fourth five year review report

FOURTH FIVE-YEAR REVIEW REPORT FOR WESTINGHOUSE ELEV ATOR COMPANY PLANT SUPERFUND SITE

ADAMS COUNTY, PENNSYLVANIA

June 2016

Prepared By: United States Environmental Protection Agency

Region 3 Philadelphia, Pennsylvania

t Do mique Lueckenhoff, Acting Director Hazardous Site Cleanup Division U.S. EPA, Region 3

JUN 16 2016

Date

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TABLE OF CONTENTS LIST OF ABBREVIATIONS ...................................................................................................... 3

EXECUTIVE SUMMARY .......................................................................................................... 4

FIVE-YEAR REVIEW SUMMARY FORM ............................................................................. 6

1.0 Introduction ............................................................................................................................. 9

2.0 Site Chronology ..................................................................................................................... 10

3.0 Background ........................................................................................................................... 11

3.1 PHYSICAL CHARACTERISTICS ........................................................................................ 11 3.2 LAND AND RESOURCE USE ............................................................................................ 12 3.3 HISTORY OF CONTAMINATION ....................................................................................... 12 3.4 INITIAL RESPONSE ......................................................................................................... 15 3.5 BASIS FOR TAKING ACTION ........................................................................................... 15

4.0 Remedial Actions .................................................................................................................. 16

4.1 REMEDY SELECTION ...................................................................................................... 16 4.2 REMEDY IMPLEMENTATION ........................................................................................... 17 4.3 OPERATION AND MAINTENANCE .................................................................................... 18

5.0 Progress Since the Last Five-Year Review ......................................................................... 19

6.0 Five-Year Review Process .................................................................................................... 21

6.1 ADMINISTRATIVE COMPONENTS .................................................................................... 21 6.2 COMMUNITY INVOLVEMENT .......................................................................................... 22 6.3 DOCUMENT REVIEW ...................................................................................................... 22 6.4 DATA REVIEW ............................................................................................................... 26 6.5 SITE INSPECTION ............................................................................................................ 31 6.6 INTERVIEWS ................................................................................................................... 32

7.0 Technical Assessment ........................................................................................................... 32

7.1 QUESTION A: IS THE REMEDY FUNCTIONING AS INTENDED BY THE DECISION

DOCUMENTS? ............................................................................................................... 32 7.2 QUESTION B: ARE THE EXPOSURE ASSUMPTIONS, TOXICITY DATA, CLEANUP LEVELS AND

REMEDIAL ACTION OBJECTIVES (RAOS) USED AT THE TIME OF REMEDY SELECTION

STILL VALID? ............................................................................................................... 33 7.3 QUESTION C: HAS ANY OTHER INFORMATION COME TO LIGHT THAT COULD CALL INTO

QUESTION THE PROTECTIVENESS OF THE REMEDY? ...................................................... 34 7.4 TECHNICAL ASSESSMENT SUMMARY ............................................................................. 34

8.0 Issues ...................................................................................................................................... 35

9.0 Recommendations and Follow-up Actions ......................................................................... 35

10.0 Protectiveness Statement .................................................................................................... 36

11.0 Next Review ......................................................................................................................... 37

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Appendix A: List of Documents Reviewed ................................................................................ A-1 Appendix B: Press Notice ........................................................................................................... B-1 Appendix C: Data Review Supporting Documentation .............................................................. C-1 Appendix D: Site Inspection Checklist ....................................................................................... D-1 Appendix E: Site Inspection Photographs ................................................................................... E-1 Tables Table 1: Chronology of Site Events .............................................................................................. 10 Table 2: Groundwater Cleanup Goals ........................................................................................... 17 Table 3: Progress on Recommendations from the 2011 FYR ...................................................... 20 Table 4: Plant Property Ownership ............................................................................................... 23 Table 5: Institutional Control (IC) Summary Table ..................................................................... 24 Table 6: Monitoring and Extraction Well Summary .................................................................... 26 Table 7: Groundwater VOC Summary ......................................................................................... 27 Table 8: PMW-16B TCE Concentrations ..................................................................................... 28 Table 9: 1,4-Dioxane in Residential Wells ................................................................................... 30 Table 10: Current Site Issues ........................................................................................................ 35 Table 11: Recommendations to Address Current Site Issues ....................................................... 35 Table C-1: Summary of Mann-Kendall Trend Analysis ........................................................... C-10 Table C-2: 1,4-Dioxane in Select Wells ................................................................................... C-11 Table C-3: Vapor Intrusion Data .............................................................................................. C-12 Table C-4: Groundwater Analytical Results for SVMW-1 and SVMW-2 ............................... C-16 Figures Figure 1: Site Location Map ......................................................................................................... 13 Figure 2: Detailed Site Map .......................................................................................................... 14 Figure 3: Institutional Control Base Map ..................................................................................... 25 Figure C-1: Potentiometric Surface – Shallow Bedrock Zone ................................................... C-1 Figure C-2: Potentiometric Surface – Deep Bedrock Zone ........................................................ C-2 Figure C-3: Total VOC Concentrations – Shallow Bedrock, 1996 and 2015 ............................ C-3 Figure C-4: Total VOC Concentrations - Deep Bedrock, 1996 and 2015 .................................. C-4 Figure C-5: Time-Concentration Graphs for Select Wells ......................................................... C-5 Figure C-6: Capture Zone Shallow Bedrock .............................................................................. C-7 Figure C-7: Capture Zone Deep Bedrock ................................................................................... C-8 Figure C-8: Sub-slab Vapor and Indoor Air Sampling Locations .............................................. C-9

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LIST OF ABBREVIATIONS ARAR Applicable or Relevant and Appropriate Requirement CERCLA Comprehensive Environmental Response, Compensation and Liability Act CFR Code of Federal Regulations CIC Community Involvement Coordinator COC Chemical of Concern DCA Dichloroethane DCE Dichloroethene DNAPL Dense Nonaqueous Phase Liquid EPA United States Environmental Protection Agency ESD Explanation of Significant Differences FYR Five-Year Review IC Institutional Control GMUC Groundwater Migration Under Control GPRA Government Performance and Results Act HHRA Human Health Risk Assessment HVAC Heating, Ventilation and Air Conditioning MCL Maximum Contaminant Level MCLG Maximum Contaminant Level Goal MSC Medium-Specific Concentration msl Mean Sea Level 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 PCE Tetrachloroethene PRP Potentially Responsible Party RAO Remedial Action Objective RI/FS Remedial Investigation/Feasibility Study ROD Record of Decision RPM Remedial Project Manager RSL Regional Screening Level SIM Selective Ion Method SWRAU Sitewide Ready for Anticipated Use TBC To-be-considered TCA 1,1,1-Trichloroethane TCE Trichloroethene TDS Total Dissolved Solids UAO Unilateral Administrative Order µg/L Microgram per Liter µg/m3 Microgram per Cubic Meter VI Vapor Intrusion VISL Vapor Intrusion Screening Level VOC Volatile Organic Compound

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EXECUTIVE SUMMARY The Westinghouse Elevator Company Plant Superfund Site (the Site) is located in Cumberland Township, Adams County, Pennsylvania. The Site consists of a former elevator manufacturing Plant (the Plant property) and the groundwater contaminant plume extending to the east of the Plant property. Releases during manufacturing operations and waste material storage practices resulted in impacts to groundwater, surface water, sediment, and soil by volatile organic compounds (VOCs), primarily trichloroethene (TCE) and 1,1,1-trichloroethane (TCA). The United States Environmental Protection Agency (EPA) selected a groundwater, surface water and sediment remedy (OU1) in a June 1992 Record of Decision (1992 ROD) and modified the remedy in two Explanations of Significant Differences (ESDs), issued in August 1998 and February 2012. The groundwater remedy, as modified, consists of groundwater extraction and treatment; discharge of treated groundwater to the northern tributary of Rock Creek; institutional controls; and groundwater and residential well monitoring. No unacceptable human health or ecological risk was identified for surface water and sediment; therefore, no remedy was selected for those media. Contaminated soil was addressed in a removal action prior to the soil Remedial Investigation (RI) and no unacceptable human health or ecological risk was identified for soil. EPA issued a “No Action” ROD for soil (OU2) in March 1995 (1995 ROD). Construction of the remedy was performed from May 1997 through September 1998 and the Site achieved Construction Completion on September 22, 1998. The triggering action for this Five-Year Review (FYR) was the signing of the previous FYR on June 21, 2011. The remedy for the Site is protective of human health and the environment in the short-term due to the installation and continued operation of the on-Plant groundwater extraction and treatment system. Long-term groundwater and residential well monitoring are performed regularly to evaluate the effectiveness of the remedy. Institutional controls are in place requiring the operation and maintenance of a VI mitigation system at the former Plant building, if such a system is installed, and requiring a VI evaluation and/or mitigation at future buildings on the Plant property. Institutional controls are also in place to restrict land and groundwater use on-Plant, to limit groundwater use off-Plant, and to protect the components of the remedy. However, for the remedy to be protective of human health and the environment in the long-term, additional evaluation is necessary to address 1,4-dioxane contamination at the Site and to determine how to meet cleanup goals throughout the groundwater contaminant plume. Additionally, an ESD is necessary to document the institutional controls related to VI.

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Government Performance and Results Act (GPRA) Measure Review As part of this FYR, the GPRA Measures have also been reviewed. The GPRA Measures and their status are provided as follows: Environmental Indicators Human Health: Current Human Exposure Controlled and Protective Remedy in Place (HEPR) Groundwater Migration: Groundwater Migration Under Control (GMUC) Sitewide Ready for Anticipated Use (SWRAU) The Site achieved the SWRAU Measure on June 15, 2006.

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FIVE-YEAR REVIEW SUMMARY FORM

SITE IDENTIFICATION

Site Name: Westinghouse Elevator Company Plant

EPA ID: PAD043882281

Region: 3 State: PA City/County: Cumberland Township/Adams County

SITE STATUS

NPL Status: Final

Multiple OUs?

Yes

Has the site achieved construction completion?

