SDMS DociD 2088957 FIVE-YEARREVIEW REPORT

Approved by:

FIVE-YEAR REVIEW REPORT

Eastern Diversified MetalsSuperfund Site

Rush Township

Schuylkill County, Pennsylvania

EPAID#:PAD980830533

February 2008

PREPARED BY:

u.s. Environmental Protection AgencyRegion III

Philadelphia, Pennsylvania

Date:

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Hazardous Site Cleanup Division

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3'd Five-Year Review Report - ii

Five-Year Review Report

Table of Contents

List ofAcronyms '" vExecutive Summary viFive-Year Review Summary Fonn .ix

I. Introduction 1

II. Site Chronology 2Table 1: Chronology of Site Events 2

III. Background 4Physical Characteristics 4Land and Resource Use 4History of Contamination 5Basis for Taking Action 7

IV. Remedial Actions 8Remedy Selection 8Remedy Implementation 11System Operation/Operation and Maintenance 16

Table 2: Volume of Treated Effluent 18

V. Progress Since the Last Five-Year Review 18Table 3: Actions Taken Since the Last Five-Year Review 19

VI. Five-Year Review Process 19Administrative Components 19Community Involvement 20Document Review 20Data Review 20

Table 4: NPDES Monthly Monitoring Data for STP (last 12 months) 22Site Inspection 25Interviews 26Potential for Reuse of the Site 27

VII. Technical Assessment. 28Technical Assessment Summary 31

VIII. Issues 32Table 5: Issues 32

IX. Recommendations and FoIlow~up Actions 32

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Table 6: Recommendations and Follow-up Actions 32

x. Protectiveness Statement 33 "XI. Next Review 33

ATTACHMENTS 34

ATTACHMENT 1: EDM Site Location Map 35ATTACHMENT 2: Treatment Plant Process Flow Diagram ~ 36ATTACHMENT 3: List of Documents Reviewed 37ATTACHMENT 4: Applicable or Relevant and Appropriate Requirements(ARARs) .' 38

ATTACHMENT 5: Summary ofEDM Monitoring Well Network .40ATTACHMENT 6: EDM Monitoring Well Locations 41ATTACHMENT 7: EDM Water Quality Results (January 2005) .; .42

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I. II

ARAR

CD

CERCLA

CFR

COC

DNAPL

EPA

GMP

MCL

MCLG

NCP

NPL

O&M

OMPEP

PADEP

PADER

PRPs

RA

RAO

RCRA

RD

RDWP

RIIFS

ROD

RPM

SDWA

UAO

USACE

VOC

List of Acronyms

Applicable or Relevant and Appropriate Requirement

Consent Decree

Comprehensive Environmental Response, Compensation, and Liability Act

Code of Federal Regulations

Contaminant ofConcern

Dense Non-Aqueous Phase Liquid

United States Environmental Protection Agency

Groundwater Monitoring Plan

Maximum Contaminant Level

Maximum Contaminant Level Goal

National Contingency Plan (the "National Oil and Hazardous Substances PollutionContingency Plan")

National Priorities List

Operation and Maintenance

Operations, Monitoring, and Performance Evaluation Plan

Pennsylvania Department of Environmental Protection

Pennsylvania Department of Environmental Resources

Potentially Responsible Parties

Remedial Action

Remedial Action Objective

Resource, Conservation and Recovery Act

Remedial Design

Remedial Design Work Plan

Remedial Investigation/Feasibility Study

Record of Decision

Remedial Project Manager

Safe Drinking Water Act

Unilateral Administrative Order

U.S. Army Corps of Engineers

Volatile Organic Compound

3rd Five-Year Review Report - v

Executive Summary

The Eastern Diversified Metals (EDM) Superfund Site (the "Site") is located in RushTownship, Schuylkill County, Pennsylvania. The Site is an industrial property containing amassive waste pile of chipped plastics composed of aluminum and copper wire insulation. Thewaste insulation material, referred to as "wire chopping fluff' or "fluff', occupies approximately7.5 acres in a large pile located on the property.

The EDM Site was divided into four operable units (OUs) as follows:

Operable Unit 1 (OUl):

March 1991 ROD

Operable Unit 2 (OU2):

March 1991 RODSeptember 1993 ROD


July 1992 ROD


November 2001 ROD

Hotspot areas (fluff and soil areas contaminated withdioxins and PCBs above cleanup levels);Sediments and soils contaminated with metals above targetlevels; and miscellaneous debris.

Groundwater (i.e. shallow and deep groundwater andstormwater management)

Remainder of the Site, in particular the remainder of thefluff pile (i.e. recycling of fluff pile)

On-Site containment of the fluff pile.

The remedies for OU1 and OU2 included the removal of dioxin-impacted "hotspots"from the on-Site waste plastics fluff pile, upgrade of the existing leachate treatment plant, andenhancement of storm water and leachate collection systems. The trigger for this five-yearreview was the previous Five-Year Review Report signed on February 12,2003. The assessmentof this five-year review found that the components of the remedy for OU1 and OU2 werecompleted in accordance with the requirements of the Records of Decision (RODs) dated March29,1991 and September 29,1993 with the exception of sediment removal from the unnamedtributary to the Little Schuylkill River. Pursuant to the November 2001 ROD for on-Sitecontainment of the fluff pile, the sediment removal has been deferred until construction of thecap is completed. Consequently, the unnamed tributary sediment removal has been incorporatedinto the OU4 remedial activities. The completed portions of OU1 and OU2 are functioning asdesigned.

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The remedy for OU1 is expected to be protective of human health and the environmentupon completion, and in the interim, exposure pathways that could result in unacceptable risksare being controlled. The principal threat from the dioxin-impacted fluff was addressed by theexcavation, treatment, and subsequent off-site disposal of dioxin-impacted fluff at an off-siteincineration facility. The only portion of the remedy not completed for OU1 is the sedimentremoval from the unnamed tributary to the Little Schuylkill River. Remedial activities toaddress this remaining portion of OU1 were integrated into the OU4 remedial design. Theremedy for OUI is expected to be protective of human health and the environment uponcompletion of the remedial activities for OU4.

The remedy for OU2 is protective of human health and the environment. The September1993 ROD selected "No Action" for the deep groundwater at the Site, and shallowoverburden/leachate was addressed by the remedial actions as specified in the March 1991 RODthat included enhanced shallow groundwater collection and treatment.

The remedy for OU3, recycling ofthe fluff pile, was changed pursuant to the OU4 RODissued on November 26,2001, which selected on-Site containment of the fluffpile, groundwatermonitoring, and institutional controls.

The remedy for OU4, on-Site containment of the fluff pile, is currently underconstruction and expected to be protective of human health and the environment uponcompletion, and in the interim, exposure pathways that could result in unacceptable risks arebeing controlled. OU4 is the final remedial action for the Site. Land use restrictions for the caparea (institutional controls)'described in the November 2001 ROD (OU4) have not yet beenimplemented since ownership of the property remains an issue. The Site is expected to achieveconstruction completion in fiscal year 2008 when OU4 construction activities are scheduled to becompleted and a Final Close Out Report prepared by EPA.

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3'd Five-Year Review Report - viii

"

Five-Year Review Summary Form

SITE IDENTIFICATION

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

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

Multiple OUs?* _ YES 0 NO Construction completion date: N/A

Has site been put into reuse? 0 YES _ NO

REVIEW STATUS

Lead agency: _ EPA 0 State 0 Tribe 0 Other Federal Agency

Author name: Frank Klanchar

Author title: Remedial Proiect ManaQer IAuthor affiliation: U.S. EPA ReQ. 3, HSCD

Review period:-- 10/02/2007 to 01/31/2008

Date(s) of site inspection: 11/29/2007

Type of review:_ Post-SARA o Pre-SARA o NPL-Removal only

o Non-NPL Remedial Action Site o NPL Staten-ribe-Iead

o Regional Discretion

Review number: o 1 (first) 02 (second) _ 3 (third) 0 Other (specify)

Triggering action:o Actual RA Onsite Construction at au #__ o Actual RA Start at OU#__

o Construction Completion _ Previous Five-Year Review Report

o Other (specify)

Triggering action date (from WasteLAN): 02/12/2003

Due date (five years after triggering action date): 02/12/2008* ["au.. refers to operable Unit.]** [Review period should correspond to the actual start and end dates of the Five-Year Review in WasteLAN.]

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Five-Year Review Summary Form, cont'd.

Issues:

1. OU4 remedial activities are under construction and minimal vegetation has been established at the Site.2. Institutional controls (ICs) have not been put in place for the Site due to the uncertainty as to property ownership.3. Following completion of the OU4 remedy, the quality and quantity of water (leachate) collected at the Site

Treatment Plant (STP) may change.4. The area available for reuse at the Site may be less than specified in the OU4 ROD after implementation of the

OU4 remedial activities.

Recommendations and Follow-up Actions:

1. OU4 remedial activities need to be completed.2. Institutional controls need to be put in place to prevent damage to the cap and associated structures.3. The overall performance of the treatment plant, including opportunities for optimization, will need to be evaluated

after the OU4 remedial activities are completed.4. The area available for reuse should be documented in the Final Remedial Action Report, and if necessary, an

Explanation of Significant Differences (ESD) prepared.

Protectiveness Statement(s):

The remedy for OU1 is expected to be protective of human health and the environment upon completion,and in the interim, exposure pathways that could result in unacceptable risks are being controlled. The principalthreat from the dioxin-impacted fluff was addressed by the excavation, treatment, and subsequent off-site disposal ofdioxin-impacted fluff at an off-site incineration facility. The only portion of the remedy not completed for OU1 is thesediment removal from the unnamed tributary to the Little Schuylkill River. Remedial activities to address thisremaining portion of OU1 were integrated into the OU4 remedial design. The remedy for OU1 is expected to beprotective of human health and the environment upon completion of the remedial activities for OU4.

The remedy for OU2 is protective of human health and the environment. The September 1993 RODselected "No Action" for the deep groundwater at the Site, and shallow overburdenlleachate was addressed by theremedial actions as specified in the March 1991 ROD that included enhanced shallow groundwater collection andtreatment.

The remedy for OU3, recycling of the fluff pile, was changed pursuant to the OU4 ROD issued onNovember 26,2001, which selected on-Site containment of the fluff pile, groundwater monitoring, and institutionalcontrols.

The remedy for OU4, on-Site containment of the fluff pile, is currently under construction and is expected tobe protective of human health and the environment upon completion, and in the interim, exposure pathways thatcould result in unacceptable risks are being controlled. OU4 is the final remedial action for the Site. Land userestrictions for the cap area (institutional controls) described in the November 2001 ROD (OU4) have not yet beenimplemented since ownership of the property remains an issue. The Site is expected to achieve constructioncompletion in fiscal year 2008 when OU4 construction activities are scheduled to be completed and a Final Close OutReport prepared by EPA.

Other Comments:

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Five-Year Review Report

I. Introduction

The purpose of the five-year review is to detennine whether the remedy at a Site isprotective of human health and the environment. The methods, findings, and conclusions ofreviews are documented in Five-Year Review Reports. In addition, Five-Year Review Reportsidentify issues found during the review, if any, and recommendations to address them.

The United States Environmental Protection Agency (EPA) is preparing this five-yearreview report pursuant to the Comprehensive Environmental Response, Compensation, andLiability Act (CERCLA) § 12 I and the National Oil and Hazardous Substances PollutionContingency Plan (NCP). CERCLA §121states:

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

The Agency interpreted this requirement further in the NCP; 40 Code of FederalRegulations §300.430(f)(4)(ii) states:

Ifa remedial action is selected that results in hazardous substances, pollutants, orcontaminants remaining at the site above levels that allow for unlimited use and unrestrictedexposure, the lead agency shall review such action no less often than every five years afterthe initiati~n ofthe selected remedial action.

The United States Environmental Protection Agency Region 3 has conducted a five-yearreview of the remedial actions implemented at the Eastern Diversified Metals Superfund Site inRush Township, Schuylkill County, Pennsylvania. This review was conducted from October2007 through January 2008. This report documents the results of the review.

