industrial lane superfund site proposed changes to remediation plan

8/20/2019 Industrial Lane Superfund site proposed changes to remediation plan

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8/6/15 DRAFT

DRAFT SECOND EXPLANATION OF SIGNIFICANT DIFFERENCES

for the

INDUSTRIAL LANE SUPERFUND SITE

WILLIAMS TOWNSHIP, NORTHAMPTON COUNTY, PENNSYLVANIA

I. INTRODUCTION

Site Name: Industrial Lane Superfund Site

Site Location: Williams Township, Northampton County, Pennsylvania

Lead Agency: U.S. Environmental Protection Agency, Region III

Support Agency: Pennsylvania Department of Environmental Protection

Statement of Purpose

The U.S. Environmental Protection Agency (EPA) is issuing this draft Explanation of

Significant Differences (ESD) in accordance with Section 117(c) of the ComprehensiveEnvironmental Response, Compensation, and Liability Act, as amended (CERCLA), 42 U.S.C.

§ 9617(c), and Section 300.435(c)(2)(i) of the National Oil and Hazardous Substances Pollution

Contingency Plan (NCP), 40 C.F.R. § 300.435(c)(2)(i). Section 117(c) of CERCLA and Section300.435(c)(2)(i) of the NCP require the publication of an explanation of significant differences

when modifications to the selected remedy are necessary, and such modifications significantlychange, but do not fundamentally alter, the remedy selected in a Record of Decision (ROD) with

respect to scope, performance, or cost.

On March 29, 1991, EPA issued a ROD that selected a remedy for Operable Unit 2(OU2) at the Industrial Lane Superfund Site (Site). The remedy selected in the OU2 ROD

included: (1) closure of the unlined portion of the landfill; (2) extraction, treatment, and

discharge of contaminated groundwater; and (3) long term monitoring of the groundwater andthe landfill closure. On December 5, 1996, EPA issued the first Explanation of Significant

Differences (1996 ESD) modifying the remedy selected in the OU2 ROD. The remedy selected

in the OU2 ROD, as modified by the 1996 ESD, will be referred to in this draft second ESD asthe “OU2 Remedy”.

This second ESD is a draft document. This draft document has been prepared to providethe public with an explanation of, and an opportunity to comment on, EPA’s proposal to modify

the OU2 Remedy for the second time. This proposed second ESD modifies the OU2 Remedy by

requiring the implementation of institutional controls (ICs) at the Site. The ICs will prohibit

activities at the Site that would adversely impact the OU2 Remedy and compromise the protection of human health and the environment. This draft ESD summarizes the information

that supports the proposed modification and confirms that the OU2 Remedy, as revised by this

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proposed modification, will continue to comply with the statutory requirements of Section 121 of

CERCLA, 42 U.S.C. § 9621.

The modification proposed in this draft ESD will significantly change, but not

fundamentally alter, the OU2 Remedy with respect to scope, performance, or cost. EPA will

accept comments on the proposed modification to the OU2 Remedy during a 30-day publiccomment period. Once the public comment period closes, comments, if any, will be evaluated,

this draft will be revised, if appropriate, and a final decision document may be signed and issued

by EPA.

This draft ESD and the information EPA has relied upon or considered to date in

proposing this ESD, are being added to the Administrative Record for the Site in accordancewith Section 300.825(a)(2) of the NCP, 40 C.F.R. § 300.825(a)(2). The Administrative Record

is available for public review at the locations listed below:

Mary Meuser Memorial Library

1803 Northampton StreetEaston, PA 18042

(610) 258-3040Hours: Tuesday – Thursday: 9:45 am to 8:00 pm

Friday: 9:45 am to 5:00 pm

Saturday: 9:00 am to 4:00 pm

U.S. Environmental Protection Agency, Region III

Administrative Record Reading Room1650 Arch Street

Philadelphia, PA 19103-2029(215) 814-3157

Hours: Monday – Friday: 8:00 AM to 4:00 PM

Please call to schedule an appointment.

