Masonic Homes JOSEPH E. MURPHY, N.H.A. of the R. W. Grand Lodge F. & A. M. of Pennsylvania Executive Director

ONE MASONIC DRIVE • ELIZABETHTOWN, PA 17022-2199 • [ 717] 367-1121

May 19, 1997

Sherry Gallagher-3HW22 · U.S. Environmental Protection Agency Region III 841 Chestnut Building Philadelphia P A 19107-4431

Dear Ms. Gallagher:

My understanding is that you are need of the agreements reached between Masonic Homes and Waste Mangement concerning access issues and replacement water supplies prior to the issuance of the Record ofDecision(ROD) in September. As you are aware, Masonic Homes has agreed to provide Waste Management access to our property for the purpose of remedial • activities of the Alternative Remedial Plan (ARP) and Record ofDecision (ROD).

I realize that you have been absent for many of the discussions Masonic Homes had with EPA and Waste Management concerning the critical nature of the drinking water supplies in this region. Therefore, it is imperative that you understand that Masonic Homes has weighed the advantages and risks associated with both the Alternative Remedial Plan ( ARP) and the Proposed Remedial Alternative Plan (PRAP). We endorse the ARP because it directly addresses water quality issues for the landowners adjacent and down gradient to the Elizabethtown Landfill. We believe elimination of the risks associated with consumption of the ground water in an timely fashion is preferable to the PRAP which provides no guarantee that the quality of the ground water quality will improve for the land owners affected by the "site" and does not address the concern expressed by land owners concerning decreased water well yields. We also believe that the implementation of an aggressive two year monitoring program to study the affects of the landfill upon the wells of land owners down gradient of the landfill as proposed in the ARP is needed to determine if the contamination is in steady state or is continuing to migrate off-site.

Enclosed is the Agreement executed by Masonic Homes and Waste Management and the referenced Alternative Remedial Plan presented to EPA by Waste Management. I have also included the Letter Agreement for the Siting, Design and Installation of Replacement Water Supply Well(s) executed by Masonic Homes and Waste Management. This agreement provides' for Waste Management to pay the costs associated with the siting, design and installation of a • production well on Masonic Homes property.

AR308\33

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Masonic Homes is pleased that the U.S. Environmental Protection Agency is evaluating the ARP for inclusion in the ROD. I would be happy to meet in person with you to more thoroughly discuss our concerns. Please contact me in the near future to schedule this meeting.

Sincerely,

·(9~1~ Robin L. Pepperman Director of Safety and Risk Management

enclosures (3)

c: Joseph E. Murphy Michelle Martin, Morgan, Lewis and Beckius Trevan Houser, Waste Management

AR308t34

AGREE:VfENT

AGREEi\fENT, dated Februarv 28, 1997, between The Masonic Homes ·- . , which is unincorpor::1ted. owned and operated by tire Grand Lodge of Free ::1nd Accepted

Masons of PeMsylvania ("Masonic Homes"). the owners of property located in

Elizabethtown Borough and West Donegal Township, Pennsylvania as more fully described

in Exhibit "A" hereto (the "Property"), and Waste Management Disposal Ser\·ices of

PeMsylvania. [nc .. formerly knov.;n as SCA Services of PeMsylvania. Inc. t "SCA

Sen·ices"). a PeMsylvania corporation (hereinafter collectively referred to as the "Parties").

\\ "HEREAS, SCA Services is the owner of the Elizabethtown Landtill

("Landfill"). a closed landfill located in West Donegal Township. Lancaster County,

Pennsylvania:

\\ "HEREAS, the Landfill was placed on the National Priorities List by the

U.S. Envirotu11ental Protection Agency ("EP:\.") on March 31. 1989:

\\"HEREAS. a Remedial Investigation/Feasibility Study ("Rl FS"") was

performed by SCA. Sen·ices for the Landfill based upon an EPA Region III RI. FS Consent

Order at Docket :\o. III-90-44-DC:

WHEREAS. EPA has performed a Revised Risk Assessment ( ··RR-\ ") for the

Landfill:

\\"HERE.-\S. EPA published a Proposed Remedial .-\ction Plan ("PRAP") for

the Landfill on July 26. 1995, which, among other things. generally provides for the

following resp\.~nse actions: l) an alternative water supply for fi\·e ( 5) do\\'n-gradient

67069 2/28/97

t\R30S.I 35

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residences (excluding Masonic Homes): : l upgrading of the soil cover system in the

northern portion of the -Landfill and installation of a final soil cover system in the southern

portion of the Land±111: 3) extraction of contaminated groundwater for on-site treatment and

strc:lm discharge; 4) landfill gas monitoring and management: 5) leachate collection and on-

site treatment; 6) groundwater, surface \\·ater and sediment monitoring; 7) establishment of

on-site deed restrictions; and 8) extend the security fence, inspect and maintain the

stormwater management and cover system:

WHEREAS, SCA Services has proposed to EPA an Alternative Remedial

Plan ("ARP'') for the Landfill on behalf of the Elizabethtown Stakeholders Group

('"Group'") 1 to promote the implementation of the Land Recycling and Environmental

Remediation Standards Act ('~Act 2"), Act of May 19, 1995, P.L. 4, No. 2 and EPA's

Superfund Reform Initiatives. A copy of the ARP is attached hereto as Exhibit "B". The

ARP. among other things, generally provides for the following response actions: 1)

Acceptance of the existing soil cov~r in the northern portion of the Landfill based upon an

equi\·alency demonstration under applicable Pennsylvania Department of Environmental

Protection ( "D EP") requirements and the installation of an asphalt cover over the southern

portion of the Landfill to meet state performance standards; 2) provision of alternative

\Vater supplies to the Masonic Homes and tive (5) down-gradient residences: 3) continued

groundwater. surface water and sediment monitoring. including monitoring to evaluate

The members of the Group consist of the Landfill PRP Group. the Masonic Homes. Elizabethtown Borough and West Donegal Township .

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AR308\36

natural attenuation of groundv.;ater contaminants and the need. if any. for future active • remediation measures: ~) landfill gas monitoring and management with future modifications

as dictated by gas generation: 5) upgraded leachate collection and treatment: 6)

establishment of on-site and down-gradient off-site deed restrictions: and 7) extend the

security fence. upgrade. inspect and maintain the stormwater management system and

inspect and maintain the cover system:

WHEREAS, Masonic Homes generally concurs with the ARP and appro\·es

of the same provided that SCA Services agrees and complies with the follO\\·ing terms and

conditions:

WHEREAS, SCA Services has entered into a letter agreement with Masonic

Homes dated February 6, 1997 (the "Letter Agreement") regarding the siting. design and

installation of a replacement drinking water well or wells at the Property. as more fully • described in the Letter Agreement. attached hereto as Exhibit "C". '.

NO\\". THEREFORE. the Parties hereby agree to be legally bound to the

following terms and conditions.

1. ~ [asonic Homes hereby grants the right of access to the Property to

SCA Sen·ices. its employees. agents, consultants, contractors or subcontractors and other

authorized agents. whether retained directly or indirectly by SCA Services (collective!;·.

"Grantees"). for the purposes of carrying out the Performing Work as specified in

Paragraphs 2 and 3 of this Agreement by the routes and areas described in Exhibit "A"

attached hereto and made a part hereof. or any such routes and areas as otherwise agreed

3 67069 2.'23/97 • ~R308\31

• upon b\· the Parties. Such right of access shall also extend to EPA and the Pennsvlvania . . . Department of EnvironJ!1ental Protection ("DEP") and their respective employees.

representati\·es and contractors. SCA Services shall provide Masonic Homes with notice at

least forty-eight ( 48) hours prior to entering the Property, unless otherwise agreed upon by

the Parties. and shall use reasonable effons to idemit~· therein all persons, contractors.

subcontractors or other Juthorized agents who will be entering the Property and shall

idemit~· the type of equipment to be used. SCA Sen·ices shall require that any of its

· contractors or subcontr:1ctors requiring access to the Property comply with the terms of this

.-\greement.

2. For purposes of this Agreement. "Performing Work" shall mean any

• work identified in or necessary or desirable to the implementation of the ARP, or any

monitoring or remedial \\·ork identified by EPA and agreed to by SCA Services as

necessary tor implementing the Etizabethtown Landtill Record of Decision ("ROD"),

including Remedial Design and Remedial Action components. and including, but not

limited to. any remedial activities required by EPA. as agreed to by SCA Services, upon a

derermination by the U£>:!ncy. based on the results of rhe two-year monitoring program

under the .-\RP. that additional groundwater remediation is necessary.

3. 0. lasonic Homes grants Grantees the right of access to the Property for

the duration of the Performing Work undertaken by SCA Services at the Property. The

Parties further agree to the following:

• 67069 2!28/97·

AR308138

• (a) Grantees· rights of access to and use of the Prop.:rty for

conductin!! the Performipg: Work shall include, but not be limited to. the riS!:ht of ing:ress ... - - -and egress for materials. personnel and equipment; the right to sample, study. and analyze

soils. sediments. surface water or groundwater on or beneath the Property: the right to

install monitoring wells. soil borings. and test pits and to monitor Masonic Homes· wells

EM400 and E:-.1500. ).[asonic Homes shall be provided a copy of a schedule relating to

well placement and soil borings. and a plan showing the proposed location thereof prior to

performance of said activities.

(b) ).fasonic Homes agrees to implement deed restrictions as

required by EPA under the ROD and as necessary for its implementation at limited portions

of the Property and the underlying aquifer. Exhibit "A", attached hereto, is illustrath·e of • those areas which the Parties believe may be subject to deed restrictions under the ROD.

Masonic Homes may negotiate with EPA concerning the scope of deed restrictions to be

required by EPA. under the ROD if different from Exhibit "A"; provided that ).[asonic

Homes will implement the deed restrictions required by EPA.

t,; l SC...\ Services agrees to obserYe and comply \\·ith all applicable

municipal. county. state and federal regulations, standards. ordinances and laws when

entering upon the Propert)· and in the performance of any actions pursuant to this

Agreement. Failure to comply with such applicable regulations, standards. or ordinance and

laws will be just grounds for immediate cessation of SCA Services· operations on· the

Property until st11.:h time as the noncompliance is corrected.

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(d) Upon the completion of any defined segment of the Performing

Work. SCA Sen·ices sh~ll within thirty (30) business days restore the Property to its

Original Condition as defined below; provided that any delay occasioned by a force

majeure e\·ent (which, for purposes of this paragraph constitutes an event arising from

causes not reasonably foreseeable by, and beyond the reasonable control of. SCA Sen·ices)

shall not be counted in determining the length of the restoration period. SC.-\ Stervices shall

provide ~fasonic Homes with notice, by telephone, within three (3) business days after

becoming aware of the force majeure event. and provide .\Iasonic Homes \\'ith a written

report of such e\·ent within ten ( 1 0) business days after becoming aware of its occurrence.

The written report shall explain the event(s) giving rise to the delay and the revise4 time

table for completing restoration of the Property. For purposes of this Agreement, "Original

Condition'' shall mean the condition of the Property immediately prior to SC.A. Services

undertaking the Performing Work, except for those installations which are permanently

required to implement the ROD. In the case of monitoring wells. it is the Parties'

understanding that a "permanently required monitoring well" is one which shall be in place

for a perivd not to exceed 3.0 years. or such longer period as otherwise required by EP .-\.

-+. SCA Services acknowledges, and Masonic Homes supports, the

provision of alternate water supplies to the five (5) downgradient residences from the

Landfill. as set forth in the ARP .

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AR308l40

5. ~[asonic Hom>!s agrees to cooperate with and support any activities • undertaken b\· SCA Sen·ices in connection with the Performing; Work at the Landtill and . . -the Property as agreed to herein. including but not limited to the following:

(al Masonic Homes agrees that it will fully support the ARP.

cooperate with SCA Sen·ices in SC.-\ Services' efforts to secure EPA approval of the ARP

in the ROD for the Landfill and the implementation thereof;

(b l :Vfasonic Homes agrees that it will use its best efforts to consult

with SCA Services prior to initiating any activities on the Property which could interfere

with the implementation of the .-\RP:

(c) Masonic Homes agrees to share with SCA Services any data in its

possession relating to groundwater. surface water, soil, geological or hydrogeological • conditions at the Property: and

(d) Without cost to Masonic Homes. Masonic Homes agrees to

cooperate with SCA Sen·ices in obtaining any permit, license, certificate or other

government approval that may be necessary for the performance of any activities by SCA

Services relating to the Property or the Landtill.

6. In addition to the other valuable. consideration 'agreed to by SCA

Services hereunder. SC.-\ Services shall pay the Masonic· Homes· costs. and the Parties

otherwise agree as follows:

(al Within thirty (30) days after execution of this Agreement by

both pa,rties. SCA Servi~es shall pay ~ [asonic Homes the amount of $150.000.00. which

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shall compensate Masonic Homes for (i! granting the right of access. (ii) agreeing to the

provisions described herein for establishing deed restrictions, (iii) lost crop value, (iv) lost

use o.f the Property and (v) past technical consultant and Masonic Homes· overhead costs;

(b) Upon issuance by EPA. of a ROD approving the ARP or the

key elements thereof, SCA Services shall pay Masonic Homes an additional $150,000.00

for technical consultant and Masonic Homes· overhead costs to be incurred by the Masonic

Homes· in connection with reviewing and/or overseeing those measures required under. the

ROD which may affect \'[asonic Homes or the Property:

(c) The payments pro\·ided herein shall be in addition to any

payments provided for under the Letter Agreement;

(d) ·Nothing set forth herein or in the Letter Agreement is intended

tO resolve Masonic Homes' claims. if any, on account of alleged future devaluation of the

Property on account of the imposition of deed restrictions limiting the withdrawal of

g:roundwater from the aquifer underlying the Property, and both Parties fully reserve any

claims and defenses that they may have with respect thereto; and

(e) Masonic Homes does hereby release SCA Services from any and

all costs incurred or to be incurred by Masonic Homes arising out of or relating to the

Landtill or the alternath·e water supply except as set forth in this paragraph and to the

extent provided in the Letter Agreement.

7. SCA Services agrees to split samples with Masonic Homes or its

representatives. the cost of any such split samples to be borne by Masonic Homes. and

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AR308142

provide to Masonic Homes or its representati\·es copies of all test results of any wells

installed and/or monitor~d on the Property by SCA Sen·ices within a periodic and

expeditious time frame.

8. SCA Services co\·enants not to sue Masonic Homes and its officers.

directors. employees, agents and contractors for any ci\·il claim or cause of action,

administrative or judicial, past or future. in law or equity, for claims. demands or lawsuits

arising out of or in any way related to alleged personal injuries, property damage. reduced

property values. natural resource or .em·ironmental damage, response costs or other damages

or endangerment to health. the em·ironment or property arising out of or relating to the

Landfill; provided that nothing set forth herein shall bar SCA Services from bringing any

action on account of any breach of this Agreement by Masonic Homes or othenvise arising

out of or relating to the performance of this Agreement.