This is the third (3 Td) five-year review for the Eastern Diversified Metals Site. The

triggering action for this review is the signature date of the last five-year review, as shown inEPA's WasteLAN database: February 12,2003. The Five-Year Reviews for this Site are neededbecause hazardous substances, pollutants, or contaminants will remain on-Site and not allow forunlimited use and unrestricted exposure after all actions are completed.

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'f!I

II. Site Chronology

The table below summarizes important events and relevant dates in the chronology of theEastern Diversified Metals Site.

fS· EIT bl 1 Cha e : fono ogy 0 fte vents

Event Date

Eastern Diversified Metals Corporation (EDM) beginsoperations at the Site. Waste insulation material (i.e. "fluff") 1966from chopping of wire is disposed on-Site.Pennsylvania Department of Health (PADOH) inspects the

1970Site and determines that a solid waste permit is required.EDM submits application to PADOH to operate a 25-acre

1971landfill at the Site.PADOH finds EDM in violation of Pennsylvania CleanStreams Law as a result of leachate from the fluff pile 1972entering an on-Site stream.Pennsylvania Department of Environmental Resources(PADER) and EDM enter into a Consent Decree to install aleachate collection and treatment system. EDM constructs the 1974required systems and submits application for a Water QualityManagement Permit.EDM receives a National Pollutant Discharge EliminationSystem (NPDES) permit and water treatment system begins 1975operation.EDM ceases all operations at the facility and transfersownership to Theodore Sall, Inc. The building housing the 1977process equipment is sold to Bernard Gordon.Hometown Fire Department extinguishes small fires on

1979portions of the main fluff pile.EPA conducts sampling at the EDM Site. 1985-1986Pursuant to a Consent Order with EPA, SaIl constructs a chain

1987link fence around the Site.The EDM Site is placed on the National Priorities List (NPL). 1989The Remedial Investigation/Feasibility Study (RIfFS) is

1991completed.EPA issues the first Record of Decision (ROD) for the EDMSite addressing OU1 (final remedy) and OU2 (interim March 1991remedy).EPA issues a Unilateral Administrative Order (DAO) toAT&T and Sall to implement portions of the March 1991 September 1991ROD.

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Event Date

EPA issues a second ROD for the remainder of the fluff pileJuly 1992

(OU3). This ROD selects recycling of the fluff pile material.EPA issues a UAO which requires implementation of the

June 1993recycling remedy for the fluff pileEPA issues a final ROD for OU2 and selects "No Action" for

September 1993deep groundwater at the Site.EPA issues a second Order requiring Nassau Metals (asubsidiary of AT&T which subsequently became Lucent) to

March 1994implement the remaining remedial actions required by theMarch 1991 ROD.EPA and Lucent enter into a Consent Decree to perform aFocused Feasibility Study (FFS) to determine other ways to June 1997address the fluff pile in lieu of recycling.EPA conducts the first Five-Year Review of the Site. February 1998EPA issues a ROD for OU4 which selects in-place capping of

November 2001the fluff pile.EPA issues Special Notice Letters to Nassau Metals and SaIl,

June 2002and Consent Decree negotiations begin.EPA conducts the second (2no

) Five-Year Review of the Site. February 2003EPA and Nassau Metals enter into a Consent Decree in whichNassau agrees to implement the remedial design and remedial October 2003action for OU4 at the EDM Site.EPA approves the Remedial Design Work Plan for OU4. January 2004The Court grants EPA access to the Site for the purposes ofimplementing all activities associated with the OU4 ROD, November 2004including operation and maintenance.EPA approves a Remedial Action Work Plan for theremediation of soils associated with OU4 on the Bernard October 2005Gordon property.An early Remedial Action of OU4 for the excavation andremoval of contaminated soils and visible fluff from the December 2005Gordon property is completed.EPA approves the RA Report for the Gordon Property

April 2006Remedial Action.EPA approves the Remedial Design for OU4 (cap). July 2006On-Site construction begins for the OU4 Remedial Action. September 2006


III. Background

Physical Characteristics

The Eastern Diversified Metals (EDM) Superfund Site (the "Site") is located in RushTownship, Schuylkill County, Pennsylvania, approximately one (1) mile northwest of theintersection of PA Routes 54 and 309 in the town of Hometown. See Attachment 1. The Site isapproximately one thousand (1,000) feet west of Lincoln Avenue (SRI021) at the western end ofa light industrial park. The Site covers approximately twenty-six (26) acres of partially forestedland, in a deep east to west trending topography valley. East-west oriented railroad tracks borderthe Site on the north valley ridge. The Little Schuylkill River flows in a south-southeasterlydirection two hundred fifty (250) feet west of the Site property. A shallow unnamed tributary("UNT") to the Little Schuylkill River flows westerly along the southern border of the Site in thevalley bottom.

The Site is an industrial property containing a massive waste pile of chipped plasticscomposed of aluminum and copper wire insulation. The waste insulation material, referred to as"wire chopping fluff' or "fluff', occupies approximately seven and one-half (7.5) acres in a largepile on the property. The fluff is primarily composed of polyvinyl chloride (PVC) andpolyethylene (PE) insulation chips, fiber insulation liner, and residual wire fragments. Roughlyhalfof the material is PVC and PE, which is present as visible, medium to coarse, sand-sizedparticles. The remainder of the material consists of dirt and fiber, with some fine metal andplastic fragments, and large-sized debris, primarily consisting of unprocessed wire/cable, stone,wood, metal cable, and metal hardware from various types of wire installations. The fluff isresidual material from the chopping of copper and aluminum communication and power wireand cable to recover and recycle the metal content of the wire. An estimated three-hundred fifty(350) million pounds of fluff are on-Site in a pile approximately two-hundred fifty (250) feetwide by one-thousand five-hundred (1,500) feet long, ranging from five (5) to sixty (60) feetdeep.

Land and Resource Use

The Site is bordered on the north by a railroad right-of-way, and beyond that anundeveloped property and a residential property. EPA is unaware of any plans to further developor subdivide the property to the north of the Site. The Site is bordered on the south and east byan industrial park for light industry. The portion of the Site at the eastern end of the fenced areais relatively flat and will be cleaned up to provide the opportunity for future commercial landuse. This area is approximately four to six acres. However, this area of the Site includes surfacewater drainage features which must be maintained, therefore, future redevelopment may belimited. Pennsylvania State Game Lands and the Little Schuylkill River border the Site to thewest. The capped area will be fenced and land use restricted to protect the integrity of the cap.The soil cleanup levels will be protective of workers or although unlikely, any trespasser whomight access the Site.


Deep groundwater flows westward toward the Little Schuylkill River. The deepgroundwater has not been significantly impacted by Site-related contamination. There are noresidential or public wells between the Site and the Little Schuylkill River. A dam upstream ofthe Little Schuylkill River supplies water for Tamaqua and Hometown. Residential wells areupgradient of the Site and located adjacent to an industrial park.

History of Contamination

Prior to 1966, the Site property was owned by a manufacturing company engaged in theextrusion of aluminum for hospital furniture. Pre-1966 activities were confined to a singlebuilding on an adjacent property, with the remainder of the Site left vacant. The manufacturingcompany disposed of wooden wire reels, wooden pallets, and similar debris and trash on-Site.

In, or around September 1966, Greater Tamaqua Industrial Development Enterprisesconveyed the Site property to Eastern Diversified Metals Corporation ("EDM"). EDM operatedat the Site, reclaiming copper and aluminum from wire and cable in a processing building onLincoln Avenue, from 1966 until 1977. The EDM plant received wire from numerous sources,including AT&T Nassau Metals Corporation. Plastic insulation surrounding metal cable andwire was mechanically stripped and separated from the metal using gravitational separationtechniques at the EDM plant. This process involved chopping the wire, stripping the plasticcoating from the wire with steel blades, and separating the wire from the plastic coveringsthrough the use of an air clarifier and a water table. The "fluff' (paper fiber and plastic) anddebris (wooden cable spools, miscellaneous metal hardware, etc.) generated during thereclamation activities were disposed on the ground in the topographic valley at the Site.

The metal reclaimed by EDM was either sold or returned to the sources. EDM disposedof the waste insulation material on the ground in the valley behind the plant at the Site. The pilewhich currently is being capped was a direct result of this disposal practice. EDM terminatedoperations at the Site in 1977.

The original property was subdivided in 1978, and the parcel with the manufacturingbuilding was sold to Bernard Gordon. The parcel containing the pile of fluff and debris wasretained in ownership by Theodore SaH, Inc. ("SaH"), as successor to EDM. As such, the "Site"is comprised of two parcels, the Theodore SaIl property and the Bernard Gordon property. In1979 and 1980, the Rush Township Board of Supervisors wrote letters to Diversified Industries,Inc. (SaIl's parent company) on behalf of area residents who had complained of odors from theSite and expressed health concerns.

Initial Response

In 1974, pursuant to a Consent Order with the Pennsylvania Department ofEnvironmental Resources ("PADER") (now known as the Pennsylvania Department ofEnvironmental Protection - "PADEP"), EDM installed a leachate collection and secondarytreatment system in the southwest comer of the Site in order to monitor, collect, and treat


leachate emanating from the fluff pile. EDM received a National Pollutant DischargeElimination System ("NPDES") permit and the water treatment system began operation. Thetreatment plant is still operating and is part of a leachate management system that also includeserosion control measures, surface diversion ditches, and two shallow groundwater interceptortrenches that convey leachate to an on-Site treatment plant.

A fire was extinguished on the eastern end of the south face of the fluff pile in June 1979.On, or about November 2, 1979, the Hometown Fire Company responded to a report of a fire atthe Site. On or about November 20, 1979, smoldering was noted in the same general area of theprevious fires; the smoldering was extinguished with fire retardant and water. Subsequently, SaIlexcavated the burn area in an effort to ensure that the fire was extinguished. The area wheresmoldering fires were noted is limited to a portion of the fluff pile in the vicinity of thesecondary leachate seep (southeast side of the fluff pile).

In 1985, Todd Giddings and Associates, Inc. completed a Site Evaluation Report for SaIl.This evaluation included sampling and analysis of surface water, leachate, groundwater, fluff,and sediment. These investigations determined that the fluff contained polychlorinatedbiphenyls ("PCBs") and failed the Extraction Procedure Toxicity test for lead. Additionally,various metals were detected in the downgradient monitoring well.

In 1985, the EPA Field Investigation Team subcontractor, NUS Corporation, sampledsurface soil, surface water, stream sediment, leachate, leachate runoff path sediment, andgroundwater to provide data in order for EPA to further assess the Site.

In 1987, EPA issued an Administrative Order pursuant to section 106(a) of CERCLA, 42U.S.C. § 9606(a), to Diversified Industries, Inc. and SaIl directing them to install a security fencearqund the Site. The fence was subsequently installed by those parties. On October 19, 1987,SaIl and AT&T Nassau Metals Corporation signed an Administrative Order on Consent withEPA for the performance of a Remedial Investigation/Feasibility Study ("RIIFS") at the Site.The purpose of the RIIFS was to determine the nature and extent of contamination and toevaluate remedial alternatives for implementation at the Site. Samples were collected andanalyzed from air, soils, sediments, groundwater, and surface water. A majority of these sampleswere taken in and around the fluff pile area.

EPA placed the Site on the CERCLA National Priorities List in October 1989. See 54Fed. Reg. 41036 (Oct. 4, 1989).

The RIfFS was completed in February 1991. Data collected prior to and during the RIfFSrevealed hazardous substances in the fluff and surrounding soils, sediments, surface water, andgroundwater. Hazardous substances related to the presence of the fluff pile that present apotential threat to human health and the environment include: Lead, bis(2ethylhexyl) phthalate("DEHP"), di-n-octylphthalate ("DNOP") and PCBs. These hazardous substances found in thefluff have contaminated soil, subsurface soils, and sediments. Dioxins have been found inhotspot areas of the fluff pile and zinc, iron, manganese, copper, and phenols in fluff pileleachate.