The Administrative Record is also available online at:

http://loggerhead.epa.gov/arweb/public/advanced_search.jsp

II. SUMMARY OF SITE HISTORY, CONTAMINATION, AND SELECTED

REMEDY

A. Site History and Contamination

The Site is located in Williams Township, Northampton County, Pennsylvania. Although

the name of the Site is listed as the Industrial Lane Site on the National Priorities List (NPL), the

Site is actually located on Industrial Drive. The Site is also part of an operating landfill known

as Chrin Brothers Sanitary Landfill. The Site borders on the city limits of Easton, Pennsylvania

and is located approximately 15 miles east of Allentown, Pennsylvania. The communities of

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Glendon Borough and Lucy’s Crossing are located northwest and west of the Site, respectively.

Figure 1 shows the location of the Site.

The Chrin Brothers Sanitary Landfill began operations at the Site in 1961. On June 2,1975, the Pennsylvania Department of Environmental Protection (PADEP) (f/k/a Pennsylvania

Department of Environmental Resources) issued a municipal waste management permit (Permit No. 100022) to the landfill to operate as a natural renovation sanitary landfill that was approvedto receive municipal solid waste. A liner was not required to be placed on the surface prior to

placing waste material. By 1980, the landfill had expanded to 30 acres.

Groundwater contamination was detected in local wells in 1983. As a result, in 1984,EPA placed the Site on the NPL. The Site includes the unlined portion of the Chrin Landfill that

encompasses approximately 30 acres, and the adjacent areas under which contaminated

groundwater is located. The 30-acre portion of the landfill is identified in Figure 1 as the

“Approximate Site Location”.

In 1986, EPA completed a Remedial Investigation/Feasibility Study (RI/FS) for the Site.The RI evaluated the nature and extent of Site contamination and determined that local

groundwater was contaminated with volatile organic compounds (VOCs). The Site wasseparated into two operable units. Operable Unit 1 (OU1) addressed the private well users in the

vicinity of the Site. OU2 addressed the contaminated groundwater. In 1991, EPA conducted a

Focused Feasibility Study which developed and evaluated remedial alternatives to address thecontaminated groundwater at the Site.

B. Selected Remedy

In 1986, EPA issued a ROD for OU1 at the Site, which focused on the private well users

in the vicinity of the Site and addressed the threat to human health in the area from drinkingcontaminated groundwater. The selected remedy in the OU1 ROD involved connecting private

well users in Glendon Borough and Lucy’s Crossing to existing public water mains. The OU1

remedial action was completed in 1989.

On March 29, 1991, EPA issued the OU2 ROD to address contaminated groundwater at

the Site and the potential for the continued release of contaminants posed by the unlined portion

of the landfill. The groundwater remedy consisted of the following three elements: (1) properclosure of the unlined portion of the landfill; (2) extraction, treatment, and discharge of

groundwater to the Lehigh River; and (3) long-term monitoring of the groundwater quality and

the landfill closure.

On December 5, 1996, EPA issued the 1996 ESD, which revised certain requirements of

the OU2 ROD as follows: (1) The 1996 ESD revised the OU2 ROD cap requirements from the

closure regulations set forth in Section 273.234 of the Pennsylvania Municipal Waste

Management Regulations to the abatement regulations set forth in Section 273.287. The

abatement regulations in Section 273.287 are applicable to landfills closed prior to April 9, 1988.

The 1996 ESD confirmed that the cap installed on the unlined portion of the landfill complied

with the applicable abatement regulations set forth in Section 273.287 that were in effect at the

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FIGURE 1

SITE LOCATION

M P

CITY OF EASTON

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landfill obtained a valid discharge permit from PADEP under the National Pollution Discharge

Elimination System (NPDES) program. As a result, a treatment plant was constructed at the Site

and treated water is discharged under the NPDES permit to a small tributary by Morville Road

which leads to the Lehigh River; and (3) The 1996 ESD revised the groundwater clean-up goalsfrom "background" concentrations to the Maximum Contaminant Levels (MCLs) set forth in 40

C.F.R. § 141.61 or the non-zero Maximum Contaminant Level Goals (MCLGs) set forth in

40 C.F.R. § 141.50, whichever are more stringent, pursuant to the Safe Drinking Water Act,42 U.S.C. § 300f et seq. In the case of 1,1-dichloroethane, for which there was no MCL or non-

zero MCLG, the cleanup standard was changed to the Medium Specific Concentration (MSC)

developed by PADEP, using standard EPA risk assessment guidance, for use under thePennsylvania Land Recycling and Environmental Remediation Standards Act (Act 2), 35 P.S.