9. Masonic Homes co\·enants not to sue SCA Sen·ices, its parent.

subsidiary and successor corporations and its and their officers, directors. employees. agents

and contractors with respect to any and all losses, liabilities, damages. claims. demands and

expenses (including legal fees) of \\·hate\·er kind or nature. past or future. in la\\. or equity.

arising out of or relating to (a) personal injury caused by, arising out of or relating to the

ingestion of \Vater supplied on or from the Property, (b) diminution in the value of the

Property caused by or related to the quality of the ground or surface water upon or beneath

the Property or otherwise related to the Landfill: provided that nothing set forth herein shall

bar Masonic Homes from bringing any action on account of any breach of this .-\greement

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AR308143

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• by SCA Sen·ices or otherwise arising out of or relating to the performance of this

Agreement.

10. SCA Services accepts the Property in its present condition. "as-is,"

with all latent Jnd patent defects. Masonic Homes shall have absolutely no obligation to

Grantees to keep or maintain the Property in any condition or to perform any work or

supply any se:-\·ice with respect to SCA Sen·ices or the Property except as pro\·ided in the

Letter Agreerr.ent. Not\vithstanding the foregoing. Masonic Homes shall use its best efforts

to avoid remo\·imz. destrovin!Z. damaszin!Z or otherwise interferimz \\"ith monitorinf! wells. - .,_ -- - -supply wetls. markers or equipment or devices placed in or upon the Property by the

Grantees pursuant to the performance of any response actions. Masonic Homes shall also

furnish SC.-\ Services with such descriptions as it shall have in its possession of any

• underground utility lines. underground storage tanks or other underground structures or

hazards within the portion of the Property to which Grantees are granted access under this

Agreement.

11. The use ofthe Property by SCA Services, its agents. contractor,

subcontractors vr other Juthorized representatives shall be at the sok risk. cost. and expense

of SCA Services. its agents. contractors, subcontractors or other authorized representatives:

12. SCA Services, its agents. contractors, subcontractors or other

authorized representati\·es shall maintain during this Agreement the follO\\·ing minimum

insurance cove:age naming ~1asonic Homes as an additional insured party and certificate .

holder: (a) Comprehensive General Liability. including without limitation. bodily injury and

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AR308l44

property damage. in the amount of $1.000.000 per occurrence and $2.000.000 in the • aggregate: and (b) Automobile Liability, including bodily injury and property damage. m

the amount of $1,000.000 per occurrence and in the aggregate.

13. SCA Services must also maintain workmen's compensation insurance

for the period that SCA Services, its agents. contractors. subcontractors or other authorized

representati\'es are undertaking the Performing Work and for the duration of this

Agreement. Such policies shall be issued by carriers of recognized responsibility and

licensed by the Common\\·ealth of Pennsylvania. SC\ Services· agent. contractors.

subcontractors or other authorized representati\·es shall cause Masonic Homes to be issued.

by such carriers, certificates of such insurance. which certificates shall require thirty (30)

days notice to Masonic Homes prior to any termination. expiration or change in such

policy. This Agreement in no way establishes any employer/employee relationship between • :\ fasonic Homes and SCA Services.

14. This Agreement in no way com·eys ownership of the Property to SCA

Sen·ices.

15. Nothing set forth in this A.greement shall obligate SCA Sen·ices to

carrv out or waive anv ri2:hts SCA Services mav ha\·e to challemre the ROD or anv - .. - .. - .

response actions required by EPA or other go\·errunent authorities with respect to the

Landtill.

16. To the extent not covered under the insurance policies described in

Paragraphs l2 and 13. SCA Services shall indemnify. defend. release. and hold ~vfasonic

l l 67069 2/28/97 • AR308llt5

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Homes harmless from and against any and all losses. liabilities or damages to any property

(including the Property): injuries (including death) to any person, claims. demands. and

expenses (including legal fees) of whatever kind or nature, resulting from or arising out of

the acts or omissions of SCA Services or its contractors, subcontractors. or agents on the

Property in connection with the performance of any work required pursuant to this

Agreement. except to the extent that such losses, liabilities, damages, injuries. claims.

demands or expenses result from the actions of Masonic Homes! its employees. contractors

or agents.

17. :-.rasonic Homes represents and warrants that it holds title to the

Property free of any restrictions that would affect the use of the Property in the manner set

forth herein .

18. SCA Services agrees that it will take or cause to be taken such

measures as shaH be necessary or desirable to cause alternative water supplies to be

furnished to the the downgradient residences as described in the ARP to the extent such

supplies are required by the ROD and until such time as the water quality under such

properties ·as determined by samples from wells for such residences are determined to meet

federal and state drinking water standards: provided that the property owners agree to such

deed restrictions and institutional controls as may be required by EPA.

1 9. yfasonic Homes and SCA Services reserve their rights. claims and

prh·ileges relating to: (a) proYiding access to the Property for SCA Sen·ices to perform

acti\·ities not co\·ered by the Performing Work: and (b) the need to take further action to

12 67069 2/28/97

~R308f46

pro\·ide a replacement drinking water supply for EM400 should the replacement well or

wells installed pursuant to the Letter Agreement fail to provide drinking \Vater of an

equivalent yield to EM-+00 on account of contamination emanating from the Landfill and

unrelated to the operation and maintenance of the replacement well or wells by Masonic

Homes.

20. .\fasonic Homes agrees to provide SCA Services thirty ( 30) days written

notice prior to the sale or other transfer of any interest in the Property. Masonic Homes

agrees to require as a condition of any transfer of any interest in the property that the

transferee agree that such transfer be subject to the terms and conditions of this Agreement.

21. This Agreement shall expire upon completion of the Performing Work

and restoration of the Property by SCA Services in accordance with this Agreement;

provided that Paragraphs 6(d) and (e), 8, 9 and 16 shall survive indefinitely. The terms of

this Agreement may be extended at the request of SCA ·Services and with the approval of

Masonic Homes.

.,., Any \\Titten notice required under this Agreement shall be deemed to

haYe been sufticiently given when delivered in person or by first class mail to the address

of the Parties below:

Masonic Homes:

Joseph E. Murphy Executive Director Masonic Homes One Masonic Drive Elizabethto\\-n, PA 17022-2199

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67069 2/28/97

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SCA Services:

Trevan J. Houser Remedial Projects :\fanager Waste Management. Inc. One Lincoln Crossing 400 Old Lincoln Highway Suite 100 Fairless Hills. P A 19030

Either party may change the person designated to receive notices by giving notice of such

change to the other party in the m::umer described in this paragraph.

:23. \fasonic Homes represents and warrants that the undersigned has the

authority to enter imo this Agreement, and has been so authorized by the Grand Lodge of

Free and Accepted :Yfasons of Pennsylvania .

Agreed this 28th day of February, 1997.

Masonic Homes

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By:

Name: Joseph E. Murphy

Title: Executive Director

Waste Management Disposal Services of Pennsylvania, Inc.

By: -----------------

Name:---------------

Title: _______ _

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SCA Services:

Trevan J. Houser Remedial Projects Manager Waste Management, Inc. One Lincoln Crossing 400 Old Lincoln Highway Suite 100 Fairless Hills. PA 19030

Either party may change the person designated to receive notices by givjng notice of such

change to the other party in the manner described in this paragraph.

?"' _.J. Masonic Homes represents and warrants that the undersigned has the

authority to enter into this Agreement, and has been so authorized by the Grand Lodge of

Free and Accepted Masons of Pennsylvania.

Agreed this ___ day of February, 1997.

Masonic: Homes

By: ______________ _

Name: Joseph E. Murphy

Title: Executive Director

Waste Management Disposal Services of Pennsylvania, Inc:.

Title: __ E_n_v_i_ro_n_m_e_n_t_a _1 _counse 1 ,

Waste Management, Inc.

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NOTES

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l.) (:()('fOifofATtS FOil f'IUQioi(I'[JtS .NQ WOHIT'CftN2 1IQ.U '-"'Lim 11" lJHll .....W:'t CCHSIA.lAMt'S. M:.. 1'QM. PA. DA'rt 01 ~y ~It , .. l"l.

rEil !.J ,.s1

200

WASTE MANAGEMENT, INC.

6 P'ebruary 1997

Masonic Homes One MMonic Drive: Eli7..abcthtown Pennsylvania 17022·2199

Attn: Ms. Robin P~ Director of Safety S¢rviccs

Rc: LcUc:.1 Agrecmeut to~· the

Robin:

Siting, Design. and Installation of a Replacement Water Supply Wcll(s)

Trrn1 J. HoUIU C:u")uiJ.~ (2t5):11~0

Thill lcu.cr ~o"UllJ'llw:- <.he !'ollowul! undcrstancin.p ~c:hc:d dw'ing our mc:ctin,J of 9 December 19~ , ODd during subsequent conversations, between representatives of the Masonic Homes of the It W. Grand Lodge F.&. A.M. of Pennsyl\'ClDia ('Masonic Homes"} ana Waste Management Disposal Services of Pennsylvania. Inc. f'WMDSPJ), n:ganlin~ the ~liug. design. and installation of a replacement wcJl or welts o! equh':lleat :l';eJcl to

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EM:400 at the Masonic Homes property Ioeateci in Ell.7.abcthtown Borough ana West Donegal Township. • Pennsylvania. This ldtcr supersedes ana renders null ana void my letter dated 17 January 1996 addressed to you c:cnccming the same subject matter.

1. Subject to the provisions contained herein. WMDSPI agrees to pay for costs of the desi~:,rn and 1nsta11atton of a rt'p.lacemem drinJdng water well or wclb ur cqu.i valent yield to nM400.

2. Masonic Homes will lm'C its consultant. GcoServices. Inc. ("GcoServices~) prepare a proposal 1.0 Sltc. <1eSlgn, and install a repJacemcru: drinking water wc:ll ur well:. v! cquh·alcnt yiclcl to 1!.~400, includin' (l) a. det3iled cost breakdown and (2) a proposed contract to perform the work.

3. Masomc l:iomes will submit the proposal tD VY'MDSPI fu1 ib u:"iew and approval 1\3 part of 'WMDSPrs review of the proposal. WMDSPI and its consultant may consult directly with GcoSe.Mces.

4. Upon WMDSPl·s approval of the propo501i. Masonic Iiomes will c.xc~o:ub:: tW: ~nu·aa with GeoServiccs in a form acceptable to both Masonic Homes and WMDSPt WMDSPI will noc have any responsibility for the performance of the work

S. Final well location. design and the need. if any. for more than one ( 1) well to achieve equivalent yield to EM400 will be as mutDally acc~le to WMDSPI and Masonic Homes through consultations between GeoSctvices and WMDSPrs consu.Itant.

6. WMDSPI will pay the a)sts for confonning work wtdu the conttact upon reeeipt of GeoScro.ices invoices.

7. GeoSeniccs shall provide both Masonic Homes and W'MDSPI \lith monthly progress reportS concerning the work perf~ 1lilder the controct

AR308151

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8. OccServi=s lliU pte~>ide both Masonic: Homes and WMDSPI with any data ge:ncrax:c1 in conn=.iuu wi!h work pelformcct undtr the ~ct.

'The ~ qrccmcm ia withcut prejudice to 'm'f au- imJeS outstaJidinc between Masonic Romes a.cd WMDSPL md both pnties agree to continue toWard resobing these issues as e:cped.iliously as possible. If such =gotiations =a be sua:es5fully ccacluded, eithct party retains the right to temrinam the aboYe <lgttetnent provttlcc1 tba1 any WS1.5 ~by c-scmcos ~ the co=xt to that date will be paid. by WMDSPL

WMJJSl'! Is plc:aal lhlt m a~ has "'-' reacW ~Cpzdiz!~ thi~ i!WIC with the Masonic: Homes. We look £onvard to ccmilmed =sotiatious regardinc other issues mel eventually to a successftl1 ccmplcticn of \he entire rc:mcdia1 project at the~ Supediuld Si!e.

To ~ tbis ag:reetM!Il. please sign below and retum an origiaal to t'I1Y ltliiZ!tioa. 1'hanlc you.

MASONICROMES aCdre llW. GlWiD LODGE 11'. & A.M. of'PENNSl'I.VANJA:

==rt~~ Data:

c: Stephen !Gyl::o Anl1y LcYi.ol:, ~-Bn~~:e ~ Esq. 11onalban. Sp:::gel. Esq. Fuc: f03.0ID7

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August 1996 , 1~ 923-6053 ~;;;o.=::.:..:,~;__---------~~'--~-~-~-_________ __.,..;::;.:::_:;,;:;.:;.;;_ 1.0 INTRODUCTION

1.1 General

Golder Associates Inc. (Golder Associates) was retained by SCA Services of Pennsylvania, Inc. (SCA) to evaluate ~ and transport aspects of groundwater constituents at the Elizabethto'Ml Landfill (Site), Elizabetbto\\11, Pennsylvania. The objective of this study was to evaluate whether or not the leachate constiruents in the bedrock groundwater at the Site are in steady state conditions. Steady sta:te conditions would occur when the mass of leachate constituents dissolved into groundwater would equal the mass of constituents treated through natural attenuation processes.

This study was based largely on the results of the "Revised Final Remedial Investigation Report" produced by Golder Associates, May 1994 (RI Report) and on the "Final Feasibility Study Report" produced by Golder Associates, February 1995 (FS Report), including the pwnping test results and concq>tual solute transport modeling conducted by RUST Environment and In:fra.structure (RUST) as part of the FS (see Appendix D of the FS Report).

Section 1.2 of this Attachment includes a summary of the Site background data including an outline of the conceptual Site model, and Section 1.3 describes the approach used for the study objective. Section 2 describes the analytical solute transport modeling, including an outline of the mathematical model (Section 2.1) and parameter selection (Section 2.2). Section 3 presents a summary of the model results, a comparison with observed data and the conclusions based on the results of this study. A list of references is provided at the end of the text.

1.2 Site Background Data

The Elizabethtown Landfill is a 16-acre tacility situated· on the northwestern flank of a hill that slopes from West Ridge Road down to Canoy Creek. The facility is locitted on the site of a former quarry that was active during the 1950's and 1960's. The landfill operations started in early 1961 with the excavated areas from the quarrying activities serving as the original refuse placement areas. During its history, the landfill was operated by several owners. The f.lcility was closed in July 1973. A more detailed account of historical activities at the Site is presented in Section 2.3 of the RI Report.

The Elizabethtown Landfill ~ located within the Triassic Lowlands seCtion of the Piedmont Physiographic Province in eastern Pennsylvania. Geologically, the Site is situated within the Newark-Gettysburg basin, a regional northeast-southwest trending rift graben of Triassic age. The uppermost geologic unit beneath the Site is comprised of alternating gray to tan sandstones and conglomerates and red-brown siltstones of the New Oxford Formation. Locally, these strata strike approximately southwest to northeast and dip at an angle of approximately 22° to the northwest.