Basis for Taking Action

Contaminants

Hazardous substances that have been released at the Site in each media include:

Groundwater1,1, I-TrichloroethaneTrichloroethene·Lead

SoilsDEHPPCBsDioxinsCopperLeadZincCadmium

LeachateTrichloroethenePolychlorinated Biphenyls (PCBs)Bis(2-ethylhexyl)phthalate (DEHP)Di-n-octylphtha1ate (DNOP)CopperLeadZincManganesePhenols

SedimentDEHPDNOPPCBsCopperLeadZincAluminum

Surface WaterCopperLeadZincManganese

Fluff MaterialPCBsDioxinsPolychlorinated Napthalenes (PCNs)Lead

The principal threat posed by the Site was the area of the fluff pile contaminated withhigh levels of dioxin. These high levels of dioxin contaminated fluff were removed from the Siteas a highest priority remedial action. Lower level current threats to human health and theenvironment are posed by moderately contaminated fluff and soils which contain dioxin, PCBs,phthalates, lead, copper, and zinc. Contaminated sediments and surface water in the intermittentstream pose a low level threat to the aquatic ecology at the Site and in the Pennsylvania StateGame Lands.

Lower-level threats also include the remainder of the fluff material which has beenclassified as a hazardous waste, due to its lead content and Toxicity Characteristic Leachingprocedure ("TCLP") results.

Potential human exposure pathways for Site contaminants evaluated in the riskassessment included inhalation of contaminated dust; dermal contact and incidental ingestion ofcontaminated soils and fluff; dermal contact and incidental ingestion of surface water; dermalcontact with leachate (for children), and ingestion, dermal contact, and/or inhalation ofcontaminated groundwater. Exposure to Site contaminants via these pathways would poseunacceptable health risks to children and adults in the local area. Exposure scenarios in the risk


___ ._a. _

assessment very conservatively assumed the absence of the existing fence at the Site, whichcurrently prohibits public entrance, and, for groundwater, assumed the presence of a hypotheticaldowngradient well, which would most likely never exist because downgradient lands arePennsylvania State Game Lands.

The actual current risk pathways driving the risk at the Site, under realistic current andfuture use scenarios, are dermal contact and ingestion. The carcinogenic risk under theseexposure scenarios is primarily due to PCBs and dioxins. The systemic human health risk driveris lead. The primary ecological risk driver for aquatic life in the intermittent stream is zinc inleachate, which is being addressed by the on-Site treatment system. The contaminants in thefluff pose a contact risk to animals visiting the Site.

The contribution from the Site to maximum lifetime carcinogenic risks for adults andchildren is 2.05 x 10-4 (2 additional cancer cases per 10,000 adults exposed) and 7.17 x 10-4 (7additional cancer cases per 10,000 children exposed), respectively. The overall risk result of therisk assessment for adults and children was 9.44 x 10-4.

In addition, the Hazard Index (HI) for the Site is greater than 1.0 for children using a veryconservative theoretical scenario which assumes fugitive emissions, residential use of a nonexistent downgradient well and other possible but unlikely exposures (HIs were in theunacceptable range of 1.31 to 10.6). Actual exposure scenarios produced HI risks that rangedfrom 0.05 to 1.1.

In addition to actual site-specific calculations, there are several risk-related concentrationlevels of contaminants that usually require EPA to take remedial action. As stated above, theaverage lead level in the fluff is between 3,000 and 11,000 ppm. EPA generally remediates leadlevels above 1,000 ppm for commercial and industrial settings. The average level of PCBs in thefluff is just above 50 ppm, which requires action under the Toxic Substances Control Act(TSCA).

IV. Remedial Actions

Remedy Selection

The EDM Site was originally divided into operable units ("OUs") as follows:

Operable Unit I (OUI):

Operable Unit 2 (002):

Hotspot areas (fluff and soil areas contaminated withdioxins and PCBs above cleanup levels);Sediments and soils contaminated with metals above targetlevels; and Miscellaneous debris.

Groundwater (i.e. shallow and deep groundwater andstormwater management)


Operable Unit 3 (OU3): Remainder of the Site, in particular the remainder of thefluff pile (i.e. recycling of fluff pile)

EPA issued three Record of Decisions (RODs) that addressed the OUs as stated above.On November 26,2001, EPA issued a fourth ROD that designated a new operable unit, OU4.The November 2001 ROD changed the remedy for OU3 and provided for other minor changes tothe other past RODs. The following provides a summary of each ROD.

March 1991 ROD - OU1 (Hotspot Areas) and OU2 (Shallow Groundwater)

On March 29, 1991, EPA issued the first ROD for the EDM Site in which EPA selected afinal remedy for OUl, that included incineration of the principal threat (fluff and soil areascontaminated with dioxin and moderate levels of PCBs); removal of contaminated stream bedsediments, metals-contaminated soils, and miscellaneous debris; and stabilization of incineratorresiduals, soils, and sediments, if necessary. The March 1991 ROD also selected an interimremedy for OU2 that included enhanced shallow groundwater collection and treatment; andfurther study of the deep groundwater system. The shallow groundwater is overburdengroundwater/leachate. At the time of the March 1991 ROD, EPA's analytical results indicatedthat PCB concentrations above 25 ppm were localized in a few small areas, but in these smallareas, concentrations were very high.

July 1992 ROD - OU3 (Remainder ofFluffPile)

On July 2, 1992, EPA issued a second Record of Decision for the Site. The remedialaction selected for implementation at the Site in the OU3 ROD required, among other things, thatall fluff at the Site be recycled within fifteen (15) years of the date the ROD was issued; that allrecycling residuals be tested and, if necessary, treated to eliminate hazardous characteristics; thatall residuals (including non-hazardous residuals) be disposed in an off-site landfill; that soilsunderlying the fluff be sampled and analyzed to determine the nature and extent ofcontamination, if any; and that erosion and sedimentation controls be implemented to controldrainage and minimize erosion of exposed soils at the Site.

September 1993 ROD - OU2 (Deep Groundwater)

On September 29, 1993, EPA issued a third Record of Decision for the deep groundwaterportion of OU2, finalizing the groundwater remedies at the Site. Site-related contamination wasnot found in the bedrock groundwater and contaminants are at relatively low levels in theshallow overburden leachate. The deep groundwater was found to be contaminated with TCE. Itwas determined, however, that TCE contamination was from an unknown upgradient source notassociated with the EDM Site. Therefore, EPA selected No Action for the deep groundwater inthe OU2 ROD. The interim actions for the shallow groundwater were not affected by theSeptember 1993 ROD and were performed in accordance with the March 1991 ROD. A


-- -- ....-----

subsurface shallow overburden leachate collection system was constructed along the western andsouthern toe of the main fluff pile at the Site in the winter of 1995/1996.

November 2001 ROD - OU4 (On-Site Containment)

The remedy selected in the July 1992 ROD (OU3) was intended to reduce or eliminatethe threats presented by the remaining fluff by recycling the fluff material and properly disposingof hazardous residuals. The alternative selected in the July 1992 ROD (recycling) was found tobe impractical after aggressive efforts to recycle the fluff material failed.

Therefore, after the completion of a Focused Feasibility Study to evaluate otheralternatives in lieu of the recycling alternative for the fluff material in the July 1992 ROD, EPAissued a fourth ROD on November 26,2001 that selected a containment remedy for the massivefluff pile present at the EDM Site. The 2001 ROD also revised several aspects of the previousRODs which needed to be changed. The November 2001 ROD is the final ROD for the EDMSite. The November 2001 ROD contained the following elements:

• Grading the fluff pile to less than 4: 1 slopes and covering the fluff pile with aRCRA-equivalent multi-lined cap system;

• Excavation and placement under a RCRA-equivalent multi-lined cap of all Sitesoils contaminated above the cleanup levels listed in this ROD;

• Management of storm water run-on/runoff and elevated overburden groundwateraround the cap containment system;

• Study gas generation in the fluff pile and, if necessary, install a gas collection andtreatment system;

• Groundwater monitoring and if necessary landfill gas monitoring;

• Institutional controls to prevent certain access and to prevent damage to the capand associated structures;

• Site inspections and maintenance to sustain the protectiveness of the cap; and

• Elimination of the requirement to remove PCB hotspots detailed in the ROD forOUI due to EPA's conclusion that the PCB hotspots did not really exist and werethe result of a lab analysis problem.

In addition, the ROD for OU4 noted that completion ofthe sediment removal from theunnamed tributary under OUI would be deferred until after the final construction of the cap andassociated system. Deferring this action would avoid contaminating a clean area during the OU4remedial action.


Remedy Implementation

QUi/QU2 RQD (March i991)

The ROD for OUI and OU2 for the EDM Site was signed on March 29, 1991. RemedialAction Objectives (RAOs) were developed as a result of data collected during the remedialinvestigation to aid in the development and screening of remedial alternatives to be consideredfor the ROD. The RAOs for the EDM Site were:

• Address the principal threats at the Site by preventing further exposure andreducing the toxicity, mobility, and volume of dioxins and PCBs; and

• Reduce human and animal contact by decreasing fluff and contaminant transportto groundwater and surface water.

On September 30, 1991, EPA issued an Administrative Order directing AT&T NassauMetals Corporation and Theodore SaIl, Inc. to implement portions of the March 29, 1991 RODwhich included miscellaneous debris removal, additional groundwater studies, fencemaintenance, and continued monitoring. The September 30, 1991 Administrative Order did notrequire the implementation of the remedy for removal and incineration of the PCB and dioxinhotspot areas, upgrade of the leachate treatment plant, sediment removal, upgrade of the stonnwater lagoon, or installation of additional leachate collection trenches. Remedial Design formiscellaneous debris was completed in late 1992. In 1993, approximately 6,500 cubic yards ofdebris (consisting of un-chopped wire, wood, scrap metal, soil, and fluff) was removed from theSite and transported off-site for disposal.

Also in September 1991, AT&T petitioned EPA to reopen the March 1991 ROD claimingthat the PCB analytical results reported and relied upon in the RIfFS and the Risk Assessmentwere inaccurate. AT&T provided more recent analytical data showing that PCBs were present atlower concentrations in the PCB hotspot area than indicated by the original analyses. Theseanalyses also revealed the presence of Polychlorinated Naphthalenes ("PCNs") in what wasfonnerly defined as the "PCB hotspot" area. It appeared that the reported PCB levels were dueto a misidentification by the lab ofPCNs as PCBs. PCNs may have been used as a fire retardantto coat the wire or in the paper insulation in some electrical wire and cable.

On March 2, 1994, EPA issued an Administrative Order directing AT&T Nassau MetalsCorporation and Theodore SaIl, Inc. to implement portions of the March 29, 1991 ROD whichwere not addressed in the September 30, 1991 Order. The actions required by this Orderincluded upgrading the on-Site waste water treatment plant, removal of the contaminatedsediments in the unnamed tributary, upgrading or replacing the equalization basin,installing/upgrading groundwater collection trenches, repairing or replacing the pump andcontrol valve in the groundwater sump, and on-Site/off-Site incineration of dioxin contaminatedmaterials present on-Site.

3,d Five-Year Review Report - 11

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Leachate Management/Storm Water Management

On August 4, 1994, EPA issued an Administrative Order directing AT&T Nassau MetalsCorporation and Theodore SaIl, Inc. to operate the wastewater treatment plant on-Site to mitigatethe threat of uncontrolled overflow of the equalization basin on the Site. Pursuant to expeditedactions taken under the March 2, 1994 Order and the August 1994 Order, work commenced inthe fall of 1995 to replace the old equalization basin at the Site with a storm water runoffcollection basin, construct a subsurface leachate collection trench along the southern and westerntoe of the main fluff pile, and upgrade the Site Treatment Plant ("STP"). Fluffpile leachate isnow collected and treated in the expanded subsurface system which was constructed in 1995, andwhich was repaired and enhanced in the fall of 1998. In 1996, a new storm water collection andtreatment system was installed at the Site to prevent erosion and runoff water from carrying flufffrom the Site. Construction of a biological treatment plant and a 20,000-gallon equalizationstorage tank addition to the STP was started in 1997 and completed in the spring of 1998. In thefall of 1998, repairs were made to the leachate collection trench at the Site and additionalleachate seep collectors were constructed near the storm water runoff basin and downstream ofthe STP on the unnamed tributary of the Little Schuylkill River. The leachate/shallowgroundwater continues to be collected and treated by the STP pursuant to the OU1 ROD.

