SIXTH FIVE-YEAR REVIEW REPORT FOR
BUTZ LANDFILL SUPERFUND SITE
MONROE COUNTY, PENNSYLVANIA

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AUGUST 2021

Prepared by

U.S. Environmental Protection Agency
Region 3
Philadelphia, Pennsylvania

Digitally signed by
LINDA DIETZ
Date: 2021.08.06

08:48:33 -04'00'	AllgUSt 6, 202 1

Linda Dietz, Acting Director	Date

Superfund and Emergency Management Division
U.S. EPA, Region 3

LINDA
DIETZ


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Table of Contents

LIST 01 ABBREVIATIONS AND ACRONYMS	2

I.	INTRODUCTION	3

Site Background	3

FIVE-YEAR REVIEW SUMMARY FORM	4

II.	RESPONSE ACTION SUMMARY	4

Basis for Taking Action	4

Response Actions	5

Status of Implementation	7

Systems Operations/Operation and Maintenance	13

III.	PROGRESS SINCE THE PREVIOUS REVIEW	13

IV.	FIVE-YEAR REVIEW PROCESS	14

Community Notification, Community Involvement and Site Interviews	14

Data Review	16

Site Inspection	21

V.	TECHNICAL ASSESSMENT	22

QUESTION A: Is the remedy functioning as intended by the decision documents?	22

QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels and remedial action objectives

used at the time of the remedy selection still valid?	23

QUESTION C: Has any other information come to light that could call into question the protectiveness of the
remedy?	24

VI.	ISSUES/RECOMMENDATIONS	24

OTHER FINDINGS	25

VII.	PROTECTIVENESS STATEMENTS	26

VIII.	GOVERNMENT PERFORMANCE AND RESULTS ACT MEASURES	27

IX.	NEXT REVIEW	27

APPENDIX A - REFERENCE LIST	

APPENDIX B - SITE CHRONOLOGY	

APPENDIX C - ADDITIONAL SITE MAPS	

APPENDIX D - INSTITUTIONAL CONTROLS	

APPENDIX E - TCE CONCENTRATION GRAPHS	

APPENDIX F - SCREENING-LEVEL VAPOR INTRUSION EVALUATION

APPENDIX G - SITE INSPECTION PHOTOS	

APPENDIX H - ARAR REVIEW	

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LIST OF ABBREVIATIONS AND ACRONYMS

ARAR

Applicable or Relevant and Appropriate Requirement

bgs

Below grounds surface

CERCLA

Comprehensive Environmental Response, Compensation, and Liability Act

CFR

Code of Federal Regulations

CIC

Community Involvement Coordinator

COC

Contaminant of Concern

DCE

Dichloroethene

EPA

United States Environmental Protection Agency

ESD

Explanation of Significant Differences

FYR

Five-Year Review

IC

Institutional Control

MCL

Maximum Contaminant Level

l-Lg/L

Micrograms per Liter

NCP

National Oil and Hazardous Substances Pollution Contingency Plan

NPDES

National Pollutant Discharge Elimination System

NPL

National Priorities List

O&M

Operation and Maintenance

OU

Operable Unit

PADEP

Pennsylvania Department of Environmental Protection

PADER

Pennsylvania Department of Environmental Resources

PCB

Polychlorinated Biphenyl

PJJWA

Pocono Jackson Joint Water Authority

PRP

Potentially Responsible Party

RPM

Remedial Project Manager

TBC

To-Be-Considered

TCE

Trichloroethene

UU/UE

Unlimited Use/Unrestricted Exposure

VI

Vapor Intrusion

VISL

Vapor Intrusion Screening Level

VOC

Volatile Organic Compound

2


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I. INTRODUCTION

The purpose of a five-year review (FYR) is to evaluate the implementation and performance of a remedy to
determine if the remedy is and will continue to be protective of human health and the environment. The methods,
findings and conclusions of reviews are documented in FYR Reports such as this one. In addition, FYR Reports
identify issues found during the review, if any, and document recommendations to address them.

The U.S. Environmental Protection Agency (EPA) is preparing this FYR pursuant to the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA) Section 121, consistent with the National
Oil and Hazardous Substances Pollution Contingency Plan (NCP) (40 Code of Federal Regulations (CFR) Section
300.430(f)(4)(h)), and considering EPA policy.

This is the sixth FYR for the Butz Landfill Superfund site (the Site). The triggering action for this statutory
review is the completion date of the previous FYR. The FYR has been prepared because hazardous substances,
pollutants or contaminants remain at the Site above levels that allow for unlimited use and unrestricted exposure
(UU/UE).

The Site consists of two operable units (OUs) and both OUs will be addressed in this FYR. OU1 is the water
supply system EPA constructed in 1992 to serve the area affected by the Site. OU2 is contaminated groundwater
at the Site.

The EPA remedial project manager (RPM) led the FYR. Additional participants from EPA included the EPA
community involvement coordinator (CIC), human health and ecological risk assessors, a hydrogeologist and
legal counsel. The Pennsylvania Department of Environmental Protection (PADEP) also participated in the
review. Skeo provided EPA contractor support for this FYR. The review began on August 27, 2020.

Site Background

The Site is located on North Road (also known as Township Road 601) in Monroe County, Pennsylvania (Figure
C-l). The Site contains an 8.5-acre closed landfill on two parcels (totaling 13 acres) in Jackson Township and an
area of groundwater contamination that extends into Pocono Township. The Site is in a rural area; the closest
town is Reeders, about 1 mile south of the landfill. The terrain is relatively flat with a mixture of woods,
meadows, and farmland.

Landfilling operations at the Site began as early as 1965. Although the specific quantities of waste received are
unknown, it is known that the landfill accepted municipal waste, sewage sludge/liquids and possibly industrial
wastes. An operating permit application for the landfill was submitted to the Pennsylvania Department of
Environmental Resources (PADER, now PADEP) in 1970; the permit was denied due to insufficient technical
information about the landfill site. Waste disposal continued at the landfill without a permit until late 1973 when
the PADER ordered it closed. The events leading to its closure in 1973 and the response actions that followed are
summarized in Section II of this FYR Report.

Currently, the part of the landfill near North Road is used for soil, aggregate, and heavy equipment storage. The
rest of the site property is wooded and is occasionally used for firewood collection, all-terrain vehicle riding and
hunting. The groundwater treatment plant is also on the Site property (Figure 1). Land use around the Site is
primarily residential, recreational (e.g., fishing, hunting, skiing) and agricultural. Big Pocono State Park is less
than 1,000 feet north of the Site. Camelback Mountain Resort, a skiing area, is within Big Pocono State Park.

Groundwater near the Site occurs within three hydraulically interconnected layers (Layers 1, 2, and 3). Layer 1 is
the shallowest unit and Layer 3 is the deepest unit. Because the geologic layers in the Site area have a high degree
of slant (dip), the depth from the ground surface to Layers 2 and 3 varies across the Site. The shallow aquifer is
the saturated portion of the glacial till and is within Layer 1, while the deeper aquifer is found in bedrock. For the

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bedrock aquifer, groundwater occurs within the primary and secondary porosity. Secondary porosity dominates
and consists of open fractures and joints. The bedrock aquifer is recharged by infiltration through glacial till and
directly into outcrops. Groundwater flow is controlled by the orientation of bedding plane fractures. The primary
groundwater flow direction is to the northeast, with minor southwest flow due to historical residential well
pumping southwest of the landfill. All residential wells in the area of contaminated groundwater have either been
abandoned or converted to monitoring wells. Currently residences near the Site are supplied by a public water
system that was constructed by EPA in 1992 as the first remedial action (see OU1 below).

Refer to Appendix A for additional resources and to Appendix B for the Site's chronology of events.
FIVE-YEAR REVIEW SUMMARY FORM

SITE IDENTIFICATION

Site Name: Butz Landfill
EPA ID: PAD981034705

Region: 3

State: PA

City/County: Jackson Township / Monroe County

NPL Status: Final

Multiple OUs?

Yes

Has the Site achieved construction completion?

Yes

Lead agency: EPA

Author name: Stephen Tyahla, with additional support provided by Skeo Solutions, Inc.

Author affiliation: EPA Region 3
Review period: 8/27/2020 - 8/25/2021
Date of site inspection: 11/12/2020
Type of review: Statutory
Review number: 6

Triggering action date: 8/25/2016

Due date (fiveyears after triggering action date): 8/25/2021

II. RESPONSE ACTION SUMMARY

Basis for Taking Action

EPA's 1992 Record of Decision (ROD) for OU2 stated that past waste disposal at the Site resulted in
contamination of approximately 1.5 square miles of groundwater with trichloroethene (TCE), which had been

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disposed of in the landfill. Other volatile organic compounds (VOCs) were found in the groundwater at
significantly lower concentrations; some of these were likely related to the natural degradation of TCE.

The Site's groundwater contaminants of concern (COCs) as identified in the OU2 ROD are:

•	TCE

•	cis-l,2-Dichloroethene (cis-l,2-DCE)

•	trans-1,2-Dichloroethene (trans-1,2-DCE)

•	Vinyl chloride

•	Benzene

•	Ethyl benzene

•	Tetrachloroethene

•	Toluene

•	Carbon tetrachloride

•	Chloroform

•	1,1 -Dichloroethene (1,1 -DCE)

•	Methylene chloride (also known as dichloromethane)

•	Chlorobenzene

EPA found that exposure to the Site's groundwater posed potential human health risks. EPA's risk assessment
found that the Site's soil, surface water and sediments do not pose a risk to human health or the environment.

Response Actions

Initial Response

Local citizens submitted complaints about the landfill; the first documented complaints were in 1971. The
PADER (now known as PADEP) subsequently ordered the landfill closed due to improper operation, and required
development of a surface water management plan, groundwater monitoring and a landfill cover. Waste disposal
ceased at the landfill in late 1973. The landfill owners installed a soil cover in September 1973. EPA's 1991
remedial investigation found that the soil cover was about 1 foot thick.

Groundwater sampling conducted by PADER in 1986 indicated high levels of TCE in residential wells south of
the landfill, which prompted a request from PADER to EPA that the Site be considered for an emergency
response action.

During July 1986, PADER and EPA initiated area-wide response activities including site inspections, public
information meetings, residential well sampling, and provided bottled water and/or water treatment systems to
homes with contaminated well water. Over the next several months, EPA provided bottled water to 28 locations,
and installed carbon filtration systems at 22 residences. In addition, 17 groundwater monitoring wells were
installed.

In April 1987, EPA completed a study for an alternate water supply system to serve residents in the area of
contaminated groundwater wells. In March 1989, three water supply test wells were drilled and informed the
design of a potable water distribution system that was completed in January 1990 and later constructed as OU1.

In March 1989, as a new water supply system was being studied and designed, the EPA added the Site to the
Superfund program's National Priorities List (NPL).

QUI: Construction of Water Supply System

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EPA issued a Record of Decision (ROD) in September 1990, selecting construction of a water system (i.e., three
new supply wells, storage tank and distribution lines) to provide a new source of water to the residences affected
by groundwater contamination from the landfill. EPA's OU1 remedial action objective was to mitigate and/or
prevent human exposure to currently used contaminated groundwater.

OU2: Groundwater Cleanup

EPA issued a ROD in June 1992, selecting a remedial action for the cleanup of the contaminated groundwater.
EPA has also issued two Explanations of Significant Differences (ESDs). The first ESD, issued in August 1999,
revised the groundwater performance standards and the locations of groundwater extraction wells. The second
ESD, issued in July 2011, revised the groundwater performance standards and called for institutional controls.
EPA's OU2 remedial action objective is to mitigate and/or prevent human exposure to contaminated groundwater
and to return groundwater to its beneficial use as a source of drinking water. As stated in the ROD, no remedial
actions were needed for surface water, sediments, or the landfill proper, because these media did not pose a risk to
human health or the environment.

The selected groundwater cleanup remedy, as revised by the ESDs, includes:

•	Installation of wells to extract contaminated groundwater.

•	Construction of a system to treat the extracted groundwater to meet the specified discharge limits.

•	Compliance with air discharge limits for the groundwater treatment system.

•	Discharge of treated groundwater to a local stream via a wetland.

•	Operation and maintenance (O&M) of the groundwater extraction and treatment system until the
performance standards are met.

•	Institutional controls to protect the installed remedies.

•	Institutional controls to prohibit use of contaminated groundwater for drinking, bathing, or any other
potable use.

Table 1 presents the Site's groundwater remedy performance standards. They are based on applicable or relevant
and appropriate requirements (ARAR) that include drinking water Safe Drinking Water Act maximum
contaminant levels (MCLs) and Pennsylvania's Statewide Health Standards. The 2011 ESD requires that the
remediation of groundwater at the Site continue until: (1) the ARAR-based performance standards for individual
contaminants are achieved; (2) the cumulative risk presented by all remaining site-related compounds in the
groundwater is at or below the 1 x 10"4 cancer risk level; and (3) the non-cancer hazard index for these compounds
is equal to or less than 1.

Table 1: Groundwater COC ARAR-Based Performance Standards

(>muiulw;iiiT ( ()(

Poii'oniiiinco Si;ni(l;inl
(microtinuns per liter

TCE

5

Vinyl chloride

2

cis-l,2-DCE

70

1,1-DCE

7

trans-1,2-DCE

100

Benzene

5

Ethylbenzene

700

Tetrachloroethene

5

Toluene

1,000

Carbon tetrachloride

5

Chloroform

80

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(>muii(lw;ilcr ( ()('

Poii'oniiiinco Si;ni(l;inl
(niicmiiniiiiN per liter

Methylene chloride

3

Chlorobenzene

55

Notes:

Source: Table 1 in the 2011 ESD

All ARARs are based on MCLs, except for methylene chloride and
chlorobenzene. The ARARs for methylene chloride (aka diehloromethane)
and chlorobenzene are Pennsylvania's Statewide Health Standards
established pursuant to the Land Recycling and Environmental
Remediation Standards Act.

Status of Implementation

QUI: Construction of Water Supply System

EPA's contractor began construction activities for the water line on June 8, 1992, with users connected to the
system by December 18, 1992. Construction was completed on June 30, 1993. Seven of the 55 properties that
were part of the designed water supply system's service area declined to be connected to the system. However,
since then, four of these properties have been connected. As part of the 2021 FYR, EPA determined that the
remaining three properties, while still not connected, are outside the area of groundwater contamination.

The water line construction included:

•	Installation of about 8 miles of ductile iron trunk line.

•	Drilling and/or re-drilling of three groundwater supply wells in an upgradient area not affected by
groundwater contamination.

•	Construction of a 75,000-gallon water storage tank and pump house.

•	Realignment of a township road to provide access to the wellhead site.

•	Connecting 48 service users to the water supply.

•	Grouting of formerly-used groundwater supply wells.

OU2: Groundwater Cleanup

Construction of the groundwater (OU2) remedy was delayed for one year because of the discovery of a protected
species, the bog turtle, near the Site. Following an on-site bog turtle investigation and several site visits with the
United States Fish and Wildlife Service, EPA made design changes to the groundwater extraction and treatment
system to include construction of a strip of wetlands between extraction wells EW-1 and EW-2, relocation of the
discharge structure, and construction of about 3 acres of new wetlands at the discharge structure.

EPA constructed the groundwater extraction and treatment system from June 2000 to April 2001. Under an
interagency agreement with the EPA, the United States Bureau of Reclamation secured a construction contractor
and provided oversight of the work. The system consists of the following features:

•	A treatment building that houses a low-profile air stripper and a computerized control system.

•	An access road to the treatment building and a road between the extraction wells, treatment building and
discharge structure.

•	Three extraction wells (EW-1, EW-2, and EW-5).1

•	Three new monitoring wells and five retrofitted monitoring wells.

•	A treated water conveyance system and discharge structure with newly-created wetlands.

1 EPA replaced EW-3 with EW-5 in 2020 to improve the performance of the groundwater extraction and treatment system.

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On June 20, 2001, EPA issued a Preliminary Close-Out Report and declared the Site construction complete. The
groundwater extraction and treatment remedy was determined to be operational and functional on October 1,

2001.

The treatment system originally included an off-gas carbon treatment system to remove contaminants from the air
effluent. In March 2007, the height of the off-gas stack was increased by 5 meters to a new height of 10 meters
and the off-gas carbon treatment system was taken off-line because air modeling determined that it was no longer
needed. Air samples were also collected on a semi-annual basis to evaluate off-gas concentrations and confirm
that the increased discharge stack height is sufficient for reducing risk from treatment system air emissions.
Semiannual ambient air samples were also collected to confirm the same.