Groundwater is recharged to the aquifer by infiltration of precipitation in the upland areas and discharges ·to the local streams. Groundwater flows from the recharge area (West Ridge Road) northwestward toward Canoy Creek. Data collected during the RI field investigation indicated that , the groundwater flow is downward in the upland areas, predominantly horizontal or subhorizontal in most of the area beneath the landfill and upward where it discharges to local streams. Depth to groundwater in the Site vicinity ranges from approximately 4 feet below ground sutfllcc (bgs) at the northwestern end of the Site to approximately 2S feet bgs in the upland area at the Site entrance on West. Ridge Road. A more detailed discussion of the geologic and hydrogeologic conditions at the Site is presented in Sections 3.4 and 3.5 of the RI Report.

AU2Ust 1996 -2- 923-6053

Volatile organic compounds (VOCs) and semivolatile organic compounds (SVOCs), have been • detected in the groundwater and are shown to be migrating off-property based on the Rl results. Except for a few isolated occurrences, metals concentrations were below the maximum contaminant levels (MCLs) in both upgradient and downgradient locations. The most prevalent VOCs detected in downgradient wells at the Site were chlorobenzcne, benzene, vinyl chloride, and 1, 1-dichloroethcne (refer to Figure 3-27 of the Rl Report). SVOCs were far less prevalent than VOCs in groundwater samples at the Site and were reported sporadically with the most prevalent being bis(2-chloroethyl}ethcr.

Two groundwater impact areas were identified during the RI. The southern groundwater impact area appears to have originated in the vicinity of the fanner sand and gravel pit The northern groundwater impact area appears to have originatM in the vicinity of the northern limit of the landfill. Chlorobenzene was used to delineate the extent of the groundwater impact areas because it is the most common constituent detected in groundwater at the Site and occurs at higher concentrations. Other compounds (i.e., vinyl chloride) that were of concern for potential future groundwater use risk are within the area delineated by the extent of chlorobenzcne.

1.3 Approach

In the Revised Risk Assessment conducted by USEP A, the only human health risk associated with the Site was potential future use of impacted groundwater. The Alternative Remedial Plan includes as the main goal the elimination of risk associated with potential future groundwater use. This approach requires an understanding of the future extent of the impacted groundwater. Since. the lapdfilling activities started in the early 1960's and ceased in 1973, it was suspected that the • current constituent concentrations and the extent of groundWater impact had reached steady state conditions. To address this issue, an analytical solute transport model was used to evaluate whether or not the leachate constituents occurring in groundwater at the Site are in steady state conditions. ·

The analytical model selected for this evaluation is presented in "Quantitative Hydrogeology" prepared by de Marsily (1986). Two solutions of the one-dimensional advection-dispersion equation for groundwater flow and solute transport were developed for the following conditions:

1. Advective-dispersive transport with constituent retardation due to adforption; and,

2. Advective-dispersive transport with constituent retardation and contaminant exponential decay.

These solutions (models) were used to predict both the long-term steady-state and transient groundwater constituent concentrations at the Elizabethtown Landfill.

The first solution did not account for degradation of constituents over time (the solution did not inclu~ the exponential decay term). In this situation, the predicted groundwater impact area and constituent concentrations represented an extreme worst case in which the total mass of a constituent in the groundwater was continuously increasing. The continuous mass increase was the result of an assumed continuous constituent release from the 1andfi11 combined with no degradation of the constituent over time. This solution was used for comparison to Site specific data to evaluate whether natural attenuation is occurring.· This solution indicated that natural attenuation was occurring. Therefore, the decay term was added and used in the second modeling.

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The second solution accounted for the degradation of the coilstituents by natural attenuation (the organic constituents can degrade due to natural chemical and biological processes). The parameter used to estimate the tate of degradation was the half-life time (i.e., the amount of tiine it takes for the concentration of a compound to decrease by one-half due to degradation processes). The second solution appropriately accounted for both constituents released into the groundwater (mass increase) and collStitqents. treated through natural attenuation processes (mass decrease). Steady state conditions occur when the mass of leachate constituents dissolved into ground\\--ater equals the mass treated through natural attenuation processes.

Both of these solutions were compared against concentrations measured in ground,..-ater during the RI for indicator constituents such as: chlorobenzene, vinyl chloride, 1,1-dichloroe:thene, bis(2-chloroethyl)ether, and benzene. These are the main constituents of concern for potential future groundwater use risk (see Table 1). The comparison used the highest detected values for each compound, which was a conservative approach, as not all areas of the Site contain all of these compounds. Since the half-life time estimates are available in literature as ranges of values, a calibrated value was selected based on the range. In addition, a source strength (concentration) was also estimated (Table I) using an iterative process based on comparison between measured and simulated concentrations. The model was then used to predict potential future changes in the area of impacted groundwater measured as distance from the landfill for 50 years and 100 years travel time, respectively .

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2.0 ANALYTICAL SOLUTE TRANSPORT MODELING

2.1 Mathematical Model

Following de Marsily (1986), a one-dimensional·case was chosen to model the displacement of a constituent (C) in a semi-infinite medium given the following initial and bounda!y conditions:

C(x) = 0, C(O) =Co.

x> 0, t=O t> 0

The governing equation is therefore:

where: C = concentration; t = time; x = distance; U = the groundwater velocity and constant for one-dimensional flow; D = the dispersion coefficient and constant (only longitudinal dispersion); a. ""' the water content; and, R = the retardation tactor of the constituent due to adsorption.

The solution to equation ( 1) is:

(1)

C(x t) = C, [erfic(x -(U I aJR)t )+ (Ux)erfc(x + (U I OJR)t )] (2) ' 2 z.J Dt I aJR exp D ·z.J Dt I OJR.

where: erfc= the complementary error function.

The solution given in equation (2) is shown in graphic fonnat as Figure 2.1 of de Marsily (1986) for the dimensionless parameters,

; = Ut/a.Rx. C/Co 11=D/Ux

on the horizontal a.-,Qs, a dimensionless distance; on the vertical axis, a dimensionless concenttation ratio; and, curve parameter.

These characteristic "breakthrough" curves are used to predict the constituent concentrations at various distances (i.e. travel times) away from the source.

If decay (degradation) is added, the governing equation is:

&c ec ec D--U-=(I}R(-+AC)

tJx2 ax at (3)

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Ausrost 1996 -5-

where: A. = the coefficient of exponential decay; and. R =- the retardation £actor, as before.

Here, A. was determined from:

A. /2 = A. exp( -kt)

where: k = the half-life decay constant.

923-6053

The ba.lf-life decay constant (k) was obtained from literature for a given constituent. The. solution to equation (3) is:

C(x, t) = Co exp( Ur ){exp(-Bx)eifc[X'- t~(U I OJR)2 + 4AD I mR)] 2 2D 2~ Dt I CJJR.

<B )erfi [r + t.j(U I OJR)2 + 4).[) I (J)R) ]}

+exp x c ~ 2 Dt I aJR

(4)

where:

B = ~(U I 2D)2 +(AolR./ D)

2.2 Parameter Selection

The solute transport model input parameters were: hydraulic conductivity, transmissivity, aquifer thickness, hydraulic gradients, distribution coefficient, retardation factor, porosity, bulk density, dispersivity, and half-life time. The rationale for selecting parameter values used in the solute transport model is described in the following paragraphs.

Hydraulic Conductivity and Transmissivity

The hydrogeologic tests performed at the Site included packer tests, slug tests (see RI Report) and a constant rate pumping test (see FS Report). The calculation of the average hydraulic conductivity for each tested corehole using packer test results indicated values ranging from l.Sxl0-4 cm/s to 5.7x10-4 cm/s with an average of 3.8x10,. cmls. The average hydraulic conductivity of the pumping test was 2.5xl 0,. c:m/s based on an average transmissivity of 181 fflday and an aquifer thickness of 245 feet.· The average hydraulic conductivity of the aquifer used in the model was the average of packer tests and the pumping test (3.2xl0-4 cmls; 0.9 ft./day). The hydraulic conductivity from the packer test results was considered to be in very good agreement with the results of the pumping test. In addition, the average hydraulic conductivities calculated for the coreholes at the Site vary within a D3ITOW range. This indicated a relatively unifonn hydraulic conductivity for the interlaycn:d sandstone/siltstone geologic sequence across the Site area..

Hydraulic Gradients

The average horizontal hydraulic gradient (I) perpendicular to the strike of geologic strata (main direction of the groundwater tlow) was 4xl0"2 ftlft (see Section 3.5.2.4 of the Rl Report). The main direction of the groun~ flow in the vicinity of the landfill area is towards the ,northwest.

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Closer to Canoy Creek the flow direction changes gradually to the west. Along this westerly direction the hydraulic gradient is expected to be lower (5x10"3 ftlft to 2.5x10.z ftlft; see Table 3-5 • in the Rl Report}. However, the higher gradient was used (4xlo-z ft/ft) to aceount for the potential effects of pumping from the Masonic Homes 500 foot well and represented a more conservative estimate.

Distribution Coefficient

The linear sorption isothenn assumes that the sorbed concentration (C,) is directly proportional to the dissolved phase concentration:

C, = K.tC

where K.t is the distribution coefficient. The distribution coefficient <Kci) was calculated using the published organic carbon partitioning coefficient <Koc) and an assumed fraction of organic carbon (~) as follows:

Table l presents a summary of these parameters. An individual retaidation filctor was calculated for each compound included in this analysis. The retardation filctor was calculated using the retardation equation (Freeze and Cherry, 1989, p. 404):

where:

R = 1 + K.t Pb /n

R = Retardation factor; n = Porosity of the rock mass; this was estimated at 10 Percent (see Table 3-S and

Appendix L of the RI Report); and Pb = Bulk density; the bulk density was estimated at 2.5 g/cm3 (157lbsl~). (Marshall

et al., 1988)

The individual retardation filctors calculated for each compound range from 1.03 to 1.91. This range of values is consistent· with the retardation £actor estimated in the RI, Report. The average retardation factor for chloroben.zcne was estimated to be 1.8 (see Table 3·5, Section 4.4, and Appendix L in the RI Report). This estimate was verified by caJodaring the overall chlorobenzene travel distance (Section 4.4.3 in the: RI Report). The results of. the calculation indicated an average K.t value of3xlo·z cm3/g, which is consistent with the calculated I<.. value: shown in Table 1.

Longitudinal Dispersivity

In general, it can be estimated that the: longitudinal dispersivity (ar.) is about 10 percent of the mean travel distance (EPA, 1985, pp. 366). The historic travel dista.nce of the organic constituents is about 2,000 feet for each groundwater impacted ma {see Table 4-S in the RI Report). Therefore, the longitudinal dispersivity was estimated to be 200 feet.

Half-Life Time

Organic constituents in groundwater degrade due: to natural chemical and biological processes. The half-life (t 1n) of a compound represents the time required for the concentration to decrease to

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one-half of the original value. Table 1 presents the ranges of half life times for the compounds considered in this analysis. The half-life was used to calculated the parameter A. (A.= (In 2)/ t 11:z) [time"1

]. This parameter represents the rate of mass treated for both the dissolved phase and sorbed phase.

Travel1imes

The landfill operations initially started in early 1961 in the fanner quarry. Thus the nwdmum estimated travel time of leacbate constituents from the southern area of the landfill up to the 1992 groundwater sampling events ( 1~ 1B and 1 C) is approximately 30 years. The landfill operations ceased in 1973, so the travel time of leachate constituents from the northern area of the landfill is about 25 years (sec Section 4.4.3 of the Rl Report). To simplify the solute transport modeling results a travel time of 27.5 years was used to compare the measured concentrations versus the simulated concentrations.

Travel Distances

Estimates of travel distances were used in the comparison of measured versus simulated concentrations. Travel distances were measured from the general area of the former quarry and fi:om the northern landfill area as indicated in Figure 4-5 of the RI RePort .

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3.0 RESULTS

The parameters used ·ror this analysis included: chlorobenzene, vinyl chloride, 1,1-dichloroethene, bis(2-chloroethyl)ether, and benzene. Using the approach outlined in Section 1.3 the following steps were performed:

• Plotted maximum constituent concentration detected in monitoring wells during Phase lA, lB and lC of the RI sampling events versus distance from the landfill to the well with that detected concentration. Only the wells with high constituent concentrations were used in order to account for maximum concentration along the groundwater impact areas.

• Calculated constituent concentration versus distance using the average parameters presented in Section 2.2 for an average travel time of 27.5 years (constituent conditions at the time of the RI).

• Adjusted the half-life timC estimate and initial constituent concentration (source strength) to match the measured constituent concentrations (see Table 1 and Figures l to 5).

• Using the "calibrated" half-life time and initial constituent concentration, perfonned additional simulations using compound degradation and 50-year and 1 00-year travel time!, respectively. The results of these simulations are presented on Figures 6 and 7 for chloroben.zene, Figures 8 and 9 for vinyl chloride, Figures 10 and 11 for 1,1-dichloroethene, Figures 12 and 13 for bis(2-chloroethyl)ether, and Figures 14 and 15 for benzene.

The lower curves (with natural attenuation) on Figures 1 to S indicate a. good match of measured versus simulated concentrations when constituent degradation was included. This comparison indicates that the model represented current {at the time of the Rl) conditions. The upper curves (without natural attenuation) on Figures 1 to 5 show that when assuming no degradation the simulated constituent concentrations were much higher than the measured concentrations in groundwater. This comparison to Site specific data indicated that natural attenuation is occurring and that predicting future groundwater conditions without considering constituent degradation by natural attenuation would be inappropriate.

The model with constituent degradation was also used to predict potential future changes in the area of impacted groundwater for SO-year and 100-ycar time frames (Figures 6 through IS). For reference, the Masonic Home wells were plotted on all the figures at a distance measured from the center of the landfill along the interpreted groundwater Bow direction. The predictions indicated that the impacted groundwater is in steady state conditions. These predictions also indicated that the constituents will not impact the Masonic Home wells (well 400 and well 500) within the modeled time frame. As shown on the figures, the predicted distance at which MCLs are attained is essentially the same for a given compound for time increments of 27.5, SO and 100 years (i.e., the impacted area is at steady state) with a constant source loading. For the constituents modeled, this distance is between about 500 and 1,200 feet from the landfill. This is considerably less than the distance to the Masonic Homes wells. As expected, relatively mobile constituents, such as benzene and vinyl chloride, with a small retardation factor (R) and a longer half-life, extend the furthest. These constituents also have the lowest MCLs. Thus, they represent worst case examples. Since the source loading is expected to diminish with time due to implementation of enhan~ source control measures, lower concemrarions within the impacted area arc expected in the future.

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REFERENCES

Freeze., A.R. and J.A. Cherry. Groundwater, Prentice Hall, Englewood Cliffs, New Jersey 604 pp., 1979.

de Marsily, Quantitative Hvdrogeology, Academic Press, Inc., 1986.

Golder Associates Inc., "Final Rcpo~ Phase II Hydrogeological Investigation. Elizabethtown Landfill/' 1989.