Dioxin-Impacted Fluff

Dioxin-contaminated fluff was found to originate in a hotspot located on the south centralside of the fluff pile. The source of the dioxin hotspot was attributed to accidental fires thatoccurred at the Site in 1977 and 1979 and was called the Former Burn Area ("FBA"). AMiscellaneous Debris Pile (WI-12) was found to contain burnt and melted fluff similar to thatobserved in the FBA. The FBA was the reported source of the material in Miscellaneous DebrisPile WI-l2. Burnt and melted Fluff and debris from Miscellaneous Debris Piles WI-1 and WI12, and similar loose material located on the "apron" of the FBA (relatively flat area adjacent tothe toe of the slope of the main fluff pile and the fire-impacted portion of the pile) were handledseparately from other Miscellaneous Debris Piles and placed in twenty 30-cubic yard rolloffcontainers and staged on-site in 1993. The containerized debris was shipped off-site in Marchand April 1994 for incineration at the Aptus incinerator in Coffeyville, Kansas.

A cleanup level of 20 ug/kg dioxin was established for the removal of dioxincontaminated fluff from the FBA. Initial delineation sampling of the FBA was conducted inMarch and June 1996. Delineation results also showed there to be a layer of dioxincontaminated fluff on the FBA apron area to be addressed as part of the remedial action anddioxin levels in soil below the apron fluff that were below the cleanup level. The initialdelineation tentatively isolated the impacted fluff to an approximately 2,000 square foot portionof the sloping face of the fluff pile. The fluff delineation and removal was to proceed in 12-inchlayers. Dioxin contaminated fluff from the FBA was to be excavated, placed directly into linedstorage or disposal containers, and taken off-site for incineration.

The FBA hotspot removal was initiated in October 1996. The areal extent of thecontamination and depth into the pile increased substantially over the initial estimates. Theexcavation of the increased amount of dioxin contaminated fluff coupled with limited timeframes


for acceptance of the material by the off-site disposal facility, with periodic interruptions due totemporary facility shutdowns, and long laboratory turn around times, resulted in a much longertime frame for the removal of the dioxin impacted fluff. The FBA hotspot delineation andremoval was ultimately completed in November 2001. Remediation of the dioxin hotspot in theFBA resulted in the excavation and incineration of 3,856,860 pounds (1,928 tons) of dioxinimpacted fluff at off-site facilities. All but one load of the FBA material was sent to the Aptusfacility in Coffeyville, Kansas. The last remaining load was sent to the Safety-Kleen facility inAragonite, Utah.

Sediment

Pursuant to the March 2, 1994 Order, a Remedial Design was completed in the fall of1996, and action commenced to remove sediments from the unnamed tributary of the LittleSchuylkill River and remove dioxin-contaminated fluff and debris in the former burn area on thefluff pile. The sediment removal was suspended on December 13, 1996 at the direction of EPAto enable the Agency to re-evaluate the appropriateness of the design of this component of thecleanup. Sediment removal from the unnamed tributary was deferred until after the finalconstruction of the cap and associated system is completed pursuant to the November 2001 RODfor OU4. During the substantial regrading that will be necessary, it will probably be impossibleto avoid some contamination of the unnamed tributary. Deferring this action will avoidcontaminating a clean area during the cap remedial action.

OU3 ROD (Julv 1992)

On June 25, 1993, EPA issued an Administrative Order pursuant to section 106(a) ofCERCLA, 42 U.S.c. I 9606(a), directing AT&T Nassau Metals Corporation and Theodore SaIl,Inc. to implement the OU3 ROD. AT&T Nassau Metals Corporation prepared a remedial designwork plan, took numerous additional samples of the fluff, and performed extensive on~Site andoff-Site treatability testing to determine the extent to which the various fractions of the fluffcould be separated for recycling. These activities, conducted between approximately March1994 and May 1996, revealed that the plastic fractions within the fluff contain PCBcontamination at levels that would prohibit reuse absent an authorization by the Administrator ofEPA under the Toxics Substances' Control Act ("TSCA."). AT&T Nassau Metals reported toEPA that techniques that might be used to remove PCB contamination from the PVC fractionseither required potentially hazardous solvents (some of which are banned from use) or wouldresult in an extremely brittle residual product that could not be used. The company also reportedthat its efforts to find buyers for the separated plastic fractions were severely hampered by thepresence of PCBs in those fractions.

On October 30, 1996, EPA met with AT&T Nassau Metals Corporation, which had beenrenamed Nassau Metals Corporation, to discuss its findings and conclusions and agreed that aFocused Feasibility Study (FFS) was appropriate to evaluate alternatives to the recyclingremedy as selected in the July 2, 1992 ROD.


•

On June 17, 1997, EPA signeq. an Administrative Order on Consent pursuant to sections104 and 122 ofCERCLA, 42 U.S.C. I 9606(a), with Nassau Metals Corporation to complete aFocused Feasibility Study ("FFS") for the Site. The June 1997 FFS Order also suspended alldeadlines required by the June 25, 1993 Order to implement the OU3 ROD, fluff recycling.

OU4 ROD (November 2001)

Based on the results of the FFS, EPA issued a ROD for OU4 at the EDM Site onNovember 26, 200 1. This ROD changed the remedy selected in the OU3 ROD from recycling ofthe fluff material to on-Site containment. On January 29, 2004, EPA approved 'a RemedialDesign Work Plan (RDWP) for OU4 that was prepared by Environmental ResourcesManagement (ERM). The RDWP provided the scope of work for preparation ofa remedialdesign for the selected remedy under OU4 and the remaining sediment removal for the unnamedtributary under OUI. Several pre-design investigations were conducted to provide necessaryinformation to aid in the completion of the remedial design effort. These investigations includedthe following:

1. Down-gradient Collection Trench Investigation,2. Unnamed Tributary Water Quality Investigation,3. Up-gradient Diversion Trench Investigation,4. Perimeter Soils Delineation,5. Fluff Pile Gas Investigation,6. Stormwater Basin Soils Investigation, and7. Topographic and Boundary Survey.

In addition, baseline groundwater sampling events were included in the Work Plan. Thepurpose of this sampling was to provide an initial set of site-wide groundwater data for use in thePost-Closure Monitoring.

Subsequent to submittal of the OU4 Preliminary Design, Nassau Metals Corporationmade a request to EPA to accelerate the removal of impacted soils and fugitive fluff from theBernard Gordon'Property in advance of the remaining areas in order to assist the property ownerin facilitating the planned sale of the property. The Gordon Property, which abuts the easternboundary of the Sall Property, contains the former manufacturing building area and is recognizedas part of OU4 because of the delineation of impacted surface soils. EPA granted permission forthis activity, and a work plan for the soil remediation, entitled Remedial Action Work Plan Gordon Property (dated September 21, 2005), was completed and submitted to EPA. EPAapproved the Work Plan in November 2005.

After negotiating an access agreement with Bernard Gordon, the removal of impactedsoil and fugitive fluff from the property was completed by Nassau Metals Corporation inNovember and December 2005. The total volume of soil removed from the Gordon property andconsolidated onto the fluff pile within the Sail property is estimated at 1,855 cubic yards. Thismaterial will be graded and capped under the OU4 remedial activities. On March 6, 2005,Nassau submitted a report to EPA entitled Completion Report for the Gordon Property Remedial


Action that documented the remediation activities that were completed. EPA subsequentlyapproved the Report on April 13, 2006.

In the interim, several design submittals in progressive phases were submitted to EPA forreview in 2005 and 2006. A final design report entitled Final Design Submillal and RemedialAction Work Plan OU-1 and OU-4 was submitted to EPA on June 28, 2006. EPA approved theFinal Design on July 28, 2006. The central feature of the approved design is the "RCRAequivalent cap" that will cover the consolidated fluff and contaminated Site soils. The cap isintended to prevent future direct human contact with these materials and minimize the infiltrationof precipitation and subsequent leaching of Site contaminants. The fluff pile will be regraded toprovide stable slopes for the placement of cap components. Final side slopes will be no steeperthan 4 horizontal to 1 vertical (4H: 1V). The slopes will also be broken in length by 15 foot-wideterraces located every 25 feet of vertical rise in slope. The existing steep slope (approximately2: 1) located in the southwest region of the Site, immediately adjacent to the STP is known as thewestern embankment. The western embankment contains fluff. The fluff from areas within thewestern embankment will be partially excavated and consolidated onto the fluff pile. Thewestern embankment will receive a 3-foot soil cover (2.5-foot thick clayey soil and 6-inch thicktopsoil). This cover is sufficient to ensure that any remaining fluff materials will not be exposedand subject to contact, ingestion, or inhalation. The cap and western embankment will remaincontained within the Sall Property, while also providing enough space on the perimeter forrunoff collection, sediment control, run-on diversions, and access for maintenance.

The design also contains other substantial elements, including but not limited to: therelocation and expansion of the current leachate and overburden groundwater collectiontrenches; installation of new discharge line for the Site Treatment Plant; removal of sedimentsfrom the unnamed tributary and restoration (remaining OUI remedial action); construction of asteep embankment; stormwater management features for the Site; relocation of utilities; andconstruction of access roads. New security fencing will encompass the SaIl property to preventunauthorized access to the engineered cap and supporting features, including the leachatecollection and handling facilities and the STP.

In August 2006, Nassau completed their contractor selection process and selected EnviroAir (EA) Technologies, Inc., of Coopersburg, PA to conduct the OUI and OU4 constructionactivities. EPA subsequently approved the contractor selection on August 18, 2006. EAmobilized at the Site in September 2006 and began initial activities such as setting up erosionand sediment control structures, and clearing and grubbing the Site. From the time period fromOctober 2006 thru January 2007, construction of sediment traps, excavation of impacted soils forconsolidation, utility line placement, and general earthwork operations were conducted. Severecold temperatures and a heavy snowfall forced a shutdown of remedial activities in February andinto March 2007. When work resumed in late March, continuation of the previous activitiesresumed and the extension of the storm water diversion flume on the western end of the Site wasinitiated.

Construction activities conducted at the Site in the spring of 2007 included thereplacement of the overhead electrical line, importing and screening of clean clayey fill for use inearthwork construction, placement of the clayey fill on the western embankment, construction of


II

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the new leachate conveyance line, screening of excavated soils to be used as sub-base below thecap, placement of gabions in the storm water channels, re-grading the fluff pile and placement ofscreened excavated soil, retro-fitting sediment trap #3, and general site grading outside the limitsof the cap.

In August and September 2007, major construction activities that were completedinclude: the removal of impacted soils from within the unnamed tributary; removal of impactedsoils from the floodplain areas within State Game Land 227; and restoration of the unnamedtributary channel and floodplain excavation areas. The gabion basket structure at the water maincrossing of the unnamed tributary was also constructed during this time. The fluff pile continuedto be prepared in anticipation for placement of the cap system geosynthetic materials. ::

The subcontractor installing the geosynthetic materials for the cap system mobilized atthe Site in early October 2007. Placement of the geosynthetic materials began on the northernside of the fluff pile and continued to the southern side. The cap subcontractor demobilized atthe end of the month due to a prior commitment and remobilized in early November 2007.However, bad weather conditions forced a decision by Nassau to postpone construction of theremaining areas of the cap system until spring of 2008 and any exposed geosynthetic materials

Iiwere prepared for winter weather. Approximately one-half of the 13-acre area to be capped had "Ii

received the geosynthetic materials. In the interim, EA continued other site operation activitiessuch as completion of fluff pile grading, placement of a one-foot layer of sub-base soils on thefluff pile, importing and screening cover soils, placement ofamended cover soil and seedingoutside the cap area, installation of the new STP discharge line, and temporary and permanentseeding of Site soils.