From 2008 to 2013, EPA conducted a two-phase in-situ bioremediation pilot study. The objective of the pilot
study was to determine whether in-situ bioremediation could shorten the time needed to clean up the Site's
groundwater. The Phase I injection of vegetable oil was in April 2009; the Phase II injection was in August 2011
and used a proprietary groundwater amendment called EHC-L®. The Phase I injections were made into well EW-
4, which is in the southeastern portion of the landfill. Phase II injections were made into EW-5 (Figure 1). As part
of the pilot study, the groundwater extraction and treatment system was not operated between October 2011 and
October 2013, to allow more time for the injected chemicals to react with the contaminants. On October 21, 2013,
the groundwater treatment system was restarted for continuous operation.

EPA's National Risk Management Laboratory reviewed the results of the pilot study and found that in-situ
bioremediation could be an effective part of the Site's remedial approach, in combination with the (modified as
necessary) groundwater extraction and treatment system. However, consistent distribution of reagents throughout
the contaminated zones would be important to the success of in-situ bioremediation at the Site, and the fractured
rock geology beneath the Site would make it difficult to control reagent distribution. No additional bioremediation
work has been done at the Site.

The 2016 FYR concluded that the groundwater extraction and treatment system, as configured and operated at
that time, was unlikely to achieve its objective (restoring groundwater to its beneficial use as a source of drinking
water) within a reasonable length of time. To address this issue, in 2020, EPA improved the groundwater
extraction and treatment system by replacing extraction well EW-3 with EW-5, conducting a capture zone
analysis, and servicing the extraction wells to improve their performance. The 2020 capture zone analysis found
that the groundwater extraction and treatment system is collecting contaminants migrating east from the landfill;
however, the analysis found that the system is not capturing the portions of the plume south of the landfill and
east of extraction wells EW-1 and EW-2. EPA and PADEP will evaluate the groundwater extraction and
treatment system to assess whether the recent improvements will allow the Site's cleanup goals to be achieved
within a reasonable time.

Institutional Control (IC) Review

The status of the Site's institutional controls is summarized in Table 2, below.

In 1991, Jackson and Pocono Townships enacted ordinances requiring property owners within the water supply
system's service area to use the water system as their exclusive source of potable water and requiring wells within
the service area to be disabled (Figure 2). Appendix D provides copies of the ordinances (Figures D-l and D-2).
Three properties within the water supply system's service area but outside the area of groundwater contamination
are not connected to the system.

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Figure 1: Detailed Site Map

250

500

1,000
Feet

Sources: Esri, U.S. Census Bureau 2019
TIGER/Line Geodalabases, Bureau of
Transportation Statistics, EPA, DigitalGlobe,
GeoEye, Earthstar Geographies, DeLonne, Tele
Atlas, AND, First American, UNEP-WCMC,
USGS, CNES/Airbus DS, USDA, AeroGRID.
IGN, the GIS User Community, the 1992 ROD,
the 2016 FYR and the 19th-Year Groundwater
Monitoring and System Operations Report.

Legend

Landfill Property	®	Extraction Well

I:: I: :l Extent of Fill	~ -	Treatment System Piping

	 Road		Treated Water Discharge Line

Stream	\Z2 Treated Water Discharge Outlet

A Skeo O

V	NORTH

Butz Landfill Superfund Site

Jackson Township, Monroe County, Pennsylvania

Disclaimer: This map and any boundary lines within the map are approximate and subject to change. The map is not a survey. The map is for informational
purposes only regarding EPA's response actions at the Site.

9


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In 2017, EPA added the Site to the Pennsylvania One Call System to protect the groundwater remedy's
engineered structures from being damaged by any future excavation. Pennsylvania Act 287 requires excavators to
notify the One Call System three to 10 business days prior to excavation. The One Call System emails a
notification ticket to the RPM whenever anyone notifies the One Call System that they are planning to dig within
the area shown on Figure 3. Given the remoteness of the Site, not many "tickets" are received and all have been
readily "cleared" without the need to visit the Site and mark the subsurface utilities that are part of the remedy.
EPA will work with PADEP to transfer monitoring responsibilities of the PA One Call System to PADEP.

Table 2: Summary of Institutional Controls (ICs)

Mediii.
r.niiiiK'crod
Coin nils. ;¦ iid
Areiis 1 hill Do

\o( Support
I 1 /I 1 IJiised on
ClUTCUl
Conditions

ICs
Needed

ICs ( idled
lor in the
Decision
Documents

Impiiclcd
Parcels

IC

()h.jeeli\e

Tide of l( Inslriinicnl
Implemented iind Diile

Groundwater

Yes

Yes

Area with
groundwater
contamination
(see Figure 2)

Prevent use of
contaminated
groundwater for
drinking, bathing, and
any other potable use

Jackson and Pocono
Township ordinances
require use of water supply
system as exclusive source
of water.

Environmental covenant
recorded 11/3/2015
prohibits use of
contaminated groundwater
for drinking, bathing, and

any other potable use
(applies only to parcel 08-
6362-0035-7153).

Groundwater
treatment system

Yes

Yes

See Figure 3

Prohibit damaging the
groundwater remedy's
engineered structures

Environmental covenant

recorded 11/3/2015
prohibits damaging the
groundwater remedy's
engineered structures
(applies only to parcel 08-
6362-0035-7153).

Site added to Pennsylvania
One Call System
3/13/2017. One Call
notifies the RPM whenever
anyone submits the legally-
required notification that
they are planning to dig
within the area shown on
Figure 3.

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Figure 2: Water Supply System Map

Jackson arid Poconc Township
ordinances require property owners
within the water supply system's service
area to use the water supply system as
their exclusive source of water.

0' 625 1,250

2,500
Feet

Legend

Sources: Esri, U, S. Census Bureau 2019
TtGER/Line Geodatabases, Bureau of
Transportation Statistics, EPA,
DigitaKSfobe, GeoEye, Earthstar
Geographies, DeLorme, Tele Atlas, AND,
First American, UNEP-WCMC, USGS.
CNES/Airbus DSr USD A, AeroGRIDr IGN,
the GIS User Community, the 19th-Year
Groundwater Monitoring and System
Operations Report and the 2016 FYR.

Landfill Property

Original Water Supply System

Later Additions to Water Supply
System

2020 Concentration Contour:

TCE > 5 pg/L

^ Skeo

Butz Landfill Superfund Site

Jackson Township, Monroe County, Pennsylvania

Disclaimer: This map and any boundary lines within the map are approximate and subject to change. The map is not a survey. The map is for informational
purposes only regarding EPA's response actions at the Site.

li


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Figure 3: Institutional Control Map

250 500

Sources. Esri, U.S. Census Bureau 2019
TIGER/Line Geodatabases, Bureau of
Transportation Statistics, EPA, DigitaiGlobe,
GeoEye. Earthstar Geographies, DeLonve,
Tele Atlas, AND. First American, UNEP-
WCMC, USGS, CNES/AirbUS DS, USDA,
AeroGRID, IGN, the GIS User Community,
the 19th-Year Groundwater Monitoring and
Sysfem Operations Report, the 2016 FYR
and the 2017 PA One Call Map.

1.000 Legend

Feet 	

Landf I Property

l_ J

E

One Call Area

® Extraction Well
=-=- Treatment System Piping

Subject to Environmental 	Treated Water Discharge Line

Covenant Recorded Nov. 2015
Road

Treated Water Discharge Outlet

^ Skeo

Butz Landfill Superfund Site

Jackson Township, Monroe County, Pennsylvania

Disclaimer: This map and any boundary lines within the map are approximate and subject to change. The map is not a survey. The map is for informational
purposes only regarding EPA's response actions at the Site.

12


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Systems Operations/Operation and Maintenance

The water supply system (OU1) was initially maintained by EPA through the Bureau of Reclamation. On January
31, 1995, EPA relinquished the water supply system to the Pocono Jackson Joint Water Authority (PJJWA),
which took over O&M of the system and continues to supply residents in the area with drinking water.

In October 2011, PADEP assumed O&M responsibilities for OU2 (groundwater cleanup) from EPA. PADEP's
O&M contractor has conducted annual groundwater sampling since 2004; the sampling frequency for a given
well, depending on prior sampling results, is either annual, every two years or every five years. Before 2004,
groundwater sampling was conducted on a semiannual basis. The current O&M manual (dated October 2011) for
the groundwater treatment system includes daily remote monitoring, monthly O&M activities, quarterly influent
and effluent treated water sampling, annual off-gas air sampling, and long-term groundwater performance
monitoring. Daily monitoring and monthly O&M log sheets are completed by PADEP's O&M contractor. The
O&M contractor performs regular inspections, sampling, and repair work at the Site in accordance with the O&M
manual. This work is documented in monthly progress reports submitted to EPA and PADEP as well as annual
groundwater performance monitoring reports. PADEP's O&M contractor submitted a revised Sampling and
Analysis Plan (SAP) in March 2017 and EPA approved the revised SAP in April 2017.

The groundwater extraction and treatment system is regulated by a series of alarms that cause the system to shut
down in the event of a malfunction. PADEP's O&M contractor makes regular monthly maintenance visits to the
Site. From August to December 2020, the system operated only 20% of the time due to various false alarms (low-
flow, no-flow, building leak detection). PADEP's O&M contractor will continue to troubleshoot these problems
in an attempt to return the system to consistent operation. During the May 2021 O&M visit, PADEP's O&M
contractor had some success in resolving system faults related to the treatment building's sump alarm and air
stripper sump high water alarm by having its electrical subcontractor clean corroded switches and make other
electrical component repairs. At the end of that visit, the system was operating in automatic mode. Continued
diligence during monthly O&M visits and prompt component repair and replacement are important to ensuring
reliable automated operations.

III. PROGRESS SINCE THE PREVIOUS REVIEW

This section includes the protectiveness determinations and statements from the previous FYR as well as the
recommendations from the previous FYR and the status of those recommendations.

Table 3: Protectiveness Determinations/Statements from the 2016 FYR

()l #

Pmleclhciiess
l)cliTinin;ilion

Pro(oc(i\oiK'ss Siiiicmonl

1

Protective

The remedy at OU1 currently protects human health and the
environment because a permanent municipal water supply system
was installed for affected residents and businesses. The system is
being operated and maintained by the PJJWA.

2

Short-term Protective

The remedy at OU2 currently protects human health and the
environment because there is no known current exposure to
contaminated groundwater, site-related constituents are not present
in indoor air at levels of concern, the groundwater extraction and
treatment system is functioning as intended, an institutional control
is in place prohibiting use of wells within the water supply service
area, and treated water meets discharge requirements prior to being
discharged to wetlands. In order for the OU2 remedy to be
protective in the long term, an analysis of the groundwater remedy
should be performed, and additional institutional controls
implemented.

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()l #

Prnleclheiicss
DcliTiniiiiilion

Proicclheness Miilcim-nl

Sitewide

Short-term Protective

The Site's remedy currently protects human health and the
environment because a permanent municipal water supply system
was installed for affected residents and businesses, there is no
known current exposure to contaminated groundwater, site-related
constituents are not present in indoor air at levels of concern, the
groundwater extraction and treatment system is functioning as
intended, an institutional control is in place prohibiting use of wells
within the water supply service area, and treated water meets
discharge requirements prior to being discharged to wetlands. In
order for the Site's remedy to be protective in the long term, an
analysis of the groundwater remedy should be performed, and
additional institutional controls implemented.

Table 4: Status of Recommendations from the 2016 FYR

()l

#

Issue

Kccomiiiciuliilion

( II ITCH 1
Sliilus

( iinvnl
linploiiionliilion Sliilus
Description

( omplclion
Diilc

2

It is unlikely that the
groundwater extraction
and treatment system, as
currently configured
and operating, will be
able to achieve its
objective (restoring
groundwater to its
beneficial use as a
source of drinking

water) within a
reasonable length of
time.

l ake aclioiib lo iiiipro\ e
performance of the
groundwater extraction and
treatment system including,
but not limited to: a.)
cleaning the extraction
wells; b.) performing a
capture zone analysis; and
c.) evaluating what
optimization or system
enhancements can be made
to achieve the groundwater
performance standards
sooner.

Completed

EPA/PADEP improved

the groundwater
extraction and treatment
system by replacing
extraction well EW-3
with EW-5; conducting
a capture zone analysis;
and servicing the
extraction wells to
improve their
performance.

6/6/2020

2

Institutional controls
need to be implemented
for several parcels to
prohibit damaging the
groundwater remedy's
engineered structures.

Pursue environmental
covenants on the remaining
three parcels with
groundwater remedy
engineered structures.

Completed

EPA registered the Site
with the Pennsylvania
One Call System in
order to prevent digging
that could damage the
groundwater treatment
system's underground

piping, wiring and
treated water discharge
pipe.

3/13/2017

IV. FIVE-YEAR REVIEW PROCESS

Community Notification, Community Involvement and Site Interviews

A public notice was published in the Pocono Record newspaper on May 1, 2021 stating that the FYR was
underway and inviting the public to submit any comments to EPA. No comments were received. The results of
the review and the report will be made available at the Site's information repository, the Pocono Township
Library located in the Municipal Building, 112 Township Drive, Tannersville, Pennsylvania 18372, and at
www.epa. gov/superfund/butz.

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During the FYR process, interviews were conducted to document any perceived problems or successes with the
remedy that has been implemented to date. The interviews are summarized below.

On December 2, 2020, the CIC conducted a telephone interview with the PADEP Project Manager for the Butz
Landfill, Ron Schock. The Project Manager stated that overall, he feels the project is going fine, although there
are occasionally some issues that come up with the treatment plant and there is currently an issue with one of the
extraction wells (EW-2). Mr. Schock mentioned that the state's contractor goes out to the treatment plant monthly
to check-in and he tries to accompany the contractor when he can, although he has not been able to do so since the
start of the COVID-19 pandemic.

Mr. Schock stated there have not been any complaints or violations related to the Site, although recently there was
a homeless person setting up camp at the Site. The state police became involved and the issue was addressed.

The PADEP Project Manager feels well informed on the Site's activities and progress and feels things are going
well with EPA. However, the Project Manager did state that he has some questions as to some of the decisions
that were made at the Site in the past. Mr. Schock became involved with the Butz Landfill site about two years
ago and has some questions about the cleanup. He is curious as to why the source area at the landfill was never
capped or removed as he feels that would have helped the groundwater situation. However, not having the
historical knowledge of the Site, he recognizes these decisions are difficult to understand. Other than that, Mr.
Schock did not have any other comments, suggestions or recommendations regarding the Site's management or
operation.

On November 24, 2020, the CIC conducted a telephone interview with the Chairman of the Board for the PJJWA,
Len Barthol. Mr. Barthol took over as Chairman of the Authority in early 2020, however he has been on the
PJJWA Board for approximately six years. He is familiar with the Site and the cleanup as he is a resident of the
area for 30 years.

Mr. Barthol stated that there have not been any routine communications or activities conducted by PJJWA
regarding the Site. He states that aside from driving past the Site frequently, there has not been any need for site
visits or inspections. He also stated that since his time on the Board of PJJWA, he is not familiar with any
complaints, violations or incidents related to the Site.

The CIC asked Mr. Barthol about a comfort letter that EPA sent in 2017 to the Brodhead Creek Regional
Authority who was looking to pursue purchase of the PJJWA and its assets. The CIC inquired about the status and
Mr. Barthol mentioned that nothing has happened with this purchase. The major development project that was
going to happen did not occur and therefore, the Brodhead Creek Regional Authority backed out of pursuing the
acquisition.

The CIC asked about the status of the drinking water system's operations and compliance. Mr. Barthol stated that
everything is in compliance and that the Authority received a grant in 2020 and is in the process of upgrading its
system. The CIC mentioned a map of the PJJWA's connections from 2016 and asked if there was an updated map
to share. The Chairman informed the CIC that nothing has changed or been expanded with the system since 2016.

The Chairman informed the CIC that on the northern side of the landfill (north side of North Road), a proposal is
pending for a concrete and block paver company to build their operations. They purchased the land this past year
and are going through the engineering and permitting process with the township. The township is conducting a
preliminary review of the documentation. It could be several years before the business is built, but Mr. Barthol
wanted to make EPA aware that they will be connecting to the system and using a significant amount of water if
the project moves forward.

Lastly, the Chairman asked the CIC if regular groundwater monitoring takes place and if there would ever be a
need for the groundwater monitoring wells to hook up to the PJJWA system. The Chairman was concerned about
this happening and incorporating such costs into the Authority's budget. The CIC explained that groundwater is

15


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sampled annually by PADEP and it does not appear that these wells would need to be connected to the PJJWA
system. (It is likely that Mr. Barthol misunderstood the purpose of the groundwater monitoring wells which are
exclusively for collecting groundwater samples and would never act as water supply wells.) Mr. Barthol had no
further comments or suggestions regarding the Site.

Data Review

For this FYR, EPA reviewed groundwater, air effluent and treated water effluent data from the past five years. In
addition, this section summarizes vapor intrusion sampling results from 2007 to 2014 and presents a screening-level
vapor intrusion evaluation conducted as part of this FYR.