Golder Associates Inc., "Remedial Investigation/Feasibility Study, Revised Final Remedial Investigation Repo~ Elizabethtown Landfill," 1994.

Johnston. H.E., ''Hydrogeology of the New Oxford Formation in Lancaster County, Pennsylvania," Water Resource Repo~ Bulletin W23, Pennsylvania Bureau of Topographic and Geologic Survey, 1966.

Mackay, Donald, Wan Y'mg Shiu and Kue Ching Ma. lllustrated Handbook of PhvsicabChemical Prnpsrties and Environmental Fate for Organic Chemicals. Volume 1, Lewis Publishers, Boca Raton, 1992.

Marshall, T.J. and J.W. Holmes. Soil Phvsics. Cambridge University Press, Cambridge, Great Britain, Second Edition, 1~88. ·

U.S. Environmental Protection Agency, "W~r Quality Assessment: A Screening Procedure for Toxic and Conventional Pollutants in Surface and Groundwater, Part II," 1985 .

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Table1 Summary of Solute Transport P._r .. melers

Compound Organic Carl>on Fractional Di&lribution Retardation Factor Partitioning Coolficlent Organic Camon Coefficient

l<oc: foe ~= l<oc: foe R = 1+~ r11 In (mUg) r •. -"· -··

Chlorobenzene 330 0.0001 0.033 1.83 V10yl Chloride 57 0.0001 0.006 1.14 1 , 1-Dichloroothene 65 0.0001 0.007 1.16 Bis(2-chloroothyl)edler 13.9 0.0001 0.001 1.03 Benzene 65 0.0001 0.006 1.15 1, 2-0ichloroothane H 0.0001 0.001 1.04 T etrachboethene 36-4 0.0001 0.036 . 1.91 T richloroolhene 126 0.0001 0.013 1.32 1 2-0ichloroethene 59 0.0001 0.006 1.15

1 '1-0ichlor~~ 30 0.0001 0.003 1.08 --------------

Note: all J<oc vaJuM from EMzabethtaNn Landf• Rl Report, except for 1,1-0ichloroolheoe and vinyl chloride liOUI'ce for 1,1-0ictlloroe~ and vinyl chloride"' Supedund Public Health Manual, USEPA, 1966

B!Jk Density (r ~o) • Poroaoity (n) =

2.5 0.1

(glcm~)

Hal-Life

tta(mlnlmax) (days)

3Q0.60()

56-2850 56-132 56-360 10-720

100-360

-320-1620 56-2850 64-ts.t

Note: • =parameter not evaluated bocauae calculated cancer and non-cancer risks were within USEPA acceptable limita.

z:\projects\923-ro53\revplan\TAB1ATI.XlS Gokltr Auo,clatn

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923-6053

Caocer Non-Cance· MCL Calibrated Calibrated Risk Risk Half-Life lrn.liaJ

t1/2 Concentration (ppb) (days) rppbJ

- 3.2 100 600 2000 2x10"~ - 2 200 30 2x10"~ - 7 132 100 1x10"~ - NA 360 80 7x10 .. - 5 720 80 6lC10 .. 0.1 5 • . 2x1o·• 0.2 5 • • 2x10 .. 5 • •

- 0.1 70 • • - '- ().1 ____ fo.IA • •

.1of1

~ ~ ~ d ~ ~ "0

~ >

.....

0 0 ~ ~~

1\):rJr­....,>O . -1:0 01_ -<oo !:!zm :o<Z en, fit

oz Ciim ;! z 0 m

•

~ <&>

1.:> 0 I. Co ~J:) ~,.P

••

Chlorobenzene 1-D Advection/Dispersion with Reaction Terms

R=1.8, t112=600 days, T=27.5 yrs

2~.-~~=---------------------------------------------------------~

1800

1600

1400 ::0 a. a 1200

15 11000 I 800 0

600

.coo

200

Upper Curve :; C(x,l) for R only (without natural attenuation)

lower Curve = C(x,t) for R and t112 0 \ (with natural attenuallon)

E0\02R

WELL 600

0eD-24

-~""""' --1------·-------·-------1- MCL

0~--------~====------------~--------~~=L--------------~ 0 1000 2000 3000 4000 5000 6000

Distance from Source (It)

0 fT1 I c 0 ~i z

0 m ~< ~·

a ~~~ ~

.> ~ 0.-1 -~ -<00 CP

.,.=>

::0 ~ z ::1: t?

-o < r ·'b

~ !4g ·~~J.

> CJJ -cc mm . II -1

> z I\) I 0 m

VInyl Chloride 1-0 Advection/Dispersion with Reaction Terms

R=1.14, t112=500 days, T=27.5 yrs

30r-------~~~~---------------------------------------------;

25

:a' 20 a. .s c 0

i 15

3 c 0 0 10

5

. Upp,er Curve = C(x,l) for R only (wllhout natural allenuallon)

lower Curve = C(x,t) tor R and t112 (with natural allenuallon)

WELL400

1-----~::------------1 -----~--- =:,........: I MCL 0 I a:;u-;: .. 0 ~ 1 I

1 I

1 ===-=-===!

0 1000 2000 3000 4000 5000 6000

Distance from Source (ft)

100

90

80

.70 :a' a..

~ 0 i .., ~ ~ fi 50

m o • ~ ~!: ~ s •• -1 -10 Cl' 30 0 1\) :0- r=> ~ :..a> 5! 0 20

' 01::!r ~ > -< 0 0 :J' 10

::o m z:n ~ > 0 0 -o :0 ~ ~ ED-101 0

> cn· c

II ~~ z

(A)I 0 m

1,1-Dichloroethene 1-D Advection/Dispersion with Reaction Terms

R::;1.15, 1112::;132 days, T=27.5 yrs

Upper Curve = C(x,t) for R only (without natural allenuallon)

lower Curve = C(x,t) for R and 1112 (wilh natural auenuallon)

WELL 400

OED-23

2000 3000 4000

Distance from Source (ft)

•

5000 6000

'''" l,JI)

0 ~ Om ~ za; o-m ~b ~ ..., :X d "'"-~>r ~~ Cn::l~

oo ~ ~z~ :::u >< -o lJ m ' en· -o c

>II ~~ z!lJ

~I ~

~ (;I)

., 1:-l~"' .--Q '::~, ,,.

Bls(2~chloroethyl)ether

1·0 Advection/Dispersion with Reaction Terms

R=1.03, t112=360 days, T=27.5 yrs

80r---------=;==~-----------------------------------------------.

70

60

:a" !50 a I .. o ft 8 30

20

10

·.

Lower Curve = C(x,t) for R and t112 ED-120 (wllh natural allenuallon)

Upper Curve = C(x,l) for R only (wllhoul nalural allenuallon)

WELL400

0eD-24

5000

I I ==tMCL I ~ I I 0 .......:::: I 6000 2000 0 1000 3000 .cooo

Distance from Source (ftl

R308166

I (:! 0 0

~ z 0 I m !2 ~ -1 I a 1\) :u

~ -...l>m ....... . -em •(!::: oa_z tC:. ~ -<ON f;-::u mZm c,· '1J ><Z ~ iJ- :om m 'o, > CD~ -en

II -1 > z

011 0 m I

80

70

60

:a 50 S· c 0 ;I 40 i • u ~ 30 0

20

10

0

AR30

• Benzene

1-D Advection/Dispersion with Reaction Terms

R=1.16, t112=720 days, T=27.5 yrs

lower Curve = C(x,t) for R (with natural allenualion)

Upper Curve = C(x,t) for R only (wilhoul nalural allenuallon)

WELL 400

I =:.....-:;,:- -. ·---·--·1 ·---·--·--·--·-·· . I

0 1000 2000 3000 4000

Distance from Source [ft)

•

5000 6000

:ii'

2000

1600

1600

1400

11 .s 1200

~ o I t 1000 !);! ~ §ooo m o 8

5! !l! 0 I

600

d-1 :0 X 400

01 r • ~ o~O 200

j;- -< 6~ -~ :::0 m z m v· 0 "'0 > m r=> '-.. :o<Z ,?

"'0 cntnm ,.,.,.:. > . ·~ c (11

II ~m z

0>1 0 m

0

AR3081.o8

Chlorobenzene 1-D Advection/Dispersion with Reaction Terms

R=1.8, 1112=600 days, T=50 yrs

.

C(x,t) for R and 1112 . (wUh nalural altenuaUon)

WElL400 WEll600

·-· ----- --- --·------- MCl

1000 2000 3000 4000 5000 6000

D'lstance from Source (ft)

•

~ 0

~ 0 z

m 0

~ !l!o ! g~§l "$?-'", ..

,·.~·

~ -(001 r :l

-o !:zm .: ··~

-:n- :0 < ~ _,

~,f.> .~,

l> CD~ N &:;<"'

Q~

II ~ 111

2!

""I 0 m

2000

1800

1600

1400 :ii' Q. .a 1200 c 0 1 1000

8 c 800 0 0

600

400

200

0

Chlorobenzene 1-D Advection/Dispersion with Reaction Terms

R=1.8, t112=600 days, T=100 yrs

C(x,t) for R and t112

(with natural allenuatlon)

WELL 400 WELL 600

I ~ ·--------1 --------·----------1-·-------------------1 MCL

0 1000 2000 3000 4000 5000 6000

Dlsta.nce from Source (It}

·~

.. -:;

(:! 0

~ 0 z

m 0·

~· 9!< ~· ~-· 0 01>~ ~ 0-1 -;' ~ -<oo 'Ci:· ;o ~zx ,· .. 'll r . ........... :o< (..~ ~ CDS'~ ;~

cc c.am -t > z

m1 0 m .I

VInyl Chloride 1-0 Advection/Dispersion with Reaction T arms

R=1.14, t112=500 days, T=50 yrs

~ r-----------------------------------------------------------------~~

25

no 20 a. a fi i 15

ft c a 0 10

5

0 0

C(x,t) far R and t1n (with natural attenuation)

1000 2000

WELL 400

3000

Distance from Source (ft}

WELL 500

·~ MCL

4000 5000 6000

AR308l70

• • • ~ 2 ~I ~ ' ... ~ l!l ~I "

I '\\ ~ J! ~ :a 1:1\ .....

21 0 e . VInyl Chloride

p. 1-0 Advection/Dispersion with Reaction Terms

; i a ~ s R=1.14, t1,2=500 days, T=100 yrs I , ~ 30

• 251\ ~

, 8 ~" >

' i 0 "(;;- z

2 .., .... ~ ~ ~ m

:o' 20 D. B . c 0

~ 0 g 15 c

0 3 ~ z c

0

0 0 10 C(x,t) for Rand lu2 m

~< ~ (wilh natural altenualion) -1-

5 WELL400 WELL600 -d ~:u~ 0 O> ~ 0-1 -e

'--- ·--· ··--·-. -------------· ---·---·--------- ---- ---·- MCL - ccP ");- -(00 0 mz:::c r.:l 0 1000 2000 3000 4000 5000 6000 :::0 ><' (/

~ ~ Dlalance from Source (h)

i:t :o.o L~ t/J• ;g > cc

I mm -1 > . z

co 0 m

I

a , ·~ I '\.1 I I

100

90

80

70 ~ a. .e 60 c 0

i 50

§ 40 0 0

301

20 I

10 I

0 l

0

I:! 0 0

~ z m n .... ~ ~~ a :oo ~ g:>:c ~ ::!r CP , -<oo 1:.:> )>. mz:o o :o > o m. "0 :u < !!) 'Ba ' UJtD "0 • > c:C

(ij~ II ~m

z ol 0 m

I • ~R30J3l72

1,1-Dichloroethene 1-D Advection/Dispersion with Reaction Terms

R=1.15, 1112=132 days, T=50 yrs

C(x,t) for R and l112 (with natural altenuallon)

1000 2000

WELL 400 _I

I 3000

Distance from Source (ft)

·•·

WELL 500

-I-4000

·-----,MCL

5000 6000

·'

1:! ~ m

~ d ~

~ ~ )>

.­_..

iii,

0 0 z

§~ .... :u-• o>o 0-tl:: -· ~ -(00 C§l mz:o > 0 . (.-!)

:D<m o CJ) P' -1 ~

o:t '§.

m91 ~m z 0 m

100

90

80

.10

i .a 60

f5 1 5o c J .co

30

20

10

0

•

1, 1·Dichloroethene 1-D Advection/Dispersion with Reaction Terms

R==1.15, 1112=132 days, T=100 yrs

C(x,t) for R and lu2 (wUh natural attenuation)

WELL .COO WELL 600

•

t { -~·

~ -~----·-------~------------·-----·--1 MCL

I I .

0 1000 2000 3000 4000 5000 6000 Distance from Source (II)

'-· ,j ;

'1

!:! 8ml ~ z-m ocn ~ ~~. d :oX ~ 01> ....

0::!~ ");- -< 0 0

;o ~z~ "0 :0 < ir en~~» > c

II ~~ ..... , ~!D 1\) m

.I

80

70

60

I 50 &:: 0 -i .. 0

ft fi 30 0

20

10

~ ClJ

i:J 0

0 , 'lQ .g,

Bls(2-chloroethyl)ether 1-D Advection/Dispersion with Reaction Terms

R=1.03, 1112=360 days, T=50 yrs

C(x,t) for R and tu2 · (wllh nalural auenuallon)

WELL 400 WELL 600

0 b::=:=:=~=:~~~====~========:±==========~==jt====:::========::MCL

3000 2000 1000 -iOOO 5000 6000

Distance from Source (ft]

AR308174

• ~ 1 a1 il ~ ~ ~I ~1 t

:i!le :a ! ~ e

jl ~I ~I E

~ 8m ~ za; m 0~

~ ~b d ..AiJ::J: :;; O>r-2 O-tO ...... -:u > -coo ::o mzm -u ><-1 ~ :u,~ > mcc

II ~~ ..&.I ~:o cu m

80

70

60

i 50 a fi ::1 <10

fi g 30 0 0

20

10

~ 0

t?o -& L.P., c;..

•

Bls(2-chloroethyl)ether 1-0 Advection/Dispersion with Reaction Terms

R=1.03, t112=360 days, T=100 yrs

C(x,t) for R and t112 (wilh natural allenualion)

WELL400 WELL500

•

I :: -= I I I I ~ MCL 0 1000 2000 3000 4000 5000 6000

Distance from Source (ft]

80

70

60

i 50 a c 0

~ 0 I 1 40 t:

~ -~ 3 5 30 m 0: 0

~ ~ I 20

~ il a 01>m 10 ~ 0::1~ ~

~ -<o~ cg-., 0 ;u mz ,:-!>

0 "'D ><Z 0

~ :n"' m ·:h. CIJ· ·~->. c -CD

II -1 > z

tl f.l_l AR3U8176.