Yes

REVIEW STATUS

Lead Agency: EPA If “Other Federal Agency” selected above, enter Agency name: N/A

Author name: Bhupi Khona and John Epps, with additional support provided by Skeo Solutions

Author affiliation: EPA Region 3

Review period: August 2015 – June 2016

Date of site inspection: October 29, 2015

Type of review: Statutory

Review number: 4

Triggering action date: June 21, 2011

Due date (five years after triggering action date): June 21, 2016

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Issues and Recommendations Identified in the Five-Year Review:

OU(s): OU1 Issue Category: Changed Site Conditions

Issue: 1,4-Dioxane has been detected in groundwater at concentrations exceeding the EPA tap water Regional Screening Level (RSL) and Pennsylvania Department of Environmental Protection (PADEP) Medium Specific Concentration (MSC).

Recommendation: Perform additional sampling to evaluate the extent of 1,4-dioxane contamination, to determine if 1,4-dioxane is a contaminant of concern (COC) at the Site, and to determine if modifications to the groundwater extraction and treatment system are necessary to treat for 1,4-dioxane.

Affect Current Protectiveness

Affect Future Protectiveness

Implementing Party

Oversight Party

Milestone Date

No Yes PRP EPA 09/30/17


OU(s): OU1 Issue Category: Changed Site Conditions

Issue: The vapor intrusion (VI) evaluation identified potential unacceptable human health risk due to VI at the former Plant building and at future buildings on the Plant property. VI was not addressed by previous decision documents.

Recommendation: Issue an ESD for institutional controls requiring the operation and maintenance of a VI mitigation system at the former Plant building, if such a system is installed, and requiring an evaluation and/or mitigation of VI at any future buildings on the Plant property.



Implementing Party

Oversight Party

Milestone Date

No Yes EPA EPA 09/30/16

Issues/Recommendations

OU(s) without Issues/Recommendations Identified in the Five-Year Review:

OU2

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OU(s): OU1 Issue Category: Remedy Performance

Issue: The off-Plant groundwater extraction and treatment system was shut down in 2005; however, contaminant concentrations in the off-Plant groundwater contaminant plume exceed groundwater cleanup goals.

Recommendation: Evaluate optimization of the existing groundwater extraction and treatment systems and/or alternative remedial technologies to meet cleanup goals throughout the groundwater contaminant plume.



Implementing Party

Oversight Party

Milestone Date

No Yes PRP EPA 09/30/17

Sitewide Protectiveness Statement(s)

Operable Unit: Sitewide

Protectiveness Determination: Short-term Protective

Addendum Due Date (if applicable): N/A

Protectiveness Statement: The remedy for the Site is protective of human health and the environment in the short-term due to the installation and continued operation of the on-Plant groundwater extraction and treatment system. Long-term groundwater and residential well monitoring are performed regularly to evaluate the effectiveness of the remedy. Institutional controls are in place requiring the operation and maintenance of a VI mitigation system at the former Plant building, if such a system is installed, and requiring a VI evaluation and/or mitigation at future buildings on the Plant property. Institutional controls are also in place to restrict land and groundwater use on-Plant, to limit groundwater use off-Plant, and to protect the components of the remedy. However, for the remedy to be protective of human health and the environment in the long-term, additional evaluation is necessary to address 1,4-dioxane contamination at the Site and to determine how to meet cleanup goals throughout the groundwater contaminant plume. Additionally, an ESD is necessary to document the institutional controls related to VI.

Issues/Recommendations (continued)

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Fourth Five-Year Review Report for

Westinghouse Elevator Company Plant Superfund Site 1.0 Introduction The purpose of a five-year review (FYR) is to evaluate the implementation and performance of a remedy in order to determine if the remedy will continue to be protective of human health and the environment. FYR reports document FYR methods, findings and conclusions. In addition, FYR reports identify issues found during the review, if any, and document recommendations to address them. The United States Environmental Protection Agency (EPA) prepares FYRs pursuant to Section 121 of the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) and the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). Section 121 of CERCLA states:

If the President selects a remedial action that results in any hazardous substances, pollutants, or contaminants remaining at the site, the President shall review such remedial action no less often than each 5 years after the initiation of such remedial action to assure that human health and the environment are being protected by the remedial action being implemented. In addition, if upon such review it is the judgment of the President that action is appropriate at such site in accordance with section [104] or [106], the President shall take or require such action. The President shall report to the Congress a list of facilities for which such review is required, the results of all such reviews, and any actions taken as a result of such reviews.

EPA interpreted this requirement further in the NCP, 40 Code of Federal Regulations (CFR) Section 300.430(f)(4)(ii), which states:

If a remedial action is selected that results in hazardous substances, pollutants, or contaminants remaining at the site above levels that allow for unlimited use and unrestricted exposure, the lead agency shall review such action no less often than every five years after initiation of the selected remedial action.

EPA Region 3, with contractor support from Skeo Solutions, conducted the FYR and prepared this Report regarding the remedy implemented at the Westinghouse Elevator Company Plant Superfund Site (the Site) in Cumberland Township, Adams County, Pennsylvania. EPA conducted this FYR from August 2015 to June 2016. EPA is the lead agency for developing and overseeing implementation of the potentially responsible party (PRP)-financed remedy at the Site. The Pennsylvania Department of Environmental Protection (PADEP), as the support agency representing the Commonwealth of Pennsylvania, has reviewed all supporting documentation and provided input to EPA during the FYR process. This is the fourth FYR for the Site. The triggering action for this statutory review is the previous FYR. The FYR is required because hazardous substances, pollutants or contaminants remain at

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the Site above levels that allow for unlimited use and unrestricted exposure. The Site consists of two operable units (OUs). OU1 addresses groundwater, surface water and sediment and OU2 addresses soil. This FYR primarily evaluates the OU1 remedy because no remedy was selected for OU2. 2.0 Site Chronology Table 1 lists the dates of important events for the Site. Table 1: Chronology of Site Events

Event Date The Pennsylvania Department of Environmental Resources (PADER), now PADEP, investigated the Site in response to resident complaints.

August 1, 1983

PADER completed a preliminary assessment. November 1, 1983 EPA issued a Unilateral Administrative Order (UAO) to Westinghouse Elevator Company (Westinghouse) to conduct removal actions at three different locations in the Gettysburg area, including this Site. The UAO required Westinghouse to sample residential wells.

March 22, 1984

Westinghouse completed removal actions, consisting of installation of a public water line along Biglerville Road and a portion of Boyds School Road, and installation of a groundwater extraction and treatment system.

March 1984 to June 1985

EPA proposed the Site for listing on the Superfund National Priorities List (NPL). October 15, 1984 EPA listed the Site on the NPL. June 10, 1986 EPA and Westinghouse entered into an Administrative Order on Consent to conduct the remedial investigation/feasibility study (RI/FS) at the Site;

March 10, 1987

Westinghouse performed the RI/FS for OU1. March 1987 through June 1992

Schindler Elevator Corporation (Schindler) used the Plant and continued elevator manufacturing operations.

1989 through 2013

Solvent release occurred in the Plant courtyard while operated by Schindler. May 1991 Westinghouse performed the FS for OU2. March 1992 through

March 1995 EPA issued the Record of Decision (ROD) for OU1. June 30, 1992 EPA issued a UAO to Westinghouse and Schindler to implement the OU1 remedy; Schindler did not comply.

December 29, 1992

Westinghouse performed the OU1 remedial design. March 16, 1993 to May 30, 1997

EPA issued a “No Action” ROD for OU2. March 31, 1995 EPA issued an Explanation of Significant Differences (ESD) for OU1 requiring an additional off-Plant groundwater extraction and treatment system.

August 3, 1998

The groundwater extraction and treatment systems began full-scale operation. September 3, 1998 EPA issued the Preliminary Close-out Report for the Site documenting Construction Completion.

September 22, 1998

EPA issued the first FYR. June 20, 2001 EPA approved shutdown of the off-Plant groundwater extraction and treatment system because influent groundwater contaminant concentrations had met cleanup goals.

March 31, 2005

EPA issued the second FYR. June 21, 2006 Westinghouse added an aqueous-phase carbon unit to the on-Plant groundwater extraction and treatment system.

October 2007

EPA issued the third FYR. June 21, 2011 EPA issued an ESD that modified the remedy to include additional institutional controls for the off-Plant groundwater contaminant plume.

February 10, 2012

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Event Date Schindler ceased elevator manufacturing operations and vacated the Plant. 2013 Westinghouse completed a vapor intrusion (VI) investigation of on-Plant buildings. June 2015 Westinghouse sold the Plant property to Logistics Resource, LLC. July 9, 2015 Environmental Covenant recorded with the Adams County Recorder of Deeds to restrict use of the Plant property.

July 21, 2015

Environmental Easement and Restrictive Covenant recorded with Adams County Recorder of Deeds to incorporate restrictions from Environmental Covenant and add restrictions related to VI.

July 29, 2015

3.0 Background 3.1 Physical Characteristics The Site is located along the west side of Biglerville Road (Pennsylvania State Route 34), approximately 1.5 miles north of downtown Gettysburg in Cumberland Township, Adams County, Pennsylvania (Figure 1). The Site consists of an 84-acre former elevator manufacturing plant (the Plant property) and the groundwater contaminant plume extending to the east of the Plant property (Figure 2). Primary features of the Site include a former manufacturing building, paved parking areas, groundwater extraction and treatment system building and a monitoring and extraction well network. A second groundwater extraction and treatment system building and monitoring and extraction well network are also located at the Site to the east of the Plant property. The Site is bounded to the south by the Gettysburg National Military Park, and to the west, north and east by residential and small commercial properties. The nearest private residences are located approximately 200 feet east of the Site. The regional topography in the area of the Site is low to medium relief, undulating terrain. Specifically, the Site slopes moderately to the east, dropping in elevation from 600 feet above mean sea level (msl) in the west to 525 feet above msl in the east. The Site is located within the watershed of Rock Creek, a small southward-flowing stream located approximately 0.75 mile to the east of the Plant property. Surface water at the Site is collected by a storm drain system that eventually discharges to two tributaries of Rock Creek, identified as the Northern Tributary and Eastern Tributary and shown on Figure 2. Bedrock underlying the Site is mapped as the Heidlersburg member of the Gettysburg Formation. The Heidlersburg member is described as a series of red and gray sandstones, red mudstones and dark gray sandstones and shales. Groundwater in the vicinity of the Site occurs in both shallow and deep zones. The shallow groundwater zone consists of saturated soils and weathered bedrock. The deep groundwater zone consists of more competent fractured bedrock. Groundwater flow in both the shallow and deep zones is to the east-southeast toward Rock Creek. Appendix C includes April 2015 potentiometric surface maps for both the shallow and deep groundwater zones.

