5 cm/sec and in lower areas between main fracture systems.
V. Land and Resource Use
The area immediately surrounding the Site is a combination of agricultural, residential, recreationaland commercial properties. An automobile reclamation operation and a convenience store lie north of theSite. A recreational area (baseball field), transformer substation, cultivated fields and recycling operation lieeast of the Site. Residences lie south and west of the Site.
Land use surrounding the Site is primarily agricultural and residential. Public water is supplied toresidences north of the Site by municipal water supply line. Groundwater use in the Site area is generallyrestricted to individual supplies for private dwellings; however, two trailer parks located east of the Site usegroundwater for private use. No large industrial plants or municipal water intakes are located near the Site.
VI. History of Contamination
Prior to the commencement of the Remedial Investigation/Feasibility Study (RI/FS; ICF/GolderAssociates, 1991), the 66-acre landfill and its surrounding area had been the subject of several geologic andhydrogeologic studies. The first study relating to the remedial activities at the original 66-acre landfill wasconducted in 1975 by R. E. Wright. At that time, the investigations centered on the feasibility of utilizingshallow pumping wells as a primary leachate recovery system for the 66-acre landfill and concluded thatleachate from the original 66-acre landfill could be effectively collected in this manner.
Between January and May 1981, PADEP collected groundwater samples from wells and springs inthe vicinity of the 66-acre landfill and detected volatile organic compounds (VOCs) in some samples. In1982, the EPA Region III Field Inspection Team contractor conducted a Preliminary Assessment and SiteInvestigation.
In June 1984, the original 66-acre landfill was scored in accordance with the Hazard RankingSystem for possible inclusion on the National Priorities List (NPL) under CERCLA. The 66-acre landfillwas proposed for inclusion on the NPL in October 1984, and was officially listed on the NPL by publicationin the Federal Register on June 10, 1986,51 Fed. Reg. 21054.
On September 20, 1984, Modern entered into a Consent Order and Agreement with PADEP tocorrect conditions at the facility, most notably leachate from the original 66-acre landfill contaminating thegroundwater and surface water. This Consent Order and Agreement was superseded by a Consent Order andAgreement dated December 3, 1986. In accordance with these Orders and Agreements, Modern undertookseveral remedial actions, including construction of two groundwater extraction systems and a wastewatertreatment plant.
6
An RI/FS was conducted pursuant to a Consent Order and Agreement entered into by Modern andPADEP on November 4, 1987. A disposal history investigation of the 66-acre landfill completed as part ofthe RI/FS indicated disposal of sodium molybdate wastes, pesticide wastes, rare earth chlorides, papermanufacturing sludge, polychlorinated biphenyls (PCBs), ethylene diamine, oily wastes and paint wastes.
Volatile organic compounds (VOCs), inorganic, and radioactive compounds were detected in thegroundwater, surface water, and sediment at the site. The list of VOCs, inorganics, and radionuclides thatwere considered in the risk assessment can be found in Section VIII.
VII. Initial Response
Prior to the Site being included on EPA's National Priorities List (NPL), the Commonwealth ofPennsylvania was mainly responsible for directing corrective actions at the Site, which were implementedby Modern. Modern operated four surface impoundments to treat leachate seepage collected by theinterceptor trench along the western perimeter of the Site under PADEP Water Quality Management PermitNo. 6786201 issued on September 24, 1976. The groundwater interceptor trench and surface impoundmenttreatment system were designed in 1976 and were constructed in 1977. Construction Quality Assurance(CQA) was provided by William E. Sacra and Associates, and as-built plans were provided in their August3, 1977 report. On January 14, 1985, groundwater extraction wells along the western perimeter werebrought on line. The extracted groundwater was conveyed to the impoundments for treatment.
The surface impoundment treatment system was designed to treat 72,000 gallons of groundwater perday. The treatment process consisted of: pH elevation using a liquid lime slurry; metals precipitation;aeration; clarification; and chlorination. The surface impoundment treatment system consisted of thefollowing:
• Two 303,000-gallon lime sludge settling impoundments;
• One 1,100,000-gallon aeration impoundment; and,
• One 604,000-gallon polishing impoundment.
The impoundment liners consisted of 6 to 12 inches of soil cement and an asphalt coating.
VIII. Basis for Taking Action
EPA proposed the Site for inclusion on the NPL on October 15, 1984 and placed it on the NPL onJune 10, 1986. The results of the RI/FS conducted from 1990 to 1991 indicated a total of 26 VOCs ofpotential concern in the groundwater, surface water and sediment to be considered in the risk assessment,including:
• 1,1,1-trichloroethane • dichlorodifluoromethane • 1,1-dichloroethane • ethylbenzene • 1,1-dichloroethene • methylene chloride • 1,2-dichloroethane • noncarcinogenic PAHs• 1,2-dichloroethene (total) • ortho-and para-xylenes • 1,4-dichlorobenzene • tetrachloroethene • 4-methylphenol • toluene • acetone • total dichlorobenzenes • benzene • trans-1,2 dichloroethene
7
• bis(2-ethylhexyl) phthalate • trichloroethene • carbon tetrachloride • trichlorofluoromethane • chloroethane • vinyl chloride • chloroform • xylenes (total)
Additionally, 15 inorganic and radioactive compounds of potential concern in the groundwater,surface water and sediment were detected, and these compounds were also considered in the riskassessment:
• aluminum • iron • vanadium • barium • lead • radium 226 • cadmium • manganese • radium 228 • cobalt • mercury • thorium 230 • cyanide • nickel • uranium
The VOCs, inorganics and radionuclides were detected in the environmental media sampled. Manyof the detected substances were found not to contribute significantly to overall public health. However, itwas determined that the actual or threatened releases of hazardous substances from this Site may present animminent and substantial endangerment to public health, welfare, or the environment, and thereforeremediation of VOCs in the groundwater was warranted.
To evaluate potential human health risks, several exposure pathways were selected in the riskassessment for detailed evaluation under both current and possible future Site conditions. An exposurepathway, defined as a source and mechanism of chemical release, an environmental transport medium, apoint of potential exposure, and a route of exposure, is considered "complete" if all of these elements arepresent. If an exposure pathway was considered complete, the potential risk was quantitatively calculated.
Two scenarios were evaluated during the risk assessment: a no-action alternative, and ano-further-action alternative. The no-action alternative represented Site conditions without operation of thegroundwater extraction and treatment systems. The no-further-action alternative represented Site conditionswith operation of the groundwater extraction and treatment systems. The assessment of these scenariosenabled a determination of whether further remedial action was required.
The conclusions of the risk assessment were:
• Federal and state drinking water standards were exceeded in groundwater for six VOCs(benzene; carbon tetrachloride; 1,2-dichloroethene; 1,1-dichloroethene; trichloroethene; andvinyl chloride).
• The potential risks associated with direct sediment and surface water contact on-site are wellbelow regulatory levels of concern for both the no-action and no-further-action alternatives.
• The potential risks associated with future ingestion of groundwater on the CERCLA Siteunder the no-action alternative, if concentrations of the VOCs above remained at the levelsmeasured in the late 1980s for three decades, are above regulatory levels of concern.
• The potential risks under the no-further-action alternative associated with future groundwateringestion on the CERCLA Site, if concentrations of the VOCs above remained at the levelsmeasured in the late 1980s for three decades despite operation of the groundwater extractionsystem, are above regulatory levels of concern. The risks are considered to be overestimated
8
because actual groundwater concentrations were expected to be significantly reduced due tooperation of the groundwater extraction system.
• The potential risks associated with future groundwater ingestion on-site under theno-further-action alternative, conservatively assuming concentrations of the VOCs aboveremained at the levels measured in the late 1980s for three decades despite operation of thegroundwater extraction system, are at levels within the EPA's target risk range for Superfundsites. Considering groundwater concentrations were expected to be significantly reduced dueto operation of the groundwater extraction system, the estimated risk levels were notconsidered to be unacceptable (insufficient data were available to evaluate potential risks dueto groundwater ingestion on-site for the no-further-action alternative).
• For both the no-action and no-further-action alternatives, the potential risks associated withfuture groundwater ingestion off-Site are well within the EPA's target risk range forSuperfund sites, conservatively assuming concentrations of the VOCs above remained at thelevels measured in the late 1980s for three decades despite operation of the groundwaterextraction system. Since under the no-further-action alternative groundwater concentrationswere expected to be significantly reduced due to continued operation of the groundwaterextraction system, the estimated risk levels for this alternative were not considered to beunacceptable.
IX. Remedial Actions
The remedial actions implemented at the Site include those described in Section VII above (InitialResponse), and landfill capping, groundwater extraction, groundwater and leachate treatment, landfill gasextraction, and groundwater and surface water monitoring, described in Section X (Remedy Selection)below.
X. Remedy Selection
Based on data collected and the risk assessment results of the RI/FS, EPA established RemedialAction Objectives (RAOs) for the Site. Remediation is generally focused on exposure pathways showingexcess cancer risks greater than 1 x 10-6 or, for non-carcinogens, a hazard index greater than the thresholdlevel of one. These points of departure were exceeded for the groundwater ingestion exposure pathwayonly. Therefore, RAOs were developed for groundwater only.
RAOs for the Site:
• Reduce leachate production and migration to groundwater;
• Reduce the amount of groundwater degradation on the CERCLA Site;
• Decrease the potential for migration of degraded groundwater from the Modern Landfill property;
• Minimize migration of leachate constituents into surface water;
• Prevent exposure of contaminated groundwater;
• Restore contaminated groundwater to beneficial uses where practicable; and,
• As a goal, restore contaminated groundwater to background quality. 9
1991 Record of Decision
The selected Remedial Action at the Site as described in the ROD of June 28, 1991 included thefollowing major components:
• Continued operation and maintenance of all previous remedial actions conducted on-site including,the landfill cap, groundwater extraction systems, on-site wastewater treatment facility, gas extractionsystem (for removal and destruction of landfill generated methane gas), and groundwater and surfacewater monitoring;
• Completion of the landfill cap system and final cover for the 66-acre landfill;
• Maintenance of Site fencing and all access restriction;
• The addition of extraction wells to the eastern and western extraction systems to preventcontaminated groundwater from bypassing those systems;
• The completion of additional monitoring and/or extraction wells as needed to ensure protectivenessand to control groundwater flow, respectively; and,
• As a goal, restore contaminated groundwater to background quality.
Table 1 presents the chronology of remediation activities including pre-ROD remedial actions andrelevant milestones.
Performance Standards set forth in Section VI.B. of the June 10, 1993 Consent Decree (CD) aredirected toward groundwater restoration and cleanup. The Performance Standards include the followingcomponents:
• Submission and approval of the Construction Quality Assurance Plan (CQAP) for the remedialactivities required by the ROD. The CQAP includes the remedial action construction plan, a Healthand Safety Plan (HASP) for any field activities, and a remedial action schedule;
• Submission and approval of a Remedial Operations and Maintenance Plan (ROMP) for continuedoperations of the existing Remedial Actions. The ROMP includes a Sampling and Analysis Plan(SAP), a HASP for any field activities, an Operations and Maintenance (O&M) Plan, and an O&Mschedule; and,
• Performance of work in such a manner as to achieve the Performance Standards set forth in the CD.
Remedy Implementation
In June 1993, EPA, PADEP, and Modern entered into a Consent Decree (CD; Appendix B) forremedial action and cost recovery. The CD acknowledged that since the date of the signing of the ROD,Modern had accomplished the following:
• Completion of the design for the final four acres of the landfill cap and final cover system (includingPADEP approval). These remaining four acres are commonly referred to as the "highwall area"; and
• Construction of additional groundwater extraction wells (Well Nos. W68 and W69) required by theROD and deepening extraction well B20 (renamed after modification as extraction well W20).
10
As outlined in the CD, the EPA determined that the remaining work required by the ROD consistedof the following:
• Completion of the construction of the final four acres of the landfill cap (i.e. the highwall area), and;
• Operation and maintenance of the remedial actions previously completed, and those to be completedunder the CD. These include: the entire landfill cap and final cover system; the entire groundwaterextraction system; on-site wastewater treatment facility; landfill gas extraction system; and thesurface water and groundwater monitoring network.
All remedial actions implemented at the Site were based on PADEP-approved designs that includedCQA plans. Each construction phase implemented at the Site was overseen by a fulltime independent CQAfirm. Table 2 provides a list of the construction activities as well as the CQA firm and the CQA report. Thereferenced reports provide details regarding construction activities, problems that may have beenencountered, and any deviations from the designed requirements. Specific engineering certifications forms(e.g., PADEP Form 37) were sealed by a professional engineer (PE) registered in Pennsylvania and weresubmitted to PADEP as part of the CQA reports. Table 2 also provides a list of firms that provided designand CQA services. Costs associated with design and construction of the remedy are further discussed inSection XL
The field activities implemented in the NPL portion of the Site were conducted based on HASPsdeveloped by engineering consultants and construction contractors. In general, the HASP developed as partof the RI/FS Work Plan (Colder Associates, 1988) was largely used as the basis for project specific plansdeveloped by each engineering consultant and construction contractor.
Capping and Cover Systems
The cap and cover systems areas placed over the 66-acre landfill include the following components(see Figure 4):
• Landfill slope cap/vertical expansion area, which was placed to separate the 66-acre landfill from the30-acre vertical expansion area;
• Twenty-acre plateau area final cover system (geomembrane cover);
• Forty-two-acre landfill cap (clay cap) and cover system over the side slope area (approximately 42acres); and,
• Landfill cap and cover system over the highwall area (approximately 4 acres built as part of Cell12B, 13 A, and 13B construction).
Other landfill construction activities including landfill cell construction and final landfill cap andcover systems were also conducted in other non-NPL areas of the Site based on PADEP permit approvals.These areas include the 21-acre Northern Expansion and the 17-acre Northern Expansion (collectivelyreferred to as the Northern Expansion), the Southwest Expansion and the Northwest Expansion.
The following paragraphs contain a description of the landfill cap and final cover systemsconstructed over the 66-acre landfill.
Landfill Slope Cap/Vertical Expansion Area
11
A slope cap was placed over 30 acres of the 66-acre landfill. The slope cap consists of, in ascendingorder, at least one foot of intermediate cover, a 60-mil HOPE geomembrane, a geonet drainage layer, twogeotextiles, and two feet of AASHTO No. 8 granular drainage medium. The slope cap serves to isolate therefuse in the unlined landfill from the refuse being placed in the vertical expansion area, to eliminateinfiltration of rainwater, and to isolate leachate generated from the vertical expansion area. Leachateproduced in the vertical expansion area is collected for treatment at Modern's wastewater treatment facility.The installation of the landfill slope cap was completed in October 1989. Hamilton Excavating andDevelopment Company, Inc. was the earthmoving contractor; Gundle Lining National Seal Co. andConstruction Corp. were the liner contractors; and GeoServices, Inc. was the CQA consultant for Cell A.Colder Associates was the CQA consultant for Cells B and C. J&L Testing Company, Inc. and ColderAssociates were the outside laboratories selected for soils and geosynthetics testing.
Twenty-Acre Plateau Area
A synthetic geomembrane final cover system was installed over the 20-acre plateau area. Thegeomembrane final cover was designed to reduce infiltration of precipitation and thereby reduce thequantity of leachate generated by the 66-acre landfill. The cap consists of, in ascending order, at least onefoot of intermediate cover soil overlain by a geotextile fabric, a 40-mil HOPE geomembrane, a geonetdrainage layer, another geotextile layer, and two feet of surficial soil.
The installation of the final cover system over the 20-acre plateau area was completed in August1990. Modern personnel performed earthmoving work; National Seal Co. was the liner contractor; andColder Associates was the CQA consultant. Colder Associates was the outside laboratory selected for soilsand geosynthetics testing.
Forty-Two-Acre Side Slope Area
The side slopes from the crown of the 66-acre landfill to the toe were capped with, in ascendingorder, a minimum one foot of intermediate cover, three feet of clay compacted to less than 10-7 cm/secpermeability, a 6-inch granular drainage layer, and two feet of surficial soil. Near the base of the slope andat intermediate terraces, the drainage layer discharges into surface water drainage channels.
The installation of the final cover system over the 42-acre side-slope area was completed in April1991. Hamilton Excavating and Development, Inc. was the earthmoving contractor; Hively Farm andEquipment Co. was the hydroseeding contractor; and Dames & Moore and Colder Associates were the CQAconsultants. Golder Associates was the outside laboratory selected for soils testing.
Four-Acre Highwall Area
As outlined in the CD (1993), the EPA determined the remaining construction work required by theROD consisted of the construction completion of the final four acres of the landfill cap (i.e. the highwallarea). In July 1993, Modern submitted a redesign of the 4-acre highwall area to EPA and PADEP for reviewand approval. The report provided a pre-design of the 4-acre highwall area, final cover design on thehighwall slope, and permit modification as required by PADEP. The redesign was conditionally approvedby EPA in September 1995, noting that it was deficient with respect to the thickness of the textured HOPEgeosynthetic cap. The proposed thickness in the design was 30-mil, substantially less than the 60-mil whichwas promulgated in 40 CFR § 258.40(b).
During this time, Modern informed the EPA of application for a permit modification for anapproximate 67-acre landfill expansion (Northwest Expansion). The Northwest Expansion would provide an
12
additional 15 years of disposal life and be wholly located within Modern's present boundaries. TheNorthwest Expansion would fill in the area between and to the northwest of the two existing landfills (theoriginal 66-acre landfill and the Southwest Expansion) and encompass the 4-acre highwall area. Under thispermit modification, double-lined landfill cells would be constructed on top of the highwall area. Theselandfill cells would also receive a composite capping system as a final cover when the cells are completed.As a result of this action, a meeting was held on July 8, 1996 and the EPA agreed to defer construction ofthe final cover for the 4-acre highwall area until PADEP completed its review of the permit modification.
In April 1997, Modern submitted the formal permit modification application for the NorthwestExpansion to PADEP. The following year, in response to technical comments on the Northwest Expansion,EPA asserted the design and specifications for the Enhanced Western Groundwater Control System(EWGCS) would be considered an equivalent method of groundwater recovery to the existing westerngroundwater extraction system. The permit modification for the Northwest Expansion (Permit No. 100113)was approved by PADEP in April 1999.
According to the design for the Northwest Expansion, the remaining 4 acres of highwall area to becapped would be addressed during construction of Cells 12, 13, and 14. The geosynthetic liner system forthese cells would consist of secondary and primary geotextile layers and two 60-mil textured geomembraneswith a primary geosynthetic clay liner.
EPA determined the specifications of the Northwest Expansion design met or exceed thosespecifications proposed for the 4-acre highwall cap redesign of 1995. As a result, EPA was willing to acceptthe design change and documented these non-significant post-ROD changes in a memorandum datedSeptember 26, 2000.
Construction of the Northwest Expansion began in May 1999. Initial Site activities includedconstruction of a new entrance road, sedimentation pond, and stream relocation, as well as implementationof the EWGCS. The 4-acre highwall area was encountered during the construction of Cell 12B in February2000. Cell 12B, consisting of a slope area and floor area approximately five and two acres respectively, islocated south of, and adjacent to, Cell 12A of the Northwest Expansion, and was constructed as adouble-lined containment area to be utilized for municipal solid waste disposal. Construction activities forCell 12B included stripping the existing topsoil and vegetation, placement of structural fill and subbase,installation of the geosynthetic liner system components, placement of protective cover aggregate, andinstallation of leachate collection piping connecting existing Cell 12A to the leachate collection andconveyance system. A clay subbase layer, with a minimum thickness of six inches was placed andcompacted over the entire footprint of Cell 12B. The subbase layer exhibited a permeability of no greaterthan 10-5 cm/sec.
The geosynthetic liner system consisted of secondary and primary geotextile layers and two 60-milHOPE textured geomembranes with a primary geosynthetic clay liner extending a minimum of threevertical feet up the perimeter slope sides. The secondary collection system consists of a geocompositematerial on both the floor and slope areas. The primary collection system consists of a minimum of 18inches of protective cover aggregate and lateral and header pipe drains.
Construction of Cell 13 commenced immediately after the completion of Cell 12B in May 2000.Construction was completed in two phases resulting in Cell 13A and Cell 13B. Cell 13, also consisting of aslope area and floor area of approximately 21 acres, is located south of, and adjacent to Cell 12B. Cell 13was constructed in the same manner as Cell 12B, as described above. The survey limit of the 4-acrehighwall area in the vicinity of the Cell 13/14 interface was conducted during construction activities ofCells 13A and 13B. In September 2000, it was verified that Cells 13A and 13B would provide the remaining
13
coverage of the 4-acre highwall area required by the ROD. Therefore, construction is considered completefor the 66-acre landfill even though construction of the Northwest Expansion still remains for non-NPLportions of the Site.
For construction of Cells 12, 13, and 14, National Earth Products was the earthmoving contractorand leachate system contractor; Serrot International, Inc. was the liner contractor; and Earth Tech, Inc. wasthe CQA consultant. Golder Associates was the outside laboratory selected for soils and geosyntheticstesting. The outline of the Northwest Expansion cells and current Site conditions are summarized in Figure5.
The pre-final inspection was conducted at the Site on September 25, 2000 with representatives fromEPA in attendance. The entire 4-acre highwall area is now covered with a primary and secondary linersystem. The pre-final inspection indicated that only minor items not affecting performance of the remedyneeded to be addressed. Some of these items, such as providing a temporary intercell protective cover bermbetween Cells 13 and 14 and finishing the remaining panels of geotextile in Cell 13, were completed at theend of 2000.
Groundwater Remedial Actions
Western Groundwater Interceptor Trench
Leachate seeps and the presence of leachate constituents in the groundwater were noticed prior to1976 on the west side of the 66-acre landfill. As a result, a groundwater interceptor trench and surfaceimpoundment treatment system were designed in 1976 and constructed in 1977. CQA was provided byWilliam E. Sacra and Associates, and as-built plans are provided in their August 3, 1977 report. Thegroundwater interceptor trench was 2,200 feet long and 6 feet to 15 feet deep. Seepage water collected bythis trench was pumped to the original surface impoundment treatment system, then to the on-sitewastewater treatment plant (April 1987). Following PADEP approval of the Northwest Expansion (1999),the western groundwater interceptor trench was replaced by the EWGCS. The EWGCS became completelyoperational in January 2000.
Western Groundwater Extraction System
In 1984, a network of 12 groundwater extraction wells was designed to augment the westerngroundwater interceptor trench, pursuant to a September 20, 1984, Consent Order/Agreement betweenPADEP and Modern. The groundwater extraction system design (i.e., required radius of influence andspacing of the wells) was completed by RE WAI (REWAI, 1984). The installation of the extraction wellsand the CQA was provided by REWAI (REWAI, 1984a). These wells became operational on January 14,1985.
Following REWAI's evaluation (REWAI, 1987), two additional wells, W62 and W64, were added tothe western extraction well system in 1987, bringing the total number of extraction wells to 14. Theinstallation of the additional extraction wells and CQA was provided by REWAI (REWAI, 1987). Waterextracted by the system was pumped to the surface impoundment treatment system until the new wastewatertreatment plant was brought into operation in April 1987.
Following the RI/FS and in accordance with the ROD (June 1991) existing well B20 was deepened(new designation W20) and two additional extraction wells (W68 and W69) were added to the westerngroundwater extraction system. The design of the western extraction system modification and CQA wereconducted by Golder Associates (1991, 1992). The new extraction wells were connected to the westerngroundwater extraction system in 1992.
14
Following PADEP approval of the Northwest Expansion (April 1999), the western groundwaterextraction system was replaced by the EWGCS. The EWGCS was partially operational in October 1999,and became completely operational in January 2000.
Eastern Groundwater Extraction System
The presence of leachate constituents in the eastern tributary determined the need for construction ofa groundwater remediation system along the eastern side of the Site. In 1985, REWAI assessed thehydrogeology of this area and designed a system of 13 extraction wells positioned along the easterntributary (REWAI, 1985). The installation of the additional extraction wells and CQA was provided byREWAI (REWAI, 1985). This system became operational in November 1986, pursuant to the September20, 1984, Consent Order/Agreement between PADEP and Modern. Groundwater collected by this systemwas originally pumped to the surface impoundment treatment system until the new wastewater treatmentplant was brought on line on April 22, 1987.
Following the RI/FS (ICF/Golder Associates, 1991), existing well W60 was connected to the easterngroundwater extraction system. The extraction well CQA was provided by REWAI (REWAI, 1987). Thenew extraction well was connected to the western groundwater extraction system in 1991.
In 1992, based on recommendations made by Golder Associates (Golder Associates, 1991) and withPADEP approval, two extraction wells (W23 and W34) were removed from the eastern extraction systembecause of their low efficiency of VOC removal, and were converted to groundwater constituent assessmentwells. Currently, the eastern extraction system includes 12 wells.
Enhanced Western Groundwater Control System (EWGCS)
In February 1996, as part of the landfill permit modification for the Northwest Expansion, Modernsubmitted a conceptual design for blasting a groundwater collection trench along a 400-foot section of theexisting western groundwater extraction system (Rust Environment & Infrastructure and Golder Associates,1996). In April of 1996, Modern provided the Phase I/II Submittal of the permit application to PADEP(Rust Environment & Infrastructure, 1995).
During the first and second quarters in 1997, a pilot groundwater extraction trench was installed, aspart of the Demonstration Project, to replace a portion of the existing groundwater extraction system and tomonitor the effectiveness of the proposed system. The enhanced groundwater extraction pilot trench(Demonstration Project) was comprised of three engineered elements: (i) a mass of blasted rock; (ii) anexcavated trench backfilled with course porous sand; and (iii) a coarse gravel surface blanket. A six-monthhydrogeologic and geochemical monitoring period was initiated immediately after construction of theDemonstration Project. The results of the Demonstration Project indicated leachate-impacted groundwaterwas withdrawn at a flow rate approximately 24% greater than previously, and leachate-derived compoundswere withdrawn at a rate approximately 80% greater, by mass, than previously. Based on this effectivenessevaluation, it was recommended that the entire EWGCS be implemented (Golder Associates, 1997). Thedesign and modeling of the EWGCS was reviewed extensively by a third party consulting firm (OgdenEnvironmental, 1998) as well as by EPA and PADEP.
For the Demonstration Project construction in 1997, blasting services were provided by J. Roy's Inc.;earthmoving, trenching and gravel blanket construction services were provided by Bilran Construction; welldrilling services were provided by Eichelberger's Inc.; and CQA services and geotechnical soil testingservices were provided by Golder Associates.
15
Following EPA and PADEP approvals (July 1998, and April 1999, respectively), the EWGCS wasconstructed between May and December 1999. The EWGCS is a passive groundwater collection systemdesigned to replace an extraction well network, located beneath the Northwest Expansion. The systemconsists of two elements: (i) a blast trench constructed by shattering existing bedrock in place to depths of105 feet using controlled blasting techniques; and (ii) an engineered backfill trench constructed by replacingoverlying low permeable overburden materials with a highly permeable sand to a depth of 20 feet. The totallength of the EWGCS is 2,825 feet and is comprised of over 195,000 cubic yards of modified nativesubsurface materials. Groundwater, impacted by leachate from the adjacent 66-acre landfill, is collected andconveyed by the system due to its enhanced hydraulic conductivity and natural gravity feed. At thedowngradient end of the system, an extraction well network withdraws the collected groundwater fortreatment at the on-site wastewater treatment plant. To ensure proper construction of the EWGCS, rockblasting, engineered backfill placement, hydrogeologic testing, and groundwater extraction activities weremonitored and documented extensively through the construction period. The Final As-Built Report for theEWGCS was prepared submitted to EPA in March 2000 (Golder Associates, March 2000).
For EWGCS construction in 1999, blasting services were provided by Energetic Solutions Inc.,earthmoving and trenching services were provided by Brubacher Excavating Inc., well drilling serviceswere provided by Reichert Well Drilling Inc. and Uni-Tech Drilling Inc.; and CQA and soil laboratoryservices were provided by Golder Associates.
Since implementation of the EWGCS, in 1999, Modern has monitored groundwater extraction ratesin the system and groundwater levels outside the system. To design the EWGCS, Golder Associates used acalibrated groundwater model (Golder Associates, June 1998). As part of the Five-Year Review process,Golder conducted additional groundwater modeling runs, using site data collected since 1999 to simulate actual conditions and determine the effectiveness of the groundwater model. Appendix C contains thegroundwater modeling report with the updated modeling runs.
Groundwater and Leachate Treatment Facilities
Modern operated four surface impoundments to treat leachate seepage collected by the interceptortrench along the western perimeter of the Site under PADEP Water Quality Management Permit No.6786201 issued on September 24, 1976. The groundwater interceptor trench and surface impoundmenttreatment system were designed in 1976 and were constructed in 1977. CQA was provided by William E.Sacra and Associates, and as-built plans are provided in their August 3, 1977 report. On January 14, 1985,groundwater extraction wells along the western perimeter were brought on line. The extracted groundwaterwas conveyed to these impoundments for treatment.
The surface impoundment treatment system was designed to treat 72,000 gallons of groundwater perday. The treatment process consisted of: pH elevation using a liquid lime slurry; metals precipitation;aeration; clarification; and chlorination. The surface impoundment treatment system consisted of thefollowing:
• Two 303,000-gallon lime sludge settling impoundments;
• One 1,100,000-gallon aeration impoundment; and,
• One 604,000-gallon polishing impoundment.
The impoundment liners consisted of 6 to 12 inches of soil cement and an asphalt coating.
16
On November 20, 1986, PADEP issued Modern NPDES Permit No. PA0046680. Under this permit,Modern was permitted to do the following:
• Construct and operate a temporary treatment plant to treat groundwater from the easterngroundwater extraction wells;
• Continue operation of the impoundment treatment system for the western groundwater extractionsystem and interceptor trench; and
• Construct and operate a permanent wastewater treatment plant, consisting of physical, chemical andbiological treatment.
The impoundments and temporary treatment plant were operated until the new wastewater treatmentplant became operational on April 22, 1987. The temporary treatment plant and four surface impoundmentswere decommissioned in June 1987 in accordance with a May 27, 1987 agreement with PADEP.
The wastewater treatment plant is designed to accept flow from the groundwater extraction systems,and leachate from the existing double-lined landfills and slope cap/vertical expansion area. The wastewatertreatment facility comprises a 500,000 gallons per day (gpd) physical/chemical plant and a biological plantto treat extracted groundwater and leachate from the existing double-lined landfill. The physical/chemicaltreatment portion includes an air stripper to remove volatile organic compounds (permitted under PADEPAir Quality Control Permit No. 67-330-004). The biological treatment portion was added to enabletreatment of leachate collected in the double-lined landfill cells (and the slope cap/vertical expansion area).The wastewater treatment plant was constructed by Johnson and Construction, and the CQA was providedby Buchart-Horn, Inc. The biological portion of the treatment system was constructed by Envirex.
Landfill Gas Extraction System
The purpose of a landfill gas extraction system at Modern is to prevent landfill gas migration. Theoperation of the landfill gas extraction system subjects the entire refuse volume within the 66-acre landfill toa pressure equal to or slightly less than that of atmospheric pressure, reducing landfill gas migration. Thelandfill gas extraction system consists of four basic components:
• Gas extraction devices, wells and trenches;
• Pipe network transportation system consisting of header pipelines and laterals;
• Condensate management structures consisting of a condensate storage tank and pump stations; and
• Blower/flare station.
Gas extraction devices provide an escape route for landfill gas. Gas extractors (horizontal trenchesand vertical wells) are constructed with a porous medium surrounding a hollow cylindrical core. Horizontalextractors are most effective in areas of shallow refuse or in areas where wellhead assemblies and cappenetrations are not desired. Vertical extractors are most effective in areas of greater refuse depth.
The pipe network transportation system is constructed of HDPE pipe having diameters ranging from4 inches to 18 inches. The pipe network is designed to perform three separate functions: (i) to supply all theextraction devices with sufficient low-pressure so the entire refuse volume will be subject to pressures equalto or lower than atmospheric pressure; (ii) to transport all collected landfill gases from the extraction
17
devices to the flaring facility; and (iii) to transport all condensate formed within the pipe network to thecondensate management structures.
Condensate management structures are designed to eliminate the operational problems associatedwith a dual (gas/liquid) pipe transportation system. The condensate management structures consist ofcondensate pump stations and discharge lines and condensate storage facilities. Condensate managementstructures are configurations of HOPE pipe which force the landfill gas from a horizontal flow direction to avertically upward flow direction. The much heavier liquid condensate drops vertically downward thusseparating the gas from the liquid. The condensate from the eastern portion of the gas extraction systemflows to a condensate storage tank, where it is pumped from the tank and trucked to the on-site wastewatertreatment plant. Condensate from the western gas extraction system flows directly to the on-site wastewatertreatment plant.
The blower in the blower/flare station pulls landfill gas from the extraction devices and maintains apressure less than atmospheric in the refuse. The gas removed from the pipe network is pressurized withinthe blower housing and discharged to the flare for thermal oxidation.
The flare destroys unwanted and odorous elements within the landfill gas during thermal oxidation,which occurs at high combustion temperatures. The flare system is designed with continuousself-monitoring and self-igniting safety systems. The self-monitoring system includes automatic shut-downdevices if the proper combustion cannot be maintained.
The gas extraction system was designed by Waste Management, Inc. The initial gas extractionsystem consists of 28 production wells and two production trenches, connected to a main header pipe whichconducts the gas flow to a flare station. The installation of the gas extraction system was conducted between1986 and 1989.
In 1986, 14 landfill gas control wells (W-l through W-14) were installed along the perimeter of the66-acre landfill based on PADEP-approved design plans and specifications prepared by WasteManagement, Inc., (1985). The installation of the 14 landfill gas extraction wells was completed in July1996. Kellett's Well Drilling was the drilling contractor, and Fred C. Hart Associates, Inc. was the CQAconsultant (Fred C. Hart Associates, Inc., 1986).
In 1989 the following components of the landfill gas extraction system were installed under GolderAssociates supervision: landfill gas extraction wells W-l5 through W-31; gas collection trenches "B-B" and"C-C"; gas production header line and laterals; and installation of trench control assemblies, condensatepump stations, condensate tank, and the blower/flare station. The installation of the gas extraction wells wasperformed by Kellet Well Boring Inc. from October 22 through October 28, 1987. Stewart & March, Inc.was contracted to perform the installation of the remaining portion of the gas extraction system. BetweenOctober 22, 1987 through August 27, 1988, Golder Associates provided full-time third party CQAinspection and documentation of all activities associated with the construction of the gas extraction system.
In 1989, additional construction work was completed under the supervision of Buchart-Horn, Inc.The construction activities included installation of gas collection trenches "D-D" and "E-E", and lateralconnections to the existing gas extraction wells. This work was completed by May 1989. HamiltonExcavation and Development was the construction contractor, and Buchart-Horn, Inc. was the CQAconsultant (Buchart-Horn, Inc., 1989).
In 1999, the old gas flare was decommissioned and a state-of-art enclosed flare was installed at theSite. The enclosed gas flare was installed by LFG, Inc. and Johnston Construction, and CQA was provided
18
by EarthTech, Inc. In addition, modification to HOPE piping connections and gas condensate collectionlines were made as a result of the PADEP-approved Northwest Expansion. These modifications were madeby Organic Waste Technologies, Inc. and CQA was provided by EarthTech, Inc.
Groundwater and Surface Water Monitoring Systems
The current monitoring program implemented at the Site is based on the PADEP approved program(PADEP Form 18) and includes groundwater monitoring, surface water monitoring, wastewater treatmentplant discharge monitoring, and other non-NPL programs such as macroinvertebrate monitoring andrelocated stream flow monitoring. Details of monitoring systems implemented at the Site are included in theSite Specific Monitoring Plan (Golder Associates, August 2000), and PADEP Form 18. Summaries ofhistoric and current monitoring data and interpretation of the results are provided in the annual assessmentreports submitted to PADEP.
The following paragraphs contain a summary of the PADEP-approved groundwater, surface watermonitoring system, and wastewater treatment plant discharge monitoring.
Groundwater Monitoring System
The groundwater monitoring system at the Site is designed to:
• Monitor the groundwater chemistry in the vicinity of the Site as required by the ROD;
• Allow determination of the effectiveness of the remedial actions at the Site; and
• Satisfy the PADEP regulations regarding municipal waste landfills.
The groundwater monitoring system at the Site is comprised of 34 groundwater monitoring wells, 7constituent assessment wells, 16 extraction wells, and 17 surface water monitoring stations. Figure 5 showsthe locations of the active monitoring points. Table 3 summarizes the current PADEP-approved monitoringnetwork (as of April 16, 1999).
Groundwater Monitoring Wells
Thirty-four (34) wells are currently utilized as groundwater monitoring wells. Table 3 summarizeswell construction details and sampling information. The location of each well is selected to satisfy one ofthe following criteria:
• To monitor groundwater quality downgradient of the northern lined expansion areas;
• To monitor groundwater quality outside the limits of the groundwater extraction system; and
• To determine upgradient background groundwater quality (MU101, MU127, and MU427).
If it can be determined in the future that some of the monitoring wells provide unnecessary orredundant water quality data, then the unnecessary or redundant well(s) will be removed from themonitoring system following approval from PADEP.
Groundwater Extraction Wells
19
Currently, the active groundwater extraction wells include four extraction wells as part of theEWGCS, and 12 extraction wells as part of the eastern groundwater extraction system (total of 16 extractionwells). The locations of all active extraction wells are shown on Figure 5. These wells are monitoredaccording to the schedule and parameters and shown in Tables 4 and 5, respectively. The groundwaterextraction wells are monitored to assess the changes of groundwater quality that result from the extractionpumping. Analytical results of samples from the groundwater extraction wells are utilized in thedetermination of when a well can be removed from service.
Groundwater Constituent Assessment Wells
In order to assess the effects of the groundwater extraction system, seven wells (see Table 3) havebeen designated as groundwater constituent assessment wells. Two wells (MD128 and MD209D) lie outsidethe area of influence of the eastern groundwater extraction system, and five wells (MD120, MD122S,MD1231, W23 and W34) lie inside the area of influence of the EWGCS and eastern groundwater extractionsystem. These wells are used to evaluate more closely areas of leachate constituent concentrations.
Surface Water Monitoring System
Seventeen surface water sampling points are included in the monitoring program listed on Table 3.These locations are shown on Figure 5. These points have been located at: springs (e.g. MSP 110) to detectpossible surface discharge of constituents from the groundwater; in streams (e.g. (MS201) to help determineif constituents are being transported in the runoff from the Site; at sedimentation basins (e.g., MPH501) to determine the quality of the surface water runoff which discharges from the basins; and at the outfall fromthe wastewater treatment plant (MTP001).
Sample Parameters and Monitoring Schedule
Tables 4 and 5 present the sample parameters and sampling schedule for each sampling point inaccordance with current PADEP regulatory requirements.
Data Evaluation, and Reporting
All data are electronically transferred to PADEP using the Land Links Program. In addition,chemistry data are summarized and interpreted as part of the annual assessment reports submitted toPADEP. The annual groundwater assessment reports contain information regarding the groundwaterextraction systems and leachate generation; summarize the analytical data that are collected frommonitoring wells; assess analytical data quality assurance/quality control (QA/QC) procedures; andcompare the data to project specific data quality objectives (DQOs). The DQOs for this project are theRemediation Goals for Groundwater summarized in the ROD.
From 1987 onward, annual groundwater assessment reports of the groundwater extraction systemswere prepared from the quarterly and annual chemistry data obtained from monitoring wells and surfacewater monitoring points. These reports were prepared by Golder Associates (1988, 1989, 1990b, 1991,1992, 1993, and 1997 through 2004) and Rust Environment & Infrastructure (1994, 1995 and 1996).
Groundwater remediation has been an ongoing and successful process at the Site. The groundwaterextraction systems began operating at full capacity in 1986 (western extraction system) and 1987 (easternextraction system), and were then enhanced by the replacement of the western groundwater extractionsystem with the EWGCS in 1999. Groundwater quality downgradient of the extraction systems has beenrestored, while the total VOC concentrations in groundwater between the 66-acre landfill and the extraction
20
systems decreased by one to two orders of magnitude. This is the result of the remedial measuresimplemented at the Site, which include capping and gas extraction in addition to the pump-and-treatgroundwater systems.
System Operations/O&M
Currently, Modern operates the landfill cap, groundwater extraction systems, on-site wastewatertreatment plant, landfill gas extraction system, and groundwater and surface water monitoring. Modernmaintains a fence around the Site and access is restricted to authorized personnel and contractors.
As part of current permit conditions, PADEP requires the implementation of specific O&M activitiesfor the cover systems, groundwater extraction systems, wastewater treatment plant, landfill gas extractionsystem, and groundwater monitoring system. The O&M activities are reported to PADEP as part of thegroundwater annual assessment reports (i.e., operational data for the extraction systems, wastewatertreatment plant, and integrity of the groundwater monitoring system).
XI. Summary of Project Remediation Costs
Remedial system construction and O&M costs were estimated in the 1991 ROD at approximately$3.5 million in capital costs (for remaining capital projects not yet completed) and $18 million (net presentworth) for O&M. Costs were estimated for an anticipated 30-year O&M time period; a discount rate of five(5) percent was used in the ROD estimate. Details of the cost estimate documentation used in the ROD canbe found in the Feasibility Study (ICF/Golder Associates, 1991).
The total remedial action capital construction costs are listed below:
1) Modern Landfill Wastewater Treatment Plant $ 7,310,500
2) Groundwater Monitoring System $ 452,400
3) Gas Collection Wells/System $ 3,732,033
4) Groundwater Extraction System $ 7,801,250
5) Final Cap over 66 Acre $ 6,172,582
6) Fencing $ 40,000
TOTAL CAPITAL $ 25,508,765
The total project cost is estimated at approximately $44 million. This total is based on the $25.5million for capital construction and $ 18 million for the estimated 30-year O&M period.
XII. Progress Since Last Five-Year Review
This is the first Five-Year Review for the Modern Sanitation Landfill Superfund Site.
21
XIII. Five-Year Review Process
Administrative Components
Members of Modern and PADEP were notified of the initiation of the five-year review on August16, 2004. The Five-Year Review Team was led by Mr. Frank Klanchar (RPM) of EPA Region III, Mr.William Hudson, EPA Community Involvement Coordinator, and Mr. Asuquo Effiong, Project Officer fromPADEP. Modern and its consultant, Golder Associates Inc., also provided information to EPA indevelopment of the Five-Year Review.
The review team established the review schedule which included:
• Community Involvement; • Document Review; • Data Compilation and Review; • Site Inspection; • Site Interviews; and • Five-Year Review Report Development and Review.
The schedule extended through February 11, 2005.
Community Involvement
EPA provided notice to the public that it would be conducting a Five-Year Review in anannouncement in the York Daily Record on September 16, 2004. Appendix D contains a copy of theannouncement. The announcement provided telephone numbers so that the public could contact EPA withany questions or comments. No comments were received during the review period.
Following signature of this five-year review, an ad will be placed in a local newspaper announcingthat the First Five-Year Review for the Modern Sanitation Landfill Superfund Site is complete, and that theresults of the review and the report are available to the public at the Windsor Township Municipal Buildingin Red Lion, PA.
Document Review
The Five-Year Review process included a review of the administrative documents including the1991 ROD and the 1993 CD. Investigation Reports, in particular the RI/FS (ICF/Golder Associates, 1991),were reviewed to understand historical site conditions as well as identified risks. These reports were alsoreviewed to evaluate how the systems were designed to achieve the remedial objectives and identified risksassociated with the Site.
Annual Assessment Reports, which present the monitoring results and summaries of the operation ofthe groundwater extraction systems, were reviewed for current operating and analytical data trends. AnnualAssessment Reports available for review included reports dating back to 1987. Other reports useful for theFive-Year Review included the Interim Remedial Action Report (Golder Associates, 2001), and the SiteSpecific Monitoring Plan (Golder Associates, 2000).
Data Review
A review of historical and recent groundwater and surface water data was performed. Results of thisreview are presented and discussed in Section X.
22
Site Inspection
A Site inspection was performed on October 20, 2004 as part of the Five-Year Review process. Theinspection included a review of the groundwater extraction systems and treatment plant operations. Thoseparticipating in the inspection included Mr. Frank Klanchar and Mr. William Hudson of EPA Region III,and Mr. Asuquo Effiong of PADEP.
The purpose of the site inspection was to assess the protectiveness of the remedy, including thepresence of a fence to restrict access, the integrity of the monitoring and extraction wells, the performanceof the landfill gas extraction system, and the overall condition of the groundwater and leachate treatmentfacilities.
No significant issues were identified at the time of the site inspection.
Site Interviews
During the inspection, EPA and PADEP discussed the operation of the remedial systems with MarkPedersen, Environmental Engineer/Manager for Modern. EPA also contacted officials from Windsor andLower Windsor Townships. As requested, EPA will distribute a copy of this five-year review to eachtownship following EPA signature.
XIV. Technical Assessment
Question A: Is the remedy functioning as intended by the decision documents?
The review of documents and the results of the site inspection indicate that the completed elementsof the remedy are functioning as intended by the ROD. The objectives of the remedy as described in theROD were to control the sources of groundwater contamination by:
• Completion and maintenance of the landfill cap and final cover system;
• Completion and maintenance of the groundwater extraction system;
• Installation of additional extraction wells to ensure the capture of contaminated groundwater flowingto the north;
• Operation and maintenance of the on-site wastewater treatment facility with discharge to theunnamed tributary to Kreutz Creek;
• Operation and maintenance of the vapor (i.e., landfill gas) extraction system;
• Groundwater and surface water monitoring; and,
• On-site fencing.
Monitoring of the Eastern and Western Groundwater Extraction Systems (EGES and WGES) isperformed in accordance with the Site-Specific Monitoring Plan (SSMP). Detailed summaries of analyticaldata are documented in the Annual Assessment Reports, which are used to identify data trends. Specificexamples of how the EGES and the WGES are performing to meeting the goal of groundwater treatmentinclude:
23
• Treatment of over 500 million gallons of groundwater since start-up of the EGES (average of 29.5million gallons per year);
• Treatment of over 1,100 million gallons of groundwater since start-up of the WGES (average of 65million gallons per year);
• Removal of over 570 pounds of VOCs since start-up of the EGES and WGES; and,
• Based on groundwater levels, operation of the extraction system is interpreted as being an effectivemeasure for hydraulic containment of on-site source areas.
Long-term groundwater monitoring is continuing in accordance with the SSMP. Improvements weremade to the WGES in 1999 by replacing 16 extraction wells with the EWGCS, which includes fourextraction wells at the downgradient end. Capping of the 66-acre landfill has been completed by fourseparate capping projects, dating from 1989 to 1999.
EPA concludes that the remedies selected for the Site are functioning as intended by the ROD.
Optimization Opportunities
There were no opportunities for system optimization observed during this review. GolderAssociates, Modern's technical consultant, evaluates system performance and any opportunities for systemoptimization would be provided in the annual groundwater assessment report. EPA and PADEP will reviewthe annual groundwater assessment reports and any recommendations for optimization will be assessed bythe agencies.
Question B: Are the exposure assumptions, toxicity data, cleanup levels, and RAOs used at the time of theremedy still valid?
The exposure assumptions, toxicity data, site-specific cleanup criteria, and remedial actionobjectives specified in the ROD are still valid.
Land use near the Site has not changed significantly over the past few years, and still remains amixture of agricultural and residential. Although municipal solid waste disposal operations at the Site havebeen continued throughout the Site's history, this does not affect the protectiveness of the remedy, and thegroundwater remediation systems are being fully maintained. No physical changes to Site conditions havebeen made that would affect the protectiveness of the remedy.
No new human health or ecological routes of exposure or receptors have been identified or changedin a way that could affect the protectiveness of the remedy. There have been no newly identifiedcontaminants, contaminant sources, or unanticipated toxic byproducts of the remedy that were notpreviously addressed by the decision documents. Standardized risk assessment methodologies have notchanged in a way that could affect the protectiveness of the remedy.
Changes in Standards or To Be Considereds
As remedial work has been completed, the ARARs for construction-type activities cited in the RODhave been met. ARARs that still must be met at this time and that have been evaluated relate togroundwater, leachate, and landfill gas collection and treatment systems. The list of ARARs can be found inAppendix B of the ROD, which is included in this document as Appendix A. There have been no changes inthese ARARs and no new standards or TBCs affecting protectiveness of the remedy.
24
Question C: Has any other information come to light that could call into question the protectiveness of theremedy?
No newly identified risks, impacts from natural disasters, or other information has come to lightwhich could affect the protectiveness of the remedy.
Summary of Technical Assessment
The elements of the 1991 ROD Remedy are functioning as intended and are protective of humanhealth and the environment. This has been achieved primarily through construction of, operation of, andimprovements to the groundwater extraction and treatment systems, completion of the landfill cappingsystems, and maintenance of the landfill gas extraction system. There have been no major changes in thephysical conditions of the Site that would affect the protectiveness of the remedy. There has been nochanges in the toxicity factors for the contaminants of concern that were used in the baseline riskassessment, and there have been no changes to the standardized risk assessment methodology that wouldaffect the protectiveness of the remedy. There is no other information that calls into question theprotectiveness of the remedy.
XV. Issues
There were no issues identified during this five-year review that would affect the current or futureprotectiveness of the response actions conducted at the Site.
XVI. Recommendations and Follow-Up Actions
There are no recommendations and follow-up actions since no issues were identified in Section XV.
No opportunities for system optimization were observed during this review. Golder Associates,Modern's technical consultant, evaluates system performance, including O&M and any opportunities forsystem optimization would be provided in the annual groundwater assessment report. EPA and PADEPreview the annual groundwater assessment reports and any recommendations for optimization orimprovements to O&M activities will be assessed by the agencies
XVII. Protectiveness Statement
The remedies for the Site are protective in the short-term because exposure pathways that couldresult in unacceptable risks are being controlled. The Site will be fully protective when the RAOs have beenattained.
Institutional controls are not required for the Site since it is an active municipal waste landfilloperating under PADEP Solid Waste Permit No. 100113. Under a permit modification in April 1999,double-lined landfill cells were constructed on top of the Site. These cells will receive a composite cappingsystem as a final cover when the cells are completed. The integrity of this action will be protected in thefuture by the implementation of the PADEP-approved Closure Plan and Postclosure Land Use Plan for thefacility.
XVIII. Next Review
The next Five-Year Review for the Modern Sanitation Landfill Superfund Site will be completed nolater than five years after signature of this five-year review.
25
XIX. References
Golder Associates Inc., 1988 through 1993, and 1997 through 2004. Annual Groundwater AssessmentReport, Modern Landfill, York, Pennsylvania.
Golder Associates Inc., 1991. 1990 Annual Groundwater Assessment Report, Modern Landfill, York,Pennsylvania.
Golder Associates Inc., August 2000. Site Specific Monitoring Plan, Modern Landfill, York, Pennsylvania.
Golder Associates Inc., June 1998. Additional Groundwater Modeling Report, Appendix A Attachment toComment 85 (i), Response to May 13, 1998 Technical Comments, Volume 2 of 2, Modern Landfill -Northwest Expansion, York, Pennsylvania.