Benzene 1-0 Advection/Dispersion with Reaction Terms

R=1.16, t112=720 days, T=50 yrs

C(x,t) for R and t112 (with natural allenuallon)

WEll400 WEll500

- 1----------1·----·----·---------1 MCL

1000 2000 3,000 4000 5000 6000

Dlslance from Source [ft)

., '

• • • ~ ilfa -------

~ ~

Gl ~ ~ 1. ' :$

:i! ~ :D .... cs 01

0 e . Benzene

1-D Advection/Dispersion with Reaction Terms i ~ ~ s I ,. R=1.16, t112=720 days, T=100 yrs

80

-o

~ 70

8 l; z 'r ~ til ~ 60

CJ)

i 50 .a .. c 0

~ .o I 40 0

~ z II u

0 5 30 m 0 C(x,t) for R and t112

! ~ ~ (wilh natural allenualion)

-f 20

a ..a.:O WELL400 WEll500

~ O>m ").-,.. 10 O-tm c;. .......... -(QZ 6> . --~- ... -·--·------··----- ---·---·--·----- --------·-·-- --------- MCL )> I .:) 0 ::0 mz~ (?

0 1000 2000 3000 4000 5000 6000 "ll ><z --:5

' :O.cn m ';·_~, Distance from Source (ft) 'll CD· ,-p )> c -en i -f .

> z ...&. 0 01 m

AR308177

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~ WASTE MANAGEMENT, INC . Remedial Projects Department

A WMX Tecnnololia Company One lJJic:oln Crouinc 440 Old Unc:oln Hwy. S..ita 100 Fairieta Hllls. PA 19030

21 August 1996

U.S. Environmental Protection Agency Region ill Hazardous Waste Management Division 841 Chestnut Building Philadelphia Pennsylvania 19107

Attn: Mr. Frank Klanchar (3HW22) Remedial Project Manager

TrennJ.Houaer Pltonr. (ll!) !69-U~9 Fas: (l1!) l69·UJO

Re: Elizabetht0'\\11 Landfill Superfund Site Docket No. ill-90-44-DC Alternative Remedial Plan (ARP)

Mr. Klanchar:

WMX

Via Federal E:tpress 227~159801

Attached pi~ find three (3) copies of the document entitled "Alternative Remedial Plan" prepared for the Elizabethtown Landfill Superfund Site (Site). This ARP evaluates an alternate remedy to that chosen by the Agency in the Proposed Remedial Action Pian (PRAP) dated 26 July 1995. The Plan has been developed with consideration of the interests of the many of the site Stakeholders. The Stakeholders who have provided input to the ARP include various Potentially Responsible Parties (PRPs), the Masonic Homes, Elizabethtown Borough. West Donegal Township, and adjacent property owners.

The ARP is the result of significant effort put forth toward promoting the goals of the Agency's Superfund Administtative Reforms initiative. .The Plan proposes an alternate remedy which is protective of human health and the environment. compliant with Applicable or Relevant and Appropriate Requirements (AR.ARs), provides a better balancing of the National Contingency Plan (NCP) criteria for remedial actions, and includes consideration of the interests of the Stakeholders.

This Plan has been prepared on behalf of SCA Services of Pennsylvania, Inc. (SCA), with the general support of various Site Stakeholders, for the Agency's.consideration in preparing the Record of Decision (ROD) for the Site. Upon review, SCA would encourage a meeting to discuss any questions or to resolve any issues with respect to the Plan.

For SCA Services ofPennsylvania, Inc.,

&-.J£,~ /frevanJ. r Remedial Pro Manager

~R308l78 .:.._, ...... ~ ...... :::J~'

c: Site Stakeholders: w/ att. Mr. Nick VISa)me (Elizabethtown Borough) Ms. Robin Pepperman <Masonic Homes) Mr. G. Paul Klinger (West Donegal Township) Participating PRPs {Vm Manko, Gold & Katcher) Mr. Peter Robelen (GeoSenices, Ltd. -consultant to Masonic Homes)

Mr. Jeffi'ey Silar (P ADEP) w/att. Mr. Gregg C.rystall (USEPA • 3HW22) w/o att. Mr. Tom Santaniello (Office ofU.S. Congressman Gekas) w/o att.

AR308179

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AUG 2 6 1996 •

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ALTERNATIVE REMEDIAL PLAN

ELIZABETHTOWN LANDFILL

WEST DONEGAL TOWNSmP, LANCASTER COUNTY, PENNSYLVANIA

Au~l996

Prepared By: Golder Associates, Inc. 305 Fellowship Road, Suite 200

Mount Laurel New Jersey 08054

Prepared On Behalf of: SCA Services of Pennsy~vania, Inc. One Lincoln Crossing

400 Old Lincoln Highway Fairless Hills PeDDSylvania 19030 ,

AR308\80

August 1996 -2- 923-6053.760

INTRODUCTION

This document provl.des additional review comments on the Proposed Remedial Action Pl.an (PRAP) for the Elizabethto"Wll Landfill Site (Site) which was issued by the United States Environmental Protection Agency (USEPA) on July 26, 1995. The PRAP was based on the results of the Remedial Investigation (R1) and Feasibility Study (FS) prepared by Golder Associates Inc., on behalf of the Elizabethtown Landfill PRP Group, and a Revised Risk Assessment (RRA) prepared by the USEP A The PRAP summarized the results of the RI. FS and RRA and outlined the preferred alternative from those considered in the FS. SCA Services of Pennsylvania, Inc. (SCA) provided review comments on the PRAP in a letter dated September 14, 1995 and provided additional input to USEP A regarding other public comments in a letter dated December 8, 1995. The Alternative Remedial Plan (ARP) presented herein supplements SCA's previous comments on the PRAP. Additional comments were deemed appropriate due to changes in P~~ regulations, USEPA administrative changes, and dialogue with various concerned parties or Stakeholders which have oo:urred since issuance of the PRAP. These issues are discussed further below.

On July 18, 1995, just before the PRAP was issued. Pennsylvania enacted ''The Land Recycling and Environmental Remediation Standards Act" (Act 2). This Ia~ substantially changed the approach to environmental restoration in Pennsylvania and established 1) procedures for evaluation of the potential environmental risks in developing remedial plans, and 2) standards for site remediation applicable to all cleanup projects in Pennsylvania. Act 2 emphasizes community involvement in remedial planning, cost effectiveness in remedy evaluation and selection, and allows the use of engineering and inStitutional controls, in conjunction with other remedial actions, to be considered in eliminating exposure pathways. Furthennore, based upon discussions with USEP A personnel, USEP A recognized the possible need to revisit the PRAP based upon further consideration ofthe impact of regulatory and administrative changes.

The new approach taken by Pennsylvania was mirrored by the Superfund Administrative Rcfonn Initiatives announced by the USEPA in October 1995, after issuance of the PRAP. These refonn initiatives are designed to establish greater stakeholder role and community planning in remedy selection, to consider reasonable exposure pathways and risk assessment in developing cleanup alternatives, and to promote cost effectiveness in remedy selection. The goal of these initiatives is to develop "smarter cleanup objectives that protect public health at less cost" (USEP A, 1995).

STAKEHOLDERS

The time that has elapsed since the issuance of the PRAP bas also allowed SCA to seek the input of various Stakeholders regarding the remedial actions for the Site. SCA has proactively solicited the views of various Stakeholders to foster implementation of these refonns and to identify a feasible remedial alternative which is supported by these stakeholders. The Stakeholders who have been consulted in preparing this ARP include the Elizabethtown Landfill PRP Group, the Masonic Homes of Elizabethtown (an adjacent property owner), Elizabethtown Borou~ and West Donegal Township. Based on discussions with these Stakeholders, SCA has prepared this ARP to reflect the stakeholder interests, consider future conununity planning, eliminate the potential future human health risk of impacted groundwater use, ensure protection of human health and the environment, confonn with AltARs, and satisfy the National Contingency Plan (NCP) criteria for remedy selection.

Golder Associates 4R308f81

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August 1996 -3· 923-6053.760

The individual interests of the Stakehold~rs are refleaoo in various components of the ARP. The Stakeholders have indicated that they generally support the overall concept put forth in the Plan . However, as a complex document, not all Stakeholders have been able to provide specific comment on all aspectS of the Plan. In addition, the Pennsylvania Department of Environmental Protection has been consulted in the development of the Plan, and it is anticipated that the Department will not oppose the Plan should it be adopted.

COMPARISON OF PLANS

Remedial components for the PRAP and this ARP are grouped into three general categories: Landfill Cover, Miscellaneous, and Groundwater. A comparative summary of these major components of the PRAP and the ARP is presented in Table 1. The principal differences between the remedial components in the two plans are those dealing with the landfill cover and the approach to eliminating potential future human. health risks associated with groundwater use. The miscella.neous components are largely unchanged, except that the ARP proposes that monitoring and operations and maintenance (O&M) details be developed during Remedial Design (RD) and that upgrades of the leachate management system be included. These components are summarized in the following paragraphs and Table I. A detailed evaluation of the ARP as it relates to NCP consistency is presented in the Appendix. ·

LANDFILL COVER COMPONENTS

There are two parts of the landfill cover component: one in the northern (steep slope) end of the landfill and one in the southern (parking lot) end of the landfill. The existing cover in the northern end of the landfill was constructed in accordance with the approved closure plan and is retained in the ARP. The cover proposed in the southern area is also consistent with the approved closure plan for the site. The cover proposed in the ARP for the southern end of the ~dfill is an asphalt paving cover. Both of these covers meet the performance requirements of the Pennsylvania regulations for Municipal W~ Management set forth in 2S PA Code Chapter 273.234(c). This would be demonstrated during RD in accordance with the equivalency review provisions of the Municipal Waste Management Regulations (25 PA Code Chapter 273.234(d) and 271.231). On the basis of the equivalency demonstration, the ARP covers would meet the current ARARs identified in the FS report and the PRAP, meet the Remedial Action Objectives, and promote re-use ofthe Site, which is a desire voiced by the local municipalities. Additional descriptio~ of the equivalency demonstration approach is provided in the Appendix.

McrSCELLANEOUSCO~ONENTS

The ARP does not propose significant changes to the Miscellaneous Components (M-2) selected in the PRAP. However, the ARP suggests that specific details of the O&M plans, including environmental monitoring, be prepared during the RD process ·rather than having the elements of the plan specified in the Record of Decision (ROD). The ARP does propose an extensive two (2) year monitoring plan be prepared and implemented to gather additional data regarding potential impacts to environmental media at and near the Site. This would include monitoring of groundwater, surface water, and stream sediments. The details of this monitoring would be d:veloped in conjunction with the Stakeholders and ultimately submitted for P ADEP concurrence and USEP A approval. Once the additional data has been properly evaluated, a detailed O&M plan would be developed.

Golder Associates AR308l82

Au21.1st 1996 923-6053.760

GROUNDWATER COMPONENTS

The groundwater component of the ARP is based upon the results of the EPA baseline risk assessment and an improved understanding of the dynamics of the constituents in the groundwater since preparation ofthe PRAP. In USEPA's risk assessment, the only potential human health risk associated with the Site.was future use of impacted groundwater. Elimination of potential risk associated with future groundwater use and enhancement of the existing source control systems to protect the groundwater resource are central components of the ARP. Pathway eliminatio~ a primary feature of the State's remcdi.al program. has already been achieved for five (5) downgradient groundwater users by providing them with an alternative water supply. The West Donegal To'WtlSbip Water Authority will be involved in determining the appropriate alternate water supply method for their residents. The ARP includes continued provision of an alternate source of water for these users for the future. In addition, specific groundwater needs of the Masonic Homes, also a downgradient water user, will be addressed by assuring them a potable water supply. This would be accomplished through drilling of a replacement groundwater supply well with a yield equivalent to well EM400, or other groundwater remedial actions deemed appropriate. In additio~ wells EM400, EMSOO, and the replacement well for well EM400 would be included in the site monitoring program to be developed during the remedial design. Should monitoring of these wells indicate landfill related impacts, necessary treatment and maintenance will be provided, if required, to ensure the Masonic Homes a comparable quantity and quality of drinking water. If the data from the two(2) year monitoring program (discussed below) shows contaminant concentrations increasing in the area of the "stable plume", appropriate groundwater remediation measures will be further evaluated. Pathway elimination will be achieved for potential future groundwater users by deed restrictions on groundwater use within the impacted area downgradic:nt of the landfill and provision of alternative water supply. By ~g the potential groundwater use pathway, risk is eliminated, ARARs are attained, and human health and the environment are protected.

One of the goals of the groundwater extraction system in the PRAP is to control the further downgradient migration of impacted groundwater. Additional analyses of groundwater data. performed by Golder Associates, Inc. since the PRAP was completed indicate that the zone of impacted groundwater may be in a steady state condition. That is, the mass constituent loading from the landfill equals the mass of constituent treatment through natural attenuation processes. This appears to indicate that the existing source control systems at the landfill and natural attenuation are effectively controlling further downgradient migration of the impacted groundwater. Because there docs not appear to be a net downgradicnt migration of the zone ·of impacted groundwater, it is possible that there is no potential far impacted groundwater to reach any additional existing downgradient groundwater users, thereby eliminating the potential risk associated with future groundwater use. In time, it is expected that mass constituent treatment through natural attenuation will exceed the mass constituent loading from the landfiJJ, as a result of cap completion and leachate collection system upgrades. Furthermot"ey any potential future use of groundwater in the impacted zone will be controlled by deed restrictions and provision of potable water.

Further evaluation of the actual conditions of the aquifer groundwater and other media would be conducted during the proposed intensive two (2) year monitoring program. This program, which would include Masonic Homes wells EM400, EM500, and the rcp1accmcnt well fur well EM400, would likely consist of quarterly monitoring of groundwater, sur:facc water, and sediment. The purpose of this two {2) year monitoring program will be to further evaluate the aquifer conditions

Golder Associates AR308t83

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August 1996 -5· 923-6053.760

and attempt to confirm that steady-state conditions exist. An appropriate fate and transport model will be selected to evaluate the data and aquifer conditions. Further, monitoring of surface water and sediment media· will be conducted to develop -additional data and evaluate any potential impacts to aquatic communities and users of surface water from Canoy Creek (i.e. -cattle).

It is anticipated that sequencing of site activities will be as follows: (1). drilling and start-up of a replacement for Well EM400; (2) implementation and completion of the two (2) year monitoring program; (3) treatment of groundwater supplied from Well EMSOO and the replacement for EM400 as necessary, should monitoring indicate landfill related impacts; and (4) implementation of appropriate groundwater remediation measures following the two(2) year data collection and monitoring effort, should appropriate analysis of monitoring data document that contaminant transport is not in steady state and that threats from groundwater quality degradation show potential for increase.

In order to provide added assurance that the contaminant sources are being effectively controlled at the landfill and that the further downgrad.ient migration of constituents is· prevented, the existing source control systems at the landfill are proposed to be upgraded. These upgrades include the installation of an asphalt cover at the southern end of the landfill and upgrading of the leachate copection system at the northern end of the landfill. Therefore, additional groundwater impacts are prevented, which is one of the objectives of the PRAP. and contaminant migration is controlled without active groundwater extraction.