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3.2 Land and Resource Use Between 1968 and 1989, Westinghouse Elevator Company, currently known as CBS/Westinghouse of PA, Inc. (Westinghouse), operated an elevator and escalator manufacturing plant at the Site. Prior to 1968, the Site was utilized primarily as farmland. Schindler Elevator Corporation (Schindler) leased the Site from Westinghouse in 1989 and continued elevator manufacturing operations until 2013. In July 2015, Logistics Resource, LLC, operating as Moran Industries, purchased the Site and is currently renovating the former Plant building for potential commercial/industrial tenants. Westinghouse is the primary Potentially Responsible Party (PRP) for the Site and has performed all response actions to date. Current land use for the surrounding area is residential, commercial and recreational. Although zoning changes have occurred over the years, it is anticipated that land use in the vicinity of the Site will remain unchanged. Public water is available in the vicinity of the Site and most nearby residents are connected to the system. However, some residents continue to rely on private wells for their water supply and have refused a connection to the public water system. Westinghouse samples the residential wells in the vicinity of the Site on an annual basis. 3.3 History of Contamination As previously indicated, the Site was historically utilized by Westinghouse and Schindler as an elevator and escalator manufacturing facility. Historic elevator manufacturing operations utilized chlorinated solvents such as trichloroethene (TCE) and 1,1,1-trichloroethane (TCA) as degreasing agents. Waste materials generated at the Site included spent solvents, paint sludges, spent oils and greases, and excess insulation board. Releases during manufacturing operations and waste material storage resulted in impacts to groundwater, surface water, sediment, and soil at the Site.

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Figure 1: Site Location Map

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.

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Figure 2: Detailed Site Map


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3.4 Initial Response PADER, now PADEP, investigated the Site in 1983 in response to complaints from local residents. PADER sampling identified VOCs in groundwater at the Site, including TCE and TCA. Additional sampling by PADER and Westinghouse identified VOCs in surface water and soil samples from the Site. In November 1983, Westinghouse voluntarily removed 10 drums of contaminated soil from the railroad dock area and 33 drums of contaminated soil from the pump house area. The drums were disposed offsite at a permitted landfill. In 1984, Westinghouse voluntarily provided bottled water and carbon filtration systems to residents whose wells were potentially affected by contaminated groundwater from the Site. Westinghouse also installed water mains to the east of the Site along Biglerville Road and a portion of Boyds School Road to provide access to the public water supply for potentially affected residences. Since 1984, Westinghouse has installed additional mains along stretches of Boyds School Road, Cedar Avenue, Maple Avenue, Apple Avenue and other newly developed streets. In June 1984, Westinghouse voluntarily installed a groundwater extraction and treatment system at the Site. This system was modified and incorporated into the groundwater remedy and is still in operation, as discussed in additional detail in Section 4.2, Remedy Implementation. EPA proposed the Site for listing on the Superfund National Priorities List (NPL) on October 15, 1984, and formally listed the Site on the NPL on June 10, 1986. On March 10, 1987, Westinghouse entered into an Administrative Settlement Agreement and Order on Consent (AOC) with EPA to perform an RI/FS at the Site. The RI focused primarily on groundwater contaminant characterization and was completed in July 1991. As previously indicated, a solvent release occurred in May 1991 while Schindler was operating the Plant. Schindler removed soil impacted by the release, disposed of the soil offsite, and performed confirmation sampling. However, additional sampling was necessary to determine if a remedial action was necessary for soil. Therefore, to avoid further delay in selecting a groundwater remedy, EPA divided the Site into two OUs. OU1 addressed groundwater, surface water, and sediment and OU2 addressed soil. Westinghouse submitted the final FS for OU1 in March 1992 and the final FS for OU2 in December 1993. 3.5 Basis for Taking Action

The RI indicated that releases during manufacturing operations and waste material storage impacted shallow and deep groundwater zones with VOCs, consisting primarily of TCE, TCA, 1,1-dichloroethene (1,1-DCE), 1,2-dichloroethene (1,2-DCE). Although dense non-aqueous phase liquid (DNAPL) was not observed in any wells or borings, the VOC concentrations measured in groundwater were indicative of the presence of DNAPL, which was identified as a principal threat waste at the Site.

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The human health risk assessment (HHRA) identified potential unacceptable carcinogenic risks to nearby residents due to exposure to contaminated groundwater via ingestion and inhalation of vapors while showering. No unacceptable human health risks were identified for surface water, sediment, or soil. The screening level ecological risk assessment (SLERA) did not identify any unacceptable ecological risks associated with groundwater, surface water, sediment or soil. Based on the conclusions of the HHRA and SLERA, the RI indicated that remedial actions were necessary to address the human health risks associated with contaminated groundwater. 4.0 Remedial Actions In accordance with CERCLA and the NCP, the overriding goals for any remedial action are the protection of human health and the environment and compliance with applicable or relevant and appropriate requirements (ARARs). A number of remedial alternatives were considered for the Site and the final selection was made based on an evaluation of each alternative against nine evaluation criteria that are specified in Section 300.430(e)(9)(iii) of the NCP. 4.1 Remedy Selection Groundwater (OU1) EPA selected the remedy for groundwater, surface water, and sediment in a June 30, 1992 ROD and modified the remedy in two ESDs, issued on August 3, 1998 and February 10, 2012. No unacceptable human health or ecological risk were identified for surface water or sediment; therefore, the 1992 ROD did not select a response action for those media. The 1992 ROD identified the following remedial action objectives (RAOs):

Prevent migration of all contaminated on-Plant groundwater to off-Plant residential wells, to the extent technically practicable, especially groundwater in contact with DNAPLs;

Prevent migration of all contaminated off-Plant groundwater past the area served by public water;

Restore contaminated groundwater to beneficial use.

The groundwater remedy consists of the following primary components:

Extraction and treatment of contaminated on-Plant groundwater via air stripping and carbon adsorption of air emissions utilizing an on-Plant treatment system to contain highly contaminated groundwater and restore groundwater on-Plant to beneficial use;

Extraction and treatment of contaminated off-Plant groundwater via air stripping utilizing an off-Plant treatment system to restore contaminated groundwater that has migrated off-Plant to beneficial use;

Discharge of treated groundwater to the northern tributary of Rock Creek under an NPDES permit;

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Deed restrictions to prevent the use of contaminated groundwater both on and off-Plant and to prevent activities that could interfere with the remedy;

Groundwater and residential well monitoring. Because the 1992 ROD did not specifically require the installation of two separate groundwater extraction and treatment systems, EPA issued the 1998 ESD to incorporate the use of the two separate systems into the groundwater remedy. The 1992 ROD and 2012 ESD also required institutional controls both on and off-Plant, as described in additional detail in Section 6.3, Document Review. The 1992 ROD identified the cleanup goals for the groundwater contaminants of concern (COCs) as the non-zero maximum contaminant level goal (MCLG), if one exists, or the MCL for that contaminant as summarized in Table 2, below. Non-zero MCLGs for the COCs are either the same as the MCL or do not exist; therefore, MCLs were selected as the cleanup goals for all COCs. Table 2: Groundwater Cleanup Goals

Groundwater COC1

MCL2 (microgram per liter, µg/L)

TCE 5 1,1,1-TCA 200 1,1-DCE 7 1,1-DCA NA3

cis-1,2-DCE 70 trans-1,2-DCE 100

1,2-DCA 5 Notes: 1) The 1992 ROD referred to these COCs as Compounds of Interest. 2) Federal MCLs available at http://water.epa.gov/drink/contaminants/#List, accessed November 23, 2015. 3) NA, not applicable. An MCL has not been established for this constituent.

Soil (OU2) EPA issued a “No Action” ROD for soil on March 31, 1995 because no unacceptable human health or ecological risk was identified for soil. The ROD also noted that any remaining contaminants in soil that may migrate into groundwater would be captured by the on-Plant groundwater extraction and treatment system selected by the 1992 ROD. 4.2 Remedy Implementation EPA issued a Unilateral Administrative Order (UAO) to Westinghouse and Schindler on December 29, 1992, which required performance of the groundwater remedial design and remedial action. Westinghouse complied with the UAO; however, Schindler declined to participate. Westinghouse completed the remedial design from March 1993 through May 1997.

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The groundwater remedy was designed to create two separate capture zones for contaminated groundwater, Capture Zone 1 and Capture Zone 2, using two separate groundwater extraction and treatment systems. The on-Plant groundwater extraction and treatment system was designed to capture both the shallow and deep groundwater zones along the center line of the groundwater contaminant plume on-Plant (Capture Zone 1). The off-Plant groundwater extraction and treatment system was designed to capture the deep groundwater zone along the downgradient edge of the off-Plant groundwater contaminant plume (Capture Zone 2). Pumping rates for the extraction wells in Capture Zone 2 were designed so that the extraction wells did not interfere with Capture Zone 1, and to avoid causing off-Plant migration of highly contaminated groundwater. The area between Capture Zone 1 and Capture Zone 2 was designated as the stagnation zone. Pumping rates within Capture Zones 1 and 2 were designed to be varied to move the stagnation zone periodically so that all contaminated groundwater at the Site would be addressed. Contaminated groundwater not recovered by Capture Zone 1 wells was expected to be captured within Capture Zone 2. Construction of the on-Plant and off-Plant pilot groundwater extraction and treatment systems began in July 1996. The on-Plant groundwater recovery and treatment system utilized components of the system originally installed in 1984 and began operation in October 1996. The off-Plant groundwater extraction and treatment system, located on Boyds School Road east of the Site, began operation in November 1996. In March 2005, EPA approved the shutdown of the off-Plant groundwater extraction and treatment system. No COCs were present in the influent to the off-Plant system at concentrations exceeding MCLs and COC concentrations were below MCLs or had significantly decreased in the off-Plant monitoring wells. Additionally, monitoring data indicated that the off-Plant pumping may have been causing contaminated groundwater to migrate from Capture Zone 1 into Capture Zone 2. 4.3 Operation and Maintenance Operation and maintenance (O&M) is performed by Westinghouse in accordance with the 1994 O&M Plan. Current O&M activities consist primarily of groundwater sampling and analysis and operation of the on-Plant groundwater extraction and treatment system. Progress reports summarizing O&M tasks and sampling results are submitted to EPA on a monthly basis. A total of 39 monitoring wells and seven extraction wells are sampled for VOCs on a semi-annual basis. Monitoring and extraction well networks are located within the shallow and deep groundwater zones and at both on-Plant and off-Plant locations. Beginning in 2011, ten monitoring wells are also sampled for 1,4-dioxane on a semi-annual basis. Groundwater monitoring results are discussed in detail in Section 6.4. The area surrounding the Site is served by a public water supply system. However, eight residential properties in the vicinity of the Site are not connected to the public water system and continue to rely on private wells for water supply. The residential water supply wells are located to the east (RW-1 through RW-5) and north (RW-6 through RW-8) of the Site, as shown on Figure 2. RW-1 is no longer in use and is not included in the monitoring program. Residential