Golder Associates Inc., March 2000. Enhanced Western Groundwater Control system Final As-BuiltReport, Modern Landfill, York, Pennsylvania.
Golder Associates Inc., May 2001. Interim Remedial Action Report, Modern Landfill, York County,Pennsylvania.
Golder Associates, December 1997. Overall Assessment Report, Enhanced Western Groundwater ControlSystem Demonstration Project, Modern Landfill, York, Pennsylvania.
ICF/Golder Associates Inc., 1991. Remedial Investigation and Feasibility Study, Modern Landfill, York,Pennsylvania.
Ogden Environmental Inc., February 1998. Technical Evaluation of the Proposed Western GroundwaterControl System for the Modern Landfill Sanitation Site, York, Pennsylvania.
Rust Environment & Infrastructure, 1994 through 1996. Annual Groundwater Assessment Reports, ModernLandfill, York, Pennsylvania.
Rust Environment & Infrastructure and Golder Associates Inc., February 1996. Enhanced WesternGroundwater Control System Demonstration Project, Modern Landfill, York, Pennsylvania.
Rust Environment & Infrastructure, December 1995. Application for Solid Waste Disposal, ModernLandfill, Northwest Expansion, Permit Modification Phase II, Permit No. 100113.
USEPA, January 2001. Preliminary Close Out Report, Modern Sanitary Landfill.
USEPA, June 10, 1993. Modern Landfill Superfund Site Consent Decree.
USEPA, June 2001. Comprehensive Five-Year Guidance Document, Office of Emergency and RemedialResponse, EPA 540-R-01-007/OSWER No. 9355.7-03B-P.
USEPA, June 28, 1991. Record of Decision, Modern Landfill, York, Pennsylvania.
26
TABLES
JANUARY 2005 Our Ref. 043-6299
Table 1Chronology of Remediation Activities
Modern Landfill, York PA
Dale
1976
1977
1980's
September 20, 1984
1984
January 14, 1985
1985
June 10, 19861986- 1989
November, 1986November 20, 1986Decembers, 1986
1987
April 22, 1987June, 1987
19901991
1987- 19891988- 1991
1991
June, 1991
1991 - 1992
1992
1992- 1994
June, 1993
July, 1993Winter 1994
May 18, 1995
September, 1995
February, 1996
Activity
Design of Western Groundwater Interceptor Trench and lagoon treatment system
Construction of Western Groundwater Interceptor Trench and lagoon treatmentsystem
Various activities related to cap installation and landfill expansions (see Table 5)
Consent Order/Agreement between PADEP and Modern LandfillInstallation of 12 groundwater extraction wells to augment the WesternGroundwater Interceptor TrenchWestern Groundwater Extraction System brought on line
Design and construction of the Eastern Groundwater Extraction System (13 wells)
Modern Landfill officially listed on the National Priorities ListInstallation of landfill gas extraction systemEastern Groundwater Extraction System becomes operationalPADEP issued Modern Landfill NPDES Permit PA0046680Consent Agreement and Order for RI/FS at Modern landfill signedAddition of two wells (W62 and W64) to the western groundwater extraction wellsystemWastewater Treatment Plant commences operationTemporary treatment plant and surface impoundments were decommissionedRemedial Investigation submitted to USEPAFeasibility Study submitted to USEPAConstruction of Landfill Gas Management SystemCap construction on 66-acre unlined landfill (see Table 5)Well W60 connected to the Eastern Groundwater Extraction System
USEPA signed the ROD selecting the remedy for cleanup at the Modern Landfill
Western Groundwater Extraction System modifications designed and installed(deepened well B20 (new designation W20) and added W68 and W69)
Wells 23 & W34 were removed from the Eastern Groundwater Extraction Systemwith PADEP approval due to their low efficiency of VOC removal.Cap construction on 66-acre unlined landfill (see Table 5)USEPA, PADEP, and Modern Landfill entered into a Consent Decree for remedialaction and cost recoveryRedesign of 4-acre Highwall submitted to PADEPMeetings with USEPA and PADEP to discuss Northwest ExpansionMeeting between USEPA, PADEP and Modern Landfill to discuss the 4-acreHighwall Cap, Northwest Expansion, and enhancements to the WesternGroundwater Extraction System and agreement to perform the Demonstration BlastProjectRedesign of 4-acre Highwall conditionally approved by USEPAModern Landfill submitted a conceptual design for blasting a groundwater collectiontrench along a 400-foot section of the existing Western Groundwater ExtractionSystem
P:\Proiects\2004tO43-6299 Modern Landfill 5 yr Review\Repor!\Table l.xls 1/5/2005 9:51 AM Golder Associates page 1 of 2
JANUARY 2005 Our Ref. 043-6299
Table 1Chronology of Remediation Activities
Modern Landfill, York PA
Date
April, 1996
July, 1996
Spring 1 997
April, 1997
Summer/Fall 1997
July, 1998
April, 1999
May, 19991999
May 1999 - December 1999
May 1999 - August 2000
August, 2000
September, 2000
September 25. 2000
February 14, 2001
Activity
Modern Landfill submitted the Phase l/ll Permit Application to PADEP in relation tothe Northwestern Expansion
USEPA Agrees to defer construction of 4-acre Highwall Cap pending results of theDemonstration Project and PADEP review of Modern's permit modification
Installation of a pilot groundwater extraction trench to replace a portion of thegroundwater interceptor trench connected with the Western GroundwaterExtraction System (Demonstration Project)Modern Landfill submits the formal permit modification for the Northwest Expansionto PADEPSix month hydrogeological and geochemical monitoring period of the groundwaterextraction trenchUSEPA allows that the design specifications of the Enhanced WesternGroundwater Control System is an equivalent method of groundwater recovery tothe existing Western Groundwater Extraction System and issued approval toproceed with the EWGCSPADEP approves permit modification for the Northwestern Expansion and theEWGCSInstallation of additional gas collection piping across the 66-acre landfillOld gas flare decommissioned and replaced with an enclosed flareThe Western Groundwater Extraction System was replaced by the EnhancedWestern Groundwater Control System (EWGCS) and becomes operational inJanuary 2000Construction of Cells #12A, #12B, #13A, #13B (see Table 5)
Site Specific Monitoring Plan for Modern landfill submitted to USEPA and PADEP
USEPA accepted design of Northwest Expansion as meeting or exceeding thosespecifications proposed in the 4-acre highwall redesign of 1995. USEPAdocumented these non-significant post-ROD changes in a memo to the file.
USEPA conducted the pre-final inspection for remediation of the 66-acre unlinedlandfillUSEPA and PADEP conducted the final inspection for remediation of the 66-acreunlined landfill
Checked by:.Reviewed by:
P:\Projects\2004\043-6299 Modern landfill 5 yr Review\Report\Table 1 ids 1/5/2005 951 AM Golder Associates page 2 of 2
JANUARY ZOOS Our tW. M342M
Table 2Summary of Engineering Construction Certifications
Modern Landfill York PA
Engineering Consulting Finn(Author)
Fred C. Han Associates. Inc.
Golder Associates Inc.
Golder Associates Inc.
Golder Associates Inc.
Dames & Moore
Golder Associates Inc.
Buchart-Hom. Inc.
Buchart-Hom, Inc.
GeoServices Inc. ConsultingEngineers
Golder Associates Inc.
Golder Associates Inc.
Golder Associates Inc.
Golder Associates Inc.
Donahue & Associates, Inc.
SEC Donahue
Rust E & 1
Rust E & 1
Earth Tech, Inc.
Golder Associates Inc.
Earth Tech, Inc.
Earth Tech, Inc.
Earth Tech, Inc.
Earth Tech. Inc.
Report Title
As-Built Documentation Gas Control Well Installation
As-Built Documentation 21-Acre Northern Landfill Expansion Cell 1 andCei 2 Volume 10(2
As-Bull Documentation Geosynthetic Ljnig Instalatwn Leachate StoragePond
Gas Vent Decommissioning
As-Built Documentation 21-Acre northern Landfill Expansion Cells 3, 3A,38. 3C and Col! 28
Final Report Final Cover Project Modem Land!!
As-Built Documentation LandfiN Gas Management System
Certification Report for Phase IV Construction Gas Management System
Not Applicable
Construction Quality Assurance of the Installation of Die GeosyntheticCap System for Slope Area A Cap Extension
As-Built Documentation Cells Band C slope Cap
As-Built Documentation Phase 1 and II Clay Capping
As-Built Documentation Plateau Synthetic Cap
As-Built Documentation 1990 Phase II Clay Cap
Construction Documentation lor Cell 4; 17 Acre Northern Expansion
Construction Documentation for Cell 5; 17 Acre Northern Expansion
As Buirl Documentation Report 1992/1993 Final Cap
As-BuM Documentation Report 1994 Final Cap
Not Applicable
Enhanced Western Groundwater Control System Final As-Built Report
Record Documentation and Construction Certification, Cell 12A, ModemLandfill. PADEP Solid Waste Permit Number 1001 13
Record Documentation and Construction Certification. Cell 12B, ModemUndfHI. PADEP Solid Waste Permit Number 1001 13
Record Documentation and Construction Certification, Cell 13A, ModemLandfill. PADEP Solid Waste Permit Number 1001 13
Record Documentation and Construction Certification, Cell 13B, ModemUndfia, PADEP Solid Waste Permit Number 1001 13
Report Date
September 1986
March 1988
May 1988
June 1988
December 1988
December 1988
February 1989
May 1989
Not Applicable
September 1989
August 1990
August 1990
December 1990
December 1991
January 1992
August 1992
March 1994
January 1995
Not Applicable
March 2000
March 2000
June 2000
December 2000D
December 2000O
CertifyingEngineer
John Boshuk, Jr.
Michael RBeaudoin
Michael RBeaudoin
Michael RBeaudoin
Michael RBeaudoin
Richard WHking
MehaelRBeaudoin
Keavin L Nelson
Not Applicable
Robert B.Wallace
Mark A. Snow
Mark A. Snow
James E. Whitty
James E. Whitty
Robert H,Isenberg
Robert H.Isenberg
James L Bender
William L. Eberts
Nol Applicable
Not Applicable
John Conturo
John Conturo
John Conturo
John Conturo
Certificated For
Gas Management System
Liner Installation
Leachate Ponds
Gas Management System
Liner Installation
Cap
Gas Management System
Gas Management System
Treatment Ran
Cap
Liner installation
Cap
Cap
Cap
Liner Installation/Leachale collectionsystem
Liner Installation/Leachate collectionsystem
Cap
Closure
Gas Management System
Groundwater Extraction System
Cap
Cap
Cap
Cap
WorttB*gl£
July 14, 1906
October 20. 1986
October 10. 1987
October. 1946
November 1, 1987
April 29. 1988
October 22. 1987
March 23. 1989
June 8. 1905
July 19. 1983
July 7. 1989
June 12, 1989
February 1,1 990
March 20. 1990
April 25, 1991
March 12, 1991
August 10, 19H2
May 3. 1994
1996
March. 1999
April. 1999
March, 1999
March. 2000
March. 2000
Work Ends
July 19. 1986
October 20. 1987
April 5. 1988
March, 1987
August 11. 1988
October 3. 1988
August 27. 1988
May 4, 1989
June 11. 1905
August 12. 1988
October 4, 1989
January 31, 1990
August 1. 1990
April 15. 1991
November 22. 1991
July 10. 1992
December 17, 1993
December 16, 1994
February, 1997
December, 1999
January, 2000
May, 2000
August, 2000
August. 2000
Contractor*
Reliefs Well Drilling. Inc.
Gundle Lining Construction Corp.
Hamilton Excavating & Development, Inc.
Hamilton Excavating & Development, Inc.
Gundte Lining Construction Corp.
Lambert, Inc.
Hamilton Excavating & Development, Inc.
Gundle Lining Construction Corp.
Hamilton Excavating & Development, Inc.
Stewart & March Inc.
Kellet Well Boring Inc.
WMI Oakbrook. IL
Hamilton Excavating & Development, Inc.
Johnston Construction
National Seal Co.
Gundle Lining Construction Corp.
Land Survey Consultants
Hamilton Excavating & Development, Inc.
National Seal Co.
Land Survey Consultants
Hoechst Celanese Corp
Gundle Lining Construction Corp.
Hamilton Excavating & Development, Inc.
Hively Farm and Equipment Co.
Serrot Corp.
National Seal Co.
Johnston Construction
Modem Landfill Construction Staff
Waste Management PA Liner Crew
Organic Waste Technologies
Iron & Minerals Corp
Waste Management PA Uner Crew
LFG, Inc/tohnson Construction
Organic Waste Technologies
Energetic Solutions. Inc
Brubacher Excavating, Inc.
Reichert Well Drilling, Inc.
Golder Associates Inc.
National Earth Product, Inc.
Brubacher Excavation. Inc.
Serrot International
National Earth Product, Inc.
Serrot International
IT Corporation
Serrot International
IT Corporation
Serrot International
Contractor Role
Gas Well Drilling
Liner Installation
Earthwork
Earthwork
Unerlnstalalkxi
Drilling
Earthwork
Liner Installation
Earthwork
Gas Production System
Gas Production System
System Design
Earthwork/Gas SystemConstruction
Construction
Liner Installation
Liner Installation
As-Built Surveying
Earthwork
Poly net PN 3000 geonet
As-Built Surveying
Trevira1155*1135
40 mil HOPE
Earthwork
Hydroseeded/Mulched
Liner Installation
Liner Installation
Pump House construction
Earthwork
Liner Installation
Eartwork/Gas System Installation
Earthwork
Liner Installation
Gas System flare
Gas System
Blasting Services
Earthmovino/Trenching
Dnning
CQA/Soils Laboratory
Earthwork
Earthwork
Liner Installation
Earthwork
Liner Installation
Earthwork
Uner Installation
Earthwork
Liner Installation
Description of the WortcPerfomed
Installation of 14 gas control wells
Uner installation in Celts 1 and 2
COA leachate storage ponds;
Decommissioned 60 three-inch (Sameter gas vena from the southeast comer and 4 ten-inch diameter gas vents from eastern edge of landfill
Uner Installation/protective cover/collection system for Cells 3, 3A. 3B and 3C
Cap construction - 7.55 acre clay cap
Installalion of 28 production wells and 2 production trenches (B-B and C-C) andcandlestick flare
Installation of gas collection trenches DO S EE and lateral connections lo gas wells 20.21. 24, 25, and 26
Construction/modification of groundwater treatment plant
COA c! installation of HOPE geomembrane. geonet and geotexliles at Slope Area ACap E>1ension
CQA liner installation for slope cap construction for cells B, C1 and C2
Used to convey surface water into existing sedimentation basins A and B: Phase 1 cap =36' clay over 3.8 acres; Phase II cap * 12" over 0.8 acres and 36' over 1 .4 acres
Installed iiner over 4.5 acres
Final Clay cap: 36' thick compacted cl;ay layer underlying 6' drainage stone and 24*surficial soil: approx. 19.5 acres
Construction of closure cap Cell 4 of 17 acre northern expansion and double-walledgravity loachate lines
Construction of closure cap Cell 5 of 17 acre northern expansion
Fianl cap (or Cells A, C and 1
Final can lor A, C. 2, 3, 4 and 5
Installation ol enclosed gas flare following decommissioning of candlestick flare.
Modilicaions to HOPE piping connections and gas collection lines
Fracturirg ol rock using explosive blasting techniques
Installalion of backfilled trench for groundwater conveyance to extraction wells
Installation ol Extraction Well network
Construction of Cell 12A
Construction ol Cell 12B
Construction ol Cell 13A
Construction of Cell 13B
Note: Information regarOVxj the oflglnil Groundwater Extraction System and Kttttoi of Wete W68. W69. and B20 » provided m Table 3.
R«v»w«dbv:
JANUARY L..,J 04342S9
Table 3Groundwater Monitoring Wells, Constituent Assessment Wells, Extraction Wells and Surface Water Monitoring Points
Modern Landfill, York, PA
WellName
MONITORINGMD112S
MD113D
M0118
M0119
M0 125
M0 133
MO137
M0138
MD201S
MD202D
MO207S
M0208I
M0210S
MO2III
M0212S
MD403
M0431
MO432
MD433
MD50IS
MO5O2D
MD503SR
MO504OR
MD505SH
M05060H
M0563S
MO 5640
MD565S
M0566D
MO569SR
M0570DR
MU101
MU127
MU427
CONSTITUENMO 120
M0122S
MD123I
M012B
M0209D
W23
W34
Northing[feet]
WELLS231.828.21
231 ,829.03
232105.06
231.633.78
229.239.01
231.017.33
231,589.17
231 ,663.95
232,375.99
232.372.56
232.75900
232.762.30
232,717.00
232,67970
232.45720
228.17528
229.16600
228.822 12
228.516.59
230,738.86
230.71959
231.540.37
231.539.99
231.607.94
231.604.79
230.184.14
230.130.72
231.234.87
231.21430
231.72016
231.712.20
228.541.98
228.99270
227.92386
rASSESSMEN231.305.00
230.40992
230.426.63
229.66328
232,75850
230.21094
230.356.44
Easting[feet]
2.323.398.58
2.323.38002
2.325.05572
2.325,140.52
2.325,18813
2.326.266.60
2.325.971.30
2.325.563.78
2.323.24162
2.323,230.80
2,323.715.70
2.323.761.70
2.324.06830
2,324.104.00
2.324,593.30
2.323.663.30
2,322.334.52
2.322.602.48
2.322.902.26
2.322.14204
2.322.14484
2.322,359.58
2.322.373.59
2.322.829 91
2.322.81703
2.322. 17038
2.322.170.12
2.321.996.36
2,322,003.26
2.323,123.84
2.323.110.15
2.325,007.82
2.325.741.87
2,324,505.93
GroundElevation[feet msl]
534.94
535.23
520.20
532.33
L 669-09
573.45
541.96
529.15
,_ 501.90
500.90
501.80
501.41
501.39
501.15
507.61
671 00
592.50
604 10
607.40
517.90
517.60
52043
52052
513.68
514.15
521.20
522.40
50340
50540
49581
495.74
71591658.71
730.20
r WELLS2.325,089.00
2.325.271.05
2,325566.45
2.325.998.01
2.323.80430
2.326.30959
2.326.296.33
56650
61790
617.06
61080
•N/A
561.20
57840
MeasuringPoint
Elevation[feet msl]
537.40
537.31
523.25
534.82
671.46
575.61
544.1 1
53171
505.90
504.73
504I5
50393
50385
503.55
51005
677.58
595.27
606.85
61295
520.64
52053
522.82
52284
51627
516.48
52382
52508
506.35
50831
497.82
49784
718.35
660.74
732.56
568.76
619.73
619.67
612.18
•N/A
58381
57996
WellDepth
[feet bgs]
64.30
1 57.80
73.00
7450
8250
91 10
94.30
70.00
32.25
195.00
5000
100.00
50.00
100.00
50.00
75.00
95.00
95.00
8500
50.00
100.00
5000
10000
50.00
100.00
50.00
100.00
50.00
10000
51.00
101.00
81 50
9920
95.60
7200
6800
179.30
49.00
130.00
7200
70.00
CasingDiameter[Inches]
Depth toTop ofScreen
[feet bgs]
2.0
2.0
2.0
2.0
2.0
2.0
2.0
2.0
2.0
20
2.0
2.0
20
2.0
2.02.0
2.0
2.0
2.0
2.0
2.0
2.0
2.0
2.0
2.0
20
2.0
2.0
2.0
2.0
2.0
20
20
20
31.05
105.80
13.00
6.50
31 50
39.10
51.30
2.40
17.25
180.00
20.00
50.00
20.00
50.00
20.00
45.00
45.00
45.00
50.00
25.00
50.00
30.00
50.00
3000
50.00
25.00
50.00
2500
50.00
31 00
51.00
31.50
3680
4560
20
40
2.0
40
2-0
6.0
6.0
3900
8.00
13250
9.00
100.00
15.00
20.00
Top ofScreen
Elevation[feet msl]
503.89
429.43
507.20
525.83
637.59
534.35
490.66
52675
484.65
320.90
48180
451.41
481.39
451.15
487.61
626.00
547.50
559.10
557.40
492.90
46760
490.43
470.52
483.68
464.15
496.20
472.40
47840
45540
46481
444.74
68441
621-91
684.60
Depth toBase ofScreen
[feet bgs]
64.30
157.80
73.00
74.50
8250
91.10
9430
7000
32.25
195.00
50.00
100.00
5000
100.00
50.00
75.00
95.00
9500
85.00
50.00
100.00
5000
10000
50.00
100.00
50-00
100.00
50.00
100.00
51.00
101.00
81.50
9920
95.60
Base ofScreen
Elevation[feet msl]
470.64
377.43
447.20
457.83
586.59
482.35447.66
459.15
469.65
30590
451.80
401.41
451.39
401 15
457.61
596.00
497.50
50910
522.40
467.90
417.60
470.43
420.52
463.68
414.15
471.20
422.40
453.40
40540
444.81
394.74
634.41
559.51
634.60
527.50
609.90
484.56
601.80• N/A
56620
558.40
72.00
68.00
17930
4900
130.00
72.00
70.00
49450
549.90
437.76
561 80• N/A
509.20
508.40
MidScreen
Elevation[feet mst]
487.27
40343
477.20
49183
61209
508.35
469.16
49295
477.15
313.40
466.80
426.41
46639
426.15
472.61
611.00
522.50
534.10
53990
48040
442.60
480.43
445.52
47368
439.15
48370
447.40
46590
430.40
454.81
41974
659.41
590.71
659.60
511.00
57990
461.16
581.80
•N/A
537.70
53340
ConstructionDate
[mm/ddVyr]
06/19/86
08/18/86
01/23/9108/24/86
09/29/86
09/18/86
09/13/86
08/25/86
12/10/87
01/28/88
07/1 8/90
07/17/90
07/19/90
07/18/90
07/20/90
10/06/88
09/19/94
09/19/94
03/19/96
10/21/94
10/21/94
09/07/99
09/07/99
09/08/99
09/09/99
10/31/94
10/28/94
10/19/94
10/18/94
09/07/99
09/07/99
08/13/86
09/16/86
03/19/93
02/25/87
07/26/85
08/28/8606/23/85
07/16/90
01/28/85
12/20/85
Table Acronyms: txjs • Below ground surface
msi -Mean sea Level
Checked by:Reviewed by: ^M
Colder Associates Pagel of 2
NOVEMBEKTable 3 (continued)
Groundwater Monitoring Wells, Constituent Assessment Wells, Extraction Wells and Surface Water Monitoring PointsModern Landfill, York, PA
WellName
Northing[feet]
Easting[feet]
GroundElevation[feet msl]
MeasuringPoint
Elevation[feet msl]
WellDepth
[feet bgs]
CasingDiameter[Inches]
Depth toTop ofScreen
[feet bgs]
Top ofScreen
Elevation[feet msl]
Depth toBaaeofScreen
[feet bgs]
Base ofScreen
Elevation[feet msl]
MidScreen
Elevation[feet msl]
ConstructionDate
[mm/dd/yr]EXTRACTION WELLSEastern Groundwater Extraction SystemW?1
W35
W36
W37
W38
W39
W40
W41
W43
W44
W45
W60
Enhanced We.ESW-t
ESW-2
ESW-3ESW-4
Western GrouW20W01W03W04W05W07WOflW09W10W11W12W13W62W64W6«W6'J
REW-1
SURFACE WAMS1 11
MS1 12
MS113
MS1 14
MS1 15
MS201
MS202
MS400
MS40I
MPH501
MS502
MS503
MS601
MS602
MSPI10
MTP001
231.49731
230.496 26
230.611 40230.705 68
230.79828
230,894 11
230.984 73
230.15954
231.195.70
231.34862
231 .452 27
231,443 11
fern Ground*231.56830
231.574 10
231.56355
231.57925
ndwater Extrac231.14092229.20097230.19383229.99839229.833 01229,29125229.10933230.349 95230.536 66230.778 14230,979 87230.078 92230.268 92229,165 11231.32478231.49946229,350 68
TER MONITOR232.388 00
231.65500
228,17528
230,181 00
22951553
229.387 00
232.915 20
228.080 70
228.776 60
229.245 00231.76000
231.71000
232.655 00231.90031
2,325,741 37
2.326.26700
2.326.230.37
2.326.19900
2.326.16776
2.326.13805
2.326,11069
2.326.085 93
2.325.975 87
2.325.861 66
J.325,797132,325.024 45
iter Control Sy2.323.461 712.323.477 07
2.323.471 87
2.323.469 64
tion System (D2.323.464 082,324,254302,323,761.872.323.825 482.323.883 202.324.065422,324.388042.323.619002.323.449 962.323.307 402.323.339 572.323.835212.323.694 352.324.297 322,323.455 152.323.463 482.324,059 87
NG POINTS2.325.03000
2.325.651 00
2.323.663 30
2.326.360.00
2.325.97495
2.322.039 302.323.21680
2.323.02910
2.322.076 20
2,325.115002,321.62500
2.321,32000
2.324.16800
2.323.29559
53720
52020
56530
56330
55950
556.80
553.80
5521055030
54450
539 10
551 60
stem531 K
532 18
531 90
531 93
ecomm/ss/one516265922054210545.405533057990596105305052010513105098054610541 8059482511 345142957360
510.00
52880
56000
572.00
62050
53000
48200
58050
54300
6670048900
49000
4955052500
53731574 10
53482
56876
6197361967
671 46
612 18
57561
544 11
531 71
553 13
53436
53463
5348953509
d)603585932554357547 1455425582355983153229522595150651176574.135428059632514345172957660
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
9700
7550
7500
7500
7500
7500
7500
7500
7500
9430
7500as oo
11000
11000
11000
11000
10000435040004800490097005000960050005000470096007500750010000100006550
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
600
600
6.00
600
600
600
6.00
600
600
600
600
600
600
600
600
600
6.00
6006006006006006006006006006.00
600600600600600600
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
1800
1800
11 00
950
1800
19.00
1000
23001800
1850
1800
3220
3000
30.00
3000
3000
1800
235020002800290018.501000
21 50200020.001700
39001900
20001600
20001500
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/
N/
N/
N/
N/
N/
N/
5192050220
55430
55380541 50
53780
54380
529.10
5323052600
521 10
519.40
501 65
502 18
501 90
501 93
4982656870522 1051740524.30561 40586105090050010493 1049280507 10522805748249534494.2955860
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
97.00
7550
75.00
7500
7500
75.00
7500
75.007500
9430
75.00
8500
11000
11000
11000
11000
10000435040004800490097.005000980050005000470098002900750010000100006500
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
44020
444 70
49030
48830
484.50
481 60
47880
477 10
475.30
45020
464 10
46660
421 65
42218
42190
421 93
416.26
54870
502 10
497.40
50430
48290546.104325047010463 1046280448105128051982411 3441429508.60
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
47970
47345
522.30
521 05
51300
50980
511 30
50310
50380
48810
49260
49300
461 65
46218461 90
461 93
457.2655870512105074051430522155661047075485104781047780477605178054732453344542953360
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
02/05/85
33.26100
11/21/85
06/24/85
1 1/27/85
12/16/85
12/18/85
12/19/85
01/02/86
06/24/85
12/31/8501/16/87
36,514.00
36.51000
36.511.00
36,382.00
33.521 0030.742.0030.7430030.841 0030.6440030.8460030.8540030.851 0030.8520030.6480030.8480030.872 0031.6420031.643.0033.5190033,5190035.538 00
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Table Acronvms bgs Beta ground surtace
msl • Mean Sea Level
P V>rjKt.«\2004«M342W Modem S yr HtvwwWeocrM,** 3 *» Golder Associates Page 2 of 2
JANUARY 2005 Our Ref. 043-6299
Table 4Monitoring Frequency and Parameters
Modern Landfill, York PA
SamplingEvent
First Quarter
Second Quarter
Third Quarter
Fourth Quarter
GroundwaterExtraction
Wells
Not Sampled
Not Sampled
Form 19Annual and Quarterly
Parameters
Not Sampled
GroundwaterConstituentAssessment
Wells
Not Sampled
Not Sampled
Form 19Annual and Quarterly
Parameters
Not Sampled
GroundwaterMonitoring
WellsForm 19Quarterly
Parameters
Form 19Quarterly Parameters
Form 19Annual and Quarterly
Parameters
Form 19Quarterly Parameters
SurfaceWater
SamplingPoints
Form 19Quarterly
Parameters
Form 19Quarterly Parameters
Form 19Annual and Quarterly
Parameters
Form 19Quarterly Parameters
Checked by:Reviewed by:
P:\Proiects\2004\043-6299 Modern Landfill 5 yr ReviewVReponATable 4.xls1/5/2005 9:53 AM Golder Associates Page 1 of 1
JANUARY 200$ Our Ref. 043-8299
Table 5PAOEP Form 19 Quarterly Water Quality Analytes
Modern Landfill, York PA
InorganicsAmmonia-Nitrogen
Bicarbonates (as CaCO3)Chemical Oxygen Demand (COD)
ChlorideIron (total)
Magnesium (total)Manganese (total)Nitrate-Nitrogen
pH (field and laboratory)Sodium (total)
Specific Conductance (field and laboratory)Total Organic Carbon (TOG)
Total PhenolicsTurbidity
Orqanics
Benzene1,2-Dibromoethane1,1-Dichloroethane1,1-Dichloroethene1 ,2-Dichloroethane
cis-1 ,2-Dichloroethenetrans-1 ,2-Dichloroethene
Ethyl BenzeneMethytene chlorideTetrachloroethene
Toluene1,1,1-Trichloroethane
TrichloroetheneVinyl Chloride
Xylene
Additional Parameters
Calcium (total and dissolved)Dichlorofluoromethane
Iron (dissolved)Manganese (dissolved)
Sodium (dissolved)Temperature
Checked by: _Reviewed by:_ 3*5
P:\ProKctty2004UX3-6299 Modem Landfill 5 yr Bav«!«\ReecfTiTaOle 5 «>s1/5/2006 9 58 AM Colder Associates Page 1 of 2
JANUARY 2005 Our Ref. 043-6299
Table 5 (continued)PADEP Form 19 Annual Water Quality Analytes
Modern Landfill, York PA
Inorganics
Sulfate
Arsenic (total and dissolved)Barium (total and dissolved)
Cadmium (total and dissolved)Calcium (dissolved)
Chromium (total and dissolved)
Total Alkalinity
Metals
Copper (total and dissolved)Lead (total and dissolved)
Magnesium (total and dissolved)Mercury (total and dissolved)
Potassium (total and dissolved)Selenium (total and dissolved)
Silver (total and dissolved)Zinc (total and dissolved)
Organics
BromoformBromomethane
Carbon TetrachlorideChlorobenzeneChloroethane
DibromochloromethaneMethyl Chloride
3-Chloro-1-propene
1 ,2-Dichlorobenzene1 ,3-Dichlorobenzene1 ,4-Dichlorobenzene
Dichlorodifluoromethanex,y-Dichloropropane
cis-1 ,2-Dichloropropenetrans-1,2-Dichloropropene
Methyl Ethyl Ketone
4-Methyl-2-Pentanone1,1,1 ,2-Tetrachloroethane1 , 1 ,2,2-Tetrachloroethane
1 , 1 ,2-TrichloroethaneTrichlorofluoromethane1 ,2,3-Trichloropropane
Subtitle D Orqanics
AcetoneAcrylonitrile
BromochloromethaneBromodichloromethane
Carbon Disulfide
Antimony (total only)Beryllium (total only)
Chloroform1 ,2-Dibromo-3-Chloropropanetrans-1 ,4-Dichloro-2-Butene
Methyl butyl ketoneMethyl bromide
Subtitle D Metals
Cobalt (total only)Nickel (total only)
Methylene IodideStyrene
Vinyl Acetate
Thallium (total only)Vanadium (total only)
Notes:* Annual list includes all parameters on Quarterly List.
Checked by: _Reviewed by:_
P \Proieca\2004V043-6299 Modern Landfill 5 yr RevievAReporrtTaMe 5 xls1/S/2005 1001 AM Colder Associates Page 2 ol 2
FIGURES
APPENDIX A
RECORD OF DECISION
RECORD OF DECISION MODERN LANDFILL
DECLARATION
SITE NAME AND LOCATION
Modern Landfill Site Windsor and Lower Windsor Townships York County, Pennsylvania.
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for the Modern Landfill Site, also known as theCERCLA Site in the Remedial Investigation, in York County, Pennsylvania. The selected remedial action waschosen in accordance with the Comprehensive Environmental Response, Compensation and Liability Act of1980, as amended by the Superfund Amendments and Reauthorization Act of 1986 (CERCLA); and, to theextent practicable, the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). Thisdecision is based on the Administrative Record for this site.
The Pennsylvania Department of Environmental Resources (PADER), acting on behalf of the Commonwealthof Pennsylvania, has verbally concurred with the selected remedy.
ASSESSMENT OF THE SITE
Pursuant to duly delegated authority, I hereby determine, pursuant to Section 106 of CERCLA, 42 U.S.C.Section 9606, that actual or threatened releases of hazardous substances from this site, as discussed in"Summary of Site Risks", if not addressed by implementing the response action selected in this Record ofDecision (ROD), may present an imminent and substantial endangerment to the public health, welfare, or theenvironment.
DESCRIPTION OF THE REMEDY
Modern Landfill is located in the Townships of Windsor and Lower Windsor, in York County, PA, and isadjacent to Prospect Road approximately one-half mile south of Route 124. The Landfill has been usedcontinually for waste disposal since the early 1940's, and it has principally accepted municipal/residual wastesthroughout its history of operation. Evidence exists, however, that some disposal of hazardous substances hasoccurred at this site, though the exact quantities, the nature of these substances, and the particular locations oftheir disposal are currently unknown to EPA. According to existing records, some of these wastes have beenremoved from the site.
In response to public health concerns, Modern Trash Removal of York, Inc., under a 1987 AdministrativeConsent Order and Agreement with the Pennsylvania Department of Environmental Resources (PADER) ,conducted a Remedial Investigation/Feasibility Study (RI/FS) for this site. Early in the RI process, it wasdetermined that groundwater contamination emanates from the old, unlined portion of the landfill. This unlinedportion, which is currently inactive, is part of what is referred to as the CERCLA site, because it is the subjectof EPA's and PADER's remedial efforts under CERCLA.
The selected remedy for this site addresses the long-term threats present at the Modern Landfill site. Theprincipal components of the selected remedy are as follows:
1. Continued operation and maintenance of all previous remedial actions conducted onsite, including the landfill cap, groundwater extraction system, onsite wastewater treatment facility,gas extraction system (for removal and destruction of landfill generated methane gas) andgroundwater and surface water monitoring.
2. Completion of the landfill cap system and final cover for the unlined 66-acre landfill.
3. Maintenance of site fencing and all access restrictions.
4. The addition of extraction veils to the eastern and western extraction systems to preventcontaminated groundwater from bypassing those systems.
5. The completion of additional monitoring and/or extraction wells as needed to ensureprotectiveness and to control groundwater flow, respectively.
6. As a goal, restore contaminated groundwater to background quality.
STATUTORY DETERMINATION
The selected remedy is protective of human health and the environment, complies with Federal and Staterequirements that are legally applicable; or relevant and appropriate to the remedial action, and is cost-effective.
This remedy utilizes permanent solutions and alternative treatment technologies, to the maximum extentpracticable, and satisfies the statutory preference for remedies that employ treatment that reduces toxicity,mobility, or volume as a principal element.
Because the selected remedy will result in hazardous substances remaining onsite above health-based levels, areview under Section 121(c) of CERCLA, 42 U.S.C. 9621(c) will be conducted within five years after thecommencement of remedial action to ensure that the remedy continues to provide adequate protection of humanhealth and the environment.
RECORD OF DECISIONMODERN LANDFILL SITE
DECISION SUMMARY
A. SITE NAME, LOCATION, AND DESCRIPTION
GENERAL
MODERN LANDFILL IS LOCATED IN THE TOWNSHIPS OF WINDSOR AND LOWERWINDSOR, IN YORK COUNTY, PA. IT IS APPROXIMATELY ADJACENT TO PROSPECT ROAD,ONE-HALF MILE SOUTH OF ROUTE 124. THE MODERN LANDFILL SITE, ALSO REFERRED TO ASTHE CERCLA SITE IN THE REMEDIAL INVESTIGATION/FEASIBILITY STUDY (RI/FS), CONSISTSOF THE ORIGINAL 66-ACRE UNLINED LANDFILL TOGETHER WITH ALL OTHER PROPERTY THATAS A WHOLE IS BOUNDED ON THE EAST AND WEST BY THE RESPECTIVE GROUNDWATEREXTRACTION AND MONITORING SYSTEMS, ON THE NORTH BY THE 17-ACRE, DOUBLE-LINEDLANDFILL EXPANSION, AND ON THE NORTH BY THE SOUTHERN EXTENSION OF BOTHMONITORING AND EXTRACTION SYSTEMS. THE MODERN LANDFILL SITE IS ONLY APORTION OF WHAT IS REFERRED TO IN THE RI/FS AS MODERN LANDFILL. THE LANDFILL HASBEEN USED CONTINUOUSLY FOR WASTE DISPOSAL SINCE THE EARLY 1940'S, AND IT HASPRINCIPALLY ACCEPTED MUNICIPAL/RESIDUAL WASTES THROUGHOUT ITS HISTORY OFOPERATION. THE SITE IS SHOWN ON MAPS IN FIGURES 1 AND 2.
MODERN LANDFILL IS AN ACTIVE LANDFILL PERMITTED BY THE PENNSYLVANIADEPARTMENT OF ENVIRONMENTAL RESOURCES (PADER) TO ACCEPT MUNICIPAL WASTE ANDA NUMBER OF NON-HAZARDOUS INDUSTRIAL WASTE STREAMS. IT INCLUDES AN INACTIVE,UNLINED 66-ACRE AREA AND AN ACTIVE, SYNTHETIC HDPE DOUBLE-LINED AREA. THEORIGINAL 66-ACRE UNLINED LANDFILL IS LOCATED ON LAND OWNED BY HORACE HEINDELAND IS OPERATED BY MODERN TRASH REMOVAL OF YORK, INC., (MODERN) UNDER TERMSOF A LEASE AGREEMENT. MODERN OWNS ADDITIONAL PROPERTY CONTIGUOUS TO THELEASEHOLD.
MODERN LANDFILL CONTAINS SEVERAL COMPONENTS INCLUDING:
• THE ORIGINAL 66-ACRE UNLINED LANDFILL;• AN EXISTING, PADER-APPROVED, CONTIGUOUS 17-ACRE DOUBLE-LINED
LANDFILL AREA;• BORROW AREAS FOR DAILY, INTERMEDIATE, AND FINAL COVER;• A PROPOSED, CONTIGUOUS NORTHERN HORIZONTAL EXPANSION AREA;• A PROPOSED, NONCONTIGUOUS SOUTHWEST EXPANSION AREA;• EASTERN AND WESTERN PERIMETER GROUNDWATER EXTRACTION SYSTEMS
AND WESTERN GROUNDWATER INTERCEPTOR TRENCH;• A WASTEWATER TREATMENT PLANT;• A LANDFILL GAS-EXTRACTION SYSTEM;• EROSION AND SEDIMENTATION CONTROL SYSTEMS; AND• A LOW-PERMEABILITY FINAL COVER SYSTEM.
TO ENSURE CONSISTENCY WITH THE REMEDIAL INVESTIGATION/FEASIBILITY STUDY(RI/FS), THROUGHOUT THIS RECORD OF DECISION THE FOLLOWING DEFINITIONS WILL BEUSED TO DESCRIBE THE VARIOUS AREAS OF THE MODERN LANDFILL SITE:
1
• THE CERCLA SITE: THIS AREA INCLUDES THE UNLINED 66-ACRE LANDFILL ANDALL MODERN LANDFILL PROPERTY (LEASED BY MODERN FROM HORACEHEINDEL) UP TO AND INCLUDING THE MONITORING WELLS JUST WITHIN THEEASTERN AND WESTERN EDGES OF THE EXTRACTION SYSTEM, AS WELL ASLAND OWNED BY MODERN. THE BOUNDARIES OF THE CERCLA SITE ARE SHOWNIN FIGURE 3.
• THE PROPERTY: THIS AREA INCLUDES ALL MODERN LANDFILL PROPERTY(OWNED AND LEASED) EXCLUSIVE OF THE CERCLA SITE.
• OFF THE PROPERTY: THIS AREA INCLUDES LOCAL AREAS BEYOND THE CERCLASITE AND THE PROPERTY.
THE FACILITY IS LOCATED WITHIN THE CONESTOGA VALLEY SECTION OF THEPIEDMONT PHYSIOGRAPHIC PROVINCE. TOPOGRAPHICALLY, THIS PROVINCE ISCHARACTERIZED BY WELL-DEVELOPED NORTHEAST-SOUTHWEST TRENDING VALLEYS AND DRAINAGE PATTERNS. THE LANDFILL IS LOCATED ON A HILL BOUNDED ON THE NORTH,EAST, AND WEST BY STREAMS (UNNAMED TRIBUTARIES TO KREUTZ CREEK).
APPROXIMATELY 800 PEOPLE LIVE WITHIN A ONE-MILE RADIUS OF MODERNLANDFILL, WHILE ABOUT 3,100 PEOPLE LIVE WITHIN A THREE-MILE RADIUS OF THE SITE. LAND USAGE IN THE AREA IS PRIMARILY FARMING AND RESIDENTIAL. AWAY FROM THEIMMEDIATE VICINITY OF THE MODERN LANDFILL THE LAND IS USED PREDOMINATELY FORARABLE FARMING WITH SOME PASTURE LAND EXISTING. SEVERAL WOODLAND AREAS ANDSMALL APPLE ORCHARDS ARE ALSO LOCATED IN THE AREA.
THE NEAREST CITY TO THE MODERN LANDFILL IS YORK, PENNSYLVANIA, LOCATEDABOUT 8 MILES TO THE WEST, WITH OTHER COMMUNITIES LOCATED WITHIN A DISTANCE OF4 TO 6 MILES FROM THE SITE.
CLIMATE
THE CLIMATE OF THE AREA IS RELATIVELY MILD AND HUMID. THE AVERAGEPRECIPITATION OBSERVED AT THE YORK, PENNSYLVANIA, METEOROLOGICAL STATION IS 41INCHES PER YEAR. AVERAGE SNOWFALL IS ABOUT 30 INCHES PER YEAR, WHICH ISEQUIVALENT TO ABOUT 2.5 INCHES OF RAINFALL. MEAN WINTER TEMPERATURE IS 34DEGREES F AND THE MEAN SUMMER TEMPERATURE IS 76 DEGREES F, WITH TEMPERATUREEXTREMES ABOVE 95 DEGREES F AND BELOW 0 DEGREES F NOT UNCOMMON.
SURFACE WATER HYDROLOGY
THE DRAINAGE PATTERNS EVIDENT IN THIS AREA OF YORK COUNTY VARY BETWEENTRELLIS AND DENDRITIC WITH A TENDENCY TOWARDS NORTH-SOUTH ANDNORTHEAST-SOUTHWEST TRENDING VALLEYS. THESE DRAINAGE PATTERNS ARE CONSIDERED TO REFLECT THE UNDERLYING GEOLOGIC STRUCTURE. THE LANDFILL SITE ISBOUNDED ON THE EAST, NORTH, AND WEST BY TWO TRIBUTARIES WHICH ARE REFERRED TOAS THE EASTERN AND WESTERN TRIBUTARIES. THE TRIBUTARIES ARE FED BY SPRINGS ANDRUNOFF, AND FLOW EFFECTIVELY NORTHWARD AND DISCHARGE INTO KREUTZ CREEK,WHICH THEN FLOWS NORTHWARDS AND THEN EASTWARD, 11 MILES, INTO THE
2
SUSQUEHANNA RIVER. KREUTZ CREEK DOES NOT SUPPLY WATER TO ANY DOWNSTREAMINHABITANTS OR MUNICIPALITIES.
REGIONAL GEOLOGY
MODERN LANDFILL IS LOCATED IN THE CONESTOGA VALLEY SECTION IN THENORTHERN PART OF THE PIEDMONT PROVINCE. THE PIEDMONT PROVINCE IS A BROADPLATEAU SLOPING GENTLY EASTWARD FROM THE BLUE RIDGE PROVINCE TO THE COASTALPLAINS. IT IS UNDERLAIN BY METAMORPHIC OR PLUTONIC ROCKS, AND CUT BY SEDIMENTFILLED BASINS OF JURASSIC AGE. THE PIEDMONT PROVINCE IS THE EASTERN EXTREME OFTHE FIVE TECTONIC PROVINCES WHICH COMPOSE THE APPALACHIAN MOUNTAIN CHAIN. THE MAIN REGIONAL STRUCTURE IN THE AREA IS A PRE-METAMORPHIC THRUST FAULTWHICH FORMS THE BOUNDARY BETWEEN PRECAMBRIAN METAVOLCANICS AND SCHISTSAND CAMBRIAN META-SEDIMENTS. THIS FAULT, KNOWN AS THE MARTIC LINE, IS LOCALLYA WELL DEFINED PRE-METAMORPHIC THRUST FAULT WITH PRECAMBRIAN WISSAHICKONSCHIST OVERLYING ORDOVICIAN CONESTOGA LIMESTONE. IN THE AREA TO THE SOUTH OFMODERN LANDFILL, THE MARTIC LINE IS POORLY DEFINED AS IT DIVIDES THE CAMBRIANPHYLLITE FROM THE PRECAMBRIAN/CAMBRIAN SCHISTS, TWO VERY SIMILAR ROCK TYPES. THIS INFORMATION SUGGESTS THAT MUCH OF THE CLASSIC WORK DONE IN LANCASTERCOUNTY MAY NOT BE AN ANALOG FOR THE GEOLOGIC SETTING IN THE VICINITY OFMODERN LANDFILL.
B. SITE HISTORY AND ENFORCEMENT ACTIVITIES
HISTORY
PRIOR TO THE COMMENCEMENT OF THE REMEDIAL INVESTIGATION/FEASIBILITYSTUDY, MODERN LANDFILL AND THE AREA AROUND THE MODERN LANDFILL HAD ALREADYBEEN THE SUBJECT OF SEVERAL GEOLOGIC STUDIES. THE FIRST STUDY RELATING TOREMEDIAL ACTIVITIES AT MODERN LANDFILL WAS CONDUCTED IN 1975. AT THAT TIME, THEINVESTIGATIONS CENTERED ON THE FEASIBILITY OF UTILIZING SHALLOW PUMPING WELLSAS A PRIMARY LEACHATE RECOVERY SYSTEM FOR MODERN LANDFILL AND CONCLUDEDTHAT LEACHATE FROM THE 66-ACRE UNLINED LANDFILL COULD BE EFFECTIVELYCOLLECTED IN THIS MANNER.
BETWEEN JANUARY AND MAY, 1981, PADER COLLECTED GROUNDWATER SAMPLESFROM WELLS AND SPRINGS IN THE VICINITY OF MODERN LANDFILL AND DETECTEDVOLATILE ORGANIC CHEMICALS IN SOME OF THESE SAMPLES. THE EPA REGION III FIELDINSPECTION TEAM (FIT) CONTRACTOR THEN CONDUCTED A PRELIMINARY ASSESSMENT ANDSITE INVESTIGATION (PA/SI) IN 1982. THE PA/SI REPORT RECOMMENDED THE FOLLOWINGACTIONS BE TAKEN:
• PERIODIC SAMPLING OF NEARBY RESIDENTIAL WELLS;• SAMPLING OF GROUNDWATER AND SURFACE WATER BEING USED BY AREA
FARMS FOR LIVESTOCK AND IRRIGATION;• DETERMINING THE EFFECTIVENESS OF THE LEACHATE COLLECTION SYSTEM;• INVESTIGATING REACTIVATION OF THE ONSITE WASTEWATER TREATMENT
FACILITY; AND,• INVESTIGATING POSSIBLE ACTIONS TO MITIGATE THE GROUNDWATER
PROBLEM.3
ADDITIONAL STUDIES WERE CONDUCTED BASED ON THESE RECOMMENDATIONS.
A HYDROGEOLOGIC STUDY OF THE LANDFILL WAS CONDUCTED IN 1982 ANDINVOLVED THE INSTALLATION OF TWO MONITORING WELLS AND THE EXTENSION OF TWOEXISTING MONITORING WELLS. SURFACE WATER, MONITORING WELLS, AND RESIDENTIALDRINKING WELLS WERE SAMPLED.
IN 1983 THE EFFECTIVENESS OF THE WESTERN INTERCEPTOR TRENCH WASEVALUATED AND IT WAS DETERMINED THAT THE INTERCEPTOR TRENCH SHOULD BEMODIFIED AND UPGRADED. QUARTERLY SAMPLING OF MONITORING WELLS BEGAN IN AUGUST 1983.
AN INVESTIGATION OF LEACHATE COLLECTION ALTERNATIVES IN THE WESTERNPERIMETER REGION WAS CONDUCTED IN 1984. GEOLOGIC DATA WAS REVIEWED, WELLSWERE INSTALLED AND SAMPLED, AND THE NEED FOR ADDITIONAL WORK WAS DETERMINED. A SERIES OF BORINGS WERE COMPLETED, EXISTING PERIMETER WELLS WERESAMPLED, AND 11 INTERCEPTOR WELLS WERE INSTALLED. AN EXISTING WATER SUPPLYWELL WAS ACTIVATED AS AN EXTRACTION WELL. IN JUNE, 1984, THE 66-ACRE UNLINEDLANDFILL WAS SCORED IN ACCORDANCE WITH THE HAZARD RANKING SYSTEM FORPOSSIBLE INCLUSION ON THE NATIONAL PRIORITIES LIST (NPL) UNDER CERCLA. THEUNLINED LANDFILL RECEIVED A SCORE OF 36, BASED ON POTENTIAL FOR EXPOSURE TOCONTAMINATED GROUNDWATER. THE MODERN LANDFILL SITE WAS PROPOSED FORINCLUSION ON THE NPL IN OCTOBER 1984.
A FOLLOW-UP STUDY IN 1985 WAS CONDUCTED TO INVESTIGATE LEACHATEINTERCEPTION ALTERNATIVES IN THE NORTHERN AND EASTERN PERIMETERS OF THECERCLA SITE. ORGANIC CONTAMINANTS WERE FOUND AT THE EASTERN, BUT NOT THENORTHERN, BORDER OF THE CERCLA SITE. AS A RESULT OF THIS INVESTIGATION, 13EXTRACTION WELLS WERE INSTALLED ALONG THE EASTERN PERIMETER.
THE MODERN LANDFILL SITE WAS OFFICIALLY LISTED ON THE NPL IN JUNE, 1986.
PREVIOUS ACTIONS
THE ORIGINAL 66-ACRE LANDFILL HAD NO ACTIVE METHOD OF LEACHATE CONTROL.THE AREA IS NOW EQUIPPED WITH GROUNDWATER INTERCEPTOR AND COLLECTIONSYSTEMS TO CONTROL THE MIGRATION OF LEACHATE CONSTITUENTS FROM THE UNLINEDLANDFILL.