The physical construction of OU 1 and OU4 activities are expected to be complete in thesummer of 2008 and the Site is expected to achieve construction completion status by the end ofSeptember 2008.

System Operation/Operation and Maintenance

The current EDM Site Treatment Plant (STP) has been in operation since 1996. The STPconsists offour distinct treatment processes connected in series to treat the influent streams fromleachate collection and shallow groundwater collection systems. These processes includeinfluent mixing/equalization, extended aeration biological treatment, metal scavenging ionexchange, and pH adjustment. Attachment 2 provides a diagram showing the process flow of theSTP. The primary design objectives of the combined treatment system are the removal ofcarbonaceous biochemical oxygen demand (CBOD), total suspended solids (TSS), and zinc,along with pH adjustment, to meet effluent discharge limits. The biological system treats theinfluent waters for CBOD removal, and provides clarification, which lowers TSS and removessome metals. The ion exchange system further treats the biological process effluent andgroundwater influent for removal of targeted metals, primarily zinc. Other groundwater istreated to adjust its pH. Treated water is then discharged into an unnamed tributary of the LittleSchuylkill River.


The influent flow rates from the various sources vary seasonally and with periods ofprecipitation and snow melt. The leachate collection and shallow (upper) groundwater collectiontrenches flow entirely by gravity to the STP. The lower groundwater collection trench ishydraulically downgradient from the STP and flows by gravity to the site outfall, but is equippedwith a sump from which the collected water can be pumped to the STP if desired. The seepalong the unnamed tributary is also hydraulically downgradient of the STP and is pumped to theSTP from a collection sump. The influent mixing/equalization process manages the fluctuatinginflow rates to more gradually increase (or decrease) flow through the biological process. Storedinfluent and ion exchange backwash, as they occur, are mixed with fresh influent to assure amore consistent influent quality. A 20,000-gallon influent tank provides storage. The tankaddresses flow management during maintenance activities and periods of high influent flow. Anemergency generator is connected to the STP for use in the event of power outages.

Nassau is responsible for the long-term operation and maintenance of the STP. WestonSolutions, Inc. (WSI), has been retained by Nassau to assist in the management of O&Mactivities associated with the STP. RJS Environmental, via a subcontract with WSI, provides theservices of an on-Site operator for the STP. Environmental Resources Management (ERM)provides engineering oversight and support.

RJS Environmental operates and maintains the STP. The STP is monitored two to threedays per week to ensure proper operation of the treatment system. RJS Environmental alsoperforms routine monitoring of the treatment system and collects the STP discharge inaccordance with the approved Standard Operating Procedures (SOP) for the STP. The SOP wasrecently revised in February 2005.

The STP monitoring program includes zinc monitoring for resin exhaustion, bioreactormonitoring for solids generation, and outfall monitoring for monthly NPDES dischargerequirements. Samples are collected several times a month for STP performance monitoring andinclude the analysis of water from mid-resin and post resin sample ports for zinc and monitoringof the bioreactor mixed liquor for total suspended solids and volatile suspended solids. Periodicbackwashing of resin vessels and aggregate vessels is also performed monthly. Maintenance ofthe biological system includes monitoring of biological parameters and nutrient feed preparation.

Monitoring of the STP effluent for NPDES discharge requirements is conducted on amonthly or quarterly basis depending on the parameters being monitored. NPDES dischargeparameters that are monitored monthly in the effluent include chemical biological oxygendemand (CBODs), total suspended solids (TSS), zinc, and pH. Parameters which are monitoredquarterly include aluminum, copper, iron, lead;manganese, and chloroform. In general, effluentdischarge to the unnamed tributary from the STP has been in compliance with the required limitsas set forth under the NPDES discharge requirements.

In addition to the chemical analyses of the STP and effluent outfall, physical inspectionsof other Site structures are also completed on a monthly basis. These include: site security (i.e.,fence); storm water runoff collection system; basin integrity; leachate collection system integrity;groundwater collection system integrity permanent fluff/sediment controls; and the Site access


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roads. Repairs are made as necessary. Monitoring and site inspection reports are submitted toEPA and PADEP on a monthly basis.

O&M costs for the STP have remained fairly consistent since the last five-year reviewand average approximately $150,000 per year. This includes labor, operating expenses(chemicals and utilities), maintenance and repairs, laboratory, and disposal costs.

The STP has on average treated approximately 8.6 million gallons of water per year overthe past four-year period from 2003 thru 2006. The amount of water treated yearly during thistime period is shown on Table 2.

Table 2: Volume of Treated Effluent

Year Meter Starting Volume Meter Ending Volume Treated Flow

(gal) (gal) (gal)

2003 19,347,798 29,702,075 10,354,277

2004 29,702,075 39,753,825 10,051,750

2005 39,753,825 46,522,167 6,768,342

2006 46,522,167 53,853,151 7,330,984

2007' 53,853,151 60,140,775 6,287,624

TOTAL 40,792,977

'through October 29,2007

V. Progress Since the Last Five-Year Review

This is the third (3 rd) Five-Year review for the Site and the second review perfonned

under EPA's Comprehensive Five-Year Review Guidance (June 2001). Table 3 summarizes theprogress at the Eastern Diversified Metals Site since the last five-year review. The issues andrecommendations in Table 3 were generated from the 2nd Five-Year Review Report for the Site.

The statements on protectiveness from the 2nd Five-Year Review Report only addressedthe remedies for OU1 and OU2. The report stated that the remedy for OU1 is expected to beprotective of human health and the environment upon completion, and in the interim, exposurepathways that could result in unacceptable risks are being controlled. The only portion of theremedy not completed for OUI is the sediment removal from the unnamed tributary on the Site.Pursuant to the November 2001 ROD for on-Site containment of the fluff pile, the sedimentremoval has been deferred until construction of the cap is completed.

The remedy for OU2 is protective of human health and the environment because thethreats from uncontrolled discharges of leachate to the unnamed tributary on-Site and surface


water runoff from the fluff pile have been addressed by the upgrade of the Site Treatment Plant,leachate collection systems, and surface water control systems at the Site,

Table 3: Actions Taken Since the Last Five-Year ReviewIssues Recom mendationsl Party Milestone Action Taken and Date of

Follow-up Actions Responsible Date Outcome Action

Low pH ofSTP Addition of sodium PRPs The pH adjustment system Februaryeffluent bicarbonate system to STP; was installed by the PRP. 2003

continued monitoring Monitoring indicates thatthe pH of the STP effluentnow meets dischargelimitations.

Overflow ofSTP; Identify and submit report PRPs Modifications made to March 2003delayed notification on preventative measures; STP such as increasing thruof overflow optimize storage capacity; pipe and pump sizes. February

reset high level alarm; more changing controller logic 2004timely notifications (within to ma,"'\imize storage24 hours) capacity of all tanks, and

general operation andmaintenance proceduresfor the STP.

VI. Five-Year Review Process

Administrative Components

The Eastern Diversified Metals Five-Year Review Team was led by Frank Klanchar(EPA Remedial Project Manager (RPM)), with EPA technical support staff Bill McKenty(hydrogeologist), Dawn Ioven (toxicologist), and Trish Taylor (Community InvolvementCoordinator (CIC)). Meg Boyer, PADEP Project Officer, assisted in the review as therepresentative of the support agency.

Beginning in September 2007, the review team established the review schedule whosecomponents included:

• Community Involvement;• Document Review;• Data Review;• Site Inspection;• Local Interviews; and• Five-Year Review Report Development and Review.

The schedule extended through January 2008.

yd Five-Year Review Report - 19

Community Involvement

A notice announcing that EPA was conducting a five-year review for the Site waspublished in The Pottsville Republican Herald and the Lehighton Times News, both widelydistributed local newspapers, on September 27,2007. EPA's Community InvolvementCoordinator (Ms. Trish Taylor) and the EPA RPM interviewed a local resident and the Mayor ofTamaqua. Several attempts were made to interview representatives of Rush Township, but theTownship felt that it would be more beneficial if EPA updated them on the findings of the fiveyear review after it was completed.

The interviews with the local resident and mayor were held on November 15,2007. Atthat time, EPA summarized the requirements of the five-year review inspection for the EDM Siteand solicited input or concerns on the protectiveness of the remedy.

Following signature on this Five-Year Review document, an ad will be placed in thePottsville Republican Herald and the Lehighton Times News announcing that the Five-YearReview report for the EDM Superfund Site is complete, and that the results of the review and thereport are available to the public at the information repository and via the EPA Region IIIwebsite.

Document Review

A complete list of documents reviewed can be found in Attachment 3. Documentsreviewed in the process of conducting this five-year review included previous Five-Year ReviewReports, Records of Decisions (RODs), Administrative Orders, Remedial Design Reports,Remedial Action Reports, and monthly progress reports (including monthly NPDES dischargemonitoring reports). The Applicable or Relevant and Appropriate Requirements (ARARs) listedin the March 1991 ROD (OU1 and OU2) and November 2001 ROD (OU4) were also reviewed,and are presented here in Attachment 4.

Data Review

Site Treatment Plant (STP) Performance Monitoring Results

Monitoring of the STP effluent for NPDES discharge requirements is conducted on amonthly or quarterly basis depending on the parameters being monitored. NPDES dischargeparameters that are monitored monthly In the effluent include chemical biological oxygendemand (CBODs), total suspended solids (TSS), zinc, and pH. Parameters which are monitoredquarterly include aluminum, copper, iron, lead, manganese, and chloroform. Flow rates are alsorecorded when collecting samples at the outfall. The STP maintenance monitoring program(monitoring of resin exhaustion and solids in the bioreactor) is conducted weekly for TSS andvolatile suspended solids (VSS).

In general, effluent discharge to the unnamed tributary from the STP have been withinthe required limits as set forth under the NPDES discharge requirements for both daily maximumand monthly average values. NPDES monitoring data for the past 12 months is shown in


Table 4. All monthly and quarterly NPDES monitoring data since the previous five-year reviewwas examined. All monitoring data is available and can be found in the monthly progressreports.

With the exception of one sampling event in the last 12 months (June 2007), pHmeasurements have been within the acceptable ranges as established under the NPDES dischargerequirements (i.e., pH between 6 to 9). The pH level for June 2007 was 5.9, which wasmarginally below the goal of 6-9. Five additional pH grab samples were collected at the outfallduring that month and were analyzed at the STP. All of these samples met the discharge goal of6-9. It should be noted that low pH was identified as an issue during the last five-year review. Asodium bicarbonate system was added to the STP in 2003 and provides for pH adjustment of theSTP effluent and the combined outfall flow when needed. This system has resolved low pHproblems.

The STP experienced an overflow event in April 2007. On April 5,2007, the O&Mcontractor received an alarm from the STP auto-dialer system that a high water level wasoccurring in Chamber 1. This alarm indicated that the available excess storage capacity at theplant was about to be exceeded, which would result in an overflow of untreated leachate to theoutfall. Upon arrival at the STP, the operator discovered that the combined influent flow of theleachate/upper groundwater trench rate was approximately 100 gpm, that untreated leachate wasoverflowing to the outfall from Chamber 6, and the forward feed pumps in MH-I were operatingonly intermittently, resulting in the accumulation ofleachate in the influent storage chambers.The STP operator determined that the cause of the intermittent pump operation was that one ofthe phases on the three-phase power supply to the STP was periodically dropping low. The STPwas switched over to generator power, and the MH-l pumps began operating consistently andliquid level in the influent chambers was drawn down. Overflow discharge from Chamber 6 tothe outfall was halted approximately five (5) hours from when the alarm was received. Thefollowing day, the electrician was able to access the faulty transformer and determined that someof the internal contacts had corroded. The transformer was repaired and the STP was removedfrom generator power.

In accordance with the approved standard operating procedure (SOP) for the STP, a watersample was collected from the outfall after the alarm. The sample was submitted to the lab foranalysis of CBODs, pH, TSS, and zinc. The zinc concentration was measured at 2.0 mg/l, whichexceeded the daily maximum limit of 1.2 mg/1. All other parameters were below their maximumdischarge limits.