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Wells RW-2 through RW-8 are sampled for VOCs on an annual basis. RW-2 through RW-5 are also sampled for 1,4-dioxane on an annual basis. Residential well monitoring results are discussed in detail in Section 6.4. O&M of the on-Plant groundwater extraction and treatment system consists primarily of equipment maintenance, data logging, and non-routine tasks. The off-Plant system has been shut down since 2005. Treatment system effluent is sampled for VOCs and other parameters on a bi-monthly basis in accordance with the National Pollution Discharge Elimination System (NPDES) program. No violations of the NPDES discharge permit were reported during this FYR period. The NPDES permit was renewed in January 2016. Annual O&M costs for the Site during the current FYR period are summarized below. The 1992 ROD originally estimated annual O&M costs of $140,000. 2011: $138,000 2012: $82,000 2013: $116,000 2014: $95,000 2015: $170,000 5.0 Progress Since the Last Five-Year Review The protectiveness statement from the 2011 FYR for the Site stated the following: The protectiveness of the remedy at the Site cannot be determined at this time and will be deferred until the vapor intrusion pathway has been evaluated and the presence of 1,4-dioxane is ruled out. Once these evaluations are complete, a protectiveness determination will be documented in an addendum to this FYR. The 2011 FYR included six issues and recommendations. This report summarizes each recommendation and its current status below. An addendum to the 2011 FYR was not prepared.

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Table 3: Progress on Recommendations from the 2011 FYR

Recommendations Party

Responsible Milestone

Date Action Taken and Outcome

Date of Action

A capture zone analysis should be performed in accordance with EPA guidance “A Systematic Approach for Evaluation of Capture Zones at Pump and Treat Systems (EPA 600/R-08/003).” Depending upon the results of the capture zone analysis, decisions would be made whether to restart the Zone 2 groundwater extraction system and/or optimize the Zone 1 extraction system.

PRP June 2012

Westinghouse completed a capture zone analysis in October 2011, in accordance with EPA guidance. The analysis concluded that the on-Plant treatment system was adequately capturing contaminated groundwater within Capture Zone 1. The analysis also concluded that restarting the extraction wells in Capture Zone 2 was not necessary. Figures C-6 and C-7 show the approximate capture zones in the shallow and deep groundwater zones.

10/20/2011

For residents who elected not to be hooked up to the public water supply system, include a statement regarding the availability of the option to be hooked up to the public water supply system in the annual well monitoring results notification.

PRP September

2011

Westinghouse includes a statement in the annual residential well monitoring results letters offering to connect the residents to public water. No responses have been received to date.

03/08/2013

Modify sampling plans to include l,4-dioxane in the future groundwater analyses.

PRP September

2011

Westinghouse sampled eleven monitoring wells and five residential wells for 1,4-dioxane beginning in August 2011. 1,4-dioxane was detected at concentrations exceeding the EPA Regional Screening Level (RSL) and the Pennsylvania Land Recycling and Remediation Standards Act (Act 2) medium-specific concentration (MSC) in five on-Plant monitoring wells. Westinghouse currently samples for 1,4-dioxane on a semi-annual basis at ten monitoring wells and on an annual basis at four residential wells.

02/28/2012

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Recommendations Party

Responsible Milestone

Date Action Taken and Outcome

Date of Action

Perform a VI investigation of the Plant and homes which overlay the shallow VOC plume.

PRP December

2011

Westinghouse completed a VI investigation of the former Plant building in June 2015. Details of this investigation are presented in Section 6.4, Data Review. The former Plant building is currently unoccupied, however, in a letter dated November 20, 2015, Westinghouse agreed to install a VI mitigation system in the former Plant building if the former Plant building is occupied in the future. Westinghouse also performed a VI evaluation at the closest residences to the Plant property. The evaluation indicated that VI is not a concern at those locations because shallow groundwater is not impacted in the vicinity of the residences.

June 2014 through

November 20, 2015

Prepare and issue an ESD to require the implementation of institutional controls.

EPA September

2011

EPA issued an ESD requiring institutional controls to restrict the use of groundwater at the Site until cleanup goals are achieved. The ESD also required institutional controls to restrict activities that could adversely affect or interfere with the off-Plant groundwater extraction and treatment system and associated physical structures.

02/10/2012

Conduct a mechanical inspection of both treatment systems and make repairs as necessary including replacement of the inlet pump for the on-Plant treatment system if it is required.

PRP September

2011

The 2011 FYR noted signs of minor leaks at the various plumbing joints of the groundwater extraction and treatment system, but the follow-up inspection found that the issue was related to condensation and not leaks. No repair of the system was necessary.

11/06/2012

6.0 Five-Year Review Process 6.1 Administrative Components EPA Region 3 completed the FYR from August 2015 through June 2016. EPA remedial project managers (RPMs) Bhupi Khona and John Epps led the EPA Site review team. Contractor support was provided to EPA by Skeo Solutions. The remainder of the EPA Site team consisted of Jeff Tuttle, EPA toxicologist, Bill McKenty, EPA hydrogeologist, Joe McDowell and Patricia Flores-Brown, EPA VI team, and Larry Johnson, EPA community involvement coordinator (CIC). The review consisted of the following activities: Community notification Document review Data collection and review

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Site inspection Local interviews FYR report development and review

6.2 Community Involvement On February 10, 2016, EPA published a public notice in the Gettysburg Times newspaper announcing the commencement of the FYR process for the Site, providing contact information for EPA, and inviting community participation.

EPA will make the final FYR Report available to the public via the EPA FYR website (www.epa.gov/superfund/search-superfund-five-year-reviews) and at the designated Site repository: Adams County Public Library, 140 Baltimore Street, Gettysburg, Pennsylvania. 6.3 Document Review This FYR included a review of relevant, Site-related documents, including the RODs, ESDs, prior FYR reports, monthly progress reports and recent monitoring data. Appendix A presents a complete list of the documents reviewed. ARARs Review Groundwater ARARs The 1992 ROD identified contaminant-specific ARARs for groundwater as the non-zero MCLGs (40 CFR §141.50) and MCLs (40 CFR §141.12 and 141.61) established under the Safe Drinking Water Act and the Pennsylvania drinking water standards (25 PA Code Sections 264.90-264.100 and in particular, 264.97(1), (j), and 264.100(a)(9)). The PADEP ARAR at the time required that contaminated groundwater be remediated to background concentrations. The 1992 ROD waived the PADEP background ARAR because compliance with this requirement would be technically impracticable from an engineering perspective and would result in greater risk to human health and the environment due to the presence of DNAPL in on-Plant groundwater. Contaminant concentrations are compared to current non-zero MCLGs and MCLs for the purposes of long-term groundwater monitoring (Table 2). Surface Water ARARs The 1992 ROD did not identify chemical-specific surface water ARARs. The 1992 ROD identified the Pennsylvania Water Quality Criteria (25 PA Code §93.1 through 93.9), as related to groundwater extraction and treatment system effluent, as to-be-considered (TBC) criteria. The numeric Pennsylvania Water Quality Criteria were not specified in the 1992 ROD. Contaminant concentrations in the groundwater extraction and treatment system effluent are compared to the discharge criteria specified in the NPDES permit.

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Institutional Control Review On November 23, 2015, EPA contractor staff performed a public records search using the Adams County Recorder of Deeds website (http://www.adamscounty.us/Dept/RecOfDeeds/Pages/default.aspx). The public records search indicated that Westinghouse transferred ownership of the Plant property to Logistics Resource, LLC on July 9, 2015, as summarized in Table 4, below. Table 4: Plant Property Ownership

Date Type of

Document Description Book # Page # Parcel #

07/09/2015 Deed

Transferred ownership of the former Westinghouse Plant property from CBS/Westinghouse of PA, Inc. to Logistics Resource, LLC. Deed includes an environmental deed notification, which summarizes chemicals of potential concern in soil and groundwater at the property.

6050 674 09F11-0124A--000

(about 84 acres)

The 1992 ROD and 2012 ESD required institutional controls to prevent the use of contaminated groundwater at the Site and to prevent activities that could interfere with the remedy. The public records search identified institutional controls that meet these requirements, as discussed below. EPA contractor staff located the UAO for the Site, recorded with the Adams County Recorder of Deeds (Book 704, Page 201). The deed also contains an Environmental Deed Notification that provides a brief summary of environmental conditions at the Site. EPA contractor staff also located an Environmental Covenant, recorded July 21, 2015, which applies to the Plant property. The Environmental Covenant restricts groundwater use at the Plant property; prohibits actions that could interfere with the remedy; provides for operation and maintenance of the on-Plant groundwater extraction and treatment system; restricts construction of any future buildings on the Plant property without evaluation and/or mitigation of VI; and provides access to conduct remedial actions. EPA contractor staff also located an additional institutional control in the form of an Environmental Easement and Restrictive Covenant, recorded July 29, 2015. The Environmental Easement and Restrictive Covenant, executed between Logistics Resources, LLC and Westinghouse, incorporates the restrictions in the July 21, 2015 Environmental Covenant; grants Westinghouse access to the Plant property to perform remedial actions; requires the operation and maintenance of a VI mitigation system at the former Plant building, if installed; and requires the installation, operation, and maintenance of a VI mitigation system at any future buildings, if required by EPA per the July 21, 2015 Environmental Covenant.