AS OF DECEMBER, 1990, APPROXIMATELY 64 ACRES OF THE 66-ACRE UNLINEDLANDFILL ARE PRESENTLY COVERED WITH A PADER APPROVED, LOW-PERMEABILITY CAP. THE ENTIRE 66-ACRE UNLINED LANDFILL IS SCHEDULED TO RECEIVE A PADER APPROVEDLOW-PERMEABILITY FINAL COVER SYSTEM. THIRTY-SIX ACRES ARE ALREADY AT FINALELEVATIONS AND ARE CURRENTLY BEING CAPPED. WHEN FINAL ELEVATIONS AREREACHED, THE 66-ACRE LANDFILL WILL HAVE A 20-ACRE PLATEAU AREA AND A 46-ACRESIDE SLOPE AREA. THE SYNTHETIC GEOMEMBRANE FINAL COVER SYSTEM PROPOSED FORTHE 20-ACRE PLATEAU AREA AND THE 46-ACRE CLAY SIDE SLOPE CAP AREA ARE DESIGNEDTO REDUCE INFILTRATION OF PRECIPITATION AND THEREBY REDUCE THE QUANTITY OFLEACHATE GENERATED BY THE LANDFILL.
4
LEACHATE SEEPS AND THE PRESENCE OF LEACHATE CONSTITUENTS IN THEGROUNDWATER WERE NOTICED IN THE PAST ON THE WEST SIDE OF THE CERCLA SITE AND,AS A RESULT, A GROUNDWATER INTERCEPTOR TRENCH AND LAGOON TREATMENT SYSTEMWERE CONSTRUCTED IN 1977. THE GROUNDWATER INTERCEPTOR TRENCH IS BETWEEN 6AND 15 FEET BELOW GROUND AND IS APPROXIMATELY 2,200 FEET LONG. SEEPAGE WATERCOLLECTED BY THIS TRENCH IS PUMPED TO AN ONSITE TREATMENT FACILITY.
IN JANUARY 1985, A NETWORK OF 12 GROUNDWATER EXTRACTION WELLS, DESIGNEDTO AUGMENT THE WESTERN GROUNDWATER INTERCEPTOR TRENCH, BECAMEOPERATIONAL. IN 1987 TWO ADDITIONAL WELLS WERE ADDED TO THE SYSTEM AND A 14THWELL BECAME OPERATIONAL IN JANUARY 1990. WATER PUMPED FROM THESE WELLS ISTREATED AT THE ONSITE TREATMENT FACILITY.
A GROUNDWATER EXTRACTION SYSTEM SIMILAR TO THAT INSTALLED ON THEWESTERN SIDE OF THE LANDFILL WAS CONSTRUCTED ON THE EASTERN PERIMETER ANDBECAME OPERATIONAL IN NOVEMBER 1986. WATER PUMPED FROM THIS EXTRACTIONSYSTEM IS ALSO TREATED AT THE ONSITE TREATMENT FACILITY.
MODERN OPERATED FOUR SURFACE IMPOUNDMENTS TO TREAT GROUNDWATER ANDLEACHATE COLLECTED BY THE INTERCEPTOR AND EXTRACTION WELLS ALONG THEWESTERN PERIMETER OF THE CERCLA SITE. TREATMENT CONSISTED OF METALS PRECIPITATION, AERATION, AND CLARIFICATION. THESE SURFACE IMPOUNDMENTS WERELINED WITH 6 TO 12 INCHES OF SOIL CEMENT AND AN ASPHALT COATING. THESEIMPOUNDMENTS WERE CLEAN-CLOSED IN MAY 1987 UNDER A PADER-APPROVED CLOSUREPLAN.
IN APRIL, 1987, A REPLACEMENT TREATMENT FACILITY FOR THE SURFACEIMPOUNDMENTS BECAME OPERATIONAL. THE REPLACEMENT FACILITY ACCEPTS FLOWFROM THE EASTERN AND WESTERN GROUNDWATER EXTRACTION WELL SYSTEMS, THE WESTERN INTERCEPTOR TRENCH, AND LEACHATE FROM THE EXISTING DOUBLE-LINEDLANDFILL AND SLOPE CAP AREA. THIS FACILITY HAS A DESIGN CAPACITY OF 500,000GALLONS PER DAY AND INCLUDES PHYSICAL/CHEMICAL AND BIOLOGICAL TREATMENTSYSTEMS. THE PHYSICAL/CHEMICAL PORTION INCLUDES METALS PRECIPITATION,FILTRATION, AND AIR-STRIPPING. THE BIOLOGICAL TREATMENT PORTION WAS ADDED TOENABLE TREATMENT OF LEACHATE COLLECTED IN THE RECENTLY CONSTRUCTEDDOUBLE-LINED LANDFILL CELLS.
PERMITS AND PADER CONSENT ORDERS
MODERN LANDFILL AND THE ASSOCIATED EXTRACTION AND TREATMENT SYSTEMSOPERATE IN ACCORDANCE WITH SEVERAL PERMITS AND CONSENT ORDERS ISSUED BYPADER. EACH OF THESE IS BRIEFLY DESCRIBED BELOW.
MODERN LANDFILL IS PERMITTED BY PADER UNDER SOLID WASTE PERMIT NO. 100113ISSUED ON AUGUST 17, 1978, TO ACCEPT MUNICIPAL WASTE AND A NUMBER OFNON-HAZARDOUS INDUSTRIAL (RESIDUAL) WASTE STREAMS. THE ORIGINAL 66-ACREUNLINED LANDFILL DOES NOT ACCEPT WASTE AND IS BEING CAPPED. THE ACTIVEDOUBLE-LINED LANDFILL AND VERTICAL EXPANSION AREA ARE OPERATED PURSUANT TO APERMIT MODIFICATION ISSUED BY PADER ON DECEMBER 12, 1986. THE GAS EXTRACTION
5
SYSTEM IS ALSO COVERED BY THIS SOLID WASTE PERMIT.
MODERN OPERATED FOUR SURFACE IMPOUNDMENTS FROM SEPTEMBER 1976 TO APRIL1987 TO TREAT LEACHATE SEEPAGE COLLECTED BY AN INTERCEPTOR TRENCH ANDEXTRACTION WELLS ALONG THE WESTERN PERIMETER OF THE LANDFILL UNDER A PADERWATER QUALITY MANAGEMENT PERMIT NO. 6786201 ISSUED ON SEPTEMBER 24, 1976.
ON NOVEMBER 20, 1986, PADER ISSUED NPDES PERMIT NO. PA0046680 THAT PERMITTEDCONSTRUCTION OF A TEMPORARY TREATMENT PLANT TO TREAT GROUNDWATER FROM THEEASTERN GROUNDWATER EXTRACTION WELLS; CONTINUED OPERATION OF THEIMPOUNDMENT TREATMENT SYSTEM FOR THE WESTERN EXTRACTION WELLS ANDINTERCEPTOR TRENCH; AND CONSTRUCTION OF A NEW TREATMENT PLANT CONSISTING OFPHYSICAL/CHEMICAL AND BIOLOGICAL TREATMENT. THE TEMPORARY TREATMENT PLANTAND FOUR SURFACE IMPOUNDMENTS WERE DECOMMISSIONED BY JUNE 1987 INACCORDANCE WITH A MAY 27, 1987 AGREEMENT WITH PADER.
THE PHYSICAL/CHEMICAL PORTION OF THE NEW TREATMENT PLANT INCLUDES AN AIRSTRIPPER, PERMITTED UNDER PADER AIR QUALITY CONTROL PERMIT NO. 67-330-004, TOREMOVE VOLATILE COMPOUNDS FROM THE EXTRACTED GROUNDWATER AND LEACHATE.
CERCLA ENFORCEMENT ACTIVITIES
MODERN ENTERED INTO A SEPTEMBER 20, 1984 CONSENT ORDER AND AGREEMENTWITH PADER TO CORRECT CONDITIONS AT MODERN LANDFILL, MOST NOTABLY, LEACHATEFROM THE 66-ACRE UNLINED LANDFILL CONTAMINATING THE GROUNDWATER ANDSURFACE WATER. THIS CONSENT ORDER AND AGREEMENT WAS SUPERSEDED BY ACONSENT AGREEMENT AND ORDER DATED DECEMBER 3, 1986. IN ACCORDANCE WITH THESEORDERS AND AGREEMENTS, MODERN UNDERTOOK SEVERAL REMEDIAL ACTIONS,INCLUDING CONSTRUCTION OF GROUNDWATER EXTRACTION SYSTEMS AND AWASTEWATER TREATMENT PLANT.
THE RI/FS FOR THE MODERN LANDFILL SITE WAS CONDUCTED PURSUANT TO ACONSENT ORDER AND AGREEMENT ENTERED INTO BY MODERN AND PADER ON NOVEMBER4, 1987.
POTENTIALLY RESPONSIBLE PARTY (PRP) SEARCHES FOR THE MODERN LANDFILL SITEHAVE BEEN CONDUCTED IN THE PAST AND ARE CONTINUING AT THE PRESENT TIME. TWOPRPS HAVE BEEN IDENTIFIED AND HAVE BEEN ISSUED GENERAL NOTICE LETTERS. SEVERALOTHER PARTIES HAVE BEEN ISSUED REQUESTS FOR INFORMATION UNDER SECTION 104(E) OFCERCLA.
C. HIGHLIGHTS OF COMMUNITY PARTICIPATION
THERE HAS BEEN MODERATE COMMUNITY INTEREST IN THE MODERN LANDFILL SITEDUE TO ITS PROXIMITY TO AND ITS IMPACT ON THE GROUNDWATER OF NEARBYRESIDENCES.
IN ACCORDANCE WITH SECTIONS 113 AND 117 OF CERCLA, 42 USC SECTIONS 9613 AND9617, EPA HELD A PUBLIC COMMENT PERIOD FROM APRIL 16, 1991 THROUGH JUNE 15, 1991 FOR
6
THE PROPOSED REMEDY AT THE MODERN LANDFILL SITE. A PUBLIC MEETING ON THEPROPOSED REMEDY FOR THIS SITE WAS HELD ON MAY 7, 1991 AT THE EASTERN HIGHSCHOOL, YORK COUNTY , PA. WITH RESPECT TO THE REMEDY PROPOSED BY EPA FOR THISSITE, HOWEVER, LITTLE COMMUNITY INTEREST EXISTS.
SOME CONCERN WAS EXPRESSED BY THOSE IN ATTENDANCE AT THE MEETING THATNOT ALL CITIZENS INTERESTED IN THE SITE MAY HAVE BEEN AWARE OF THE MEETING, ANDBOTH AN EXTENSION TO THE COMMENT PERIOD AND A SECOND PUBLIC MEETING WEREREQUESTED. IN LIEU OF THE PUBLIC MEETING, EPA PREPARED A FACT SHEET ON THEPROPOSED ACTION AT THE SITE AND DIRECTLY MAILED THE FACT SHEET TO SEVERALHUNDRED POTENTIALLY INTERESTED RESIDENCES. EPA ALSO OFFERED TO MEETINFORMALLY WITH LOCAL OFFICIALS AND/OR REPRESENTATIVES OF ANY CITIZENS GROUPSIF REQUESTED. NO SUCH MEETING REQUESTS WERE RECEIVED. IN RESPONSE TO REQUESTSMADE AT THE MAY 7, 1991 MEETING, HOWEVER, THE PUBLIC COMMENT PERIOD WASEXTENDED TO JUNE 15, 1991.
D. SCOPE AND ROLE OF THE RESPONSE ACTION
THE ONLY CONCERN PRESENTING SIGNIFICANT RISK TO NECESSITATE REMEDIATIONAT THE CERCLA SITE IS THE PRESENCE OF VOLATILE ORGANIC CONTAMINANTS IN THELEACHATE FROM THE 66-ACRE UNLINED LANDFILL. THERE IS NO PRINCIPAL THREAT ATMODERN LANDFILL. PREVIOUS SITE INVESTIGATIONS HAVE DETECTED VOLATILE ORGANICCOMPOUNDS AND SOME INORGANIC CONSTITUENTS IN THE GROUNDWATER AND SURFACEWATER ON THE CERCLA SITE AS WELL AS IN SOME ON-PROPERTY RESIDENTIAL DRINKINGWATER WELLS; HOWEVER, THESE RESIDENCES ARE NO LONGER IN EXISTENCE.
GROUNDWATER BENEATH THE CERCLA SITE EXCEEDED FEDERAL AND STATEDRINKING WATER STANDARDS FOR THE FOLLOWING CHEMICALS: BENZENE, CARBONTETRACHLORIDE, 1,2-DICHLOROETHENE, 1,1-DICHLOROETHENE, TRICHLOROETHENE, ANDVINYL CHLORIDE. THE PRESENCE OF THESE CHEMICALS INDICATES THAT AN EXCESSLIFETIME CANCER RISK (ELCR) FOR THE POTENTIAL INGESTION OF WATER FROM BENEATHTHE CERCLA SITE IS GREATER THAN THE ACCEPTABLE EPA RISK LIMITS. THE CURRENTRESPONSE ACTION WILL REDUCE OR ELIMINATE THE LOW LEVEL THREAT POSED BY THECONTAMINATED GROUNDWATER BENEATH THE CERCLA SITE.
E. SUMMARY OF SITE CHARACTERISTICS
DISPOSAL HISTORY
THE DISPOSAL HISTORY OF MODERN LANDFILL IS BASED ON A REVIEW OFCORRESPONDENCE BETWEEN REGULATORY AGENCIES AND MODERN AND ITS INDUSTRIALCUSTOMERS. ALSO INVESTIGATED WERE COMPLAINTS, PERMITS, SITE INSPECTIONS, ANDOTHER DOCUMENTS RELATED TO THE SITE. MODERN LANDFILL USERS WERE IDENTIFIEDFROM GATE RECEIPTS, BUT THOSE RECEIPTS DID NOT PROVIDE INFORMATION AS TO WASTETYPE OR COMPOSITION. DATA CURRENTLY AVAILABLE PROVIDE ONLY PARTIALINFORMATION ON THE MODERN DISPOSAL HISTORY AND IN MOST CASES WASTE QUANTITIESAND LOCATIONS IN THE 66-ACRE UNLINED LANDFILL ARE NOT CURRENTLY KNOWN TO EPA.
7
IN ADDITION TO COMMERCIAL AND RESIDENTIAL REFUSE, MODERN LANDFILL WASPERMITTED TO ACCEPT AND DID ACCEPT SEVERAL INDUSTRIAL WASTE STREAMS DURINGTHE OPERATING HISTORY OF THE 66-ACRE UNLINED LANDFILL. INFORMATION ON THESEWASTES, TO THE EXTENT KNOWN IS GIVEN BELOW.
SODIUM MOLYBDATE WASTE. APPROXIMATELY 15 TO 20 TONS PER YEAR OF ANINORGANIC RESIDUE FROM SODIUM MOLYBDATE PRODUCTION WERE DISPOSED OF ATMODERN LANDFILL FOR AN UNDETERMINED NUMBER OF YEARS STARTING PRIOR TO1972. THE WASTE WAS REPORTED TO HAVE BEEN COMPOSED OF THE FOLLOWING:MOLYBDENUM TRIOXIDE, SULFUR, CUPRIC OXIDE, FERRIC OXIDE, SILICON DIOXIDE,AND WATER.
PESTICIDE WASTE. PESTICIDE WASTES FROM AN UNSPECIFIED SOURCE WEREDISPOSED OF AT MODERN LANDFILL IN THE SUMMER OF 1972.
RARE EARTH CHLORIDES. IN 1973, PADER APPROVED IN PRINCIPLE THEENCAPSULATION OF RARE EARTH WASTES IN CRUSHED LIMESTONE IN THE 66-ACREUNLINED LANDFILL. ABOUT 1,000 CUBIC YARDS OF RARE EARTH CHLORIDES CONTAINING THORIUM AND URANIUM AND 500 CUBIC YARDS OF CERIUM FLUORIDEWERE DISPOSED OF AT MODERN LANDFILL BETWEEN 1975 AND 1979. THE EXACTCOMPOSITION OF THE WASTES IS UNKNOWN. ALTHOUGH SOME TRACES OF THESE ELEMENTAL SPECIES WERE FOUND IN GROUNDWATER AND SOILS DURING THEREMEDIAL INVESTIGATION (AND THEIR ANALYSIS SUBSEQUENTLY CARRIEDTHROUGH THE RISK ASSESSMENT), NO EVIDENCE OF RISK FROM THESE WASTES HASBEEN DETERMINED AT THE SITE.
PAPER MANUFACTURING SLUDGE. A SLUDGE FROM PAPER MANUFACTURING WASDISPOSED OF AT MODERN LANDFILL DURING 1975 THROUGH 1981. THE WASTE WASREPORTED TO CONTAIN 60 PERCENT INORGANIC MATERIAL AND 40 PERCENT ORGANICMATERIAL. THE WASTE APPARENTLY HAD A LOW PH AND CONTAINED HEAVYMETALS. MODERN WAS EVENTUALLY ORDERED TO CEASE ACCEPTANCE OF THISWASTE BY PADER.
POLYCHLORINATED BIPHENYLS (PCBS). AN ESTIMATED 20 TO 70 DRUMS OF PCBWASTES WERE DISPOSED OF AT MODERN LANDFILL IN THE MID-1970'S. IN SEPTEMBERAND OCTOBER 1985, THESE DRUMS AND 400 CUBIC YARDS OF CONTAMINATED SOILWERE EXCAVATED AND TRANSPORTED OFFSITE FOR DISPOSAL.
ETHYLENE DIAMINE. ON DECEMBER 13, 1980, A ROLLOFF CONTAINER WASUNLOADED AT MODERN LANDFILL. A LIQUID LEAKING FROM THE CONTAINER WASANALYZED AND DETERMINED TO CONTAIN ETHYLENE DIAMINE. THERE IS NO CLEAR EVIDENCE THAT THIS WASTE WAS ULTIMATELY DISPOSED OF AT MODERN LANDFILL.
OILY WASTES. DURING A PADER INSPECTION OF MODERN LANDFILL ON MARCH 10,1982, ABOUT 40 CUBIC YARDS OF MIXED RESIDUAL AND MUNICIPAL WASTES WEREUNLOADED AT THE FACILITY. ABOUT ONE FOURTH OF THE WASTE MIXTURE WASSATURATED WITH A PETROLEUM LIQUID. THE EXACT NATURE OF THE WASTE WASAPPARENTLY NEVER DETERMINED.
8
PAINT WASTE. PAINT WASTE WAS DISPOSED OF AT MODERN LANDFILL ACCORDINGTO A PADER INSPECTION IN APRIL, 1984. PADER ORDERED THE GENERATOR TO CEASESENDING THIS WASTE TO FACILITIES NOT PERMITTED TO ACCEPT SUCH WASTES. THECHARACTERISTICS AND COMPOSITION OF THE WASTE AND THE QUANTITY DISPOSEDARE NOT KNOWN.
A SET OF CHEMICALS OF POTENTIAL CONCERN AT THE SITE HAS BEEN SELECTED FORDETAILED EVALUATION IN THE RISK ASSESSMENT AND ARE SHOWN IN TABLE 1,SUMMARIZED BY ENVIRONMENTAL MEDIA.
GEOLOGIC AND HYDROGEOLOGIC CONDITIONS
THE SURFACE AND SUBSURFACE INVESTIGATION DETERMINED THAT A SYNFORMUNDERLIES MODERN LANDFILL AND THAT THE PRESENCE OF A SYNFORM STRUCTUREUNDER MODERN LANDFILL IS CONSISTENT WITH THE REGIONAL GEOLOGY MAPPED IN THERI/FS REPORT.
THE HYDRAULIC CONDUCTIVITY OF THE GEOLOGIC FORMATIONS AT MODERNLANDFILL DECREASE WITH DEPTH AND CAN BE RELATED TO THE PRESENCE OR ABSENCE OFLINEATIONS, WHICH ARE INTERPRETED TO BE MAIN FRACTURE SETS. WITHIN THE ROCKMATERIALS, THE PHYLLITE EXHIBITS A STRONG ANISOTROPY, WHILE THE HYDRAULICCONDUCTIVITY OF THE META-SANDSTONE APPEARS TO BE RELATIVELY ISOTROPIC. THEDOLOSTONE ZONE EXHIBITS A HETEROGENEOUS DISTRIBUTION OF HYDRAULICCONDUCTIVITY VALUES, WHICH ARE PROBABLY RELATED TO FRACTURE SYSTEMSTRENDING EAST-WEST THROUGH THE ZONE. MOST GEOLOGIC CONTACTS SHOW HIGHERHYDRAULIC CONDUCTIVITY VALUES THAN THE ADJACENT ROCK MASS.
GROUNDWATER FLOWS TOWARDS THE EASTERN AND WESTERN EXTRACTIONSYSTEMS WITH THE POSSIBLE EXCEPTION OF THE GROUNDWATER FLOWING FROM BENEATHTHE NORTH-CENTRAL AREA OF THE 66-ACRE UNLINED LANDFILL, WHICH MAY BE BYPASSING THE WESTERN EXTRACTION SYSTEM. THIS FLOW POSSIBLY BYPASSING THEEXTRACTION SYSTEM PASSES THROUGH VINTAGE DOLOSTONE, WHICH HASCHARACTERISTIC EAST-WEST ZONES OF HIGH HYDRAULIC CONDUCTIVITY ALTERNATINGWITH ZONES OF LOW HYDRAULIC CONDUCTIVITY.
IT IS CONSERVATIVELY ESTIMATED THAT THE TRAVEL TIME OF LEACHATEPERCOLATING FROM THE CENTRAL SECTION OF THE 66-ACRE UNLINED LANDFILL ANDMOVING TO THE WESTERN EXTRACTION SYSTEM IS 2 YEARS, WHILE THE TRAVEL TIME TOTHE EASTERN EXTRACTION SYSTEM IS 3.5 YEARS UNDER NON-PUMPING CONDITIONS.
THE GROUNDWATER EXTRACTION SYSTEMS AT MODERN LANDFILL HAVE LOWEREDTHE GROUNDWATER SURFACE ELEVATION ALONG BOTH THE EASTERN AND WESTERNEXTRACTION SYSTEMS. THESE DRAWDOWN TROUGHS CAUSE GROUNDWATER TO FLOW TOWARD THE EXTRACTION WELLS, EFFECTIVELY CAPTURING THE MAJORITY OFCONTAMINATED GROUNDWATER. THIS DRAWDOWN HAS ALSO SUBSTANTIALLY REDUCEDSTREAM FLOWS IN BOTH THE EASTERN AND WESTERN TRIBUTARIES OF KREUTZ CREEK.
ORGANIC CONTAMINANT CONCENTRATIONS IN WELLS AT OR INSIDE THE EXTRACTIONSYSTEMS HAVE GENERALLY FOLLOWED A BELL-SHAPED CURVE SINCE STARTUP OF THE
9
GROUNDWATER EXTRACTION SYSTEMS. CONCENTRATIONS ROSE AFTER STARTUP OF THEEXTRACTION SYSTEM AS CONTAMINATED GROUNDWATER WAS PULLED TO THE WELLS,THEN FELL, USUALLY BELOW THEIR INITIAL LEVELS. THIS TREND IS CONSISTENT AMONGWELLS IN ALL AREAS OF MODERN LANDFILL, INDICATING THAT THE CHANGES ARE DUE TOTHE EXTRACTION SYSTEM, RATHER THAN TO CHANGES IN THE CONTAMINANT SOURCE.
WELLS OUTSIDE THE EXTRACTION SYSTEM GENERALLY HAVE EITHER CONTINUED TOSHOW NO CONTAMINATION OR CONTAMINANT CONCENTRATIONS HAVE DECREASED SINCESTARTUP OF THE EXTRACTION SYSTEM.
SEDIMENT, SURFACE WATER, AND AIR QUALITY
MODERN LANDFILL IS LOCATED IN THE DRAINAGE CATCHMENT AREA FOR KREUTZCREEK AND IS BOUNDED ON THE EAST AND WEST BY TWO UNNAMED TRIBUTARIES WHICHARE FED BY SPRINGS AND RUNOFF. BACKGROUND DATA WERE UNAVAILABLE FORCOMPARISON WITH THE MODERN LANDFILL SEDIMENT DATA BECAUSE THE EASTERN ANDWESTERN TRIBUTARIES ORIGINATE ON MODERN LANDFILL PROPERTY; HOWEVER, ASDISCUSSED LATER, RISKS FROM LOW LEVELS OF COMPOUNDS IN SEDIMENTS WERE WITHINRANGES GENERALLY CONSIDERED ACCEPTABLE BY EPA.
DURING THE REMEDIAL INVESTIGATION, SURFACE WATER SAMPLES WERECOLLECTED FROM THE EASTERN AND WESTERN TRIBUTARIES, THE SEDIMENTATION PONDS,AND THE WASTEWATER TREATMENT PLANT OUTFALL. NO ORGANIC CHEMICALS AND 15INORGANIC CHEMICALS WERE DETECTED IN THE SURFACE WATER. BECAUSE THETRIBUTARIES ORIGINATE ON THE MODERN LANDFILL PROPERTY, NO BACKGROUNDSURFACE WATER DATA ARE AVAILABLE AND SAMPLES COULD NOT BE COMPARED TOBACKGROUND LEVELS.
AIR SAMPLES WERE ANALYZED FOR TOTAL VOLATILE ORGANIC COMPOUNDS.VOLATILIZATION OF ORGANIC COMPOUNDS AND FUGITIVE DUST GENERATIONS ARE THEMAIN RELEASE MECHANISMS INTO AIR AT MODERN LANDFILL. THE OPERATING METHANEGAS MONITORING, EXTRACTION, AND FLARE SYSTEM, WHICH CONSISTS OF GASEXTRACTION WELLS AND GAS COLLECTION TRENCHES AROUND THE SOUTHERN, EASTERN,AND WESTERN PERIMETERS OF MODERN LANDFILL, MINIMIZES THE POTENTIAL FOR AIRRELEASES TO THE AMBIENT AIR FORM THE CERCLA SITE. THE WASTEWATER TREATMENTPLANT INCLUDES AN AIR STRIPPER TO REMOVE VOLATILE COMPOUNDS DURINGTREATMENT OF WATER FROM THE INTERCEPTOR TRENCH AND EXTRACTED GROUNDWATERFROM THE EXTRACTION SYSTEMS.
DURING AIR MONITORING OF THE SITE, ONLY TRACE LEVELS OF ORGANIC VAPORSAND NO RADIATION ABOVE SITE SPECIFIC BACKGROUND WERE DETECTED IN THE AMBIENTAIR. THE 66-ACRE UNLINED LANDFILL HAS BEEN COVERED WITH SOIL OR SYNTHETIC CAPSAND THEREFORE NO POTENTIAL FOR FUGITIVE DUST EMISSION EXISTS FROM THIS AREA.
10
TIbU I-ecu*
I . I . l-ir1ehlorfl««v»««
l.Z-<KcMoro«thm (total)
bwztn*bli<2-«etrbon titrccftiorida
ehlorofoni4 ich lorof tM
mthyltn* chl«rldi
totaltrtntrldilorMtlWM
nickelvaMdtiai
ratflta 121thorlta £MurMliai
• ft
F. SUMMARY OF SITE RISKS
HUMAN HEALTH RISKS
THE 66-ACRE UNLINED LANDFILL HAS RECEIVED A PADER-APPROVED CLOSURE COVERWHICH IS BEING UPGRADED WITH A LOW PERMEABILITY CAP. IN SOME PORTIONS ABOVETHE 66-ACRE UNLINED LANDFILL, A SYNTHETIC LINER HAS ALSO BEEN INSTALLED. AS ARESULT OF THESE CONDITIONS, THERE IS NO POTENTIAL FOR FUGITIVE DUST EMISSIONSFROM POTENTIAL CONTAMINANT SOURCE AREAS IN THE 66-ACRE UNLINED LANDFILL.
THE 66-ACRE-UNLINED LANDFILL, COVERED AND CAPPED, IS NOT A SOURCE OFDIRECT CONTACT EXPOSURE. BASED ON THIS CONSIDERATION, COMBINED WITH THE LACKOF INFORMATION ON THE EXACT LOCATIONS OF POTENTIAL CONTAMINANT SOURCE AREASAND THE FACT THAT CAPPING THE 66-ACRE UNLINED LANDFILL HAS REDUCED THEACCESSIBILITY TO SUCH SOURCE AREAS, IT WAS DETERMINED THAT SUBSURFACE SOLIDSSAMPLING WITHIN THE 66-ACRE UNLINED LANDFILL ITSELF WOULD NOT BE FEASIBLE ORNECESSARY. CONTINUED OPERATION OF THE EXTRACTION SYSTEM WILL STEADILYDEPLETE CONCENTRATIONS FROM POTENTIAL SOURCE AREAS WITHIN THE 66-ACREUNLINED LANDFILL. FOR THE REASONS SUMMARIZED ABOVE, EVALUATION OF POTENTIALEXPOSURE PATHWAYS RELATED TO AMBIENT AIR AND TO POSSIBLE SOURCE AREAS IN THECERCLA SITE WAS NOT NECESSARY FOR THIS ASSESSMENT.
BASED ON SAMPLING RESULTS AND A REVIEW OF THE SUMMARIZED DATA,CHEMICALS IDENTIFIED AS POTENTIALLY SITE-RELATED WERE SELECTED FOR FURTHEREVALUATION IN THE RISK ASSESSMENT. THE CRITERIA FOR SELECTION INCLUDEDPRESENCE IN ENVIRONMENTAL MEDIA AT CONCENTRATIONS ABOVE BACKGROUND AND/ORBLANK CONCENTRATIONS AND THEIR RELATIONSHIP TO PAST DISPOSAL PRACTICES AT THESITE.
SAMPLE CONCENTRATIONS OF INORGANIC CHEMICALS WERE COMPARED WITH THOSELEVELS CONSIDERED TO BE NATURALLY OCCURRING IN THE SITE REGION; IF THE DETECTEDLEVELS WERE ELEVATED ABOVE BACKGROUND, THE CHEMICAL WAS CONSIDERED FORFURTHER EVALUATION IN THE ASSESSMENT. SITE-SPECIFIC BACKGROUND SEDIMENT ORSURFACE WATER SAMPLES COULD NOT BE COLLECTED DURING THE RI SINCE THE EASTERNAND WESTERN TRIBUTARIES ORIGINATE ON THE PROPERTY. A COMPARISON OF MODERNLANDFILL SITE SEDIMENT RESULTS WITH AVAILABLE REGIONAL SOIL BACKGROUNDVALUES WAS MADE. SEDIMENT CONCENTRATIONS WHICH WERE WITHIN THESEBACKGROUND RANGES WERE CONSIDERED TO BE PRESENT AT NATURALLY OCCURRINGLEVELS AND WERE NOT FURTHER EVALUATED. AVAILABLE REGIONAL BACKGROUND DATAOF INORGANIC CHEMICALS IN SOIL THROUGHOUT THE STATE AND FROM THREE LOCATIONSWITHIN 50 MILES OF THE MODERN LANDFILL WERE USED IN THE EVALUATION.
AS A FINAL SCREEN TO SELECT CHEMICALS OF POTENTIAL CONCERN, ORGANICCHEMICALS WHICH WERE DETECTED INFREQUENTLY IN THE SAMPLES COLLECTED FROM ASPECIFIC MEDIUM, AND WERE DETECTED AT CONSISTENTLY LOW CONCENTRATIONS IN ASAMPLED ENVIRONMENTAL MEDIUM, AND ARE NOT KNOWN TO BE ASSOCIATED WITH PASTDISPOSAL PRACTICES, WERE NOT CONSIDERED TO BE CHEMICALS OF POTENTIAL CONCERN. PRIOR TO REMOVING CHEMICALS FROM FURTHER EVALUATION BASED ON THESECONSIDERATIONS, EXCEPT FOR THOSE CHEMICALS THAT ARE PRESENT AT OR BELOW
11
NATURALLY OCCURRING BACKGROUND LEVELS, THEIR APPLICABLE OR RELEVANT ANDAPPROPRIATE REQUIREMENTS OR TOXICITY CRITERIA WERE CHECKED TO ENSURE THATCHEMICALS THAT MAY BE TOXIC EVEN AT VERY LOW DOSES WERE NOT REMOVED.
BASED ON A REVIEW OF THE MODERN LANDFILL RI/FS DATA, A SET OF CHEMICALS OFPOTENTIAL CONCERN HAS BEEN SELECTED FOR DETAILED EVALUATION IN THE RISKASSESSMENT. THESE CHEMICALS ARE SUMMARIZED BY ENVIRONMENTAL MEDIA IN TABLE1.
FOR RISK ASSESSMENT PURPOSES, INDIVIDUAL POLLUTANTS WERE SEPARATED INTOTWO CATEGORIES OF CHEMICAL TOXICITY DEPENDING ON WHETHER THEY EXHIBITNONCARCINOGENIC OR CARCINOGENIC EFFECTS. THIS DISTINCTION RELATES TO THECURRENTLY HELD SCIENTIFIC OPINION THAT THE MECHANISM OF ACTION FOR EACHCATEGORY IS DIFFERENT. EPA HAS ADOPTED, FOR THE PURPOSE OF ASSESSING RISKSASSOCIATED WITH POTENTIAL CARCINOGENS, THE SCIENTIFIC POSITION THAT A SMALLNUMBER OF MOLECULAR EVENTS CAN CAUSE CHANGES IN A SINGLE CELL OR A SMALLNUMBER OF CELLS THAT CAN LEAD TO TUMOR FORMATION. THIS IS DESCRIBED AS ANO-THRESHOLD MECHANISM, SINCE THERE IS ESSENTIALLY NO LEVEL OF EXPOSURE TO ACARCINOGEN WHICH WILL NOT RESULT IN SOME FINITE POSSIBILITY OF CAUSING THEDISEASE. IN THE CASE OF CHEMICALS EXHIBITING NONCARCINOGENIC EFFECTS, HOWEVER,IT IS BELIEVED THAT ORGANISMS HAVE PROTECTIVE MECHANISMS THAT MUST BEOVERCOME BEFORE THE TOXIC ENDPOINT IS MANIFESTED. THIS THRESHOLD VIEW HOLDSTHAT A RANGE OF EXPOSURES FROM JUST ABOVE ZERO TO SOME FINITE VALUE CAN BETOLERATED BY THE ORGANISM WITHOUT APPRECIABLE RISK OF CAUSING CANCER. SOMECHEMICALS CAN EXHIBIT BOTH CARCINOGENIC AND NONCARCINOGENIC EFFECTS.
HEALTH CRITERIA FOR CHEMICALS EXHIBITING NONCARCINOGENIC EFFECTS AREGENERALLY DEVELOPED USING REFERENCE DOSES (RFDS). THE RFD, EXPRESSED IN UNITSOF MG/KG/DAY, IS AN ESTIMATE OF THE DAILY EXPOSURE TO THE HUMAN POPULATIONTHAT IS LIKELY TO BE WITHOUT AN APPRECIABLE RISK OF DELETERIOUS EFFECTS DURING ALIFETIME. THE RFD PROVIDES A BENCHMARK TO WHICH CHEMICAL INTAKES BY OTHERROUTES MAY BE COMPARED. POTENTIAL CONCERN FOR NONCARCINOGENIC EFFECTS OF ASINGLE CONTAMINANT IN A SINGLE MEDIUM IS EXPRESSED AS THE HAZARD QUOTIENT (HQ)(OR, THE RATIO OF ESTIMATED INTAKE DERIVED FROM THE CONTAMINANTCONCENTRATION IN A GIVEN MEDIUM TO THE CONTAMINANT'S REFERENCE DOSE). THE HQIS ALSO REFERRED TO AS THE DOSE/RFD RATIO. BY ADDING THE HQS FOR ALLCONTAMINANTS WITHIN A MEDIUM OR ACROSS ALL MEDIA TO WHICH A GIVEN POPULATIONMAY REASONABLY BE EXPOSED, THE HAZARD INDEX (HI) CAN BE GENERATED. THE HIPROVIDES A USEFUL REFERENCE POINT FOR GAUGING THE POTENTIAL SIGNIFICANCE OFMULTIPLE CONTAMINANT EXPOSURES WITHIN A SINGLE MEDIUM OR ACROSS MEDIA.
HUMAN CARCINOGENIC RISK IS EVALUATED BY DETERMINING THE EXCESS LIFETIMECANCER RISKS (ELCRS) FOR ACTUAL OR POTENTIAL EXPOSURES. ELCRS ARE DETERMINEDBY MULTIPLYING A CONTAMINANT'S EXPOSURE DOSE BY THE CANCER POTENCY FACTOR(CPF). CPFS ARE EXPRESSED IN UNITS OF (MG/KG/DAY)-1 AND DESCRIBE AN UPPER BOUNDESTIMATE OF THE RELATIVE CARCINOGENIC POTENCY OF A TOXICANT.
THESE CALCULATED RISKS ARE PROBABILITIES THAT ARE GENERALLY EXPRESSED INSCIENTIFIC NOTATION. AN ELCR OF 1 X (10-6) INDICATES THAT, AS A REASONABLE UPPER
12
BOUND, AN INDIVIDUAL HAS A ONE-IN-ONE MILLION CHANCE OF DEVELOPING CANCER AS ARESULT OF SITE-RELATED EXPOSURE TO A CARCINOGEN OVER A 70 YEAR LIFETIME UNDERTHE SPECIFIC EXPOSURE CONDITIONS AT A SITE.
DATA SHOWING HEALTH EFFECTS CRITERIA AND OTHER IMPORTANT RISK RELATEDINFORMATION USED IN DETERMINING THE RISKS ASSOCIATED WITH THIS SITE ARECONTAINED IN THE TABLES IN APPENDIX A TO THIS RECORD OF DECISION.
THE FOLLOWING RISK SUMMARY IS PRESENTED FOR THIS RECORD OF DECISION:
IN THE RISK ASSESSMENT, A SET OF CHEMICALS OF POTENTIAL CONCERN WERESELECTED FOR DETAILED EVALUATION BASED ON THE RI SAMPLING RESULTS. CHEMICALSWERE SELECTED SEPARATELY FOR THREE ENVIRONMENTAL MEDIA: GROUNDWATER,SURFACE WATER, AND SEDIMENTS. A TOTAL OF 26 ORGANIC CHEMICALS, 11 INORGANICCHEMICALS, AND FOUR RADIONUCLIDES WERE SELECTED FOR THE RISK ASSESSMENT. THERISK ASSESSMENT THEN EVALUATED THE POTENTIAL HUMAN HEALTH RISKS ASSOCIATEDWITH EXPOSURE TO THOSE CHEMICALS OF CONCERN.
TO EVALUATE POTENTIAL HUMAN HEALTH RISKS, SEVERAL EXPOSURE PATHWAYSWERE SELECTED FOR DETAILED EVALUATION UNDER BOTH CURRENT AND POSSIBLEFUTURE SITE USE CONDITIONS. AN EXPOSURE PATHWAY, DEFINED AS A SOURCE ANDMECHANISM OF CHEMICAL RELEASE, AN ENVIRONMENTAL TRANSPORT MEDIUM, A POINT OFPOTENTIAL EXPOSURE, AND A ROUTE OF EXPOSURE, IS CONSIDERED "COMPLETE" IS ALL OFTHESE ELEMENTS ARE PRESENT. IF AN EXPOSURE PATHWAY WAS CONSIDERED COMPLETE,THEN THE POTENTIAL RISK WAS QUANTITATIVELY CALCULATED.
IN ADDITION TO THE ABOVE CONDITIONS, TWO SCENARIOS WERE CONSIDEREDDURING THE RISK ASSESSMENT: A NO-ACTION AND A NO-FURTHER-ACTION ALTERNATIVE. THE NO-ACTION ALTERNATIVE REFLECTS THE SITE AS IT WOULD BE WITHOUT THECURRENT GROUNDWATER EXTRACTION AND TREATMENT SYSTEM OPERATING. THENO-FURTHER-ACTION ALTERNATIVE CORRESPONDS TO THE CURRENT CONDITION OF THEMODERN LANDFILL CERCLA SITE WITH THE EXTRACTION AND TREATMENT SYSTEMSOPERATING. THE ASSESSMENT OF THESE TWO ALTERNATIVES ENABLES A DETERMINATIONTO BE MADE OF WHETHER FURTHER REMEDIAL ACTION IS REQUIRED FOR MODERNLANDFILL.
FOR THE NO-ACTION AND NO-FURTHER-ACTION ALTERNATIVES UNDER BOTH FUTUREAND CURRENT SITE USE CONDITIONS, THE PATHWAYS FOR DIRECT CONTACT WITH SURFACEWATERS AND SEDIMENTS ON THE CERCLA SITE WAS NOT COMPLETE BECAUSE NOSEDIMENTS OR SURFACE WATERS EXIST ON THE CERCLA SITE. NO QUANTITATIVEEVALUATION WAS CONDUCTED FOR THESE PATHWAYS.
THE PATHWAYS FOR DIRECT CONTACT WITH SURFACE WATERS AND SEDIMENTS, FORTHE NO-ACTION AND NO-FURTHER-ACTION ALTERNATIVES OFF THE PROPERTY UNDERCURRENT SITE USE CONDITIONS IS COMPLETE; HOWEVER, BECAUSE OFF PROPERTY RI DATAFOR SEDIMENTS AND SURFACE WATER ARE NOT AVAILABLE, NO QUANTITATIVEEVALUATION WAS CONDUCTED.
13
FOR BOTH FUTURE AND CURRENT SITE USE CONDITIONS UNDER THENO-FURTHER-ACTION ALTERNATIVE, SURFACE WATER FLOWS ON THE PROPERTY AREINTERMITTENT, AND SURFACE WATER CONTACT IS MINIMAL. FOR THIS REASON, NO QUANTITATIVE EVALUATION OF THIS PATHWAY WAS CONDUCTED.
FOR CURRENT SITE USE UNDER THE NO-FURTHER-ACTION ALTERNATIVE, NOGROUNDWATER PATHWAY WAS FOUND TO EXIST BECAUSE NO RECEPTORS ARE CURRENTLYLOCATED ON THE CERCLA SITE, ON THE PROPERTY, OR OFF THE PROPERTY. NO CURRENTGROUNDWATER RECEPTORS EXIST AS NO RESIDENCES CURRENTLY EXIST ON THE CERCLASITE. THE EASTERN AND WESTERN TRIBUTARIES FORM A DISCHARGE FOR THE AQUIFERSAND THEREFORE ON-PROPERTY AND OFF-PROPERTY RESIDENTIAL WELLS, WHICH ARELOCATED BEYOND THE TRIBUTARIES WOULD NOT BE EXPECTED TO CONTAIN SITE-RELATEDLEACHATE CONSTITUENTS. RESIDENTS NORTH, NORTHEAST, AND NORTHWEST OF THECERCLA SITE HAVE BEEN HOOKED UP TO THE MUNICIPAL WATER SYSTEM.
FOR FUTURE SITE USE UNDER THE NO-ACTION ALTERNATIVE, THE GROUNDWATERPATHWAY WAS FOUND TO BE COMPLETE FOR RECEPTORS ON THE PROPERTY. AVAILABLEDATA, HOWEVER, WERE INSUFFICIENT TO QUANTITATIVELY EVALUATE THIS PATHWAY.
FOR EACH COMPLETE EXPOSURE PATHWAY, POTENTIAL RISKS TO HUMAN HEALTHWERE QUANTITATIVELY ESTIMATED. THE RESULTS OF THE RISK ASSESSMENT ARESUMMARIZED IN TABLE 2 AND ARE DISCUSSED BELOW.
• CURRENT LAND USE CONDITIONS-POTENTIAL FOR NONCARCINOGENICEFFECTS. NO-ACTION AND NO-FURTHER ACTION ALTERNATIVES. THEHAZARD INDEX VALUES ASSOCIATED WITH INCIDENTAL AND INFREQUENTDIRECT CONTACT WITH SEDIMENTS IN THE EASTERN AND WESTERNTRIBUTARIES WERE LESS THAN ONE FOR BOTH THE AVERAGE AND MAXIMUMREASONABLE CASES. THE HAZARD INDEX VALUES ASSOCIATED WITHINCIDENTAL AND INFREQUENT DIRECT CONTACT WITH SURFACE WATER IN THEEASTERN AND WESTERN TRIBUTARIES WERE LESS THAN ONE FOR THENO-ACTION ALTERNATIVE. DIRECT SURFACE WATER CONTACT FOR THE NO-FURTHER-ACTION ALTERNATIVE WAS NOT QUANTITATIVELY EVALUATED. ADVERSE NONCARCINOGENIC EFFECTS WOULD NOT OCCUR UNDER THEEXPOSURE SCENARIOS EVALUATED.
• FUTURE LAND USE CONDITIONS: EXCESS LIFETIME CANCER RISKS. SEDIMENT AND SURFACE WATER CONTACT PATHWAYS WERE NOT EVALUATEDSEPARATELY UNDER FUTURE LAND USE CONDITIONS BECAUSE THE PRESENTSITE USE SCENARIOS ADDRESSING THESE PATHWAYS OF EXPOSURE ARECONSIDERED TO BE REPRESENTATIVE OF POSSIBLE FUTURE SITE USE EXPOSURECONDITIONS.
SEVERAL GROUNDWATER INGESTION PATHWAYS WERE, HOWEVER, EVALUATEDUNDER POTENTIAL FUTURE CERCLA SITE AND SURROUNDING LAND USECONDITIONS. THESE INCLUDED INGESTION OF GROUNDWATER ON THE CERCLASITE, ON THE MODERN LANDFILL PROPERTY, AND OFF THE MODERN LANDFILLPROPERTY. WITH THE EXCEPTION OF ON THE PROPERTY RISKS FOR THENO-ACTION ALTERNATIVE, EACH PATHWAY WAS EVALUATED FOR BOTH THENO-ACTION AND NO-FURTHER-ACTION ALTERNATIVES.
14
Tab!* 2
Qt •OTINTtAl NUUO MCAlTN IIU (STIMUI HJt MGDCM(HO-ACTtCaj *MO •Q-rua.Titl-ACTia AirttMTlVtS)
Ijieaaa ufatiaaj Cwcor
'louaibia »
(i) carcin«aani« 191
CJM»»«r»aa »t*i
c»«a c«»a
Curront I, ana Uia Canditiana
Ha-Action AUtrrtattva (0)Oira«t SooJiaant Contact
uottarn TributaryE«*torn Tributary
0tract lurfaca watar Contactwaatam Tributary(aatarn Tributary
Futura Land uta Condition
I no. aat I an af Craunduatar (a)On tfM CIIOA Slta
•a-Actian Altamatlv*
Action Aitarnatlw
On tM Praawrty*• Action Altarnat1««
Action Altamotlv*
Zt-0*21-99
»C•C
if-OI lu2C-09 M
MCMC
• 1 •*
31-09 M-fll
vC. 1.1-001.1.1-OCA. CC14
ve. i.i-oei.1.1-OCA. CC14
ecu2-«C|.
ect*.
Inouff lalont data avoilaMo ta avoluat*.
Of» ««••-Action Altormttv*
A«ttan
H-0»
»-«7
71 -0*
11*0*
(a)
(b)
(e)
(a)
<l)
ilKty tftaf an <natTIM tarvat cancar r
Irdlviduoi aacaa* llfatlav cancar riafe raoraaanta tfta> aoaMtlanati cancar avar a TQ-yaar Ufatlojo ao. a raault af uaajaura canal 11 ana awatuataal.
by Va ta tvaluata StavrfvraJ tltao la froa 11-M to ll-OA.Tha Naaartf indaa InOlcatao lAatftor ar nat aapaauraa) ta c*«na»aa af nancaralnaoonla ckaailcaU avy roawithaaltM affacti. A Haiaro inatam laoa> t»an ana I nat cat aa mat aafrarta) HUVMI Kaatt* affaata ara v««i<uiyliitao* diaalcala «r» tJMaa) «ilt» aaaooaj llfotloa eancar rlaaa af i|-0e or araatar far caralnaojana ana tratloo af am ar araotar for naraaja CM* conrilllano.Tfio raoutta far tHaaa •acftMay* or* oloo canal oar aal ra«rao«ntat<va) of tM na fwrtkar aat I on ottarnotl««turfaca Motor ana) laaJlaant omiurlivj eita *ara cat I act aO <«l(a tM oatraatlan ayatoa «oai aaaratlnf.far vvtotUo cJtaoricalo piaaom In ue Mtajr. ojotonttoi rlao* fraaj tnHoU>a/vvtatllao ralaaocaj Inco Ito taroaj aa tAaaa
af tM . _Moftlnaa) rlak for 1.1-«tt. TN, tajaft. araJ la2Zi Ii araator nan 1I>«. Aavraalaataiyhalf af tM total calouUtoot OMOM cancar riafc la frao) raalanuallaaa). •felon aaour nacwroily.
af tM ovajrooaj>«ee rlake Nr (He InoHvloluol OoaJaaH dot act aa) la aojMk to ar traotar tMn 10-4;tM laMlnaa] Haft for tM, talM. anf teSf la oroetor OMM H-««,
to «c«\^.naa« •'» ai:i«e
tinea a*»r ono) laaHaont oonltarlnf OBta MOT* callactari <«l(a »• oatraatlan ayato* «OM ooaratlncAcailcaia otaaom In ue Mtajr. ojotonttoi rlaM fraa trAai/W vvtatllao roiaoooe Ince
thaaa aaaaalotaal nidi 41 root frajootlaw. •'aiariao laao rtaka far tte Irajlvtatel cAoaloato oatactag la aeuai t« ar iraatar tHan 1rlafc for 1.1-tC*. TW1 taZM, ana) la2Zi Ii oraator nan 1I>«. ioaraalaataiy
M • aat aaaMlcoM* I•C • aat caiouiatae
CHOHCM, isnrnaTiomitl.t-oet • t,1-«HafelaraotMnos 1,1-fXl • 1.1-a)lotilorootAonoi CCU •(ratal); trawl,a-OO • tram>l,2-artafttara«fMnaj TOl • trfaaHeftlarloa; 1.4-OO • 1,4-«HoHliroMnioni»' "' raeiui a»; laZZi • raaHiai Otf U • uronlwj* 1.J-4O • 1,1-41
aurfaoo) wear aaktMt carat
totraalilorienVC • vinyl
l«ta t««oa«a.
NO-ACTION ALTERNATIVE. THE POTENTIAL EXCESS LIFETIME CANCER RISKSFOR GROUNDWATER INGESTION ON THE CERCLA SITE ARE 3 X (10-5) FOR THEAVERAGE CASE AND 8 X (10-3) FOR THE MAXIMUM REASONABLE CASE. THECHEMICALS WITH ESTIMATED CANCER RISKS GREATER THAN (10-6) FOR THEAVERAGE CASE INCLUDED VINYL CHLORIDE, 1,1-DICHLOROETHANE,1,1-DICHLOROETHENE, AND CARBON TETRACHLORIDE.
THE CONCENTRATIONS MEASURED IN WELLS ON THE CERCLA SITE ASSUMED TOBE UNAFFECTED BY THE EXTRACTION SYSTEM WERE ALSO USED TO PROVIDE AVERY CONSERVATIVE INDICATION OF POTENTIAL ON PROPERTYCONCENTRATIONS UNDER THE NO-ACTION ALTERNATIVE. THUS THE RISKSPRESENTED FOR INGESTION OF GROUNDWATER ON THE CERCLA SITE PROVIDEAN UPPER BOUND INDICATION OF POTENTIAL FUTURE RISKS ON THE PROPERTYUNDER THE NO-ACTION ALTERNATIVE.
