Long-Term Stewardship Assessment Report

Chester County Solid Waste Authority Lanchester Landfill

EPA ID #: PAD980550545

Narvon, Pennsylvania 19344

Assessment Date: May 18. 2022

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

Site Background: The Chester County Solid Waste Authority Lanchester Landfill (CCSWA) is
located at 7224 Division Highway in Narvon, Pennsylvania, Caernarvon Township, Lancaster County,
Pennsylvania (Facility). The Facility property consists of approximately 630 acres, including 160 acres
of landfills and is located at the border of Lancaster County and Chester County. The Facility is
bordered by wooded and agricultural property, along with limited commercial and residential property.

The following three landfills, comprising approximately 160 acres collectively, are located at the
Facility: the Mountain Top landfill, Stabilized Waste landfill and Municipal landfill. As a result of past
operations at the Facility, groundwater at the Facility became contaminated with volatile organic
compounds (VOCs) and metals at concentrations exceeding applicable maximum contaminant levels
(MCLs) codified at 40 C.F.R. Part 141 and promulgated pursuant to the Safe Drinking Water Act, 42
U.S. C. §§300f et seq.

The Municipal landfill currently operates under Pennsylvania Department of Environmental Protection
(PADEP) Municipal Solid Waste Operating Permit No. 100944 and accepts municipal solid waste.
Closure of the sub-areas that are filled to capacity occurred in four phases from 1992 through 2008.
The closure activities include interim covers for areas that are or will be overfilled, final covers
(synthetic liner and soil) for completed areas, drainage layers and gas management systems.

Current Site Status: On December 22, 2010, EPA issued the Final Decision and Response to
Comments (FDRTC). The final remedy determination is Corrective Action Complete with Controls.
Controls include operation and maintenance and monitoring actions for the landfill caps and
groundwater monitoring system; and compliance with and maintenance of institutional controls.

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The final remedy detailed in the FDRTC is implemented through a Hazardous Waste Facility
Post-Closure Permit between EPA and CCSWA dated December 22, 2010 (EPA Permit). The EPA
Permit incorporates all provisions of the Facility's RCRA Post-Closure Permit No. PAD980550545
and the Municipal Solid Waste Operating Permit No. 100944, both issued by PADEP (DEP Permits).
A portion of the facility remains under continued use as a municipal landfill.

Long-term Stewardship Site Visit: On May 18, 2022, EPA conducted a long-term stewardship site
visit with Chester County Solid Waste Authority to discuss and assess the status of the implemented
remedies at the site.

The attendees were:

Name

Organization

Role

Email Address

Todd

Richardson

EPA Region 3

Long Term Stewardship
Coordinator

richardson.todd (3>epa.gov

John Hopkins

EPA Region 3

Long-Term Stewardship
Coordinator

hopkins.iohn(3>epa.gov

Teresa Devine

Chester County Solid Waste
Authority

Compliance Officer

tdevine(3>chestercswa.org

Robert Watts

Chester County Solid Waste
Authority

Executive Director

bwatts (3>chestercswa.org

Institutional Controls (ICs) Status:

EPA Permit. The EPA Permit is the method for implementing institutional and engineering controls
required as a condition of the Statement of Basis and Final Decision. The following ICs apply to the
CCSWA Lanchester Landfill facility, shown on Figure 1:

Land Use Restriction: The Facility shall not be used for residential purposes unless it is demonstrated
to EPA that such use will not pose a threat to human health or the environment and EPA provides prior
written approval for such use. There were no residential structures observed at the time of the visit.

Groundwater Use Restriction: The groundwater from the Facility shall not be used for any purpose
other than to conduct the operation and maintenance and monitoring activities required by
Pennsylvania Department of Environmental Protection (PADEP) and to implement EPA's selected
remedy, unless it is demonstrated to EPA that such use will not pose a threat to human health or the
environment or adversely affect or interfere with the selected remedy and EPA provides written
approval for such use. CCSWA is currently in compliance with the above use restriction.

Engineering Controls (ECs) Status:

Mountain Top and Stabilized Waste Landfill Caps: CCSWA has maintained the integrity and
effectiveness of the landfill caps by mowing approximately twice per year. In addition to mowing,
sheep (shown in Picture 8) are used to assist in the maintenance of the approximate 9-acre Stabilized

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Waste Landfill (IU Site) cap. In 1989, CCSWA completed construction of a composite cap, consisting
of a synthetic liner and soil over the IU Site. In 1991, CCSWA completed construction of a cap over
the Mountain Top landfill. An additional composite cap, consisting of a synthetic liner and soil, was
constructed over the flat areas of this landfill and a clay cap was constructed over the steep slope areas.
The construction also included the installation of surface water/runoff channels, a passive gas
management system, and a leachate collection system

The IU Site is currently being maintained and monitored under a RCRA post-closure permit, Permit
No. PAD 980 550 545. While the Mountain Top landfill is not operating under a permit, because of its
proximity to the Municipal landfill, groundwater monitoring, inspection and maintenance obligations
are required by Municipal Solid Waste Operating Permit No. 100944. No plants with deeply
penetrating root systems or signs of significant erosion were observed at either of the capped landfills.
Surface water berms and swales were in good condition with no signs of ponding. A solar panel array
was recently installed on Mountain Top landfill (Picture 9).