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The requirements in the Environmental Covenant and Environmental Easement and Restrictive Covenant related to VI at the former Plant building and at future buildings on the Plant property were not required by the 1992 ROD, 1998 ESD, or 2012 ESD. Therefore, EPA will issue an ESD to add these institutional control requirements to the remedy for the Site. VI at the Site is discussed in detail in Section 6.4, Data Review. Cumberland Township has implemented ordinances that require new developments to be connected to public water and sewer (Cumberland Township Residential District Development Standards Ordinance §27-503 and Industrial Development Ordinance §27-70l). Cumberland Township has also implemented an ordinance requiring a permit for all new water supply wells (Cumberland Township Well Ordinance §26-101). These ordinances meet the institutional control requirement for restricting the use of groundwater in vicinity of the Site. Table 5 lists the institutional controls associated with areas of interest at the Site. Figure 3 depicts the properties subject to institutional controls at the Site.

Table 5: Institutional Control (IC) Summary Table

Media ICs

Needed

ICs Called for in the Decision

Documents

Impacted Parcel

IC Objective

Instrument in Place

On-Plant Groundwater

Yes Yes 09F11-0124A--000

Restrict use of groundwater on-Plant until groundwater cleanup goals are achieved; prohibit actions that could interfere with, obstruct or disturb the efficacy, function, and operation or maintenance of the groundwater extraction and treatment systems or other physical features associated with the groundwater remedial action.

Environmental Covenant, recorded with the Adams County Recorder of Deeds on July 21, 2015.

Environmental Easement and Restrictive Covenant recorded with the Adams County Recorder of Deeds on July 29, 2015.

Off-Plant Groundwater

Yes Yes

Parcels above the groundwater contaminant plume

Restrict use of groundwater off-Plant until groundwater cleanup goals are achieved.

Cumberland Township Ordinances §27-503 and §27-70l;

Cumberland Township Ordinance §26-101.

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Figure 3: Institutional Control Base Map


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6.4 Data Review The data review evaluated groundwater, residential well, and VI monitoring data collected between 2011 and 2015. Monitoring well and residential well sampling locations are presented on Figure 2. Appendix C includes potentiometric surface maps and isoconcentration maps for the shallow and deep groundwater zones. Groundwater Monitoring Groundwater monitoring is performed on a semi-annual basis at 39 monitoring wells and seven extraction wells, as presented in Table 6. Samples from all wells are analyzed for VOCs and from ten monitoring wells for 1,4-dioxane. Sampling results are discussed below. Table 6: Monitoring and Extraction Well Summary

On-Plant Wells Off-Plant Wells

Monitoring Wells Shallow Deep Shallow Deep

PMW-1A PMW-1Ba N/A PMW-14a PMW-2A PMW-2Ba N/A PMW-15 PMW-3A PMW-3Ba/C/D PMW-16A PMW-16B

N/A PMW-4 N/A PMW-17 N/A PMW-5a PMW-20Aa PMW-20Ba

PMW-7A PMW-7B N/A PMW-21A/B PMW-8A PMW-8B N/A PMW-22A/B PMW-9Aa PMW-9Ba PMW-23 N/A PMW-10A PMW-10B PMW-25 PMW-25A/B PMW-12A PMW-12B N/A OW-1 PMW-13A PMW-13Ba N/A OW-2

Extraction Wells EW-1 EW-5 EW-2 EW-6 EW-3

EW-7 EW-4

Notes: a) Well currently sampled for 1,4-dioxane.

VOC Results Concentrations of TCE exceeded the MCL of 5 µg/L in multiple on-Plant wells and in three off-Plant wells during the FYR period. Concentrations of 1,1-DCE, cis-1,2-DCE, tetrachloroethene (PCE), and TCA also exceeded MCLs during the FYR period in a limited number of on-Plant monitoring wells. Table 6 summarizes maximum detected concentrations of COCs in groundwater during this FYR period. A complete summary of historical groundwater data can be found in the June 10, 2015 Monthly Progress Report No. 267, prepared by Woodard & Curran.

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Table 7: Groundwater VOC Summary

COCa MCL (µg/l)

Maximum Detected

Concentrationb

(µg/l)

Location of Maximum Detected

Concentration (Date)c

Number of Wellsd with Detections

above MCL

TCE 5 6,600 EW-2 (Nov 2014) 17 1,1-DCE 7 470 EW-2 (Nov 2014) 5

cis-1,2-DCE 70 1,800 PMW-9A (Nov 2014) 3 PCE 5 130 PMW-9A (Dec 2012) 2

1,1,1-TCA 200 400 EW-2 (Nov 2014) 2 Notes:

a) Only those VOCs with at least one detection above the MCL are included in this table. b) The maximum detected concentration between August 2011 and April 2015. c) EW-2 and PMW-9A are located on-Plant. d) Includes monitoring wells and extraction wells; does not include the wells installed as part of the VI

monitoring program (SVMW-1 and SVMW-2). Appendix C includes isoconcentration maps prepared using total groundwater data from prior to system startup (July to August 1996) and the April 2015 sampling event for both the shallow and deep groundwater zones at the Site. The maps show the change in size and concentration of the groundwater contaminant plumes. The on-Plant groundwater extraction and treatment system has been effective in capturing and reducing the groundwater contaminant plume in the shallow groundwater zone (Capture Zone 1). Total VOC concentrations within the shallow groundwater zone have decreased by an order of magnitude and the extent of the shallow groundwater contaminant plume, as defined by the 100 µg/l total VOC contour, has decreased since the system began operation in 1996. The groundwater contaminant plume in the shallow groundwater zone is shown on Figure C-3. The on-Plant groundwater extraction and treatment system has also been effective in capturing and reducing the groundwater contaminant plume in the deep groundwater zone. Total VOC concentrations in the deep groundwater zone have also decreased by an order of magnitude and the extent of the plume, as defined by the 1,000 and 100 µg/L total VOC contours, has decreased since the system began operation in 1996. The extent of the 10 µg/L total VOC contour has remained relatively consistent. The groundwater contaminant plume in the deep groundwater zone is shown on Figure C-4. Although total VOCs show an overall decrease in concentration since system startup, TCE concentrations have not changed substantially in on-Plant wells PMW-9A and PMW-9B since 2008 and remained relatively consistent throughout the FYR period. These wells have historically contained the highest VOC concentrations at the Site and are located closest to the former Plant building, which is considered the source area at the Site. TCE concentration trends for these wells are shown on Figure C-5. Three off-Plant deep bedrock wells (PMW-14, PMW-16B and EW-6) contained TCE at concentrations exceeding the MCL of 5 µg/L during the FYR period. The TCE concentration in PMW-14 ranged from 4.7 µg/L to 6.8 µg/L and was below the MCL in four of the eleven sampling events during the FYR period. The TCE concentration in EW-6 ranged from 3.6 µg/L

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to 7.5 µg/L and was below the MCL in seven of the thirteen sampling events during the FYR period. Concentrations of TCE in both PMW-14 and EW-6 exhibit an overall decreasing trend since 1996 and have stabilized since the off-Plant groundwater extraction and treatment system was shut down in 2005. The TCE concentrations detected in PMW-16B during the FYR period are presented in Table 8, below. Table 8: PMW-16B TCE Concentrations

Monitoring Well

May 2011

Oct. 2011

June 2012

Dec. 2012

April 2013

Oct. 2013

April 2014

Nov. 2014

April 2015

Nov. 2015

April 2016

PMW-16Ba 25 70 77 83 89 98 100 100 93 86 72 a) TCE concentrations reported in µg/L.

TCE concentrations increased in this well during the FYR period. The increasing trend is biased by the historically low TCE concentration detected in May 2011. TCE concentrations in PMW-16B prior to the current FYR period ranged from 65 µg/L to 93 µg/L, which are consistent with current concentrations in this well and indicate that the groundwater contaminant plume is not migrating in this portion of the Site. However, the off-Plant groundwater extraction and treatment system was not effective in reducing contaminant concentrations in this well and was shut down in 2005 due to concerns that contaminated groundwater was being drawn off-Plant. Therefore, an evaluation is necessary to determine if optimization of the existing groundwater extraction and treatment systems and/or alternative remedial technologies would be able to address groundwater contamination in the vicinity of PMW-16B and meet cleanup goals throughout the groundwater contaminant plume. VOC Statistical Analysis A statistical analysis of total VOC concentrations from 2011 through 2015 was also performed for 21 monitoring and extraction wells using the Mann-Kendall method. Decreasing trends were observed in seven wells, no trend was observed in two wells, and increasing trends were reported in twelve wells. Of the twelve wells in which increasing trends were observed, statistically significant increasing trends were observed in four wells: PMW-16B, PMW-21B, EW-2 and EW-4. Table C-1 presents a summary of the Mann-Kendall statistical analysis. EW-2 and EW-4 are on-Plant extraction wells and the increasing trends indicate that the on-Plant groundwater extraction and treatment system is continuing to remove contaminant mass from the source area at the Plant. PMW-16B and PMW-21B are off-Plant monitoring wells. Detected VOCs at PMW-21B were below MCLs. TCE was the only COC that exceeded the MCL in PMW-16B. As discussed above, although the total VOC concentration indicated an increasing trend, the trend may be biased due to the historically low TCE concentration detected in 2011 and total VOC concentrations have generally been consistent with historic results. As indicated above, an evaluation is necessary to determine how to meet cleanup goals throughout the groundwater contaminant plume.

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1,4-Dioxane Results 1,4-dioxane was not identified as a COC at the Site at the time of the 1992 ROD. However, due to the historic use of chlorinated solvents such as TCE and TCA, sampling for 1,4-dioxane was recommended in the 2011 FYR. In response, Westinghouse began sampling select monitoring, and residential wells for 1,4-dioxane in 2011. Westinghouse currently samples for 1,4-dioxane at ten monitoring wells on a semi-annual basis and at four residential wells on an annual basis. Table C-2 presents a summary of the 1,4-dioxane detections at the Site. Because no MCL has been established for 1,4-dioxane, the EPA tap water RSL and PADEP MSC were used for data analysis. Four on-Plant wells and one off-Plant well contained 1,4-dioxane at concentrations exceeding the EPA tap water RSL of 0.46 µg/L and/or the Pennsylvania MSC of 6.4 µg/L.

