UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III
Four Penn Center
1600 John F. Kennedy Boulevard
Philadelphia, Pennsylvania 19103-2852

SUBJECT: Long-Term Stewardship Desktop Assessment

Lear Corporation - Lear Dye and Finishing Plant
EPA ID: PAD002377703
1 Penn Dye Street
Pine Grove, PA 17963

April 17, 2023

Alizabeth Olhasso, Chief
RCRA Corrective Action Section South

Priscilla Ortiz, RPM

Long-Term Stewardship File for Lear Corporation
RCRA Corrective Action Section South

REMEDY ASSESSMENT SUMMARY:

On September 29, 2015, in a Final Decision and Response to Comments (FDRTC or Final
Remedy), EPA announced its selection of a final remedy for Lear Corporation (Lear/Facility)
located at 1 Penn Dye Street, Pine Grove, PA. The Final Remedy requires the continuation of
pumping and treatment of groundwater until Maximum Contaminant Levels (MCLs) are met or
EPA determines such activity is no longer necessary, maintaining the existing asphalt cap in
compliance with the EPA approved Post Remediation Care Plan (PRCP) and implementing land
and groundwater use restrictions designed to minimize the potential for human exposure to
contaminants. EPA concludes the Facility meets the objectives of the 2015 FDRTC and 2018
Environmental Covenant (EC).

INTRODUCTION:

Long-term stewardship (LTS) refers to the activities necessary to ensure that engineering
controls (ECs) are maintained and that institutional controls (ICs) continue to be enforced. The
purpose of the EPA Region 3 LTS program is to periodically assess the efficacy of the
implemented remedies (i.e., ECs and ICs) and to update the community on the status of the
RCRA Corrective Action facilities. The assessment is conducted in twofold, which consists of a
record review and a field inspection, to ensure that the remedies are implemented and maintained
in accordance with the final decision.

FACILITY BACKGROUND:

The Lear Corporation - Lear Dye and Finishing Plant (formerly Guilford Mills, LLC) consists of
3 3-acres located at the intersection of Penn Dye Street and Tulpehocken Street in Pine Grove
Borough, Schuylkill County, Pennsylvania. Swatara Creek divides the Facility roughly in half
and flows to the southeast in the vicinity of the Facility. The Facility consists of a main

DATE:
TO:

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manufacturing building, a wastewater treatment plant, and a man-made reservoir. Since 1960, the
Facility has been used to dye and finish textiles.

In 1989 former Guilford Mills, Inc. discovered soil and groundwater contamination had occurred
at the Facility as the result of industrial operations. In September 1992 the Facility entered into a
Consent Decree with EPA and completed various investigations and remedial actions to address
this contamination. Pursuant to the Order, the Facility began pumping groundwater from three
production wells to provide containment of contaminated groundwater, installed a granular
activated carbon treatment system to treat contaminated water pumped from the most-impacted
production well, and continued use of the on-site reservoir for storage of pumped groundwater.
The Order also required the Facility to conduct a RCRA Facility Investigation (RFI) and prepare
a Corrective Measures Study (CMS).

As a result of these efforts, the groundwater and soil contamination at the Facility have been
significantly reduced. However, tetrachloroethylene (PCE), trichloroethylene (TCE), 1,1-
dichloroethene (1, 1-DCE), cis-l,2-dichloroethene (cis-l,2DCE), and vinyl chloride (VC) were
found at levels exceeding their applicable MCLs in a limited number of groundwater monitoring
wells, and their applicable Regional Screening Level for residential soil in areas covered by an
existing asphalt cap.

In December 2003 a soil vapor extraction (SVE) system was installed and began operations as a
remedy for soils. The permanent shutdown of the soil SVE system was approved in September
2011 after a temporary shutdown and soil sampling event demonstrated that the system had
adequately remediated soils in the source area beneath the Facility.

The alternative remedial measure of an aeration system in lieu of the carbon adsorption system to
further reduce the low levels of remaining groundwater contamination beneath the Facility was
approved in May 2012. Results from an 8-month pilot study of the aeration system demonstrated
that the performance of the system (i.e., chlorinated volatile organic removal efficiency) is
comparable to the removal efficiency of the carbon adsorption system.