Groundwater

Historically, analyses of the Site's contaminant plumes indicated that the levels of contamination vary with depth
and the distribution of contaminants varies by layer. The contaminant distribution and groundwater flow are
strongly influenced by the geologic structure (the strike and dip of the bedrock units). The highest TCE
concentrations in the center of the plume occur within the lower portion of Layer 1 and the upper portion of Layer
2, reflecting the preferred migration of the contaminant plume along the bedding planes of the dipping bedrock.
Layer 3 is historically the least-contaminated layer. Samples collected from monitoring wells at the Site are
denoted by the well number followed by the following depth intervals (from deepest to shallowest): A, B, C, D, E,
II and 12 (these letters do not correspond to Layers 1, 2 and 3).

TCE, cis-l,2-DCE and vinyl chloride concentrations are one to two orders of magnitude greater than their
respective performance standards (Table 1) at varying depths. TCE is the primary and most widespread site
contaminant. Appendix E provides graphs of TCE concentrations since 2001. TCE concentrations in almost all
monitoring wells have decreased since groundwater treatment began in 2001. Over the past 10 years, TCE, cis-
1,2-DCE and vinyl chloride concentrations have increased in some wells, decreased in some wells, and remained
relatively stable in other wells.

Figures C-4 through C-9 in Appendix C show the estimated lateral extent of TCE contamination in 2001 and in
2016 through 2020. Layers 1 and 2 are the most highly contaminated layers; Figures C-4 through C-9 are
predominantly based on Layer 1 and 2 data. These figures indicate that the groundwater treatment system has
been effective in shrinking the TCE plume from approximately 297 acres in 2001 to approximately 195 acres in
2020. The Site's sampling data indicates that the extent of other VOCs is within the extent of the TCE plume.
Figures C-5 through C-9 indicate that the areal extent of the TCE plume has neither expanded nor shrunk over the
past five years. As discussed under above under "Status of Implementation." to address this issue, EPA improved
the groundwater extraction and treatment system in 2020. EPA and PADEP will evaluate the groundwater
extraction and treatment system to assess whether the recent improvements will allow the Site's cleanup goals to
be achieved within a reasonable time.

The VOC plume is beneath several small intermittent streams (see Figure C-9). However, it is unlikely that
contaminated groundwater is discharging to surface water at levels that would cause ecological risk. The TCE
cross-section profiles in the most recent annual monitoring report indicate that the concentrations near the ground
surface are far lower than the concentrations at greater depths. The most recent TCE concentrations in the shallow
screened intervals of monitoring wells PWA, PWB and PWC (which are near a stream and a small wetland
created as part of the Site's remedy) ranged from 45.6 to 89.1 (ig/L, which is greater than EPARegion3's
ecological freshwater screening benchmark (21 (ig/L). However, these samples represent depths of greater than 15
feet below ground surface. Previous results for shallower intervals showed far lower concentrations; for example,
the shallowest interval of well PWA was most recently sampled in 2015 and had TCE at 1.8 j^ig/L while deeper
intervals had TCE at 330 (ig/L and 136 (ig/L.

16


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The eastern edge of the groundwater contamination is not well defined. The location of highest VOC
concentrations is east of the landfill property, indicating a roughly eastward direction of contaminant migration.
See Figure 4. The farthest downgradient contaminated well screened in Layer 1 is R6 which is screened at two
depth intervals: R6-A is screened at 70-240 feet below ground surface (bgs) and R6-B is screened at 15-65 feet
bgs. Groundwater samples from the deeper interval, R6-A, have had consistently high levels of TCE since 2001,
with a concentration of 469 (ig/L in 2020 (see Figure C-3). In contrast, the 2020 sample from R6-B, the shallower
interval, had a TCE concentration of 11.6 (ig/L. The nearest monitoring well downgradient of R6 that has a zone
screened in Layer 1 (R9-C) is half a mile away and had no detectable TCE in 2020; land uses between monitoring
wells R6 and R9 include residences and a childcare facility (see Figure 4).

The farthest downgradient contaminated wells screened in Layer 2 are PWA-A (screened at 145-160 feet bgs) and
PWB-A (screened at 135-152 feet bgs); the most recent TCE concentrations were 436 (ig/L (in 2020) and 117
(ig/L (in 2019), respectively. The nearest monitoring wells downgradient of PWA and PWB that have a zone

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Figure 4: 2020 TCE Plume2

Sources: Esri, U.S. Census Bureau 2019 TfGERAine Geodatabases, Bureau of
Transportation Statistics, EPA. DigitalGlobe, GeoEye, Earthstar Geographies.
DeLorme, Tele Atlas, AND, First American, UNEP-WCMC, USGS, CNES/Airbus
DS, USD A, AeroGRiD, IGN, the GIS User Community, the 19th-Year Groundwater
Monitoring and System Operations Report and the Map of VI Testing Locations.

Legend	2020 Concentration Contours:

Landfill Property	I I TCE > 1.000 ua/L
Groundwater Sample TCE > 100 pg/L

Ct Residence Sampled for Vapor Intrusion	I I TCE > 5 pg/L

^ Skeo O

V ~	NORTH

Butz Landfill Superfund Site

Jackson Township, Monroe County, Pennsylvania

Disclaimer: This map and any boundary lines within the map are approximate and subject to change. The map is not a survey. The map is for informational purposes only regarding EPA's response actions at the
Site.

2 Concentration contours are shown as drawn by PADEP's O&M contractor and presented in Figure 2-3 of the Nineteenth-Year Groundwater Monitoring and System
Operations Report, which is based on concentrations "measured in various hydrostratigrapliic layers although Layer 2 concentrations were predominantly used where
available."

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screened in Layer 2 (R9 and RW12) are about half a mile away from PWA and PWB.3 Therefore, given the large
distances between contaminated and uncontaminated wells, the presence of potential receptors, and the potential
for vapor intrusion (discussed below), it may be helpful to collect additional data to refine the understanding of
the eastern edge of the groundwater contamination, particularly with respect to the shallowest zone of
groundwater.

From 2004 to 2020, the groundwater treatment system removed 1,694 pounds of TCE and 351 pounds of cis-1,2-
DCE. The combined pumping rate for the three extraction wells is currently about 30% of the originally designed
rate of about 75 gallons per minute. PADEP plans to optimize the reconfigured extraction well network (EW-1,
EW-2, and EW-5), and attempt to increase the system pumping rate to the originally designed rate.

Vapor Intrusion (VI)

There are VOCs in shallow groundwater at and near the Site. Figure F-l shows the most recent TCE groundwater
concentrations in each well's shallowest sampling interval. Residences, a church, and a childcare facility are
located near the shallow groundwater contaminant plume. Therefore, vapor intrusion is a potentially complete
exposure pathway.

From 2007 to 2014, EPA conducted seven rounds of indoor air sampling to evaluate vapor intrusion as a potential
exposure pathway. Figure F-l shows the locations of the houses that were sampled. Following a recommendation
from the 2011 FYR, EPA conducted vapor intrusion sampling in March 2012 in three residences near the Site.
The sampling included collection and analysis of indoor air and sub-slab vapor samples. Although indoor air
samples did not identify site-related constituents at levels of concern, sub-slab concentrations prompted additional
sampling events. Additional vapor intrusion monitoring performed after the March 2012 sampling event included:

•	In January 2013, the three residences sampled in March 2012 were again sampled to test indoor air and
sub-slab vapor. The results did not suggest that the indoor air was impacted by site-related contaminants.

•	In November 2013, EPA collected indoor air, ambient air and sub-slab vapor samples and also performed
real-time indoor air monitoring at six residences near the Site. Site-related contaminants were not detected
in indoor air at levels above risk-based screening levels. One of the six units tested had TCE in sub-slab
vapors at levels above risk-based levels; the lack of indoor air exceedances suggests that attenuation is
occurring to reduce concentrations between sub-slab air and indoor air.

•	In March 2014, EPA collected indoor air, ambient air and sub-slab vapor samples and also performed
real-time indoor air monitoring at seven residences near the Site. Site-related contaminants were not
detected in indoor air at levels above risk-based screening levels. Two units tested had TCE in sub-slab
vapors at levels above risk-based levels; the lack of indoor air exceedances suggests that attenuation is
occurring to reduce concentrations between sub-slab air and indoor air.

The last FYR concluded that should Site conditions change, such as a substantial increase in TCE in groundwater
or modifications to homes, additional vapor intrusion sampling would be considered in the two residences where
TCE concentrations were detected above EPA's risk-based screening levels in sub-slab samples. During this
FYR, substantial increases in TCE in groundwater or modifications to homes have not been observed. While an
increase in groundwater concentrations could suggest a need for more indoor air sampling, it cannot necessarily
be concluded that sub-slab concentrations are otherwise stable. Vapors can be influenced by many factors. At
residential Unit 107 in particular (Figure F-l), upward fluctuations have been noted in past sub-slab vapor TCE
concentrations. Over the course of the Butz Landfill sampling, EPA has lowered the standard for acceptable TCE

3 RW-12 has never had any VOC exceedances and was last sampled in 2010 and is no longer sampled. R9 is sampled every 5
years (due to historically low detections) and has had TCE concentrations below 5 |ig/L since 2005 with the 2020 result for
the shallowest interval (R9-C) being non-detect (<0.5 |ig/L).

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air concentrations to 2 (ig/m3; based on a new understanding of TCE's toxicity when inhaled; therefore it would
not take a large increase or fluctuation to bring indoor air into the range of concern, if vapor intrusion occurs. The
current plume map (Figure 2-3) also places these homes within the area of TCE MCL exceedance, although not
necessarily in the shallowest groundwater interval.

This FYR conducted a screening-level evaluation of the potential health risk from vapor intrusion for buildings
near elevated levels of VOCs (TCE > 5 j^ig/L) in the most recent shallow groundwater samples. Appendix F
describes the evaluation. The main results of the screening-level vapor intrusion evaluation are:

•	The house nearest to monitoring well R7 (approximately 114 feet away) was not previously evaluated for
vapor intrusion. The most recent (2015) TCE concentration measured in shallow groundwater at well R7-
E (35-47 ft. bgs) (35.2 (ig/L) was significantly greater than levels previously detected that were typically
below 5 (ig/L. In 2020, access to the property to sample well R7 was denied by the homeowner. The
screening-level assessment based on the 2015 result found that the groundwater TCE concentration could
potentially result in an unacceptable non-cancer hazard from vapor intrusion in the nearby house.

•	A church in an area with elevated levels of TCE in the groundwater has not been previously evaluated for
vapor intrusion. At the closest monitoring well (PWA), results from the shallowest groundwater (see
PWA-E) suggest that there was no unacceptable vapor intrusion risk near the well during 2002 to 2015.
Sampling of the PWA-E interval was discontinued in light of consistently low (< 5 (ig/L) TCE
concentrations. Using more recent (2020) groundwater sampling results from the second-shallowest
screened interval (PWA-D), the area near the well could have an unacceptable non-cancer hazard.
However, the well is about 400 feet away from the church in a side-gradient direction, so groundwater
concentrations (and corresponding vapor intrusion risk) at the church are difficult to assess but seem
unlikely based on the historically low concentrations observed in the shallowest interval (PWA-E).

•	There are a childcare facility and several homes in an area that may have elevated levels of TCE in
shallow groundwater. These buildings have not been previously evaluated for vapor intrusion. Using the
closest monitoring well (R6, 400 to 800 feet upgradient), the screening-level evaluation estimates a non-
cancer hazard of 1, which is just at the acceptable level. However, the childcare and residences are several
hundred feet downgradient of the well, so groundwater concentrations (and corresponding vapor intrusion
risk) closer to the buildings would be expected to be lower than at the well.

The Vapor Intrusion Screening Level (VISL) calculator's results are intended to be conservative (i.e., to
overestimate risk) in order to be used as a screening tool to help determine if additional vapor intrusion evaluation
is recommended. The calculator is conservative because it does not take into account the depth to contaminated
groundwater, site-specific soil properties or building-specific properties, all of which generally can result in
significantly lower indoor air concentrations than are predicted by the VISL calculator. However, the bedrock
fractures in the area may provide preferential pathways for vapors to travel without being attenuated; this may
make the VISL results less conservative than at other sites without fractures. There is a high degree of uncertainty
for the risk and hazard estimates generated by this FYR's screening-level review because the monitoring wells are
far from the buildings and most of the samples represent deeper groundwater (and greater depth ranges) than
would be ideal for vapor intrusion evaluations. Since TCE and other contaminants at the Site are heavier than
water and tend to have higher concentrations at greater depths, the use of deeper samples would tend to make the
VISL results more conservative. While the likelihood of VI impacts appear low, as a precaution, this FYR
recommends further evaluation of the VI pathway for structures that are potentially near high levels of VOCs in
shallow groundwater and that have not been previously evaluated for the vapor intrusion pathway. Assessing
shallow groundwater quality nearer to the structures would be an appropriate way to proceed with such
evaluations.

Air Effluent from Groundwater Treatment System

Air samples have been periodically collected from the groundwater treatment system since February 2001,
originally to confirm the performance of the granular activated carbon used to treat off-gas vapors released from

20


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the air stripper, and later to confirm that emissions remain acceptable after the granular activated carbon treatment
was removed. For this FYR, EPA reviewed sampling results from air stripper off-gas and ambient air samples
collected in January 2020. As expected from a functioning air stripper, the off-gas contained TCE, cis-l,2-DCE
and vinyl chloride. None of the ambient air samples had any detectable concentrations of VOCs.

EPA modeled the emissions to potential nearby receptors for annual and 24-hour maximums and averages,
assuming continuous operation of the air stripper, and determined that concentrations would be within the
acceptable risk range (Hazard Index below 1, cancer risk less than 1 x 10"4). Overall, the data indicate that the
groundwater extraction and treatment system is functioning in a manner that does not pose an unacceptable risk to
nearby receptors. Monitoring of the effluent air and ambient air should continue in order to ensure that
concentrations remain within the protective range.

Treated Water Effluent

PADEP's O&M contractor analyzes treated water effluent quarterly for VOCs. The 1992 ROD states that the
surface water discharge will comply with Clean Water Act National Pollutant Discharge Elimination System
(NPDES) regulations, Pennsylvania NPDES regulations, and Pennsylvania Water Quality Standards. PADEP
discharge limits have not been established through an NPDES equivalency process although a draft NPDES
permit application was completed at the time of the remedial system's design in 1997. It is unclear as to why
NPDES discharge limits have not been established. As a matter of practicality, the 2011 O&M Manual identifies
maximum discharge concentrations based on drinking water MCLs. The use of MCLs as maximum discharge
concentrations is not directly relevant or appropriate for a surface water discharge. Therefore, among the "Other
Findings" in this report is a recommendation that NPDES-equivalent discharge limits be established by PADEP.

For this FYR, EPA compared treated water effluent sampling results for VOCs from June 2016 through February
2020 against Pennsylvania's Water Quality Standards (25 Pa. Code § 93.8c). None of the samples had detectable
levels of VOCs, except for the samples from June 2016. The June 2016 samples may have been affected by a
laboratory error; the trip blank samples contained levels of TCE and DCE similar to the levels in the effluent
samples.

The effluent samples have a VOC detection limit of 0.5 j^ig/L: this level is lower than groundwater cleanup
performance standards (Table 1), but above the current Pennsylvania Water Quality Criteria for vinyl chloride
(0.02 (ig/L) and carbon tetra chloride (0.4 (ig/L). The detection limits are in accordance with the 2017 EPA-
approved SAP prepared by PADEP and have been deemed sufficient given the effectiveness of VOC removal of
the air stripper and consistent non-detections of VOCs in the system effluent. Given the lack of any VOC
detections in the treatment plant effluent (excepting the anomalous June 2016 result), it is unlikely any effluent
discharge contained VOCs exceeding the Pennsylvania Water Quality Standards.

Site Inspection

The site inspection took place on November 12, 2020. Participants included the EPA RPM, PADEP
representatives, PADEP O&M contractor and Skeo (EPA contractor support). The purpose of the inspection was
to assess the protectiveness of the remedy. Appendix G provides photographs from the site inspection. The Site
inspection was conducted during a time of COVID-19 restrictions. All recommended CDC, State and local
required precautionary measures were taken in conducting the Site inspection including social distancing, masks,
and use of sanitizer, etc.

Site inspection participants toured the groundwater treatment plant building, extraction and monitoring wells and
the treated water discharge location. PADEP's O&M contractor was conducting the annual groundwater sampling
event at the time of the FYR Site inspection. Monitoring wells were unlocked due to this sampling event. Site
inspection participants observed the new extraction well EW-5. Standing water was present on the floor of the

21


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EW-5 vault. The groundwater extraction and treatment system was running at about 35 gallons per minute at the
time of the FYR site inspection.

PADEP's O&M contractor reported that there has been no vandalism in the past five years. The part of the Site
property near North Road is used for heavy equipment storage. The rest of the site property is occasionally used
for firewood collection, all-terrain vehicle riding and hunting. PADEP recently learned that a trespasser was
camping on the Site property; PADEP notified law enforcement and the trespasser is no longer present. The Site
property is not fenced. There are fences with locked gates around the groundwater treatment building and the
extraction wells.