1,4-dioxane was detected at the highest concentrations in on-Plant monitoring well PMW-9A. Concentrations ranged from 220 to 410 µg/L, exceeding both the EPA tap water RSL and PADEP MSC. Groundwater contamination in this area is contained by the on-Plant groundwater extraction and treatment system and is within Capture Zone 1. 1,4-dioxane was detected in off-Plant monitoring well PMW-14 at concentrations ranging from 0.59 µg/L and 1 µg/L. These concentrations exceed the EPA tap water RSL but are below the PADEP MSC. Detected concentrations in this well have been stable since sampling began in 2011. Due to the detections of 1,4-dioxane in both on and off-Plant wells, all monitoring and extraction wells at the Site should be sampled and analyzed for 1,4-dioxane to evaluate the extent of 1,4-dioxane contamination and to determine if 1,4-dioxane is a COC at the Site. Additionally, influent and effluent to the on-Plant groundwater extraction and treatment system should be sampled for 1,4-dioxane to determine if additional treatment is necessary, because air-stripping does not remove 1,4-dioxane. Residential Well Monitoring Residential well monitoring is performed on an annual basis at seven locations (RW-2 through RW-8). Samples from all residential wells are analyzed for VOCs and from four residential wells (RW-2 through RW-5) for 1,4-dioxane. Sampling results are discussed below. TCE, 1,1-DCE and 1,4-dioxane were detected in select residential wells during the FYR period. All detections of TCE and 1,1-DCE were below MCLs. 1,4-Dioxane was detected in two residential wells at concentrations below the EPA tap water RSL and PADEP MSC. Table 9 summarizes 1,4-dioxane detections in residential wells.

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Table 9: 1,4-Dioxane in Residential Wells Residential

Well1 Nov. 2011 Dec 2012 Oct 2013 Nov 2014 Nov 2015

EPA RSL2

Pennsylvania MSC3,4

RW-45 0.11 0.13 <0.10 0.21 <0.20 0.46 6.4

RW-55 0.14 0.19 <0.10 0.27 0.26 Notes: 1 – Only those wells with 1,4-dioxane detections are included in the table. 2 – EPA RSL from http://www.epa.gov/risk/risk-based-screening-table-generic-tables, accessed December 15, 2015, based on cancer risk of 1 x 10-6. 3 – Pennsylvania MSC is for a residential used aquifer with total dissolved solids (TDS) ≤ 2,500. 4 – Pennsylvania MSC from http://www.dep.pa.gov/Business/Land/LandRecycling/Standards-Guidance-Procedures/Pages/Statewide-Health-Standards.aspx#.VnBOVb9UV_c, accessed December 15, 2015. 5 – 1,4-Dioxane concentrations reported in µg/L.

Westinghouse has offered to connect the remaining residents with residential wells to the public water supply on multiple occasions. To date, no additional residents have elected to connect to the public water supply. Residential wells will continue to be sampled for VOCs and 1,4-dioxane on an annual basis to ensure that residents are not being exposed to contaminated groundwater from the Site. Vapor Intrusion Monitoring Westinghouse performed a VI evaluation at the former Plant building in March and April 2015. Co-located sub-slab soil vapor and indoor air samples were collected at ten locations in the former Plant building in March 2015 and analyzed for VOCs, including 1,4-dioxane. A second set of indoor air samples was collected in April 2015. Sampling results were compared to the EPA industrial air RSLs for data analysis. Figure C-8 shows the VI sampling locations. Three Site-related VOCs (TCE, 1,1-DCA and 1,4-dioxane) were detected at concentrations exceeding the respective EPA industrial RSLs in the sub-slab vapor samples collected at five locations during the March 2015 sampling event, assuming an attenuation factor of 0.03. TCE was also detected at concentrations exceeding the industrial RSL in two indoor air samples collected during the March 2015 sampling event. Table C-3 presents the VI evaluation sampling results. Because the method detection limits (MDLs) were greater than the EPA industrial RSLs for several VOCs during the March 2015 sampling events, additional indoor air samples were collected in April 2015. These samples were analyzed using the TO-15 Selective Ion Method (SIM) to ensure that the MDL did not exceed the EPA industrial RSL for any VOCs. TCE was detected above the EPA industrial RSL (0.88 µg/m3) at five indoor air sample locations during the April 2015 sampling event at concentrations ranging from 0.918 µg/m3 to 1.39 µg/m3. Westinghouse performed a screening level human health risk assessment to evaluate the cumulative carcinogenic and non-carcinogenic risk due to VI. The assessment concluded that no unacceptable carcinogenic or non-carcinogenic human health risk was associated with the indoor air TCE concentrations. However, at the time of the April 2015 sampling event, the building was unoccupied, and the heating, ventilation, and air conditioning (HVAC) system was not in operation. Therefore, due to the high TCE concentrations detected in the sub-slab samples during the March 2015 sampling

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events, VI may present an unacceptable human health risk in the future if the building is occupied and conditions in the building change. Westinghouse indicated in a November 20, 2015 letter to EPA that they will voluntarily install a VI mitigation system in the former Plant building, if the building is occupied in the future. If a mitigation system is installed, additional sampling will be conducted prior to occupation of the building, but with the HVAC system in operation, to determine the impact of the mitigation system on indoor air TCE concentrations. As indicated in Section 6.3, Document Review, Westinghouse entered into an Environmental Easement and Restrictive Covenant on July 29, 2015 with the current property owner, Logistics Resources, LLC, requiring the operation and maintenance of a VI mitigation system at the former Plant building, if such a system was installed. The detections of elevated concentrations of VOCs in sub-slab and indoor air samples at the existing Plant building indicate that VI may be a concern if buildings are constructed on the Plant property in the future. The July 21, 2015 Environmental Covenant restricts construction of any future buildings on the Plant property without evaluation of VI. The Environmental Covenant also allows for the installation of a VI mitigation system in lieu of the VI evaluation. Requirements for institutional controls related to VI were not included in the 1992 ROD, 1998 ESD, or 2012 ESD. Therefore, EPA will issue an ESD for institutional controls requiring the operation and maintenance of a VI mitigation system at the former Plant building, if such a system is installed, and requiring an evaluation and/or mitigation of VI at any future buildings constructed on the Plant property. Prior to the 2011 FYR, Westinghouse installed two shallow off-Plant groundwater monitoring wells, SVMW-1 and SVMW-2, to evaluate the potential for VI at the residences closest to the Site. The map that was evaluated during the 2011 FYR showed the incorrect location of these wells and the 2011 FYR indicated that additional VI investigation was necessary. However, the correct well locations were subsequently provided by Westinghouse and the sampling data was reevaluated during this FYR period. The evaluation indicated that shallow contaminated groundwater does not extend within 100 feet of the residences and that VI is not currently a concern at those locations. The correct locations of SVMW-1 and SVMW-2 as well as the extent of the shallow groundwater contaminant plume in relation to the residences are shown on Figure C-3. 6.5 Site Inspection EPA performed the FYR Site Inspection on October 29, 2015. In attendance were Bhupi Khona, EPA RPM; Asuquo Effiong, PADEP site manager; Douglas Spicuzza and Christine Kuzmkowski, Westinghouse contractors; and Ryan Burdge and Jill Billus, Skeo Solutions. For a full list of site inspection activities, see the Site Inspection Checklist in Appendix D. Site photographs are available in Appendix E. Site Inspection participants observed the Plant property, on-Plant monitoring and extraction wells, and the on-Plant groundwater extraction and treatment system. The treatment system and wells were well maintained, and no significant issues were noted. The locks on some monitoring wells were broken, and EPA requested a well inspection and repair be completed by

32

Westinghouse. EPA also suggested that Westinghouse consider raising the height of a vent on the northern exterior wall of the treatment system building to avoid the possibility of snow cover. Site Inspection participants also observed the inactive off-Plant groundwater extraction and treatment system building and off-Plant monitoring and extraction wells to be in good condition. EPA contractor staff visited the Site repository, Adams County Public Library located at 140 Baltimore Street in Gettysburg, Pennsylvania. The site repository was up to date with Site documents. 6.6 Interviews The FYR process included interviews with parties affected by the Site. The purpose was to document the perceived status of the Site and any perceived problems or successes with respect to the remedy. All interviews were conducted in person on October 29, 2015. EPA met with Mr. Ben Thomas, Jr., Township Manager for Cumberland Township, and Mr. Bill Naugle, Zoning and Code Enforcement Officer for Cumberland Township. The township representatives felt they were well-informed about the Site and did not have any concerns with the Site or remedy. They were unaware of any trespassing concerns at the Site. EPA also met with Mr. Al Penska, Manager for Adams County. Mr. Penska stated that Adams County intended to purchase the property where the off-Plant groundwater treatment building is located for use as office space. The County was aware of the groundwater treatment building on the property and Mr. Penska did not believe it would interfere with the County’s anticipated use of the property. 7.0 Technical Assessment 7.1 Question A: Is the remedy functioning as intended by the decision documents?

Yes. The remedy is functioning as intended by the decision documents. The on-Plant groundwater extraction and treatment system has established and maintained Capture Zone 1 as designed and is effectively containing the on-Plant groundwater contaminant plume. Currently, the on-Plant treatment system is operating at a pumping rate of approximately 6 to 10 gallons per minute (gpm). VOC concentrations in groundwater have decreased by an order of magnitude or more in the on-Plant source area since system startup in 1996. The initial influent VOC concentration of the on-Plant treatment system was 5,210 µg/L in October 1996 compared to influent VOC concentrations of approximately 660 µg/L in July 2015. Groundwater treated by the on-Plant treatment system is being discharged in accordance with the requirements of the NPDES permit and no violations of the permit limits occurred during the FYR period. Treatment system air emissions total approximately 20 pounds per year of VOCs, within the allowable limit of 6,160 pounds per year of VOCs. The off-Plant groundwater extraction and treatment system was shut down in 2005 per EPA approval. Contaminant concentrations in off-Plant groundwater were below cleanup goals during the FYR period in all but three wells. TCE concentrations in one of these wells, PMW-16B, have

33

increased during this FYR period; however, these concentrations are consistent with historic concentrations for this location. An evaluation is necessary to determine if optimization of the existing groundwater extraction and treatment systems and/or alternative remedial technologies would be able to address groundwater contamination in the vicinity of PMW-16B and meet groundwater cleanup goals throughout the groundwater contaminant plume. The majority of residences in the vicinity of the Site are connected to the public water supply. However, seven residential wells are located in the vicinity of the Site. VOCs and 1,4-dioxane have been detected in select residential wells at concentrations below MCLs, or the EPA tap water RSL and PADEP MSC for 1,4-dioxane. Westinghouse has offered to connect these residences to the public water supply but no residents have elected to connect to date. 1,4-dioxane has been detected above the EPA tap water RSL and/or the PADEP MSC in select on-Plant and off-Plant extraction and monitoring wells and in select residential wells. Sampling for 1,4-dioxane should be performed by Westinghouse at all extraction and monitoring wells to delineate the full extent of 1,4-dioxane contamination and to determine if 1,4-dioxane is a COC at the Site. Samples should also be collected by Westinghouse from the on-Plant groundwater extraction and treatment influent and effluent to determine if additional treatment for 1,4-dioxane is necessary. Institutional controls are in place to restrict the use of groundwater; provide for maintenance of the groundwater remediation system; require operation and maintenance of a VI mitigation system in the former Plant building, if such a system is installed; restrict construction of any new buildings on the Plant property without a VI evaluation and/or mitigation; and allow continued access by the PRP to conduct remedial actions. Local ordinances are also in place that require new developments to be connected to the public water supply and require permits for any new wells. 7.2 Question B: Are the exposure assumptions, toxicity data, cleanup levels and remedial action objectives (RAOs) used at the time of remedy selection still valid?