§§ 6026.101 et seq.

The landfill operator, Chrin Brothers, Inc., implemented the OU2 Remedy under the

oversight of PADEP and EPA. A cap was constructed in 1993 over the unlined portion of thelandfill. A groundwater treatment plant and associated features including extraction wells were

constructed in 1999. On June 29, 1999, EPA signed a Preliminary Close-Out Report, at whichtime the Site achieved construction completion status.

The landfill operator continues to operate the groundwater extraction and treatment plantand conduct operation and maintenance activities at the Site. EPA performs oversight functions

including conducting Five-Year Reviews to evaluate the protectiveness of the remedy. Based on

these reviews, EPA issued Five-Year Review Reports for the Site on the following dates: June10, 1997, September 29, 2003, September 30, 2008, and September 25, 2013.

C. Remedial Action Objectives

The remedial action objectives of the OU2 Remedy are to eliminate the threat to human

health and the environment from the continuing contamination of the groundwater by chemicalsdisposed of in the landfill, and to restore the groundwater to its beneficial use.

D. Recent Events

On the evening of March 12, 2013, landfill materials in an area identified as Stage 3D

and 3E of the active Chrin Brothers Sanitary Landfill suddenly moved about 60 feet at the top portion of the landfill and about 80 feet at the base of the landfill, affecting approximately 10

acres near the perimeter of the facility. The landfill operator is removing the liner under the

waste, the disposed waste materials, and the cover over the waste from the slide area and placingthem in a new portion of the landfill that is lined. This work started the next day, March 13,

2013, and is still in progress. The wells that were impacted by the slide of landfill materials have

been rehabilitated and are now used again in all sampling events.

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III. DESCRIPTION OF SIGNIFICANT DIFFERENCES AND THE BASIS FORSUCH DIFFERENCES

The OU2 Remedy provided that if EPA, in consultation with PADEP, determined that the

cleanup standards could not be reached in certain portions of the aquifer, then certain measuresinvolving long-term management could be taken.

One of the measures set forth in the OU2 ROD that could be taken if the cleanupstandards could not be reached and the aquifer could not be restored to its beneficial use, is

implementation of institutional controls (ICs) to restrict access to those portions of the aquifer

which remain above cleanup standards. The OU2 ROD provides that certain measures may betaken by EPA, in consultation with PADEP, and may require a modification to the OU2 Remedy.

Although EPA has not determined that the aquifer cannot be restored to its beneficial use,

EPA noted, in the course of performing the third Five-Year Review of the Site, that ICs

restricting access to portions of the aquifer which have groundwater contaminants abovecleanup levels had not been implemented at the Site. EPA recommended in the Third Five-Year

Review Report, issued on September 30, 2008, that ICs should be evaluated based on the currentsize and concentration of the contaminated groundwater plume and implemented where

necessary. In the Fourth Five-Year Review Report, issued on September 25, 2013, EPA also

recommended modifying the remedy to require ICs to restrict groundwater use and prohibitactivities that would interfere with or damage the integrity and protectiveness of the remedy.

Accordingly, in this draft ESD, EPA is proposing to modify the OU2 Remedy to requireimplementation of ICs to prohibit certain activities at the Site, to ensure that activities at the Site

will not adversely impact the OU2 Remedy and to protect human health and the environment.

One of the proposed ICs prohibits the construction of new wells at the Site, unless EPA

in consultation with PADEP determines that such action will not adversely impact the OU2

Remedy. This measure is needed because the groundwater treatment plant and the associatedextraction and monitoring wells work in conjunction to evalutate, pump, and treat the

contaminated groundwater, and any type of new well may adversely affect the proper operation

of the groundwater treatment system. A new well could adversely affect the capture ofgroundwater in the area where the extraction wells pump groundwater to be treated by the

groundwater treatment plant. Additionally, a new well could influence the groundwater flow that

is currently being evaluated by the monitoring well network to evaluate the progress of theremediation.