FOR POTENTIAL GROUNDWATER INGESTION OFF THE PROPERTY, THEESTIMATED EXCESS LIFETIME CANCER RISKS FOR THE NO-ACTIONALTERNATIVE WERE 2 X (10-7) FOR THE AVERAGE CASE AND 1 X (10-6) FOR THEMAXIMUM REASONABLE CASE, WHICH ARE AT OR BELOW THE LOW END OFEPA'S TARGET CANCER RISK RANGE.
NO-FURTHER-ACTION ALTERNATIVE. THE POTENTIAL EXCESS LIFETIMECANCER RISKS FOR GROUNDWATER INGESTION ON THE CERCLA SITE UNDERTHE NO-FURTHER-ACTION ALTERNATIVE WERE THE SAME AS THE RISKS FORGROUNDWATER INGESTION ON THE CERCLA SITE UNDER THE NO-ACTIONALTERNATIVE BECAUSE THE SAME SET OF GROUNDWATER DATA WERE USEDFOR BOTH ALTERNATIVES.
FOR GROUNDWATER INGESTION ON THE PROPERTY FOR THENO-FURTHER-ACTION ALTERNATIVE, THE TOTAL CANCER RISK ESTIMATESWERE 2 X (10-6) FOR THE AVERAGE CASE AND 2 X (10-5) FOR THE MAXIMUMREASONABLE CASE. NO INDIVIDUAL CHEMICAL EXCEEDED THE (10-6) EXCESSCANCER RISK FOR THE AVERAGE CASE. THE RISKS ESTIMATED FOR FUTUREGROUNDWATER INGESTION ON THE PROPERTY ARE LIKELY TO BEOVERESTIMATED SINCE REDUCTIONS IN CHEMICAL CONCENTRATIONS DUE TOCONTINUED OPERATION OF THE EXTRACTION SYSTEM AND NATURALPROCESSES WERE NOT ASSUMED TO OCCUR.
FOR POTENTIAL GROUNDWATER INGESTION OFF THE PROPERTY UNDER THENO-FURTHER-ACTION ALTERNATIVE, THE ESTIMATED CANCER RISKS WERE 2 X(10-7) FOR THE AVERAGE CASE AND 1 X (10-6) FOR THE MAXIMUM REASONABLE CASE.
• FUTURE LAND USE CONDITIONS: POTENTIAL FOR NONCARCINOGENICEFFECTS. NO-ACTION ALTERNATIVE. ADVERSE NONCARCINOGENIC EFFECTSWOULD NOT BE EXPECTED TO OCCUR UNDER THE AVERAGE CASE BUT COULDOCCUR UNDER THE MAXIMUM REASONABLE CASE SCENARIO AS A RESULT OFDAILY INGESTION OF GROUNDWATER ON THE CERCLA SITE IN THE FUTUREUNDER THE NO-ACTION ALTERNATIVE. THIS WOULD RESULT FROM DAILY
15
EXPOSURES FOR 70 YEARS TO THE CURRENTLY MEASURED MAXIMUMDETECTED CONCENTRATIONS OF 1,2-DICHLOROETHENE,TRANS-1,2-DICHLOROETHENE, CARBON TETRACHLORIDE, AND TRICHLOROETHENE IN GROUNDWATER. IT IS LIKELY THAT THE HAZARD INDEXVALUES ARE OVERESTIMATES SINCE THIS SCENARIO ASSUMES THAT CURRENTGROUNDWATER CONCENTRATIONS WILL PERSIST FOR AT LEAST 30 TO 100YEARS IN THE FUTURE EVEN THOUGH CONCENTRATIONS WILL LIKELYDECREASE OVER TIME.
THE DATA FROM THE CERCLA SITE ALSO PROVIDE AN UPPER-BOUND ESTIMATEOF THE POTENTIAL FOR NONCARCINOGENIC EFFECTS TO OCCUR DUE TO THEDAILY INGESTION OF GROUNDWATER ON THE PROPERTY FOR FUTURE SITE USECONDITIONS UNDER THE NO-ACTION ALTERNATIVE.
POTENTIAL USE OF GROUNDWATER OFF THE PROPERTY IN THE FUTURE, UNDERTHE NO-ACTION ALTERNATIVE, IS NOT EXPECTED TO RESULT IN ADVERSENONCARCINOGENIC EFFECTS AS THE HAZARD INDEX VALUES ARE LESS THANTHE THRESHOLD LEVEL OF ONE.
NO-FURTHER-ACTION ALTERNATIVE. SINCE THE DATA FROM THE CERCLASITE WERE USED TO EVALUATE BOTH NO-ACTION AND NO-FURTHER ACTIONSALTERNATIVES, THE POTENTIAL FOR NONCARCINOGENIC EFFECTS TO OCCURDUE TO THE INGESTION OF GROUNDWATER ON THE CERCLA SITE IN THEFUTURE UNDER THE NO-FURTHER-ACTION ALTERNATIVE IS THE SAME AS THEPOTENTIAL FOR NONCARCINOGENIC EFFECTS TO OCCUR UNDER THE NO-ACTIONALTERNATIVE.
POTENTIAL USE OF GROUNDWATER ON THE PROPERTY AND OFF THE PROPERTYIN THE FUTURE, UNDER THE NO-FURTHER-ACTION ALTERNATIVE, IS NOTEXPECTED TO RESULT IN ADVERSE NONCARCINOGENIC EFFECTS AS THEHAZARD INDEX VALUES ARE LESS THAN THE THRESHOLD LEVEL OF ONE.
BASED ON THE EXCESS LIFETIME CANCER RISK FROM THE POTENTIAL INGESTION OFGROUNDWATER ON THE CERCLA SITE, ACTUAL OR THREATENED RELEASES OF HAZARDOUSSUBSTANCES FROM THIS SITE, IF NOT ADDRESSED BY IMPLEMENTING THE RESPONSEACTION SELECTED IN THIS ROD, MAY PRESENT AN IMMINENT AND SUBSTANTIALENDANGERMENT TO PUBLIC HEALTH, WELFARE, OR THE ENVIRONMENT.
ENVIRONMENTAL EVALUATION
AN ECOLOGICAL ASSESSMENT WAS NOT CONDUCTED AS PART OF THIS RISKASSESSMENT. THIS WAS BASED ON SEVERAL REASONS, INCLUDING THE RESULTS OF ANAQUATIC BIOLOGICAL INVESTIGATION CONDUCTED FROM THE SUMMER OF 1981 TO THESPRING OF 1982 IN THE WESTERN TRIBUTARY BY PADER. PADER CONCLUDED THAT"LEACHATE FROM MODERN LANDFILL HAS NOT RESULTED IN ANY DEGRADATION TO THEUNNAMED [WESTERN} TRIBUTARY TO KREUTZ CREEK. THE GREATEST SINGLE FACTORCONTRIBUTING TO POOR CONDITIONS IN THE CREEK WAS SILTATION CAUSES BY GRAZINGCATTLE ON THE HEINDEL FARM." THIS STUDY WAS CONDUCTED PRIOR TO THE OPERATIONOF THE WESTERN EXTRACTION SYSTEM, WHEN GROUNDWATER RECHARGE TO THE
16
TRIBUTARY WAS STILL A POTENTIALLY IMPORTANT MIGRATION PATHWAY FOR VOLATILEORGANIC CHEMICALS FROM THE 66-ACRE UNLINED LANDFILL. SINCE IT BEGAN OPERATING,THE EXTRACTION SYSTEM HAS SIGNIFICANTLY REDUCED THE SURFACE WATER FLOW INBOTH THE WESTERN AND EASTERN TRIBUTARIES AND THUS ALSO MINIMIZED THEPOTENTIAL FOR SITE-RELATED CHEMICALS TO HAVE AN ADVERSE IMPACT ON THETRIBUTARIES. ADDITIONALLY, THERE IS CURRENTLY NO POTENTIAL FOR CHEMICALS OFPOTENTIAL CONCERN ASSOCIATED WITH THE CERCLA SITE TO MIGRATE VIA SURFACERUNOFF INTO THE TRIBUTARIES.
ACCORDING TO THE PENNSYLVANIA FISH AND GAME COMMISSION, NONE OF THE FISH,AMPHIBIANS, OR REPTILES ON THE STATE'S ENDANGERED OR THREATENED SPECIES LISTSARE KNOWN TO OCCUR IN THE VICINITY OF THE MODERN LANDFILL. ACCORDING TO THE USFISH AND WILDLIFE SERVICE, EXCEPT FOR OCCASIONAL TRANSIENT SPECIES, NOFEDERALLY LISTED OR PROPOSED THREATENED OR ENDANGERED SPECIES UNDER THEIRJURISDICTION ARE KNOWN TO EXIST IN THE GENERAL VICINITY OF MODERN LANDFILL. FINALLY, ACCORDING TO PADER"S BUREAU OF FORESTRY, THERE ARE NO "SIGNIFICANTNATURAL FEATURES OF CONCERN" (SUCH AS PLANT AND ANIMAL SPECIES OF SPECIALCONCERN, EXEMPLARY NATURAL COMMUNITIES AND UNIQUE GEOLOGIC FEATURES) IN THEGENERAL VICINITY OF MODERN LANDFILL. A 1988 WETLANDS FIELD STUDY ALSOCONCLUDED THAT WETLANDS OF THE KIND AND SIZE OBSERVED AT MODERN LANDFILL ISNOT A UNIQUELY IMPORTANT ECOLOGICAL HABITAT. BASED ON THIS INFORMATION, ITWAS CONCLUDED THAT AN ECOLOGICAL ASSESSMENT NEED NOT BE CONDUCTED AS PARTOF THE RISK ASSESSMENT.
G. DESCRIPTION OF ALTERNATIVES
BASED ON DATA COLLECTED AND THE RISK ASSESSMENT RESULTS OF THE REMEDIALINVESTIGATION/FEASIBILITY STUDY, EPA HAS ESTABLISHED REMEDIAL ACTION OBJECTIVESFOR THE MODERN LANDFILL SITE. REMEDIATION IS GENERALLY FOCUSED ON EXPOSUREPATHWAYS SHOWING EXCESS LIFETIME CANCER RISKS GREATER THAT 1 X (10-6) OR, FORNONCARCINOGENS, A HAZARD INDEX GREATER THAN THE THRESHOLD LEVEL OF ONE. THESE POINTS OF DEPARTURE WERE EXCEEDED FOR THE GROUNDWATER INGESTIONEXPOSURE PATHWAY ONLY. REMEDIAL ACTION OBJECTIVES HAVE THEREFORE BEENDEVELOPED FOR GROUNDWATER ONLY.
THE GENERAL REMEDIAL ACTION OBJECTIVES FOR THE MODERN LANDFILL SITE ARE:
• REDUCE LEACHATE PRODUCTION AND MIGRATION TO GROUNDWATER.
• REDUCE THE AMOUNT OF GROUNDWATER DEGRADATION ON THE CERCLA SITE.
• DECREASE THE POTENTIAL FOR MIGRATION OF DEGRADED GROUNDWATERFROM THE MODERN LANDFILL PROPERTY.
• MINIMIZE MIGRATION OF LEACHATE CONSTITUENTS INTO SURFACE WATER.
• PREVENT EXPOSURE TO CONTAMINATED GROUNDWATER.
• RESTORE CONTAMINATED GROUNDWATER TO BENEFICIAL USES WHEREPRACTICABLE.
17
• AS A GOAL, RESTORE CONTAMINATED GROUNDWATER TO BACKGROUNDQUALITY.
THE BASELINE RISK ASSESSMENT CONCLUDED THAT UNDER THENO-FURTHER-ACTION ALTERNATIVE, RISKS FROM INGESTION OF GROUNDWATER ON THEPROPERTY AND OFF THE PROPERTY WERE WELL WITHIN EPA'S TARGET RISK RANGE OF (10-6)TO (10-4). EVEN FOR THE NO-ACTION ALTERNATIVE, RISKS OFF THE PROPERTY WERECALCULATED TO BE WELL WITHIN THIS RANGE. THUS, REMEDIATION IS NEEDED ONLY ONTHE CERCLA SITE, NOT ON THE PROPERTY AND/OR OFF THE PROPERTY.
THE FOLLOWING SUBSTANCES HAVE BEEN EVALUATED FOR GROUNDWATERINGESTION RISKS ON THE MODERN LANDFILL CERCLA SITE WITH AN ESTIMATED UPPERBOUND EXCESS LIFETIME CANCER RUSK OF 1 X (10-6) OR GREATER, OR WITH A CDI TO RFDRATIO OF 1.0 OR GREATER. THESE SUBSTANCES WILL BE REMOVED TO THEIR BACKGROUNDLEVELS AS DESCRIBED LATER IN THIS RECORD OF DECISION.
BENZENE CARBON TETRACHLORIDE CHLOROFORM 1,4-DICHLOROBENZENE TOTAL DICHLOROBENZENES 1,1-DICHLOROETHANE 1,2-DICHLOROETHANE 1,1-DICHLOROETHENE TRANS-1,2-DICHLOROETHENE 1,2-DICHLOROETHENES (TOTAL) METHYL CHLORIDE TETRACHLOROETHENE TRICHLOROETHENE VINYL CHLORIDE
AREA OF ATTAINMENT
THE NATIONAL CONTINGENCY PLAN, IN DISCUSSING DOCUMENTATION OF THEREMEDY SELECTION IN THE ROD STATES THAT "PERFORMANCE SHALL BE MEASURED ATAPPROPRIATE LOCATIONS IN THE GROUNDWATER, SURFACE WATER, SOILS, AIR, AND OTHERAFFECTED ENVIRONMENTAL MEDIA." UNDER CURRENT SITE CONDITIONS, GROUNDWATERFLOW FROM THE CERCLA SITE IS EFFECTIVELY CONTAINED BY THE EXISTINGGROUNDWATER EXTRACTION SYSTEM. TO MONITOR THE EFFECTIVENESS OF THEREMEDIATION AND PROTECTION PROVIDED TO USERS OF THE GROUNDWATER IN THEVICINITY, GROUNDWATER MONITORING POINTS OUTSIDE THE EXTRACTION SYSTEM AREAPPROPRIATE (AND SOME ARE ALREADY INSTALLED).
THE ATTAINMENT AREA FOR MODERN LANDFILL IS LOCATED BETWEEN THE CERCLASITE AND THE EXISTING GROUNDWATER COMPLIANCE MONITORING AND ASSESSMENTPOINTS. ALL OF THESE COMPLIANCE MONITORING AND ASSESSMENT POINTS ARE LOCATEDWELL WITHIN THE PROPERTY BOUNDARIES SO THAT IF WATER QUALITY IS DETERMINED TOBE UNACCEPTABLE, STEPS CAN BE TAKEN TO PREVENT FURTHER MIGRATION AND TOPROTECT HUMAN HEALTH AND THE ENVIRONMENT. ADDITIONAL COMPLIANCE ANDMONITORING POINTS MAY BE CONSTRUCTED IF DEEMED NECESSARY BY THE PADER AND/OREPA.
SUMMARY OF ALTERNATIVES
EPA STUDIED A VARIETY OF TECHNOLOGIES TO DETERMINE WHICH WERE APPLICABLEFOR USE AT THE MODERN LANDFILL SITE. AFTER A PRELIMINARY SCREENING OF
18
TECHNOLOGIES WAS COMPLETED, THOSE MOST APPLICABLE TO THE SITE WERE DEVELOPEDINTO REMEDIAL ALTERNATIVES. THE ALTERNATIVES WHICH WERE DEVELOPED TO TREATTHE RELATIVELY LOW LEVEL THREAT FROM THE MODERN LANDFILL SITE ARE AS FOLLOWS:
• ALTERNATIVE 1 -- NO-ACTION
• ALTERNATIVE 2A -- NO FURTHER ACTION (CONTINUED OPERATION OF GROUNDWATERAND VAPOR EXTRACTION SYSTEMS)
• ALTERNATIVE 2B -- GROUNDWATER AND VAPOR EXTRACTION SYSTEMS AND FINALCOVER
• ALTERNATIVE 2C -- AUGMENTED EXTRACTION SYSTEMS PLUS FINAL COVER
A MORE DETAILED DESCRIPTION OF EACH OF THESE ALTERNATIVES FOLLOWS.
ALTERNATIVE 1 -- NO ACTION
CAPITAL COST: $0OPERATION AND MAINTENANCE COSTS: $218,500PRESENT WORTH COST: $3,398,000
THE NATIONAL CONTINGENCY PLAN REQUIRES THAT A NO ACTION ALTERNATIVE BEEVALUATED IN DETAIL. THIS PROVIDES A BASELINE FOR COMPARISON TO OTHERALTERNATIVES. AT THE MODERN LANDFILL SITE, HOWEVER, A TRUE NO-ACTIONALTERNATIVE IS NOT POSSIBLE. THE BEST APPROXIMATION TO A NO-ACTION ALTERNATIVEIS CEASING CURRENT ACTIONS, THAT IS, SHUTTING OFF THE EXTRACTION SYSTEM ANDCEASING MAINTENANCE OF THE CAP AND OTHER COMPONENTS OF THE EXISTINGREMEDIAL ACTION. THE NO-ACTION ALTERNATIVE WOULD INCLUDE GROUNDWATERMONITORING CONSISTING OF SAMPLING AND ANALYSIS IN ACCORDANCE WITH PADERSOLID WASTE PERMIT NO. 100113.
THIS ALTERNATIVE PROVIDES MORE PROTECTION TO HUMAN HEALTH AND THEENVIRONMENT THAN A TRUE NO-ACTION ALTERNATIVE AS SOME LEACHATE CONSTITUENTSHAVE ALREADY BEEN REMOVED FROM THE LANDFILL, THE CAP ALREADY IN PLACE WILLCONTINUE TO REDUCE INFILTRATION AND THE CONCENTRATION OF LEACHATECONSTITUENTS IN THE GROUNDWATER, AND THE SITE FENCE WILL CONTINUE TO RESTRICTACCESS TO THE SITE.
IN GENERAL, THIS ALTERNATIVE WOULD NOT MEET THE APPLICABLE OR RELEVANTAND APPROPRIATE REQUIREMENTS (ARARS) FOR THIS SITE, PARTICULARLY THEGROUNDWATER REMEDIATION GOALS OF BACKGROUND WATER QUALITY.
ALTERNATIVE 2A -- NO FURTHER ACTION (CONTINUED OPERATION OF THE EXISTINGGROUNDWATER AND VAPOR EXTRACTION SYSTEMS)
CAPITAL COST: $47,000OPERATION AND MAINTENANCE COSTS: $1,107,500PRESENT WORTH: $16,963,500
19
THIS ALTERNATIVE INVOLVES THE CONTINUED OPERATION AND MAINTENANCE OFALL EXISTING REMEDIAL ACTIONS, INCLUDING THE LANDFILL CAP, GROUNDWATEREXTRACTION SYSTEM, ONSITE WASTEWATER TREATMENT FACILITY, VAPOR EXTRACTIONSYSTEM, AND GROUNDWATER MONITORING.
A LANDFILL CAP AND FINAL COVER ARE CURRENTLY UNDER CONSTRUCTION. THISALTERNATIVE DOES NOT INCLUDE COMPLETION OF THE LANDFILL CAPS CURRENTLY UNDERCONSTRUCTION BUT DOES ALLOW FOR MAINTENANCE OF COMPLETED CAPS. THE PURPOSEOF THE CAP SYSTEM IS TO REDUCE INFILTRATION OF PRECIPITATION WHICH WILLULTIMATELY RESULT IN THE REDUCTION OF THE AMOUNT OF LEACHATE PRODUCED FROMTHE SITE AREA, THEREBY REDUCING THE CONCENTRATION OF LEACHATE CONSTITUENTS INTHE GROUNDWATER.
A NETWORK OF 12 GROUNDWATER EXTRACTION WELLS WHICH WAS DESIGNED ANDINSTALLED IN 1985 AUGMENTS THE WESTERN GROUNDWATER INTERCEPTOR TRENCH. ANADDITIONAL TWO EXTRACTION WELLS WERE ADDED IN 1987, BRINGING THE TOTAL NUMBEROF EXTRACTION WELLS ON THE WESTERN PERIMETER TO 14. ALONG THE EASTERNPERIMETER A SIMILAR EXTRACTION SYSTEM, CONSISTING OF 13 WELLS, BECAMEOPERATIONAL IN 1986.
THE PURPOSE OF THE EXTRACTION SYSTEM IS TO CREATE A HYDRAULIC BARRIER TOGROUNDWATER FLOW FROM THE CERCLA SITE AND TO REMOVE GROUNDWATERCONTAINING LEACHATE CONSTITUENTS. ALL EXTRACTED WATER IS DIVERTED TO ANDPROCESSED THROUGH THE ONSITE WASTEWATER TREATMENT FACILITY. THE TREATMENTFACILITY, PERMITTED UNDER PADER WATER QUALITY MANAGEMENT PERMIT NO.PAD00678201, IS DESIGNED TO ACCEPT FLOW FROM BOTH THE EASTERN AND WESTERNGROUNDWATER EXTRACTION SYSTEMS AND THE GROUNDWATER INTERCEPTOR TRENCH. THE WASTEWATER TREATMENT FACILITY IS COMPRISED OF A PHYSICAL/CHEMICAL PLANTAND A BIOLOGICAL PLANT TO TREAT EXTRACTED GROUNDWATER. WASTEWATERRECEIVED FROM THE PHYSICAL/CHEMICAL TREATMENT PLANT IS PROCESSED IN THEBIOLOGICAL TREATMENT PLANT AND RETURNED TO THE PHYSICAL/CHEMICAL PLANT PRIORTO SAND FILTERING. WASTEWATER IS THEN PROCESSED THROUGH THE AIR STRIPPERBEFORE DISCHARGE.
SITE FENCING IS INCLUDED IN THIS ALTERNATIVE TO RESTRICT SITE ACCESS. THESECTION OF THE CERCLA SITE WEST OF PROSPECT ROAD IS SURROUNDED BY EXISTING SITEFENCING AND SECTIONS OF THE CERCLA SITE EAST OF PROSPECT ROAD ARE ENCLOSED BYSITE FENCING. THE RISK ASSESSMENT SHOWED THAT RISKS ASSOCIATED WITH DIRECTSURFACE WATER AND SEDIMENT CONTACT FOR THE NO FURTHER ACTION ALTERNATIVE TOBE BELOW THE REGULATORY LEVELS OF CONCERN. THE EXISTING SITE FENCE ISTHEREFORE PROTECTIVE OF HUMAN HEALTH AND THE ENVIRONMENT BY RESTRICTING SITEACCESS.
THE PURPOSE OF THE LANDFILL GAS MANAGEMENT SYSTEM AT MODERN LANDFILL ISTO PREVENT LANDFILL GAS MIGRATION OFF THE PROPERTY. THE OPERATION OF THELANDFILL GAS MANAGEMENT SYSTEM SUBJECTS THE ENTIRE REFUSE VOLUME TO APRESSURE EQUAL TO OR SLIGHTLY LESS THAN THAT OF ATMOSPHERIC PRESSURE,REDUCING LANDFILL GAS MIGRATION.
20
IN ADDITION TO THE ABOVE, GROUNDWATER MONITORING IN ACCORDANCE WITHTHE PADER SOLID WASTE PERMIT NO. 100113 WOULD CONTINUE WITH THIS ALTERNATIVE,BOTH UPGRADIENT AND DOWNGRADIENT OF THE SITE TO DETECT CHANGES INGROUNDWATER QUALITY. THE GROUNDWATER MONITORING PROGRAM CURRENTLYINCLUDES THREE QUARTERLY SAMPLING AND ANALYSIS PERIODS DURING THE MONTHS OFMARCH, JUNE, AND DECEMBER, AND ONE ANNUAL SAMPLING AND ANALYSIS PERIODDURING SEPTEMBER.
THE CURRENT WATER QUALITY MONITORING SYSTEM CONSISTS OF 19 GROUNDWATERMONITORING WELLS, 14 GROUNDWATER CONSTITUENT ASSESSMENT WELLS, THE 27EASTERN AND WESTERN EXTRACTION WELLS, AND 17 SURFACE WATER SAMPLING POINTS.
NEW GROUNDWATER MONITORING AND ASSESSMENT WELLS MAY BE NEEDED ON THEPROPERTY TO EVALUATE PROGRESS TOWARD MEETING THE REMEDIATION GOALS IN THEATTAINMENT AREA. THE EXACT LOCATION AND NUMBER OF THESE WELLS WILL BEDETERMINED IN THE REMEDIAL DESIGN PHASE.
THIS ALTERNATIVE WOULD BE EXPECTED TO MEET ALL ARARS, EXCEPT THEGROUNDWATER REMEDIATION GOALS UNDER FUTURE CONDITIONS.
ALTERNATIVE 2B -- GROUNDWATER AND VAPOR EXTRACTION SYSTEMS AND FINALCOVER
CAPITAL COST: $3,486,500OPERATION AND MAINTENANCE COSTS: $1,166,500PRESENT WORTH COST: $17,947,000
THIS ALTERNATIVE CONSISTS OF THE SOME REMEDIAL ACTIONS AS ALTERNATIVE 2APLUS ADDITIONAL REMEDIAL ACTIONS THAT ARE CURRENTLY PLANNED AND PERMITTEDTO ENHANCE THE EFFECTIVENESS OF THE OVERALL REMEDY. THESE ADDITIONAL ACTIONSINCLUDE COMPLETION OF THE CAP AND FINAL COVER OVER THE 66-ACRE UNLINEDLANDFILL.
IN ADDITIONAL TO THE COMPLETION OF THE LANDFILL CAPS, THE ENTIRE 66-ACREUNLINED LANDFILL WILL RECEIVE A PADER APPROVED LOW-PERMEABILITY FINAL COVERSYSTEM. THE FINAL COVER OVER THE LANDFILL WILL INCLUDE A 20-ACRE PLATEAU CAPAND A 46-ACRE SIDE SLOPE CAP.
THIS ALTERNATIVE IS ALSO EXPECTED TO COMPLY WITH ARARS. UNDER FUTURE USECONDITIONS, HOWEVER, THE PENNSYLVANIA BACKGROUND REQUIREMENT FORBACKGROUND QUALITY MAY NOT BE MET EITHER ON AND/OR OFF THE SITE SHOULDGROUNDWATER BYPASS THE EXTRACTION SYSTEM.
ALTERNATIVE 2C --AUGMENTED EXTRACTION SYSTEMS PLUS FINAL COVER
CAPITAL COST: $3,509,000OPERATION AND MAINTENANCE COSTS: $1,175,000PRESENT WORTH COST: $18,078,000
21
THIS ALTERNATIVE INCLUDES ALL OF THE ACTIONS UNDERTAKEN AND PLANNED FORIN ALTERNATIVES 2A AND 2B ABOVE. IN ADDITION, THIS ALTERNATIVE INCLUDES FURTHEREXPANSION OF THE EXISTING GROUNDWATER EXTRACTION SYSTEM. THE OBJECTIVE OFTHIS ALTERNATIVE IS TO MINIMIZE THE FLOW OF DEGRADED GROUNDWATER THAT COULDPOTENTIALLY ESCAPE THE EXTRACTION WELL SYSTEM TO THE NORTHWEST.
IN THIS ALTERNATIVE, TWO ADDITIONAL WELLS ARE PROPOSED AT THE NORTHWESTEND OF THE WESTERN EXTRACTION SYSTEM. THESE PROPOSED WELLS ARE STRATEGICALLYLOCATED TO CAPTURE GROUNDWATER THAT MIGHT BYPASS THE CURRENT THE NORTHEND OF THE WESTERN EXTRACTION SYSTEM.
THIS ALTERNATIVE, LIKE ALTERNATIVE 2A AND 2B, IS EXPECTED TO MEET ARARS.
H. SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
THE FOUR REMEDIAL ACTION ALTERNATIVES DESCRIBED ABOVE WERE EVALUATEDUNDER THE NINE CRITERIA IN THE NCP, 40 CFR 300.430(E)(9). THESE NINE CRITERIA CAN BEFURTHER CATEGORIZED INTO THREE GROUPS: THRESHOLD CRITERIA, PRIMARYBALANCING CRITERIA, AND MODIFYING CRITERIA, AS FOLLOWS:
THRESHOLD CRITERIA
• OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT• COMPLIANCE WITH APPLICABLE OR RELEVANT AND APPROPRIATE
REQUIREMENTS (ARARS)
PRIMARY BALANCING CRITERIA
• LONG-TERM EFFECTIVENESS• REDUCTION OF TOXICITY, MOBILITY, OR VOLUME THROUGH TREATMENT• SHORT-TERM EFFECTIVENESS• IMPLEMENTABILITY• COST
MODIFYING CRITERIA
• COMMUNITY ACCEPTANCE• STATE ACCEPTANCE
THESE EVALUATION CRITERIA, WHICH MEASURE THE OVERALL FEASIBILITY ANDACCEPTABILITY OF THE REMEDY, RELATE DIRECTLY TO REQUIREMENTS IN SECTION 121 OFCERCLA, 42 USC SECTION 9621. THRESHOLD CRITERIA MUST BE SATISFIED IN ORDER FOR AREMEDY TO BE ELIGIBLE FOR SELECTION. PRIMARY BALANCING CRITERIA ARE USED TOWEIGH MAJOR TRADE-OFFS BETWEEN ALTERNATIVES. STATE AND COMMUNITYACCEPTANCE ARE MODIFYING CRITERIA FORMALLY TAKEN INTO ACCOUNT AFTER PUBLICCOMMENT IS RECEIVED ON THE PROPOSED PLAN.
THE COMPARATIVE EVALUATION OF ALTERNATIVES FOLLOWS.
22
OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT.
ALTERNATIVE 1 WOULD NOT BE PROTECTIVE OF HUMAN HEALTH AND THEENVIRONMENT AS THE SITE WOULD RETURN TO ITS PREVIOUS UNCONTROLLED STATE ANDLEACHATE CONSTITUENTS COULD MIGRATE IN BOTH THE GROUNDWATER AND SURFACEWATER. AS THIS ALTERNATIVE IS NOT PROTECTIVE OF HUMAN HEALTH AND THEENVIRONMENT, IT WILL NOT BE CONSIDERED FURTHER IN THIS RECORD OF DECISION.ALTERNATIVES 2A, 2B, AND 2C WOULD BE PROTECTIVE OF HUMAN HEALTH AND THEENVIRONMENT BY DECREASING THE POTENTIAL FOR DIRECT CONTACT WITH SURFACEWATER AND SEDIMENTS, AND BY DECREASING THE POTENTIAL FOR INGESTION OFGROUNDWATER CONTAINING LEACHATE CONSTITUENTS. ALTERNATIVE 2B WOULD BEMORE PROTECTIVE THAN 2A AS THE COMPLETION OF THE CAP WOULD FURTHER REDUCETHE POTENTIAL OF LEACHATE GENERATION, WHILE ALTERNATIVE 2C, IN ADDITION TO THEABOVE BENEFITS, WOULD ENSURE THE REMOVAL OF CONTAMINANTS THAT MAY BEBYPASSING THE EXTRACTION SYSTEM TO THE NORTH.
COMPLIANCE WITH APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
ALTERNATIVE 2C WOULD COMPLY WITH ALL ARARS. GROUNDWATER EXTRACTIONWILL CONTINUE UNTIL THE PENNSYLVANIA ARAR FOR BACKGROUND WATER QUALITY ISREACHED. UNDER ALTERNATIVES 2A AND 2B, HOWEVER, REQUIREMENTS MAY NOT BE METON AND/OR OFF THE PROPERTY IN THE FUTURE SHOULD GROUNDWATER BYPASS THECURRENT EXTRACTION SYSTEM. ALTERNATIVE 2C WILL ENSURE THAT SUCH BYPASSINGDOES NOT OCCUR.
LONG TERM EFFECTIVENESS
THE MAGNITUDE OF RESIDUAL RISK WILL BE SUBSTANTIALLY REDUCED BYIMPLEMENTATION OF ANY OF THE ALTERNATIVES. THE USE OF GROUNDWATEREXTRACTION AND LANDFILL GAS EXTRACTION SERVES AS A METHOD OF LEACHATECONSTITUENT REMOVAL. THIS, IN COMBINATION WITH REDUCED MOBILITY OF LEACHATECONSTITUENTS FROM THE EXISTING LOW-PERMEABILITY LANDFILL CAP, WILL MITIGATE ASUBSTANTIAL AMOUNT OF POTENTIAL RISK.
THE RISKS ASSOCIATED WITH DIRECT CONTACT WITH SEDIMENT AND SURFACEWATER HAVE BEEN SHOWN TO BE WELL BELOW THE REGULATORY LEVELS OF CONCERN.THESE RISKS WILL BE FURTHER MINIMIZED BY THE EXISTING SITE FENCING AND THEREDUCTION OF CONSTITUENT MIGRATION TO THE SURFACE WATER. THE RISKS ASSOCIATEDWITH INGESTION OF GROUNDWATER ARE BEING REDUCED BY THE INSTALLATION OFLANDFILL CAPS, THE CONNECTION OF AN ADDITIONAL WELL UNDER ALTERNATIVE 2B, ANDTHE COMPLETION OF FINAL COVER AND ANOTHER EXTRACTION WELL UNDER ALTERNATIVE2C.
REDUCTION OF TOXICITY, MOBILITY, OR VOLUME THROUGH TREATMENT.
ALL THREE ALTERNATIVES, 2A, 2B, AND 2C REDUCE THE INHERENT HAZARDSASSOCIATED WITH INGESTION OF DEGRADES GROUNDWATER BY OPERATION OF THEGROUNDWATER EXTRACTION SYSTEM. DEGRADED GROUNDWATER REMOVED BY THEEXTRACTION SYSTEM TYPICALLY CONTAINS CHLORINATED HYDROCARBONS AND SOME
23
INORGANIC COMPOUNDS. LEACHATE CONSTITUENTS ARE PHYSICALLY AND CHEMICALLYSEPARATED FROM THE GROUNDWATER BY THE ONSITE WASTEWATER TREATMENT PLANT.
SOME REDUCTION IN THE VOLUME OF LEACHATE CONSTITUENTS PRESENT IN THELANDFILL HAS AND WILL BE ACCOMPLISHED BY THE GROUNDWATER AND VAPOREXTRACTION SYSTEMS. THE MOBILITY OF LEACHATE CONSTITUENTS WILL BE REDUCED BYTHE EXISTING LOW-PERMEABILITY LANDFILL CAP. THE REDUCED INFILTRATION OFPRECIPITATION RESULTS IN REDUCED MIGRATION OF LEACHATE CONSTITUENTS INTO THEGROUNDWATER.
ALTERNATIVES 2B AND 2C WILL EACH REMOVE INCREMENTALLY GREATER AMOUNTSOF CONTAMINANTS FROM THE GROUNDWATER, AND ALTERNATIVE 2C WILL FURTHERREDUCE THE MOBILITY OF CONTAMINANTS WITH THE COMPLETION OF THE FINAL LANDFILLCOVER SYSTEM.
SHORT TERM EFFECTIVENESS
WITH ALL THREE ALTERNATIVES, IMPLEMENTATION OF THE FULL REMEDIES WOULDCOMMENCE ALMOST IMMEDIATELY. AS THE GROUNDWATER EXTRACTION AND VAPOREXTRACTION SYSTEMS HAVE BEEN IN OPERATION FOR SOME TIME, THE SHORT TERMEFFECTIVENESS OF EACH REMEDY HAS ALREADY BEEN DEMONSTRATED.
ALTERNATIVES 2B AND 2C WOULD REQUIRE SOME ADDITIONAL TIME FROMSELECTION OF REMEDY TO IMPLEMENTATION; HOWEVER, THIS TIMEFRAME WOULD BEEXPECTED TO BE LESS THAN ONE YEAR. ADDITIONALLY, THE FINAL COVER SYSTEM TO BEIMPLEMENTED WITH ALTERNATIVE 2C WOULD FURTHER REDUCE THE MOBILITY OF THECONTAMINANTS IN AN EXTREMELY SHORT TIMEFRAME.
THE COMMUNITY, WORKERS, OR THE ENVIRONMENT ARE NOT EXPECTED TO BEADVERSELY AFFECTED BY ANY OF THE ALTERNATIVES.
IMPLEMENTABILITY
ALL PHASES OF ALTERNATIVE 2A HAVE BEEN IMPLEMENTED EXCEPT THEINSTALLATION OF ADDITIONAL MONITORING WELLS. IMPLEMENTATION OF THISALTERNATIVE POSES NO TECHNICAL DIFFICULTIES. THIS ALTERNATIVE IS RELATIVELYSIMPLE TO OPERATE AND IS RELIABLE.
ALL COMPONENTS OF ALTERNATIVE 2B HAVE BEEN IMPLEMENTED WITH THEEXCEPTION OF THE INSTALLATION OF ADDITIONAL MONITORING WELLS, AND COMPLETIONOF LANDFILL CAPPING AND FINAL COVER. AGAIN, THE IMPLEMENTATION OF THESEACTIONS POSE MINIMAL DIFFICULTY.
ALL COMPONENTS OF ALTERNATIVE 2C HAVE BEEN IMPLEMENTED EXCEPT THEINSTALLATION OF ADDITIONAL MONITORING WELLS, COMPLETION OF LANDFILL CAPPINGAND FINAL COVER, AND THE DESIGN AND INSTALLATION OF TWO ADDITIONAL EXTRACTIONWELLS. THE COMPLETION OF THESE ACTIONS POSE MINIMAL DIFFICULTY. THEALTERNATIVE IS RELATIVELY SIMPLE TO OPERATE AND IS RELIABLE.
24
ALL MATERIALS AND SERVICES REQUIRED BY THIS ALTERNATIVE ARE COMMONCONSTRUCTION ITEMS AND PROCEDURES, AND INVOLVE ROUTINE SAMPLING ANDANALYTICAL PROCEDURES.
COST
THE CAPITAL COST FOR ALTERNATIVE 2A IS RELATIVELY LOW AT $47,000 AS MOST OFTHE COMPONENTS OF THIS REMEDY HAVE ALREADY BEEN IMPLEMENTED. THE OPERATIONAND MAINTENANCE COSTS OF ALL OF THE ALTERNATIVES ARE, FOR ALL PRACTICALPURPOSES, ABOUT EQUAL AT JUST OVER $1 MILLION, AND THE PRESENT WORTH COSTS OFALL OF THE ALTERNATIVES ARE JUST ABOUT EQUAL, RANGING FROM $16,963,500 FORALTERNATIVE 2A TO $18,078,000 FOR ALTERNATIVE 2C.
COMMUNITY ACCEPTANCE
A PUBLIC MEETING ON THE PROPOSED PLAN FOR MODERN LANDFILL WAS HELD ONMAY 7, 1991. COMMENTS RECEIVED FROM THE PUBLIC DURING THE PUBLIC COMMENTPERIOD ARE REFERENCED IN THE RESPONSIVENESS SUMMARY ATTACHED TO THE RECORDOF DECISION. NO MAJOR PUBLIC OBJECTION TO THE PROPOSED REMEDY FOR MODERNLANDFILL EXISTS.
STATE ACCEPTANCE
PADER, ON BEHALF OF THE COMMONWEALTH OF PENNSYLVANIA, HAS VERBALLYCONCURRED IN THE SELECTION OF ALTERNATIVE 2C.
I. THE SELECTED REMEDY
BASED UPON CONSIDERATION OF INFORMATION AVAILABLE FOR THE MODERNLANDFILL SITE, INCLUDING THE DOCUMENTS AVAILABLE IN THE ADMINISTRATIVE RECORD,AN EVALUATION OF THE RISKS CURRENTLY POSED BY THE SITE, THE REQUIREMENTS OFCERCLA, THE DETAILED EVALUATION OF ALTERNATIVES, AND COMMUNITY INPUT, EPA HASSELECTED ALTERNATIVE 2C AS THE REMEDY TO BE IMPLEMENTED AT MODERN LANDFILL.
THIS ALTERNATIVE INVOLVES THE CONTINUED OPERATION AND MAINTENANCE OFALL EXISTING REMEDIAL ACTIONS, INCLUDING THE COMPLETION AND MAINTENANCE OFTHE LANDFILL CAP AND FINAL COVER SYSTEM, GROUNDWATER EXTRACTION SYSTEM,INSTALLATION OF ADDITIONAL EXTRACTION WELLS TO ENSURE THE CAPTURE OFCONTAMINATED GROUNDWATER FLOWING TO THE NORTH, ONSITE WASTEWATERTREATMENT FACILITY, VAPOR EXTRACTION SYSTEM, AND GROUNDWATER MONITORING.THE 66-ACRE UNLINED LANDFILL WILL HAVE A 20-ACRE PLATEAU AREA AND A 46-ACRE SIDESLOPE AREA. A TOTAL OF 27 GROUNDWATER EXTRACTION WELLS WILL CONTINUE INOPERATION. THE GROUNDWATER EXTRACTION SYSTEM WILL CONTINUE TO OPERATE UNTILTHE REMEDIATION GOAL OF BACKGROUND LEVELS OF CONTAMINANTS IS REACHED. THECLEAN UP LEVEL FOR THE AQUIFER CONTAMINANTS ARE, FOR EACH CONTAMINANT, THELOWER OF (1) THE STANDARDS LISTED IN TABLE 3 AND (2) THE BACKGROUND LEVEL OFTHAT CONTAMINANT. BACKGROUND CONCENTRATIONS FOR EACH OF THE CONTAMINANTSLISTED IN TABLE 3 SHALL BE THE METHOD DETECTION LIMIT FOR THE METHOD OFANALYSIS UTILIZED WITH RESPECT TO THAT CONTAMINANT. AS OF THE DATE OF THIS
25
RECORD OF DECISION, THE APPROPRIATE METHODS OF ANALYSIS ARE 40 CFR PART 136(SERIES 601 AND 602), AND 40 CFR PART 141 (SERIES 524.2). THE ATTAINMENT AREA FOR THISREMEDIATION IS LOCATED BETWEEN THE CERCLA SITE AND THE GROUNDWATERCOMPLIANCE MONITORING AND ASSESSMENT POINTS, ALL OF WHICH ARE LOCATED WITHINTHE PROPERTY BOUNDARIES. IF IMPLEMENTATION OF THE SELECTED REMEDYDEMONSTRATES, IN CORROBORATION WITH HYDROGEOLOGICAL AND CHEMICAL EVIDENCE,THAT IT WILL BE TECHNICAL IMPRACTICABLE TO ACHIEVE AND MAINTAIN THEREMEDIATION GOALS THROUGHOUT THE AREA OF ATTAINMENT, THE EPA, INCONSULTATION WITH THE COMMONWEALTH OF PENNSYLVANIA, INTENDS TO AMEND THEROD OR ISSUE AN EXPLANATION OF SIGNIFICANT DIFFERENCES TO INFORM THE PUBLIC OFALTERNATIVE GROUNDWATER GOALS.
GROUNDWATER FORM BOTH THE EASTERN AND WESTERN EXTRACTION SYSTEMSAND THE GROUNDWATER INTERCEPTOR TRENCH WILL BE TREATED AT THE ONSITEWASTEWATER TREATMENT FACILITY AND DISCHARGED TO THE UNNAMED TRIBUTARY TOKREUTZ CREEK IN ACCORDANCE WITH THE REQUIREMENTS OF PADER PERMIT PAD00678201. THE TREATMENT PROCESS CONSISTS OF BOTH BIOLOGICAL AND PHYSICAL/CHEMICALTREATMENT TRAINS, SAND FILTERING, AND AIR STRIPPING.
CONTINUED GROUNDWATER AND SURFACE WATER MONITORING IS ALSO A PART OFTHE SELECTED REMEDY AS IS THE INSTALLATION OF ADDITIONAL MONITORING ANDEXTRACTION WELLS IF NEEDED. SITE FENCING IS INCLUDED IN THIS ALTERNATIVE TORESTRICT SITE ACCESS AND MINIMIZE ANY DIRECT CONTACT THREAT.
REMEDIATION OF THESE LOW LEVEL THREATS AT THE MODERN LANDFILL SITE WILLEFFECTIVELY ELIMINATE THE RISKS ASSOCIATED WITH POTENTIAL INGESTION OFGROUNDWATER ON THE CERCLA SITE.
THE CAPITAL COST OF THIS ALTERNATIVE IS $3,509,000, THE ANNUAL OPERATION ANDMAINTENANCE COSTS ARE $1,175,000, AND THE PRESENT WORTH COST IS $18,078,000.
J. STATUTORY DETERMINATION
UNDER ITS LEGAL AUTHORITIES, EPA'S PRIMARY RESPONSIBILITY AT SUPERFUNDSITES IS TO UNDERTAKE REMEDIAL ACTIONS THAT ARE PROTECTIVE OF HUMAN HEALTHAND THE ENVIRONMENT. IN ADDITION, SECTION 121 OF CERCLA ESTABLISHED SEVERALOTHER STATUTORY REQUIREMENTS AND PREFERENCES. THESE SPECIFY THAT WHENCOMPLETE, THE SELECTED REMEDIAL ACTION FOR A SITE MUST COMPLY WITH APPLICABLEOR RELEVANT AND APPROPRIATE ENVIRONMENTAL STANDARDS ESTABLISHED UNDERFEDERAL AND STATE ENVIRONMENTAL LAWS UNLESS A STATUTORY WAIVER IS GRANTED. THE SELECTED REMEDY MUST ALSO BE COST-EFFECTIVE AND UTILIZE TREATMENTTECHNOLOGIES OR RESOURCE RECOVERY TECHNOLOGIES TO THE MAXIMUM EXTENTPRACTICABLE. FINALLY THE STATUTE INCLUDES A PREFERENCE FOR REMEDIES THATPERMANENTLY AND SIGNIFICANTLY REDUCE THE VOLUME, TOXICITY, OR MOBILITY OFHAZARDOUS WASTES.
26
PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
THE SELECTED REMEDY WILL BE PROTECTIVE OF HUMAN HEALTH AND THEENVIRONMENT BY ELIMINATING THE THREAT POSED BY THE HAZARDOUS SUBSTANCESWITHIN THE MODERN LANDFILL. THESE HAZARDOUS SUBSTANCES CURRENTLY PROVIDE ATHREAT TO HUMAN HEALTH DUE TO POTENTIAL INGESTION OF GROUNDWATER ON THECERCLA SITE. THE SELECTED REMEDY WILL ELIMINATE THAT POTENTIAL RISK BYEXTRACTING THE CONTAMINATED GROUNDWATER BENEATH THE SITE AND TREATING THECONTAMINATED GROUNDWATER BEFORE DISCHARGE.
ANY POTENTIAL FOR DIRECT CONTACT WITH SITE CONTAMINANTS WILL BEELIMINATED BY COMPLETION OF THE CAP AND FINAL COVER SYSTEMS OVER THE UNLINED66-ACRE LANDFILL. THESE CAP AND COVER SYSTEMS WILL ALSO REDUCE THE PRODUCTIONOF LEACHATE AND CONTAMINATED GROUNDWATER WHICH ORIGINATES UNDER THECERCLA SITE. IN ADDITION, SITE FENCING WILL RESTRICT ACCESS TO THE SITE TO FURTHERREDUCE THE DIRECT CONTACT RISK.
THE SELECTED REMEDY WILL NOT POSE ANY UNACCEPTABLE SHORT-TERM RISKS ORCROSS-MEDIA IMPACTS TO THE SITE, THE WORKERS, OR THE COMMUNITY. THE SELECTEDREMEDY WILL BE READILY IMPLEMENTABLE.
COMPLIANCE WITH ARARS
THE SELECTED REMEDY WILL ATTAIN ALL APPLICABLE OR RELEVANT ANDAPPROPRIATE REQUIREMENTS FOR THE SITE. THESE REQUIREMENTS ARE SHOWN INAPPENDIX B. MOST SPECIFICALLY, THE PENNSYLVANIA ACTION-SPECIFIC REQUIREMENTTO REMEDIATE GROUNDWATER TO BACKGROUND CONCENTRATIONS (25 PA CODE, CHAPTER75, PART 264.97) WILL BE MET THROUGH IMPLEMENTATION OF THIS REMEDY. IFIMPLEMENTATION OF THE SELECTED REMEDY DEMONSTRATES, IN CORROBORATION WITHHYDROGEOLOGICAL AND CHEMICAL EVIDENCE, THAT IT WILL BE TECHNICALLYIMPRACTICABLE TO ACHIEVE AND MAINTAIN THE REMEDIATION GOALS THROUGHOUT THEAREA OF ATTAINMENT, THE EPA, IN CONSULTATION WITH THE COMMONWEALTH OFPENNSYLVANIA, INTENDS TO AMEND THE ROD OR ISSUE AN EXPLANATION OF SIGNIFICANTDIFFERENCES TO INFORM THE PUBLIC OF ALTERNATIVE GROUNDWATER GOALS.
COST EFFECTIVENESS
THE ESTIMATED PRESENT WORTH COST OF THE SELECTED REMEDY IS $18,078,000. EPAAND THE COMMONWEALTH OF PENNSYLVANIA BELIEVE THE SELECTED REMEDY ISCOST-EFFECTIVE IN MITIGATING THE RISKS POSED BY THE MODERN LANDFILL SITE. ALTHOUGH THE NO-ACTION ALTERNATIVE CAN BE IMPLEMENTED AT A MUCH LOWER COST,THAT ALTERNATIVE IS NOT PROTECTIVE OF HUMAN HEALTH AND THE ENVIRONMENT ANDDOES NOT MEET ARARS. ALTERNATIVES 2A AND 2B ARE ONLY SLIGHTLY LESS EXPENSIVETHAN THE SELECTED REMEDY AND DO NOT PROVIDE THE SAME AMOUNT OF PROTECTION ASTHE SELECTED REMEDY.
UTILIZATION OF PERMANENT SOLUTIONS AND ALTERNATIVE TREATMENTTECHNOLOGIES OR RESOURCE RECOVERY TECHNOLOGIES TO THE MAXIMUM EXTENTPRACTICABLE
27
EPA HAS DETERMINED THAT THE SELECTED REMEDIAL ACTION REPRESENTS THEMAXIMUM EXTENT TO WHICH PERMANENT SOLUTIONS AND TREATMENT TECHNOLOGIESCAN BE UTILIZED WHILE PROVIDING THE BEST BALANCE AMONG THE OTHER EVALUATIONCRITERIA. OF THE ALTERNATIVES THAT ARE PROTECTIVE OF HUMAN HEALTH AND THEENVIRONMENT AND MEET ARARS, EPA HAS DETERMINED THAT THE SELECTED REMEDYPROVIDES THE BEST BALANCE OF TRADE-OFFS IN TERMS OF LONG-TERM EFFECTIVENESSAND PERMANENCE; IMPLEMENTABILITY; SHORT-TERM EFFECTIVENESS; REDUCTION INTOXICITY, MOBILITY, OR VOLUME THROUGH TREATMENT; STATE AND COMMUNITYACCEPTANCE; AND THE CERCLA PREFERENCE FOR TREATMENT.