No. The exposure assumptions and toxicity data from the time of the 1992 ROD have changed. However, these changes do not impact the protectiveness of the remedy. 1,4-dioxane has been detected in groundwater at the Site and was not evaluated at the time of the 1992 ROD. All monitoring and extraction wells at the Site should be sampled for 1,4-dioxane by Westinghouse to evaluate the extent of 1,4-dioxane contamination in groundwater and to determine if 1,4-dioxane is a COC at the Site. Additionally, influent and effluent samples from the on-Plant groundwater extraction and treatment system should be collected by Westinghouse to determine if treatment for 1,4-dioxane is necessary. VI was not evaluated at the time of the 1992 ROD. A VI evaluation was performed at the former Plant building and for the residential area adjacent to the Site. Sub-slab and indoor air sampling indicated that VI may be a concern at the former Plant building. The former Plant building is currently unoccupied; however, Westinghouse will voluntarily install a VI mitigation system and perform sampling to confirm that the system is effective if the former Plant building is occupied

34

in the future. Institutional controls are also in place requiring operation and maintenance of a VI mitigation system at the former Plant building, if such a system is installed, and requiring a VI evaluation and/or mitigation at any future buildings on the Plant property. Based on groundwater data in the vicinity of residents adjacent to the Site, the shallow groundwater contaminant plume does not extend beneath the residential area and VI is not a concern in this area. EPA will issue an ESD to incorporate changes to the remedy related to the VI institutional controls. VOCs have been detected in select residential wells in the vicinity of the Site at concentrations below the respective MCLs. Westinghouse has offered to connect the affected residences to public water but the residents have elected not to connect at this time. Residential well monitoring will continue to be conducted on an annual basis to ensure that residents are not exposed to groundwater contamination from the Site. The RAOs used at the time of the 1992 ROD are still valid. The on-Plant groundwater extraction and treatment system has met the RAO of preventing the migration of contaminated groundwater and has made significant progress toward restoring groundwater to beneficial use. The off-Plant groundwater extraction and treatment system was shut down in 2005 after meeting the RAO of preventing the migration of contaminated groundwater past the area served by public water and restoring the majority of the off-Plant groundwater contaminant plume to beneficial use. An evaluation is necessary to determine how to meet cleanup goals throughout the groundwater contaminant plume. Operation of the on-Plant groundwater extraction and treatment system, long-term groundwater and residential well monitoring, and institutional controls will ensure that the RAOs continue to be met and that the remedy is protective in the long-term. 7.3 Question C: Has any other information come to light that could call into question the protectiveness of the remedy?

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

7.4 Technical Assessment Summary The remedy is functioning as intended by the decision documents for the Site. The groundwater extraction and treatment systems have prevented further migration and reduced the extent of the groundwater contaminant plume and progress has been made toward restoring groundwater to beneficial use. An evaluation is necessary to determine if optimization of the existing groundwater extraction and treatment systems and/or alternative remedial technologies would be able to meet cleanup goals throughout the groundwater contaminant plume. Additional sampling is necessary to delineate the extent of 1,4-dioxane contamination in groundwater, to determine if 1,4-dioxane is a COC at the Site, and to determine if treatment for 1,4-dioxane is necessary. The VI evaluation performed at the former Plant building indicated that VI mitigation may be necessary if the building is occupied in the future and may be necessary if additional buildings are constructed on the Plant property. Westinghouse will voluntarily install a VI mitigation system at the former Plant building, if it is occupied in the future. Institutional controls are in place to restrict land and groundwater use and to require evaluation and/or mitigation of VI and operation and maintenance of any installed VI mitigation systems at the current and future

35

buildings on the Plant property. EPA will issue an ESD to document the institutional controls related to VI. 8.0 Issues Table 10 summarizes the current Site issues. Table 10: Current Site Issues

Issue Affects Current Protectiveness? Affects Future Protectiveness?

1,4-Dioxane has been detected in groundwater at concentrations exceeding the EPA tap water RSL and PADEP MSC.

No Yes

The VI evaluation identified potential unacceptable human health risk due to VI at the former Plant building and at future buildings on the Plant property. VI was not addressed by previous decision documents.

No Yes

The off-Plant groundwater extraction and treatment system was shut down in 2005; however, contaminant concentrations in the off-Plant groundwater contaminant plume exceed groundwater cleanup goals.

No Yes

9.0 Recommendations and Follow-up Actions Table 11 provides recommendations to address the current Site issues. Table 11: Recommendations to Address Current Site Issues

Issue Recommendation / Follow-Up Action

Party Responsible

Oversight Agency

Milestone Date

Affects Protectiveness?

Current Future

1,4-Dioxane has been detected in groundwater at concentrations exceeding the EPA tap water RSL and PADEP MSC.

Perform additional sampling to evaluate the extent of 1,4-dioxane contamination, to determine if 1,4-dioxane is a COC at the Site, and to determine if modifications to the groundwater extraction and treatment system are necessary to treat for 1,4-dioxane.

PRP EPA 09/30/17 No Yes

36

Issue Recommendation / Follow-Up Action

Party Responsible

Oversight Agency

Milestone Date

Affects Protectiveness?

Current Future

The VI evaluation identified potential unacceptable human health risk due to VI at the former Plant building and at future buildings on the Plant property. VI was not addressed by previous decision documents.

Issue an ESD for institutional controls requiring the operation and maintenance of a VI mitigation system at the former Plant building, if such a system is installed, and requiring an evaluation and/or mitigation of VI at any future buildings on the Plant property.

EPA EPA 09/30/16 No Yes

The off-Plant groundwater extraction and treatment system was shut down in 2005; however, contaminant concentrations in a portion of the off-Plant groundwater contaminant plume exceed groundwater cleanup goals.

Evaluate optimization of the existing groundwater extraction and treatment systems and/or alternative remedial technologies to meet cleanup goals throughout the groundwater contaminant plume.

PRP EPA 9/30/17 No Yes

The following additional item, though not expected to affect protectiveness, warrants additional follow-up: The locks on some monitoring wells were observed to be broken or damaged during the Site

Inspection. A comprehensive inspection of all Site wells should be performed and any damaged locks should be repaired or replaced.

10.0 Protectiveness Statement The remedy for the Site is protective of human health and the environment in the short-term due to the installation and continued operation of the on-Plant groundwater extraction and treatment system. Long-term groundwater and residential well monitoring are performed regularly to evaluate the effectiveness of the remedy. Institutional controls are in place requiring the operation and maintenance of a VI mitigation system at the former Plant building, if such a system is installed, and requiring a VI evaluation and/or mitigation at future buildings on the Plant property. Institutional controls are also in place to restrict land and groundwater use on-Plant, to limit groundwater use off-Plant, and to protect the components of the remedy. However, for the remedy to be protective of human health and the environment in the long-term, additional evaluation is necessary to address 1,4-dioxane contamination at the Site and to determine how to

37

meet cleanup goals throughout the groundwater contaminant plume. Additionally, an ESD is necessary to document the institutional controls related to VI. 11.0 Next Review The next FYR will be due within five years of the signature/approval date of this FYR.

A-1

Appendix A: List of Documents Reviewed Capture Zone Analysis, Gettysburg Elevator Plant Superfund Site. Prepared by Cummings/Riter Consultants, Inc. October 20, 2011. Explanation of Significant Differences, Westinghouse Elevator Superfund Site, OU1, Cumberland Township, Adams County, Pennsylvania. Prepared by USEPA. August 3, 1998. Five-Year Review Report, Westinghouse Elevator Plant Superfund Site, Gettysburg, Adams County, Pennsylvania. Prepared by USEPA. June 2001. Monthly Progress Reports, Remedial Design Remedial Action, Gettysburg Elevator Plant Site. Prepared by Cummings/Riter Consultants Inc. and Woodard & Curran. June 2011 through September 2015. Proposed Sampling Plan – 1,4-Dioxane Monitoring, Addendum to Groundwater Monitoring Programs, Gettysburg Superfund Sites. Prepared by Cummings/Riter Consultants Inc. February 28, 2012. Record of Decision, Westinghouse Elevator Co. Plant, OU1, Cumberland Township, Adams County, Pennsylvania. Prepared by USEPA. June 30, 1992. Record of Decision, Westinghouse Elevator Co. Plant, OU2, Cumberland Township, Adams County, Pennsylvania. Prepared by USEPA. March 31, 1995. Remedial Investigation/Feasibility Study, Westinghouse Plant Site, Gettysburg, Pennsylvania. Prepared by Paul C. Rizzo Associates, Inc. March 4, 1991. Second Explanation of Significant Differences for the Westinghouse Elevator Plant Superfund Site, Cumberland Township, Adams County, Pennsylvania. Prepared by USEPA. February 10, 2012. Second Five-Year Review Report for Westinghouse Elevator Plant Superfund Site, Cumberland Township, Adams County, Pennsylvania. Prepared by USEPA. June 2006. Third Five-Year Review Report for Westinghouse Elevator Plant Superfund Site, Cumberland Township, Adams County, Pennsylvania. Prepared by USEPA. June 2011. Vapor Intrusion Report, Gettysburg Elevator Plant Superfund Site, Adams County, Pennsylvania. Prepared by Woodard & Curran. June 9, 2015.