Another proposed IC prohibits the use of untreated contaminated groundwater at the Site.Groundwater at the Site is currently contaminated above groundwater cleanup standards, MCLs,

and therefore poses a risk to human health. The OU2 ROD identifies VOCs as the prinicipal

contaminants in the groundwater, summarizes the risk assessment, and selects a remedy. As

described in the OU2 ROD, the risk assessment showed an excess cancer risk to humans usingthe groundwater for drinking water purposes. As a result of this risk, EPA selected a remedy for

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the landfill cap and groundwater. The OU2 ROD determined that the remedy would protect

human health and the environment and would reduce the risk to an acceptable level.

The former landfill and the extraction and certain monitoring wells are included in the

Abatement Zone Area shown in Figure 2. The extraction wells pump contaminated groundwater

and then it is conveyed to the groundwater treatment plant. The groundwater treatment planttreats the contaminated groundwater and discharges the treated groundwater as an effluent that

meets the NPDES requirements to a stream. The NPDES requirements ensure that the effluent

complies with the water quality criteria to protect the stream. On occasion after the groundwateris treated in the treatment plant it is used for landfill operations. For example, the treated water is

used for dust control of the landfill operations which is an acceptable use under the proposed

ICs. While the groundwater remedy is operating, use of the effluent should be resticted to landfilloperations like dust control and discharged in the approved permit location.

The effluent from the treatment plant complies with NPDES requirements and is not a

source for public drinking water. The Chrin facility has a source of public drinking water that is

provided by the Easton City Water Authority. Additionally, there is a fire hydrant on the landfill property that would provide the water used for any fire suppression on the landfill property.

The 1996 ESD established the MCLs as the groundwater cleanup standards at the Site.

The cleanup standards (MCLs), which must be met in the pumping and monitoring wells in the

Abatement Zone Area (see Figure 2) for the completion of the remedy, are to ensure that thegroundwater is restored to MCLs. The MCLs are not equivalent to the concentrations required in

the NPDES permit. The NPDES permit establishes allowable discharge concentrations based on

complying with the water quality criteria to protect the receiving stream. Thus, it is appropriateto restrict use of groundwater, and restrict use of treated groundwater, to landfill operations.

The proposed ICs also prohibit activities that could disturb or otherwise adversely impact

the landfill cap and/or the groundwater treatment plant. The landfill cap and the groundwater

treatment plant are components of the OU2 Remedy. The landfill cap is essential to ensure that

the waste is contained under a cover as well as to prevent any potential exposures to humanhealth and the environment. The operation of the groundwater treatment plant ensures that the

contamination is treated until the groundwater cleanup standards are achieved in the Abatement

Zone Area marked on Figure 2. Additionally, the groundwater treatment plant captures thecontamination and prevents it from migrating. Therefore, prohibiting activities that could disturb

the OU2 Remedy are necessary.

Figure 2 shows the approximate Abatement Zone Area that includes the pumping wells

and monitoring wells used to evaluate contaminant levels in the groundwater for the Site.

Monitoring wells outside of the Abatement Zone Area are marked in Figure 2 as Non-AbatementZone Groundwater Monitoring Wells and are not considered part of the Site remedy. The

Abatement Zone Area also includes the Former Approximate 30-Acre Landfill (Fill Areas 1, 2,

and 3) marked on Figure 2, which was the original unlined area of disposal. The Abatement

Zone Area is the area where the ICs related to groundwater contamination, the extraction andtreatment of contaminated groundwater, and the landfill cap are proposed to apply. Figure 3

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shows the location of the treatment plant, labeled “Groundwater Treatment Plant”, where ICs are

also proposed to apply.

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A. Documentation of Institutional Controls (ICs)

The Site is part of a currently operating landfill, Chrin Brothers Sanitary Landfill, which

operates under a permit issued by PADEP. ICs are necessary at the Site (1) to restrict activities

that could interfere with the landfill cap and the groundwater treatment plant and its associated

components (including piping, monitoring and extraction wells); and (2) to restrict use ofcontaminated groundwater from beneath the Site without treatment. The proposed ICs shall

include the following restrictions in order to protect the OU2 Remedy and human health and the

environment.

The OU2 Remedy has been implemented and is currently operated and maintained, but it

has not achieved the cleanup standards set forth in the 1996 ESD. Until such time as the cleanupstandards are achieved and documented, these ICs are necessary, as described above.