In May 2007, the treatment capacity of the STP was enhanced by placement of a secondion exchange unit in parallel to the existing unit. This action was taken due to EPAlPADEPconcerns regarding the ability of the STP to handle additional flow generated in the near termduring remedial construction activities and spring rains. The second ion exchange unit addedapproximately 50 gpm of additional treatment capacity, for a total of approximately 100 gpm.


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Table 4: NPDES Monthly Monitoring Data for STP (last 12 months)

Sampling Date CBODs (mg/I) TSS (mg/l) Zinc (mg/l) pH Flow (gpm) Flow (MGD)

NPDES Permit' Discharge Limits

Monthly Avg./Daily Max. 25/50 30/60 0.6/1.2 6-9

December 12,2006" ND<0.33 ND<3.4 0.570 7.0 19.9 0.03

January 4, 2007 ND<0.33 ND<3.4 0.24J 6.6 20.5 0.03

February 7, 2007 NA ND <3.4 0.5 6.3 18.3 0.03

February 9, 2007 ND<0.33 NA NA NA

March 7, 2007" <2.0 8.8 0.17J 6.2 30.8 0.04

April 12, 2007 7.3 3.68 0.2 7.1 47.4 0.07

May 3, 2007 5U 3.4U 0.41 6.8 38.1 0.05

June 7, 2007" <5 <4 0.58 5.9 25.0 0.04

July 5,2007 <5 11.6 0.48 6.4 13.8 0.02

August 2, 2007 <5 <4 0.29 6.4 16.7 0.02

September 13, 2007" <5 11.2 0.36 6.8 11.2 0.Q2

October 4, 2007 <5 <4 0.39J 6.6 11.6 0.02

November 8, 2007 <5 <3.4 0.34 6.8 13.0 0.02

Notes: NO - Not detected.

- Discharge Permit No. PA-0070327 U - Not detected above the noted method detection limit

..- Quarterly sampling event J- Estimated value; concentration below reporting limit

NA - Not analyzed.

The temporary ion exchange unit was removed from the STP in October 2007 due togenerally dry Site conditions and reduced leachate flows that did not require the operation of theunit. Leachate flows have since remained well below the approximate 50-gpm limit of the STP.

Groundwater Monitoring Requirements and Results

The most recent groundwater sampling activities conducted at the Site were during thepreliminary design investigation for OU4. At that time, an initial phase was completed inJanuary 2005, and a second round of water sampling was taken during low flow conditions inJuly 2005.

Long-term (routine) groundwater sampling will be conducted on a semi-annual basisafter the completion of remedial activities associated with OU4. The OU4 ROD requires that atleast one upgradient and three downgradient well nests be sampled for Target Compound List(TCL) volatiles, semi-volatiles, PCBs, and Target Analyte List (TAL) metals.

To provide the three required downgradient shallow/deep aquifer sampling points, wellnests MW-3, MW-14, and MW-16 will be sampled. Well nest MW-8 will be utilized tocharacterize upgradient conditions. A summary of the monitoring well network at the EDM Site


is listed in Attachment 5. The corresponding monitoring well locations are shown onAttachment 6.

After an initial three-year sampling period following completion of remedial activities,the frequency of sampling will be re-evaluated by EPA and PADEP. Nassau will submit dataannually to EPA within two (2) months following the completion of the final sampling event foreach calendar year. Groundwater elevation measurements will be collected from all Sitemonitoring wells (not just those to be sampled) during each sampling event.

Groundwater Quality

Januarv 2005 Results.

Attachment 7 presents the water quality results (surface water, seep, and groundwater) forcopper, lead, zinc, and trichloroethene (TCE) from the January 2005 sampling event. The fulllist of groundwater analytical results can be found in Table 2-2 of the document entitledUnnamed Tributary Water Quality Report; Eastern Diversified Metals Site, Hometown,Pennsylvania dated October 28, 2005.

Only one VOC, TCE, was detected at a concentration exceeding MCLslMSCs in Sitegroundwater during this sampling event. The pattern of TCE detections in groundwater issimilar to that seen historically. As a general trend, TCE concentrations in groundwater werehighest to the south of the EDM Site and decreased towards the north. This is consistent with aTCE plume that originates to the east of the Site and which has an axis roughly oriented from theeast-northeast to the west-southwest. The decreasing TCE concentrations to the north suggestthe main axis of the TCE plume is located to the south of the EDM Site.

Other VOCs detected in groundwater from at least one well include very lowconcentrations of carbon tetrachloride, cis-I ,2-dichloroethese, and toluene, all of which werewell below MCLs/MSCs. No SVOCs were detected in any of the groundwater samples,including classes of compounds typically indicative of plastics within the fluff pile such asphenols and phthalates. Likewise, PCBs also were not detected in any of the groundwatersamples from January 2005.

Total lead exceeded its MCLlMSC of 5 ugll in well MW-14/0. However, the dissolvedphase result was significantly lower (0.17 ug/l), indicating that total lead was likely related tosuspended solids within the sample and is not truly indicative of groundwater conditions.Turbidity reading from MW-14/0 ranged from 180 to 780 NTUs during purging, significantlyhigher than in any other well. The only other metals which exceeded MCLslMSCs in any of themonitoring well samples were the common earth elements iron, manganese, and aluminum. TheSupplemental Hydrogeological Investigation Report (June 11, 1993) concluded that manganeseand iron are likely due to natural background conditions within the aquifer and are unrelated tothe fluff pile. The aluminum detections in MW-3/0 and MW-14/0 also appear related tosuspended solids within the sample, since filtered aluminum results were one to three orders ofmagnitude lower in these wells and were below MCLs/MSCs.

)'d Five-Year Review Report - 23

July 2005 Results.

The full list of groundwater analytical results for the July 2005 sampling event can befound in Table 3-5 of the document entitled Unnamed Tributary Water Quality Report,' EasternDiversified Metals Site, Hometown, Pennsylvania dated October 28, 2005.

Similar to the January 2005 results, TCE was the most widely detected VOC ingroundwater samples at the Site. The highest concentrations were noted at locations on the Sallproperty, including MW-13S (170 ug/l), MW-19/S (235 ug/l), and seep LS-8 (74.5 ug/I), each ofwhich exceeded the MCL for TCE of 5 ug/l. TCE concentrations in groundwater decrease withdistance to the north away from the axis formed by the locations of these southernmost samplingpoints. The July 2005 data correlates with the January 2005 sampling event in that the pattern isconsistent with a TCE plume that originates to the east of the Site, and which has an axis roughlyoriented west-southwest to the south of the EDM Site. Together, the data from 2005 supportsprior conclusions that the TCE in groundwater is not related to the EDM Site.

Carbon tetrachloride, cis-l ,2-DCE, and tetrachloroethene (PCE) were also detected in atleast one groundwater sample. For each of these, the highest concentrations were detected inwell MW-13/S, the background well to the east of the Site. The carbon tetrachlorideconcentration in MW-13/S (11.9 ug/l) was the only result for these parameters that exceededMCLs. No semivolatiles (SVOCs) or PCBs were detected in any of the monitoring wells.

The primary purpose ofthe groundwater sampling during July 2005 was to further refinethe understanding of potential sources of copper and zinc that might affect water quality withinthe unnamed tributary. None of the copper and zinc concentrations from the July 2005 samplingevent exceeded MCLs.

Dioxin Impacted Fluff (Former Burn Area)

Data associated with the removal of dioxin-impacted fluff indicated that the perfonnancestandard for removal to 20 uglkg dioxin was achieved in the Former Bum Area. Thisinformation is contained in the document entitled Remedial Action Report; Former Burn AreaDioxin Hotspot Removal; Eastern Diversified Metals Site; Hometown, PA dated April 2002.

Removal of Impacted Surface Soils (Gordon Property)

The removal of impacted soil and fugitive fluff from the Bernard Gordon property wascompleted by Nassau Metals Corporation in November and December 2005. Data associatedwith the removal indicated that the perfonnance standard for removal of soils withconcentrations exceeding the OU4 ROD-specified soil cleanup levels was achieved. Thisinformation is contained in the document entitled Completion Report for the Gordon PropertyRemedial Action; Eastern Diversified Metals Site, HometOlvn, PA dated March 6, 2006.


Site Inspection

On November 29,2007, a Site inspection was conducted by the EPA RPM (Mr. FrankKlanchar) and a PADEP Representative (Ms. Meg Boyer). Other parties present were a Nassaurepresentative (John Galasso), ERJv1 Project Manager (Pete Beyer), and RJS representative (BobStockl). The purpose of the inspection was to assess the protectiveness of the remedy, includingthe presence of a secure fence to restrict access, surface water and leachate management systems,and the overall condition of the Site Treatment Plant (STP). The weather on the day of the Siteinspection was overcast and cold (approximately 40° F). Construction activities associated withthe OU4 remedial action were in progress.

EPA made the following observations during the Site inspection:

Fencing and Site Access

The remedial action for OU4 (on-Site containment) is currently under construction. Mostof the Site security fencing has been removed and replaced with temporary fencing or highvisibility plastic tape. The fencing was removed in the fall of 2006 when construction activitiesbegan for OU4. Entrance gates are in place at the eastern end of the Site and restrict vehicularand pedestrian access. Signage is present on the fence stating that this area is construction siteand that access is restricted. Permanent security fencing and gates are scheduled to be installedaround the entire Site (Sall property) in the spring of 2008. The new fencing will be eight-foothigh chain link fence and include appropriate signage.

All access roads at the Site are in the process of being replaced under the OU4 remedialaction. The main access road, southern access road and part of the northern access road arescheduled to be constructed in the spring of 2008. The northern access road (west of existingsediment trap #5) and a new access road on the area to be capped will be completed aftervegetation is established at the Site and sediment trap #5 is taken out of service. Theseremaining sections of access road are planned for construction in the summer of 2009.

Site Treatment Plant (STP)

At the time of the Site inspection, the STP was operating normally. There werediscussions with the Nassau representative and treatment plant operator regarding on-lineperformance, removal efficiencies, and energy consumption. The treatment plant is wellmaintained and consequently, downtime has been minimized. The removal efficiency of theSTP has been very consistent. The issue of low pH of the STP effluent was resolved by theaddition of a sodium bicarbonate system in 2003. Energy usage has remained fairly constantover the years. The new overhead power line (installed under the OU4 remedial action)improved service to the STP. All pumps were in good condition and properly operating. Thecomputer that controls the STP was functioning properly. The computer recorded no recentalarms. No significant issues were noted during the Site inspection.


The EPA RPM suggested that the amount of influent to the STP (from the leachatecollection lines and shallow groundwater trench) might be reduced after construction of OU4remedial activities. In response to this comment, the Nassau representative stated that they areplanning to re-evaluate the STP operation in the future since influent flows have already shown amarked decrease with the commencement of OU4 capping activities. The re-evaluation willexplore opportunities for optimizing the performance of the STP.

Groundwater Monitoring Wells

Several groundwater monitoring wells not associated with the long-term groundwatermonitoring program were recently abandoned. These wells include the MW-2 well nest, MW4/0, the MW-5 well nest, the MW-7 well nest, and MW-17/0. These wells were abandonedunder OU4 remedial action activities. The MW-16 well nest, which is designated as a long-termgroundwater monitoring point, may need to be relocated based on its location within the futurecapped area. However, it may be possible to modify these two wells and leave them in place.All other wells not impacted by construction activities were in good condition and secured bypadlock.

Surface Water Drainage Systems

The OV4 remedial action, which is currently under construction, has altered the drainagefeatures at the Site. Temporary erosion and sedimentation controls have been put in place inaccordance with the approved OU4 design and specifications. These controls are generallyperforming as designed. Impacts from erosion during construction activities have beenminimized through routine maintenance. Permanent drainage controls and enhancements to theexisting flume that conveys Site run-on water around the western end of the fluff pile willprovide storm water control at the Site once OU4 remedial activities are complete. Thepennanent measures are expected to be compJete in the summer of2008.