A second goal of the groundwater extraction system in the PRAP is to restore the impacted area of the aquifer to background standards. Recent studies on the effectiveness of extracting groundwater for the purpose of aquifer restoration have concluded that this technology is ineffective for restoring aquifer water quality within a predictable time. frame. In particular, groundwater restoration using pumping technologies has been widely shown to be technically impracticable in deep fractured bedrock systems similar to those at the Site. Therefore,_ in addition to the fact that the need for groundwater extraction as a contmninant migration control system described in the precffling paragraph is not technically supported, the technical impracticability of aquifer restoration indicates that expenditure of resources on such a costly and potentially ineffective system is not an appropriate balancing of the NCP criteria. Supporting details are provided in the Appendix, including a list of references regarding the technical impracticability of groundwater pump and treat systems as a means for aquifer restoration. In accordance with CERCLA guidance (Guidance on Remedial Actions for Contaminated Ground Water at Superfund Sites, USEPA, 1988, pp.S-3 through S-4), natural attenuation, which may require a loJJger time frame to achieve cleanup levels, is an appropriate groundwater remedy at sites such as the Elizabethtown Landfill where potential exposure to impacted groundwater will be . effectively and reliably controlled. Further, the PRAP performance standard ·of restoring· aquifer groundwater to background conditions is not considered an ARAR thus requiring a modification to the Remedial Action Objective.

Details of various elements, as shown on the attached Table 1. will be _established in the Remedial Design Phase .

Golder Associates AR308l84

Ausrost 1996 923~053.760

SUMMARY

In an effort to promote the implementation of regulatory reform initiatives issued by Pennsylvania and the USEP A, SCA, with the general support of various Stakeholders, has developed this ARP for the Elizabethtown l.a;nd.fill Site. This plan is conceptually supported by the Stakeholders, and has as its central theme the elimination of potential risk posed by the Site. The ARP is protective of human health and the environment, complies with ARARs as well as CERCLA a.drninistrative and policy guidance, and will undoubtedly expedite the RDIRA process. The major differences between the ARP and the PRAP are an asphalt cover equivalent over the southern portion of the landfill, a demonstration of equivalence for the existing cover over the northern portion of the landfill, enhancement and continued operation of the effective groundwater source control measures, elimination of groundwater risk through deed restrictions, provision of an alternative water supply to impacted downgradient water users, additional srudy of the groundwater regime, and minor revisions to the approach in developing.the monitoring and O&M plan.

As described in the Appendix, the ARP is believed equal to or superior to the PRAP for the nine NCP criteria. The PRAP does not provide any further risk reduction than the ARP, but costs more than three times as much. It is clear that the ARP, in addition to being ARAR complian~ provides a more cost effective remedy for the Site that is as protective of human health and the enviromnent than the preferred alternative presented in the PRAP.

Recent Superfund administrative reform initiatives have embraced " ... smarter cleanup choices that protect public health at less cost'" and emphasized that "disproportionately costly remedies

•

are to be avoided" (USEP A, 1995). One of the policy measures of this refonn initiative is • establishing a cost effectiveness threshold for selection of prOtective, ARAR-compliant remedies. USEPA guidance currently requires review of remedies costing over SlO million where there is an equally protective and compliant remedy that costs less than half of the proposed remedy. In these cases, the guidance expresses the preference for the most cost effective protective remedy. Also, the Superfund administrative reform initiatives place strong emphasis on establishing greater stakeholder role in remedy seledion. Clearly, the ARP generally supported by the Stakeholdcts, meets both of these rc:fonn initiatives and is the. appropriate rc:mcdy for the Elizabethtown Landfill Site .

. The ARP provides a pragmatic, consensus approach that would proviqe benefit to the Site Stakeholders. SCA and the Stakeholders welcome continued dialogue with USEP A and P ADEP in order to provide additional information about the ARP, to further elucidate Stakeholder concerns, and to explore approaches for incorporation of the ARP components into the ROD.

Golder Associates AR308185

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Ausrust 1996 -1- 923-6053.760

TABLE 1 COMPARISON OF USEPA PRAP AND THE

ALTERNATIVE REMEDIAL PLAN ELIZABETHTOWN LANDFILL SITE

USEPAPRAP · ALTERNATIVE REMEDIAL PLAN

Landfill Cover Comeonents Landfill Cover Comeonents

1} lnstallatipn of a final cover over the southern 1) Installation of an asphalt cover over the portion of the landfill that specifically meets the southern portion of the landfill in compliance soil cover requirements of the current with 25 PA Code Chapter 273.234(d) and Pennsylvania Department of Environmental . 271.231. In addition, it allows future use of this Protection (PAOE?) regulations in 25 PA Code portion of the Site and the existing building by Chapter 273.234(a). the local community in concert with brownfield

development approaches formulated by the USE?A and as encouraged by the recent Pennsylvania Act 2 legislation, effective July 18. 1995. Design and maintenance details would be developed during Remedial Design (RO). .

2) Upgrading the existing final cover over the 2) Retain the existing cover that was northern portion of the landfill such that it constructed with the approved closur-e plan and specifically meets the soil cover requirements that will meet the equivalency requirements in of the current regulations in 25 PA Code compliance with 25 PA Code Chapter Chapter 273.234(a), including placement of an 273.234(d} and 271.231. additional 1 a inches of soil cover to promote veoetatlon. 3} Upgrade stormwater controls in the northern 3) SAME. Install appropriate stonnwater and southern portions of the landfill. controls for the southern portion of the Site.

and improve existing stormwater controls in the northern portion of the Site as needed.

Miscellaneous Comgonents Miscellaneous Comeonents

4} Continue to provide alternative water 4) SAME. To be contlm,1ed in the future. suoclv for five downgradient l'eSidences. 5) Continued routine inspection and repair of 5) SAME. To be incorporated into a detailed security fence. monitoring and Operation and Maintenance

(O&M) Plan to be developed during RO. 6) Continue maintenance of landfill covers, 6) SAME. To be incorporated into a detailed including annual mowing of vegetation and monitoring and O&M Plan to be developed rearadino and reveoetation of eroded areas. during RD. 7) Continue maintenance of stormwater 7) SAME. To be incorporated into a detailed management system, including sediment monitoring and O&M Plan to be developed removal from ditches and sediment basins, during RD. plus erosion recair .

Golder Associates aR308l8&

Ausrust 1996 -2- 923-6053.760

TABLE 1 COMPARISON OF USEPA PRAP AND THE

ALTERNATIVE REI\'IEDIAL PLAN ELIZABETHTOWN LANDFJLL SITE

(Continued)

USEPAPRAP ALTERNATIVE REMEDIAL PLAN

Miscellaneous Comeonents Miscellaneous Comeonents

8) Continue operation and maintenance of the S) SAME, except that the gas management gas management system to actively collect the system would be modified in the future as gas generated in the landfill, prevent its dictated by gas generation. Details of the data migration off-Site, and bum it at a flare station. . collection and monitoring to determine proper

gas management would be incorporated Into a detailed monitoring and O&M Plan to be developed during RD.

9) Continue landfill gas monitoring around the 9) SAME. To be incorporated into a detailed perimeter of the Site to measure gas migration. monitoring and O&M Plan to be developed

during RD. 1 0) Continue operation and maintenance of the 1 0) SAME plus upgrades of the leachate leachate collection system, induding the drains management system. System upgrades and a and seep collectors. detailed monitoring and O&M Plan · to be

developed during_ RD. 11) Continue groundwater and surface water 11) SAME: Specific monitoring requirements to monitoring for organic and inorganic be determined during RD and would be contaminants. incorporated Into a detailed monitoring and

O&MP!an. 12) extension of the security fence to surround 12) SAME, except the fencing at the southern the entire landfill. portion of the Site Would .be compatible with

future land use. 13) Establish deed restrictions to protect the 13) SAME. Deed restrictions would allow landfill caps, prevent human exposure to specific use of Site by the local community in landfill contents, and prevent use of concert with brownfield development. groundwater both now and in the future. 14) Sediment monitoring as a measure of 14} Specific media to be monitored would be remedial effectiveness. determined during the • RO and would be

incorporated into a detailed monitoring and O&M Plan.

Groundwater Comeonents Groundwater Corneonents

15) Extraction of groundwater. 15) Enhancement/continued operation of the source control systems. Groundwater risk elimination by providing alternative water supply to affected downgradient · users, including the Masonic Homes and placing deed restridions Qnduding an acceptable access agreement) on affected properties. Additional groundwater monitoring will be performed to confirm steady state groundwater conditions.

16) On-Site treatment of groundwater and 16) Continued treatment of groundwater via leachate using chemical precipitation, air natural processes. Continued treatment of stripping (with emission controls), and, if leachate. necessarv. carbon adsorotion.,

Golder Associates AR308187

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August 1996 -3- 923-6053.760

TABLE 1 . COMPARISON o·F USEPA PRAP AND THE

ALTERNATIVE REMEDIAL PLAN EliZABETHTOWN LANDFILL SITE

(Continued)

USEPAPRAP ALTERNATIVE REMEDIAL PLAN

Groundwater Comgonents Groundwat§r Comgonents

17) DisCharge of treated groundwater/leachate 17) No extraction of groundwater. Continue to Coney Creek in compliance with NPOeS existing management of leachate from Site. disCharge requirements.

1 18) Shallow groundwater level monitoring to 18) Not included since groundwater extraction assess groundwater extractlon impacts on is not proposed. wetlands hvdroloov. ·

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ALTERNATIVE REMEDIAL PLAN ELIZABETHTOWN LANDFILL

923-6053.760

WEST DONEGAL TOWNSHIP, LANCASTER COUNTY; PENNSYLVANIA

APPENDIX

Al.O INTRODUCTION

This Appendix to the Alternative Remedial Plan (ARP) for the Elizabethtown Landfill Site (the

Site) demonstrates that the ARP is consistent with the remedy selection requirements of the

National Contingency Plan (NCP). The requirements are satisfied by comparing the ARP to the

nine NCP remedy selection criteria and, for each of the nine criteria, by comparing the ARP to the

Proposed Remedial Action Plan (PRAP} prepared by the U.S. Enviromnental Protection Agency

(USEPA) on July 26, 1995. Relevant background information, including a description of the Site

conditions and the existing remedial systems at the Site, is contained in the Remedial Investigation

(RI) and Feasibility Study (FS) reports and is summarized in the PRAP. Comparison of the

remedial systems included in the ARP and the PRAP are described in Table l of this ARP.

Section A2 of this Appendix compares the ARP to the nine NCP criteria in order to demonstrate its

consistency with the NCP. Section A3 of this Appendix compares the ARP and the PRAP to each

other for each of the nine NCP criteria. Section A4 indicates that the ARP is a more appropriate

remedy for the Site because it provides a better balancing of the NCP criteria than the PRAP and it

is consistent with the Superfund Administrative Refonn Initiatives (USEP A, 1995), "The Land

Recycling and Environmental Remediation Standards Act?' (Act 2) enacted by Pennsylvania, and

the US~ A 1995 Brownfields Action Agenda.

The Remedial Action Objectives (RAOs) for the Site listed in the FS report are as follows:

l. Protect human health and the environment by cleaning up the entire plume of contaminated groundwater beyond the boundary of the trash disposal area to background concentrations unless, after selection and implementation of groundwater remediation, EPA in consultation with DER detennines that meeting such a goal is technically impracticable from an engineering perspective;

2. Control all Site related discharges to Canoy Creek and the tributaries so that P ASWQS are satisfied;

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3. Control all Site related discharges to Conoy Creek and the tributaries to prevent future impacts • to sediments related to the Site contaminants of concern;

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4. Prevent to the extent technically practicable, infiltration and resulting leachate generation in the southern portion of the landfill (which is a potential source for the identified groundwater impacts and an area with downward hydraulic ~ents); and

5. Continue to collect and treat landfill gas.

'I)le RAOs for groundwater presented in the FS were based on a Pennsylvania Departtnent of

Environmental Resources (PAD ER) policy of remediation to background concentrations. On July

18, 1995, just before the PRAP was issued, Pennsylvania enacted Act 2 which no longer

recognizes background concentrations as the only appropriate groundwater remediation standard ..

Act 2 allows selection of one or a combination of three remediation standards: 1) a background

standard, 2) a Statewide health standard, or 3) a site-specific standard.

For groundwater, the Statewide health standard would be Maxllnum Contaminant Levels. (MCLs)

and the site-specific standard would be risk-based. The NCP indicates that MCLs and non-zero

MCL Goals (MCLGs) are to be used as groundwater remedial goals. The risk-based site specific

standard proposed by Act 2 could be less stringent than.the NCP goal ofMCLs/non-zcro MCLGs.

Therefore, MCLs and non~zero MCLGs will be the most stringent chemical-specific ARAR for

• groundwater. It is appropriate to revise the groundwater RAOs for the Site to reflect this change.

•

Consequently, the first RAO from the FS listed above has been revised for purposes of this ARP as

follows:

• Protect human health and the environment by preventing future ingestion and inhalation e.xposures to gro~water containing constituents at concentrations exceeding MCLs and non­zero MCLGs, or background, whichever is greater •

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A2.0 COMPARISON OF ALTERNATIVE REMEDIAL PLAN TO NATIONAL CONTINGENCY PLAN CRITERIA

A number of remedial systems are common to both the.ARP and the PRAP. Consistency of these

systems with the NCP was demonstrated in the FS Report and in the PRAP and is therefore not

repeated herein. As listed in the PRAP, and in Table 1 of the main text, these systems arc as

follows:

• Provision of an alternative water supply for five downgrad.ient residences;

• Routine inspection and repair of the security fence;

• Maintenance of landfill covers, including annual mowing of vegetation, plus regrading and revegetating of eroded areas;

• Maintenance of stonnwater management ~ including sediment removal from ditches and sedimentation basins, plus erosion repair;

• Operation and maintenance (O&M) of the landtill gas management system to actively collect the gas generated in the landfill, prevent its migration off-Site, and bum it at a flare station;

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• Operation and maintenance of the Jeacbate collection system which includes drains and • seep collectors;

• Landfill gas monitoring around the perimeter of the site to measure gas migration;

• Groundwater and surface water monitoring for organic and inorganic contaminants;

• Extension of the security fence to SUITOund tho entire landfill;

• Establishment of deed restrictions to protect the landfill caps, prevent human exposure to landfill contents, and prcvem usc of groundwater both now ~ in the future; and

• Sediment monitoring as a measure of remedial effectiveness.

The remainder of Section A2 describes how the systems which have changed from the PRAP to the

ARP are consistent with the NCP.

A2.1 Overall Protection of Human Health and the Environment

The ARP is protective ofhuman health and the environment by specifically addressing the potential

future groundwater risk associated with the Site. The Revised Risk Assessment (RRA) prepared

by the US EPA did not identify any risk of adverse human health effects which exceeds the target

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range defined. in the NCP for current land use exposure scenarios. The only future risk that \Vas

identified to exceed the target range \\'aS potential future usc of impacted groundwater from a new

well located in the area. immediately downgradicnt of the landfill. To eliminate the potential future

groundwater use risk. the ARP includes the following elements:

• Enhanced source control measures;

• Groundwater exposure pathway elimination by deed restncttons (including an acceptable access agreement) and providing an alternate potable water supply.