THE SELECTED REMEDY ADDRESSES THE LONG-TERM, LOW-LEVEL THREATS POSED BYTHE SITE CONTAMINANTS AT MODERN LANDFILL. THE REMEDY IS PROTECTIVE OF HUMANHEALTH AND THE ENVIRONMENT, MEETS ARARS, AND IS COST-EFFECTIVE. TREATMENT AS APRINCIPAL ELEMENT IS PROVIDED FOR IN THE ONSITE TREATMENT OF EXTRACTEDGROUNDWATER AND LEACHATE PRIOR TO DISCHARGE.
AS THIS ALTERNATIVE WOULD RESULT IN HAZARDOUS SUBSTANCES REMAININGONSITE, 5-YEAR REVIEWS, PURSUANT TO SECTION 121(C) OF CERCLA, WILL BE REQUIRED TOMONITOR THE EFFECTIVENESS OF THIS ALTERNATIVE.
K. DOCUMENTATION OF SIGNIFICANT CHANGES
NO SIGNIFICANT CHANGES FROM THE PROPOSED PLAN HAVE BEEN MADE.
28
Appendix A P*ie I of 3 \EFFSCTS CJHTtnu «• uwourtoi UKKMC ro y xjrtiru*. ::x£;
Cr.aBieol
AcatonoAluatniailarlviaSanianoCArcifloa,antc r"AH»
(AS aanxoMpyrana)lli(2-athylnuyl)ptt>uUtoCACtalUBCarbon totr«chlortdoChlareathanoOilorefonaCobaltCyan 144OleMorooonionaa:
(«* 1.2-OleDlarabanzana)(«a 1.4-OlchlaroDOMano)
1.1-OlcnlorootnaiMt.Z-OlehloroottiiM-l.l-OlcRtorootnam1.2-OlehloroaUiano (total):
traitfOletilarofluorooathanoEUiylaonsanoIronlaaa)
Harcury:IiWfanUInorganic one AttylMoreurlal
Nothylono eh lor 1 all4-dattylahanolManure tnaoMla MM*
(aa MaonthalaM)•1ek4l:
Salufelo talta«af inary duotSuawlfldo
ladltti mTatracnlaraathan* .
TohiamTrldilorMUwwTrlelilavajfluorvanhoM
VanadlMVinyl dil4r1da>XytonM (taUl)t
Nlioall.l.l-rnoHloroajtJajbi
laroranea Ooaa(BfO)
(ng/ka/day)
..
—0.0001—"^
—"
———~-•
0.040.7 aaj/ail0.1
»•
—
.._
———0.0001
1_
_ M
3 of/oa*-«
—
->
-„„
—I
ol__
0.4*0.1
SafatvPjetar {«)
.._
1.000..
••
—
———-.— .~
1.000too
1. 000— -—
..
————100
—^m
100——
—
—.
—
too1.000
_
—
1.0001.000
Sourca (B)
.
HO
•
-
•
-
•
--
--
--
HUHU--"-•
..
..—»••-HU
--
_ m
HU
—-«
»•
-
_«
—
Ha
~1—-•HUHU
(•»Ai/«Uy)-l Sowrc* (•)
--*• ••
I 9C-02 ;<ts
HISS.I .|KS
I U-01 UIS.-
a it-ot HIS. .-.. -.
- «tA
9.lt-«2 HIS1.2 HIS
.. —
.. __
.. >.
.. _
.. —
.. —
• • T.
l.i|-« HIS.. —.- -»
.. --i.ani HIS
1.7 ins.* • *m
*« * —•
0.0033 • HU
_ —4 M-43 HU (f)
.• • —_ —
2.SSC-4)! (h) HU
-• —«. —
•« j-t
• to-: a ' :.
i
it
tfjl
> j
•t
|£
C
,^. •• ---It
" ™
It•-•-
• •AA
..
It• *
u'.'.•
A
..• •
footmtao) or* ooj Takto 0-lSt.
Appendix A Page 2 of ]
C'-CA.
AcotaraAltjiinua3inv*EantanaCArcir.c?anic PAMa (1)
(AS SoniofA]pyrtna)8 i s(2*ot)iy ihaxy IJphtlia lotaCidaitfi
CArban tatr»eMar<daOi larcotnAMChlorafanaCobaltCyonidaOtcnlarabamenaa (1)
(AS 1.4-01chlerobafuena)l.l-OlehloroatMAnoI.2-Olel)taroathan41.1-0 ten larootAoM1.2-0 led laraatAano (total)
cts-trana-
0 ten torof.1wr«Mthano)
lroa>laaeManfOfWMNareary:
1 no raw tctnoraajiid and ATkylftarcvrlal
NatnylaM enldrloto4-MathylpnanolNonctrtlMfonte PAM (1)
(aa laaMhilano)NleUl:
Salublo salt*Raflnonr *««Sukonlftdo
lAdliaa 221Kadlwi 210Tatratii loraotftano
TaluowTrldiloroothaMTr ten lorof luoraaoUwwUraaiiaiVAiudltaiVinyl Ch1ar1d4Xylanoo (toul)>
Nlioa)1 1 1 Ti-ihtirnoitaae
^M.7H crFECTJ «ITW'A
'ofortrtco 3osa!"0)
(i^/ka/day)
O.I- (1)
o.os•-
0.020.001 (food) •
O.OOOS (•atari0.0007
- (D0.010.03 (Mo.u0.10.1
0.000(1):
0.01Q.OZ- m0.1- (M
o.x-•
0.0003 m0.0003 *
0.000.090.4 •
O.OX
_^
——o.ot
0.30.00731*
0.1«••
0.00?••
X
::« ~.m sjpcsuit ro c*j»::_:-j & f^nnrin. "x"^
. , t«rear 'otoney ., :--- . 7 < f*ct9r •' '
'••000 HIS
130 HIS
I JC-02 HIS /11. J ' <A (a) n
1.000 (MIS ! ir rt» 'a tt10 1C A '••%*1« .«H .1
laj «•
l-°W [«IS 1. 11-01 HIS -l
I. COO HIS | irl^j jiij > >--
500 IRIS '.'. .". '.'.
1-000 HA i if -in IOTA it1. 000 MIA fitC-Ol HU il. " •• J.1C-4X HIS lll-°°° "IS S.OC-4)t HIS C
1.000 HA ..i.ooo nr$
1.000 HIS ~ H-* -» m^ mm ••
— — II100 HU .. "
"* "" -• ••10 MCA -
1.000 HU - -100 HIS 1 SI-43 HIS IZ
'too Nu1 n n '.'.300 HIS „ „
I II ""
——LOW '-is o.asi • HU 11
100 HlS ~ ™ .'.1.000 HA. . i i£^« HU It1 EMM ' tfA • ».»»-^ f^**1 . OO4 »*A , -.
" S.Ot-« (J) -100 HU — —
2.1 «A »
100 (If. — -1.000 III'. - -
art OB Talk 0-10C.
ApptndiJC A ?4g. 3 Of 3
PC* Hatrx E-FJCTJ
(l) :«foty fictori Ara '..*a orsiuetl af jneortAinty Nctari <na modifying fKtcri. uicartA'"ty 'Kt3M ,IM ••:t»o':s -t'trtoeo :eiot ;oncr«lly eanim zf •'ultio'os 3f 10. .xi t»cn f4ctsr -ogroiont '«*. 4 i;ae>' c i it-:i jncortamty in tra OAtA tvAiUo'o. I a itiroir^ uncirtAtnty '«etari tncluca tra 'ol'o*i«a;:
« i:-fgl<| f*c:ar to «eeaunt 'or :ha •4ri4Cien in tonntivity 4«anf tra <w«ari of:na niMAA goouUtion:
. 4 10-fold f4c:ar :o tccount far tna uncorttinty in oitr4paUtina Minal data:a ft C4jo of "unani;
. 4 13-fold f4c:er to 4CCOunt for uncartAinty In oatropaUtlno frgai tm-tfun*cr.rame nCACLi ta r.hrenie MACLt: 4nd
. 4 10-fold fActor to Account for tha uncortAinty tn ojitrAoaUtin^ fro* LQAlLsto .iCAELs.
Hodlfyino f4Cters 4ro tpglltd 4t tha dlscratlon of tha ravlaoar ta covar othar urxartAintiot in tha *it4
(b) IRIS « tha choMtcal filos of EPA't Inta«.ratad Ilik Infomotion Systoa) (AS of 01/01/IJ). H(A « *««lthEffaeti AsiaiiMflt Suiaiary r«blaa (04/01/U); HA • Ha«itA Adviiary (Office of Orimnnf w«tor ) .
(c) EPA woight of cvldanea cUtitf leAtion ichomo for CArelnooana: A--MWA CAreinoajOM. sufficiantovidanea fro* huaan opld«aiale«j<CAl studios; H—'roftoAlo nVaMa Ureinoaan. liaitod ovidanca fromoptdoanolof »eal itudlas And adaquato ovldanca froa wiiaal itudloi; 12— 'rababla Huaan C4rc<no|an.irudoquata avtdaneo froa op idaaiio logical itudtoa ond AOaouata rvidanca froai Aniaal ttudaa:C—Po»»tblo Ht«an CArctnocjaa. llailtad avldonco In Anuaali In tha Afesanca af Maaan eiAta;0—Mot Cloulflad AS to huaan CAreinoflanlctty; And E— E*<daneo of tanearclnacjaniclty.
(d) Haalth Effaeta Assasswant for 8onio(4)pyrana. Emlranaawtal Crltarla And AssaaaaaMt Offlca.Clnclnnatt, Ohio. E?A S40/1-M-044.
(a) fharo Is Inadoquato ovldanea far carcfnogantclty af this ccaajound ky tha aril rout a.
(f) lAMd an RfO for aaitliyl aorcury.
(l) NUlaa. I. 1900. Panonal ecaaJMleatlan «ttn Or. looort talllaa. Caraiitoajoai AIIEPA. Alia la tha EPA 1944 HoalUt Cffaets Assasaaawit for TriehloroaUiylana. EwrlrCrltarla And Assassowt Offlca. Cincinnati. Ohio. EM/S40/1-44-044.
I
(h) lasori an aajt Aba Iliad doaa.
(I) For thaao chooleal alituras. tnlelty data for ono af tha amt taxle coBajoitndo In tna aliturota usad to raorasant tho anttra alituro. o.|.. bonso(a)ayrajna for carciMOONla PAMo. n«ontnalan«for none Are tnojanlc PAM*. l.A-dlehlorooanaano for diefilarobaManaa. cls-l.2-d1ch1araotnanofor 1.2-41eMoroothanaa.
(J) Trio CAncar pataney f AC tar. dorlvaa) uslnf Inforaatloai 1* EM (1900). Is la units of(ptt/kaydayH.
(k) An Intarlai IfO MS caleulatad for UM in thla Asaoaoawt froai tha oral 1090 (ITtCS 1907)Aeeard.ln« ta tho Approach dascrtbad In Uyton at al. (1907).
(1) An Intarlaj RfO eauld not bo cakuUtod bacauaa oral L090 valuoo vajra not ivallaalo(KTtrj 1947).
• • Pandtna/i«ndor ravlav. ' /
TABLE 3 REMEDIATION GOAL FOR GROUNDWATER
COMPOUND (A) TARGET CONCENTRATION (UG/L)
VALUE BASIS
BENZENE 5 MCL CARBON TETRACHLORIDE 5 MCL CHLOROFORM 13 RISK BASED (B, C) 1,4-DICHLOROBENZENE 75 MCL TOTAL DICHLOROBENZENE 75 MCL (D) 1,1-DICHLOROETHANE 5 QUANTITATION LIMIT (E) 1,2-DICHLOROETHANE 5 MCL 1,2-DICHLOROETHENE 7 MCL TRANS-1,2-DICHLOROETHENE 100 PMCL 1,2-DICHLOROETHENES (TOTAL) 70 PMCL (F) METHYLENE CHLORIDE 11 RISK BASE (B) TETRACHLOROETHENE 5 PMCL TRICHLOROETHENE 5 MCL VINYL CHLORIDE 2 MCL
REFER TO PAGE 25 OF THE RECORD OF DECISION FOR A COMPLETE DISCUSSION OFGROUNDWATER REMEDIATION GOALS FOR THIS SITE.
NOTES:
ND NOT DETECTED AT LEVELS AT OR ABOVE THE QUANTITATION LIMIT.
(A) INCLUDES ALL CHEMICAL EVALUATED FOR GROUNDWATER INGESTION RISKS ON THE MODERN LANDFILL CERCLA SITE WITH AN ESTIMATED UPPER BOUND EXCESS LIFETIME CANCER RISK OF 1 X (10-6) OR GREATER, OR WITH A CDI TO RFD RATIO OF 1.0 OR GREATER (SEE TABLE 6-31 OF THE RISK ASSESSMENT, CHAPTER 6 OF THE RI REPORT).
(B) RISK-BASE LEVELS ARE CALCULATED ASSUMING INGESTION OF 2 LITERS/DAY, 365 DAYS/YEAR, FOR 30 YEARS BY A 70 KG INDIVIDUAL.
(C) THE MCL FOR TOTAL TRIHALOMETHANES IS 100 UG/L.
(D) VALUE FOR 1,4-DICHLOROBENZENE.
(E) BASED ON EPA CONTRACT LABORATORIES PROGRAM CONTRACT-REQUIRED QUANTITATION LIMIT. THIS IS CONSISTENT WITH THE MCL FOR 1,2-DICHLOROETHANE, WHICH HAS APPROXIMATELY THE SAME CANCER POTENCY AS 1,1-DICHLOROETHANE. THE RISK-BASE CONCENTRATION FOR 1,1-DICHLOROETHANE WOULD BE 0.9 UG/L (1 X (10-6)) EXCESS LIFETIME CANCER RISK.
(F) VALUE FOR CIS-1,2-DICHLOROETHENE.
APPENDIX B APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
MODERN LANDFILL
REQUIREMENT DESCRIPTION
RCRA Maximum Federal Standards for several toxic chemicals are set forth toConcentration Limits protect groundwater. Standards will be used when setting goals for(40 CFR 264.94) acceptable levels of the listed chemicals.
Safe Drinking Water Act Federal Standards for several chemicals including the RCRAMaximum Contaminant Levels MCLs, adopted to protect public drinking water systems. (40 CFR Part 141) Standards will be considered and used in characterizing human
health risks associated with possible contaminated groundwaterused for public consumption.
PA Hazardous Waste Regulations Requires cleanup of groundwater to background levels.(25 PA Code 264.97)
PA Safe Drinking Water Act of 1984 State act which established drinking water standards at least as(25 PA Code 109 et. 3eq.) stringent as Federal Standards.
PA Municipal Waste Landfill Regulations State Requirements on monitoring groundwater for potential(Title 25, Chapter 273.281- 288) leachate constituents.
PA Water Quality Standard PADER Water Quality Standards include requirements for(PA Code Title 23, Chapter 93) dissolved oxygen, temperature increase, pB, total coliform, and
chemical-specific effluent limits. Limits set on a case by casebasis.
PA NPDES System State requirements on limitation of discharge from treatment(PA Code Title 25, Chapter 92) facilities.
PA Wastewater Treatment Requirements State Requirements that set levels for surface water releases from(PA Code Title 25, Chapter 95 et. seq.) treatment facilities.
PA Clean Streams Law State Requirements set forth to protect and ensure the integrity of (35 P. P. Section 691.1) streams.
Clean Air Act- Standards for particulate matter. National Ambient Air Quality Standards (40 CFR 50)
PA Air Pollution Control Regulations Standards regulate emissions from air pollution control devices.(PA Code Title 25, Chps 121-143)
Construction, Modification, Reactivation, Requirements include BAT (Best Available Technology), planand Operation (Air Stripping) approval, and special requirements in non- attainment areas.(PA Code Title 25, Chapter 127)
PA Municipal Waste Landfill Regulations Design and performance standards for final cover. Closure with(PA Code Title 25, Chapter waste in place. Requirements for landfill gas management273.234-273.236, and 273.292,293) practices at municipal waste landfills.
PA Water Resources Regulations and Authorizes NPDES discharges and treatment facility construction. NPDES (25 PA Code 92.1 et. seq.)
PA Municipal Waste Landfill Regulations Leachate Management and Treatment Standards.(PA Code Title 25, Chapter 273.271-273.277)
40 CFR 122.44, 125 Best Available Technology to control toxic and non-conventionalpollutants from treatment of wastewater.
40 CFR 125.100, 125.104 Best Management Practices and objectives for control of toxicconstituents to surface waters.
PA Municipal Waste Landfill A closure and post-closure plan must be submitted to and approvedRegulations by PADER. (Operation and Maintenance) (PA Code Title 25, Chapter 273.321-322)
PA Code Title 25, Ch. 102 Development of an Erosion and Sedimentation Control Plan.
PA Code Title 25, Chapter 273.242 Requires erosion and sedimentation control for municipal wastelandfills.
29 CFR 1926 Safety and health regulations for construction work.
PA Hazardous Sites Cleanup Act Outlines hazardous sites cleanup in the state of Pennsylvania. (PA Code Title 35, Chs. 1-13)
RESPONSIVENESS SUMMARY MODERN LANDFILL RECORD OF DECISION
YORK COUNTY, PENNSYLVANIA
From April 16, 1991 through June 15, 1991, the U.S. Environmental Protection Agency (EPA) held apublic comment period on the Proposed Plan and the Remedial Investigation/ Feasibility Study (RI/FS) for theModern Landfill site in York County, Pennsylvania. A public meeting on the Proposed Plan was held on May 7,1991, a transcript of which is part of the Administrative Record for this site. This responsiveness summarysummarizes comments on the Proposed Plan and RI/FS pertinent to the Record of Decision that were expressedby interested parties and provides EPA's responses to the comments.
This responsiveness summary is divided into the following sections:
• Overview • Background on Community Involvement • Summary of Comments Received during Public Comment Period and Agency Responses • Remaining Concerns
A. OVERVIEW
At the time of the public comment period, EPA had already endorsed a preferred alternative for theModern Landfill site. EPA's recommended alternative addressed contaminated groundwater at the site. Thepreferred alternative specified in the Record of Decision (ROD) consists of the following:
• Continued operation and maintenance of all previous remedial actions conducted onsite,including the landfill cap, groundwater extraction system, onsite wastewater treatment facility,gas extraction system (for removal and destruction of landfill generated methane gas) andgroundwater and surface water monitoring.
• Completion of the landfill cap system and final cover for the unlined 66-acre landfill.
• Maintenance of site fencing and all access restrictions.
• The addition of extraction wells to the eastern and western extraction systems to preventcontaminated groundwater from bypassing those systems.
• The completion of additional monitoring and/or extraction wells as needed to ensureprotectiveness and to control groundwater flow, respectively.
If implementation of the selected remedy demonstrates, in corroboration with hydrogeological andchemical evidence, that it will be technically impracticable to achieve and maintain the remediation goalsthroughout the area of attainment, the EPA, in consultation with the Commonwealth of Pennsylvania, intends toamend the ROD or issue an Explanation of Significant differences to inform the public of alternativegroundwater goals.
B. BACKGROUND OH COMMUNITY INVOLVEMENT
There has been moderate community interest in the Modern Landfill site due to its proximity to and itsimpact on the groundwater of nearby residences. With respect to the remedy proposed by EPA for this site,there has been little community interest. A fact sheet on EPA's proposed action at the site was sent to
representatives of Windsor and Lower Windsor Townships and to several hundred residents in the area whoEPA believed may have been interested in EPA's proposed action.
C. SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD ANDAGENCY RESPONSES
Comments raised during the public comment period for the Modern Landfill Site are summarized below.EPA responses to the comments are provided.
Comments received from Modern Sanitation of York, Inc.
Modern Sanitation of York Inc., the current operator of the site, provided several comments to EPA. These areaddressed below.
1. Modern Landfill commented that the Pennsylvania ARAR for remediation of groundwater tobackground levels is neither applicable nor relevant and appropriate.
EPA Response: EPA disagrees. EPA has accepted the Pennsylvania requirement for remediation ofgroundwater to background levels as an ARAR.
2. Modern Landfill commented that if a state or federal ARAR is not met, it may be waived. In particular,ARAR waivers are appropriate when compliance with the requirement is technically impracticable froman engineering perspective. Modern has therefore requested that the Pennsylvania ARAR requiringtreatment of groundwater to background levels be waived.
EPA Response: EPA disagrees that the Pennsylvania ARAR requiring treatment of groundwater tobackground levels should be waived. Modern Landfill has submitted two reports, one entitled "Reviewof Remediation Goals at Modern Landfill," Golder Associates Inc., June 1991, and the second a letterreport by ICF Kaiser Engineers, dated June 14, 1991, to support this waiver request. Based on sitegeology and using data from the existing extraction systems, Modern has demonstrated that remediationof groundwater to background quality, using Method Detection Limits as the background standard,would take in excess of 100 years and, for some of the contaminants of concern, up to 200 years. . EPAGuidance on Remedial Actions for contaminated Groundwater (OSWER Directive 9283.1-2) containsprovisions for ARAR waivers based on the technical impracticability of an ARAR. Specifically, forgroundwater remedies, those remedies which generally would exceed 100 years for implementation maybe waived using the technical impracticability standard.
EPA does not fully agree with the contents of the reports submitted by Modern Landfill. In particular,EPA takes exception to the development of the linear regression constants using total priority pollutantconcentrations and applying those constants to individual components. This method does not reflect atrue representation of the value of those constants. EPA also cannot support, based on the informationcontained in the reports, the assumptions made about contaminant dilution due to groundwater flow.Without verification of these assumptions, the conclusions of the reports are not acceptable. EPAbelieves that with the collection of additional data from the continued operation of the extractionsystems, a re- evaluation of this situation can be made. If implementation of the selected remedydemonstrates, in corroboration with hydrogeological and chemical evidence, that it will be technicallyimpracticable to achieve and maintain the remediation goals throughout the area of attainment, the EPA,in consultation with the Commonwealth of Pennsylvania, intends to amend the ROD or issue anExplanation of Significant Differences (ESD) to inform the public of alternative groundwater goals.
3. Modern commented that a waiver of the background water quality ARAR is appropriate based oninconsistent application of a State requirement.
EPA Response: EPA disagrees. While it is correct that an ARAR may be waived when it has beeninconsistently applied, the background ARAR has historically been applied in a consistent manner.
4. Modern commented on some inaccuracies in the Proposed Plan.
a. Modern commented that the Proposed Plan states that 362 acres of Modern Landfill is permitted andcurrently active; however, 362 acres are permitted, 17 acres are lined, another 17 acres are underconstruction and 66 acres, which are included in the CERCLA site, are unlined.
EPA Response: EPA agrees to this clarification.
b. Modern commented that the record should reflect that the landfill principally acceptednon-hazardous. municipal/residual waste.
EPA Response: EPA does not believe that sufficient data on past disposal practices exists to state thisdefinitively. EPA believes that the majority of the wastes appear to have been municipal wastes but theextent of their composition is not currently known to EPA.
c. Modern commented that the record should state that drums of PCBs were not disposed at the site butrather, the drums were removed from the Site for disposal elsewhere.
EPA Response: EPA agrees. The Record of Decision reflects this fact.
d. Modern commented that the proposed plan states as one of the goals of the remedial action therestoration of contaminated groundwater to beneficial uses. Modern further states that this was not agoal set forth in the Feasibility Study and is not appropriate for the Site.
EPA Response: EPA disagrees. EPA's policy is to restore groundwater to beneficial uses whereverpracticable. This goal, though not stated in the FS, is appropriate for the Modern Landfill Site.
e. Modern commented that the proposed plan discusses closure of the unlined landfill and installationof a cap in accordance with PADER regulation. Modern states that this should be clarified to state thatclosure and installation are in accordance with applicable PADER municipal solid waste regulations toavoid possible misinterpretations.
EPA Response: EPA agrees with this clarification.
f. Modern commented that the approximately $15 million in pre-1990 capital and operation andmaintenance costs spent by Modern Landfill for remedial actions to date should be included in the costof the alternative remedies discussed in the plan.
EPA Response: EPA disagrees. The pre-1990 costs are not part of the proposed remedial action.Furthermore, since these costs are common to all alternatives, the evaluation of alternatives is notconsidered to be inaccurate.
g. Modern commented that the proposed plan inaccurately describes the extent of the area to becovered upon completion of the low permeability cap and placement of the final cover over the site. Theplan states that these actions will cover the entire CERCLA site which, for the purpose of this record ofdecision, has been defined as the unlined 66-acre landfill and all Modern property up to and includingthe monitoring wells. The actual remedy provides for a cap and final cover over the unlined landfillonly.
EPA Response: EPA agrees with this description of the proposed remedy.
h. Modern states that in the section on Evaluation of Alternatives, the proposed plan should state thatthe potential risk from ingestion of groundwater is hypothetical.
EPA Response: EPA disagrees. The risk from ingestion of groundwater on the CERCLA Site is apotential one being addressed by this Record of Decision. The fact that a risk is potential does not makeit hypothetical.
5. Comments were received from Mr. James Smith, a resident near Modern Landfill.
a. Mr. Smith states that in 1988 Modern was drilling wells which were affecting the water level in Mr.Smith's well.
EPA Response: As a result of the Remedial Investigation for this site, it has been shown thatgroundwater flow is not in the direction of the Smith property. Mr. Smith presented no evidence todetermine that a causal relationship exists between the well pumping at Modern Landfill and the levelsin his wells. These facts notwithstanding, the proposed remedy will continue to monitor groundwaterand surface water at the site to ensure the effectiveness of the remedy and the protection of humanhealth and the environment.
b. Mr. Smith presented data to show that contaminants from beneath the CERCLA Site are not beingcontained.
EPA Response: There is no indication of the source of the data submitted nor the sampling and analysismethods used in the data gathering process. No inference can be made from this data, based on theRemedial Investigation, that contaminants from Modern Landfill are affecting off site wells. Theproposed remedy will, however, provide for continual monitoring and evaluation of the effectiveness ofthe extraction systems and allows for their augmentation if deemed necessary by EPA or PADER.
c. Mr. Smith commented that a major fault exist directly beneath the unlined landfill.
EPA Response: Mr. Smith's conclusion that the fault line lies directly beneath the landfill is based onpreliminary reports done before the commencement of the Remedial Investigation at the Site. Theinformation in those reports was updated and refined through subsequent investigations to show that thefault line in question is south of the Modern Landfill and not beneath it.
d. Mr. Smith commented that the public notice advertising the public meeting for the site was doneimproperly as the notice was placed with commercial advertising and not the legal notices and, as aresult, fewer people than expected attended the public meeting.
EPA Response: EPA disagrees. EPA followed its normal procedures for advertising public meetings. Inaddition, EPA mailed several hundred fact sheets after the public meeting to potentially interestedparties and offered to meet with representatives from each township and interested citizens to discusstheir concerns. EPA believes that the public was adequately notified and had ample time to providecomments on the proposed plan.
APPENDIX B
CONSENT DECREE
RECEIVEDUNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 111 JUL t 2 1993841 Chestnut Building
Philadelphia, Pennsylvania 19107-4431 MODEnN UNDflil
Mr. Mark Pedersen, Environmental EngineerModern Landfill and Recycling JUL 1 1993R.D. #9, Prospect RoadYork, PA 17402
Re: Modern Landfill Superfund SiteConsent Decree
Dear Mr. Pedersen:
ECOPYAs discussed with you on July 1, 1993, the Consent Decree
between EPA Region III and Modern Trash Removal of York, Inc.became effective on June 14, 1993. EPA now has legal authorityto approve technical work completed by Modern.
Unless changed since your letter of June 29, 1992, thisnotifies you of EPA's acceptance of SEC Donohue to prepare thedesign and provide the quality assurance/quality control for theproject, and Modern Landfill as the supervising contractor. Theproject manager for SEC Donohue will be Sharon Barreras, and youwill serve as the project coordinator. Keep in mind that inaccordance with Section VI. A. of the Consent Decree, you arerequired to notify EPA in writing of the names and qualificationsof any additional contractors to be used on this project, and toreceive EPA's acceptance of these additional selections.
This letter also confirms myself as the remedial projectmanager for EPA as required by Section XIII. A. and XXVII of theConsent Decree.
Please feel free to contact me at (215) 597-8186 if you haveany questions concerning this correspondence.
Sincerely,
Frank Klanchar (3HW24)Project Manager
cc: A. Dappolone, 3HW24P. Yeany, 3RC12A. Effiong, PADER
IN THE UNITED STATES DISTRICT COURTFOR THE MIDDLE DISTRICT OF PENNSYLVANIA
UNITED STATES OF AMERICA, ::
Plaintiff, : :
v. : Civil Action No. l-CV-92-0819: Harrisburg
MODERN TRASH REMOVAL OF : (Judge Caldwell)YORK, INC., :
:Defendant. :
MOTION FOR ENTRY OF CONSENT DECREE
Plaintiff, the United States of America hereby moves for entry of the Consent Decree
that has been filed simultaneously with this motion.
The Consent Decree is a revised version of a consent decree that Plaintiff lodged with
this Court on June 16, 1992 ("the original decree"). On that date, the United States also filed its complaint in
this action, the allegations of which would be resolved by entry of the Consent Decree.
Pursuant to Department of Justice policy, 28 C.F.R. § 50.7, and Section 122(d)(2) of
the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), 42 U.S.C. §
9622(d)(2), Plaintiff caused a notice of the lodging of the original decree to be published in the Federal
Register. The notice provided that the United States Department of Justice would receive comments relating
to the proposed Consent Decree for a thirty-day period, which period expired on August 1, 1992- On that
date, the Department of Justice received comments from the Commonwealth of Pennsylvania Department of
Environmental Resources ("the Commonwealth"). No other comments were submitted. On August 1, 1992,
The Commonwealth also filed with the Court a Motion to Intervene and a Complaint in Intervention.
There ensued a period of negotiation between Plaintiff and the Commonwealth in an
effort to resolve the issues raised in the Commonwealth's comments and proposed
complaint-in-intervention. To facilitate these efforts, on September 9, 1992 and September 28, 1992, the
Court granted the parties' motions extending the time for Plaintiff to respond to the Commonwealth's
-2-
motion. On December 1, 1992, the Court granted the Commonwealth's motion for intervention for the
limited purpose of opposing the original decree on the grounds set forth in its proposed complaint, and
stayed proceedings for sixty days.
On February 2, 1992, Plaintiff submitted to the Court a Status Report to apprise the
Court of the resolution of the Commonwealth's objections to the original decree. We further reported that
we would circulate a revised consent decree for signature by the parties and submit it to the Court, along
with a motion for entry.
The Consent Decree filed simultaneously with this motion embodies the revisions
that have been agreed to by Plaintiff, Defendant, and the Commonwealth. It is otherwise is substantively
identical to the original decree. To resolve the concerns addressed in the Commonwealth's First Cause of
Action regarding the Commonwealth's authority over Modern Landfill, the parties agreed to revisions to
Section XV. A of the Consent Decree and addition of a new Section XXXV to the Consent Decree. To
resolve the concerns addressed in the Commonwealth's Second Cause of Action regarding notice to the
Commonwealth of important events occurring under the Consent Decree, the parties agreed to revisions to
several provisions (Sections XV. B, XIX. B, XX. B, and VIII. B) that will provide the Commonwealth with
the notices and opportunity for comment that it has sought.
Since the concerns raised by the Commonwealth have been resolved, and since no
person other than the Commonwealth submitted any comments on the original decree, the United States
believes that entry of the Consent Decree is in the public interest. The United States therefore requests that
the Court execute and enter the Consent Decree that accompanies this motion.
The Commonwealth has authorized us to represent that it concurs in this motion, and
that it intends to file a notice of voluntary dismissal of its complaint-in-intervention upon entry of the
Consent Decree. As indicated by the attached Certificate of Concurrence, counsel for Defendant Modern
Trash Removal of York also concurs in this motion.
-3-
Respectfully submitted,
MYLES E. FLINT Acting Assistant Attorney General Environment and Natural Resources Division U.S. Department of Justice
BY: ____________________________________DAVID ROSSKAM Environmental Enforcement Section U. S. Department of Justice P. O. Box 7611 Ben Franklin Station Washington, D.C. 20044 (202) 514-3974
WAYNE P. SAMUELSON United States Attorney
ROBERT R. LONG, JR. Assistant United States Attorney P.O. Box 11754 Harrisburg, Pennsylvania 17108
OF COUNSEL:
PHILIP YEANY Assistant Regional Counsel U.S. EPA - Region III 841 Chestnut Building Philadelphia, Pennsylvania 19107
-4-
CERTIFICATE OF CONCURRENCE
I hereby certify that I have consulted with counsel for Defendant, Modern TrashRemoval of York, Inc., and with counsel for Intervenor, the Commonwealth of Pennsylvania Department ofEnvironmental Resources, and that they have advised me that they concur in the foregoing Motion for Entryof Consent Decree.
__________________________________DAVID ROSSKAM Trial Attorney Environmental Enforcement Section U.S. Department of Justice Ben Franklin StationP.O. Box 7611 Washington, D.C. 20044
-5-
CERTIFICATE OF SERVICE
I hereby certify that I have caused to be served the foregoing Motion for Entry ofConsent Decree via regular mail, postage prepaid, on June 10, 1993 to:
Martin Siegel Assistant Counsel Commonwealth of Pennsylvania Department of Environmental Resources 400 Market Street, 9th Floor Harrisburg, Pennsylvania 17105
Andrew S. Levine Region Environmental Counsel Waste Management of North America, Inc. Three Greenwood Square 3329 Street Road Bensalem, Pennsylvania 19020
Gregory H. Knight Hetrick, Zaleski, Ernico & Pierce, P.C. 10 South Market Square, Suite 500 P. O. Box 1265 Harrisburg, Pennsylvania 17108-1265
_________________________DAVID ROSSKAM Trial Attorney Environmental Enforcement Section U.S. Department of Justice Ben Franklin Station P. O. Box 7611 Washington, D.C. 20044
IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA
__________________________________________UNITED STATES OF AMERICA )
)Plaintiff, ) CIVIL ACTION NO.
)v. )
) Modern Trash Removal of York, Inc. )
)Defendant )
)__________________________________________)
- ii -
TABLE OF CONTENTS
I. BACKGROUND . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
II. JURISDICTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
III. PARTIES BOUND . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
IV. DEFINITIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
V. GENERAL PROVISIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
VI. PERFORMANCE OF THE WORK BY SETTLING DEFENDANTS . . . . . . . . . . . 15
VII. ADDITIONAL RESPONSE ACTIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24
VIII. U.S. EPA PERIODIC REVIEW . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26
IX. QUALITY-ASSURANCE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27
X. ACCESS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32
XI. REPORTING REQUIREMENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34
XII. SUBMISSIONS REQUIRING AGENCY APPROVAL; STATE REVIEW AND COMMENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37
XIII. PROJECT COORDINATOR/REMEDIAL PROJECT MANAGER . . . . . . . . . . . . 39
XIV. ASSURANCE OF ABILITY TO COMPLETE WORK . . . . . . . . . . . . . . . . . . . . . 41
XV. CERTIFICATION OF COMPLETION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42
XVI. EMERGENCY RESPONSE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45
XVII. REIMBURSEMENT OF RESPONSE COSTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . 47
XVIII. INDEMNIFICATION AND INSURANCE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 51
XIX. FORCE MAJEURE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54
XX. DISPUTE RESOLUTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 57
XXI. STIPULATED PENALTIES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 61
XXII. COVENANTS NOT TO SUE BY PLAINTIFFS . . . . . . . . . . . . . . . . . . . . . . . . . . 65
XXIII. COVENANTS BY SETTLING DEFENDANTS . . . . . . . . . . . . . . . . . . . . . . . . . . 69
- iii -
XXIV. EFFECT OF SETTLEMENT; CONTRIBUTION PROTECTION . . . . . . . . . . . . . 70
XXV. ACCESS TO INFORMATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 72
XXVI. RETENTION OF RECORDS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 74
XXVII. NOTICES AND SUBMISSIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 75
XXVIII. EFFECTIVE DATE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 76
XXIX. RETENTION OF JURISDICTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 76
XXX. APPENDICES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 77
XXXI. COMMUNITY RELATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 77
XXXII. MODIFICATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 77
XXXIII. LODGING AND OPPORTUNITY FOR PUBLIC COMMENT . . . . . . . . . . . . . . . 78
XXXIV. SIGNATORIES/SERVICE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 79
IN THE UNITED STATES DISTRICT COURTFOR THE EASTERN DISTRICT OF PENNSYLVANIA
UNITED STATES OF AMERICA )
Plaintiff, )) CIVIL ACTION NO.
v. )
Modern Trash Removal of, )York, Inc. )
Defendant )
CONSENT DECREE
I. BACKGROUND
A. The United States of America ("United States"), on
behalf of the Administrator of the United States Environmental
Protection Agency ("EPA"), filed a complaint in this matter
pursuant to Sections 106, 107 and 113(b) of the Comprehensive
Environmental Response, Compensation, and Liability Act
("CERCLA"), 42 U.S.C. SS 9606, 9607 and 9613(b).
B. The United States in its complaint seeks:
(1) reimbursement of costs incurred by EPA and the United States
Department of Justice for response actions at the Modern Landfill
Superfund Site (as defined below) in York County, Pennsylvania,
together with accrued interest; (2) performance of response work
by the Defendant at the Site in conformity with the Record of
Decision (as defined below) and the National Oil and Hazardous
Substances Pollution Contingency Plan, 40 C.F.R. Part 300 (as
3
amended) ("NCP"); (3) a declaration of Defendant's liability for
further response costs; and (4) such other relief as the Court
finds appropriate.
C. In accordance with the NCP and Section 121(f)(i)(F) of
CERCLA, 42 U.S.C. § 9621(f)(1) (F), EPA notified the Commonwealth
of Pennsylvania (the "Commonwealth") on October 16, 1991 of
negotiations with potentially responsible parties regarding the
implementation of remedial activities for the Site, and EPA has
provided the Commonwealth with an opportunity to participate in
such negotiations and be a party to this settlement.
D. In accordance with Section 122(j)(l) of CERCLA, 42
U.S.C. § 9622(j)(l), EPA notified the Department of the Interior
on October 17, 1991, and the National Oceanic and Atmospheric
Administration on October 7, 1991 of negotiations with
potentially responsible parties regarding the release of
hazardous substances that may have resulted in injury to the
natural resources under Federal trusteeship and encouraged the
trustees to participate in the negotiation of this Consent
Decree.
E. The Defendant who has entered into this Consent Decree
("Settling Defendant") does not admit any liability to the
Plaintiff arising out of the transactions or occurrences alleged
in the complaint.
F. Pursuant to Section 105 of CERCLA, 42 U.S.C. § 9605, EPA
placed the Site on the CERCLA National Priorities List, set forth
4
at 40 C.F.R. Part 300, Appendix B, by publication in the Federal
Register on June 10, 1986, 51 Fed. Reg. 21054.
G. In response to a release or a substantial threat of a
release of a hazardous substance(s) at or from the Site, the
Modern Trash Removal of York, Inc. ("Modern") commenced on
November 4, 1987, a Remedial Investigation and Feasibility Study
("RI/FS") for the Site pursuant to the NCP.
H. Modern completed a Remedial Investigation ("RI") Report
on May 9, 1990, and completed a Draft Feasibility Study ("FS")
Report on December 18, 1990. EPA's and PADER'S comments thereto
were served on Modern on March 1, 1991.
I. Pursuant to Section 117 of CERCLA, 42 U.S.C. § 9617, EPA
published notice of the completion of the Draft FS, and of EPA's
and PADER'S comments thereto, and of the proposed plan for
remedial action on April 14, 1991, in a major local newspaper of
general circulation, the York Dispatch. EPA provided an
opportunity for written and oral comments from the public on the
proposed remedial action. A copy of the transcript of the public
meeting is available to the public as part of the Administrative
Record upon which the Regional Administrator based the selection
of the response action.
J. The decision by EPA on the remedial action and operation
and maintenance to be implemented at the Site is embodied in a
final Record of Decision ("ROD"), executed on June 30, 1991, on
which the State has given its concurrence. The ROD also includes
a summary of responses to the public comments. Notice of the
6
b. installation of additional extraction wells to
ensure capture of groundwater flowing to the north;
c. continued operation and maintenance o-f the
following:
1.) the PADER-approved low permeability cap
and cover system;
2.) the groundwater extraction systems;
3.) the on-Site wastewater-treatment facility;
4.) the vapor extraction system; and
5.) the surface water/groundwater monitoring
system.
M. Since the date of the signing of the ROD, Modern has
accomplished the following:
a. Completion of the design for the final 4 acres of
the landfill cap and final cover system (including PADER-
approval);
b. Construction of the additional extraction wells
required by the ROD.
N. EPA has determined that the remaining work required by
the ROD consists of the following:
a. Completion of the construction of the final 4 acres
of the landfill cap and final cover system;
b. Operation and Maintenance of the remedial actions
previously completed, and those to be completed under this
Decree. These include: the entire landfill cap and final cover
system; the entire groundwater extraction systems; on-Site
7
wastewater treatment facility; vapor extraction system; and,
surface water/groundwater monitoring network. To that end, the
work and activities described in Section VI of this Consent
Decree are required to be performed by the Settling Defendant
under this Decree.
O. Based on the information presently available to EPA ,
EPA believes that the Work as defined below will be properly and
promptly conducted by the Settling Defendant.
P. The Remedial Action selected by the ROD and the Work to
be performed by the Settling Defendant shall constitute a
response action taken or ordered by the President solely for_the
purposes of Section 113(j) of CERCLA, 42 U.S.C. § 9613(j).
Q. The Parties recognize, and the Court by entering this
Consent Decree finds, that implementation of this Consent Decree
will expedite the cleanup of the Site and will avoid prolonged
and complicated litigation between the Parties, and that this
Consent Decree is fair, reasonable, and in the public interest.
NOW, THEREFORE, it is hereby Ordered, Adjudged, and Decreed:
II. JURISDICTION
A. This Court has jurisdiction over the subject matter of
this action pursuant to 28 U.S.C. SS 1331 and 1345, and 42 U.S.C.
§§ 9606, 9607, and 9613(b). This Court also has personal
jurisdiction over the Settling Defendant. Solely for the
purposes of this Consent Decree and the underlying complaint,
8
Settling Defendant waives all objections and defenses that it na
have to jurisdiction of the Court or to venue in this
District. Settling Defendant shall not challenge the terms of
this Consent Decree or this Court's jurisdiction to enter and
enforce this Consent Decree.
III. PARTIES BOUND
A. This Consent Decree applies to and is binding upon the
United States and upon the Settling Defendant and their heirs,
agents, successors and assigns. Any change in ownership or
corporate status of the Settling Defendant including, but not
limited to, any transfer of assets or real or personal property
shall in no way alter such Settling Defendant's responsibilities
under this Consent Decree.
B. Settling Defendant shall provide a copy of this Consent
Decree to each contractor hired to perform the Work (as defined
below) required by this Consent Decree and to each person
representing the Settling Defendant with respect to the Site or
the Work and shall condition all contracts entered into hereunder
upon performance of the Work in conformity with the terms of this
Consent Decree. Settling Defendant or its contractors shall
provide written notice of the Consent Decree to all
subcontractors hired to perform any portion of the Work required
by this Consent Decree. Settling Defendant shall nonetheless be
responsible for ensuring that its contractors and subcontractors
perform the Work contemplated herein in accordance with this
9
Consent Decree. With regard to the activities undertaken
pursuant to this Consent Decree, each contractor and
subcontractor shall be deemed to be in a contractual relationship
with the Settling Defendant within the meaning of Section
107(b)(3) of CERCLA, 42 U.S.C. § 9607(b)(3).
IV. DEFINITIONS
A. Unless otherwise expressly provided herein, terms used
in this Consent Decree which are defined in CERCLA or in
regulations promulgated under CERCLA shall have the meaning
assigned to them in CERCLA or in such regulations. Whenever
terms listed below are used in this Consent Decree or in the
appendices attached hereto and incorporated hereunder, the
following definitions shall apply:
1. "CERCLA" shall mean the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980, as amended, 42
U.S.C. §§ 9601 et sea.
2. "Consent Decree" shall mean this Decree and all
appendices attached hereto. In the event of conflict between
this Decree and any appendix, this Decree shall control.
3. "Construction Completion and Quality Assurance Plan"
(CCQAP) shall mean a plan for the completion of the construction
of the remaining 4 acres of landfill cap, submitted by the
Settling Defendant and approved by EPA pursuant to Section VLB.
of this Consent Decree.
4. "Day" shall mean a calendar day unless expressly stated
10
to be a working day. "Working day" shall mean a day other than j.
Saturday, Sunday, or Federal holiday. In computing any period of
time under this Consent Decree, where the last day would fall on
a Saturday, Sunday, or Federal holiday, the period shall run
until the close of business of the next working day.
5. "Duly Authorized Representative" shall mean a person
designated in accordance with the procedures set forth in 40
C.F.R. § 270.11(b).
6. "EPA" shall mean the United States Environmental
Protection Agency and any successor departments or successor
agencies of the United States.
7. "PADER" shall mean the Pennsylvania Department of
Environmental Resources and any successor departments or agencies
of the State.
8. "Future Response Costs" shall mean all costs, including,
but not limited to, indirect costs, that the United States incurs
in overseeing the Work, including, but not limited to, payroll
costs, contractor costs, travel costs, laboratory costs, the
costs incurred pursuant to Section X (Access) and Section XVI.A
(Emergency Response), costs incurred by the United States in
connection with any periodic review conducted pursuant to Section
VIII of this Consent Decree (U.S. EPA Periodic Review), and the
costs of reviewing or developing plans, reports and other items
pursuant to this Consent Decree, verifying the Work, or otherwise
implementing or enforcing this Consent Decree. Response Costs
shall also include all costs, including indirect costs, incurre
12
standards, standards of control, and other substantive
requirements, criteria or limitations that are used to determine
whether the objectives of the ROD and this Consent Decree are
being achieved and that are set forth in Appendix C.
16. "Plaintiff" shall mean the United States .
17. "Record of Decision" or "ROD" shall mean the EPA Record
of Decision relating to the Site set forth in Appendix A hereto
and signed on June 30, 1991, by the Regional Administrator, EPA
Region III, and all attachments thereto.
18. "Remedial Action" shall mean all activities, as defined
by Section 101(24) of CERCLA, 42 U.S.C. S__9601(24), except for
Operation and Maintenance, to be undertaken by the Settling
Defendant to implement both the ROD and the Construction Quality
Assurance Plan (CCQAP) submitted by the Settling Defendant
pursuant to the Consent Decree and approved by EPA.
19. "Remedial Operation and Maintenance Plan" (ROMP) shall
mean a plan for the Operation and Maintenance of the remedy as
specified in the ROD, submitted by the Settling Defendant and
approved by EPA pursuant to Section VLB. of this Consent Decree.
20. "Section" shall mean a portion of this Consent Decree
identified by a roman numeral.
21. "Settling Defendant" shall mean Modern Trash Removal of
York, Inc.
22. "Site" shall mean the Modern Landfill Superfund Site,
encompassing approximately 362 acres, located adjacent to
Prospect Road, approximately one-half mile south of Route 124 in
13
the Townships of Windsor and Lower Windsor, York County,
Pennsylvania and depicted more particularly on the map attached
as Appendix B.
23. "State" shall mean the Commonwealth of Pennsylvania.
24. "Supervising Contractor" shall mean the contractor
retained by the Settling Defendant to carry out the Work under
this Consent Decree and accepted by EPA pursuant to Section VI.A.
25. "United States" shall mean the United States of America.
26. "Waste Material" shall mean (1) any "hazardous
substance" under Section 101(14) of CERCLA, 42 U.S.C. § 9601(14);
and (2) any pollutant or contaminant under Section 101(33) of
CERCLA, 42 U.S.C. § 9601(33).
27. "Work" shall mean all activities Settling Defendant is
required to perform under this Consent Decree, except those
required by Section XXVI (Retention of Records).
V. GENERAL PROVISIONS
A. Objectives of the Parties
The objectives of the Parties in entering into this Consent
Decree are to protect public health and welfare and the
environment from releases or threatened releases of Waste
Material from the Site by the construction of 4 acres of PADER-
approved cap as set forth in the ROD and the CCQAJ" and operation
& Maintenance at the Site as set forth in the ROMP by the
Settling Defendant and to reimburse response costs of the
Plaintiff.
14
B. Commitments by Settling Defendant
1. Settling Defendant shall finance and perform the
Work in accordance with CERCLA, the NCP and this Consent Decree,
including, but not limited to, Appendix C of the ROD, and all
standards, specifications, and schedules set forth in or
developed pursuant to this Consent Decree. Settling Defendant
shall also reimburse the United States for Past Response Costs
and Future Response Costs as provided in this Consent Decree.
2. The obligation of Settling Defendant to finance and
perform the Work and to pay amounts owed the United States under
this Consent Decree is joint and several.
C. Compliance With Applicable Law
All activities undertaken by the Settling Defendant pursuant
to this Consent Decree shall be performed in accordance with the
requirements of all applicable federal and state laws and
regulations. The United States has determined that the
activities conducted pursuant to this Consent Decree, if approved
by EPA, shall be considered to be consistent with the NCP.
D. Permits
1. As provided in Section 121(e) of CERCLA, 42 U.S.C.
§ 962l(e), and 40 C.F.R. S 300.430(e), no permits shall be
required for any portion of the Work conducted entirely on-Site.
However, the Settling Defendant shall ensure that all portions of
the Work on the Site shall meet the substantive requirements of
any applicable or relevant and appropriate requirement subject to
EPA's right of review and approval. Where any portion of the
15
off-site Work requires a federal, state or local permit or
approval, Settling Defendant shall timely submit complete
applications and take all other actions necessary to obtain all
such permits or approvals.
2. The Settling Defendant may seek relief under the
provisions of Section XIX (Force Majeure) of this Consent Decree
for any delay in the performance of the off-Site Work resulting
from a failure to obtain, or a delay in obtaining, any permit
required for the Work, provided they have submitted all required
information in a timely manner.
3. This Consent Decree is not, and shall not be
construed to be, a permit issued pursuant to any federal, state
or local statute, regulation or ordinance.
VI. PERFORMANCE OF THE WORK BY SETTLING DEFENDANTS
PERFORMANCE OF THE WORK BY SETTLING DEFENDANTS
A. Selection of Contractors
1. All aspects of the Work to be performed by the
Settling Defendant pursuant to Sections VI (Performance of the
Work by Settling Defendant), VII (Additional Response Actions),
VIII (U.S. EPA Periodic Review), IX (Quality Assurance, Sampling
and Data Analysis) and XVI (Emergency Response) of this Consent
Decree shall be under the direction and supervision of the
Supervising Contractor, the selection of which shall be subject
to acceptance or disapproval by EPA. Within 10 days after the
lodging of this Consent Decree, Settling Defendant shall notifi
16
EPA in writing of the name, title, and qualifications of any
contractor proposed to be the Supervising Contractor. If at any
time thereafter, Settling Defendant proposes to change a
Supervising Contractor, Settling Defendant shall give such notice
to EPA and shall obtain acceptance from EPA before the new
Supervising Contractor performs, directs, or supervises any Work
under this Consent Decree.