On-Site Containment System (cap)

The cover system for the fluff pile (OU4) is currently under construction. The fluff pilehas been regraded and a one-foot thick layer of soil sub-base has been placed over the entire areato be capped. Installation of the liner system (GCL, geomembrane, and geocomposite drainagelayer) began in October 2007. Portions of the northern and southern side of the fluff pile havereceived components of the liner system. Bad weather conditions forced a decision by Nassau topostpone construction of the liner system until spring of2008. At the time of the Site Inspection,the contractor was implementing a winter Site stabilization plan. The physical completion of thecap system for the fluff pile is expected to be complete in the summer of 2008.

Interviews

Interviews were conducted with the technical representatives associated with the Siteduring the Site inspection on November 29, 2007. Other than the ongoing construction activities


associated with OU 1 and OU4, no problems or concerns were noted for the Site. Nassau plans tore-evaluate the STP operation after the OU4 construction activities are completed.

On November 15,2007, the EPA RPM and EPA CIC conducted interviews with aresident who lives adjacent to the Site and the Mayor of Tamaqua. The resident relayed severalconcerns that he expressed to EPA. The most notable comment was that the community'sopinion did not matter in EPA's decision to cap the Site. He raised a concern if he made theright decision to stay at the property next to the Site, or if the Site's previous operations had arole in his family's ailments. He also stated that Site activities have caused a culvert located onthe adjacent railroad property to become blocked which causes periodic flooding on a portion ofhis land. The culvert opening on the SaIl property was explored during this five-year review andfound not to be restricting flow. The culvert blockage is likely on the railroad property, possiblyunderneath the active railroad line. The resident also suggested that a plaque be added at theentrance to the Site with the names of parties responsible for the cleanup.

The Mayor of Tamaqua commented that the Site looked much different than it lookedyears ago and was pleased that some progress, although slow, was occurring. He thought thatthe local media might be interested in the cleanup progress and suggested that EPA utilize thenewspapers and local television stations as a means to inform/update the community. The onlyconcern worth noting was that the nearby creek was showing signs of acid mine drainage and hefelt that it was related to the Site.

On November 29, 2007, a reporter from the Republican Herald newspaper in Pottsto\\<TI,PA interviewed the EPA RPM and EPA CIC. An article on the EDM Site was published in thenewspaper the following day and provided an update on the status of construction activities atthe Site.

Potential for Reuse of the Site

The November 2001 ROD for OU4 defined an area for potential reuse as being anapproximate four to six acre area at the eastern end of the Site. The ROD included aperformance standard that land use in that portion of the Site made available for redevelopmentwould be limited to industrial or commercial use. The ROD was clear to state that the goal wasonly to provide the opportunity for future commercial land use and EPA's remedial activities donot include actual commercial or industrial development or the construction of a building orother facilities.

The approved remedial design for OU4 entitled, Final Design Submittal; RemedialAction Work Plan; QUI and QU4 dated June 28, 2006 discussed that a portion of the Siteoutside the regraded fluff pile perimeter on the eastern end of the Site was planned forredevelopment. However, the four to six acre area was removed from further considerationduring the OU4 preliminary design. This decision was based on the footprint of the fluff pile at4: 1 slopes reducing the possible size of this parcel below which there would be any practical orfunctional use.


•

The construction of the OU4 remedy is underway at the time of this five-year review. Itshould be noted that a portion of the eastern end of the Site will be available for redevelopmentonce construction is complete, but the exact area is will not be known until a final survey iscompleted for the Site. The survey will take place after in the summer of 2008 and the areaavailable for reuse will be documented in the Final Remedial Action Report.

With the exception of the eastern portion of the Site available for reuse as discussedabove, the remainder of the Site property will be fenced and will require operation andmaintenance of the remedial actions. The cap, drainage structures, stormwater impoundment,maintenance roads, and the treatment plant will take up most of this area. The primary Sitecontaminant is lead and this contaminant will remain immobile under the cap, therefore, the capmust be maintained indefinitely. The supporting structures and maintenance roads will beneeded indefinitely and any development thereof could pose a risk to the integrity of theremedial action. Although there are discrete non-contiguous sections of this area that existbetween constructed elements of the remedial action, using these for any purpose other thanmaintenance of the remedy would pose a risk to the remedial action. Moreover, these smallareas within the remedial action construction area would be very small, and so is anycorresponding commercial value. The land is within an industrial park and is not suitable forpublic use and could pose a risk to children or trespassers. Because the cap is on downwardsloping terrain, the cap is terraced and this would not make a good candidate for any recreationaluse. A stormwater impoundment will pose a water hazard to trespassing children and trespassingmight lead to vandalism of important structures. The fence will be an impediment to trespassing.After the OU4 remedial action is completed, it will be possible to use the property in a mannerthat would not pose any risk to the integrity of the cap, treatment plant, leachate collectionsystem or associate elements of the remedial action.

VII. Technical Assessment

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

Yes. The review of decision documents, work plans, remedial designs, monthly progressreports, ARARs, risk assumptions, results of interviews, and the Site inspection indicates theremedy is functioning as intended by the March 1991 ROD (OUI and OU2), September 1993ROD (OU2), and November 2001 ROD (OU4).

Cover System (cap)

The OU4 remedy is currently under construction and is being constructed in accordancewith the approved design specifications. The central feature of the approved design is the"RCRA-equivalent cap" that will cover the consolidated fluff and contaminated Site soils. Thecap is intended to prevent future direct human contact with these materials and minimize theinfiltration of precipitation and subsequent leaching of site contaminants. The fluff pile has beenregraded to provide stable slopes for the placement of cap components. Final side slopes will beno steeper than 4 horizontal to 1 vertical (4H: 1V). The slopes will also be broken in length by 15foot-wide terraces located every 25 feet of vertical rise in slope. The existing steep slope(approximately 2:1) located in the southwest region of the Site, immediately adjacent to the STP


I,

is known as the western embankment. The western embankment contains fluff. The fluff fromareas within the western embankment will be partially excavated and consolidated onto the fluffpile. The western embankment will receive a 3-foot soil cover (2.5-foot thick clayey soil and 6inch thick topsoil). This cover is sufficient to ensure that any remaining fluff materials will notbe exposed and subject to contact, ingestion, or inhalation. The cap and western embankmentwill remain contained within the SaIl Property, while also providing enough space on theperimeter for runoff collection, sediment control, run-on diversions, and access for maintenance.

The design also contains other substantial elements, including but not limited to, therelocation and expansion of the current leachate and overburden groundwater collection trenches,installation of new discharge line for the Site Treatment Plant, removal of sediments from theunnamed tributary and restoration (remaining OU 1 remedial action), construction of a steepembankment, stormwater management features for the Site, relocation of utilities, andconstruction of access roads. New security fencing will encompass the Sall property to preventunauthorized access to the engineered cap and supporting features, including the leachatecollection and handling facilities and the STP.

The physical construction of OUI and OU4 activities are expected to be complete in thesummer of 2008 and the Site is expected to achieve construction completion status by the end ofSeptember 2008.

Site Treatment Plant CSTP)

The remedial action objective of reducing the fluff and contaminant transport to thegroundwater and surface water have been met by the upgrade of the surface water and leachatecollection systems and the STP. Storm water runoff and leachate migration are being controlledthrough a series of surface water management systems and groundwater collection trenches. Thesite treatment plant is effectively treating leachate and shallow groundwater prior to its dischargeto the unnamed tributary on-Site in accordance with the NPDES discharge requirementsestablished for the Site.

In general, effluent discharge to the unnamed tributary from the STP have been withinthe required limits as set forth under the NPDES discharge requirements for both daily maximumand monthly average values. The previous issue of low pH of the STP effluent was addressed bythe addition of a sodium bicarbonate system in 2003. The STP is properly operated andmaintained.

In review of the system's present operation, all operational parameters of the extractionsystem are deemed adequate and functioning as intended by the 1985 ROD and 1991 RODAmendment. No modifications to the STP are recommended at this time.

Dioxin-Impacted Fluff

The remedial action objective (RAO) of preventing further exposure and reducing thetoxicity, mobility, and volume of dioxins and PCBs has also been achieved. The removal ofdioxin-contaminated fluff from the Former Burn Area (FBA) is complete and a review of the


analytical data reveals that the impacted fluff was removed to the required performance standardof 20 uglkg dioxin.

Institutional Controls

The November 2001 ROD for OU4 required that land use restrictions are to beimplemented to prevent any land use of the capped area which would pose a risk of damage tothe cap and associated structures or a risk of injury to people from the on-Site response structuresand equipment. Ancillary systems which support the cap integrity, such as the surface waterdrainage systems and leachate collection systems, are to be included within the scope of theinstitutional controls.

Institutional controls have not been put in place at the Site. Nassau alleges that it doesnot own the property that will contain the capped area. The last owner of record is TheodoreSail, Inc. This company is no longer in existence. Access to the Site property for the purpose ofimplementing the OU4 remedial action, including operation and maintenance, was grantedthrough the Courts in 2004.

The permanent fencing and gates around the Site (Sall property) will be constructed inthe spring of2008. The new fencing will be eight-foot high chain link fence and includeappropriate signs placed at 1OO-foot intervals. Once constructed, the perimeter fence should beeffective at preventing unauthorized persons from accessing the Site.

Optimization Opportunities

There were no opportunities for system optimization observed during this review.Nassau Metals Corporation, the PRP implementing the ongoing OU4 remedial action andconducting O&M activities at the Site, stated that their intentions are to re-evaluate the operationof the STP following completion of OU4 remedial activities. Their re-evaluation will exploreopportunities for optimizing the performance of the STP. Any future recommendations for STPchanges or optimization would be reviewed and assessed by EPA and PADEP.

• Question B: Are the exposure assumptions, toxicity data, cleanup levels, and remedialaction objectives (RAGs) used at the time ofremedy selection still valid?

Yes. The toxicity data, cleanup levels, and remedial action objectives have not changedand are still valid.

The exposure assumptions used to develop the Human Health Risk Assessment includedboth current and future exposures. These assumptions are considered to be conservative andreasonable in evaluating risk and developing risk-based cleanup levels. New PBC and lead dataacquired during the abandoned recycling design (OU3), combined with calculations consistentwith the current Risk Assessment Guidance, might make some minor changes to the risknumbers. However, the changes would have little impact on the selection of an appropriateremedial action. Based on a review of the 1990 risk assessment by EPA at the time of the 2001


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assessment methods are used, but the overall baseline risk assessment was still valid.

Land lise near the Site has not changed since the last five-year review. The Site remainsbordered on the south and east by an industrial park for light industry, on the west by State GameLands, and to the north by railroad tracks. Beyond the railroad tracks are an undevelopedproperty and a residential property. EPA is unaware of any plans to further develop or subdividethe property to the north of the Site.

Activities associated with the OU4 remedial action (capping) are currently underconstruction and physical changes are occurring on the surface of the Site. However, no changeshave been made that would compromise or affect the protectiveness of the remedy.

Changes in Standards and To Be Considered

As remedial work has been completed, all ARARs for construction-type activities cited inthe ROD and ROD Amendment have been met. ARARs that still must be met at this time areassociated with the OU4 construction activities and the STP. A list of ARARs is included inAttachment 4. There have been no changes in these ARA.Rs and no new standards or TBesaffecting the protectiveness of the remedy.

• Question C: Has any other information come to light that could call into question theprotectiveness ofthe remedy?

No. There is no new or other information that calls into question the protectiveness ofthe remedies as specified in the 1991 ROD (aU I and OU2), 1993 ROD (OU2), or the 2001ROD (OU4).

Technical Assessment Summary

According to the data reviewed, the Site inspection, and the interviews, the remedy isfunctioning as intended by the March 1991 ROD (OUI and OU2), September 1993 ROD (OU2),and November 2001 ROD (OU4). Activities associated with the OU4 remedial action (capping)are currently under construction and physical changes are occurring on the surface of the Site.However, no changes have been made that would compromise or affect the protectiveness of theremedy. The action specific ARAR for the STP effluent discharge is being met. The previousissue of low pH of the STP effluent was addressed by the addition of a sodium bicarbonatesystem in 2003 and the STP is properly operated and maintained. Based upon a review of the1990 risk assessment by EPA at the time of the 2001 ROD (OU4), EPA concluded that the risknumbers may be somewhat changed if the current risk assessment methods are used, but theoverall baseline risk assessment was still valid. There is no other information that calls intoquestion the protectiveness of the remedies for the Site.