V. TECHNICAL ASSESSMENT

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

Question A Summary:

Yes, the remedy is functioning as intended by the decision documents. EPA constructed a water supply system to
provide water to properties affected by groundwater contamination. The Pocono Jackson Joint Water Authority
operates the system and continues to supply residents in the area with drinking water. PADEP operates the
groundwater extraction and treatment system, which continues to remove VOCs from the groundwater.
Institutional controls are in place to prevent use of contaminated groundwater and to prohibit damaging the
groundwater treatment system.

Remedial Action Performance

The 2016 FYR concluded that the groundwater extraction and treatment system, as configured and
operated at that time, was unlikely to achieve its objective (restoring groundwater to its beneficial use as a
source of drinking water) within a reasonable length of time. To address this issue, in 2020, EPA
improved the groundwater extraction and treatment system by replacing extraction well EW-3 with EW-
5, conducting a capture zone analysis, and servicing the extraction wells to improve their performance.
The 2020 capture zone analysis found that the groundwater extraction and treatment system is collecting
contaminants migrating east from the landfill; however, the analysis found that the system is not
capturing the portions of the plume south of the landfill and east of extraction wells EW-1 and EW-2.
EPA and PADEP will evaluate the groundwater extraction and treatment system to assess whether the
recent improvements will allow the Site's cleanup goals to be achieved within a reasonable time.

Based on the depth and the concentrations VOCs in groundwater, EPA does not believe that contaminated
groundwater is discharging to surface water at levels that would cause ecological risk. In addition, the
treated water effluent meets discharge standards, including EPA Region 3's ecological freshwater
screening benchmarks.

The eastern edge of the groundwater contamination is not well defined. Given the large distances between
contaminated and uncontaminated wells, the presence of potential receptors, and the potential for vapor
intrusion (discussed below), it may be helpful to collect additional data to refine the understanding of the
eastern edge of the groundwater contamination.

System Operations/O&M

From July 2019 to June 2020, the groundwater treatment system removed 54 pounds of TCE and 18
pounds of cis-l,2-DCE, for a total of 1,694 pounds of TCE and 351 pounds of cis-l,2-DCE from 2004 to
2020. However, the system has not operated consistently due to repeated false alarms that shut down the
system. This FYR recommends that PADEP continue troubleshooting the groundwater extraction and
treatment system's alarm failures so that the system can operate consistently.

Implementation of Institutional Controls

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Institutional controls are in place to prevent use of contaminated groundwater and to prohibit damaging
the groundwater treatment system. Jackson and Pocono township ordinances require property owners
within the water supply system's service area to use the water system as their exclusive source of potable
water and require wells within the service area to be disabled. Three properties within the water supply
system's service area are not connected to the system and presumably continue to use well water but were
determined to be outside the area of groundwater contamination. To protect the underground pipes and
other parts of the groundwater treatment system, the site is enrolled in the Pennsylvania One Call System,
which notifies EPA whenever anyone submits the legally-required notification that they are planning to
dig in the area. EPA will work with PADEP to transfer One Call monitoring responsibility to PADEP. An
environmental covenant for the northern landfill parcel prohibits using groundwater for potable purposes
and prohibits damaging the groundwater remedy's engineered structures. EPA will consider whether
additional institutional controls need to be implemented to require vapor intrusion mitigation steps for any
new structures that may be built near areas with high VOC levels in shallow groundwater.

QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels and remedial action objectives used
at the time of the remedy selection still valid?

Question B Summary:

The remedial action objectives used at the time of remedy selection remain valid. Although some of the exposure
assumptions, toxicity data and cleanup levels have changed since that time, most of these changes do not affect
the protectiveness of the Site's remedy because people are no longer using contaminated groundwater for drinking
water and groundwater remediation will continue until performance standards are met at which point a risk
assessment using up-to-date toxicity factors and risk assessment methodology will be performed. While vapor
intrusion is not believed to be currently occuring, additional evaluation of this pathway is recommended for
structures that are near elevated levels of VOCs in shallow groundwater and that have not been previously
evaluated (see Section VI, Issues / Recommendations).

Changes in Standards and To-He-Cons'ulered (TBC) Criteria

The Site's decision documents require groundwater remediation to continue until each COC achieves its
performance standard (most of which are based on drinking water MCLs), and until the cumulative risk is
at or below the 1 x 10"4 cancer risk level and the non-cancer hazard index is equal to or less than 1. The
ARARs for 11 of the 13 groundwater COCs have not changed since the groundwater performance
standards were revised in the 2011 ESD (see Appendix H). The ARARs for the two other COCs have
become less stringent since the 2011 ESD.

Changes in Toxicity and Other Contaminant Characteristics

EPA's risk assessment performed in 1991 as part of the remedial investigation found that the Site's soil
does not pose unacceptable risk to human health or the environment. Therefore, EPA did not select a
remedy for soil. EPA reassessed the soil in 2010 to ensure that conclusion was still protective. As part of
the current FYR, EPA compared the surface soil, subsurface soil, and test pit soil sampling data from the
1991 Remedial Investigation/Feasibility Study4 against EPA's current regional screening levels, which
are based on current default exposure factors, toxicity factors and risk methodology. This comparison
found that all of the 1991 soil sample results are below or within EPA's risk management range (excess
cancer risk of one-in-10,000 to one-in-a-million) for residential use, with the exception of one test pit
sample. Sample TP-19, collected at a depth of 6 feet, contained an estimated concentration of 2.8
milligrams per kilogram of the polychlorinated biphenyl (PCB) Aroclor 1254; this concentration is within
EPA's risk management range for industrial use but not for residential use, based on EPA's current soil
screening levels. Aroclor 1254 was not detected in any other soil samples; therefore, it is expected that
this Aroclor detection is localized and does not represent general soil risks.

4 Remedial Investigation/Feasibility Study Tables 4-9, 4-11 and 4-12.

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As part of the 2011 ESD, EPA reviewed the groundwater COCs and conducted a risk assessment using
current data, exposure factors and toxicity factors. As a result, one additional COC (cis-l,2-DCE) was
added to the list of performance standards.

Changes in Exposure Pathways

Several properties within the water supply system's service area declined to be connected to the potable
water system constructed in 1992. However, since then, four of these properties have been connected and
the remaining three are outside the area of groundwater contamination.

EPA conducted seven rounds of sampling to evaluate vapor intrusion as a potential exposure pathway,
from 2007 to 2014. The sampling results indicated that at that time there was no indoor air risk associated
with site-related contaminants. However, at two residences, TCE was detected in sub-slab vapor at levels
above EPA's risk-based screening levels. Therefore, future periodic monitoring may be warranted in
these two residences to ensure indoor air remains protective. Vapor intrusion (VI) sampling should also
be considered if site conditions change, such as a substantial increase in TCE concentrations in
groundwater or modifications to homes. In addition, there are several buildings, including a church,
childcare facility, and homes, that may be above areas with high concentrations of VOCs in shallow
groundwater and that have not been evaluated for vapor intrusion. This FYR conducted a screening-level
review of the potential for vapor intrusion in these areas and found that additional evaluation should be
considered for structures that are near elevated levels of VOCs in shallow groundwater and that have not
been previously evaluated for the vapor intrusion pathway. Assessing shallow groundwater quality nearer
to the structures would be an appropriate way to proceed with such evaluations. And should VI sampling
be deemed necessary for the previously unevaluated structures; it is suggested that an additional round of
VI sampling be performed at the two above mentioned residences that had been sampled between 2007
and 2014.

The 2006 FYR recommended analyzing groundwater samples for 1,4-dioxane. Groundwater samples
were analyzed for 1,4-dioxane as part of the annual sampling events in 2007, 2009 and 2010. 1,4-Dioxane
was not detected in any of the samples. The detection limits for many of the samples were significantly
higher than the current EPA regional screening level for tapwater (0.46 (ig/L).5 However, multiple
monitoring wells with high concentrations of VOCs had a detection limit of 2 (ig/L for 1,4-dioxane,
which is within EPA's range of acceptable risk; therefore, the conclusion that 1,4-dioxane is not a concern
at this Site remains valid.

QUESTION C : Has any other information come to light that could call into question the protectiveness of the

remedy?

No other information has come to light that could call into question the protectiveness of the remedy.

VI. ISSUES/RECOMMENDATIONS

Issues/Recommendations

()l (s) without Issiios/kecoiniiKMHliilions I clout i I'icil in the IYR:

OU1

5 2011 FYR Attachment 1 includes the 1,4-dioxane sampling results.

24


-------
Issues and Recommendations IclentiI'iod in (ho FYR:

OU: OU2

Issue Category: Monitoring



Issue: There are several buildings, including a church, childcare facility, and
homes, that might be above areas with elevated concentrations of VOCs in
shallow groundwater and that have not been evaluated for vapor intrusion. This
FYR conducted a screening-level review of the potential for vapor intrusion in
these areas and found that the non-cancer hazard could be elevated; however, the
review was based on data from monitoring wells over 100 feet from the
structures.



Recommendation: Further evaluate the vapor intrusion pathway for structures
that have not been previously evaluated and are near elevated levels of VOCs
(TCE > 5 (ig/L) in shallow groundwater.

Affect Current
Protectiveness

Affect Future
Protectiveness

Party
Responsible

Oversight Party

Milestone Date

No

Yes

EPA

EPA

2/25/2023

OU: OU2

Issue Category: Remedy Performance

Issue: The groundwater extraction and treatment system has not operated
consistently due to repeated alarms, system breakdowns and power losses due to
weather.

Recommendation: Continue troubleshooting the groundwater extraction and
treatment system's alarms and equipment failures so that the system can operate
consistently in automatic mode and establish an extraction rate closer to the
design flow rate.

Affect Current
Protectiveness

Affect Future
Protectiveness

Party
Responsible

Oversight Party

Milestone Date

No

Yes

PADEP

EPA

8/25/2022

OTHER FINDINGS

Several additional recommendations were identified during the FYR. These recommendations do not affect
current and/or future protectiveness.

•	The 2020 capture zone analysis found that the groundwater extraction and treatment system is collecting
contaminants migrating east from the landfill; however, the analysis found that the system is not
capturing the portions of the plume south of the landfill and east of extraction wells EW-1 and EW-2.
EPA and PADEP will continue to evaluate the groundwater extraction and treatment system to assess
whether the recent improvements will allow the Site's cleanup goals to be achieved within a reasonable
time.

•	To safeguard against the potential for vapor intrusion in new construction, EPA will pursue additional
institutional controls to require vapor intrusion mitigation steps for any new structures that may be built
overtop areas with elevated VOC levels in shallow groundwater.

•	NPDES-equivalent discharge limitations should be established by PADEP.

25


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• EPA will work with PADEP to transfer Pennsylvania One Call monitoring responsibility to PADEP.

VII. PROTECTIVENESS STATEMENTS

Protectiveness Statement

Operable Unit:	Protectiveness Determination:

1	Protective

Protectiveness Statement:

The remedy at OU1 is protective of human health and the environment because a permanent municipal
water supply system was installed for affected residents and businesses. The system is being operated
and maintained by the Pocono Jackson Joint Water Authority.

Protectiveness Statement

Operable Unit:	Protectiveness Determination:

2	Short-term Protective

Protectiveness Statement:

The remedy at OU2 currently protects human health and the environment because there is no known
current exposure to contaminated groundwater, the groundwater extraction and treatment system is
functioning as intended, institutional controls are in place prohibiting use of wells within the water
supply service area, and treated water meets Pennsylvania water quality standards prior to being
discharged to wetlands. In order for the OU2 remedy to be protective in the long term, further
evaluation of the vapor intrusion pathway for structures that have not been previously evaluated should
be performed to ensure VOC concentrations in shallow groundwater are not impacting those
structures; and extraction and treatment system maintenance performed to improve reliability of
automated operation.

Sitewide Protectiveness Statement

Protectiveness Determination:

Short-term Protective

Protectiveness Statement:

The remedy at OU2 currently protects human health and the environment because there is no known
current exposure to contaminated groundwater, Site-related constituents are not known to be present in
indoor air at levels of concern, the groundwater extraction and treatment system is functioning as
intended, institutional controls are in place prohibiting use of wells within the water supply service
area, and treated water meets Pennsylvania water quality standards prior to being discharged to
wetlands. In order for the OU2 remedy to be protective in the long term, further evaluation of the
vapor intrusion pathway for structures that have not been previously evaluated should be performed to
ensure VOC concentrations in shallow groundwater are not impacting those structures; and extraction
and treatment system maintenance is performed to improve reliability of automated operation.

26


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VIII. GOVERNMENT PERFORMANCE AND RESULTS ACT MEASURES

As part of this five-year review, the Government Performance and Results Act (GPRA) Measures have been
reviewed. The GPRA Measures and their status are as follows:

Environmental Indicators

Human Health: Human Exposure Controlled and Protective Remedy in Place
Groundwater Migration: Contaminated Groundwater Migration Under Control

Sitewide Ready for Anticipated Use (SWRAU)

The Site achieved SWRAU on May 11, 2017.

IX. NEXT REVIEW

The next FYR Report for the Butz Landfill Superfund site is required five years from the completion date of this
review.

27


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APPENDIX A - REFERENCE LIST

EPA. September 28, 1990. Record of Decision, Butz Landfill Superfund Site, Operable Unit One.
https://semspub.epa.gov/src/document/03/131964

EPA. September 1991. Remedial Investigation/Feasibility Study. Butz Landfill Site.

EPA. June 30, 1992. Record of Decision, Butz Landfill Superfund Site, Operable Unit 2.
https://semspub.epa.gov/src/document/03/46798

EPA. September 17, 1996. First Five-Year Review Report, Butz Landfill Superfund Site.
https://semspub.epa.gov/src/document/03/46643

EPA. August 27, 1999. Explanation of Significant Differences, Butz Landfill Superfund Site.
https://semspub.epa.gov/src/document/03/188639

EPA. September 28, 2001. Second Five-Year Review Report, Butz Landfill Superfund Site.
https://semspub.epa.gov/src/document/03/2012718

EPA. September 26, 2006. Third Five-Year Review Report, Butz Landfill Superfund Site.
https://semspub.epa.gov/src/document/03/2069476

EPA. September 9, 2011. Fourth Five-Year Review Report, Butz Landfill Superfund Site.
https://semspub.epa.gov/src/document/03/2130943

EPA. August 25, 2016. Fifth Five-Year Review Report, Butz Landfill Superfund Site.
https://semspub.epa.gov/src/document/03/2235225

EPA. July 27, 2011. Second Explanation of Significant Differences, Butz Landfill Superfund Site.
https://semspub.epa.gov/src/document/03/2134630

EPA. May 29, 2014. Review of the Butz Landfill Vapor Intrusion Data (Rounds 1-7).

EPA Office of Solid Waste and Emergency Response. OSWER Technical Guide for Assessing and Mitigating the
Vapor Intrusion Pathway from Subsurface Vapor Sources to Indoor Air. OSWER Publication 9200.2-154. June
2015. https://www.epa.gov/vaporintrusion/technical-guide-assessing-and-mitigating-vapor-intrusion-pathwav-
subsurface-vapor

Jackson Township. July 18, 1991. Waterline Hookup Ordinance. Ordinance No. 91-100.

Lockheed Martin. December 12, 2013. Butz Landfill Vapor Intrusion Study, Monroe County, Pennsylvania,
November 2013 Trip Report.

Lockheed Martin. April 3, 2014. Final Analytical TAGA Report, Butz Landfill Vapor Intrusion Study, Revision
1, Monroe County, Pennsylvania, April 2014.

Lockheed Martin. May 15, 2014. Trip Report, Butz Landfill Vapor Intrusion Study, Monroe County,
Pennsylvania, May 2014.

Monroe County, Pennsylvania, Recorder of Deeds. November 3, 2015. Environmental Covenant. Book 2462,
Pages 4216-4223.

Pocono Township. August 28, 1991. Waterline Hookup Ordinance. Ordinance No. 54.

A-l


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Tetra Tech. January 2008. Residential Vapor Intrusion Study Long-Term Remedial Action, Butz Landfill Site.

Tetra Tech. September 3, 2008. Round 2 Residential Vapor Intrusion Study Letter Report, Butz Landfill Site,
Long-Term Remedial Action.

Tetra Tech. July 27, 2011. Round 3 Residential Vapor Intrusion Study Letter Report (Revision No. 1), Butz
Landfill Site, Long-Term Remedial Action.

Tetra Tech. October 2011. Operation and Maintenance Manual, Remedial Response Activities, Revision No. 1,
Butz Landfill Site.

Tetra Tech. June 1, 2012. Round 4 Residential Vapor Intrusion Study Letter Report, Butz Landfill Site, Long-
Term Remedial Action.