Specifically, if, in the future, the 1996 ESD cleanup standards are achieved for all the Abatement

Zone monitoring and extraction (pumping) wells, and if EPA, in consultation with PADEP, can

remove the NPDES requirement for the discharge of treated water from the Site, then, the ICs

will be re-evaluated at that time.

1. New well construction of any type is prohibited on the Site, unless EPA in

consultation with PADEP determines that such action will not adversely impact the

OU2 Remedy.

2. Groundwater at the Site shall not be used for any purpose unless the groundwater is

treated. Treatment of groundwater is defined as groundwater that has been treated by the groundwater treatment plant and meets the discharge values in the NPDES

permit. Treated groundwater shall not be used for any purpose except landfilloperations including dust control.

3. Actions that could interfere with, obstruct, or disturb the operation or maintenance of

the groundwater treatment plant, the groundwater extraction wells and monitoringwells, discharge piping, or any other accessories associated with the OU2

groundwater treatment remedial action and operations required under the NPDES

permit are prohibited at the Site, unless EPA in consultation with PADEP determinesthat such action will not adversely impact the OU2 Remedy.

4. Maintain the landfill cap in accordance with Chapters 271 and 273 of thePennsylvania Municipal Waste Management Regulations. Activities that could

disturb or otherwise adversely impact the landfill cap are prohibited, unless EPA in

consultation with PADEP determines that such activity will not adversely impact theOU2 Remedy. Routine operation and maintenance activities are acceptable actions

under this IC.

5. Provide PADEP, EPA, and their representatives, contractors, and subcontractors,with access at all reasonable times to the Site to conduct any activity relating to

response actions at the Site.

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The required ICs may be implemented through an environmental covenant entered into by the owner of the Site property pursuant to the Pennsylvania Uniform Environmental

Covenants Act, 27 Pa. C.S.A. §§ 6501 - 6517, and recorded with the deed for the Site property.

IV. SUPPORT AGENCY COMMENTS

In accordance with 40 C.F.R. § 300.435(c)(2), EPA has consulted with PADEP

concerning the changes to the OU2 Remedy proposed in this draft ESD. (EPA anticipatesreceiving a letter from PADEP with its position on the proposed changes. This section of the

final ESD will indicate the date such a letter was received.)

V. STATUTORY DETERMINATIONS

EPA has determined that the modified remedy described in this ESD complies with the

statutory requirements of Section 121 of CERCLA, 42 U.S.C. § 9621. EPA has determined that

the OU2 Remedy, as modified by this second ESD, will remain protective of human health andthe environment, will comply with Federal and State requirements that are applicable or relevant

and appropriate to this remedial action, and will be cost-effective.

VI. PUBLIC PARTICIPATION

EPA will accept comments on this proposed modification to the OU2 Remedy previously

selected for the Site during a 30-day public comment period beginning August 14, 2015, and

ending September 13, 2015. Once the public comment period closes, EPA will evaluatecomments received, revise this draft, if appropriate, and issue a final decision document. The

Administrative Record for this decision will contain all the information that EPA considers orrelies upon in making its remedy decision, including the draft ESD and any comments thereon.

The Administrative Record is available for public review at the locations listed in Section I of

this ESD. Comments concerning EPA’s action should be directed to:

Roy Schrock

Remedial Project Manager (3HS22)

U.S. EPA Region III1650 Arch Street

Philadelphia, PA 19103

(215) 814-3210

Pursuant to Sections 117(c) and (d) of CERCLA, 42 U.S.C. § 9617(c) and (d), and

Section 300.435(c)(2)(i)(B) of the NCP, 40 C.F.R. § 300.435(c)(2)(i)(B), EPA will publish anotice in the Easton Express newspaper on August 14, 2015, summarizing this proposed ESD

and informing the public of its availability and the 30-day public comment period.

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VII. SIGNATURE

This Explanation of Significant Differences modifies the OU2 Remedy set forth in the

OU2 ROD, as modified by the 1996 ESD, for the Industrial Lane Superfund Site to include

institutional controls.

Approved by:

Cecil Rodrigues, Director DateHazardous Site Cleanup Division

EPA Region III

Note: Following the public comment period and appropriate revisions, if any, the ESD may be

signed and issued by EPA as a final decision.

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industrial lane superfund site proposed changes to remediation plan

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