Lear submitted a Resource Conservation and Recovery Act (RCRA) Closure Report in April
2015, that included the characterization of sediments in the water reservoir, the performance of a
well survey, and the discussion of institutional and engineering controls anticipated to be part of
the Final Remedy for the Facility. Results from the sediment sampling suggested that the
reservoir is not contaminated above appropriate risk-based levels. The well survey identified 17
wells within a half-mile radius of the Facility; however, none of these wells are used for potable
purposes as all properties within this area are served by a public water supply. Finally, an
analysis of the groundwater pumping system demonstrated that it maintains capture of
contaminated groundwater on-site and could thus be used as a component of the Final Remedy
for the Facility.

On September 29, 2015, EPA selected a Final Remedy for the Facility in a FDRC. The terms of
the Final Remedy are as follows:

1. Soils

• Implement and comply with an EPA-approved Post Remediation Care Plan specifying


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how the asphalt cap over the area surrounding the manufacturing building shall be
maintained to limit the migration of contaminants into the groundwater.

•	Because contaminants will remain in Facility soils above levels appropriate for
residential use, the proposed remedy for soils includes land use restrictions to restrict the
Facility to non-residential. The proposed use restriction will be implemented through an
institutional control such as an enforceable permit, order and/or Environmental Covenant
pursuant to the Pennsylvania Uniform Environmental Covenants Act, 27 Pa. C.S.
Sections 6501-6517 (UECA) to be recorded with the deed for the Facility Property.

2. Groundwater

•	Pump groundwater at the Facility at a rate sufficient to prevent the off-site migration of
contaminants in excess of MCLs;

•	Treat the pumped groundwater to reduce concentrations of chlorinated VOCs to allow 1)
its use in manufacturing operations, 2) its discharge into Swatara Creek under NPDES
permit, or 3) its discharge to the local municipal sewer under permit with the municipal
sewer authority, and

•	Perform annual groundwater sampling of wells CMS-IS, CMS-ID, Ml ID, PW-1 and
PW-4 for PCE and its degradation products.

On February 2, 2018, EPA issued an Environmental Covenant with the following activities and
use limitations:

•	The Facility shall not be used for residential purposes.

•	Groundwater may be used for industrial purposes; however, groundwater shall not be
used as potable water.

•	Comply with the terms of the PRCP.

•	On an annual basis and when requested by PADEP or EPA, submit a written certification
of compliance with all terms of the Final Remedy.

•	The Facility shall not be used in any way that would adversely affect the protectiveness
of the Final Remedy.

EARTHRES workers conducted the 2022 annual groundwater sampling event at the Lear site on
August 17, 2022. RCRA monitoring wells Ml ID, CMS-ID, and CMS-IS, as well as production
wells PW-1 and PW-4, were used to collect groundwater samples. A PADEP official was on-site
during this sampling session to evaluate sample collection techniques and collect split-samples.
An analysis of the VOCs tested during the 2022 annual groundwater sampling event revealed
that most of the VOCs were either not measured over the laboratory reporting limit (RL) or
remained within their respective historical ranges. EPA MCL exceedances were observed at
monitoring well Ml ID (PCE), and at production well PW-4 (PCE and TCE). No EPA MCL
exceedances were observed at monitoring wells CMS-IS and CMS-ID and production well PW-
1 during the 2022 annual groundwater sampling event.

CURRENT SITE STATUS:

Lear continues to operate as a synthetic fabric dyeing and finishing facility. Groundwater Pump
and Treat System is operating, asphalt capped areas are inspected monthly, and the groundwater
sampling event is conducted annually. Areas of the asphalt cap require maintenance and Lear is
scheduled to complete this work during 2023.


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INSTITUTIONAL CONTROLS (ICs) STATUS:

An Environmental Covenant restricts the Facility land use to non-residential purposes and
prohibits groundwater use for any purpose other than industrial usage.

ENGINEERING CONTROLS (ECs) STATUS:

Engineering controls include maintenance of the existing asphalt cap to limit the migration of
contaminants into groundwater, and the pump and treat system to present off-site migration of
groundwater contaminated above MCLs and reduce concentrations of chlorinated volatile
contaminants in groundwater.

MAPPING:

The Facility property boundary has been geospatially mapped. The geospatial map is available at
the Facility's EPA Factsheet (https://www.epa.gov/hwcorrectiveactioncleanups/hazardous-
waste-cleanup-penn-dye-and-finishing-plant-pine-grove) under the "Reports, Documents and
Photographs" section.

CONCLUSION:

EPA concludes that the implemented remedies are effective in meeting the objectives of
protection of human health and the environment. Lear Corporation will continue to implement
the remedies set forth in the FDRC and Environmental Covenant. To ensure that ICs and ECs are
consistent and continued to be enforced at the Facility, Lear will submit results of annual
groundwater sampling events. The Pump and Treat System continue to demonstrate that the
pumping of PW-1 and PW-4 influence the deep aquifer and prevent the offsite migration of
contaminants in excess of the MCLs. During 2022, Lear personnel completed monthly
inspections of the asphalt capped area. Areas of the asphalt cap require maintenance and Lear is
scheduled to complete this work during 2023.