Tetra Tech. May 16, 2013. Revised Round 5 Residential Vapor Intrusion Study Letter Report, Butz Landfill Site,
Long-Term Remedial Action.

Tetra Tech. September 29, 2017. Revised Updated Capture Zone Analysis (CZA) Evaluation, Butz Landfill
Superfund Site, Remedial Response Activities.

Tetra Tech. June 6, 2020. Evaluation of Updated Capture Zone Analysis (May 2020), Butz Landfill Site, Jackson
Township, Pennsylvania.

Tetra Tech. July 2016 - December 2020. Monthly Groundwater Pump and Treat System Operating Reports, Butz
Landfill Superfund Site, Remedial Response Activities.

Tetra Tech. March 2017. Sampling and Analysis Plan for Long-Term Remedial Action, Butz Landfill Superfund
Site, Operable Unit 2.

Tetra Tech. June 24, 2016. Fourteenth-Year Sampling Events (May 2014 - June 2015) Groundwater Monitoring
Report, Remedial Response Activities, Butz Landfill Superfund Site, Jackson Township, Monroe County,
Tannersville, Pennsylvania.

Tetra Tech. August 2016. Draft Fifteenth-Year Sampling Events (July 2015 - June 2016) Groundwater
Monitoring Report, Remedial Response Activities, Butz Landfill Superfund Site, Jackson Township, Monroe
County, Tannersville, Pennsylvania.

Tetra Tech. November 2017. Sixteenth-Year Groundwater Monitoring and System Operations Report (July 2016
- June 2017), Remedial Response Activities, Butz Landfill Superfund Site, Jackson Township, Monroe County,
Tannersville, Pennsylvania.

Tetra Tech. March 2019. Seventeenth-Year Groundwater Monitoring and System Operations Report (July 2017 -
June 2018), Remedial Response Activities, Butz Landfill Superfund Site, Jackson Township, Monroe County,
Tannersville, Pennsylvania.

Tetra Tech. March 2020. Eighteenth-Year Groundwater Monitoring and System Operations Report (July 2018 -
June 2019), Remedial Response Activities, Butz Landfill Superfund Site, Jackson Township, Monroe County,
Tannersville, Pennsylvania.

A-2


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Tetra Tech. March 2021. Nineteenth-Year Groundwater Monitoring and System Operations Report (July 2019 -
December 2020), Remedial Response Activities, Butz Landfill Superfund Site, Jackson Township, Monroe
County, Tannersville, Pennsylvania.

A-3


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APPENDIX B - SITE CHRONOLOGY

Table B-l: Site Chronology

I.mmH

D.ile

Site owners began landfilling activities at the Site

1965

Pennsylvania denied application from site owners for landfill operating

1970

permit



Residents submitted complaints about the Site to PADER, now called

1971

PADEP



PADER ordered the site owners to close the landfill

1973

Site owners ceased waste disposal at the Site

1973

Site owners installed landfill cover

September 1973

PADER found elevated levels of TCE in domestic wells south of the

1984 and 1986

landfill, and requested that EPA consider emergency response action



Pennsylvania requested EPA's assistance in defining and resolving the
Site's contamination problem

1986

EPA began an emergency removal action (providing residents with
bottled water)

July 1986

EPA proposed listing the Site on the Superfund program's NPL

June 24, 1988

EPA finalized the Site's listing on the NPL

March 31, 1989

EPA completed an engineering evaluation and cost analysis for OU1

August 13, 1990

EPA issued the OU 1 Record of Decision selecting construction of a

September 28, 1990

water supply system



EPA completed OU 1 remedial design

June 13, 1991

Jackson Township adopted Ordinance No. 91-100, requiring residents
within the water supply system's service area to use the water system as
their exclusive source of potable water, and requiring wells within the
service area to be disabled

July 18, 1991

Pocono Township adopted Ordinance No. 54, requiring residents within
the water supply system's service area to use the water system as their
exclusive source of potable water, and requiring wells within the service
area to be disabled

August 23, 1991

EPA issued OU2 remedial investigation and feasibility study

April 22, 1992

EPA began OU 1 construction

June 8, 1992

EPA issued OU2 Record of Decision selecting construction of a

June 30, 1992

groundwater extraction and treatment system



EPA finished connecting users to OU 1 water supply system

December 18, 1992

EPA completed OU1 construction

June 30, 1993

EPA completed OU 1 remedial action

September 14, 1993

EPA turned over the water system to the Pocono Jackson Joint Water

1995

Authority (PJJWA)



EPA issued first FYR

September 17, 1996

EPA completed OU2 remedial design

June 17, 1997

EPA issued first ESD

August 27, 1999

EPA and PADEP signed State Superfund Contract

October 28, 1999

EPA began OU2 construction

June 28, 2000

EPA completed OU2 remedial action

June 20, 2001

EPA issued Preliminary Close-Out Report
Site achieved "construction complete" milestone



EPA issued second FYR

September 28, 2001

Groundwater extraction and treatment remedy became operational and

October 1, 2001

functional



EPA issued third FYR

September 26, 2006

EPA increased the height of the air emissions stack and shut down the

March 2007

off-gas carbon treatment system



EPA conducted a vapor intrusion evaluation (round 1)

August 2007

B-l


-------
r.\cn(

D.ile

EPA conducted a vapor intrusion evaluation (round 2)

May 2008

EPA conducted Phase I of the in-situ enhanced bioremediation pilot test

April 2009

EPA conducted an updated groundwater human health risk assessment

January 2011

EPA conducted a vapor intrusion evaluation (round 3)

March 2011

EPA issued second ESD

July 27, 2011

EPA conducted Phase II of the in-situ enhanced bioremediation pilot test

August 2011

EPA issued fourth FYR

September 9, 2011

PADEP took over responsibility for the Site's O&M

October 2011

EPA conducted a vapor intrusion evaluation (round 4)

March 2012

EPA conducted a vapor intrusion evaluation (round 5)

January 2013

EPA conducted a vapor intrusion evaluation (round 6)

November 2013

EPA conducted a vapor intrusion evaluation (round 7)

March 2014

EPA issued fifth FYR

August 25, 2016

EPA conducted a capture zone analysis for the Site's groundwater
extraction system

February - September 2017

EPA began monitoring the Site using Pennsylvania's One Call system

March 2017

EPA replaced extraction well EW-3 with EW-5 and conducted an
updated capture zone analysis

May 2020

EPA issued Remedial Action Completion Report for the modification of
the groundwater extraction system

November 2020

B-2


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APPENDIX C - ADDITIONAL SITE MAPS

Figure C-l: Site Vicinity Map

Butz Landfill
Superfund Site

Tannersville

[Stroud sburq

IBrodheadsvitte



Tannersville

0	0.375	0.75	1.5

Miles

Sources: Esri, U.S. Census Bureau 2019 TIGER/Line Geodatabases,
Bureau of Transportation Statistics, EPA, DigitalGlobe, GeoEye,
Earthstar Geographies, DeLorme, Tele Atlas, AND, First American,
UNEP-WCMC. USGS, CNES/Airbus DS. USDA. AeroGRID, IGN, the
GIS User Community and the 2016 FYR.

Legend

Landfill Property
= Original Water Supply System
= Later Additions to Water Supply System

^ Skeo

Butz Landfill Superfund Site

Jackson Township, Monroe County, Pennsylvania

Disclaimer: This map and any boundary lines within the map are approximate and subject to change. The map is not a survey. The map is for informational
purposes only regarding EPA's response actions at the Site.

c-i


-------
Figure C-2: Monitoring Wells

C-2


-------
EW-5	11/13/20

CCE (|ig/L)	1,040

TCE (MQ.'L)	1,500

VC (yg/L)	64.5

R1-1A

DCE (pgA.)
TCE < j^L)
VC(pg/L)

MW-6011

DCfc (pg/L)
TCE (pg/L)
VC (iig/Lji

11/11/20
172
1,230
ND

Figure C-3: TCE, cis-l,2-DCE and Vinyl Chloride Concentrations, Autumn 2020

DCE (pg/L)
TC5 Im^L>
VC(Mgfl-)

R2

DCE (pgA.)
TCt (.(JS-fL)
VC  48.6
VCfygiL} 1&4

B

C

11/12/20

11/12/20

49.0

T.6

38.8

0.62

12.5

4.6



MW-6012	11/11/20

DCE (pg/L)	03.0

TCE (uy/L)	260

VC (pg/L)	MO

DCE (pg/L)
TCE (M0L>
VC (pg/Lj>

A

06/07/19
36.2
117
ND

B

05/07/19
rfi.B
3.8
42.3

LEGEND:

INACTIVE EXTRACTION WELL
LOCATION AND DESIGNATION

EXTRACTION WELL LOCATION
NOT SAMPLED OR USED

MONITORING WEIL LOCATION
AND DESIGNATION

MONITORING WELL LOCATION
NOT SAMPLED OR USED

cfs— 1,2—Dl CW LOROETHE NE

TETRATECH

TRICHLORGETHENE

VINYL CHLORIDE

AVERAGE OF MULTIPLE RESULTS
FROM MULTIPLE ANALYSES

NON DETECT

ROADS

SURFACE WATER

LANDFILL

&RW14

I f

112IC08434GM01

SCALE

AS NOTED

EW-6	11/1Q/20
DCE  J54
TCE (Utfi'l) 530
VC {pg/L) AID

C

11/12/20

TCE. DCE, AND VC CONCENTRATIONS
AUTUMN 2020
BUTZ LANDFILL SITE
MONROE COUNTY, PENNSYLVANIA

F!GUn£ NUMBER

2-10

PWA A	B	C	D

11/11/20 11/11/20	1V11/20	11,'11/20

DCE (pg/L) 108	172	354 173

TCE
-------
Figure C-4: 2001 TCE Plume

LEGEND:

¦ EXTRACTION WELL LOCATION AND
EW2 DESIGNATION

I LANDFILL

5	TCE CONCENTRATION CONTOUR,

TCE >5 jUg/L <100 ^jg/L
(DASHED WHERE INFERRED)

tOO TCE CONCENTRATION CONTOUR.

TCE £100 pg/L <1,000 pg/L

—1,000— TCE CONCENTRATION CONTOUR,
TCE >1,000 jug/L

1200

SCALE IN FEET

TETRATECH

ESTIMATED EXTENT OF
GROUNDWATER PLUME BEFORE
GROUNDWATER TREATMENT, 2001

BUTZ LANDFILL SITE
MONROE COUNTY, PENNSYLVANIA

FILE

SCALE

112IC08434GM06

AS NOTED

FIGURE NUMBER

REV DATE

FIGURE 2-2

0 5/22/1a

ACRES
L20J KILOMETERS*

C-4


-------
Figure C-5: 2016 TCE Plume



1,000-

LANDFlUL

/ . .J

JL_!L
V

\ I

LEGEND:

¦ EXTRACTION WELL LOCATION .AND

ew2 des:gwation

wc$ LANDFILL

	5	TCE CONCENTRATION CONTOUR,

TCE >5 pg/L <100 pg/l
(DASHED WHERE INFERRED)

100 TCE CONCENTRATION CONTOUR,
TCE 2,tOC jjg/L <1,000 fjq/l

	1,000— TCE CONCENTRATION CONTOUR,

TCE >1.000 pg/L

SCALE IN FEET

TETRATECH

RECENT ESTIMATED EXTENT
OF GROUNDWATER PLUME
SPRING 2016
BUTZ LANDFILL SITE
MONROE COUNTY, PENNSYLVANIA

FILE

112C07599GM05

SCA.E

AS NOTED

F'GURE MUMfiCR

FIGURE 2-3

REV	DATE

0 8/16/16

ACRES
0.79 KILOMETERS*

C-5


-------
Figure C-6: 2017 TCE Plume

si

s
!

s

s

j



LEGEND:

¦ EXTRACTION WELL LOCATION AND
EWV DESIGNATION

5		 ~CE CONCENTRATION CONTOUR.

TCE >5 ;jg/L <100 /jg/L
(DASHED WHERE NFERRED)

100 TCE CONCENTRATION CONTOUR.

TCE £100 Jjg/L <1,000 jwg/L

-1,000—-CE CONCENTRATION CONTOUR,
TCE £1.000 pg/L

SCALE IN FEET

TETRATECH

RECENT ESTIMATED EXTENT
OF GROUNDWATER PLUME
SPRING 2017
BUTZ LANDFILL SITE
MONROE COUNTY, PENNSYLVANIA

FILE

112C07599GM05

SCALE
AS NOTED

Fi3U=?E NUMBER

FIGURE 2-3

DATE

5/13/17

EW1L3

ACRES
0.79 KILOMETERS'

C-6


-------
Figure C-7: 2018 TCE Plume

It

TETRATECH

RECENT ESTIMATED EXTENT
OF GROUNDWATER PLUME
SPRING 2018
BUTZ LANDFILL SITE
MONROE COUNTY. PENNSYLVANIA

FILE

1121C08434GM01



FIGURE NUMBER

FIGURE 2-3

¦ EW2

LEGEND:

¦ EXTRACTION WELL LOCATION AND
FW? DESIGNATION

_ I LANDFILL

	5	TCE CONCENTRATION CONTOUR,

TCE >5 ^jg/L <100 >jg/L
(DASHED WHERE INFERRED)

tOO TCE CONCENTRATION CONTOUR.

TCE >100 pg/L <1,C0C >jg/L

—1,000— TCE CONCENTRATION CONTOUR,
TCE ^1,000 jug/L

1200

SCALE IN FEET

ACRES
0.79 KILOMETERS'

C-7


-------
Figure C-8: 2019 TCE Plume

It

LEGEND:

¦ EXTRACTION WELL LOCATION AND
EW2 DESIGNATION

LANDFILL

	5	TCE CONCENTRATION CONTOUR,

TCE >5 pg/L <100 pg/L
(DASHED WHERE INFERRED)

100 TCE CONCENTRATION CONTOUR.

TCE 2.100 pg/L <1.000 pg/L

—1.000— TCE CONCENTRATION CONTOUR,
TCE £1.000 pg/L

0	600	]200

SCALE IN FEET

TETRATECH

RECENT ESTIMATED EXTENT
OF GROUNDWATER PLUME
SPRING 2019
BUTZ LANDFILL SITE
MONROE COUNTY, PENNSYLVANIA

112IC08434GM09

SCALE

AS NOTED

FIGURE NUMBER

FIGURE 2-3

DATE

7/2/19

EW13

^— m

EW3

:&ns-°°°°7s

ACRES
0.79 KILOMETERS*

C-8


-------
Figure C-9: 2020 TCE Plume

C-9

L£££MQl

¦ EXTRACTION WELL LOCATION AND
EW2 DESIGNATION

LANDFILL

	5	TCE CONCENTRATION CONTOUR.

TCE >5 jjg/L <100 pg/L
(DASHED WHERE INFERRED)

100 TCE CONCENTRATION CONTOUR,
TCE £100 pg/L <1,000 pgA

1.000 — TCE CONCENTRATION CONTOUR,
TCE >1,000 pg/L

SCALE IN FEET

ft

TETRATECH

RECENT ESTIMATED EXTENT
OF GROUNDWATER PLUME
AUTUMN 2020
BUTZ LANDFILL SITE
MONROE COUNTY, PENNSYLVANIA

11 ?ICQfl434GM04
nCJRE NUMBER

2-3

SCM£
AS NOTED

B£V	MTT

0 1/10/2)



v>. ,¦>, N ' \ \

^===>: X\ />


-------
APPENDIX D - INSTITUTIONAL CONTROLS

Figure D-l: Jackson Township 1991 Waterline Hookup Ordinance

Tip &U1ttecK-OP O/tdliMUce

;¦ UACKSttJ "r	f	Adopted 7/16/91

8l3bjll

CiKISC: POCOKO
EGF;mrab (4/9/91)

ORDINANCE 80. 91-100

IK ORDINANCE DESIGNATING THE 'HATER SUPPLY SY8TEX TO BE OPERATED BY THE
POCONO JACKSON JOINT WAITER AUTHORITY AS THE EXCLUSIVE SOURCE OF POTABLE
HATER FOR HUMAN CONSUMPTION AND FOR ALL OTHER USES IN AREAS OF THE
TOWNSHIP, REQUIRING ABUTTING PROPERTY OWNERS TO CONNECT WITH AND USE
SUCH WATER SUPPLY SYSTEM, AUTHORIZING TKE SUPERVISORS TO MAKE SUCH
CONNECTION AND RECOVER THE COST THEREOF IN CASE OF NEGLECT OR REFUSAL
OF OWNERS TO DO SO, PROVIDING FOR INSPECTION OF THE CONNECTIONS AND
PENALTIES.