Leachate Collection System: The original area of the Municipal landfill was constructed beginning in
1984 with a single asphalt liner. All areas constructed after 1988 have a double liner and leachate
collection system. One leachate sampling is collected quarterly at each of twelve leachate monitoring
points. These points include the leachate storage tank and from primary leachate collection systems in
Manhole #6, Expansion B Cells 1, 2, 3 and 4, Municipal Overflow Units 1 and 2, the Area D
Expansions Cells 1, 2 and 3, ant the Area E Expansion Cell 1. Quarterly samples are also collected at
the three sump locations; The Churchtown Road Pump Station, The Railroad Cut Collection system
and the Mountain Top landfill sump EW-1. Areas with leachate collection also have detection zone
monitoring to identify when leachate contamination may occur. Approximately every 90 days, leachate
collected by the leachate collection system is transferred to a tanker truck and disposed of at a RCRA
permitted disposal facility. At the time this assessment was conducted, facility representatives reported
that an estimated 500 -700 gallons of leachate accumulates during a 90day period. CCSWA continues
to operate the leachate collection as intended.

Groundwater Monitoring: The Facility's RCRA Post-Closure Permit and Municipal Solid Waste
Operating Permit collectively impose operation and maintenance and groundwater monitoring
requirements on the entire Facility. As part of its post-closure care and operating requirements,
embodied in the permits, CCSWA conducts quarterly groundwater monitoring to assess releases from
the three landfills and maintains the integrity and protectiveness of the landfill caps. Results of
quarterly groundwater monitoring are reported annually.

Data is screening with applicable 25 PA Code Chapter 250 groundwater quality standards. The
monitoring network for each landfill consists of the following number of groundwater wells: eleven
(11) at the Former Mountain Top landfill, eight (8) at the IU Site, three (3) at the Lanchester Municipal
landfill, five (5) at the Municipal landfill Overfill unit, six (6) at the Expansion Area B 1, 2, 3, and 4
Cells, four (4) at the Expansion Area D Cells and four (4) at the Expansion Area E Cells.

Results of the latest 2021 Water Quality Monitoring Report suggests that contaminant concentrations
in groundwater are consistent with historical trends. Primary contaminants of concern include mercury,
chromium, arsenic, benzene. As of 2021, constituents with an increasing trend at various monitoring

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wells include calcium, chloride, manganese, nitrogen, potassium, sodium and sulfate. CCSWA will
continue to conduct quarterly groundwater sampling events and recommend changes to the monitoring
plan as necessary.

Financial Assurance: Financial assurance is required in the form of a collateral bond approved by
PADEP. A financial assurance evaluation, which includes a review of site operation, maintenance and
sampling costs, is completed annually by CCSWA.

Reporting Requirements/Compliance: All reporting requirements of the DEP Permits have been
met. CCSWA submits annual Water Quality Monitoring Plan reports the last of which was received in
June 2022. CCSWA also submits annual cap inspect reports the last of which was received May 15,
2022.

Mapping: The EPA facility website map is accurate and includes the 630-acre CCSWA Lanchester
property. A downloadable geospatial PDF map is available on EPA's corrective action facility
webpage under the "Reports, Documents and Photographs" section, found here.

Conclusions and Recommendations: No EC/IC deficiencies were identified. Some minor areas of
erosion were observed on the cover of the Stabilized Waste Landfill. Erosion control measures were
being implemented in various areas as shown in Pictures 2 and 3. Continue to monitor and repair areas
of erosion as needed. EPA has determined that the remedy institutional and engineering controls have
been fully implemented.

Attachments:

Figure 1: Aerial Map of Chester County Solid Waste Authority Lanchester Landfill
Picture 1: From top of Stabilized Waste Landfill facing south

Picture 2: Western area of Stabilized Waste Landfill- erosion control measures in drainage ditch

Picture 3: Top of Stablized Waste Landfill facing north towards Municipal Landfill Areas - area of
minor erosion repair

Picture 4: Top of Mountain Top Landfill facing southwest - passive ventilation system
Picture 5: Top of Mountain Top Landfill northern boundary - passive ventilation system
Picture 6: Monitoring Well IUW-20
Picture 7: Monitoring Well IUW-19

Picture 8: Sheep used in conjunction with mowing to maintain vegetative landfill covers
Picture 9: Solar panels on Mountain Top Landfill

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Figure 1: Aerial Map of Chester County Solid Waste Authority Lanchester Landfill

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Stabilized Disfiesal Site
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CCSW Landfill

Property Boundary
Stablized Disposal Area
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Mourrtaintop Site
Municipal Site

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Feet

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Picture 1: From top of Stabilized Waste Landfill facing south

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Picture 2: Western area of Stabilized Waste Landfill- erosion control measures in drainage ditch

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Picture 3: Top of Stablized Waste Landfill facing north towards Municipal Landfill Areas - area of

minor erosion repair

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Picture 4: Top of Mountain Top Landfill facing southwest - passive ventilation system

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Picture 5: Top of Mountain Top Landfill northern boundary - passive ventilation system


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Picture 6: Monitoring Well IUW-20


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Picture 7: Monitoring Well IUW-19


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Picture 9 - Solar panels on Mountain Top Landfill

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