FILES REVIEWED

Environmental Indicator Groundwater, Prepared by EPA January 2002
Environmental Indicator Human Health, Prepared by EPA January 2002
Statement of Basis, Prepared by EPA August 2015

Final Decision and Response to Comments, Prepared by EPA September 2015
Environmental Covenant, Prepared by EPA February 2018

2022	Certification of Compliance- Final Remedy, Prepared by EARTHRES Group, Inc. April

2023


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Map of Facility

PENN DYE & FINISHING PLANT

1 Penn Dye Street

Pine Grove, PA 17963

EPA ID: PAD002377703	n

| | CAPPED_AREA	A

ENVIRONMENTAL_COVENANT_AREA

ENTIRE_FACILITY
			.	_	»¦- _ ¦

!


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Engineering Control/Institutional Control
Corrective Action Remedy Summary

Facility Name

Lear Corporation - Lear Dye and Finishing Plant

Address

1 Penn Dye Street, Pine Grove, PA 17963

EPA ID Number

PAD002377703

Arc there restrictions
or controls tlisit
;i (Id less:

Yes

No

A rests

Description of
rest rid ions, cont rols.
sind niechsHiisni

Groundwater

X



Entire Facility

Industrial or remedial
purposes only.

Residential Use

X



Entire Facility

Nonresidential use only.

Excavation



X



Contaminated soil was
removed.

Vapor Intrusion



X





Capped Areas

X



Entire Facility

The area surrounding the
manufacturing building
was capped with asphalt.

Other Engineering
Controls

X





Groundwater Pump and
Treat System currently
active

Other Restrictions

X





Use of groundwater on
site without treatment is
prohibited.

LTS Checklist Template

IC Review and Assessment Ouestions:

Yes

No

Notes

• Have the ICs specified in the remedy been fully
implemented? Implementation mechanism in place?

X





• Do the ICs provide control for the entire extent of
contamination (entire site or a specific portion)?

X





• Are the ICs eliminating or reducing exposure of all
potential receptors to known contamination?

X






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• Are the ICs effective and reliable for the activities
(current and future) at the property to which the
controls are applied?

X





• Have the risk of potential pathway exposures
addressed under Corrective Action changed based on
updated screening levels and new technologies?



X



• Are modifications to the IC implementation
mechanism needed? (i.e. UECA Covenant, Permit or
Order)



X



• Are there plans to develop or sell the property?



X



• Have all reporting requirements been met?

X







Groundwater Review and Assessment Ouestions:

Yes

No

Notes









• Is groundwater onsite used for potable purposes?



X

Groundwater is restricted to
industrial and remedial
purposes.

• Is the Facility connected to a public water supply?



X



• Have any new wells been installed at the facility?



X



• Are the current groundwater flow rate and direction
similar as mentioned in the previous studies?

X





• Groundwater contaminants stable or decreasing in
concentration?

X





• Are groundwater monitoring wells still in place (#
wells)?

X





• Any evidence or reason to re-evaluate the number
and location of monitoring points and/or monitoring
frequency?

X





• For wells where groundwater monitoring is no longer
required, have the wells be decommissioned?



X



• Is there evidence of monitored natural attenuation
occuring in groundwater?

X





• Has (active remediation system) been maintained as
necessary?

X






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• Is the (groundwater containment system) effectively
containing COCs and protecting potential receptors
(surface water body and/or groundwater resource) via
hydraulic control?

X





• Have notification letters been sent to the local
POTW, County Department of Health, and Planning
and Zoning Department regarding groundwater use
restrictions?





N/A



Surface and Subsurface Soil Review and
Assessment Ouestions:

Yes

No

Notes

• Is the facility being used for residential purposes?



X



• Have there been recent construction or earth-moving
activities or plans for such?



X





Engineered Can or Cover Review and Assessment

Yes

No

Notes

Ouestions:



• Have geosynthetic/vegetative landfill caps (name)
been properly maintained?

X



N/A

• Have any repairs been necessary? (i.e. regrading,
filling, root removal)

X



A 2022 inspection observed
that some areas required
maintenance. This work will
be completed in 2023.

• Is the leachate collection system operating and
effectively preventing groundwater contamination?





N/A


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