WHEREAS, the underground waters of certain portions of Pocono and
Jackson Townships have been adversely affected by the discharge into
those Maters of contaminants and pollutants from a source known ae the
But* Landfill, and

WHEREAS, the contamination and pollution of the said waters of the
township has rendered those waters unfit for human consumption and use,
and

WHEREAS, the Butz Landfill and the affected areas of Pocono and
Jackson Townships have been placed on the National Priorities List
pursuant to the Comprehensive Environmental Response, Compensation and
Liability Act (CERCLA), PL 96-510, 42 USC 9601-9657, as amended and
reauthorized, commonly known as "Superfund", and

WHEREAS, to provide potable and safe water for human consumption
and use, the townships of Pocono and Jackson have formed the Pocono
Jackson Joint Water Authority for the purposes, inter alia, of
acquiring, holding, constructing, altering,, improving, refurnishing,

¦V *' ¦

enlarging, furnishing water works, water supplies, water distribution

D-l


-------
systems and the acquisition of lands or interests therein necessary for
such purposes in the township, and

whereas, It is in the public interest of all citizens of tha
township that a public water supply and water supply systea be provided
in the township in the affected areas, and

whereas f the Authority Is proceeding to construct, or have
constructed, a water supply system In an area designated as the service
area, which is store particularly described as follows!

(insert description)

Bounded by North Road, Possinger Drive, Storm Lane, and
Pennsylvania Legislative Route 715, and as may from time to time
be amended by the Jackson - Pocono Joint Water Authority.

i ins

whereas, pursuant to "Superfund* and applicable laws and
regulations, there is to be constructed within'the township a potable
water system to be owned and operated by the Authority, in the
designated service areas of the township, and at such other places
within the township as 'tee township may in tha future be established by
resolution of the township,

NOW, THEREFORE, be it ordained by the Supervisors of Jackson
Township, Monroe County, Pennsylvania as follows:

Section It Definitions. Unless^ the context specifically denotes
otherwise, the aeaning of the taras used in this Ordinance shall be as
follows:

consulting- ingtaear

The Registered Professional Engineer employed by the Township or

the Authority for the design, supervision of construction, or operation

2

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of the Water Supply System within the Township, or any member of his
staffs

Service Line^

The water line on the property of an abutting property owner from
the water distribution line to the location of the water in the building
of an abutting property owner.

• water ygt*y

A device for Measuring the quantity of water used to be installed
by the Authority or Township on the premises of the abutting property
owner.

The water distribution system constructed in the Township and
operated by the Authority, and to include the acquisition of all
necessary lands, easements and rights-of-way and the construction of a
Mater Works System including pumping stations, water distribution
systen, fire hydrants, valves and appurtenances thereto.

Section 2: Exclusive Source of Water. The water supply system to
be constructed within the Township shall provide the exclusive source
of water for human consumption and for industrial, commercial or farm
use within that portion of the Township herein or hereafter designated
by the Supervisors of the township or any part thereof, and abutting
property owners shall connect with and use such water supply system in
the manner herein provided. Within thirty (30) days following
connection of the water supply system, each abutting property owners
within the designated area shall permanently render any well or wells

3

D-3


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on the property- theretofore used for the production and provision of
water for any purpose incapable of drawing, producing or providing any
additional quantify of water, nor shall the veil or wells be used to
draw, produce or provide water for any purpose whatsoever, The
Authority and the Township shall be empowered to establish rules and
regulations concerning the disablement of any well within the designated
area and to enforce the sane. -

Section li Mandatory Connection. Each owner of any house,
building, structure or property used for human occupancy, employment,
recreation, or other purpose situated within a designated area of the
Township and abutting on any street, alley or right-of-way in which
there has been constructed a water supply system shall connect to such
water supply system in accordance with the following schedule:

a)	if the cost of connection is borne by an agency of the federal
government, then at such tine as the connection is supplied and
installed by 'the federal government or its contractors.

b)	In all other cases, within sixty {60) days after the date of
notice to do so given In the manner prescribed by law by the Supervisors
of the Township or their agent.

Section 4; Payment for connection.

Unless the cost of the connection, as hereinafter defined, is borne
by an agency of the federal government, pursuant to law and regulation,
then the cost of connection shall be at the sole expense of the owner

of any property for which connection is mandatory. *

4

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gee felon 5i	CoimftctAon bv	Supervisors or their Agents* In case any

owner of property shall neglect or refuse to connect with said water
system for a period of sixty (60) days after notice to do so lias been
served upon hi* fey the Supervisors or their Agents, either by personal
service or by register nail, the Supervisors or.their Agents a&y enter
upon such property and construct such connection. In such case, the
Supervisors shall forthwith, upon completion of the work, send an
itemized bill of the costs of construction of such connection to the
owner of the property to which connection has been made, which bill
shall be payable forthwith or the Supervisors may authorize the payment
of the cost of construction of connections in equal monthly
installments, to bear interest at a rate not exceeding 7% per annum, for
a period not to exceed one year.

Section..ss	float	of	CormectiOB The cost of construction of the

connection shall include the cost of construction of the Service Line
on the property of the abutting owner for the distribution line to a
location within the building where the meter is located, including the
cost of the meter and all necessary connections and equipment.

Section 7s payment. The cost of construction of the connection
shall be payable at the office designated form time to tine by the
Supervisors either in whole within thirty (30) days, or in equal monthly
installments with interest at the rate of 7% per annum from the date of
completion of construction. In case of default in the payment of any
installment and interest for a period of siifty. (60)-days after the same
shall become due, the entire cost of construction of connection and

5

D-5


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accrued Interest shall become due; and, the Township Solicitor shall
proceed to collect the same under the general laws relating to the
collection of Municipal claims.

section ai Application for Service. Each owner of any premises set
forth in Section 3 hereof shall make application in writing to the
Authority for water service. Such application shall be in such form as
the-Authority shall designate.,

Section.9;	Protection from Pamag«.. Mo person shall maliciously,

wilfully, or negligently break, damage, destroy, uncover, deface, or
tamper with any structure, appurtenance, or equipment which is a part
of the municipal water supply system.

Section 10t Powers and authority of Inspectors. The Consulting
Engineer and other duly authorized employees or agents of the Township
or the Authority bearing proper credentials and identification shall be
permitted to enter upon all properties for the purpose of inspection,
observation, measurements, sampling and testing in accordance with the
provisions of this Ordinance.

Section ill Penalties.

a) Any person who shall violate any provision of this Ordinance
shall be served by Jackson Township with written notice stating the
nature of the violation and providing a reasonable time limit for the
satisfactory correction thereof. THe offender shall, within the period
of time stated in such notice, permanently cease all violations. Any
person who shall continue any violation aftejr such notice be subject to
a fine in an amount not exceeding $300.00 for each violation. Each day,

6

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or part thereof, during which noncompliance with this ordinance shall
continue, shall be a separate violation.

b.	All fine,s and penalties imposed for violation of any part of
this Ordinance shall be paid to the Treasurer of the Township of Jackson
for the use of the Township. Default in payment of the fine and costs
shall sake the defendant liable to imprisonment for a tern not to exceed
thirty (30) days.

c.	Any person violating any of the provisions of this Ordinance,
in addition to becoming liable for a fine and penalty, shall become
liable to the Township for any expense, loss or damage occasioned the
Township or the Authority by reason of such violation.

a.	All Ordinances or parts of Ordinances in conflict herewith are
hereby repealed.

b.	The invalidity of any Section, clause, sentence, or provision
of this Ordinance shall not affect the validity of any other part of
this Ordinance shall not affect the validity of any other part of this
Ordinance which can be given effect without such invalid part or parts.
It is hereby declared to be the intention of the Supervisors of

had such invalid Section, Clause, sentence, or provision not been
included herein.

Jackson

Township that this Ordinance would have been adopted



Vice Chairman

7

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Figure D-2: Pocono Township 1991 Waterline Hookup Ordinance

T&CO/JO 7~Of>. WbteRji/O®	^Wc//A>dAice

POCONO TOWNSHIP SUPERVISORS

H, JANE CILUISO, Soewtory and Treasurer

TANNIRSVIULt, PENNSYLVANIA 18372
(717 >629-1922

August 30, 1991

Mr. Victor Janosik (3HW27)

U. S. Environssental Protection Aqencv

841 Chestnut Boulevard
Philadelphia, PA 19017

REFERENCE: POCONO-TWP. ORDINANCE #54 - (WATER CONNECTION)

RE; POCONO-JACKSON JOINT WATER AUTHORITY

BUTZ LANDFILL, ETC,

Dear Mr.Janosik;

time?6 adViSB Sh°Uld	further be required at this

Sincerely,

POGpNO TOWNSHIP SUPERVISORS

Cilurso	¦ •

secretary

Enc.

jc

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CtHISCS POCONO	1 :

EGFtxrnib (4/9/91)

ORDINANCE SO.

m ORDINANCE DESIGNATING THE RATER SUPPLY SY8TEM TO BE OPERATED BY THE
POCONO JACKBON JOINT WATER AUTHORITY AS THE EXCLUSIVE SOURCE OF POTABLE
WATER FOR HUMAN CONSUMPTION AND TOR ALL OTHER USES IN AREAS OF THE
TOWNSHIP, REQUIRING ABUTTING PROPERTY OWNERS TO CONNECT WITH AMD USE
SUCK WATER SUPPLY SYSTEM, AUTHORISING! THE SUPERVISORS TO MAKE SUCH
CONNECTION AND RECOVER THE COOT THEREOF IN CASE OF NEGLECT OR REFUSAL
OF OWNERS TO DO SO, PROVIDING JTOft INSPECTION OF THE CONNECTIONS AND
PENALTIES.	, .

WHEREAS, the underground waters of certain portions of Pocono and

Jackson Townships have been adversely effected by the discharge into

those waters of contaminants and pollutants from a source known as the

Butz Landfill, and

WHEREAS, the contamination and pollution of the said waters of the

township has rendered those waters unfit for human consumption and use,

and		

* WHEREAS, the Butz Landfill and the affected areas of Pocono and

Jackson Townships have been placed on the National Priorities List

pursuant to the Comprehensive Environmental Response, Compensation and

Liability Act (CEKCLA), PL 96-510, 42 USC 9601-9657, as amended and

reauthorized, commonly known as *8uperfund", and ¦

WHEREAS, to provide potable and eafe water for human consumption

and use, the townships of Pocono and Jackson have formed the Pocono

Jackson Joint Water Authority for the purposes, inter alia, of

acquiring, holding, constructing, altering, improving, refurnishing,

enlarging, furnishing water works, water supplies, water distribution

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», systems and the acquisition of lands or Interests therein.Decessary for
such purposes in the township, and

WHEREAS, it is lit the public interest of all citizens of tha
township that a public water supply and water supply system be provided
in the township In the affected areas, and

WHEREAS, tha Authority is proceeding to construct, or • hava
constructed, a water supply system in an area designated as the service
area, which Is more particularly described oft tfi# map attached
hereto and made part hereof as Exhibit "A"#

«	i	' '

, and

WHEREAS, pursuant to "Superfund" and applicable laws and

regulations, there ia to be constructed within the township a potable
water system to be owned and operated by the Authority, in the
designated service areas of tha township, and at such other places
within the township as the township way in the future be established by
resolution of the township,

NOW, THEREFORE, be it ordained by tha Supervisors of
Township, Monroe County, Pennsylvania as followst

Section li Definitions,. Unless the context specifically denotes
otherwise, the weaning of the terns used in this ordinance shall be as
follows!

SfiMBlMM-Bnataeai	,

The Registered Professional Engineer employed by the Township or
the Authority for the design, supervision of construction, or operation

2

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•of the Water Supply System within the Township, or any member of his

• i . "	* • *	*

staff.		¦* 1	-I-	i* • - • . - .

Service Linn	¦¦•I'--:- vc.	1

The water line on the property of an abutting property owner from
the water distribution line to the location of the meter in the building
of an abutting property owner.

Water Meter

A device for measuring the quantity of water used to be installed

by the Authority or Township on the premises of the abutting property

owner,	' ! " ¦ ' 'r!- '•

-» *

Rater supply System	'

The water distribution system constructed in the Township and
operated by the Authority andf to include the acquisition of all
necessary lands, easements and rights-of-way and the construction of a
Hater Works System including putnping stations, water distribution
system, fire hydrants, valves and appurtenances thereto.

Section 2t Exclusive Source of water. The water supply system to
be constructed within the Township shall provide the exclusive source
of water for human consumption and for industrial,:commercial or farm
use within that portion of the Township herein or hereafter designated
by the supervisors of the township or any part thereof, and abutting
property owners shall connect with and use such water supply system in
the manner herein provided. -Within thirty (30) days following
connection of the water supply system, each abutting property owners
within the designated area shall permanently render any well or wells

3

D-ll


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, on the property theretofore vised for the production and provision of

water for any purpose Incapable of drawing, producing or providing any
additional quantity of water, nor shall tha well or walls be used to
draw, produce or provide water lor any purpose whatsoever. Tha
Authority and the township shall foe empowered .to establish rule* and
regulations concerning tha disablement of any well within the designated
area and to enforce the sane.

Section 3t Mandatory Connection. Each owner of any house,
building, structure or property used for human occupancy, employment,
recreation, or other purpose situated within a designated area of the
Township and abutting on any street, alley or right-of-way in which
there baa been constructed a water supply system shall connect to such
water supply system In accordance with the following schedules

a)	If the cost of connection is borne by an agency of the federal
government, then at such time ae the connection is supplied and
installed by the federal government or its contractors.

b)	In all other eases, within sixty (60) days after the date of
notice to do so given in the manner prescribed bf law by the Supervisors
of the Township or their agent.

Unless the cost of the connection, as hereinafter defined, is borne
by an agency of the federal government, pursuant to law and regulation,
then the cost of connection shall be at tha sola expense of tha owner
of any property for which connection is mandatory.

4

,. jjzjzmamaam

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Section 51 Connection by Supervisors or their agents. In case any

» • ¦*

owner of property shall' neglect or refuse to connect with said water
system for a period of sixty (60) days after notice to do so has been
served upon him by the Supervisors or their Agents, either by personal
service or by register mail, the Supervisors or their Agents way enter
upon such property and construct such connection. In such case, the
Supervisors shall forthwith, upon Completion of the work, send an
itemized bill of the costs of construction of'such connection to the
owner of the property to which connection has been tnade, which bill
shall be payable forthwith or the Supervisors nay authorize the payment
of the cost of construction of connections in equal monthly
installments, to bear interest at a rate not exceeding 7% per annum, for
a period not to exceed one year.

Section 61 Cost of Connection. The cost of construction of the
connection shall include the coat of construction of the Service Line
on the property of the abutting owner for the distribution line to a
location within the building where the meter is located, Including the
cost of the meter and all necessary connections and equipment.

section 7i Payment. The cost of construction of the connection
shall be payable at the office designated form time to time by the
Supervisors either in whole within thirty (30) days, or in equal monthly
installments with interest at the rate of 7% per annum from the date of
completion of construction. In case of default in the payment of any
installment and interest for a period of sixty (60) days after the same
shall become due, the entire cost of construction cf connection and

5

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,accrued interest shall become duaf and, the Township Solicitor shall
proceed to collect tha same under tha general laws relating to the
collection of Municipal claims.	,

Beotlon 8i Application -tor Berries. Each owner of any premises set
forth in Section 3 hereof shall make application in writing to the
Authority for water service. Such application shall be in such form as
the Authority shall designate. •

Station 9» Protection from Damage. , Ho person shall maliciously,
wilfully, or negligently break, danage, destroy, uncover, deface, or

tamper with any structure, appurtenance, or equipment which is a part

»

of the Municipal water supply system.

flection..lot	Powers and Authority	of Inspectors. The Consulting

Engineer and other duly authorised employees or agents of the Township
or the Authority bearing proper credentials and identification shall be
permitted to enter upon all properties for tha purpose of inspection,
observation, measurements, sampling and testing in accordance with the
provisions of this Ordinance.

Section 111Penalties. -
. a) Any person who shall violate any provision of this Ordinance
shall be served by tiwnnn	Township with written notice stating the

nature of the violation and providing a reasonable tima limit for the
satisfactory correction thereof. THe offender shall, within the period
of time stated in such notice, permanently cease all violations. Any
parson who shall continue any violation after such notice be subject to
a fine in an amount not exceeding $300.00 for each violation. Each day,

6

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or part thereof, during which noncompliance with this ordinaries shall
continue, shall ba a separate violationt

b.	All fines and penalties imposed for violation of any part of
this Ordinance shall be paid to the Treasurer of the Township of jEocono
for the use of the Township* Default in payment of the fine and costs
shall make the defendant liable to imprisonment for a tar® not to exceed
thirty <30) days,

c.	Any person violating any of the provisions of this Ordinance;
111 addition to becoming liable for a fine and penalty, shall become
liable to the Township for any expense, loss or damage occasioned the
Township or the Authority by reason of such violation.

flection 12t validity.

a* All Ordinances or parts of Ordinances in conflict herewith are
hereby repealed.

f». The invalidity of any Section, clause, sentence, or provision

of this Ordinance shall not affect the validity of any other part of
this Ordinance shall not affect the validity of any other part of this
Ordinance which can be given effect without such invalid part or parts.
It is hereby declared to be the intention of the Supervisors of

Snrnnn		 Township that this Ordinance would have been adopted

had such invalid Section, Clause, sentence, or provision not been
included herein.