The enhanced source control measures include installation of a cover on the southern portion of the

landfill and upgrading the present leachate collection system to enhance its effectiveness as a

source control for leachate. Both of these measures will reduce the future potential f'or constituent

release to the groundwater. The combination of deed restrictions apd providing an alternate

potable water supply to downgradiem groundwater users will eliminate this potential future human

exposure pathway.

The remedy proposed in the ARP is appropriate because recent modeling of the groundwater

system indicates that the S.tte.reJated constituents in the groundwater are in a steady state condition

such that the mass of constituents released to the groundwater from the source area are at most

equal to the mass that is being treated by natural processes within the environment. The modeling

results are presented in the Attachment to this Appendix. In addition to the natural processes, the

ARP incorporates enhanced source controls to further reduce the potential for future release from

the source. This added source control will reduce the rate of constituent release which will result in

lower contaminant concentrations in the impacted area in the future. In addi~on, the ARP provides

for groundwater monitoring aDd modeling to provide ·assurance that steady state conditions are

present and that the remedy remains protective.

The Ecological Risk Assessment indicated that there might be a potential ecological risk associated

with Site-related constituents to the aquatic community in Corioy Creek and its tributaries around

the landfill. This is because concentrations of some constituents in surface water adjacent to the

Site exceed P ASWQS values for enviroruncntal protection. However, biological monitoring of '

aquatic communities for species abundance and diversity was not pcrfonned during the RIIFS to

further evaluate this potential. Furthermore, the ARP actively addresses the potential ecological

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risk through enhanced source control measures. The cover to be installed on the southern end of

the landfill and the upgrades of the leachate management system will further reduce off-Site •

migration of leachate constituents to aquatic communities in Canoy Creek and its tributaries

adjacent to the landfill. Consequently, environmental monitoring is included in the Miscellaneous

Components of the ARP to funher investigate and evaluate the potential ecological risk and the

need for any additional response actions. The proposed two (2) year monitoring period will also

provide additional data on surface water and sediment quality which will allow an evaluation of

any potential impacts to surfuce water users (ie -cattle).

A2.2 Compliance with ARARs

The ARP complies with ARARs. For the cover system, the ARP utilizes equivalence

demonstrations to comply with AR.A.Rs. The current cover on the northern portion of the landfill

met the Pennsylvania Municipal Solid Waste regulation in effect at the t:imC it was constructed and

will be subject to equivalency demonstrations. Likewise, the cover proposed to be placed on the

southern portion of the landfill is also consistent with the approved closure plan and will also be

subject to equivalency review. For the groundwater remedy component, the ARP uses source

control, deed restrictions, alternate water supply and natural attenuation to comply with ARAR.s in

accordance with ·CERCLA guidance ( Guidance on Remedial Actions for Ground Water at

Superfund Sites, USEP A, 1988).

The cover ARAR stated in the PRAP is the Pennsylvania Municipal Solid Waste Regulations,

Title 25, Chapter 273.234. This regulation allows for equivalency demonstrations under Chapter

273.234(d) and as specified in Chapter 273.231. The NCP [40 CFR 400.430(f)(l)(ii)(C)(4)J also

allows for selection of an alternative approach to meeting ~ ARAR whereby one demonstrates an

equivalent standard of performance to the approach specified for the ARAR. Equivalency requires

that the cover meet the following performance standards specified in Chapter 273.234(c):

(1) Prevent vectors, odors, blowing litter and other nuisances.

(2) Coyer solid waste after it is placed without change in its properties and without regard to weather.

(3) Be capable of allowing loaded vehicles to successfully maneuver over it after placement

(4) Be non-combustible.

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(5) Be capable of supporting the germination and propagation of vegetative cover as required by Chapters 271.235 and 271.236 (relating to revegetation; and standards for successful revegetation).

(6) Compact.well and not crack when dry.

'The existing, state-approved cover on the northern portion of the landfill meets these perfonnance

standards. The cap is well compacted and supports a healthy vegetative cover. The cap does not

show signs of cracking, prevents vectors, odors, blowing litter, and other nuisances. The cap

covers the placed solid waste without change to property regardless of weather, is non-combustible

and allows loaded vehicles to move over it without problem. Therefore, this cover is equivalent

and complies with the ARAR.

The proposed asphalt cover at the ~outhem end of the landfill will also meet the perfonnance

standards of 273.234(c), except for its ability to support vegetation as per 273.234(c}(5).

However, the vegetative layer of a land£ill cover is intended to prevent erosion of the underlying

soil. The proposed asphalt cover would be equivalent in meeting this perfonnance objective. The

asphalt cover would be well compacted and allow loaded vehicles to move over it without problem.

The cover would prevent vectors, ·odors, blowing litter, and other nuisances and would not be

combustible. The asphalt would cover any solid waste without changing its properties regardless

of weather. Consequently, the asphalt paving cover is an equivalent cover and complies with this

AR.AR.

The ARP will achieve chemical-specific ARARs for groundwater through natural attenuation.

Pennsylvania's Act 2 [Section 304{d)(l)(ili)] recognizes natural attenuation as a viable approach

for groundwater remediation. CERCLA guidance (USEP A, 1988, pg. 5-8) indicates that

hydrogeologic constraints (ie - fractured bedl:oclc settings). may "limit the effectiveness of active

restoration. •• In these cases, "Natmal attenuation and wellhead treatment with monitoring and

institutional controls may be the only feasible remedies for these sites". Thus, in accordance with

CERCLA guidance (USEPA, 1988, pp. 5-3 through 5-4). "A readily available water supply of

sufficient quality and yield that is protected from sources of contamination may reduce the

importance of rapid remediation, providing more flexibility to select a response action that requires

a longer time to achieve the cleanup level." The ARP specifically addresses these issues bec:wse

source control measures arc in place (and will be upgraded) and potential exposure to impacted

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groundwater will be effectively and reliably controlled through deed restrictions and provision of

alternative water supply.

As discussed in the FS (Se~on 2.2), the existing source control measures that were implemented

in the 1980's, in conjunction with natural attenuation processes, have effectively controlled

migration of constituents to off-Site areas. Figure l·S of the RI report shows the reduction in

leachate generation at the Site as a result of the cap placement on the northern portion of the Site.

Furthermore, downgradient groundwater users, particularly the Masonic Homes, have endorsed the

usc of institutional controls and alternative water supplies to eliminate potential future exposure to

Site-related constituents in groundwater.

A2.3 Long-T enn Effectiveness and Permanence

The existing and proposed remedial measures of the ARP will be effective and permanent. The

source control effectiveness of the existing cover on the northern end of the landfill bas been

demonstrated through the reduction in leachate generation since its construction (see Figure l·S of

the Rl report). The proposed asphalt cover on the southern portion of the 1andfi1l is expected to

provide similar source control and reduced leachate generation to the extent practicable. The

drainage channels and sedimentation basin effectively manage runoff ftom the Site. The existing

cover on the northern portion of the landfill prevents erosion and the proposed asphalt paving cover

on the southern portion of the landfill will prevent erosion. Both of these covers will withstand

natural weathering processes in the long-tenn. The ARP proposes certain upgrades to the leachate

collection system so that it will be an effi:d:ive, long-term, source control measure. Maintenance of

these remedial systems will take place in accordance with an approved monitoring and O&M plan

that will ensure they remain effective in the long term.

Deed restrictions prohibiting groundwater usc in the impacted area downgradient of the landfill will

be put in place and remain in effect until such time that groundwater ARARs have been attained.

The effectiveness of the deed restrictions is considered to be high because prohibition of

groundwater usage will eliminate human health risk associated with the Site. The current owners

understand that groundwater use is restricted, and the deed restrictions will place this notice on any

prospective future owners, should the properties ever be sold. Any groundwater wells to be used

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for drinking water purposes which might be planned on an affected downgrad.ient property would

be prohibited through the deed restrictions .

In addition to the deed restrictions, the affected Stakeholders have also been consulted in the

development of an alternative water supply as part of the ARP. This water supply will be a very

effective measure to assure that potable water is available and will eliminate the potential future

human health risk associated with the impacted groundwater. The alternate water supply will be

available until such time that groundwater ARARs have been attained.

There will be no residual risk associated with the Site which exceeds the target range specified in

the NCP. The only unacceptable risk identified by the RRA was potential future use of

groundwater in the area downgra.dient from the Site. Deed restrictions and provision of an

alternative water supply in this area will effectively eliminate any risk of potential future ~"Posure

to impacted groundwater.

Al.4 Reduction of Toxicity, Mobility, or Volume through Treatment

The existing and enhanced source control systems reduce the toxicity, mobility, and volume of

hazardous substances through treatment The leachate management system, the cover system, and

the landfill gas system reduce contaminant mobility. The eollected leachate is treated at an off-Site

treatment facility and the collected landfill gas is treated on-Site through thennal destruction

(flare). Elizabethtown Borough has expressed concern that use of the Borough's PO"'W was not

considered as an option for waste water treatment from the Site. It is hoped that the Agency will

consider this option in the ROD. These collection and treatment systems will be operated and

maintained in the future. Therefore, contaminant toxicity is reduced through pennanent and

irreversible treatment by these systems. Furthennore, as described in the Attaclllitent, the toxicity

and mobility of groundwater contaminants are being treated through natural in-situ

biologicai/chcmical mechanisms such as biodegradation and/or hydrolysis.

A2.5 Short Tenn Effectiveness

The existing remedial measures, including groundwater remediation by natural attenuation, are ,

effective in the short tenn because there is no current risk to human health (including maintenance

• workers) and the environment. The deed restrictions and provision of alternate water supply will

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effectively prevent e:\-posure to impacted groundwater. The ARP is also effective in the short term

with regard to the cap. The existing cap does not need to be upgraded thereby eliminating •

exposure to workers and the surrounding community. As shown in SCA's comments on the PRAP

(letter to USEPA dated September 14, 1995), leaving the existing cap in place would be effective

in the short term for the following reasons:

• There would be no need for grubbing activities, and consequent repairs to the existing drainage layer and underlying clay area or replacement of cover materials lost through grubbing;

• There would be no need to disrupt the existing well vegetated surflce on the northern portion of the landfill nor would the existing terrestrial habitat be disturbed;

• The construction activities at the Site could be minimized thereby minimizing the noise, additional fugitive dust, heavy traffic in the community, and risk to workers involved in Site remediation due to refuse, IandfilJ gas and heavy equipment traffic;

• There would be no need to disrupt or repair the currently operating landfill gas management system in the northern portion of the landfill;

• There would be no need to disrupt or repair the currently operating SUl'face water control and conveyance structures on the northern portion of the landfill thereby minimizing erosion and sedimentation; and

• There would be no need to regrade the landfill surflce thereby maintaining sur:tace water flow rates and reducing potential impacts to surrounding land areas and 'Canoy Creek.

In addition, by not performing groundwater pump and treat; potential impacts to wetlands and

creek habitat would be eliminated.

The proposed enhancements and additions to the existing source control systems will be

implemented using widely-practiced construction procedures and can be conducted in a manner

such that site workers, the surrounding community, and the enviromnent are not adversely affected

by their implementation.

A2.6 Implementability

There are already a number of effective remedial systems presently in place at the Site. These

include the cover on the northern end of the landfill, the leachate management system, the landfill

gas management system, and a number of misceUaneous components such as the fence :pui the

monitoring wells. The proposed asphalt cover at the southern end of the landfill can be easily

constructed because it uses conventional equipment and widely-available materials. Furthermore,

since this portion of the site is flat and is already used as a parking area, minimal regrading would

be necessary for placement of the asphalt paving.

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• circumstances. If levels of conta.minants are projected to attenuate, a waiver may not be necessary

if cleanup levels will be achieved in a reasonable time frame (i.e .• less than 100 years)."

Nevertheless, it is anticipated that sequencing if site activities will be as follows: ( 1) drilling and

sci.rt-up of a replacement well for Well EM400; (2) implementation and completion of the two (2)

year monitoring program; (3) treatment of groundwater supplied from Well EMSOO and the

replacement for EM400 as necessary, should monitoring indicate landfill related impaas; and (4)

implementation of appropriate groundwater remediation measures following the two (2) year data

collection and monitoring effort, should appropriate analysis of monitoring data document that

contaminant transport is not in steady state conditions and that threats from groundwater quality

degradation show potential for increase.

A3.3 Long-Term Effectiveness and Permanence

The Long-Term Effectiveness and Permanence of the ARP and the PRAP arc equal. Both plans

• include long-term. effective source control and groundwater exposure pathway elimination

systems.

Both plans include permanent cover and leachate management systems which are long term source

control measures. Their ~ntinued effectiveness will be ensured through maintenance. The cover

components of the ARP have equal performance to those in the PRAP. The existing cJ:ay cover on

the northern end of the tandfiU, which is to lemain as part of the ARP, will continue to reduce

leachate generation (Figure 1-5 of RI) as effectively as the proposed cover modiiications proposed

in the PRAP.

The ARP includes deed restrictions to specific downgradient properties until groundwater ARARs

are achieved. Both plans include provision of an alternate water supply to the five affected . residences immediately downgradient of the Site, in addition to the Masonic Homes. Due to the

size of the population served by the Masonic Homes, it is likely that their alternate Water supply

would include a new production well which meets applicable drinking water standards. The PRAP'

• addresses reduction of potential future groundwater risk by pumping the groundwater for treatment

and discharge. The ARP addresses potential future groundwater risk by natural attenuation

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treannent of the constituents in the groundwater and alternate water supply. Both remedies achieve

ARARs in a reasonable time frame. Thus, the ARP is as effective as the PRAP in proted:ing

human health by eliminating potential future risk of groundwater use

Altbough the groundwater extraction system included in the PRAP is intended to restore

groundwater quality for potable ~ aquifer restoration is deemed technically impracticable

because the hydrogeologic setting at the Site includes fractured bedrock and a very long time

period of continuous release of contaminants into the subsurfuce. Recent research (USEP A, 1989;

Travis and Doty, 1990; National Research Council, 1994; MacDonald and Kavanaugh. 1994) and

USEP A guidance (USEP A, 1993) indicates that it is not practicable to restore contaminated

groundwater at many sites, especially those with fractured bedrock settingS. It also takes an

extremely long period of time to potentially restore areas with historically old releases due. to the

slow, diffusion-limited transport of contaminants back out of the rn«?k matrix after several pore

volumes of groundwater have been removed (USEPA, 1989; Nyer, 1993; Haley et al., 1991;

Wood, 1996). It can not be reasonably estimated ho~ many years it will take to restore

groundwater quality. Because of the demonstrated ineffectiveness associated with pump and treat

groundwater restoration at sites such as this, the natural ~on processes occurring in the

zone of impacted groundwater are expected to be at least comparable in preventing further

migration of groundwater impacts. The ARP components are directed _at protec:tiveness of human

health and the environment during the time necessary to achieve ARARs. CERCLA guidance

fUSEPA. 1988. pg. 5-8) indicates that in fractured bedrock settings. natural attenuation along with

instittttional controls. monitoring and well-head treatment maY be the only feasible alternative.