2. EPA will notify Settling Defendant in writing of its
acceptance or disapproval of a proposed Supervising Contractor.
If EPA disapproves of the selection of any contractor as
Supervising Contractor, Settling Defendant shall submit to EPA
the names of at least three contractors, including the
qualifications of each contractor, that would be acceptable to
them within 30 days of receipt of EPA's disapproval of the
contractor previously selected. EPA will provide written notice
of the names of the contractor(s) that it accepts. Settling
Defendant may select any accepted contractor from that list and
shall notify EPA of the name of the contractor selected within 21
days of EPA's designation of accepted contractors.
3. The Settling Defendant shall submit to EPA for
acceptance the names and qualifications of any additional
contractors and subcontractors that may be used to perform the
Work required by this Decree. The Settling Defendant shall
provide a Professional Engineer to be present at the Site during
construction to ensure that the Work is performed in accordance
with the previously approved (See Section VI. A. 1.) documents.
17
EPA retains the right to disapprove any additional contractors
and subcontractors selected to perform the Work. Within fourteen
(14) days of receipt by EPA of the names of the additional
contractors or subcontractors, EPA will notify Settling Defendant
of its acceptance or disapproval of the selected additional
contractors or subcontractors. If EPA disapproves any additional
contractor or subcontractor, Settling Defendant may submit
further information to EPA giving reasons why the additional
contractor or subcontractor should be accepted. Within fourteen
(14) days of the receipt of the notice of disapproval, Settling
Defendant shall notify.the United States of the name and
qualifications of a replacement additional contractor or
subcontractor. If at any time during the pendency of this
Consent Decree a decision is made by Settling Defendant to retai..
a substitute additional contractor or subcontractor, selection of
the substitute shall be governed by the provisions of this
Paragraph. If EPA fails to provide notice of its acceptance or
disapproval of any additional contractor or subcontractor as
provided in this Paragraph and this failure prevents the Settling
Defendant from meeting one or more deadlines in a plan approved
by EPA pursuant to this Consent Decree, Settling Defendant may
seek relief under the provisions of Section XIX (Force Majeure)
of this Consent Decree.
18
B. Performance of the Work -
1. Remedial Action/Completion of Landfill Cap -
a.) Within 14 days after the effective date of this Consent
Decree, the Settling Defendant shall submit to EPA for approval a
Construction Quality Assurance Plan (CCQAP) for the
implementation of the remedial actions required by the ROD. The
CCQAP shall include all plans, schedules, and methodologies to be
used in completing the construction of all remedial actions
required by the ROD. The CCQAP shall include, but not be limited
to: (1) a remedial action construction plan and schedule; (2) a
Health and Safety Plan for any field activities; and (3) a
schedule for completion of project milestones and submission of
reports to EPA.
b.) Upon approval of the CCQAP by EPA, the CCQAP shall be
incorporated into and become enforceable under this Consent
Decree. The Settling Defendant shall implement the plan in
accordance with the schedules and methodologies contained
therein. The Settling Defendant shall submit all plans,
submittals, and other deliverables required in accordance with
the approved schedule therein for review and approval pursuant to
Section XII (Submissions Requiring Agency Approval).
2. Continued Operation and Maintenance of Existing
Remedial Actions -
A. Within 14 days after the effective date of this Consent
Decree, the Settling Defendant shall submit to EPA for approval a
Remedial Operation and Maintenance Plan (ROMP). This plan shall
19
provide for the continued operation and maintenance of all
remedial actions required by the ROD that have been previously
designed and constructed by the Settling Defendant and those
remaining to be performed pursuant to this Consent Decree. The
ROMP shall include, but not be limited to: (1) a Sampling and
Analysis Plan (SAP) or Groundwater Monitoring and Sampling Plan,
prepared in accordance with Section IX; (2) a Health and Safety
Plan for any field activities; (3) an Operation and Maintenance
Plan for the existing and ongoing remedial actions; and (4) a
schedule for completion of project milestones and submission of
reports to EPA.
B. Upon approval of the ROMP by EPA the ROMP shall be
incorporated into and become enforceable under this Consent
Decree. The Settling Defendant shall implement the plan in
accordance with the schedules and methodologies contained
therein. The Settling Defendant shall submit all plans,
submittals, and other deliverables required in accordance with
the approved schedule therein for review and approval pursuant to
Section XII (Submissions Requiring Agency Approval; State Review
and Comment).
C. The Work performed by the Settling Defendant pursuant to
this Consent Decree shall, at a minimum, achieve the Performance
Standards as set forth in Appendix C.
D. Settling Defendant acknowledges and agrees that nothing
in this Consent Decree, the Description of Selected Remedy and
Performance Standards, Appendix £, or the Construction Quality
20
Assurance Plan (CCQAP) or Remedial Operation and Maintenance Plan
(ROMP) constitutes a warranty or representation of any kind by
Plaintiff that compliance with the work requirements in the
Description of Selected Remedy and Performance Standards, set
forth in Appendix C, and the CCQAP and ROMP will achieve the
Performance Standards as set forth in Appendix C. Such
compliance shall not foreclose Plaintiff from seeking compliance
with all terms and conditions of this Consent Decree, including,
but not limited to, the applicable Performance Standards.
E. Settling Defendant shall, prior to any off-Site shipment
of Waste Material from the Site to an out-of-state waste
management facility, provide written notification to the
appropriate state environmental official in the receiving
facility's state and to the EPA Remedial Project Manager of such
shipment of Waste Material. However, this notification
requirement shall not apply to any off-Site shipment when the
total volume of all such shipments will not exceed 10 cubic
yards.
1. The Settling Defendant shall include in the written
notification the following information, where available: (a) the
name and location of the facility to which the Waste Materials
are to be shipped; (b) the type and quantity of the Waste
Materials to be shipped; (c) the expected schedule for the
shipment of the Waste Materials; and (d) the method of
transportation. The Settling Defendant shall notify the state in
which the planned receiving facility is located of major changes
21
in the shipment plan, such as a decision to ship the Waste
Materials to another facility within the same state, or to a
facility in another state.
2. The identity of the receiving facility and state
will be determined by the Settling Defendant. The Settling
Defendant shall provide the written notification required by this
Section VI. E, including the information required by Paragraph
E.I as soon as practicable, but in no case less than 14 days
before the Waste Materials are actually shipped.
F-. In the event EPA determines that the Settling Defendant have
failed to implement any provisions of the Work in an adequate or
timely manner, EPA may perform any and all portions of the Work
as EPA determines necessary. Settling Defendant may dispute
EPA's determination that the Settling Defendants failed to
implement a provision of the Work in an adequate or timely
manner, only by invoking the procedures set forth in Section XX
(Dispute Resolution). Such dispute shall be resolved on the
administrative record. Costs incurred by the United States in
performing the Work pursuant to this Paragraph shall be
considered Future Response Costs for the purposes of Section XVII
(Reimbursement of Response Costs).
VII. ADDITIONAL RESPONSE ACTIONS
A. In the event that EPA or the Settling Defendant
determines that additional response actions are necessary to meet
the Performance Standards or to carry out the remedy
23
VII.B or C and to submit written comments for the record during
the public comment period. After the period for submission of
written comments is closed, the Regional Administrator, EPA
Region III, or his/her delegate will determine in writing whether
additional response actions are appropriate.
E. Settling Defendant may invoke the procedures set forth
in Section XX (Dispute Resolution) to dispute EPA's determination
that additional response actions are necessary to meet the
Performance Standards or to carry out the remedy selected in the
ROD. Such a dispute shall be resolved pursuant to Section XX.B
through D of this Consent Decree.
VIII. P. 8. EPA PERIODIC REVIEW
A. Settling Defendant shall conduct any studies and
investigations as requested by EPA in order to permit EPA to
conduct reviews at least every five years as required by Section
121(c) of CERCLA, 42 U.S.C. § 9621(c), and any applicable
regulations.
B. If required by Sections 113(k)(2) or 117 of CERCLA, 42
U.S.C. §§ 9613(k)(2) or 9617, or the NCP, Settling Defendant and
the public will be provided with an opportunity to comment on any
additional response actions proposed by EPA as a result of the
review conducted pursuant to Section 121(c) of CERCLA, 42 U.S.C.
§ 9621(c), and to submit written comments for the record during
the public comment period. After the period for submission of
written comments is closed, the Regional Administrator, EPA
25
Settling Defendants) and XII (Submissions Requiring Agency
Approval; State Review and Comment) and, upon approval of such
plans by EPA, shall complete the additional response action in
accordance with such plans and any schedules contained therein.
IX. QUALITY ASSURANCE
A. While conducting all sample collection and analysis
activities required by this Consent Decree, the Settling
Defendant shall implement quality assurance, quality control and
chain of custody procedures in accordance with "Guidance for
Conducting Remedial Investigations and Feasibility Studies under
CERCLA", 1988 (OSWER Directive 9355.3-01); "EPA NEIC Policies and
Procedures Manual", May 1978, revised May 1986 (EPA 330/978-001-
R); "Interim Guidelines and Specifications for Preparing Quality
Assurance Project Plans", December 1980 (QAMS 005/80); "A
Compendium of Superfund Field Operations Methods", December 1987
(OSWER Directive 9355.0-14) "Data Quality Objectives for Remedial
Response Activities", March 1987 (OSWER Directive 9355.0-7B);
EPA's "Guidelines and Specifications for Preparing Quality
Assurance Program Documentation", June 1, 1987; and amendments to
these guidelines.
B. The Settling Defendant shall consult with EPA in
planning for, and prior to, all sampling and analysis required by
this Consent Decree, and any subsequent EPA-approved plans
prepared as part of this Consent Decree. Further,the Settling
Defendant shall not commence sampling until EPA approves the
26
Remedial Operation and Maintenance Plan (ROMP) and the Sampling
and Analysis Plan (SAP). Notwithstanding the prior sentence
Settling Defendant may continue to adhere to the terms of permit
number 100113, issued by the PADER on December 12, 1990.
C. In order to provide quality assurance and maintain
quality control regarding all samples collected pursuant to this
Consent Decree, the Settling Defendant shall:.
1. Submit to the EPA Remedial Project Manager the
selected laboratory's(ies') Quality Assurance Program Plan (QAPP)
and their qualifications, which shall include, at a minimum,
previous certifications, Performance Evaluation (PE) results,
equipment lists and personnel resumes. The SAP must state that
all protocols described therein take precedence over protocols
listed in the Laboratory QAPP.
2. Ensure that EPA personnel and/or its authorized
representatives are allowed reasonable access to the
laboratory(ies), records and personnel utilized by the Settling
Defendants in implementing this Consent Decree.
3. Prepare a SAP, consisting of a Quality Assurance
Project Plan (QAPjP) and a Field Sampling Plan (FSP), for sample
collection, transportation, analysis, validation and reporting to
be conducted pursuant to this Consent Decree. The SAP shall be
submitted as part of the ROMP to the EPA Remedial Project Manager
for review and approval prior to commencing sampling and
analysis. Each plan shall specify, for the phase of activity
addressed sample collection and transportation procedures, data
27
analysis methods, data reduction, data review, and reporting
procedures. Selection of analytical methods shall be justified in
SAP component of the ROMP The guidelines referenced in
Paragraph (A), above, shall be followed in the preparation of the
SAP; additional guidance may be provided by EPA when applicable
and/or requested by the Settling Defendant.
4. Ensure that the laboratory(ies) analyzing samples
pursuant to this Consent Decree uses appropriate methods. If EPA
Contract Lab Program (CLP) methods are selected, the
laboratory(ies) shall use these methods and submit deliverables
delineated in the current "Statement of Work of the EPA Contract
Lab Program." If non-CLP methods are selected, all constituents
and physical parameters shall be analyzed using methods that are
specified (method and reference) and justified in the SAP. Non-
CLP methods shall be fully described in the QAPjP and approved by
the EPA Remedial Preject Manager prior to conducting any sampling
and analysis. This description shall include, at a minimum, the
matrix, calibration, Quality Control (QC) samples (type and
frequency), corrective measures, and deliverables.
5. Ensure that the laboratory(ies) analyzing samples
pursuant to this Consent Decree agrees to demonstrate its
capability to perform the selected analyses by analyzing PE
samples, supplied by EPA. Analysis of PE samples may be waived
by EPA if the laboratory(ies) satisfactorily analyzed PE samples
using the selected methods within the six (6) months prior to
analysis conducted pursuant to this Consent Decree.
29
assurance data validation reports shall be prepared using EPA
Region III format (available from the QA Branch) and shall be
submitted, along with the validated data summary sheets and the
laboratory sample results, to the EPA Remedial Project Manager.
D. At the request of EPA, the Settling Defendant shall
allow split or duplicate samples to be taken by EPA, and/or its
authorized representatives, of any samples collected by the
Settling Defendant pursuant to this Consent Decree. The Settling
Defendant shall notify EPA not less than thirty (30) days in
advance of any such sample collection activity by setting forth
the sampling schedule in the SAP. The Settling Defendant shall
notify EPA of all proposed changes to the EPA approved sampling
schedule included in the SAP. All proposed sampling changes
shall be governed by the procedures set forth in Section XXXII of
this Consent Decree. In addition, EPA shall have the right to
take any additional samples that EPA deems appropriate. At the
request of the Settling Defendant, EPA shall allow split and/or
duplicate samples to be taken by the Settling Defendant and/or
their authorized representatives of any sample collected by EPA
pursuant to this Consent Decree.
E. Within seven days of a request by EPA, Settling
Defendant shall submit to EPA 3 copies of the results of any
sampling and/or test or other data obtained or generated by or on
behalf of the Settling Defendant pursuant to this Consent Decree
and requested by EPA .
F. Notwithstanding any provision of this Consent Decree,
30
the United States hereby retains all of its information
gathering, inspection and enforcement authorities and rights
under CERCLA, RCRA and any other applicable statute or
regulation.
X. ACCESS
A. Commencing upon the date of lodging of this Consent
Decree, and to the extent the property is owned or access to the
property is controlled by Settling Defendant, the Settling
Defendant agrees that the United States and its representatives,
including EPA and its contractors, shall have access at all times
to the Site and any other property to which access is required
for the implementation of this Consent Decree, for the purposes
of conducting any activity related to this Consent Decree
including, but not limited to:
1. Monitoring the Work;
2. Verifying any data or information submitted to the
United States;
3. Conducting investigations relating to contamination
at or near the Site;
4. Obtaining samples;
5. Assessing the need for, planning, or implementing
additional response actions at or near the Site;
6. Inspecting and copying records, operating logs,
contracts, or other documents maintained or generated by Settling
Defendant or their agents consistent with Section XXV (Access t'
31
Information); and
7. Assessing Settling Defendant's compliance with
this Consent Decree.
B. Notwithstanding any provision of this Consent Decree,
the United States retains all of its access authorities and
rights, including enforcement authorities related thereto, under
CERCLA, RCRA and any other applicable statute or regulations.
XL REPORTING REQUIREMENTS
A. In addition to any other requirement of this Consent
Decree, Settling Defendant shall submit to EPA and the
Commonwealth three (3) copies each of a written monthly progress
report during any and all remedial construction identified in the
CCQAP not completed at the time of lodging of this Decree that:
(1) describes the actions which have been taken toward achieving
compliance with this Consent Decree during the previous month;
(2) includes all results of sampling and tests and all other data
received or generated by Settling Defendant or their contractors
or agents in the previous month; (3) identifies all work plans,
plans and other deliverables required by this Consent Decree
completed and submitted during the previous month; (4) describes
all actions, including, but not limited to, data collection and
implementation of work plans, which are scheduled for the next
month and provide other information relating to the progress of
32
construction, including, but not limited to, critical path
diagrams, Gantt charts and Pert charts; (5) includes information
regarding percentage of completion, unresolved delays encountered
or anticipated that may affect the future schedule for
implementation of the Work, and a description of efforts made to
mitigate those delays or anticipated delays; (6) includes any
modifications to the work plans or other schedules that Settling
Defendant have proposed to EPA or that have been approved by EPA;
and (7) describes all activities, as approved by EPA under
Section XXXI (Community Relations) undertaken in support of the
Community Relations Plan during the previous month and those to
be undertaken in the next month. Settling Defendant shall submit
these progress reports to EPA and the Commonwealth by the tenth
day of every month following the lodging of this Consent Decree
until EPA notifies the Settling Defendant pursuant to Paragraph
B(2) of Section XV (Certification of Completion). If requested
by EPA Settling Defendant shall also provide briefings for EPA to
discuss the progress of the Work.
B. The Settling Defendant shall notify EPA in writing of
any change in the schedule or scope of the work described in the
CCQAP and ROMP for the performance of any activity, including,
but not limited to, implementation of work plans, no later than
seven days prior to the performance of the activity.
Notwithstanding the foregoing, the Settling Defendant shall
notify EPA of any change in the schedule described in the monthly
progress report for the performance of data collection no later
33
than 30 days prior to the performance of such activity.
C. In addition to the reporting required by CERCLA Section
103, 42 U.S.C. § 9603, or Section 304 of the Emergency Planning
and Community Right-to-Know Act (EPCRA), 42 U.S.C. § 11004, upon
the occurrence of any event during performance of the Work that
Settling Defendant is required to report pursuant to Section 103
of CERCLA, 42 U.S.C. § 9603, or Section 304 of EPCRA, 42 U.S.C. §
11004, Settling Defendant shall, within 24 hours of the onset of
such event, orally notify the EPA Remedial Project Manager or
appropriate Section Chief: Central Pennsylvania Remedial Section
(in the event of the unavailability of the EPA Remedial Project
Manager), or, in the event that neither the EPA Remedial Project
Manager or Section Chief is available, the EPA Region III hotline
at (215) 597-9898. Within 20 days of the onset of such an event,
Settling Defendant shall furnish to EPA and the Commonwealth a
written report, signed by the Settling Defendant's Project
Coordinator, setting forth the events which occurred and the
measures taken, and to be taken, in response thereto. Within 30
days of the conclusion of such an event, Settling Defendant shall
submit a report setting forth all actions taken in response
thereto.
D. Plans, design documents, proposals, reports or other
documents shall be signed by a Duly Authorized Representative of
the Settling Defendant certifying that the information contained
in the foregoing document. The CCQAP and ROMP and any other work
plan approved by EPA pursuant to this Consent Decree shall
34
specify which documents shall be so certified. The certificate
statement accompanying the document shall state the following:
"I certify that the information contained in or
accompanying this document is true, accurate and
complete. As to the identified portion(s) of this
document for which I cannot personally verify its
(their) truth and accuracy, I certify as the company
official having supervisory responsibility for the
person(s) who, acting under my direct instructions, made the
verification, that this information is true, accurate and
complete."
XII. SUBMISSIONS REQUIRING AGENCY APPROVAL: STATE REVIEW ANDCOMMENT
A. Any plan, report, or other item which is required to be
submitted for approval by EPA pursuant to this Consent Decree
shall be submitted to the Commonwealth at the same time it is
submitted to EPA. After review of any such plan, report or other
item, EPA shall, after reasonable opportunity for review and
comment by the Commonwealth: (1) approve, in whole or in part,
the submission; (2) approve the submission upon specified
conditions; (3) modify the submission to cure the deficiencies;
(4) direct that the Settling Defendant modify the submission; (5)
disapprove, in whole or in part, the submission, notifying
Settling Defendant of deficiencies; or (6) any combination of tl
35
above.
B. In the event of approval, approval upon conditions, or
modification by EPA, Settling Defendant shall proceed to take any
action required by the plan, report, or other item, as approved
or modified by EPA subject only to their right to invoke the
Dispute Resolution procedures set forth in Section XX (Dispute
Resolution) with respect to the modifications or conditions made
by EPA.
C. Upon receipt of a notice of disapproval or a notice
requiring a modification, Settling Defendant shall, within 14
days or such other time as specified by EPA in such notice,
correct the deficiencies and resubmit the plan, report, or other
item for approval. Notwithstanding the notice of disapproval or
a notice requiring a modification, Settling Defendant shall
proceed, at the direction of EPA, to take any action required by
any non-deficient portion of the submission.
D. In the event that a resubmitted plan, report or other
item, or portion thereof, is disapproved by EPA, EPA may again
require the Settling Defendant to correct the deficiencies, in
accordance with the preceding Paragraphs. EPA also retains the
right to amend or develop the plan, report or other item.
Subject only to their right to invoke procedures set forth in
Section XX (Dispute Resolution), Settling Defendant shall
implement any such plan, report, or item as amended or developed
by EPA. Implementation of any non-deficient portion of a
submission shall not relieve Settling Defendant of any liability
36
for stipulated penalties under Section XXI (Stipulated Penalties;
for any violations of this Consent Decree relating to any
deficient portion of the submission.
E. If a plan, report, or item is disapproved by EPA because
it is deemed substantially deficient by EPA, Settling Defendant
shall be deemed to be in violation of the provision of this
Consent Decree requiring the Settling Defendant to submit such
plan, report, or item. The provisions of Section XX (Dispute
Resolution) and Section XXI (Stipulated Penalties) shall govern
the implementation of the Work and accrual and payment of any
stipulated penalties during Dispute Resolution.
F, All plans, reports, and other items required to be
submitted to EPA under this Consent Decree shall, upon
modification and/or approval by EPA, be deemed to be an
enforceable requirement of this Consent Decree. In the event EPA
approves a portion of a plan, report, or other item required to
be submitted to EPA under this Consent Decree, the approved
portion shall be deemed to be an enforceable requirement of this
Consent Decree.
37
XIII. PROJECT COORDINATOR/REMEDIAL PROJECT MANAGER
A. EPA has selected a Remedial Project Manager for this
Site. The EPA Remedial Project Manager is the EPA representative
to whom notices and other submissions are to be submitted
pursuant to Section XXVII (Notices and Submission) of this
Consent Decree. Within 20 days of lodging this Consent Decree,
Settling Defendant will notify the EPA Remedial Project Manager,
in writing, of the name, address and telephone number of its
designated Project Coordinator. EPA shall have the right to
change its Remedial Project Manager and the Settling Defendant
shall have the right to change its Project Coordinator. Any such
change shall be accomplished by notifying the other party, in
writing, at least 5 working days before the change occurs, unless
impracticable, but in no event later than the actual day the
change is made. The Settling Defendant's Project Coordinator
shall be subject to acceptance by EPA and shall have the
technical expertise sufficient to adequately oversee all aspects
of the Work. The Settling Defendant's Project Coordinator shall
not be acting as an attorney for the Settling Defendant in this
matter. He or she may assign other representatives,
including other contractors, to serve as a Site representative
for oversight of performance of daily operations during remedial
activities.
B. EPA may designate other representatives, including, but
not limited to, EPA employees, and federal contractors and
consultants, to observe and monitor the progress of any activity
38
undertaken pursuant to this Consent Decree. The EPA Remedial
Project Manager shall have the authority lawfully vested in a
Remedial Project Manager by the NCP. In addition, the EPA
Remedial Project Manager shall have authority, consistent with
the National Contingency Plan, to halt or redirect any Work
required by this Consent Decree and to take any necessary
response action when s/he determines that conditions at the Site
may constitute an emergency situation or may present an immediate
threat to public health or welfare or the environment due to a
release or threatened release of Waste Material.
C. EPA's Project Coordinator and the Settling Defendant's
Project Coordinator will meet, at the request of EPA.
XIV. ASSURANCE OF ABILITY TO COMPLETE WORK
A. Within 30 days of lodging of this Consent Decree,
Settling Defendant shall establish and maintain financial
security in the amount of $23.4 million in one of the following
forms:
(1) A surety bond guaranteeing performance of the Work;
(2) One or more letters of credit;
(3) A trust fund;
(4) A guarantee to perform the Work by one or more
parent corporations or subsidiaries, or by one or more unrelated
corporations that have a substantial business relationship with
39
the Settling Defendant; or
(5) A demonstration that the Settling Defendant
satisfies the requirements of 40 C.F.R. Part 264.143(f) (April 7,
1982, as amended May 2, 1986).
B. If the Settling Defendant seeks to demonstrate the
ability to complete the Work through a guarantee by a third party
pursuant to Paragraph A(4) of this Section XIV, Settling
Defendant shall demonstrate that the guarantor satisfies the
requirements of 40 C.F.R. Part 264.143(f). If Settling Defendant
seeks to demonstrate its ability to complete the Work by means of
the financial test or the corporate guarantee, they shall
resubmit sworn statements conveying the information required by
40 C.F.R. Part 264.143(f) annually, on the anniversary of the
effective date of this Consent Decree. In the event that EPA,
determines at any time that the financial assurances provided
pursuant to this Paragraph are inadequate, Settling Defendant
shall, within 30 days of receipt of notice of EPA's
determination, obtain and present to EPA for approval one of the
other forms of financial assurance listed in Paragraph A of this
Section XIV. Settling Defendant's inability to demonstrate
financial ability to complete the Work shall not excuse
performance of any activities required under this Consent Decree.
40
XV. CERTIFICATION OF COMPLETION
A. Completion of the Remedial Action
1. Within 90 days after the Settling Defendant
concludes that the Remedial Action has been fully performed and
the Performance Standards have been attained, Settling Defendant
shall so certify to the United States and the Commonwealth and
shall schedule and conduct a pre-certification inspection to be
attended by the Settling Defendant and EPA. If, after the pre-
certif ication inspection, the Settling Defendant still believes
that the Remedial Action has been fully performed and the
Performance Standards.have been attained, it shall submit a
written report to EPA for approval pursuant to Section XII
(Submissions Requiring Agency Approval; State Review and Comment>
within 30 days of the inspection. In the report, a registered
professional engineer ("RPE") and a Duly Authorized
Representative of the Settling Defendant shall certify pursuant
to Section XI.D that the Remedial Action has been completed in
full satisfaction of the requirements of this Consent Decree.
The written report shall include as-built drawings signed and
stamped by a RPE and certified as required by Section XI.D. If,
after completion of the pre-certification inspection and receipt
and review of the written report, EPA determines that the
Remedial Action or any portion thereof has not been completed in
accordance with this Consent Decree or that the Performance
Standards have not been achieved, EPA will notify the Settling
Defendant in writing of the activities that must be undertaken
41
complete the Remedial Action and achieve the Performance
Standards. EPA will set forth in the notice a schedule for
performance of such activities consistent with the Consent Decree
or require the Settling Defendant to submit a schedule to EPA for
approval pursuant to Section XII (Submissions Requiring Agency
Approval; State Review and Comment). Settling Defendant shall
perform all activities described in the notice in accordance with
the specifications and schedules established pursuant to this
Paragraph, subject to its right to invoke the Dispute Resolution
procedures set forth in Section XX (Dispute Resolution).
2. If EPA_concludes, based on the initial or any
subsequent Certification of Completion by the Settling Defendant,
that the Remedial Action has been fully performed in accordance
with this Consent Decree and that the Performance Standards have
been achieved, EPA will so certify in writing to Settling
Defendant. This certification shall constitute the Certification
of Completion of the Remedial Action for purposes of this Consent
Decree, including, but not limited to, Section XXII (Covenants
Not to Sue by Plaintiffs). Certification of Completion of the
Remedial Action shall not affect Settling Defendant's obligations
under this Consent Decree that continue beyond the Certification
of Completion, including, but not limited to, access, Operation
and Maintenance, record retention, indemnification, insurance,
payment of Future Response Costs and penalties, and any work to
be conducted under Section VII (Additional Response Actions) and
Section VIII (U.S. EPA Periodic Review).
42
B. Completion of the Work
1. Within 90 days after the Settling Defendant
concludes that all phases of the Work (including O & M ) , with the
exception of the payment of Future Response Costs associated with
this Paragraph, have been fully performed, Settling Defendant
shall so certify to the United States by submitting a written
report by a RPE certifying that the Work has been completed in
full satisfaction of the requirements of this Consent Decree.
The report shall also contain the certification required by
Section XI.F. If, after review of the written report, EPA
determines that any portion of the Work has not been completed in
accordance with this Consent Decree, EPA will notify Settling
Defendant in writing of the activities that must be undertaken to
complete the Work. EPA will set forth in the notice a schedule
for performance of such activities consistent with the Consent
Decree or require the Settling Defendant to submit a schedule to
EPA for approval pursuant to Section XII (Submissions Requiring
Agency Approval; State Review and Comment). Settling Defendant
shall perform all activities described in the notice in
accordance with the specifications and schedules established
therein, subject to their right to invoke the dispute resolution
procedures set forth in Section XX (Dispute Resolution).
2. If EPA concludes, based on the initial or any
subsequent Certification of Completion by the Settling Defendant
that the Work has been fully performed in accordance with this
Consent Decree, EPA will so notify the Settling Defendant in
43
writing.
XVI. EMERGENCY RESPONSE
A. In the event of any action or occurrence during the
performance of the Work which causes or threatens a release of
Waste Material that constitutes an emergency situation or may
present an immediate threat to the public health or welfare or
the environment, Settling Defendant shall, subject to Paragraph B
of this Section XVI, immediately take all appropriate action to
prevent, abate, or minimize such release or threat of release,
and shall immediately^ notify the EPA Remedial Project Manager,
or, if the EPA Remedial Project Manager is unavailable, his/her
Section Chief, Central Pennsylvania Remedial Section, Superfund
Remedial Branch. If neither of these persons is available, the
Settling Defendant shall notify the EPA Region III Hotline at
(215) 597-9898. Settling Defendant shall take such actions in
consultation with the EPA Remedial Project Manager or other
available authorized EPA officer and in accordance with all
applicable provisions of the Health and Safety Plans, the
Contingency Plans, or any other applicable plans or documents
developed and approved pursuant to this Consent Decree. In the
event that Settling Defendant fails to take sufficient response
action as required by this Section, and EPA takes such action,
Settling Defendant shall reimburse EPA all costs of the response
action not inconsistent with the NCP pursuant to Section XVII
(Reimbursement of Response Costs).
46
account, including, but not limited to, information containing
the identity of the bank and bank account under which the escrow
account is established, a bank statement showing the initial
balance of the escrow account and a copy of the escrow agreement
establishing the escrow account. Simultaneously with
establishment of the escrow account, the Settling Defendant may
initiate the dispute resolution procedures set forth in Section
XX (Dispute Resolution). Failure to initiate the dispute
resolution procedures set forth in Section XX within the 30 day
period following receipt of the bill shall be a waiver of
Settling Defendant' right to initiate dispute resolution with
respect to that issue. If the Settling Defendant fails to
initiate the dispute resolution procedures set forth in Section
XX within the 30 day period following receipt of the bill, then
within 5 days of such 30th day, the Settling Defendant shall
direct the escrow holder to remit the escrowed monies (with
accrued interest) to the United States in the manner described in
Paragraph A of this Section. If the United States prevails in
the dispute, then within 5 days of the resolution of the dispute,
the Settling Defendant shall direct the escrow holder to remit
the escrowed monies (with accrued interest) to the United States
in the manner described in Paragraph A of this Section. If the
Settling Defendant prevails concerning any aspect of the
contested costs, the Settling Defendant shall direct the escrow
holder to remit payment for that portion of the costs (plus
associated accrued interest) for which they did not prevail to
47
the United States in the manner described in Paragraph A of this
Section; Settling Defendant shall be disbursed the balance of the
escrow account. The Dispute Resolution procedures set forth in
this Paragraph in conjunction with the procedures set forth in
Section XX (Dispute Resolution) shall be the exclusive mechanisms
for resolving disputes regarding the Settling Defendant's
obligation to reimburse the United States for its Future Response
Costs.
D. In the event that the payments required by Paragraph A
of this Section are not made within 30 days of the effective date
of this Consent Decree or the payments required by Paragraph B of
this Section within 30 days of the Settling Defendant's receipt
of the bill, Settling Defendant shall pay interest on the unpaid
balance at the rate established pursuant to Section 107(a) of
CERCLA, 42 U.S.C. § 9607(a). The interest on Past Response Costs
shall begin to accrue 30 days after the effective date of the
Consent Decree. The interest on Future Response Costs shall
begin to accrue 30 days after the Settling Defendant's receipt of
the bill. Payments made under this Paragraph shall be in
addition to such other remedies or sanctions available to the
United States by virtue of Settling Defendant's failure to make
timely payments under this Section.
E. In addition to interest, a penalty charge of six (6)
percent will be assessed on any portion of the debt which remains
delinquent more than (90) days after payment is due. However,
should assessment of the penalty be required, it will be assessed
-48
from the first day payment is due as specified in Section XVii.
Thus, to avoid the assessment of penalties, Settling Defendant
must make the payment under Section XVII.A within ninety (90)
days of the date the payment is due.
XVIII. INDEMNIFICATION AND INSURANCE
A. The United States does not assume any liability by
entering into this agreement or by virtue of any designation of
Settling Defendant as EPA's designated representatives under
Section 104(e) of CERCLA, 42 U.S.C. S 9604(e). Settling
Defendant hereby indemnifies, saves and holds harmless the United
States and its officials, agents, employees, contractors,
subcontractors, or representatives for or from any and all claims
or causes of action arising from, or on account of, acts or
omissions of Settling Defendant, their officers, directors,
employees, agents, contractors, subcontractors, and any persons
acting on their behalf or under their control, in carrying out
activities pursuant to this Consent Decree, including, but not
limited to, any claims arising from any designation of Settling
Defendant as EPA's representatives under Section 104 (e) of CERCLA
and any claim for just compensation arising out of performance of
this Consent Decree. Further, the Settling Defendant agrees to
pay the United States all costs the United States incurs
including, but not limited to, attorneys fees and other expenses
of litigation and settlement arising from, or on account of,
claims made against the United States based on acts or omissions
49
of the Settling Defendant, their officers, directors, employees,
agents, contractors, subcontractors, and any persons acting on
their behalf or under their control, in carrying out activities
pursuant to this Consent Decree. The United States shall not be
held out as a party to any contract entered into by or on behalf
of Settling Defendant in carrying out activities pursuant to this
Consent Decree. Neither the Settling Defendant nor any such
contractor shall be considered an agent of the United States .
B. Settling Defendant waives all claims against the United
States for damages or reimbursement or for set-off of any
payments made or to be made to the United States , arising from
or on account of any contract, agreement, or arrangement between
the Settling Defendant and any person for performance of Work on
or relating to the Site, including, but not limited to, claims on
account of construction delays. In addition, Settling Defendant
hereby indemnifies and holds harmless the United States with
respect to any and all claims for damages or reimbursement
arising from or on account of any contract, agreement, or
arrangement between the Settling Defendant and any person for
performance of Work on or relating to the Site, including, but
not limited to, claims on account of construction delays.
C. No later than 15 days after the effective date of this
Consent Decree, Settling Defendant shall secure, and shall
maintain until the first anniversary of EPA's certification of
completion of the Remedial Action pursuant to Paragraph A. 2 of
Section XV (Certification of Completion) comprehensive general
52
it is occurring and (2) following the potential force majeure
event, such that the delay is minimized to the greatest extent
possible. "Force Majeure" does not include financial inability
to complete the Work, or a failure to attain the Performance
Standards, or increased costs.
B. If any event occurs or has occurred that may delay the
performance of any obligation under this Consent Decree, whether
or not caused by a force raajeure event, the Settling Defendant
shall notify by telephone the EPA Remedial Project Manager or, in
his or her absence, his/her Section Chief, Central Pennsylvania
Section, Superfund Remedial Branch or, in the event both of EPA's
designated representatives are unavailable, the EPA Region III
Emergency Hotline at (215) 597-9898, within [48] hours of when
Settling Defendant first knew or should have known that the evei...
might cause a delay. Within [5] days thereafter, Settling
Defendant shall provide in writing to EPA the reasons for the
delay; the obligations and deadlines Settling Defendant claims
are affected by the force majeure event; the anticipated duration
of the delay; all actions taken or to be taken to prevent or
minimize the delay; a schedule for implementation of any measures
to be taken to prevent or mitigate the delay or the effect of the
delay; the Settling Defendant's rationale for attributing such
delay to a force majeure event if they intend to assert such a
claim; and a statement as to whether, in the opinion of the
Settling Defendant, such event may cause or contribute to an
endangerment to public health, welfare or the environment. The
54
shall have the burden of demonstrating by a preponderance of the
evidence that the delay or anticipated delay has been or will be
caused by a force majeure event, that the duration of the delay
or the extension sought was or will be warranted under the
circumstances, that best efforts were exercised to avoid and
mitigate the effects of the delay, and that Settling Defendant
complied with the requirements of Paragraphs A and B, above. If
Settling Defendant carries this burden, the delay at issue shall
be deemed not to be a violation by Settling Defendant of the
affected obligation of this Consent Decree identified to EPA and
the Court.
XX. DISPUTE RESOLUTION
A. Unless otherwise expressly provided for in this Consent
Decree, the Dispute Resolution procedures of this Section shall
be the exclusive mechanism to resolve disputes arising under or
with respect to this Consent Decree and shall apply to all
provisions of this Consent Decree. However, the procedures set
forth in this Section shall not apply to actions by the United
States to enforce obligations of the Settling Defendant that are
not disputed.
B. Any dispute which arises under or with respect to this
Consent Decree shall in the first instance be the subject of
55
informal negotiations between the parties to the dispute. The
period for informal negotiations shall not exceed 20 days from
the time the dispute arises, unless it is modified by written
agreement of the Parties to the Dispute. The dispute shall be
considered to have arisen when one party notifies the other
parties in writing that there is a Dispute.
C. In the event that the parties cannot resolve a dispute
by informal negotiations under the preceding Paragraph, then the
position advanced by EPA shall be considered binding unless,
within 10 days after the conclusion of the informal negotiation
period, the Settling Defendant invokes the formal dispute
resolution procedures of this Section by serving on the United
States a written statement of their position on the matter in
dispute, including, but not limited to, any factual data,
analysis or opinion supporting that position and any supporting
documentation relied upon by the Settling Defendant.
D. Formal dispute resolution for disputes pertaining to the
selection or adequacy of any response action and all other
disputes that are accorded review on the administrative record
under applicable principles of administrative law shall be
conducted pursuant to the procedures set forth in this Paragraph.
For purposes of this Paragraph, the adequacy of any response
action includes: (1) the adequacy or appropriateness of plans,
procedures to implement plans, or any other items requiring
59
paid as provided in Section XXI (Stipulated Penalties).
XXI. STIPULATED PENALTIES
A. The Settling Defendant shall be liable for stipulated
penalties in the amounts set forth in Paragraphs B and C of this
Section to the United States for failure to comply with the
requirements of this Consent Decree specified below, unless
excused under Section XIX (Force Majeure).. "Compliance" by the
Settling Defendant shall include completion of the activities
under this Consent Decree or any work plan or other plan approved
under this Consent Decree identified below in accordance with all
applicable requirements of law, this Consent Decree, and any
plans or other documents approved by EPA pursuant to this Consent
Decree and within the specified time schedules established by and
approved under this Consent Decree.
B. The following stipulated penalties shall be payable per
violation per day to the United States for any noncompliance
identified in Paragraph B.2, below, of this Section:
1. Penalty Per Violation Period of NoncompliancePer Day
$2,500 1st through 14th day$5,000 15th through 30th day$7,500 31st day and beyond
2. Major Compliance Milestones:
(i) Notification of the name, title and qualifications
of the Supervising Contractor within 10 days of
the lodging of the Consent Decree pursuant to
60
Paragraph VI.A of this Decree;
(ii) Subraittal of a. Construction Quality Assurance Plan
(CCQAP) and Remedial Operation and Maintenance
Plan (ROMP) for approval by the EPA within 14 days
of the effective date of the Consent Decree
pursuant to Paragraph VLB of this Decree;
(iii) Subsequent milestones identified as such in the
ROMP approved by the EPA;
C. The following stipulated penalties shall be payable per
violation per day to the United States for failure to submit
timely or adequate reports [or other written documents] pursuant
to Paragraphs XL A.; XI.C.; XI.D.:
Penalty Per ViolationPer Day
$1,000$2,000$3,000
Period of Noncompliance
1st through 14th day15th through 30th day31st day and beyond
D. All penalties shall begin to accrue on the day after the
complete performance is due or the day a violation occurs, and
shall continue to accrue through the final day of the correction
of the noncompliance or completion of the activity. Separate
penalties shall accrue for each separate violation of this
Consent Decree.
E. Following EPA's determination that Settling Defendant
has failed to comply with a requirement of this Consent Decree, -
EPA may give Settling Defendant written notification of same and
describe the noncompliance. However, penalties shall accrue as
61
provided in the proceeding Paragraph whether or not EPA has
notified the Settling Defendant of a violation. EPA may send the
Settling Defendant a written demand for the payment of the
penalties.
F. All penalties owed to the United States under this
section shall be due and payable within 30 days of the Settling
Defendant's receipt from EPA of a demand for payment of the
penalties, unless Settling Defendant invokes the Dispute
Resolution procedures under Section XX (Dispute Resolution). All
payments under this Section shall be paid by certified check made
payable to "EPA Hazardous Substance Superfund," shall be mailed
to United States Environmental Protection Agency, Attention:
Superfund Accounting, P.O. Box 360515M, Pittsburgh, PA 15251 and
shall reference CERCLA Number PAD 98053068 and DOJ Case Number
90-11-2-722. Copies of check(s) paid pursuant to this
Section, and any accompanying transmittal letter(s), shall be
sent to the United States as provided in Section XXVII (Notices
and Submissions).
G. Neither the invocation of Dispute Resolution procedures
under Section XX (Dispute Resolution) nor the payment of
penalties shall alter in any way Settling Defendant's obligation
to complete the performance of the Work required under this
Consent Decree.
H. Penalties shall continue to accrue as provided in
Paragraph D of this Section during any dispute resolution period,
and shall be paid as follows:
63
the thirty-day period following Settling Defendant's receipt
from EPA of a demand for payment at the rate established pursuant
to Section 107(a) of CERCLA, 42 U.S.C. § 9607(a). However,
nothing in this Section shall be construed as prohibiting,
altering, or in any way limiting the ability of the United States
to seek any other remedies or sanctions available by virtue of
Settling Defendant's violation of this Decree or of the statutes
and regulations upon which it is based, including, but not
limited to, penalties pursuant to Section 122(1) of CERCLA, 42
U.S.C. § 9622 (1) . '"
J. No payments made under this Section shall be tax
deductible for Federal tax purposes.
XXII. COVENANTS NOT TO SUB BY PLAINTIFF
A. In consideration of the actions that will be performed
and the payments that will be made by the Settling Defendant
under the terms of this Consent Decree, and except as
specifically provided in Paragraphs B, C, and E of this Section,
the United States covenants not to sue or to take administrative
action against Settling Defendant pursuant to Sections 106 and
107(a) of CERCLA relating to the Site. Except with respect to
future liability these covenants not to sue shall take effect
upon the receipt by EPA of the payments required by Paragraph A
of Section XVII (Reimbursement of Response Costs). With respect
to future liability, these covenants not to sue shall take effect
upon Certification of Completion of Remedial Action by EPA
64
pursuant to Paragraph A.2 of Section XV (Certification of
Completion). These covenants not to sue with respect to the
Settling Defendant are conditioned upon the complete and
satisfactory performance by the Settling Defendant of its
obligations under this Consent Decree. These covenants not to
sue extend only to the Settling Defendant and do not extend to
any other person.
B. United States' Pre-certification reservations.
Notwithstanding any other provision of this Consent Decree, the
United States reserves, and this Consent Decree is without
prejudice to, the right to institute proceedings in this action
or in a new action, or to issue an administrative order seeking
to compel Settling Defendant (1) to perform additional response
actions relating to the Site or (2) to reimburse the United
States for additional costs of response if, prior to
certification of completion of the Remedial Action:
(i) conditions at the Site, previously unknown to the
United States, are discovered after the entry of
this Consent Decree, or
(ii) information is received, in whole or in part,
after the entry of this Consent Decree,
and these previously unknown conditions or this information
together with any other relevant information indicates that the
Remedial Action is not protective of human health and the
environment.
C. United States' Post-certification reservations.
65
Notwithstanding any other provision of this Consent Decree, the
United States reserves, and this Consent Decree is without
prejudice to, the right to institute proceedings in this action
or in a new action, or to issue an administrative order seeking
to compel Settling Defendant (1) to perform additional response
actions relating to the Site or (2) to reimburse the United
States for additional costs of response if, subsequent to
certification of completion of the Remedial Action:
(i) conditions at the Site, previously unknown to the
United States, are discovered after the
certification of completion, or
(ii) information is received, in whole or in part,
after the certification of completion,
and these previously unknown conditions
or this information together with other
relevant information indicate that the
Remedial Action is not protective of human health
and the environment.
D. For purposes of Paragraph B of this Section, the
information received by and the conditions known to the United
States shall include only that information and those conditions
set forth in the Record of Decision for the Site and the
administrative record supporting the Record of Decision. For
purposes of Paragraph C of this Section, the information received
by and the conditions known to the United States shall include
only that information and those conditions set forth in the
66
Record of Decision, the administrative record supporting the
Record of Decision, and any information received by the United
States pursuant to the requirements of this Consent Decree prior
to Certification of Completion of the Remedial Action.
E. General reservations of rights. The covenants not to
sue set forth above do not pertain to any matters other than
those expressly specified in Paragraph A of this Section. The
United States reserves, and this Consent Decree is without
prejudice to, all rights, including, but not limited to, causes
of action under Sections 106 and 107 (a) of CERCLA, 42 U.S.C." §§
9606 and 9607(a) against Settling Defendant with respect to all
other matters, including but not limited to, the following:
(1) claims based on a failure by Settling Defendant
to meet a requirement of this Consent Decree;
(2) liability arising from the past, present, or
future disposal, release, or threat of release of Waste
Materials outside of the Site;
(3) liability for damages for injury to, destruction
of, or loss of natural resources;
(4) liability for response costs that have been or may
be incurred by all natural resource trustees including but
not limited to the National Oceanographic and Atmospheric
Administration and the Department of Interior, Fish and
67
Wildl i fe Service;
(5) criminal liability;
(6) liability for violations of federal or state law
which occur during or after implementation of the Remedial
Action; and
(7) liability for costs that the United States has
incurred or will incur related to the Site but which are not
within the definition of Past and Future Response Costs.
F. Notwithstanding any other provision of this Consent
Decree, the United States retains all authority and reserves all
rights to take any and all response actions authorized by law.
XXIII. COVENANTS BY SETTLING
Settling Defendant hereby covenants not to sue and agree,
not to assert any claims or causes of action against the United
States with respect to the Site or this Consent Decree,
including, but not limited to, any direct or indirect claim for
reimbursement from the Hazardous Substance Superfund (established
pursuant to the Internal Revenue Code, 26 U.S.C. § 9507) through
CERCLA Sections 106(b)(2), 111 or 112, 42 U.S.C. §§ 9606(b)(2),
9611, or 9612, or any other provision of law, any claim against
any department, agency or instrumentality of the United States
related to the Site, or to seek any other costs, damages or
attorneys fees from the United States arising out of response
activities at the Site. However, the Settling Defendant
reserves, and this Consent Decree is without prejudice to,
69
protection from contribution actions or claims as is provided by
CERCLA Section 113(f)(2), 42 U.S.C. S 9613(f)(2).
C. The Settling Defendant agrees that with respect to any
suit or claim for contribution brought by them for matters
related to this Consent Decree they will notify the United States
in writing no later than 60 days prior to the initiation of such
suit or claim. The Settling Defendant also agrees that with
respect to any suit or claim for contribution brought against
them for matters related to this Consent Decree they will notify
in writing the United States within 10 days of service of the
complaint on them. Settling Defendant acknowledges that the
United States has no obligation to defend it in any suit or claim
for contribution.
D. In any subsequent administrative or judicial proceeding
initiated by the United States for injunctive relief, recovery of
response costs, or other appropriate relief relating to the Site,
Settling Defendant shall not assert, and may not maintain, any
defense or claim based upon the principles of waiver, res
-judicata. collateral estoppel, issue preclusion, claim-splitting,
or other defenses based upon any contention that the claims
raised by the United States in the subsequent proceeding were or
should have been brought in the instant case; provided, however,
that nothing in this Paragraph affects the enforceability of the
covenants not to sue set forth in Section XXII (Covenants Not to
Sue by Plaintiffs).
70
XXV. ACCESS TO INFORJ4ATION
A. Settling Defendant shall provide to EPA upon request
copies of all documents and information within their possession
or control or that of its contractors or agents relating to
activities at the Site or to the implementation of this Consent
Decree, including, but not limited to, sampling, analysis, chain
of custody records, manifests, trucking logs, receipts, reports,
sample traffic routing, correspondence, or other documents or
information related to the Work. Settling Defendant shall also
make available to EPA for purposes of investigation, information
gathering, or testimony, its employees, agents, or
representatives with knowledge of relevant facts concerning the
performance of the Work.
B. Settling Defendant may assert business confidentiality
claims covering part or all of the documents or information
submitted to Plaintiffs under this Consent Decree to the extent
permitted by and in accordance with Section 104(e)(7) of CERCLA,
42 U.S.C. § 9.604 (e) (7), and 40 C.F.R. § 2.203(b). Documents or
information determined to be confidential by EPA will be afforded
the protection specified in 40 C.F.R. Part 2, Subpart B. If no
claim of confidentiality accompanies documents or information
when they are submitted to EPA or if EPA has notified Settling
Defendant that the documents or information are not confidential
under the standards of Section 104(e)(7) of CERCLA or 40 C.F.R.
Part 2, the public may be given access to such documents or
information without further notice to Settling Defendant. The
71
Settling Defendant may assert that certain documents, records and
other information are privileged under the attorney-client
privilege or any other privilege recognized by federal courts in
actions involving the United States. If the Settling Defendant
asserts such a privilege, they shall provide the Plaintiffs with
the following: (1) the title of the document, record, or
information; (2) the date of the document, record, or
information; (3) the name and title of the author of the
document, record, or information; (4) the name and title of each
addressee and recipient; (5) a description of the contents of the
document, record, or information; and (6) the nature and basis of
the privilege asserted by Settling Defendant. However, no
documents, records or information created, generated or collected
pursuant to the terms of the Consent Decree shall be withheld on
the grounds that they are privileged.
C. No claim of confidentiality shall be made with respect
to any data, including, but not limited to, all sampling,
analytical, monitoring, hydrogeologic, scientific, chemical, or
engineering data, or any other documents or information
evidencing conditions at or around the Site.
XXVI. RETENTION O7 RECORDS
A. The Settling Defendant shall preserve and retain all
records and documents now in its possession or control or which
come into its possession or control that relate in any manner to
the performance of the Work or liability of any person, including
72
the Settling Defendant, for response actions conducted and to b
conducted at the Site, regardless of any corporate retention
policy to the contrary, until 10 years after the Settling
Defendant's receipt of EPA's notification pursuant to Paragraph
B.2 of Section XV (Certification of Completion). Settling
Defendant shall also instruct its contractors and agents to
preserve all documents, records, and information of whatever
kind, nature or description relating to the performance of the
Work until 10 years after the Settling Defendant' receipt of
EPA's notification pursuant to Paragraph B.2 of Section XV
(Certification of Completion).
B. Upon conclusion of this document retention period,
Settling Defendant shall notify EPA at least 90 days prior to the
destruction of any such records, documents or information, and,
upon request of EPA, Settling Defendant shall deliver all such
documents, records and information to EPA . In no event
shall Settling Defendant destroy such records or documents until
EPA responds in writing approving such destruction.