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IN WITNESS WHEREOF, the Fooono Township Board of Supervisors
hftve hereunto enacted the foregoing Ordinance this JLiB day of
(J/j.Cotr 1991, the same to be effective five (8) days after
Resent.

ena

ATTEST,-

V



e Cllurso, Secretary

POCQNQ TOWNSHIP BOARD OF
SUPERVISOR

L. Patrick Roes, Chairman

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Figure D-3: 2015 Environmental Covenant

K

OWNER/GRANTOR: Twfev Mamgou.w.% LLC

PROPERTY ADDRESS: 408 North Rani, iwkm T*w*lp, Moan» Cwuty
COUNTY PARCEL NO: Wf§m-1

COUNTY PIN NO: 08-6362-003S-7153
PEED BOOK/PAGE: 2267-6797

ENVIRONMENTAL COVENANT

This Environmental Covenant is executed pursuant to the Pennsylvania Uniform Environmental
Covenants Act, Act No. 68 of2007,27 Pa. C.S. §§ 6501 - 6517 ("UECA"). This Environmental
Covenant subjects the Property identified in Paragraph 1 to the activity and/or use limitations in
this document. As indicated later in this document, this Environmental Covenant has been
approved by the United States Environmental Protection Agency ("EPA").

1. Property Affected.

He property affected by this Environmental Covenant (die "Property") is located in Jackson
Township, Monroe County, Pennsylvania.

He addra* of the Property is: 40# North Road, Jackson Township, Monroe County, PA,

The latitude and longitude of the approximate center of the Property is: Latitude 41.03397N and

Longitude 75.34291 W.

The Property subject to this Environmental Covenant is a part of the Butz Landfill Superftmd
Site ("Site"), EPA ID# PAD 03Q6.

Exhibit A to this Environmental Covenant is a copy of an Indenture, dated March 8,1963, which
provides a legal description of the Property.

A map of the Property is attached to this Environmental Covenant its Exhibit B.

;	REC to* 2462 Put *3i&

'

¦
i

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2-	Property Owner/GRANTOR / GRANTEE

Twins Management, LLC, a Pennsylvania Limited Liability Corporation, is the OWNER of the

Property and the GRANTOR and GRANTEE of this Environmental Covenant.

TTjfijpaliag address of the- Owner/Grantor and Orantaa i«»

629 East Drinker Street

Lower Level

Dtnunore, PA 18512

3-	PfigeriptiiHi of Contamination & .Remedy.

ITie Site includes an inactive 8.5 acre landfill on two parcels of land located south of
Camelback Mountain along 1 ownship Road 601. The Property is one of these two parcels As
part of the remedial action for Operable Unit 2 for the Site, EPA constructed a groundwater
treatment plant on the Property to address groundwater contamination at the Site. The Property
also contains an access road leading to the groundwater treatment plant, as well as some of the
associated piping for the pump and treat system. There are five (5) groundwater quality
monitoring wells (wells EW-4, R-1D.R-1S, 1-1 A, and
T-1B) that are sampled annually.

In the 1960s, wrote was disposed of at the Property. The landfill accepted municipal
waste, sewage sludge/liquids, and possibly industrial waste. A subsequent application for an
operating permit for the landfill was denied by the Pennsylvania Department of Environmental
Protection ("PADEP") (then the Pennsylvania Department of Environmental Resources
("PADER")) due to insufficient technical information. PADEP (then PADER) ordered the
landfill closed in 1973 due to improper operation.

In 1986, PADEP identified chlorobenzene, trans-1,2-dichloroethylene, vinyl chloride,
and tnchloroethylene (TCE) in ground water. A private well located 1,700 feet east of the Site
contained 2,600 parts per billion of TCE. Analyses conducted by PADEP in 1979 also indicated
elevated levels of chromium and mercury in drinking water wells. In January 1987, EPA
confirmed organic chemical contamination in more than 20 wells downgradient of the Site.

^st£^ ^ Site on CERCLA's National Priorities List on March 31, 1989.
EPA divided the cleanup of the Site into two operable units ("OUs"). On September 28 1990
EPA issued a Record of Decision ("ROD") for OU-1, in which it selected construction of a
wateriine to provide area residents affected by the contaminated groundwater with a new source

?n£ra!r fater' EPA subsea'uentiy completed construction of the waterline in December of
1993. On June 30, 1992, EPA issued a ROD for OU-2, This ROD selected a pump and treat
system to clean up the contaminated groundwater to levels that would meet state and federal
applicable and relevant and appropriate standards as well as be protective of human health and

SS5S? 2" iUgUl27'i9"J EPA i8Sued 811 Emanation of Significant Differences
( 999 ESD ) for the Site. Hie 1999 ESD called for additional extraction wells and changed the

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OU?RODwidSandanl1510 addreSSChan8es in *"** 8ta"danb since the date the original

„en!„ °?.J",y.27'2011> EPA issued 8 sec<>nd Explanation of Significant Differences ("2011

ILt „T8eCl Certain groundwater performance standards and required institutional
controls ('ICs ) for the Site. ICs are non-engineered instruments, such as administrative Mid/or
legal controls, that help to minimize the potential for exposure to contamination and/or protect
the integrity of a Superfund cleanup. ICs limit land or resource use by providing information
that helps modify or guide use of Superfund sites. Pursuant to the 2011 ESD EPA with the

f	^ICS WCrc necessar>'in for the 'remedy selected in

the OU RODs and ESDs (collectively the "Selected Remedy") to remain protective in the lone
term due to the presence of groundwater above levels that allow for unlimited use and
unrestricted_ exposure The ICs described in the 2011 ESD are necessary to protect human health
ana tne environment by preventing exposure to contaminated groundwater and to preserve the
integrity of the components of the Selected Remedy.

Remedy Imniementarinn

i C~i0n aLctivities for 016 0lM water line began on June 8, 1992 and were completed
™ • w,th alJ users connected to the system by December 18, 1993. On September
17,1996, EPA issued the first Five Year Review of OU-1 which confirmed that there was no
exposure to human health due from Site-related contaminants.

rw, a ?? iJU?C 28' 200°'EPA began	activities in connection with the OU-2 ROD.

On April 11,2001, EPA began construction of the groundwater pump and treatment system,
the groundwater pump and treat system became operational and functional on October 1,2001.
1 he second Five Year Review, which was issued on September 26,2001, confirmed the

ene^ °fb0th ^ OU~1 3,1(3 ou"2 remedies. In August of 2011, PADEP took over from
EPA the maintenance and operation of the groundwater pump and treat system located on the

Property pursuant to a Superfund State Contract. The pump and treat system is currently
operational.	J

mful^ins complete copies of the Administrative Records supporting the OU RODs
and ^Ds for the Site. The Administrative Records are available at the Pocono Township

^ 61 ,J Tannersvi»e>PA ' 8372 as well as at EPA Region III, 1650 Arch
Street, Philadelphia, PA 19103-2029. The Administrative Records are also available on the

internet at:

h.U.p://wwvv.epa.gov/re^.1hwmd/suner/sites/PAD000441337/index.htm

In May of2006, the Property was sold to Twins Management, LLC. Twins Management
i„ response to a request from EPA, to implement the ICs required in the
Ui bbD in the form of this Environmental Covenant on the Property with the Monroe County
Recorder of Deeds m order to protect human health and the environment by preventing exposure
to contaminated groundwater and to preserve the integrity of the components of the Selected

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5. Activity & Use Limitations. The Property is subject to the following activity
and use limitations, which the then-current owner of the Property, and its tenants, agents,
employees and other persons under its control, shall abide by:

(a)	Groundwater at the Property contaminated with TCE and/or other COCs
listed in the 2011 ESD (attached hereto as Exhibit C) that exceed(s) any of
the performance standards selected in the 2011 ESD shall not be used for
drinking water or bathing, or any other potable use.

(b)	The Property, including the access road and structures associated
with the groundwater treatment plant located on the Property, shall not be
used in any way that has a potential to adversely affect or interfere with
the efficacy and function of the treatment plant at the Site, including any
underground extraction and discharge piping or the monitoring weils.

6 Notice of Limitations ill Future Conveyances. Each instrument hereafter
conveying any interest in the Property subject to this Environmental Covenant shall contain a
notice of the activity and use limitations set forth in this Environmental Covenant and shall
provide the recorded location of this Environmental Covenant.

7- Compliance Reporting. By the end of January following EPA approval of this
Environmental Covenant, the then-current owner of the Property shall submit to EPA and
PADEP written documentation staling whether or not the activity and use limitations in this
Environmental Covenant are being abided by. In addition, within twenty-one (21) calendar days
after a) written request by EPA or PADEP, b) transfer of title of the Property or any part of the
Property affected by this Environmental Covenant, c) noncompliance with Paragraph 5 (Activity
and Use Limitations), and/or d) an application for a permit or other approval for any building or
proposed Site work, if the building or proposed Site work will affect the groundwater
contamination, the access road, the pump and treat system, and/or any associated piping and
monitoring wells on the Property subject to this Environmental Covenant, the then-current owner
will send a report to EPA and PADEP. The report will state whether or not there is compliance
with Paragraph 5. If there is noncompliance, the report will state the actions that will be taken to
assure compliance.

8. Access by the EPA and PADEP. In addition to any rights already possessed by
the EPA and/or PADEP, this Environmental Covenant grants to the EPA and/or PADEP a right
of reasonable access to the Property in connection with implementation or enforcement of this
Environmental Covenant as well as to conduct any response actions at the Property.

9- Recording and Proof and Notification. Within thirty (30) calendar days after
the date of the EPA's approval of this Environmental Covenant, Twins Management, LLC shall
File this Environmental Covenant with the Monroe County Recorder of Deeds and send a file-
stamped copy of this Environmental Covenant to the EPA and PADEP within ninety (90)
calendar days of EPA's approval of this Environmental Covenant. Within that time period.

Twins Management, LLC also shall send a file-stamped copy to each of the following: Jackson

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and each person in

10.

terminated or nLdifi	27°pTcS*£SoT' ^tiT* ^ ** ^

this Paragraph 10. The then-current owner of the Pronertvf' 1'° accordanee w">th
written notice of the oendencv nf r,™ ! ™perty shail provide EPA and PADEP with

sa*»s^^~."!srs;siar"

ngh, „ t^c:r «:„c0?;,§ Tomm- ?™",or ^ «*« <¦*

zszzz&sssr-"c™-ffl«s:2Sr

then-current owner of the Property and (iii) EPA,

27 Pa cs Eafcnemtnl of Environmental rnvra.„. In accordance with

E.v™M1^SS^„,^mmU,,,Ca,i0nS »•" "» EPA PADEP re^ing a*

EPA:

Hazardous Site Cleanup Division
Office of Siiperfund Site Remediation

Westem Pennsyi^3 and Maryland Remedial Branch
U.S. EPA, Region HI
1650 Arch Street
Philadelphia., PA 19103

PADEP:

gmronmental Cleanup Program Manager, Northeast Region
2 pSS^^' °f 1Pxo.ec.ton
Wilkes-Barre, Pennsylvania 18711-0790

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ACKNOWLEDGMENTS:

OWNER/GRANTOR, and GRANTEE:

Twins MawjfflBfaeiit, LLC

Date

—,2oj£f By

Name:

Title:' M	fk(7%f *?



COMMONWEALTH OF PENNSYLVANIA

COUNTY OF	}

//

)

)

) SS:

AlS ^	20i£ before me, personally appeared ^ ?

subscribed to this"^Lut,'"IT* ^ "
purposes therein contained.	acknowledged that he executed same for the

In witness whereof, I hereunto set my hand and official seal.

CjJUi

¦HsuifyJ

COMMONWIiALTfluFPEKNSYLYANIA	,	"J „

NOTARIAL SEAL	"V""" ,,, " -

Lynn J Harrison, Notary Public	' v'	! A

Stroudsborg Boro. Monroe Coauty

My commission expires May 19,2019	- ; •

r:;v

» * *' V

D-23


-------
APPROVED, by United States Environmental Protection
Agency, Region III

Date: jo/g.a, , 20J>'

By-

Name: Cecil Rodrigues M

Title: Director, Hazardous Site Cleanup Division

COMMONWEALTH OF PENNSYLVANIA )

COUNTY OF	Qhlkdlljlhi^ .	) SS:

On this day of D c|oj3-tfV , 20Jj$ before me, personally appeared Cecil
Rodrigues. Director, Hazardous Site Cleanup Division of the United States Environmental
Protection Agency, Region III, who acknowledged himself to be the person whose name is
subscribed to this Environmental Covenant, and acknowledged that he executed same for the
purposes therein contained.

In witness whereof, I hereunto set my hand and official seal.

f) k', tncLi}

Notary Public

>wmWw BamOmmbm if. mt

o'fc-i
	w



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D-24


-------
COUNTY OF MONROE

RECORDER OF DEEDS
610 MONROE STREET
SUITE 125
STROUDSBURG, PA 18360

Area Code (570) 517-3969

Helen Diectdue - Recorder

Book - 2462 Starting Page - 4216
4 Ic.l af Panes - 8

liislnimuut Number - 211152636™
ktvordwl On ! i/3/2015 \1 4:23:28 I'M
: Instrumeiil 1% pe CON K.YW I S
Invoice Number - 696826
• Grantor - TWINS MANAGKMK.YJ I.I.C

•Cnnlcr - IM tMl) ST A 1 KS KNYIRONMK.NTAL PROTECTION AGENCY REGION HI
I M-r in II

: Custinner l!kl I I KI1 (ii 1
: FEES

STATE WRIT TAX	$0.50

RECORDING PEES	$19.00

COUNTY ARCHIVES FEE	$2.00

ROD ARCHIVES FEE	$3.00
TAX CODE CERTIFICATION $10.00
FEES

TOTAL PAID	$34.SO

KI'Tl'KN	M I ():

likl' f I KIl'GI.I-

\!C CIS Registry ITICtr)ifk;«ion
On Novimhr'r 3, 2n) 5 By DS
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I lit* vmfk\*tion process .mil m:n not Ik- rcl"kchd on this p.tge.

0504A0

I

D-25


-------
APPENDIX E - TCE CONCENTRATION GRAPHS6

BUTZ LANDFILL
TCE CONCENTRATION TRENDS IN EXTRACTION WELLS
MAY 2001 TO NOVEMBER 2020

7000

6000

5000

u>

3

z 4000
O

LU
U
Z
O
o

3000

2000

1000

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u(OwU'liJiUlOI(j)(i)M^(DOJ(D!OoO-»

DATE

—¦—EW-1 —•—EW-2 —A—EW-3

6 Source: Nineteenth-Year Groundwater Monitoring and System Operations Report

E-l


-------
BUTZ LANDFILL
PWA TCE CONCENTRATION TREND DATA
FEBRUARY 2001 TO NOVEMBER 2020

3500

3000

2500

|?2000

:z:
o

|E 1500

z

iu

o

z

o

O 1000

500

OJ
Z3

M to W w

O |=r O m

fD	^	rc	cu

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o> oi ®	a> y

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¦^i a>	cd	to	0>0>0>0>0>0?^CQ^SP
O-ao"CiO"OOX3O-OO"On)0)fD£u^



ro m ro
o o

DATE

- PWA-A

¦ PWA-B

- PWA-C

¦ PWA-D

PWA-E

E-2


-------
BUTZ LANDFILL
PWB TCE CONCENTRATION TREND DATA
FEBRUARY 2001 TO NOVEMBER 2020

DATE

—PWB-A —PWB-B —PWB-C


-------
ro

6000

5000

4000

3000

in

o
z
o

o 2000

1000


-------
HI

o
z
o
o

100

BUTZ LANDFILL
R1_1A TCE CONCENTRATION TREND DATA
FEBRUARY 2001 TO NOVEMBER 2020

250

DATE

—R1-1A-A —R1-1A-B —A—R1-1A-C

E-5


-------
BUTZ LANDFILL
R1D TCE CONCENTRATION TREND DATA
FEBRUARY 2001 TO NOVEMBER 2020

DATE

—R1D-A —R1D-B —R1D-C


-------
BUTZ LANDFILL
R2 TCE CONCENTRATION TREND DATA
FEBRUARY 2001 TO NOVEMBER 2020

DATE

—R2-A —R2-B —R2-C

E-7


-------
BUTZ LANDFILL
R3D TCE CONCENTRATION TREND DATA
FEBRUARY 2001 TO NOVEMBER 2020


-------
50

45

40

35

o>

3, 30

25

z

o 20
z
O
o

15

10


-------
BUTZ LANDFILL
R6, R8 TCE CONCENTRATION TREND DATA
FEBRUARY 2001 TO NOVEMBER 2020

a

D

a

D

O

a

Z

Z

Z

Z

Z

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0

0

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DATE

—R6-A —R6-B —R8-A -K-R8-B

E-10


-------
BUTZ LANDFILL
R7 TCE CONCENTRATION TREND DATA
FEBRUARY 2001 TO APRIL 2015

DATE

—R7-A —R7-B —A—R7-C -*-R7-D -*-R7-E

E-ll


-------
BUTZ LANDFILL
RW39, RW43 TCE CONCENTRATION TREND DATA
FEBRUARY 2001 TO NOVEMBER 2020

































































































































'



I























































































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DATE

-RW39-A

¦ RW39-B

-RW3Q-C

RW3S-D

- RW3S-E

-RW43-A

E-12


-------
3500

3000

2500

ro

z 2000

0

i-

1

S 1500

u
z
o
o

1000

500


-------
BUTZ LANDFILL
MW-60D, MW-6011, MW-60I2 TCE CONCENTRATION TREND DATA
APRIL 2011 TO NOVEMBER 2020

DATE

MW-60D MW-6011	MW-6012

E-14


-------
APPENDIX F - SCREENING-LEVEL VAPOR INTRUSION EVALUATION

There are VOCs in shallow groundwater at and near the Site. Figure F-l shows the most recent TCE groundwater
concentrations in the shallowest sampling intervals. Residences, a church, and a childcare facility are located near
the groundwater contaminant plume. Therefore, vapor intrusion is a potential exposure pathway.