A3.4 Reduction of Toxicity, Mobility, or Volume through Treatment '

Both the ARP and the PRAP provide pennanent and irreversible reduction of toxicity, mobility, or

volume of the Site related constituents through trcatmc:nt. Both plans include treatment of landfill

gas and leachate. Both plans also include trcaancnt of groundwater to achieve MCLs. Although

the groundwater extraction system in the PRAP might provide a different initial rate of reduction in

the volume of constituents within the impacted groundwater than that in the ARP, the long-tenn

extent of treatment using natural attenuation will be consistent with that provided by the

groundwater extraction system.

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• A3.S Short Term Effectiveness

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The ARP is more effective than the PRAP in the short-tenn from the perspective of protecting

future site workers, the surrounding corrununity and the environment during implementation. As

stated above, the PRAP may have a different initial rate of treatment than the ARP, however, it

would not enhance protection of human health since the potential future groundwater use exposure

pathway would be effectively eliminated by both alternatives. Furthennore, leaving the existing

cover intact will not cause disruption and potential releases that would be associated with

constructing the PRAP-proposed cover modifications.

The proposed upgrade to the existing cover on the north end of the landfill in the PRAP will have a

short-tenn impact on the local community as discussed in Section A2.5, .above. It will likely result

in increased wind and water-borne sediment transport off-Site and. will impact the surrounding

conununity through generation of odors, noise and dust. The ARP will not cause these impacts.

Operation of the groundwater extraction system included in the PRAP could lower water levels in

wetlands nearby Canoy Creek and could adversely affect the aquatic community on a pennanent

basis. The USEP A was quite concerned regarding this aspect of the remedy and proposed

wetlands monitoring as a safeguard against these impacts. The ARP would eliminate t.his potential

adverse impact and would not require wetlands monitoring.

The groundwater treatment plant included in the PRAP will require delivery of treatment reagents

over the roadways to th~ site, as well as transport of treatment residuals through the town.

Operation of the air stripper will require pollution conti'ol measures to prev'ent air quality impacts.

The ARP does not require a groundwater extraction or treatment system and therefore eliminates

the potential for these adverse impacts to the surrounding community.

The PRAP estimate of the time required to achieve groundwater remedial goals is 15 to 30 years.

This time frame is based on the optimistic expectation that the groundwater pumping system is able

to effectively remove constituents from the fra.ctured bedrock aquifer and achieve groundwater •

remedial goals down gradient of the landfill. However, experience at many other sites suggests that

longer than initially estimated time frames arc being required to achieve such remedial goals (Haley

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et al., 1991; MacDonald ct al., 1994; Travis ct al., 1990; USEPA, 1989; and Wood. 1996). In

additio~ and often ignored, once the downgradient goals arc attained the source may have to be

continuously controlled to maintain the downgradient goals. Thus, control of future releases from

the landfill could require ~ pump and treat system to operate for an indefinite period of time until

the source is depleted. The length of time that such a system would have to operate is a function of

the volume of source constituents in the landfill as well as the hydrogeologic characteristics of the

site. Since the volume of constituents can not be determined, the length of time can not be

determined. Consequently, a pump and treat system might have to be operated for a substantially

longer time than estimated in the PRAP in order to continue meeting groundwater remedial goals.

A3.6 Implementability

The ARP can be more easily implemented than the PRAP because it requires substantially less

constructio~ requires fewer permit approvals/equivalencies than . the PRAP, and has been

developed with the consideration of the Site Stakeholders. Therefo~ the time it would take to

implement the ARP is likely quicker than the time it would take to implement the PRAP.

By using natural attenuation for groundwater treatment the ·.ARP has no groundwater extraction

system or groundwater treatment sYstem that would ba.ve to be constructed. By using the existing

cover on the northern portion of the landfill, there would be no 'risk of~ to the existing cover

and gas system that is expected with the PRAP modifications to this cover. Construction of the

PRAP cover modifications would require clearing of existing vegetation and movement of

construction vehicles over the cover which might damage the existing drainage layer and the

existing clay barrier (and potentially dehydrate the existing clay banier), thus compromising the

cover's effectiveness as an infiltration banier. Damage to ~e existing gas collection system is also

likely and there would be a risk of uncontrolled releases of landfill gas to ambient air and the

surrounding community. Dust/odor and erosio~ control measures would also be required.

Construction of the AR:P cover over the southern portion of the landfill would take less time and

effort than ~ation of the PRAP cover. The PRAP cover would require demolition of the

existing building and removal of the demolition debris for off-Site dispo~ regrading of the area

and placement of soil material for the cover. The SCA letter providing comments on the PRAP

dated. September 14, 1995 and Section A2.5 above describe some of the problems which may be

encountered during implementation of the proposed cap from the PRAP. The ARP asphalt paving

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cover would leave the building intact for potential re-use and would require minimal regrading and

subbase placement. Potential re-use of the site is a desire of the local communities and supports

Act 2 goals.

SCA envisions that the ARP would be easily implemented from a community perspective because

most of the community stakeholders have already commented on and provided input to the

proposed remedy. The Masonic Homes, one of the stakeholders, expressed concerns t4at the PRAP

did not address potential groundwater quality and quantity uncertainties with respect to their long­

range water resource needs. The Alternate Remedial Plan specifically addresses these concerns by

providing an alternate water supply. Local government officials and PADEP's Act 2 have

expressed the desire for re-use of properties such as this, and the ARP provides for such re-use at

the Site. West Donegal Township has expressed concem that their Water Authority be involved in

the selection of an appropriate alternative water supply for the five (5) residential downgradient

water users. The Township, as a Stakeholder, will be involved in the Remedial Design Phase of the

project. Because many of the Elizabethtown Landfill PRPs endorse the ARP, it is anticipated that

the initiation of Remedial Design/Remedial Action could be expedited .

A3.7 Cost

The capital, O&M, and total present worth cost of the ARP is significantly .less than that of the

PRAP. The total present worth value of the PRAP is more than three times that of the ARP, does

not provide any greater level of risk reduction, and introduces the possibility of the previously

addressed implementation difficulties. The PRAP would require significant e."Cpense to attempt to

achieve the optimistic goal of restoring groundwater quality downgradient ~f the landfill, but this

expense is expected to provide little benefit because it is reasonably expected that sucll restoration

would be technically impracticable. The ARP and PRAP estimated costs are as follows:

Cost PRAP Alternative Remedial Element Estimate(!) Plan Estimate

Capital Cost $ 5,163.328 $ 1.072.991 Operation & Maintenance

Y cars 1 through 15 $ 1.206:505 $ 283,740 Years 16 througlt 30 $ 1.196.981 $ 283.740

Total Net Present Worth $ 26.146,677 $ 6.190.402

O> PRAP cost data taken from Alternative 7 of the FS.

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A3.8 State Acceptance

Based upon discussions with PADEP personnel and their review ofthe ARP, it is anticipated that

the Commonwealth will not oppose the implementation of the ARP as the remedy for the Site.

A3.9 Community Acceptance

The ARP is expected to be more acceptable than the PRAP to the local community because it

addresses long-term re-use of the Site and water resource issues. The Stakeholders, who include

the elected officials of the local communities, have commented on the ARP and generally support

the proposed remedy because it specifically addresses issues of concern.

4.0 RECOMMENDED REMEDY

The ARP and the PRAP are essentially equal in terms of Protection of Human Health and the

Environment, Compliance with ARARs, Long Tenn Effectiveness and Pennanence, Short-Tenn

Effectiveness, and State Acceptance. The ARP is superior to the PRAP for Implementability, Cost

and Community Acceptance.

The ARP is essentially equal to or superior to the PRAP with regard to the NCP criteria. The

PRAP does not provide any further risk reduction than the ARP, but i~ significantly more costly.

It is clear that the ARP provides a. remedy for the Site that achieves both NCP threshold criteria

while representing a superior balance of the remaining NCP criteria.

Recent Superfund administrative refonn initiatives have embraced " ... smarter cleanup choices

that protect public health at less cost" and emphasizes that "disproportionately costly remedies

are to be avoided" (USEP A. 1995). One of the policy measures of this refonn initiative is

establishing a. cost effectiveness threshold for ~election of protectiv~ ARAR-compliant remedies.

USEP A guidance currently requires review of remedies costing over $10 million where there is an

equally protective and compliant remedy that costs less than half of the proposed remedy. In these

cases, the ,guidance expresses the preference for the most cost effective protective remedy. Also,

the Superfund administrative refonn initiatives place strong emphasis on establishing greater

stakeholder role in remedy selection. Clearly, the ARP as generally supported by the stakeholders

meets both of these reform initiatives and is the appropriate remedy for the Elizabethtown Landfill

Site.

Golder Associates AR308205

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August 1996 18 923-6053.760

AS.O REFERENCES

Golder Associates Inc., "Remedial Investigation/Feasibility Study, Revised Final Remedial Investigation Report, Elizabethtown Landfill," 1994.

Golder Associates Inc:, "Remedial Investigation/Feasibility Study, Final Feasibility Study Report, Elizabethtown I.andfiiJ," 1995.

Haley, J.L, B. Hanson, C. Enfield, and J. Glass, 1991. "Evaluating the Effectiveness of Groundwater Extraction Remedies," Groundwater Monitoring Review. Vol. 11, pp. 119-124.

MacDonald, J.A., and M.C. Kavanaugh, 1994. "Restoring Contaminated Groundwater: An Achievable Goal?" Environmental Science and Technology. VoL 28, pp. 362A-368A.

National Research Council, 1994. Alternatives for Groundwater Cleanup. National Academy Press, Washington, DC.

Nyer, E.1993. "Aquifer Restoration: Pump and Treat and the Alternatives," Ground,..,-ater Monitoring and Remediation. Vol. 13, pp. 89-92.

Travis, C.C. and C.B. Doty, 1990. "Can Contaminated Aquifers at Superfund Sites Be Remed.iated?" Environmental Science and Technologv, VoL 24, pp. 1464-1466.

U.S. Environmental Protection Agency, 1988. Guidance on Remedial Actions for Contaminated Ground Water at Superfund Sites. EPA-540/G-88-003, OSWER Directive 9283.1-2, December 1988.

U.S. Environmental Protection Agency, 1989. Evaluation of GroundWater Extraction Remedies. EP A/540/2-89/054.

U.S. Environmental Protection Agency, 1993. Guidance for Evaluating the Technical Impracticabilitv of Ground-Water Restoration. Interim Final, OSWER Directive 92:34.2-25, September 1993.

U.S. Environmental Protection Agency, 1995. Superfund Administrative Reforms Overview. October 1995. ·

W~ W.W., 1996. "Diffusion: The Source.ofConfusion?" Ground Water. Vol. 34, pg. 193 .

Golder Associates ~R308206

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August1996 Table A1 Alternative Remedial Plan Cost Estimate

Elizabethtown landfill

Direct Capital Costs 1) Construct asphalt parking lot In south em area 25310 sy

Construct ditch along west side of southern area

3) Construct riprop toe drain along east side of southern area

1820 cy

60 cy

130 cy

80ft

4) Place riprap In certain trenches In northern a,rea

5) Replace CMP culverts

Operation and Maintenance Costs 1) Maintain landfill cover

a) Erosion and sedimentation repair b) Mowing

2) Maintain surface water control system

Gas (LEL) monitoring

Taxes and pennlt fees

D:\923-0053\REVPLAN\TAOA1.XLS

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1 ls/yr

1 ls/yr

1 ls/yr

· Golder Associates

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$13.28 /sy

$4.39 /cy

$29.81 /cy

$29.81 /C'f

$28.24 1ft

! $125,000 /acre $2,000 ns $3,000 ns

$500 ns

$4,409 ns

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$336,223IMeans '94 025104 0200 Means '94 025 104 0460

$7,990 Means '94 022 ~54 0050

$1,789 Means '94 022 712 0100

Means '94 022 712 0100

'94 027164 2140

--df:~~~ti:h::::::::::·:-:-:-:-:·:.;·:-:·:·

$11,373 Eng.lneerlng Esllmate $2,000 Engineering Esllmate

$3,000 Engineering Estimate

$500 Engineering Estimate

$4,409 Engineering Esllmate

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.ableA1 August. Alternative Remedial Plan Cost Estimate

Elizabethtown Landfill

Direct Capital Costs 1) Fence

Establish lnslilullonal controls/deed restrictions

Indirect Capital Costs Engineering Design (16%)

Contingency (20%)

Operation and Maintenance Costs 1) Maintain fence/gales/signs

a) Fence replacement b) Gales - replace 1 per 30 years c) Signs - replace 5 per 30 years

2) Operate and maintain existing active gas collection system and flare

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1 Is

50 lflyr 1 Is 1 Is

1 Is

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$15.69 IJf

$20,000 /Is

$15.69 /If $1,000 /Is

$100 /Is

$5,000 /Is

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$22,6721Means '94 026 306 0800

$20,000 !Engineering Estimate (1)

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August 199,6 Table A1 Alternative Remedial Plan Cost Estimate

Elizabethtown Landfill

GROUNDWATER COMPONENT OPTION

Direct Capital Costs 1) Replace Masonic Homes Well EM-400 (sl,le and lnstaU) 1 Is $50,000 /Is

2) Two-year Groundwater Monitoring/Modeling Program 1 Is $300,000 /Is

3) Upgrade leachate management system 1 Is $50,000 /Is

·.-.... -.-.-.. -.-.--

, Maintenance Costs 1) Groundwater and surface water monitoring 1 ls/yr $150,000 /Is

2) Maintain groundwater moflltortng system 1 ls/yr $8,333 /Is

3) Leachate collection system a) Maintenance 1 ls/yr $2,750 /Is b) Operation 360000 gaUyr $0.12 /Is

.f) Provision ot alternative water supply to residents 1 ls/yr $4,000 /Is

• Golder Associates • 0:\923-0053\REVPLAN\T ABA 1 J<LS

923-6053

$50,000 I Estimated

$300,000 I Estimated

$50,000 Estimated

I $8,333fEnglneerlng Estimate

$2,750 Engineering Estimate $43,200 Engineering Estimate

$4,000 Engineering Estimate

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August 1.

Notes:

.. bleA1 Alternative Remedial Plan Cost Estimate

Elizabethtown Landfill

(1) Based upon an Inflation rate of 3%, a discount rate of 6%, and a 30-year O&M period. (2) The numbers presented here are estimates only. Actual costs will be refined during Remedial Design.

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(3) The Total Capital Cost. and Total Present Worth O&M Cost for the Alternative Is the sum of the values for the Individual components.

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