C. The Settling Defendant hereby certifies that it has not
altered, mutilated, discarded, destroyed or otherwise disposed of
any records, documents or other information relating to its
potential liability regarding the Site since notification of
potential liability by the United States or the Commonwealth or
the filing of any earlier suit against it regarding the Site and
that it has fully complied with any and all EPA requests for
information pursuant to Sections 104(e) and 122(e) of CERCLA, 4°
73
U.S.C. §§ 9604(e) and 9622(e), and Section 3007 of RCRA 42 U.S.C.
§ 6927.
XXVII. NOTICES AND SUBMISSIONS
Whenever, under the terms of this Consent Decree, written
notice is required to be given or a report or other document is
required to be sent by one party to another, it shall be directed
to the individuals specified in the particular Section of this
Consent Decree at the addresses specified below, unless those
individuals or their "successors give notice of a change to the
other parties in writing. Written notice as specified herein
shall constitute complete satisfaction of any written notice
requirement of this Consent Decree with respect to the United
States, EPA, and the Settling Defendant, respectively.
As to the United States:
Chief, Environmental Enforcement SectionEnvironment and Natural Resources DivisionU.S. Department of JusticeP.O. Box 7611Ben Franklin StationWashington, D.C. 20044
Re: DOJ # 90-11-2-722
and
Andrew M. Duchovnay, EsquireOffice of Regional CounselUnited States Environmental Protection Agency
74
Region III841 Chestnut BuildingPhiladelphia, PA 19107
As to EPA:
Donna M. McCartney (3HW27)EPA Remedial Project ManagerUnited States Environmental Protection AgencyRegion III841 Chestnut BuildingPhiladelphia, PA 19107
As to the Settling Defendant:
[Name]Settling Defendant' Project Coordinator[Address]
XXVIII. EFFECTIVE DATE
The effective date of this Consent Decree shall be the
date upon which this Consent Decree is entered by the Court,
except as otherwise provided herein.
XXIX. RETENTION OF JURISDICTION
This Court retains jurisdiction over both the subject
matter of this Consent Decree and the Parties for the duration of
the performance of the terms and provisions of this Consent
Decree for the purpose of enabling any of the Parties to apply to
the Court at any time for such further order, direction, and
relief as may be necessary or appropriate for the construction c
75
modification of this Consent Decree, or to effectuate or enforce
compliance with its terms, or to resolve disputes in accordance
with Section XX (Dispute Resolution) hereof.
XXX. APPENDICES
The following appendices are attached to and incorporated
into this Consent Decree:
"Appendix A" is the ROD.
"Appendix B" is the map of the Site.
"Appendix C" is the list of Performance Standards identified
as of the effective date of this Consent Decree.
XXXI. COMMUNITY RELATIONS
Settling Defendant shall cooperate with EPA in providing
information regarding the Work to the public. As requested by
EPA, Settling Defendant shall participate in the preparation of
such information for dissemination to the public and in public
meetings which may be held or sponsored by EPA to explain
activities at or relating to the Site.
XXXII. MODIFICATION
A. Schedules for completion of the Work specified in this
Consent Decree or incorporated by reference may be modified by
agreement of the Parties. All such modifications shall be made
in writing and a copy shall be filed with the Court.
B. No material modifications shall be made to the
76
Construction Quality Assurance Plan or the Remedial Operation an
Maintenance Plan, and no modifications shall be made to
provisions of this Consent Decree, other than the Construction
Quality Assurance Plan and the Remedial Operation and
Maintenance Plan as described below in Paragraph C of this
Section, without written notification to and written approval of
the United States, Settling Defendant, and the Court.
C. Modifications to the Construction Quality Assurance Plan
and the Remedial Operation and Maintenance Plan that do not
materially alter the requirements of those documents may be made
by written agreement between EPA, and the Settling Defendant. A
copy of any such modifications shall be filed with the Court.
D. Nothing in this Section shall be deemed to alter the
Court's power to supervise or modify this Consent Decree.
XXXIII. LODGING AND OPPORTUNITY FOR PUBLIC COMMENT
A. This Consent Decree shall be lodged with the Court for a
period of not less than thirty (30) days for public notice and
comment in accordance with Section 122(d)(2) of CERCLA, 42 U.S.C.
§ 9622(d)(2), and 28 C.F.R. S 50.7. The United States reserves
the right to withdraw or withhold its consent if the comments
regarding the Consent Decree disclose facts or considerations
which indicate that the Consent Decree is inappropriate,
improper, or inadequate. Settling Defendant consents to the
entry of this Consent Decree without further notice.
B. If for any reason the Court should decline to approve
77
this Consent Decree in the form presented, this agreement is
voidable at the sole discretion of any Party and the terms of the
agreement may not be used as evidence in any litigation between
the Parties.
XXXIV. SIGNATORIES/SERVICE
A. The undersigned representative of the Settling Defendant
to this Consent Decree and the Assistant Attorney General for the
Environment and Natural Resources of the Department of Justice of
the United States certifies that he or she is fully authorized
to enter into the terms and conditions of this Consent Decree and
to execute and legally bind such party to this document.
B. The Settling Defendant hereby agrees not to oppose entry
of this Consent Decree by this Court or challenge any provision
of this Consent Decree.
C. The Settling Defendant shall identify, on the attached
signature page, the name and address of an agent who is
authorized to accept service of process by mail on behalf of that
party with respect to all matters arising under or relating to
this Consent Decree. Settling Defendant hereby agrees to accept
service in that manner and to waive the formal service
requirements set forth in Rule 4 of the Federal Rules of Civil
Procedure, including, but not limited to, waiver of service of a
summons, and any applicable local rules of this Court.
80 ORDERED THIS DAY 07 , 19 .
£. 01^. JOKJC
ti FAX TRANSMISSION'> f"<i ww<*
COMMENTS:
iu. PA 19103
F»M:lZ 191 8I4-3OOX
includin*W5 cov"
6THA
A-
fo
(3) IA
c «x^ a-
L 4u
APPENDIX D
BZBLXOOR&SHT
oo
oo
oo
(19C6-1990)Deaigii
Annual Croundvatar attraction System lawaaaeat teportawestern Pariaatar oroundwatar Inteeeaptor Well sSpecifications - 9/84Eastern Peciaefter crouadvatar interceptorSpecifications - 9/8SWestern Perimeter wall System Aa-suilt - Form 6 - 2/05 ftPADS* Burvaa of Solid Waste permit Modification -Croundvater Interceptor System - 7/22/86PAM» Bureau of Solid Waste Permit #100113 Modification - 12/12/86PADER Bureau of Solid wast* remit #100113 Modification - 12/4/9O
5y»ta» Design
6/8S
ooooo
Gafl iunagaoant - Form 37 - 9/13/aaM-3»Ut - Tom 37 - 6/8/90
CM Probe *s-3ttilts - rora 37 - 5/31/89?ADCR Bureau of Solid Waste Permit #lOOU3 Modification - 12/U/86PADER Bureau of Solid Waste porait #100113 Modification - 12/4/90
o PADBR Bureau of wataf Quality BVDBS Permit OO46630 Amettd. #1 - ll/8<'o PADS* Bureau of Solid Waste Permit #100113 Modification - 12/12/86o PADZfc Bureau of Solid Waste Permit #100113 Modification - 12/4/90
Final capt
oooo
I/II Clay Capping as-Builts - Fora 37 - 2/26/90Poasa n clay Capoiig As Builts - Form 37 - 10/17/91PADSR Bureau of Solid Waste Permit #100113 Modification - 12/12/86— — Bureau of solid West* Permit #100113 Modification - 12/-1/90
-How Permit Applicationdata- VMM 11/21/91
a«at to TAfiCt 5/14/91. Tha current Permit axpirKtioa»tat» that eurrant ?«Bait will r«win ia »ff*«t
if PAOS& hajs not aetad on
tun
UNITED STATES ENVIRONMENTAL PROTECTION AGENCYREGION HI
1650 Arch StreetPhiladelphia, Panntylvania 19103-2029
9/26700
SUBJECT: Modem Landfill Superfund Site; Non-SignificantChanges to the ROD
FROM: Frank Klanchar, RPMWestern PA Remedial Section (3HS22)
TO: RD/RA Project Files
The purpose of this memorandum is to document the following non-significant post-ROD change to theremedy:
Background
The 4-acre highwall area is the remaining portion of the original 66-acre unlined landfill (i.e. theCERCLA Site) that is to receive a landfill cap and final cover system under the June 1991 ROD.
In September 1995, EPA conditionally approved the redesign of the 4-acre highwall area, noting that itwas deficient with respect to the thickness of the textured High Density Polyethylene ("HDPE")geosynthetic cap. The proposed thickness in the design was 30 mil, substantially less than the 60 milwhich was promulgated in 40 CFR § 258.40(b).
In late 1995, EPA agreed to defer construction of the final cover for the 4-acre highwall area until afterthe Pennsylvania Department of Environmental Protection ("PADEP") completed their review of apermit modification for a Northwest Expansion at the Modem Landfill.
On April 16,1999, PADEP approved the permit modification for the Northwest Expansion at the ModemLandfill (Permit No. 100] 13). The Northwest Expansion involves the construction of five new disposalcells in the area between and to the northwest of the two existing landfills (the original 66-acre unlinedlandfill and the southwest expansion) and will encompass the 4-acre highwall area.
Functional Specifications of the Remedy
EPA reviewed the design for the permit modification of the Northwest Expansion. The remaining 4-acres of highwall area will be addressed during construction of Cells #12, #13, and #14. Thegeosynthetic liner system for these cells will consist of secondary and primary geotextile layers and two(2) - 60 mil textured HOPE geomembranes with a primary geosynthetic clay liner. These landfill cellswill also receive a composite capping system aa a final cover when the cells are completed.
EPA has determined that the specifications of the Northwest Expansion meets or exceeds thosespecifications proposed in the 4-acre highwall cap redesign of 1995. As a result, EPA is willing to acceptthe design change associated with the Northwest Expansion. This change will not have a significantimpact on the scope, performance, or cost of the remedy.
TOTPL P. 06
Golder Associates Inc.
640 North Commercial Street, Suite 250Manchester, NH 03101-1146Telephone (603) 668-0880Fax (603) 668-1199www golder.com
APPENDIX CGROUNDWATER MODELING UPDATE REPORT
MODERN LANDFILL5-YEAR REVIEW
Prepared for:
Modern Landfill4400 Mt. Pisgah Road
York, Pennsylvania 17402-8240
Prepared by:
Colder Associates Inc.540 North Commercial Street
Suite 250Manchester, NH 03101
January 2005 Our Ref.: 043-6295
OFFICES ACROSS AFRICA, ASIA, AUSTRALIA, EUROPE, NORTH AMERICA AND SOUTH AMERICA
January 2005 C-i Our Ref.: 043-6299
EXECUTIVE SUMMARY
Modern Landfill (Modern) installed the enhanced Western Groundwater Control System (EWGCS) in 1999to replace the Western Groundwater Extraction System wells, to continue groundwater remediation, andallow for construction of the Northwest Expansion. Since EWGCS installation, and per permitrequirements, Modern has monitored groundwater extraction rates from the EWGCS pumping wells, andhas monitored groundwater levels outside of the EWGCS. To further evaluate the effectiveness of thenumerical groundwater flow model, Modern commissioned Golder Associates Inc. (Golder) to conductadditional groundwater model simulations of EWGCS operation for post-1999 conditions. Simulation ofJuly 2001 and July 2003 pumping conditions indicate the groundwater model continues to remain aneffective tool to assess groundwater flow conditions, as the simulated conditions matched the observedconditions well within industry standards for groundwater modeling. Conservative source area attenuationestimates predict groundwater pumping will be required as part of Modern's remediation efforts until aboutthe year 2020; after this period, the source area concentrations will likely be low enough such that naturalattenuation mechanisms will be sufficient to continue remediating groundwater.
Golder Associates
January 2005 C-ii Our Ref.: 043-6299
APPENDIX C
TABLE OF CONTENTS
Executive Summary C-i
Table of Contents C-ii
SECTION PAGE
1.0 INTRODUCTION C-l
2.0 MODELING APPROACH C-2
3.0 MODEL INPUT DATA C-3 3.1 Finite Difference Grid C-3 3.2 Bottom Elevation of Modeling Layers C-3 3.3 Hydraulic Conductivity C-4 3.4 Precipitation Recharge C-4 3.5 Constant Head and River Nodes C-4 3.6 Pumping Rates C-5
4.0 MODEL RESULTS C-5 4.1 Model Calibration and Sensitivity Analysis Results C-5
4.1.1 Model Calibration C-5 4.1.2 Updated Model Calibration Sensitivity Analysis C-6
4.2 Simulation of the EWGCS and Sensitivity Analysis C-7 4.2.1 Simulation of the EWGCS C-7 4.2.2 EWGCS Sensitivity Analysis C-8
5.0 EWGCS OPERATION C-9 5.1 2001 Conditions C-9 5.2 2003 Conditions C-9
6.0 SOURCE AREA ATTENUATION C-10 6.1 No EWGCS Pumping C-11 6.2 No Pumping Conditions C-11 6.3 Natural Attenuation Assessment C-11
7.0 SUMMARY C-13
8.0 REFERENCES C-14
Golder Associates
January 2005 C-iii Our Ref.: 043-6299
LIST OF TABLES
Table C-l Summary of Numerical Model Simulations Table C-2 Trench Depth Table C-3 September 1992 Precipitation Data Summary Table C-4 1991-2003 Precipitation Data Summary Table C-5 1995-1996 Precipitation Data Summary Table C-6 Simulated Pumping Rates Table C-7 Model Run 956H Calibration Data, 1995-1996 Site ConditionsTable C-8 Model Run 92H Calibration Data, 1992 Site Conditions Table C-9 Model Run MD10A Calibration Data, September 1992 Site Conditions Table C-10 Calibration Run (Model Run 956H) Hydraulic Conductivity Sensitivity Table C-l1 Calibration Run (Model Run 956H) Recharge Sensitivity Analysis Table C-12 Calibration Run (Model Run 956H) Constant Head Sensitivity Analysis Table C-l3 Calibration Run (Model Run 956H) Streambed Hydraulic Conductance Sensitivity Analysis Table C-14 Enhanced System (Model Run T1) Pumping Rate Table C-l5 1995-1996 Precipitation Data Summary Table C-l6 Model Run T101 Calibration Data, July 2001 Site Conditions Table C-17 Model Run T103A Calibration Data, July 2001 Site Conditions Table C-18 Total VOC Trends of Monitoring Wells Downgradient of 66-Acre Landfill Table C-19 Volatile Organic Compound Half Lives
LIST OF FIGURES
Figure C-l Well Locations Used for Numerical Model Calibration Figure C-2 Numerical Model Calibration to 1995-1996 Site Conditions Figure C-3 Numerical Model Calibration to 1992 Site Conditions Figure C-4 Rust Model Calibration to September 1992 Site Conditions Figure C-5 Simulated Enhanced System Q = 54 gpm Figure C-6 Simulated Enhanced System Q = 23 gpm Figure C-7 Measured vs. Simulated Transient Pumping Simulation Figure C-8 Modeling Layer 1 Simulated Groundwater Flux in Northerly Direction Figure C-9 Modeling Layer 2 Simulated Vertical Groundwater Flux Figure C-10 Simulated Enhanced System K Trench = 3 x 10-3 cm/s Figure C-11 Simulated Enhanced Permeability Zone Assuming 200 feet of Trench at the North End of the
Landfill Expansion Figure C-l2 Simulated Enhanced System 2001 Conditions Figure C-l3 Simulated Enhanced System 2003 Conditions Figure C-14 Simulated Enhanced System Q = 0 gpm Figure C-l5 No Pumping Conditions
Golder Associates
January 2005 C-1 Our Ref.: 043-6299
1.0 INTRODUCTION
Golder Associates Inc. (Golder) is pleased to provide the results of additional numerical groundwater flowsimulations for the Modern Landfill Site (Site). Golder performed numerical modeling to supportreplacement of the Western Groundwater Extraction System with an equally effective system (i.e., theEnhanced Western Groundwater Control System or EWGCS). This appendix presents an update to a reportsubmitted by Golder in response to comments about the Northwest Expansion (Rust Environment andInfrastructure, and Golder Associates Inc., June, 1998).
The additional numerical groundwater flow simulations are based on the initial numerical model for the Sitedeveloped by Rust Environment and Infrastructure (Rust). The initial model results are presented in thereport titled "Western Groundwater Control System Demonstration Project" (Rust and Golder Associates,February 1996). In 1998, the Pennsylvania Department of Environmental Protection (PADEP) retainedOgden Environmental (Ogden) to review the initial model developed by Rust (Ogden, 1998). Golderperformed the additional numerical simulations and provided clarifications in response to comments raisedby Ogden. In addition, Golder updated the initial model developed by Rust by incorporating the results ofthe Western Groundwater Extraction System Demonstration Project (Demonstration Project) constructed byModern Landfill in 1997.
Following completion of the EWGCS in 1999, groundwater extraction rates and levels have been monitoredweekly, as required by the Site permit. The extraction rate and water level data provide an opportunity tocompare numerical modeling predictions of EWGCS operation with the observed conditions. Additionalsimulations of 2001 and 2003 conditions are included in this appendix.
Using the calibrated and verified numerical model, Golder conducted additional analyses to predictgroundwater flow conditions if the extraction systems were turned off. We then evaluated the existinggroundwater monitoring well network to see if groundwater flow containing leachate constituents wouldbypass the monitoring well network. In addition, Golder evaluated the half-life of the volatile organicconstituents (VOCs) at the Site, the particle pathway distances, and total VOC trends to estimate when theextraction systems could be turned off, and natural attenuation would sufficiently remediate groundwater.
Golder performed numerical modeling simulations using three computer modeling codes:
• MODFLOW - a modular three-dimensional finite difference groundwater flow model(McDonald and Harbaugh, 1988);
• MODPATH - a particle tracking post-processing package for MODFLOW (Pollock, 1994);and
• Groundwater Vistas - a pre- and post-processor for MODFLOW and MODPATH(Environmental Solutions, Inc., 2004).
The remainder of this appendix is organized into seven sections:
Golder Associates
January 2005 C-2 Our Ref.: 043-6299
• Section 2.0 - updated model approach; • Section 3.0 - updated model geometry; • Section 4.0 - modeling results and sensitivity analyses; • Section 5.0 - modeling results of EWGCS operation; • Section 6.0 - prediction of source area attenuation; • Section 7.0 - summary; and • Section 8.0 - references.
2.0 MODELING APPROACH
Golder updated the numerical model developed by Rust with new data, and re-calibrated the model using ahigher precipitation recharge rate of 11 inches per year as suggested by Ogden (1998). Golder performedadditional simulations of the EWGCS using the updated numerical model. Golder also conducted asensitivity analysis to account for parameter value uncertainty and to evaluate the impacts of parametervalue changes on the estimated effectiveness of the EWGCS.
The approach for the updated numerical modeling effort is:
• Golder used the three-layer model developed by Rust (Simulation MD49) as the basis for theupdated model calibration.
• Golder used average annual groundwater level data collected from June 1995 through August1996 for the updated model calibration, as suggested by Ogden (1998). These data includegroundwater levels collected from the piezometers installed in the stream relocation area in1998 (PZ-1SR through PZ-8SR; see Figure C-l).
• Golder modified the Rust model (Simulation MD49) as follows:
o Addition of rows and columns to the finite difference grid to simulate moreaccurately the entire EWGCS;
o Modifications to the bottom of Modeling Layers 1 and 2 to simulate the reviseddesign depth of the EWGCS;
o Increases to the hydraulic conductivity zones by an average factor of 1.2 to simulatethe hydraulic conductivity zones identified during the Remedial Investigation (GolderAssociates, April 1990) and subsequent studies, as suggested by Ogden (1998);
o Refinements of river nodes based on the Site topographic map to more accuratelysimulate surface water features; and
o Addition of recharge zones as shown in Figure C-2 corresponding to the 1995-1996Site development (i.e., groundwater extraction rates, precipitation recharge, landfillcapping, and completion of expansion areas). Golder used a precipitation rechargerate of 11.03 inches per year for areas not covered by landfill cells.
Golder Associates
January 2005 C-3 Our Ref.: 043-6299
• After calibrating the model to 1995-1996 conditions (Simulation 956H), Golder verified the1992 conditions (Simulation 92H1).
• Golder compared the simulation for 1992 conditions with the initial Rust model (SimulationMD10A).
• Golder used the calibrated model to simulate operation of the entire EWGCS (SimulationTl).
• Golder conducted a sensitivity analysis to evaluate model calibration and the effectiveness ofthe EWGCS.
• Golder used the calibrated model to simulate operation of the EWGCS in July 2001 and July2003 (Simulations T101 and T103A, respectively).
• To evaluate the effects of no groundwater extraction following completion of the NorthwestExpansion cell baseliners, Golder used the calibrated model to simulate no pumping of theEWGCS (Simulation T1QO), and no pumping from the EWGCS and the Eastern ExtractionSystem well array (Simulation T1NOQA).
Table C-l presents a summary of the numerical model simulations presented in this appendix.
3.0 MODEL INPUT DATA
3.1 Finite Difference Grid
The Rust model initial finite difference grid contained square cells of 50 feet by 50 feet within a total modelsize of 7,500 feet by 7,500 feet. Golder refined the finite difference grid in the EWGCS area by graduallydecreasing the cell sizes to 25 feet by 25 feet. The area covered by the finer grid (about 500 feet by 2,800feet) includes the entire EWGCS.
3.2 Bottom Elevation of Modeling Layers
The depth of the EWGCS in the Rust model was 50 feet below ground surface (bgs). Golder updated themodel using a depth of 70 feet bgs for the EWGCS. This increase is based on results of the 400-foot longDemonstration Project trench installed in 1997 (Golder Associates Inc., October 1997 and November 1997).The average depth of the Demonstration Project was 74 feet bgs (see Table C-2). The remainder of theEWGCS trench was constructed to depths ranging from 67 to 102 feet bgs (Golder Associates Inc., March2000). Due to weathered bedrock conditions at three locations along the alignment of the EWGCS, blastingdepths were increased from about 70 feet bgs to 100 feet bgs.
The bottom elevation of Modeling Layer 2 in the Rust model was about 100 feet bgs. Golder did not changethis depth except for minor modifications along the EWGCS to allow for a 100-foot depth of the EWGCS.
Golder did not modify the Modeling Layer 3 bottom elevations of the original Rust model.
Golder Associates
January 2005 C-4 Our Ref.: 043-6299
3.3 Hydraulic Conductivity
The Rust model assigned hydraulic conductivity values by defining parameter zones within the modelinggrid. To address results of site hydrogeologic testing conducted in the 1990's, Golder increased thehydraulic conductivity in Modeling Layers 1 and 2 by two zone numbers, resulting in an average increase inhydraulic conductivity by a factor of 1.2. Golder did not change the hydraulic conductivity of ModelingLayer 3.
The Rust model did not specify anisotropic conditions for the hydraulic conductivity zones defined alongfracture trace lineaments that dissect the Harpers Phyllite Formation. Pumping tests conducted at the Site inthe Harpers Formation indicate anisotropy factors range from 3 to 5, with higher hydraulic conductivityalong foliation planes (i.e., parallel with the east-northeast strike). To accommodate anisotropic hydraulicconductivity in the Harpers Formation, Golder updated the model to include an anisotropy factor of 3 for thehydraulic conductivity zones along fracture trace lineaments.
3.4 Precipitation Recharge
The precipitation recharge rate used in the Rust model simulating September 1992 conditions was 5.7inches per year (1.3xl0-3 ft/day). The groundwater elevations used to calibrate the model were obtained priorto high precipitation events that occurred at the end of September 1992 (see Table C-3). Historically, theSeptember water levels are in general the lowest for the year (see Table C-4).
For the updated model calibration, Golder used water level data collected from June 1995 through August1996. During this period, the calculated annual precipitation was 44.7 inches (see Table C-5). Golder used aprecipitation recharge of 11.03 inches per year (2.519xl0-3 ft/day) for areas not covered by landfillbaseliners. This rate assumes a 25 percent infiltration rate into the soils, with the remainder lost toevapotranspiration and runoff.
The 66-Acre Landfill is capped with a clay and synthetic HDPE geomembrane system. Because this landfillis unlined, however, the leachate generated by refuse within the landfill will continue to recharge to thesubsurface. Golder used a recharge rate of 4 x 10-4 ft/day for the 66-Acre Landfill footprint. Golder definedthe extent of each precipitation recharge zone based on the corresponding Site development conditions (i.e.,landfill capping and completion of expansion areas).
3.5 Constant Head and River Nodes
In the updated model, Golder placed constant head boundaries at the edge of the finite difference grid.Golder selected groundwater elevations for the constant heads based on the regional groundwater contourmap presented in Figure 2-8 of the Remedial Investigation Report (Golder Associates Inc., April 1990).
Golder placed river nodes along Kreutz Creek, Cabin Creek, and their tributaries, and used the Sitetopographic map and United States Geological Survey topographic quadrangle maps to select river stageelevations. We estimated the river bottom elevations of 1 foot and 2 feet lower than the river stageelevation. Golder calculated the streambed conductance by estimating the streambed sediment hydraulicconductivity (1xl0-3 centimeters per second [cm/s]), streambed thickness (1 foot to 2 feet), and stream width(10 feet to 20 feet along the main creeks and 1 foot to 2 feet along the tributaries). Golder considered thelength of the stream within each modeling equal with the length of the finite difference cell. The calculatedstreambed conductance ranges from 280 ft/day to 1,400 ft/day.
Golder Associates
January 2005 C-5 Our Ref.: 043-6299
3.6 Pumping Rates
Table C-6 presents the pumping rates used for updated model and Rust model. The individual pumping ratesof the Western Groundwater Extraction System wells were proportionally supplemented with thegroundwater recovery rate of the Western Groundwater Interceptor Trench (Interceptor Trench).
In the original Rust model (Simulation MD10) one of the extraction wells (W41) was omitted from thesimulation. As a result, the total simulated pumping rate for the extraction wells was lower than the totalmeasured pumping rate of the extraction wells and Interceptor Trench by 1.84 gallons per minute (gpm).Golder revised the Rust model using the recalculated pumping rates (see Table C-6).
4.0 MODEL RESULTS
This section includes the model calibration results and the numerical simulation of the EWGCS conductedin 1998 (Golder Associates Inc., June 1998). Golder calibrated the updated numerical model to 1995-1996conditions (Simulation 956H), and then verified the updated model for the 1992 conditions (Simulation92H1). We also compared the simulation for the 1992 condition with the initial Rust model (SimulationMD10A). Golder then used the calibrated model to simulate operation of the entire EWGCS (SimulationTl), and conducted sensitivity analyses to evaluate model calibration and the effectiveness of the EWGCS.
4.1 Model Calibration and Sensitivity Analysis Results
4.1.1 Model Calibration
Golder calibrated the numerical model by comparing the water level data with simulated hydraulic headvalues at the corresponding well locations. Figure C-l presents the location of the water level monitoringpoints used for numerical model calibration.
Updated Model Calibration Golder used the water level data collected from June 1995 through August 1996for the updated model calibration (Simulation 965H). We used average annual water levels for the modelcalibration as suggested by Ogden (1998), and included water level data collected from the piezometersinstalled in the stream relocation area in 1998 (see Figure C-l)
The updated model calibration results are presented in Table C-7 and Figure C-2. The calibration produces aresidual mean of 1.94 feet, which represents 0.9 percent of the total hydraulic head difference for the modelarea (about 220 feet). The absolute mean for this model is 3.28 feet, which is about 1.5 percent of the totalhydraulic head difference for the entire modeling area.
A positive residual mean indicates the measured water levels are higher than the simulated hydraulic heads.Golder did not conduct further refinement of the residual mean since most of the water levels collectedduring June 1995 through August 1996 were specifically recorded after rainfall events to provide aconservative annual high groundwater table map for the Northwestern Expansion subbase design. Inaddition, the residual mean and the absolute residual mean are much lower than the industry-acceptedstandard of 10 percent of the total hydraulic head difference for the modeling area.
Updated Model Verification Golder verified the calibrated model by comparing the model simulated hydraulic heads with the average
Golder Associates
January 2005 C-6 Our Ref.: 043-6299
1992 water level data. We held constant the parameter values defined in Simulation 956H except forprecipitation recharge, which was reduced to 9.64 inches per year (2.2xl0-3 ft/day).
The model verification results are presented in Table C-8 and Figure C-3. The model verification foraverage 1992 conditions (Simulation 92H1) indicates a residual mean of -1.25 feet, which represents 0.56percent of the total hydraulic head difference for the modeling area. The model calibration results arepresented in Table C-8. The absolute mean for this model is 4.4 feet, which represents 2 percent of the totalhydraulic head difference for the modeling area. A negative residual mean indicates that the measured waterlevels are lower than the simulated hydraulic heads. Golder did not conduct further refinement of theresidual mean since the September 1992 water levels are not representative for the total precipitationrecorded (i.e., 6.90 inches, see Table C-5). The water level survey was conducted prior to late Septemberprecipitation events that totaled 3.6 inches of rain (September 22 through 26, 1992; see Table C-3).
Rust Model Calibration Data Rust used September 1992 water level data for model calibration. As indicated previously in this section,the Site conducted most of the September 1992 water level survey prior to high precipitation events thatoccurred at the end of the month. Golder reran the Rust calibration model (Simulation MD10) withoutmodifications except for the revised pumping rates (Simulation MD10A) as discussed in Section 3.5.
The Rust model calibration results are presented in Table C-9 and Figure C-4. The model calibrationindicates a residual mean of -1.45 feet and an absolute mean 7.32 feet, which represent 0.7 percent and 3.3percent, respectively, of the total hydraulic head difference for the model area. The results of the Rust modeland updated model calibration produce low values for the residual mean and absolute residual mean. Thesevalues are lower than the industry-accepted standard of 10 percent of the total hydraulic head difference forthe modeling area. In addition, the residual standard deviation for all the sensitivity runs (Tables C-10through C-13) shows a minimum value for the calibrated model indicating an optimum calibration wasachieved. Based on this, Golder considers the model calibration acceptable and the model can be used toevaluate the effectiveness of the EWGCS.
4.1.2 Updated Model Calibration Sensitivity Analysis
Golder conducted a sensitivity analysis using Simulation 956H that models 1995-1996 Site conditions. Forthe sensitivity analysis, we modified hydraulic conductivity, precipitation recharge, constant head, and riverstreambed conductance/hydraulic conductivity, and recorded the impact on the model calibration.
The sensitivity analysis results are presented in Tables C-10 through C-13. These tables indicate the modelis sensitive to changes in the hydraulic conductivity and precipitation recharge, and is less sensitive tochanges in constant head boundaries and streambed conductance/hydraulic conductivity.
The variation of input parameters produce changes in model calibration that follow a curve with relativelyuniform gradient except for changes in river streambed conductance/hydraulic conductivity. The graphshown in Table C-3 indicates changes in streambed hydraulic conductivity from 1x10-4 to 1xl0-1 cm/s do notproduce a significant impact on model calibration. However reducing river streambed hydraulicconductivity below 1xl0-4 cm/s modifies the residual mean and prevents groundwater discharge to the modelarea streams.
Golder Associates
January 2005 C-7 Our Ref.: 043-6299
4.2 Simulation of the EWGCS and Sensitivity Analysis
4.2.1 Simulation of the EWGCS
Golder used the numerical model to simulate operation of the EWGCS. We performed the simulation bymodifying the calibrated model (Simulation 956H) to reflect the construction of the EWGCS, NorthwesternExpansion baseliners, and stream relocation.
Golder simulated the EWGCS by assigning a hydraulic conductivity of 3xl0-2 cm/s in Modeling Layer 1along the proposed EWGCS trench. We placed a constant head (455 feet mean sea level [MSL]) at thenorthern (downgradient) end of the EWGCS trench to simulate groundwater discharge to a recovery well(ESW-1). Golder set the precipitation recharge to zero for the area covered by the Northwestern Expansionarea, and defined the stream relocation with river nodes having a streambed hydraulic conductivity of 1xl0-3 cm/s.
Golder conducted several computer simulations to evaluate the pumping rate and effectiveness of theEWGCS. We changed the elevation of the constant head that simulated the recovery well in 5- to 10-footincrements and recorded the discharge rate (Simulations Tl through T7). The results of these simulations arepresented in Table C-14. Golder performed particle tracking of these simulations to evaluate theeffectiveness of the capture zone created by operation of the EWGCS. The simulation results indicate theparticles released within the footprint of the 66-Acre Landfill are captured by the EWGCS and the EasternGroundwater Extraction System in all model runs except Simulation T7. Figures C-5 and C-6 present theresults of the numerical groundwater flow and particle tracking simulations for Simulations Tl and T7,respectively. Simulation Tl indicates complete particle capture along the EWGCS trench (Figure C-5),while Simulation T7 shows particles bypassing the EWGCS (Figure C-6).
The results of Simulations Tl through T7 indicate pumping rates of 30 to 55 gpm at recovery well ESW-1will provide effective hydraulic control. Higher pumping rates will likely result in efficiency losses of therecovery well as shown by the increases in slope of the graph presented in Table C-13. These simulatedpumping rates represent steady state conditions. Initial pumping rates of the EWGCS were estimated to becomparable with the recovery rate of the Western Groundwater Extraction System (i.e., 80 gpm). Howeverwhen operation of the EWGCS was initiated (October 1999), initial pumping rates during the first week ofoperation ranged from 90 to 130 gpm, with a gradual decline to about 60 gpm after a month (see FigureC-7).
The groundwater flux along the EWGCS is presented in Figures C-8 and C-9. The groundwater flux is thegroundwater volume measured in cubic feet (ft3) that flows in one day through a cross sectional area of onesquare foot (ft2). Figure C-8 presents the groundwater flux in "Y" direction (i.e. groundwater flow to thenorth). This figure shows that most of the groundwater moves along the EWGCS trench. The maximumnortherly groundwater flux along the EWGCS trench is 6.4 ft3/ft2/day at the downgradient end, and theminimum northerly groundwater flux is 0.2 ft3/ft2/day at the upgradient end. The groundwater flux is muchlower in Modeling Layer 2, ranging from 0.01 to 0.17 ft3/ft2/day beneath the EWGCS trench.
The vertical groundwater flux for Modeling Layer 2 is presented in Figure C-9. This figure indicatesgroundwater flux is upward at the southern (upgradient) end and northern (downgradient) end of theEWGCS trench. In these areas the upward groundwater flux ranges from 0.004 to 0.24 ft3/ft2/day. Along themiddle part of the EWGCS trench, the groundwater flow is essentially horizontal with upward vertical flux
Golder Associates
January 2005 C-8 Our Ref.: 043-6299
ranging from -0.001 to 0.008 ft3/ft2/day. This is consistent with observations made during the DemonstrationProject operation which indicate the trench collects water in the upgradient zone along the trench, and thenremoves the leachate impacted groundwater through a recovery well (Golder Associates Inc., December1997).
Golder used computer model simulations to evaluate the impact of the stream relocation on the groundwaterflow regime. Previous simulations completed by Rust indicate the relocated stream will lose water to theeastern bank at the southern end of the stream relocation. Golder incorporated groundwater level data frompiezometers installed along the proposed relocated stream in 1998. The updated model indicatesgroundwater discharge to the stream in this area from the western stream bank is higher, resulting in a netgaining stream for the southern end of the stream relocation area. In 1998, Modern constructed the relocatedstream using a liner in this area to minimize stream base flow losses. The remainder of the stream relocationhas a gaining stream character, collecting groundwater from both its eastern and western banks.
4.2.2 EWGCS Sensitivity Analysis
Golder conducted an additional sensitivity analysis using Simulation Tl, with recovery well ESW-1operating at a pumping rate of 54 gpm. The goal of the sensitivity analysis was to evaluate the effect ofreduced hydraulic conductivity of the EWGCS on efficiency. We also used the sensitivity analysis toevaluate the effects of a higher hydraulic conductivity of the EWGCS.
For the sensitivity analyses, Golder decreased and increased the hydraulic conductivity of the EWGCS byone order of magnitude from the simulated value of 3x10-2 cm/s (i.e., 3x10-3 and 3x10-1 cm/s, respectively).Golder performed seven simulations (Simulations T1S1 through T1S7), and the results are summarized inTable C-l5. For an increase of one order of magnitude in the EWGCS hydraulic conductivity, the pumpingrate increases from 54 to 64 gpm. For a decrease of one order of magnitude in the EWGCS hydraulicconductivity, the pumping rate decreases from 54 to 34 gpm.
The 34 to 54 gpm pumping rate range is within the estimated effective range to achieve groundwater capturefrom the 66-Acre Landfill.
Golder performed particle tracking simulations for Simulations T1S1 through T1S7 to evaluate theeffectiveness of the capture zone of the EWGCS. The simulations show that particles released within thefootprint of the 66-Acre Landfill are captured by the EWGCS and Eastern Groundwater Extraction System.Figure C-10 shows particle capture occurs along the EWGCS in Simulation T1S1 having an EWGCShydraulic conductivity of 1 x 10-3 cm/s, a reduction of one order of magnitude in hydraulic conductivity.
Golder conducted an additional sensitivity analysis run to evaluate the EWGCS's efficiency under reducedlength conditions. For this analysis, Golder assumed only the northern 200 feet of the EWGCS isconstructed (Simulation T1XS). The simulation indicates a recovery well located within at the northern endof the reduced length EWGCS will pump at a rate of 34 gpm for a corresponding groundwater levelmaintained at 445 feet MSL. The particle tracking simulation indicates capture of particles released withinthe footprint of the 66-Acre Landfill (see Figure C-11). In addition, the simulation indicates the EWGCStakes advantage of the natural groundwater flow direction and effectively captures leachate-impactedgroundwater.
Golder Associates
January 2005 C-9 Our Ref.: 043-6299
5.0 EWGCS OPERATION
This section includes simulations of EWGCS and Eastern Extraction System operation in July 2001(Simulation T101) and in July 2003 (Simulation T103). Extraction well, precipitation and groundwater leveldata collected for these periods provide an opportunity to further evaluate the calibrated and verifiednumerical model's predictive power, and identify deficiencies in model construction that could only beidentified by operation of the EWGCS.
5.1 2001 Conditions
Golder modified Simulation Tl to simulate July 2001 conditions (Simulation T101). Simulation T101 usesthe recorded pumping rates from the Eastern Groundwater Extraction system wells as measured in July2001. The precipitation rate in 2001 was below average (see Table C-4); however, Golder used the previousinfiltration precipitation rate of 11.03 inches per year for the simulation. The measured pumping rate of theEWGCS in July 2001 was 18,822 ft3/day or about 97 gpm. When we used this pumping rate for theEWGCS, the model failed to simulate pumping conditions at the downgradient end of the EWGCS. Tosimulate pumping of the EWGCS, Golder used a constant head value of 430.5 feet bgs at extraction wellESW-1. This head value is 0.5 feet above the bottom elevation of Model Layer 1 at this location. The headvalue also corresponds to a pumping rate of 12,474 ft3/day (64.8 gpm). Simulation runs exceeding 12,500ft3/day failed to model measured conditions at the north end of the EWGCS; i.e., the pumping rate of12,474 ft3/day was the maximum rate that could produce an accurate simulation result.
In July 2001, Modern constructed the baseliner of Cell 14 of the Northwest Expansion. To simulate Cell 14,Golder set the precipitation infiltration rate in Cell 14 to zero, and kept the precipitation rate of theremaining Northwest Expansion footprint to 11.03 inches per year.
The model results for Simulation T101 are presented in Table C-16 and Figure C-12. The results of the July2001 simulation produced low values for the residual mean and absolute residual mean. The modelproduces a residual mean of -0.77 feet, which represents 0.39 percent of the total hydraulic head differencefor the modeling area. The absolute mean for this simulation is 4.69 feet, which represents 2 percent of thetotal hydraulic head difference for the modeling area. A negative residual mean indicates that the measuredwater levels are lower than the simulated hydraulic heads. These values are lower than the industry-accepted standard of 10 percent of the total hydraulic head difference for the modeling area, indicating thenumerical model, even with a reduced pumping rate of the EWGCS, produces a reasonably accuratesimulation of actual conditions.
Particle pathways for Simulation T101 are shown on Figure C-l2. The particle tracking simulation indicatescapture of particles released within the footprint of the 66-Acre Landfill by the EWGCS and EasternExtraction System.
5.2 2003 Conditions
Golder modified Simulation T1 to simulate July 2003 conditions (Simulation T103). Simulation T103Auses the recorded pumping rates from the Eastern Groundwater Extraction System wells as measured in July2003. The precipitation rate in 2003 was above average (see Table C-4). Golder used an infiltratingprecipitation rate of 12.5 inches per year (about 25% of the 2003 precipitation rate of 56.42 inches). Themeasured pumping rate of the EWGCS in July 2001 was 19,568 ft3/day or about 102 gpm. To simulate
Golder Associates
January 2005 C-10 Our Ref.: 043-6299
measured pumping conditions of the EWGCS, and to avoid the use of a constant head node to simulatepumping, Golder placed four extraction well cells at the downgradient end of the EWGCS. We placed thesewells in four cells, each 25 feet by 25 feet square, for a total area of 100 square feet. We assigned a flow rateof 4,750 ft3/day for each cell, which produces an aggregate flow rate of 19,000 ft3/day, similar to thatmeasured in July 2003.
Modern constructed the baseliner of Cell 15 of the Northwest Expansion in July 2003. To simulate Cells 14and 15, Golder set the precipitation infiltration rate in Cells 14 and 15 to zero, and kept the precipitation rateof the remaining footprint to 12.5 inches per year. To provide more water to the EWGCS extraction well,we set the precipitation infiltration rate to 100% in the area north of Cell 14. This area is not vegetated anddoes not contain an appreciable runoff system.
In July 2003, the overall groundwater levels were above average. At upgradient well MU427, thegroundwater level was about seven feet above the level in 2001. To simulate an overall higher hydraulichead, Golder raised the constant heads in Modeling Layers 1, 2 and 3 by seven feet.
The model results for Simulation T103A are presented in Table C-17 and Figure C-13. The results of theJuly 2003 simulation produce low values for the residual mean and absolute residual mean.
The model produces a residual mean of -0.56 feet, which represents 0.27 percent of the total hydraulic headdifference for the modeling area. The absolute mean for this simulation is 4.49 feet, which represents 2percent of the total hydraulic head difference for the modeling area. A negative residual mean indicates thatthe measured water levels are lower than the simulated hydraulic heads. These values are lower than theindustry-accepted standard of 10 percent of the total hydraulic head difference for the modeling area.Similar to the results of Simulation T101, this indicates the numerical model, even with a reduced pumpingrate of the EWGCS, produces a reasonably accurate simulation of actual conditions.
Particle pathways for Simulation T103A are shown on Figure C-13. The particle tracking simulationindicates capture of particles released within the footprint of the 66-Acre Landfill by the EWGCS andEastern Extraction System. The particle pathways under no pumping conditions indicate that the currentgroundwater monitoring well network will provide adequate detection of leachate-impacted groundwaterleaving the 66-Acre Landfill prior to discharging to surface water.
6.0 SOURCE AREA ATTENUATION
Golder conducted analyses to predict when the extraction systems could be turned off and naturalattenuation of the leachate-impacted groundwater would be capable of providing groundwater remediation.To assist in this prediction, Golder conducted the following evaluations:
• Predict groundwater flow direction under no pumping conditions to evaluate the flow pathsafter the extraction systems would be turned off. For this purpose two additional groundwatersimulations were conducted: (i) turning off the EWGCS; and then (ii) turning off allextraction systems (i.e., EWGCS and Eastern Extraction system). The results of thesesimulations are presented in Sections 6.1 and 6.2, respectively.
Golder Associates
January 2005 C-11 Our Ref.: 043-6299
• Predict the total volatile organic compound (VOC) concentration reduction in the immediatevicinity of the 66-Acre Landfill and predict the time needed to achieve concentrations thatwould reach levels where natural attenuation alone could provide effective groundwaterremediation.
6.1 No EWGCS Pumping
Golder modified Simulation Tl by removing extraction well ESW-1 from the northern end of the EWGCS tosimulate no operation of the EWGCS (Simulation T1QO). We did not change any other parameters in the Tlmodel for this simulation. The simulation also assumes that the baseliners of the Northwest Expansion arecomplete.
The results of Simulation T1QO are shown on Figure C-14. The particle pathways show that groundwaterfrom the western and central portions of the 66-Acre Landfill flows to and within the EWGCS, anddischarges north of the treatment plant facility to Kreutz Creek. Groundwater from the northeastern portionof the 66-Acre Landfill discharges to the unnamed tributary northeast of Modern Landfill, which dischargesto Kreutz Creek. Groundwater from the southeastern portion of the 66-Acre Landfill flows to the EasternExtraction System.
6.2 No Pumping Conditions
Golder modified Simulation T1 by removing extraction well ESW-1 from the northern end of the EWGCSand removing the Eastern Extraction System to simulate no pumping conditions (Simulation T1NOQA). Wedid not change any other parameters in the T1 model for this simulation. The simulation also assumes thatthe baseliners of the Northwest Expansion are complete. As the unnamed tributary is normally dry near theEastern Extraction System, and we added tributary river nodes in this area to simulate groundwaterdischarge to the tributary under no pumping conditions.
The results of Simulation T1NOQA are shown on Figure C-15. Like Simulation T1QO, the particlepathways show that groundwater from the western and central portions of the 66-Acre Landfill flows to andwithin the EWGCS, and discharges north of the treatment plant facility to Kreutz Creek. Groundwater fromthe northeastern portion of the 66-Acre Landfill discharges to the unnamed tributary northeast of ModernLandfill, which discharges to Kreutz Creek. Groundwater from the southeastern portion of the 66-AcreLandfill also flows to the unnamed tributary.
The results of the simulations discussed in Sections 6.1 and 6.2 indicate that, if the extraction system isturned off, the existing monitoring wells along the simulated flowpaths will allow effective monitoring ofnatural attenuation of landfill leachate constituents. In addition, these simulations allowed the evaluation ofthe hypothetical leachate constituents travel distance to their discharge to surface water (i.e., 900 feet to3,600 feet).
6.3 Natural Attenuation Assessment
As discussed above, the particle pathways shown on Figures C-14 and C-15 have lengths of about 900 feetto 3,600 feet. Roughly half of the particle pathway lengths are beneath landfill areas, which do not receiveinfiltrating oxygenated precipitation. Therefore, if the extraction systems are turned off, groundwaterimpacted by leachate will be chemically reduced once leaving the 66-Acre Landfill area, and will reach
Golder Associates
January 2005 C-12 Our Ref.: 043-6299
more chemically oxidizing conditions once leaving the landfilled areas, due to infiltration of oxygenatedprecipitation. Natural attenuation via bioremediation by naturally occurring microorganisms is controlled bythe oxidizing and reducing conditions. Assessment of the potential of natural attenuation as the primaryremediation method at Modern Landfill will require predictions of oxidation-reduction conditions (as wellas other conditions) under no pumping conditions, and accounting for a reduced groundwater gradient.
To provide a prediction of total VOC reduction rates, Golder compiled the total VOC concentrationsmeasured in monitoring wells downgradient of the 66-Acre Landfill, and plotted the historical range ofconcentrations (see Table C-18). We also plotted an exponential trend line curve to help predict future totalVOC concentrations.
VOCs in groundwater degrade due to natural chemical and biological processes. The half-life (t ½) of aconstituent represents the time required for the concentration to decrease to one-half of the original value.Table C-19 presents the ranges of half-life times for the VOCs detected at the Site in 2003. Goldercalibrated the half-life using field data, and calculated the parameter 8 (8 = (1 n 2)/½) {time-1}. Thisparameter represents the rate of mass treated for both the dissolved phase and sorbed phase.
The exponential trend curve in the graph of Table C-18 containing the equation for the total VOC half-life isbased on total VOC trends measured at the Site since 1987. The equation is: y = 5E + 154e-0.1751x, where x istime in years and y is VOC concentration in ug/L. The half-life solution using a unit concentration is 3.96years or about 1,450 days. This estimate of total VOC half-life is comparable to that of the individualconstituents. Table C-19 presents the half-life time of the individual compounds that make up the total VOClist. Table C-19 has been compiled based on a literature search. As can be seen, the overall half-life timepredicted for the total VOC degradation (1,450 days; see Table C-18) represents the median value ofhalf-life time of individual VOCs listed in Table C-19.
The graph in Table C-18 shows that total VOC concentrations downgradient of the 66-Acre Landfill areexpected to be about 10 micrograms per liter [ug/L] in the year 2020 if pumping conditions remainunchanged. Based on Golder's experience, total VOCs in this concentration range can be remediated viabioremediation and natural attenuation. This is a very conservative assumption since the 10 ug/L of totalVOC would likely result in no exceedances of individual VOC constituents at the monitoring wells locatedin the immediate vicinity if the 66-Acre Landfill. As a result, no additional attenuation downgradient of the66-Acre Landfill would be needed to reduce the individual VOC concentrations below standards.
This estimate is consistent with industry standards. The USEPA estimates the time to complete operationsand maintenance remediation phases at typical Superfund sites to be about 30 years. Modern started pumpand treat groundwater in 1987. Golder estimates that currently the Site is about halfway through thisremediation phase. Based on the results of the groundwater modeling, half-life estimate, and naturalattenuation assessment, Golder believes the extraction system wells may be able to be taken off line in about15 years. After this occurs, the total VOC concentrations will be low enough such that natural attenuationmechanisms will be able to remediation impacted groundwater. As indicated above this is a conservativeestimate and the time to clean-up might be shorter.
However, to obtain a closure certification from PADEP (Owners and Operators of Hazardous WasteTreatment, Storage and Disposal Facilities, 25 PA Code 264.166), Modern Landfill would have todemonstrate to PADEP the Site no longer poses a threat to the environment. According to the Record ofDecision (ROD; see Appendix A), the goal of the Site remedy is to restore groundwater to background
Golder Associates
January 2005 C-13 Our Ref.: 043-6299
conditions. As VOCs are manufactured chemicals, and only a very few rarely occur naturally in theenvironment, the remediation goal can be interpreted to cleanup groundwater to non-detect concentrations.However, to Golder's knowledge, the definition of the Site boundary is not provided in the ROD or in thePADEP regulations, and it is unclear whether the groundwater cleanup goal is background concentrationimmediately beneath the 66-Acre Landfill or at the Site boundary. Therefore if Modern wishes to obtain aclosure certification, Modern should seek an interpretation of where background conditions must bereached.
7.0 SUMMARY
Additional numerical groundwater flow simulations of the EWGCS incorporating increases in precipitationrecharge and the inclusion of recently derived Site hydrogeologic data indicate that the results of theprevious models remain unchanged. The current and previous numerical models indicate that the EWGCS,with a recovery well pumping in steady state conditions at 35 gpm to 55 gpm, will collect leachate-impactedgroundwater as effectively as the existing Western Extraction System. The analysis indicates that evenunder an extreme reduction in the hydraulic conductivity of the EWGCS trench, the groundwater from the66-Acre Landfill will be collected by the downgradient recovery well. The results of the current models alsoindicate that the relocated stream will remain a net gaining stream. Simulations of measured conditions in2001 and 2003 verify the numerical model remains an effective predictive tool to assess groundwaterconditions at Modern Landfill. Half-life estimates of total VOC concentrations indicate the extraction wellsystems will need to be maintained to the year 2020; after this period VOC concentrations will be lowenough for natural attenuation mechanisms to be sufficient to continue remediating groundwater.