This FYRused EPA's Vapor Intrusion Screening Level (VISL) calculator to conduct a screening-level evaluation
of the potential health risk from vapor intrusion for buildings near high levels of VOCs in shallow groundwater.
At most of the monitoring wells at the Site, samples are collected from multiple depths within the monitoring
wells; the relative depth of each sample is denoted by a suffix after the well number (e.g., the deepest interval in
well R6 is denoted as R6-A and shallowest as R6-B). EPA guidance states that when groundwater contaminant
concentrations are used to assess potential for vapor intrusion, the shallowest groundwater samples should be used
(to the extent practical, groundwater samples should be collected over a narrow interval [e.g., a few feet or less]
just below the water table).7 EPA guidance recommends using 100 feet to define an initial lateral inclusion zone
for vapor intrusion evaluations, with consideration also given to groundwater flow direction.

Monitoring well R7 (southwest of the landfill property) is approximately 114 feet away from a house that was not
previously evaluated for vapor intrusion. Three houses located 300 to 700 feet east of R7 were previously
evaluated for vapor intrusion (Units 103, 102 and 104 shown on Figure F-l). The most recent (2015) TCE
concentration measured in the shallowest interval (R7-E, 35-47 feet below ground surface) was 35.2 pg/L,
whereas concentrations previously reported were 10 pg/L or less during 2001 through 2010).8 This monitoring
well was scheduled to be sampled in 2020 but access was denied by the resident. Due to the increased TCE level
in the shallowest groundwater interval and the fact that the adjacent residence (west of Unit 103) was not
previously evaluated for vapor intrusion, this FYR conducted a screening-level assessment using the VISL
calculator (Table F-l). The screening-level assessment found that the groundwater TCE concentration in the
shallowest groundwater depth sampled in monitoring well R7 could potentially cause an unacceptable non-cancer
hazard from vapor intrusion in the nearby house.

Table F-l: Screening-Level Vapor Intrusion Evaluation at Monitoring Well R7

Contaminant

R7-E
April 2015
Concentration (ju.g/L)"

VISL Calculator*1

Residential Exposure

Cancer Risk

Noncancer HQ

TCE

35.2

2 x 10"5

4

cis-l,2-DCE

1.3

--

--

Notes:

a)	Concentrations obtained from Fourteenth-Year Sampling Events Groundwater Monitoring Report.

b)	EPA's VISL calculator available at: https://www.epa.gov/vaporintrusion/vapor-intrusion-screening-level-calculator
(accessed April 12, 2021). Used groundwater temperature of 11°C based on EPA map of average shallow groundwater
temperatures. VISL's default values were used for all other parameters.

|ig/L = micrograms per liter

U = The analyte was analyzed for but was not detected above the reported detection limit. Because this compound is a
degradation product of TCE, the detection limit was used in the vapor intrusion assessment for a conservative estimate of
risk.

-- = Toxicity data unavailable

Bold and yellow-highlighted result indicates risk is above 104 or HQ is above 1	

7	OSWER Technical Guide for Assessing and Mitigating the Vapor Intrusion Pathway from Subsurface Vapor Sources to
Indoor Air, OSWER Publication 9200.2-154, EPA Office of Solid Waste and Emergency Response, June 2015.

8	The Site's annual reports present a TCE value of 19.4 |ig/L for R7-E, which appears to have been calculated by averaging
the April 2015 results from R7-E and the duplicate sample labeled R7-E. However, as noted in Appendix B of the
Fourteenth-Year Sampling Events Groundwater Monitoring Report, the duplicate sample labeled R7-E is a duplicate of R7-B
(whose detected values it more closely approximates).

F-l


-------
Figure F-l: TCE Concentrations in Shallow Groundwater

Well

Depth (ft bgs)

Year

MW-60-I2

60-70

2020

PWA-E

17-28

2015

PWB-C

30-100

2020

PWC-C

15-90

2019

R1-1A-C

85-105

2020

R1D-C

95-135

2020

R2-C

15-90

2020

R3D-C

100-140

2015

R4-B

15-70

2020

R5-B

15-70

2010

R6-B

15-65

2020

R7-E

35-47

2015

R8-C

35-92

2004

R9-C

35-87

2020

RW10-C

29-65

2015

RW12-D

60-80

2010

RW18-B

15-85

2010

RW23

53-98

2020

RW39-E

55-75

2015

RW43

20-58

2015

RW52-B

50-77

2005

T1-A

7-17

2020

T1-B

10-20

2015

T1-1A

8-13

2020

T1-1B

7-12

2020

T2

9-19

2020

T3

18-28

2020

T4

10-20

2015

T5

8.5-17

2015

59,2 015U^n^R°ad

, PWC-C

R5-B^
5U

R7-E
35.

Jn it 103

¦¦jiM

R9-C jt.
o.su^^o
,a
-------
Figures F-l and C-9 show that there is a church in an area with elevated levels of TCE in the groundwater. This
church has not been previously evaluated for vapor intrusion. The closest monitoring well to the church is PWA,
which is about 400 feet away in a side-gradient direction. The distance between PWA and the church is much
greater than the 100-foot distance recommended by EPA guidance; groundwater concentrations closer to the
church may be higher or lower than the concentration at PWA. From 2001 through 2015, the highest TCE
concentration detected in the shallowest screened interval (PWA-E, 17-28 feet below ground surface) was 11
pg/L in 2001, with all other results below 3 pg/L, suggesting that there was no unacceptable risk near PWA
during 2002 to 2015. Sampling of the PWA-E interval was discontinued in light of consistently low (< 5 pg/L)
TCE concentrations. Using more recent (2020) groundwater sampling results from the second-shallowest
screened interval (PWA-D, 32-45 feet below ground surface), the VISL calculator estimates a risk of 4 * 10"6 and
a non-cancer hazard of 2 for a commercial exposure scenario (Table F-2). However, as stated previously, well
PWA is about 400 feet away from the church in a side-gradient direction, so groundwater concentrations (and
corresponding vapor intrusion risk) at the church may be higher or lower than they are at PWA. Furthermore,
interval PWA-E would be more appropriate and that is expected to have a significantly lower concentration.

Table F-2: Screening-Level Vapor Intrusion Evaluation at Monitoring Well PWA

Contaminant

PWA-D

November 2020
Concentration (jig/L)a

VISL Calculator*1

Commercial Exposure

Cancer Risk

Noncancer HQ

TCE

63.5

4 x 10"6

2

cis-l,2-DCE

173

--

--

Notes:

a)	Concentrations obtained from Nineteenth-Year Groundwater Monitoring and System Operations Report.

b)	EPA's VISL calculator available at: https://www.epa.gov/vaporintrusion/vapor-intrusion-screening-level-calculator
(accessed April 12, 2021). Used groundwater temperature of 11°C based on EPA map of average shallow groundwater
temperatures. VISL's default values were used for all other parameters.

|ig/L = micrograms per liter

U = The analyte was analyzed for but was not detected above the reported detection limit. Because this compound is a
degradation product of TCE, the detection limit was used in the vapor intrusion assessment for a conservative estimate of
risk.

-- = Toxicity data unavailable

Bold and yellow-highlighted result indicates risk is above 10"4 or HQ is above 1	

Figures F-l and C-9 show that there are a childcare facility and several homes in an area that may have high
levels of TCE in shallow groundwater. These buildings have not been previously evaluated for vapor intrusion.
The closest monitoring well to these buildings is R6, which is within 400 to 800 feet of these buildings. Using
2020 groundwater sampling results from the shallowest screened interval (R6-B, 15-65 feet below ground
surface), the VISL calculator estimates a borderline non-cancer hazard near monitoring well R6 for a residential
exposure scenario (Table F-3). The distance between R6 and the childcare and residences is much greater than the
100-foot distance recommended by EPA guidance; the childcare and residences are several hundred feet
downgradient of R6, so groundwater concentrations (and corresponding vapor intrusion risk) closer to the
buildings would be expected to be lower than at R6.

F-3


-------
Table F-3: Screening-Level Vapor Intrusion Evaluation at Monitoring Well R6

Contaminant

R6-B

November 2020
Concentration (ju.g/L)"

VISL Calculator*1

Residential Exposure

Cancer Risk

Noncancer HQ

TCE

11.6

5 x 10"6

1

cis-U-DCE

4.5

--

--

Notes:

a)	Concentrations obtained from Nineteenth-Year Groundwater Monitoring and System Operations Report.

b)	EPA's VISL calculator available at: https://www.epa.gov/vaporintrusion/vapor-intrusion-screening-level-calculator
(accessed April 12, 2021). Used groundwater temperature of 11°C based on EPA map of average shallow groundwater
temperatures. VISL's default values were used for all other parameters.

|ig/L = micrograms per liter

U = The analyte was analyzed for but was not detected above the reported detection limit. Because this compound is a

degradation product of TCE, the detection limit was used in the vapor intrusion assessment for a conservative estimate of

risk.

-- = Toxicity data unavailable

Bold and yellow-highlighted result indicates risk is above 104 or HQ is above 1	

The VISL calculator's results are intended to be conservative (i.e., to overestimate risk) in order to be used as a
screening tool to help determine if additional vapor intrusion evaluation is recommended. The calculator tends to
be conservative because it does not take into account the depth to contaminated groundwater, site-specific soil
properties or building-specific properties, all of which generally can result in significantly lower indoor air
concentrations than are predicted by the VISL calculator. However, the bedrock fractures in the area may provide
preferential pathways for vapors to travel without being attenuated; this may make the VISL results less
conservative than at other sites without fractures. There is a high degree of uncertainty for the risk and hazard
estimates generated by this FYR's screening-level review because (except for R7) the monitoring wells are far
from the buildings and some of the samples represent deeper groundwater (and greater depth ranges) than would
be ideal for vapor intrusion evaluations. Since TCE and other contaminants at the Site are heavier than water and
tend to have higher concentrations at greater depths, the use of deeper samples would tend to make the VISL
results more conservative. This FYR recommends that EPA further evaluate the vapor intrusion pathway for
structures that have not been previously evaluated and are near high levels of VOCs in shallow groundwater. In
particular, a data gap exists in that shallow groundwater quality data is not currently available within 100 feet of
the structures described in the above evaluations.

F-4


-------
APPENDIX G - SITE INSPECTION PHOTOS

Grownaws*® is^seUation

BUTZ LANDFILL
SUPERFUND SITE

Monroe Cov'f}fy, Pet>r>$ylvan!a

Site sign

Groundwater treatment plant building

G-l


-------
Fence around groundwater treatment plant building

G-2


-------
Groundwater treatment plant control screen

Extraction well EW-5

G-3


-------
Standing water in vault of extraction well EW-5

G-4


-------
Extraction well EW-1

G-5


-------
Treated water discharge point

Heavy equipment storage on site property

G-6


-------
Storage oil site property

Fill added to site property

G-7


-------
PJJWA water station

Sign at PJJWA water station

G-8


-------
G-9


-------
APPENDIX H - ARAR REVIEW

CERCLA Section 121(d)(1) requires that Superfund remedial actions attain "a degree of cleanup of hazardous
substance, pollutants, and contaminants released into the environment and of control of further release at a
minimum which assures protection of human health and the environment." The remedial action must achieve a
level of cleanup that at least attains those requirements that are legally applicable or relevant and appropriate
requirements (ARARs).

Groundwater A RA Rs

The 1992 Record of Decision, as modified by the 1999 and 2011 ESDs, states that the Site's groundwater
performance standards are based both on ARARs and on risk-based performance standards. The ARAR-based
standards are federal Safe Drinking Water Act maximum contaminant levels (MCLs) and Pennsylvania's
Statewide Health Standards established pursuant to the Land Recycling and Environmental Remediation
Standards Act. Table H-l compares the ARAR-based performance standards from the 2011 ESD against current
MCLs and state standards. The ARARs for 11 of the 13 groundwater COCs have not changed since the 2011
ESD. The current ARARs for methylene chloride and chlorobenzene are less stringent than the ARAR-based
performance standards listed in the 2011 ESD.

Table H-l: Groundwater ARAR Review



2011 ISI)

( urmil ARAR

(fiii/l.)1'



(¦<><¦

Alt Alt

(.uji/l.)'1

ARAR ( liiin»e

TCE

5

5

No change

Vinyl chloride

2

2

No change

cis-l,2-DCE

70

70

No change

1,1-DCE

7

7

No change

trans-l,2-DCE

100

100

No change

Benzene

5

5

No change

Ethylbenzene

700

700

No change

Tetrachloroethene

5

5

No change

Toluene

1,000

1,000

No change

Carbon tetrachloride

5

5

No change

Chloroform

80°

80

No change

Methylene chloride

3d

5e

Less stringent

Chlorobenzene

55d

100e

Less stringent

Notes:







a) All ARARs are based on MCLs, except for methylene chloride and chlorobenzene.

b)	Current federal MCLs are available at httos://www.era.eov/eround-water-and-drinkine-
water/national-orimarv-drinkine-water-reeulations (accessed 1/27/2021).

c)	The ARAR for chloroform is the MCL for total trihalomethanes.

d) The ARARs for methylene chloride and chlorobenzene are Pennsylvania's Statewide Health
Standards established pursuant to the Land Recycling and Environmental Remediation

Standards Act.







e) Current Pennsylvania Statewide Health Standards are available at

htto://www.deara.eov/Business/Land/LandRecvcline/Standards-Guidance-

Procedures/Paees/Statewide-Health-Standards.aspx (accessed 1/27/2021). Table presents the

standard for used residential aquifers with total dissolved solids less than or equal to 2,500.

Surface Water ARARs

The 1992 Record of Decision states that the surface water discharge will comply with Clean Water Act National
Pollutant Discharge Elimination System (NPDES) discharge regulations, Pennsylvania NPDES regulations,
Pennsylvania Water Quality Standards and Pennsylvania Wastewater Treatment Regulations. Table H-2 presents
the current Pennsylvania Water Quality Standards, drinking water MCLs and EPA Region 3 freshwater ecological

H-l


-------
screening benchmarks. The Data Review section of this FYR compares effluent sampling data against these three
sets of values.

Table H-2: Surface Water ARAR Review



2021 lodoiiil

2021 r.PA Region 3
I- ivslmiilor
Screen inji
licnchm;irkh (iiii/l.)

2021 IVmis>l\iiiiiii \\ ;Mcr Qu;ili(\ S(;iikI;m (Is1
(iili/l.)



\1( 1.'

( rili'riii

( riliThi

lluiiiiiii
llCilllll



(fiii/l.)

Con t i iiikiii s

M;i\imii in





( oiiconli'iilioii

( oiiconlriilion

TCE

5

21

450

2,300

0.6

1,1-DCE

7

25

1,500

7,500

33

cis-l,2-DCE

70

590d

NA

NA

12

trans-l,2-DCE

100

970

1,400

6,800

100

Vinyl chloride

2

930

NA

NA

0.02

Notes:

a) Not a surface water ARAR but provided for convenient comparison. Accessed 3/16/2021 at

httos://www.era.eov/eround-water-and-drinkine-water/national-t>rimarv-drinkine-water-reeulations.

b) Accessed 3/16/2021 at httt>s://www.era.eov/risk/freshwater-screenine-benchmarks.



c) Accessed 3/31/2021 at

htto://www.racodeandbulletin.eov/Dist>lav/racode?file=/secure/racode/data/025/chat>ter93/s93.8c.html&

d=reduce.

d) Screening value for 1,2-DCE (CAS 540-59-0).

H-2


-------