3rd Five-Year Review Report - 3 I

VI II. Issues

The table below summarizes the current issues at the Eastern Diversified Metals Site.

Table 5: IssuesAffects Current Affects Future

Issues Protectiveness Protectiveness(YIN) (YIN)

1. OU4 remedial activities are under construction and minimal vegetation has N Ybeen established at the Site.

2. Institutional controls (ICs) have not been put in place for the Site due to the N Yuncertainty as to property ownership.

3. Following completion of the OU4 remedy, the quality and quantity of N Nwater collected at the Site Treatment Plant (STP) may change.

4. The area available for reuse at the Site may be less than specified in the N NOU4 ROD after implementation of the OU4 remedial activities.

IX. Recommendations and Follow-up Actions

EPA's recommendations and follow-up actions for the Eastern Diversified Metals Siteare in the following table.

Ad F IIdT bl 6 Ra e ecommen atlons an 0 ow-up ctlonsAffects Protectiveness

IssueRecommendations and Party Oversight

Milestone Date (YIN)Follow-up Actions Responsible Agency

Current Future

I. OU4 remedial activities Responsible EPA, By September N Yneed to be completed. Parties PADEP 2008

2. Institutional controls Responsible EPA, By next Five- N Yneed to be put in place to Parties PAOEP Year Reviewprevent damage to thecap and associatedstructures.

3. The overall performance Responsible EPA, By next Five- N Nof the treatment plant, Parties PADEP Year Reviewincluding opportunitiesfor optimization, willneed to be evaluatedafter the OU4 remedialactivities are completed

4. The area available for Responsible EPA, By m:xt Five- N Nreuse should be PartieslEPA PAOEP Year Reviewdocumented in the FinalRemedial Action Report,and if necessary, anExplanation ofSignificant Differences(ESO) prepared.


X. Protectiveness Statement

The remedy for au I is expected to be protective of human health and the environmentupon completion, and in the interim, exposure pathways that could result in unacceptable risksare being controlled. The principal threat from the dioxin-impacted fluff was addressed by theexcavation, treatment, and subsequent off-site disposal of dioxin-impacted fluff at an off-siteincineration facility. The only portion of the remedy not completed for OUI is the sedimentremoval from the unnamed tributary to the Little Schuylkill River. Remedial activities toaddress this remaining portion of au I were integrated into the OU4 remedial design. Theremedy for au I is expected to be protective of human health and the environment uponcompletion of the remedial activities for OU4.

The remedy for OU2 is protective of human health and the environment. The September1993 ROD selected "No Action" for the deep groundwater at the Site, and shallowoverburden/leachate was addressed by the remedial actions as specified in the March 1991 RODthat included enhanced shallow groundwater collection and treatment.

The remedy for OU3, recycling of the fluff pile, was changed pursuant to the OU4 RODissued on November 26, 200 1, which selected on-Site containment of the fluff pile, groundwatermonitoring, and institutional controls.

The remedy for OU4, on-Site containment of the fluff pile, is currently underconstruction and expected to be protective of human health and the environment uponcompletion, and in the interim, exposure pathways that could result in unacceptable risks arebeing controlled. OU4 is the final remedial action for the Site. Land use restrictions for the caparea (institutional controls) described in the November 2001 ROD (OU4) have not yet beenimplemented since ownership of the property remains an issue. The Site is expected to achieveconstruction completion in fiscal year 2008 when OU4 construction activities are scheduled to becompleted and a Final Close Out Report prepared by EPA.

XI. Next Review

EPA will conduct another five-year review within five (5) years of the completion of thisfive-year review report. The completion date is the date of the signature on the front of thisreport.


ATTACHMENT 1: EDM Site Location Map

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Eastern Diversified Metals SiteSchuylkill County, Pennsylvania

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ATTACHMENT 3: List of Documents Reviewed

Record of Decision, Eastern Diversified Metals Site. U.S. EPA Region III; March 29, 1990.

Record of Decision, Eastern Diversified Metals Site, Operable Unit Three. U.S. EPA Region III;July 2, 1992.

Record of Decision, Eastern Diversified Metals Site, Operable Unit Two: Deep Groundwater.U.S. EPA Region III; September 29, 1993.

Five-Year Review Report (Type Ia), Eastern Diversified Metals Superfund Site, Hometown,Pennsylvania. U.S. EPA Region III; February 9, 1998.

Record of Decision, Eastern Diversified Metals Site, Operable Unit 4. U.S. EPA Region III;November 26,2001.

Five-Year Review Report, Eastern Diversified Metals, Rush Township, Schuylkill County, PA.U.S. EPA Region III; February 12,2003.

Order on Consent for Remedial DesignlRemedial Action, In the Matter Of: Eastern DiversifiedMetals Site in Hometown, Schuylkill County, Pennsylvania, Nassau Metals Corporation,Civil Action No.4: CY 03-1484, October 30,2003.

Remedial Design Work Plan, Operable Unit 4, Eastern Diversified Metals Site, Hometown,Pennsylvania. ERM; January 29, 2004.

Order for Access to property owned by Theodore Sail, Inc., In the Matter Of: Eastern DiversifiedMetals Site, located near intersection of Routes 54 and 309, Hometown, SchuylkillCounty, Pennsylvania, Civil Action No. 4:04-CYOI653, November 8,2004.

Standard Operating Procedures, Eastern Diversified Metals Site Treatment Plant, ERM; June1998, Revised September 2005.

Remedial Action Work Plan - Gordon Property, Operable Unit 4, Eastern Diversified MetalsSite, Hometown, Pennsylvania. ERM; September 21, 2005.

Unnamed Tributary Water Quality Report, Eastern Diversified Metals Site, Hometown,Pennsylvania. ERM; October 28,2005.

Completion Report for the Gordon Property Remedial Action (RA Report), Eastern DiversifiedMetals Site, Hometown, Pennsylvania. ERM; March 6, 2006.

Final Design Submittal and Remedial Action Work Plan, OU-I and OU-4, Eastern DiversifiedMetals Site, Hometown, Schuylkill County, Pennsylvania. ERM; June 28,2006.

Monthly Progress Reports and Monthly Discharge Monitoring Reports (DMR) for the EasternDiversified Metals Site. Lucent Technologies; February 2003 - December 2007.


ATTACHMENT 4: Applicable or Relevant and Appropriate Requirements (ARARs)

Medium/Authority ARAR (Citation) Status Requirement SynopsisAction to be taken to

attain ARAR

OUI and OU2 ARARs (taken from March 1991 ROD)'

Surface Water/ 25 PA Code Chapter Applicable Establishes water quality ARAR being met. STP isPA Water Quality Criteria 93.1 et. Seq. criteria for protection of treating leachate prior to

freshwater aquatic life, discharge to unnamedhuman health, fish tributary on-Site.consumption.

Debris & Fluff/ 25 PA Code Chapter Applicable Establishes requirements for ARAR was addressedRCRA 261 identification of during off-Site disposal of

characteristic hazardous debris and fluff.40 CFR Part 261 waste.

Debris & FlufflRCRA and 40 CFR Part 262 and Applicable Applies to transportation of ARAR was addressedDOT Regulations 263 hazardous wastes offsite. during off-Site disposal of

debris and fluff40 CFR Parts 107and 171-179

Debris & FlufflLand 40 CFR Part 268 Applicable Establishes requirements for ARAR was addressedDisposal Restrictions disposal of hazardous during off-Site disposal of(LOR) waste. debris and fluffWorker Safety/OSHA 29 CFR Parts 1904, Applicable Establishes standards for ARARs met during OU I

1910, and 1926 worker's protection. remedial activities.Equalization 25 PA Code Applicable Establishes standards for ARARs met during OU ILagoons/RCRA Chapters 260-270 equalization lagoon remedial activities.

upgrades/new lagoon.Groundwaterf'background" 25 PA Code Sections Applicable Hazardous substances in The selected remedy willQuality for Groundwater 264.90-264.100; 25 groundwater must be attain state standards in the

PA Code Sections remediated to "background" groundwater after264.97(i), 0), and quality. completion of all remedial264. 100(a)(9). activities, including OU4.

Land/Erosion and 25 PA Code Chapter Relevant Establishes standards for ARARs met during OU ISedimentation Control 102 and erosion and sedimentation remedial activities.

Appropriate control measures.

OU4 ARARs (taken from November 2001 ROD)

Unexpected Hazardous 25 PA Code Chapters Applicable Establishes requirements for No unexpected hazardousWastes 261 a and 262a identification, generation, wastes were encountered

and handling of during OU4 construction40 CFR Parts 261 characteristic hazardous activities.and 262 wastes.

Disposal/Decontamination 40 CFR Section Applicable Equipment must be ARAR currently beingof Equipment, Structures, 264.114 disposed or decontaminated. met. Construction of OU4and Soils remedial action is

underway.Temporary Storage of 40 CFR Part 264, Applicable Establishes standards for No unexpected hazardousUnexpected Hazardous Subchapters I, J, and temporary storage of wastes were encounteredWastes L hazardous wastes on-site in during OU4 construction

containers, tanks, or waste activities.piles.

Multilayer Cap 40 CFR Section Relevant Establishes requirements for ARAR will be met264.30 I(c)(l )(i)(A) and landfill liners and vegetative following construction of25 PA Code Section Appropriate cover. OU4 remedial action288.236 Establishes requirements for activities.40 CFR Section post-closure care of264.117 hazardous waste

management units.

)'d Five-Year Review Report - 38

;,

Medium/Authority ARAR (Citation) Status Requirement SynopsisAction to be taken to

attain ARARErosion and Sedimentation 25 PA Code Chapter Relevant Establishes standards for ARAR currently beingControls 102 and erosion and sedimentation met. Construction ofOU4

25 PA Code Chapter Appropriate control measures remedial action is105 underway.

Air Emissions 25 PA Code Section Relevant Establishes standards for ARAR currently being123 and control offugitive met. Construction of OU425 PA Code Section Appropriate emissions and control of remedial action is288 explosive and toxic threats underway.

from gas emissions.Closure and Maintenance 40 CFR Section Relevant Establishes standards for ARAR will be met

264.310 and closure and post-closure following construction of40 CrR Section Appropriate care of landfills. OU4 remedial action264.117 Establishes requirements for activities.25 PA Code Section post-closure care of288.212 hazardous waste25 PA Code Chapter management units.264a

- Any ARAR associated with on-site incineration and/or incineration of PCBs as specified in the March 1991 ROD were notincluded since these activities were determined not to be necessary, and therefore, the ARARs did not apply.

}'d Five-Year Review Report - 39

•

ATTACHMENT 5: Summary ofEDM Monitoring Well Network

Monitoring Wells Installed Since 2003Eastern Diversified Metals Site

Screened Included inWell In Type Depth Diameter Interval Installation Status Post-Closure

(ft BGS) (inches) (ft BGS) Date Monitoring?MW-3/S Shallow 51 2 36-5 I December 2004 Active Yes

Bedrock

MW-14/0 Overburden 17 2 7-17 December 2004 Active Yes

MW-14/S Shallow 50 2 15-35 December 2004 Active YesBedrock

MW-15/0 Overburden 22 2 12-22 December 2004 Active No

MW-16/0 Overburden 18 2 8-18 December 2004 Abandoned No

MW-16/S Shallow 40 2 27-40 December 2004 Active YesBedrock

MW-16/1 Intermediate 90 2 60-90 October 2006 Active YesBedrock



MW-19/0 Overburden 22 2 12-22 December 2004 Active No

MW-19/S Shallow 58 2 38-58 June 2005 Active NoBedrock

MW-20/0 Overburden 17 2 5-17 June 2005 Active No

3rd Five-Year Review Report· 40

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FIGURE 2-2WATER QUALITY RESULTS

12 JANUARY 2005!!AlTERN DIV!!RSlFIED METALS SITI!

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