Golder AssociatesJanuary 2005 C-14 Our Ref.: 043-6299
8.0 REFERENCES
Environmental Solutions Inc., 2004. Groundwater Vistas User Manual, Vers. 4, Reinhold, Pennsylvania.
Golder Associates Inc., April 1990. Phase 1 Remedial Investigation Report, Modern Landfill, York,Pennsylvania.
Golder Associates Inc., October 1997. Enhanced Western Groundwater Control System DemonstrationProject Data Report, Modern Landfill, York, Pennsylvania.
Golder Associates Inc., November 1997. Hydrogeologic Assessment Report, Enhanced WesternGroundwater Control System Demonstration Project, Modern Landfill, York, Pennsylvania.
Golder Associates Inc., December 1997. Overall Assessment Report, Enhanced Western GroundwaterControl System Demonstration Project, Modern Landfill, York, Pennsylvania.
Golder Associates Inc., March 2000. Enhanced Western Groundwater Control System Final As-BuiltReport, Modern Landfill, York, Pennsylvania.
Howard, P. H. et al., 1991. Handbook of Environmental Degradation Rates, Lewis Publishers.
McDonald, M. G. and Harbaugh, A. W., 1988. MODFLOW - A Modular Three-Dimensional FiniteDifference Ground-Water Flow Model, Techniques of Water-Resources Investigations of the UnitedStates Geological Survey, Book 6, Chapter Al, US Government Printing Office, Washington, DC.
Ogden Environmental Inc., February 1998. Technical Evaluation of the Proposed Western GroundwaterControl System for the Modern Landfill Sanitation Site, York, Pennsylvania.
Pollock, D. W., 1994. User's Guide for MODPATH/MODPATH-PLOT, Vers. 3: A Particle TrackingPost-Processing Package for MODFLOW. United States Geological Survey Open-File Report94-464.
Rust Environment and Infrastructure, February 1996. Western Groundwater Control System DemonstrationProject, Modern Landfill, York, Pennsylvania.
Rust Environment and Infrastructure and Golder Associates Inc., June 1998. Modern Landfill - NorthwestExpansion, Response to May 13, 1998 Technical Comments, Modern Landfill, York, Pennsylvania
J A N U A R Y 2005 Our R e f : 043-6299
TABLE C-l
SUMMARY OF NUMERICAL MODEL SIMULATIONSFIVE-YEAR REVIEW REPORT
MODERN LANDFILL
Simulation 956HUpdated Model Calibration Run
Simula t ion 92H1Updated Mode! Verification
RunSimulat ion MD10A
RUST Model Calibration Run
Simulation Tl
Simulation T7
Simulation T1S1
Simulat ionsS956K1A through 956K4A
Simulations956H IB through 956H5B
Simulations9561 1 1C through 956H3C
SimulationsS956H ID through 956H3D
SimulationsTl through T7
SimulationsTIS1 through T1S7
Simulation TXS1
Simulation T101
Simulation T103A
Simulation T1QO
Simulation T1NOQA
Figure C-2
Figure C-3
Figure C-4
Figure C-5
Figure C-6
Figure C-10
Table C-9
Table C-10
Table C- 11
Table C-l 2
Table C-l 3
Table C-14
Figure C- 11
Figure C- 12
Figure C-13
Figure C-14
Figure C-15
Presents simulated hydrau l ic heads tor the June 1995 -August 1996 Site conditions.
Presents the simulated hydrau l i c heads for the 1992Site conditions.
Presents the simulated hydraul ic heads for September1992 Site Conditions.Presents the simulation of the proposed EnhancedSystem using a pumping rate of 54 gpm.Presents a sens i t iv i ty analysis run for the proposedEnhanced System using a pumping rate of 23 gpm.Presents a sens i t iv i ty analysis run for the proposedEnhanced System using an Enhanced System trenchhydraulic conductivity of 3x1 0-3 cm/s (pumping rate of34 gpm).Presents sensit ivity analysis runs for the UpdatedModel Calibration hydraulic conduct ivi ty. Thehydraul ic conductivity of the modeling zones wereincreased and decreased by an average factor of 1.2.Presents sensi t ivi ty analysis runs for the UpdatedModel Calibration precipitation recharge ranging from5.5 inches per year to 16.5 inches per year.Presents sensi t ivi ty analysis runs for the UpdatedModel Calibration constant head boundaries. Theconstant head boundaries were increased and decreasedby 5 feet.Presents sensitivity analysis runs for the UpdatedModel Calibration streambed hydraulic conductivityranging from I x l O " 5 cm/s to I x l O " 1 cm/s.Presents sensit ivity analysis runs for the proposedEnhanced System using groundwater elevation in therecovery well ranging from 445 feet msl to 495 feetmsl.Presents sensitivity analysis runs for the proposedEnhanced System using Enhanced System trenchhydraulic conductivity ranging from 3x10" cm/s to3x10' cm/s.Presents a sensitivity analysis run for the proposedEnhanced System using a pumping rate of 53 gpm andassuming that only 200-foot of the enhancedpermeability zone is placed at the northern end of theNorthwestern Expansion.Presents s imulat ion of Enhanced System under 2001conditions.Presents simulation of Enhanced System under 2003conditions.Presents simulation of Enhanced System with nopumping.Presents simulation with no pumping
tMahles\TABLECI DOC" Golder Associates Prepared by:Checked by:
Reviewed by: Tii ft-
JANUARY 2005 Our Ref. 043-6299
TABLE C-2TRENCH DEPTH
FIVE-YEAR REVIEW REPORTENHANCED WESTERN GROUNDWATER CONTROLED SYSTEM
MODERN LANDFILL
Pilot Test Trench Depth
Average Drilling Depth[feet]
d6777878277726768697072
Weighted Average74.36
Length[feet]
L6130922217157232221621
dx L40872310800418041309108048242176151811201512
Totals400 29744
Prepared by:Checked by:Reviewed by:
P \Proiecl5\2004\043-6299 Modern Landfill 5 yr Revtew\Report\AppendixCTRDEPTH XLS 1/5/2005 1020 AM Golder Associates Page 1 of 1
JANUARY 2005 Our Ref. 043-6299
TABLE C-3SEPTEMBER 1992 PRECIPITATION DATA SUMMARY
FIVE-YEAR REVIEW REPORTENHANCED WESTERN GROUNDWATER CONTROLED SYSTEM
MODERN LANDFILL
Month-Year
JanuaryFebruary
MarchAprilMayJuneJuly
AugustSeptember
OctoberNovemberDecember
:.||: • . Total:-'W-< Monthly Average:
1991[in.]5.381.754.220.821.02
1.051.804.832.022.003.71
28.712.39
1992[in.]4.002.37
2.335.173.003.901.706.90*1.755.105.76
43.383.62
1993[in.]2.804.149.503.903.202.60
5.004.033.565.657.57
54.054.50
1994[in.]7.906.837.722.933.01
Kfitetytti5.734.742.851.104.413.07
51.364.28
1995[in.]4.051.57
1.823.704.096.011.292.396.625.052.0939.893.32
1996[in.]4.621.714.143.752.964.285.06
5.887.075.267.55
53.814.48 -
1997[in.]1.901.454.30
4.502.302.952.352.562.607.302.55
35.562.96
oc
2.8
2.4
2.0
1.6cO
I 1.2
8 °-8
a0.4
0.0
Notes:1.) Yearly high monthly precipitation in indicated as =2.) Yealy low monthly precipitation in indicated as =3.) * Groundwater level data used for model calibration analysis was
obtained during 9/16/92 through 9/24/92 prior to 2.4 inch rainfallon 9/25/92; see graph below.
PRECIPITATION DATA, SEPTEMBER 1992
JL5 7 9 11 13 15 17 19 21
Date
Source: Modern Landfill Flow Report, September 1992.
23 25 27 29
Prepared by:
Checked by:
Reviewed by: •JV*» £*•
P:\Projects\2004\043-6299 Modem Landfill 5 yr Review\Report\Appendix C\Ta|CPRECIP.XLS 1/5/2005 10 20 AM tSblder Associates Page 1 of 1
JANUAi. .JOS if 043-6299
TABLE C-41991 - 2003 PRECIPITATION DATA SUMMARY
FIVE-YEAR REVIEW REPORTENHANCED WESTERN GROUNDWATER CONTROLED SYSTEM
MODERN LANDFILL
Month
JanuaryFebruary
MarchAprilMayJuneJuly
AugustSeptember
OctoberNovemberDecember
TotalMonthly Average
Precipitation Amount per Year [inches]19915.38
1.75
4.22
0.82
1.02
0.111.051.804.832.022.003.7128.712.39
19924.00
2.37
1.402.335.173.003.901.706.901.755.105.7643.383.62
19932.804.149.50
3.90
3.20
2.60
2.105.004.033.565.657.5754.054.50
19947.906.837.722.933.011.075.734.742.851.104.413.07
51.364.28
19954.05
1.57
1.211.823.704.096.011.292.396.62"5.052.0939.893.32
19964.62
1.71
4.14
3.75
2.96
4.28
5.06
1.53~5~o~S7.07
5.26
7.55
53.814.48
19971.90
1.45
4.30
0.804.50
2.30
2.95
2.35
2.56
2.60
7.30
2.55
35.562.96
19984.90
4.63
5.57
4.40
7.30
4.15
3.70
2.40
1.50
4.30
0.801.00
44.653.72
19996.45
2.90
2.97
3.22
2.12
1.64
1.79
2.07
13.942.70
1.95
3.91
45.663.81
20003.71
2.90
6.64
4.75
4.21
3.79
2.54
2.54
8.05
0.56 J1.81
3.04
44.543:71
20012.90
2.20
5.00
2.90
2.70
3.60
2.80
3.60
3.72
0.82 :1.211.81
33.262.77
20023.230.434.01
2.45
4.00
2.98
1.56
3.25
3.19
6.48
3.54
4.89
40.013.33
Annual Site Average < :< ; .•*••
20032.375.17
3.64
2.77
4.80
7.02
3.61
6.16
7.50
4.56
4.77
4.05
56.424.7043.95
Notes:1. Yearly high monthly precipitation is indicated as2. Yearly low monthly precipitation is indicated as
ANNUAL PRECIPITATION SUMMARY
Tota
l P
reci
pita
tion
[in.]
-* ro
co
** en
tj>
D O
O O
O O
O
- - - - -
•|: 1
i 1
•> 'y.,-
— 1
/ \' '
— i
'•?•
Site Aver
'^'
';.'.''' '
age 43 95
1f
."f': **'*
$
*v'
1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003
Year
Prepared by:Checked by
Reviewed by Ji)
f <Plt*KtfUQO*U43 «?w Monvm L.ntM 5 yiCPHtCIP XLS I/V200S 10 20 AM Colder Associates Page 1 of 1
JANUARY 2005 Our Ref. 043-6299
TABLE C-51995 - 1996 PRECIPITATION DATA SUMMARY
FIVE-YEAR REVIEW REPORTENHANCED WESTERN GROUNDWATER CONTROLED SYSTEM
MODERN LANDFILL
1995 -1996 Survey
Month-Year
Jun-95Jul-95Aug-95
Precipitation[in.]4.096.011.29
Sep-95 2.39Oct-95 • ••••• ••••••••RNov-95Dec-95Jan-96Feb-96Mar-96Apr-96May-96Jun-96Jul-96Aug-96
Total:^ W^fP? Monthly Average: ,
Calculated Annual Precipitation:
5.052.094.621.714.14
3.752.964.285.061.53
55.59$1 Y *-*•,:!•••:• '.--3.7131 ^ '::• -- •&*'
44.47
Prepared by:Checked by:Reviewed by: "J*.\ A> Ft-
P'Pro|ecls'2004\043-6299 Modern tandltll 5 yr Revie^ReQorTVAppendm CMabtes\CPHECIP XLS I(i7005 10 21 AM Golder Associates Page 1 of 1
JANUAR. _.,J5
TABLE C-6SIMULATED PUMPING RATESFIVE-YEAR REVIEW REPORT
ENHANCED WESTERN GROUNDWATER CONTROLED SYSTEMMODERN LANDFILL
Well
Wes
tern
Ext
ract
ion
Sys
tem
Eas
tern
Ext
ract
ion
Sys
tem
Total
InterceptorTrenchW01W03W04W05W07W08W09W10W11W12W13W20W62W64W68W69
ESW-1ESW-2ESW-3ESW-4W21W35W36W37W38W39W40W41W43W44W45W60
ModelCoordinate
X
[«]
4196.724054.364050.884051.614066.444225.723970.113871 063814.893910.984086.304081.074008.594225724132.234197.23
6350.396521.476524.326525.366525.976529.086532.716533.826473.926415.726388.455654.88
ModelCoordinate
Y
[ft]
3421.034520.124314.624139.463561.383373.124714.254945.825220.565400.824387.595512594615.303373.125695.585851.79
5108.123990484111.284210634308.364408.644503.234571.554746.604928.375047 385290.28
Simulated 1992Pumping Rates
[ftVday]
43.706V75
662.120.00
585.19563.92524.68277.59
1164.83443.08791 34
3698.7462829773.54
5128651241.29
n/in/in/in/i
70.411701.3249590205.9115649185.35260.83285.61
1092.411427.55484.34
1789.8824,745
Simulated 1995-1996 Pumping
Rates
[ftVday]
45.6617.16
611.69247.36590.48661 35326.04232.21
1735.541192.68674 10
1979.73360.90613.42
3848.851261.48
n/in/in/in/i
88.091475.341421.4128805149.1026062503.58456.42
2188.932347.11
754.042081.60
26,413
1992
MeasuredPumping
Rates
[gal/year]
7.208,262
100,326141,772
1,520.138
1,343,5211,294,6861,204.587
637,3192,674,2911,017,2411,816,8178,491,7871 ,442,4641,775,944
11,774,6752,849,835
n/in/in/in/i
192,2464,645.2631,353,990
562,209427,271506,066712,170779,835
2,982,6943,897.7721,322,4454,887,082
67.562,708
Recalculated 1992Pumping
[gal/year]
0
119,314168,605
1,807,8480
1 ,597,8031.539,7261.432,574
757,9423,180,4431 ,209,7702,160,678
10,098,9911,715,4732,112,069
14.003,2183,389,211
n/in/in/in/i
192,2464,645,2631,353,990
562,209427,271506,066712,170779,835
2,982,6943,897,7721,322,4454,887,082
67,562,708
[ftVday]
0.00
43.7061.75
662.120.00
585.19563.92524.6827759
1164.83443.08791.34
3698.74628.29773.54
5128.651241.29n/in/in/in/i
70.411701.32495.90205.91156.49185.35260.83285.61
1092.411427.55484.34
1789.8824744.71
1995
MeasuredPumping
Rates
[gal/year]
1,912,706
120.39145,078
1,548,013631,242
1,484,3441,553,961
775,088510,302
4,466,0212,467,9061,440,6975,216,858
943,3081,531,708
10,075,9503,094,303
n/in/in/in/i
221,5164,764,9403,627,456
701,315395,263643,670
1.355,1141,126.6054,883,7343,474,8441,919,0535,184,366
66,115,752
1996
MeasuredPumping
Rates
[gal/year]
3,586,982
1 1 1 ,483
42,0571,558,650
625,0711.514,5921,804.927
880,808669,036
4,348,4913.589,4831,982,9514.837.856
889,6471.583,7289,471,6733,312,514
n/in/in/in/i
259,5003,291,5914,134,539
871,659418,923779,493
1,394,8221,365,7997,069,5089,342,2232,198,5936,182,801
78,119,400
1995-1996
Avgerage1995-1996
Rates
[gal/year]
2,749,844
115,93743,568
1,553,332628,157
1 ,499,4681.679,444
827,948589,669
4,407.2563.028,6951.711,8245,027,357
916,4781,557,7189.773,8123,203,409
n/in/in/in/i
240,5084,028.2663,880,998
786,487407,093711,582
1,374,9681 ,246,2025,976,6216,408,5342,058,8235,683,584
72,117,576
Recalculated 1995-1 996Pumping Rates
[gal/year]
0
124,65646,844
1,670,152675,398
1,612.2371.805,749
890,215634,016
4,738,7093,256,4711.840,5645,405,445
985,4021,674,868
10.508,8633,444,325n/in/in/in/i240,508
4,028,2663,880,998
786,487407,093711,582
1,374,9681,246,2025,976,6216,408,5342,058,8235,683,584
72,117,576
[ftVday]
000
456617.16
611.6924736590.48661.35326.04232.21
1735.541192.68674.10
1979.73360.90613.42
3848851261.48n/in/in/in/i
88091475.341421.4128805149.10260.62503.5845642
2188932347.11
754.042081.60
26,412.92
2001
JulyMeasuredPumping
Rates
[ftVday]
decomdecomdecomdecomdecomdecomdecomdecomdecomdecomdecomdecomdecomdecomdecomdecom
12,474.323,224.331.71462
805.645749
1.065.371,158.96
281.75142.51146831630440542
1.246.891,812.80
793.081,578.34
27.071.39
2003
JulyMeasuredPumping
Rates
[ftVday]
decomdecomdecomdecomdecomdecomdecomdecomdecomdecomdecomdecomdecomdecomdecomdecom
12,930884,563 98
92384522.18
57 731,568.481,116.82
6494913976271.84711.18771.90
2.067 142.32233
8296398340
30,43056
Notes:n/i = not installed; EWGCS Wells (ESW-1, -2. -3. -4) installed 1999.decom = decommissioned, Western Extraction System wells decommissioned 1999ft = feet(tt3/day] = cubic feet per daygal = gallon
Prepared byChecked by
Reviewed by. JVQ h* f(r-
Golder Associates Page 1 ol i
TAoi-E C-7MODEL RUN 956H CALIBRATION DATA, 1995-1996 CONDITIONS
FIVE-YEAR REVIEW REPORTENHANCED WESTERN GROUNDWATER CONTROLED SYSTEM
MODERN LANDFILL
Well I.D.
MD102
MD103S
MD107S
MD111MD112S
MD118MD119MD120MD122S
MD128
MD138
MD201S
MD207S
MD210SMD212D
MD403
MD421S
MD423S
MD425SMD428
MD432
MD433
MD501S
MD503S
MD505SMU127
PZ-1SR
PZ-2SRPZ-3SR
PZ-4SR
PZ551SPZ553S
PZ555S
X
4309824069.59
3671 633832754244 43
589925
582656
5686 13554863
599595
6236 024262 67
4845 14
5186475577 23
3318.74
363587
392416
4096 1 3315011
2522.45
2711.94
270004
3181 95366830
5535.502331 472437 93
2460 52216804
362495
3343 39
3030 36
Y
321290421566
5381 54566597618404
590393
543296
512902423797
3290.46
5321 456756.29
6958.51
6757.12
6389 682696.21
476755
4006633413895131 583595.27
3208.78
556268
6326686256.98
273957
527501
5658.99
609709
616588
5738 35
5951 195869 33
Layer
111111111111111111111111111111111
Observed[feet MSL]
601.2853682
50430
49292494 46
512.71
51820
52048573.13
60786
521.2149228
489.66
494.55
501 45641.43
515.90
54682583.03
5135955234
578.68
51223
48975491 8963480
52263
511 43500.20
49768
49577
49921
50081
Computed[feet MSLJ
59864
52358
49772
491 82494 17
512.69
51457
5155956668
606.80
5238348927
491.44
496.18
50372
635.31505.17
54231587.64
51289551 3457078
510.12
491 57491.94
635.99
5223851237
49697
49690496 44497.0349987
Residual[feet]
2641324
6581.10
0290.02
3.63
4896.45
1.06
•263
301-1 78-1.63-227
6 12
10.73
451
-4.61
0.70
1.00
7.90
2.11
-1 82
-0.05
-1.19
025
•094
323
078•067
2 18
094
Statistics
Residual Mean 1 94
Res Std Dev 4 10Sum of Squares 133758
Abs Res Mean 3 28
Mm Residual -5 51
Max Residual 1324
Head Range 21004
Head Range/Std 0 02
Well I.D.
PZ557SPZ559S
PZ561S
PZ563S
PZ565S
PZ569S
PZ-5SR
PZ-6SRPZ-7SR
PZ-8SR
PZ-9SRMD125
MD137
MD429S
MD431
MU101MU427
MD104IMD108I
MD113D
MD123IMD202D
MD208I
MD209D
MD211MD422D
MD424D
MD426DMD430D
MD502D
MD504DMD506D
CO
MP
UTE
D V
ALU
ES
|le
«t M
SL]
450 H4
X
303051343423
315068
254643
2722 75388402
2030 78
190534
1702.59
224929
2657 37
5091 356596.99
265689
2374 96469394
4018.71
4064.503679.14
4226 685551 674271.78
4929464889.71
5165.42
3646.60
392846
4108232641 332696 08320064
3668 91
Y
5363.295471 33564576
5029 10
6081 74605382
577656
5458 715084.68
641370
663688315092
5118.07
468683400541
2550.57
2131.76
4220195376.626189.34
4233106749.53
6931 256946 666806254770.27
4021.38
3400094667 88
5541 52632041
6276 79
Layer
1
111222222333333333333333
Observed[feet MSL]
510 1450422
502.33
517.18
50025493.40
51068
5244254072
493.90
488.05
6275652674
5305754791
676.12
693.7653327
505.65
495.18
5674848373
48951
48859494.54
516.96
546.35
58522531.10
51238
49330491 17
Computed[feet MSL]
5092650333
502 735178749674
49358
50798
522 7853720
49391
48840
63208528.94
524 1453864
6705169327
523.01496.73
49389
565 1948924
49267
49208
4964050449
54095
58832
524 1851029491 54491 71
Residual[feet]
088089-040
-069
351-0 182701 64352-001
-035
-452
•220
6439275610.49
1026
891
1.30
229-5.51
-3.16-349
-1 8612.47
5.40
-3 106 922091 77
-054
•
•
• *»
A* ALayor I* • Layer 2
»A* • Layer 3
-X
>0 500 550 600 650 700
OBSERVED VALUES [!«•! MSL|
Note, r\ M/J1 ) Groundwater level data lor calibration analysis taken rom 1995-1996 daily precipitation-dependent measurements. Prepared by IV"
1995-1996 quarterly sampling events, and March 1998 measurements Checked by
Rev.ewed by fjf-
Golder Associates Page 1 ol t
JANUAK O. ,. 043-6299
TABLE C-8MODEL RUN 92H CALIBRATION DATA, 1992 SITE CONDITIONS
FIVE-YEAR REVIEW REPORTENHANCED WESTERN GROUNDWATER CONTROLED SYSTEM
MODERN LANDFILL
Well I.D.
MD102MD103SMD106MD107SMD111MD112SMD118MD119MD120MD128MD138MD201SMD207SMD210SMD413SMD415SMU102AMU127MD125MD133MD137MD407IMU101MD104IMD108IMD113DMD202DMD208IMD209DMD211IMD414DMD416D
X
4303.284064.983728.923699.143832.754240.225890.845826.565670.955995.956223.394262.674845.145186.473700.003822.084280.005535.505091.356690.806568.272400.004693.944064.503700.024226.684271.784929.464889.715165.423750.00383359
Y
3225.984239.234283.385394.925665.976175.625912.355432.965138.683290.465329.876756.296958.516757.124760.003980.062695.482739.573150.924483.065139.614690.002550.574239.945376.626189.346749.536931.256946.666806.254630.003985.10
Layer
11111111111111111122222333333333
Observed[feet MSL]
599.71536.67538.24492.86490.61492.05507.14508.93513.65605.66514.14491.11487.92493.96520.68555.56651.88629.93627.16557.31517.23523.90671 .69532.92493.31492.22482.10488.13487.36493.79512.08555.19
Computed[feet MSL]
603.75535.98536.24494.80488.88492.23512.30515.26516.15606.03525.50488.30490.99495.99509.81560.84645.56633.96628.22543.11531.02523.62660.24535.78495.01492.18488.32492.28491.67496.08515.24559.68
Residual[feet]-4.040.692.00-1.941.73•0.18-5.16-6.33-2.50-0.37
-11.362.81-3.07-2.0310.87-5.286.32-4.03-1.0614.20-13.790.2811.45-2.86-1.700.04-6.22-4.15-4.31-2.29-3.16-4.49
Note:
1 )
Statistics
Residual MeanRes. Std. Dev.Sum of SquaresAbs. Res. MeanMin. ResidualMax. ResidualHead RangeHead Range/Std
-1.255.72
1098.424.40
-13.7914.20
189.590.03
-. 650U)
1V) 600-
Q.
O0 500
450
450 500 550 600
OBSERVED VALUES [feet MSL]
A Layer t • Layer 2 # Layer 3
650
Groundwater level data lor calibration analysis taken Irom 1992 quarterly sampling events.Prepared by
Checked byReviewed by i£- Ft-
CKHTfto KLS irB9 Modem UrvIM i
10 23 AM Golder Associates Page 1 of 1
JANUARY 2005 Our Ref. 043-6299
TABLE C-9MODEL RUN MD10A CALIBRATION DATA, SEPTEMBER 1992 SITE CONDITIONS
FIVE-YEAR REVIEW REPORTENHANCED WESTERN GROUNDWATER CONTROLED SYSTEM
MODERN LANDFILL
Well I.D. Layer Observed[feet MSL]
Computed[feet MSL]
Residual[feet]
MD102MU102AMU101MD106MD111MD112SMD201SMD118MD119MD120MD137MD133MD128MD138MU127MD125
4,309.364,278.664,694.553,722.313,832.794,242.434,260.565,899.145,824.875,669.616,597.836,748.625,995.586,236.365,534.945,091.06
3,212.822,687.572,552.334,269.765,665.876,184.416,753.015,906.245,433.435,138.155,120.924,440.223,290.015,323.302,739.353,152.16
595.15650.23668.37537.38485.58491.60490.58505.10506.74511.15516.16555.30605.66509.03629.42624.90
610.91662.69675.27539.74481.38487.64487.13511.19505.98502.58521.24535.62599.36514.24633.82636.78
-15.76-12.46-6.90-2.364.203.963.45-6.090.768.57-5.0819.686.30-5.21-4.40
-11.88Statistics
Residual MeanRes. Std. Dev.Sum of SquaresAbs. Res. MeanMin. ResidualMax. ResidualHead RangeHead Range/Std
-1.458.73
1,253.697.32
-15.7619.68
182.790.05
700 -i
— 650in
600 -HI13
550 -
o.oO 500
450
450 500 550 600
OBSERVED VALUES [feet MSL]
650 700
Prepared by:
Checked by:
Reviewed by:
P \PrDiecU\2004C43-6299 Modem ..aodfill 5 yr R*visw*R*porrAppendix OTal
CMDIOATRG XLS l/S/2005 10 & AMColder Associates Page 1 ol 1
JANUARY 2005 Our Ref. 043-6299
TABLE C-10CALIBRATION RUN(MODEL RUN 956H) HYDRAULIC CONDUCTIVITY SENSITIVITY ANALYSIS
FIVE-YEAR REVIEW REPORTENHANCED WESTERN GROUNDWATER CONTROLED SYSTEM
MODERN LANDFILL
Groundwater Vistas Sensitivity AnalysisParameter: Hydraulic Conductivity
Hydraulic Conductivity Residual
RunChange Sum of Mean
Direction Zone Shift Factor Squares [feet]S956K1A Increase 2 1.2 2.17E+03 3.01S956K2A Calibration Run 0 0 1.34E+03 1.94S956K3A Decrease -1 -1.1 3.69E+03 -0.36S956K4A Decrease -2 -1.2 1.42E+04 -3.87
20 i
§, 15
| 1Q.
si5 5-n3T3
8 o -
-5 -
Hydraulic Conductivty Change vs. Residual Mean/Std.
V\\
\
"~\ . =*»
^^^^^3 - 2 - 1 0 1 2 3
ResidualStd.4.924.107.5314.28
16
14
1233
10 %a.
8 £6 §
4
2
0
Zone Shift
— • — Residual Mean » Residual Std.
Prepared by:
Checked by:
Reviewed by: "Tfa
P \Proj«cts'2004S043-6299 Modern Landfill 5 yr Revpew'-ReporUftppendm C.TablcvCS956HCH XLS 1/V20O5 10 26 AM Golder Associates Page 1 of 1
JAIMUA... 2005 Our [ ._ J43-6299
TABLE C-11CALIBRATION RUN(MODEL RUN 956H) RECHARGE SENSITIVITY ANALYSIS
FIVE-YEAR REVIEW REPORTENHANCED WESTERN GROUNDWATER CONTROLED SYSTEM
MODERN LANDFILL
Parameter: Recharge, Zone: 1 =Groundwater Vistas Sensitivity Analysis
2.52E-03 ft/day
Run MultiplierRecharge
[ft/day]Sum of
Squares
ResidualMean[feet]
ResidualStd.
AverageDrawdown
[feet]956H1B956H2B956H3B956H4B956H5B
0.50.751
1.251.5
1.26E-031.89E-032.52E-033.15E-033.78E-03
1.35E+043.63E+031.34E+031.50E+034.36E+03
9.675.301.70-1.45-4.47
10.735.654.104.596.86
9.023.700.00-3.86-7.40
Recharge Multiplier vs. Residual Mean/Std.
I|
"5•o
12
10
8
6 -
o -
0.25 0.5 0.75 1 1.25
Recharge Multiplier
-Residual Mean •- B- Residual Std.
1.5 1.75
Prepared by:
Checked by:
Reviewed by:
P\PrO|0CU\2004\O43-6299 Modern Landfill 5 yr Revi«w\Repo'f\Appgndix CMable»\CS956H XLS 1/5/20O5 1027 AM Golder Associates Page 1 ol 1
JANUARY 2005 Our Ref. 043-6299
TABLEC-12CALIBRATION RUN(MODEL RUN 956H) CONSTANT HEAD SENSITIVITY ANALYSIS
FIVE-YEAR REVIEW REPORTENHANCED WESTERN GROUNDWATER CONTROLED SYSTEM
MODERN LANDFILL
Groundwater Vistas Sensitivity AnalysisParameter: Constant Head
ConstatRun Changi
956H1C lncreas(956H2C Calibration956H3C Decreas
Residualit Head Sum of Mean F3 [feet] Squares [feet]3 5 1.22E+03 1.57Run 0 1.34E+03 1.94e -5 1.49E+03 2.26
ResidualStd.4.044.104.23
Constant Head Change vs. Residual Mean/Std.
A
B 5 •>,I 4-
S Q .^
s
T3in
o-7 -6 -5 -4
' •- _' •
- 3 - 2 - 1 0 1 2 3 4 5 6
Constant Head Change [feet]
7
— *— Residual Mean • Residual Std.
Prepared by: |ZvofeChecked by: "$"#4
Reviewed by: Jtui f^-fc-
P \Proiecla\20O4MH3 6299 Modem Landfill 5 yr ReviewVReporf.Appendix C.Tabtea'CS956HCH XLS 1(K20fK 10 26 AM Golder Associates Page 1 of 1
JANUAr, i 2005 Our,. 043-6299
TABLE C-13CALIBRATION RUN (MODEL RUN 956H) STREAMBED HYDRAULIC CONDUCTIVITY SENSITIVITY ANALYSIS
FIVE-YEAR REVIEW REPORTENHANCED WESTERN GROUNDWATER CONTROLED SYSTEM
MODERN LANDFILL
Groundwater Vistas Sensitivity AnalysisParameter: Streambed Hydraulic Conductivity, Reach: 0 =
Run MLS956H1DS956H2DS956H3DS956H4DS956H5DS956H6DS956H7D
StreambedHydraulic
iltiplier Cond. [ft/day]0.01 0.030.1 0.280.5 1.401 2.805 14.0010 28.00
100 280.00
Sum ofSquares4.24E+041.33E+031 .26E+031.34E+031.35E+031.33E+031.35E+03
2.8 ft/dayResidual
Mean Residual[feet] Std.-23.88 9.06-1.22 4.351.58 4.101.94 4.102.01 4.091.90 4.111.50 4.30
AverageDrawdown
[feet]-29.11-3.55-0.270.00-0.77-1.24-1.83
River Conductance Multiplier vs. Residual Mean/Std.
1 e-
17 10 -
!*-. 5 -
3 o-
1 " 5 "2 -10 •
§ -15 -
^ -20 •
<Z -25 -
0.001
,_
----,____jy^~
<S
/
/
/
*
0.01 0.1
MI in*g 5
1
M gf M
* * "
10 100 1000
River Conductance Hydraulic Conductivity Multiplier
— *— Residual Mean — •— Residual Std.
Prepared by: (2, V*^B
Checked by: "7fl**>
Reviewed by: Tjfc* {•*• F6-
P \PrO|ecls\2004\0« 6299 Modern LarxJMI 5 yr Rev.ew\Report\Appendix CUaDI«i\CS956M XLS KV2005 10 29 AM Golder Associates Page 1 of 1
JANUARY 2005 Our Ref. 043-6299
TABLE C-14ENHANCED SYSTEM (MODEL RUN T1) PUMPING RATE SENSITIVITY ANALYSIS
FIVE-YEAR REVIEW REPORTENHANCED WESTERN GROUNDWATER CONTROLED SYSTEM
MODERN LANDFILL
Computer Run
T2T1T3T4T5T6T7
T101 /T103
5000)£ -- 490
c S 480
| jj 470
03 oi 4600 ^~ en 450
"° f 4403 3
S °- 4300
420 J2
Extraction WellGroundwater
Elevation[feet MSL]
445455465475485490495431
Pumping Rate
[ft3/day]
11,17010,3809,3347,9866,3465,4254,43312,474
[gpm]
58.053.948.541.533.028.223.064.8
* ^^^
""" ^
^x.y = -O.Q2Q8X2 + 0.2994X + 498.46 ^ |
*
0 30 40 50 60 70 80
Pumping Rate [gpm]
—•— Pumping Rate [gpm] » T10irT103 Pumping Rate —Poly. (Pumping Rate [gpm])
Prepared by:
Checked by:
Reviewed by: i4r- )-6-
3-6299 ModerCQ_S XLS 1/5/2005 10 29 AM
i Landdll 5 yr RevieWiReporAAppendix Golder Associates Page 1 of 1
JANUAr, i 2005 TABLE C-15ENHANCED SYSTEM (MODEL RUN T1) HYDRAULIC CONDUCTIVITY SENSITIVITY ANALYSIS
FIVE-YEAR REVIEW REPORTENHANCED WESTERN GROUNDWATER CONTROLED SYSTEM
MODERN LANDFILL
Our I...... 043-6299
Groundwater Vistas Sensitivity AnalysisParameter: Kx, Zone: 85
Kx, Zone 85 = 85.05 ft/day
Run Multiplier
HydraulicConductivity
[ft/day]
Cone of Depression (COD)Sum of
SquaresAverage
Drawdown [ft]Residual
Std.
Model AreaAverage
Drawdown [ft]T1S1T1S2T1S3T1S4T1S5T1S6T1S7
0.10.250.5
0.751
1.52
8.5121.2642.5363.7985.05127.58170.10
2.65E+031.47E+035.00E+021.01E+022.35E-032.46E+027.79E+02
-7.99-5.89-3.44-1.560.002.464.42
8.696.543.801.700.012.634.63
-2.76-2.03-1.17-0.530.000.811.44
10
8 -
6 -
4 •
2 -
0 •
-2
-4
-6
-8 -
-10
Hydraulic Conductivity Multiplier vs. Average Drawdown
0 0.25 0.5 0.75 1 1.25 1.5 1.75 2
Hydraulic Conductivity Multiplier
» COD Average Drawdown - •*— Model Area Average Drawdown —*— Residual Std.
10
8
6
r 4 |
D)
2 ~
• 0
-4
225
Prepared by:
Checked by:
Reviewed by: f*- PC-
P \Proi«cl3\2004\043-6299 Modern Landfill 5 yr Review\Report\Appendix C\Tabl«8\CS71 XLS 1/S/2005 10 30 AM Golder Associates Page 1 of 1
JANUAi.. ^005 Our. ..043-6299
TABLEC-16MODEL RUN T101 CALIBRATION DATA, JULY 2001 SITE CONDITIONS
FIVE-YEAR REVIEW REPORTENHANCED WESTERN GROUNDWATER CONTROLED SYSTEM
MODERN LANDFILL
Well I.D.
MD118MD119MD-133MD138MD207SMD210SMD212SMD421SMD428MD432MD433MD501SMD503SRMD504DRMD505SRMD563S
X
5,899.255,826.566,688.256,236.024,861.485,186.475,601.403,635.873,150.112,522.452,711.942,700.043,166.703,180.003,633.302,546.70
Y La
5,903.935,432.964,481.875,321.456,920.966,757.126,410.804,767.555,131.583,595.273,208.785,562.686,249.406,245.106,160.505,030.20
yer Observed[feet MSL]
510.19515.18557.18517.87488.49494.31499.87516.52508.88547.54576.40503.25492.03491.95492.33513.36
Computed[feet MSL]
514.01520.62547.36529.97492.18496.25504.22520.92517.95549.68565.06509.06491.79491.84492.08515.87
Residual[feet]-3.82-5.449.82
-12.10-3.69-1.94-4.35-4.40-9.07-2.1411.34-5.810.240.110.25-2.51
Statistics
Residual MeanRes. Std. Dev.Sum of SquaresAbs. Res. MeanMin. ResidualMax. ResidualHead RangeHead Range/Std
-0.776.59
1,366.154.69
-12.1018.88197.490.03
Well I.D.
MD565SMD569SRMU127MD125MD137MD431MD506DRMD564DMD566DMD570DRMU101MU427MD209DMD211IMD422D
700 -
M 650-3.J^ "-7
Q SHI _
5| 550 •a —
8 500 •
45
X
2,724.003,948.105,535.505,083.436,726.182,374.963,620.502,528.902,723.803,932.404,702.983,627.284,889.715,165.423,646.60
Y
6,079.306,170.802,739.573,160.165,487.524,005.416,161.604,978.706,057.406,167.802,574.302,069.176,946.666,806.254,770.27
Layer
111222222222333
Observed[feet MSL]
493.94490.74630.99628.18520.36542.39492.10514.57494.00490.86673.96685.83488.34493.88515.45
M •**
0 500
•r
550 600 650
Computed[feet MSL]
494.63490.54635.33627.30530.14538.62492.10516.33495.01490.60655.08670.75492.13496.46520.81
i
II
700
Residual[feet]-0.690.20-4.340.88-9.783.770.00-1.76-1.010.2618.8815.08-3.79-2.58-5.36
A Layer 1
• Layer 2
» Layer 3
OBSERVED VALUES [feet MSL]
Prepared by
Checked by
Reviewed by JJU & FC-
P >Prot«cl»'£004\043 6299 Modarn I arKlliU 5 yr Rovww^oporMppondn C TjtXosl
CT101 IRQ XLS 1/V2005 1032AM Colder Associates Page 1 ol 1
JANUAK. .005 Ou . 043-6299
TABLE C-17MODEL RUN T103A CALIBRATION DATA, JULY 2003 SITE CONDITIONS
FIVE-YEAR REVIEW REPORTENHANCED WESTERN GROUNDWATER CONTROLED SYSTEM
MODERN LANDFILL
Well I.D.
MD112SMD118MD119MD120MD122SMD128MD133MD138MD201SMD207SMD210SMD212SMD421SMD428MD432MD501SMD503SRMD504DRMD505SR
X
4,244.435,899.255,826.565,688.335,599.515,995.956,688.256,236.024,262.674,861.485,186.475,601.403,635.873,150.112,522.452,700.043,166.703,180.003,633.30
Y La
6,184.045,903.935,432.965,232.424,378.973,290.464,481.875,321.456,756.296,920.966,757.126,410.804,767.555,131.583,595.275,562.686,249.406,245.106,160.50
yer Observed[feet MSL]
1 493.281 506.991 519.561 519.801 575.061 609891 555.571 512.211 488.261 489.281 494.841 501.791 519.691 512.741 551.091 504.901 497.941 497.181 495.65
Computed[feet MSL]
496.70514.58522.64522.65568.90607.18547.56532.12490.11492.58496.44504.62521.10516.57550.16509.61492.29492.35493.47
Residual[feet]-3.42-7.59-3.08-2.856.162.718.01
-19.91-1.85-3.30-1.60-2.83-1.41-3.830.93-4.715.654.832.18
Statistics
Residual MeanRes. Std. Dev.Sum of SquaresAbs. Res. MeanMin. ResidualMax. ResidualHead RangeHead Range/Std
-0.566.51
1.624.584.49
-19.9115.27
206.610.03
Well I.D.
MD563SMD565SMD569SRMU127MD137MD431MD506DRMD564DMD566DMD570DRMU101MU427MD113DMD123IMD202DMD208IMD209DMD211IMD422D
700 •
« 650-
_j ^> £ 600-
0 5
D j> 550 -Q. "
8 500 •
450 -
45
X
2,546.702,724.003,948.105,535.506,726.182,374.963,620.502,528.902,723.803,932.404,702.984,078.004,226.685,635.794,271.784,929.464,889.715,165.423,646.60
+t
0 500
Y
5,030.206,079.306,170.802,739.575,487.524,005.416,161.604,978.706,057.406,167.802,574.302,167.006,189.344,401.376,749.536,931.256,946.666,806.254,770.27
•* ""
Layer
1111222222223333333
# AL
Observed[feet MSL]
514.64495.92492.43635.57514.71545.62495.37515.90496.00492.74673.71690.87493.68565.59484.26498.23489.19494.59518.62
A
A
550 600 650
Computed[feet MSL]
51599495.04493.90636.04533.31538.82493.41516.45495.42493.85658.44677.33496.16565.54490.05493.05492.46496.74521.09
u "
700
Residual[feet]-1.350.88-1.47-0.47-18.606.801.96-0.550.58-1.1115.2713.54-2.480.05-5.795.18-3.27-2.15-2.47
A Layer 1
• Layer 2
# Layer 3
OBSERVED VALUES [feel MSL]
Prepared by
Checked by
Reviewed by
P J*rotKUV2(XM«43«79B Mexitm Lwvjld S yr Ra**t*H«KxrtAMM<idii CUabta*lTtl03«TROXLS 1/3/M03 1033AM Golder Associates Page 1 ot 1
JANUARY 2005 Our Ref. 043-6299
TABLE C-18TOTAL VOC TRENDS OF MONITORING WELLS DOWNGRADIENT OF 66-ACRE LANDFILL
FIVE-YEAR REVIEW REPORTENHANCED WESTERN GROUNDWATER CONTROLED SYSTEM
MODERN LANDFILL
Year1987
1988
1989
1990
1991
1992
1993
1994
1995
1996
1997
1998
1999
20002001
20022003
Monitoring Well and Total VOC Concentration [ug/L]MD120
787.101200.00986.00
1543.303000.004216.001115.0081000924.00540.00256.00239.00327.30376.40383.20371.70283.40
MD122S2581.702949.002584.381560.002130.00
1217.00717.00634.00488.00354.00270.00436.00255.20204.80218.20246.80
MD123I
587.60
376.00
24.0053.0060.5051.0062.0081.7085.8074.30
107.7080.60
MD125
34.4048.40
120.30180.80133.30134.40116.6057.5050.7034.0018.4512.8811.60
6.10
5.95
2.20
1.30
MD128
6.40
2.00
MD10247.6
48.3
55.621538
47.1
26252419131514
MD103S134.4
75.8
32.1429222820182022
58.2
75.8
MD104I3132.2
2157
539280317
189.7386316330334307
MD423S
10.5
6.717.03228825.531531
16.43
MD424D
6.30.13
0.55
0630.88
MD425S
0.50.15
0.13
MD426D
10.8
0.63
0.25
141.5110.98
55
Notes: ug/L = microgram per liter
5,000
10.000
1.000
100
<£<> Oo <*><<r<xo^ <<*>
1985 1990 1995 2000 2005 2010 2015 2020
-0 1751X
1990 1995 2000 2005
Time [years]
2010 2015 2020
O Total VOCs [ug/l] • Maximum Annual Concentrations [ug/lj Expon. (Maximum Annual Concentrations [ug/l])
Prepared by: "Jf4 £• Ft-Checked by:
Reviewed by:
-6299 MoJ«r-i Uncflilt 5 yCPREDICT x<» 1*2005 10 55 AM Golder Associates Page 1 of 1
JANUARY 2005 Our Ref. 043-6299
TABLE C-19VOLATILE ORGANIC COMPOUND HALF LIVES
FIVE-YEAR REVIEW REPORTENHANCED WESTERN GROUNDWATER CONTROLED SYSTEM
MODERN LANDFILL
Volatile OrganicCompound (VOC)
Half-Life[years]
1,1,1-Trichloroethane1,1-Dichloroethane1,1-Dichloroethene
1,2-Dichlorobenzene1,2-Dichloroethane
1,2-Dichloropropane1,4-DichlorobenzeneCarbon Tetrachloride
ChlorobenzeneChloroethane
cis-1,2-DichloroetheneDichlorodifluoromethane
Methylene ChlorideTetrachloroethene
TolueneTotal Xylenes
TrichloroetheneTrichlorofluoromethane
Vinyl Chloride
0 .4 -30.1 - 1.70.1 -0.50.1 - 20.3-2
0.5- 14.10.1 - 2
0.02 - 10.2- 1.6
0.02 - 0.30.1 - 80.1 - 2
0.1 -0.30.5-4.5
0.01 -0.60.02 - 10.3-4.50 .5 -40.1 - 8
Notes:1) Volatile organic compounds listed were detected in 2003.
2) Reference: Handbook of Environmental Degradation Rates. Howard, P.M. et. al. 1991.Lewis Publishers.
3) Ranges are based on Both aerobic and anaerobic degradation in groundwater.
Prepared by:Checked by:Reviewed by:
P \Protecl6\20W\043-6299 ModenCHALF XLS 1/W005 10 35 AM
Landfill 5 yr RevtewVReporMppendix CJabtesV Golder Associates Page 1 of 1
APPENDIX D
NEWSPAPER ANNOUNCEMENT
JP)N-04-20E5 15:25
Stjtis
Environmental Prottctien
- - ^^^^ •• •B^B^^^^^^^^^^^^^^^^^^^^ -
Hazardous Site Cleanup Division1650 Arch Street
Philadelphia, PA 19103-2029/ / FAX TRANSMISSION
DATE: I /4fe PAGE l of
PLEASE DELIVER AT ONCE TO
NAME:
FIRM NAME: G>c^<W-
PHONE:
FAX NUMBER: - /
FROM:
PHONE:
FAX NUMBER: .1-(215) 814-3002
COMMENTS/NOTE:
Kt-
JflN-Q4-2005 1=:^5
adopted by Israel aod thePalestinians last year butnever got off the ground, withboth sides failing to meeteven initial obligations.
blocs in aiy tuiurt aeaithe Palestinians.
Sharon said he will abideby bis disengagement plan,not the road map.
iji resi-dents poured into the streets,pelting the Israelis with rocksand molotov cocktails, according-to witnesses and theIsraeli military.
yaw-old twin German girts txirjoined at the bead resumedWednesday at the Johns Hoj>fciruc Children's Center in Balti-more, four days after beinghalted when one developed amedical problem.
TION 2004
might receive
ag surgePolls taken in the spring
and summer by the HarvardInstitute of Politics, the PewResearch Center and MTV allTound that young people saythey plan to vote in numbersthai will lar eclipse the lowwater mark of four years ago.
ad
cu-ire
alo-
Tbe pool of potential youngvoters if yiihgtjntiyl — about40 million Americans, or onein five eligible voters are ages18 In 29. according to theCenter for Information andResearch on Civic Learningand Engagement, or Circle, anonprofit research group
>h has concentrated onyouth vote.
Part or the reason for theregistration jump is not justthe new mood of the youngbut the determined efforts bynonparosan and partisangroups alike k> add to therolls.
In Oregon, where the lastpresidential race was decidedby R.765 votes, it u elbow-to-elbow combat over potentialUrge is
"As one of many youngvoters who says be gets mostof his campaign news from theirreverent Daily Show's "Inde-cision 2004." Jeff Leek, a22-year-old statistics major atthe University of Washington,said politics ic a big topic thisyear among his friends
"There's leas cynicism, lessof this -Oh, it doeol matter,1"said Leek, B native of IdahoHe said be supports Sen. JohnKern
U.S. EPA Conducts First Five-Year Review of the ModernSanitation Landfill Superfund Site
The United States Environmental Protection Agency (U.S EPA) - Region 3 is currentlyconducting a Five-Year Review of the cleaaup actions taken u the Modem Sanitation LandfillSuperfund 'Site located in York County, Pennsylvania. This review will evaluate theeffectiveness of the cleanup activities, which include the landfill cap and final cover for theunlined 66-acre landfill: the continued operation and maintenance of a groundwaier extractionsystem; ui on-site wastewater treatment facility and gas extraction system; and groundwatertod surface water monitoring
The Five-Year Review process is intended to ensure that cleanup actions at contaminated sitesremain protective of the hearth and safety of the surrounding community and the environment.During the review process, the U.S. EPA will visit the Site, review all pertinent documentsand solicit comments from the community. Scheduled completion date for this Five-YearReview Is February 11,2M5.
Documents relating to the Modern Sanitation Landfill Site can be reviewed at the WiodaorTownship Municipal Building, 1480 Windsor Rd, Red Lion, PA 17356. You can also viewdocuments online at hnip://wyw.epa.gov/reg3bwiiKy8iipcf/PA/rrK)den^s«ni/index..him.
If you would like to comment on any of the actions taken at the Site, please contact thefollowing U.S. EPA representatives:
Frank KJancharRemedial Project Manager(215)8)4-3218klanchar. frankrakpii.gov
William HudsonCommunity Involvement Coordinator(215) 814-5532Hudson, william/a/en SLCOV
crac»D3ra AirvaTOTflL P.02
tffr
APPENDIX E
SITE PHOTOGRAPHS TAKEN 10/20/2004
Modern Landfill - Northern Expansion looking south
Modern Landfill - Northern Expansion and Mt. Pisgah Road
Modern Landfill - Northwest Expansion from Office
Modern Landfill - Northwest Expansion from Office
Modern Landfill - Main entrance from Mt. Pisgah Road
Modern Landfill - Sedimentation pond
Modern Landfill - Northwest Expansion looking north
Modern Landfill - truck inspections
Modern Landfill - Northwest Expansion
Modern Landfill - Northwest Expansion
Modern Landfill - Northwest expansion and cell under construction
Modern Landfill - Treatment plant and cell under construction
Modern Landfill - Area between expansions
Modern Landfill - Area between expansions
Modern Landfill - Northwest expansion
Modern Landfill - Area between expansions
Modern Landfill - Wells at end of collection trench
Modern Landfill - Enclosed Flare
Modern Landfill - Relocated Stream
Modern Landfill - View from apex of Mt. Pisgah Road
Modern Landfill - View from apex of Mt. Pisgah Road