B-1

Appendix B: Press Notice

C-1

Appendix C: Data Review Supporting Documentation Figure C-1: Potentiometric Surface – Shallow Bedrock Zone (prepared by Woodard & Curran, 2015)

C-2

Figure C-2: Potentiometric Surface – Deep Bedrock Zone (prepared by Woodard & Curran, 2015)

C-3

Figure C-3: Total VOC Concentrations – Shallow Bedrock, 1996 and 2015 (prepared by Woodard & Curran, 2015)

C-4

Figure C-4: Total VOC Concentrations - Deep Bedrock, 1996 and 2015 (prepared by Woodard and Curran, 2015)

C-5

Figure C-5: Time-Concentration Graphs for Select Wells

0

10,000

20,000

30,000

40,000

50,000

60,000

Feb‐89

Mar‐90

Apr‐91

May‐92

Jun‐93

Jul‐94

Aug‐95

Sep‐96

Oct‐97

Nov‐98

Dec‐99

Jan‐01

Feb‐02

Mar‐03

Apr‐04

May‐05

Jun‐06

Jul‐07

Aug‐08

Sep‐09

Oct‐10

Nov‐11

Dec‐12

Jan‐14

Feb‐15

TCE (µg/L)

Sample Date

PMW‐9A

Pump and treat begins Oct‐96

0

500

1,000

1,500

2,000

2,500

Feb‐89

Mar‐90

Apr‐91

May‐92

Jun‐93

Jul‐94

Aug‐95

Sep‐96

Oct‐97

Nov‐98

Dec‐99

Jan‐01

Feb‐02

Mar‐03

Apr‐04

May‐05

Jun‐06

Jul‐07

Aug‐08

Sep‐09

Oct‐10

Nov‐11

Dec‐12

Jan‐14

Feb‐15

TCE (µg/L)

Sample Date

PMW‐9B

Pump and treat begins Oct‐96

C-6

0

50

100

150

200

250

Oct‐90

Oct‐91

Oct‐92

Oct‐93

Oct‐94

Oct‐95

Oct‐96

Oct‐97

Oct‐98

Oct‐99

Oct‐00

Oct‐01

Oct‐02

Oct‐03

Oct‐04

Oct‐05

Oct‐06

Oct‐07

Oct‐08

Oct‐09

Oct‐10

Oct‐11

Oct‐12

Oct‐13

Oct‐14

TCE (µg/L)

Sample Date

PMW‐16B

C-7

Figure C-6: Capture Zone Shallow Bedrock (Source: Capture Zone Analysis, Cummings/Riter Consultants, Inc., October 2011)

C-8

Figure C-7: Capture Zone Deep Bedrock (Source: Capture Zone Analysis, Cummings/Riter Consultants, Inc., October 2011)

C-9

Figure C-8: Sub-slab Vapor and Indoor Air Sampling Locations (Source: Vapor Intrusion Report, Woodard & Curran, June 2015)

C-10

Table C-1: Summary of Mann-Kendall Trend Analysis (Source: Woodard & Curran, January 2016)

C-11

Table C-2: 1,4-Dioxanea in Select Wells

Sampling Location Aug 2011

Jun 2012 Dec 2012 Apr 2013

Oct 2013 Apr 2014

Nov 2014

Apr 2015

EPA RSLb

PA MSCc

On-Plant

PMW-1B 3.0 2.3 3.1 4 4.3 NA 4.5 2.8

0.46 6.4

PMW-2B NAd 0.32 0.24 0.31 <0.10 0.22 0.25 0.20/ 0.20e

PMW-5 NA 0.69 0.93 1.3 1.4 1.3 1.3 0.91

PMW-9A 150 220 250 410 370 270 380 280

PMW-9B NA 5.6 4.5 5.7 7.7 5 6.9 4.7

PMW-12A 0.23 NA NA NA NA NA NA NA

PMW-13B NA 0.20 0.24 0.25 <0.10 0.27 0.33 0.20

Off-Plant

PMW-14 0.89 0.71 0.79 0.91 1 0.93 0.96 0.59

PMW-20A NA <0.095 <0.095 <0.10 <0.10 <0.10 <0.10 <0.10

PMW-20B NA <0.097 <0.099 <0.10 <0.10/ <0.10

0.11/ <0.10

<0.10 <0.11

PMW-25 NA <0.096 <0.094/ <0.095

<0.10/ <0.10

<0.10 <0.10 <0.10 <0.11

Notes: a) Results reported in micrograms per liter (µg/L). b) EPA RSL available at http://www.epa.gov/risk/risk-based-screening-table-generic-tables, accessed December 21, 2015. c) PA MSC for used aquifer with total dissolved solids ≤ 2,500 from Table 1 of Appendix A of the PA Code Chapter 250, available at

http://www.pacode.com/secure/data/025/chapter250/chap250toc.html, accessed December 21, 2015. d) NA – Not applicable; no result reported. e) “--/--“ indicates primary/duplicate result. f) Bold result indicates detected value exceeds the EPA RSL. g) Italicized result indicates detected value exceeds the PA MSC.

C-12

Table C-3: Vapor Intrusion Data (Source: Vapor Intrusion Report, Woodard & Curran, June 2015)

C-13

Sample ID: USEPA IA-01 IA-02

Parameter (µg/m~1~ Date: RSL1"1 3/10/2015 3110/2015

Sile Related Volatile Organic Compounds

1, 1-Dichloroelhane 7.7 <0.811~ <0.81

1,2-Dictboethane 0.47 <0.81 <0.81

1, 1-0ictboethene 88 <0.79 <0.79

T etractloroelhene 18 < 1.4 < 1.4

cis-1,2-Dictloroelhene .. ~I <0.79 <0.79

trans-1,2-Dictloroethene .. <0.79 <0.79

1,4-Dioxane 2.5 < 1.8 < 1.8 1, 1, 1-Tnctloroethane 2,200 < 1.1 < 1.1

1, 1,2-Trictloroethane 0.088 < 1.1 < 1.1

T rictloroethene 0.88 < 1.1 < 1.1

\ilnyl Ctloride 2.8 <0.51 <0.51

Non-Site Related Volatile Organic Compound (Detections Only)

1.3-Butooieno 0.41 <0.88 <0.88

2-&Jtaoono 2,200 2.0 J 25

Acetone 14,000 15 24

Benzene 1.6 1.2 J 1.6J

Coo:.oo Oirullide 310 < 1.6 < 1.6

Ctlorodfluororrethano 22000 2.6 J 12

Ctlororrelhano 39 1.3 J 1.2 J 1,4-Dictloroberueno 1.1 < 1.2 < 1.2

Dichb-cxlmoororrelhano 44 3.3 J 2.8J

Eihybenzene 4.9 <0.87 0.90J

Hexane 310 <0.70 <0.70

Melhyleno Chbide 260 1.2 J 1.5J

Octane .. <0.93 <0.93

Pentano 440 1.4 J 1.4 J

Toluene 2,200 1.9 J 2.0J

m'p-Xylene 44 <0.87 2.5J

o-Xylene 44 <0.87 1.1 J

T rictlorofluororrelhane 310 13 5.6J

1,2,4-Trimelhylboozene 3.1 <0.98 <0.98

NOTES: 1,1 Uri! atbeviatioos are as folows:

"µ111TI" is microc,-ams per ctbic meter of ai".

TABLE 2 INDOOR AJR / AMBIENT AJR ANALYTICAL RESULTS • MARCH 2015

ANALYTICAL METHOD USEPA T0-15 ELEVATOR PLANT SITE

GETIYSBURG, ADAMS COUNTY, PENNSYLVANIA

IA-03 IA-04 IA-05 IA-06 IA-07

3110/2015 3110/2015 3110/2015 3111/2015 3111/2015

<0.81 <0.81 < 0.81 < 0.81 <0.81 <0.81 <0.81 < 0.81 < 0.81 <0.81

<0.79 <0.79 < 0.79 < 0.79 <0.79

< 1.4 < 1.4 < 1.4 < 1.4 < 1.4

<0.79 <0.79 < 0.79 < 0.79 <0.79

<0.79 <0.79 < 0.79 < 0.79 <0.79

< 1.8 < 1.8 < 1.8 < 1.8 < 1.8 < 1.1 < 1.1 < 1.1 < 1.1 < 1.1

< 1.1 < 1.1 < 1.1 < 1.1 < 1.1

< 1.1 < 1.1 < 1.1 < 1.1 < 1.1 <0.51 <0.51 < 0.51 < 0.51 <0.51

1.2JI~ <0.88 < 0.88 < 0.88 <0.88

4.0J 7.9 6.5 3.5 J 5.0J

14 35 36 22 34

1.7 J 1.0 J 0.97 J 1.4 J 1.4J

< 1.6 < 1.6 < 1.6 2.0 J < 1.6

2.2J 2.0J 2.0J 2.3 J 1.4J

1.2J 0.97 J 1.4J 1.4 J 1.1 J < 1.2 < 1.2 < 1.2 < 1.2 < 1.2

3.0J 2.4J 2.8J 3.1 J 3.0J

9.5 < 0.87 < 0.87 1.2 J <0.87

0.86J <0.70 0.88J < 0.70 <0.70 <0.69 <0.69 < 0.69 0.72 J 0.78J

3.8J <0.93 < 0.93 < 0.93 <0.93

1.3J 1.1 J 1.5J 1.5 J 0.99J

3.5J 2.0J 1.2J 2.8J 1.1 J

35 0.88 J < 0.87 3.5 J <0.87

23 < 0.87 < 0.87 2.0 J <0.87

6.7 8.7 6.4 7.2 2.0J

1.1 J <0.98 < 0.98 < 0.98 <0.98

IA-08 IA-09 IA-10 IA-111'1 Ambient-1

3111/2015 3111/2015 3/11/2015 3110/2015 3110/2015

< 0.81 / < 0.81!0 <0.81 <0.81 <0.81 <0.81 / <0.81 <0.81 / < 0.81 <0.81 <0.81 <0.81 <0.81 / <0.81

<0.79 / < 0.79 <0.79 < 0.79 <0.79 <0.79/ <0.79

< 1.4/ < 1.4 < 1.4 < 1.4 < 1.4 < 1.4/ < 1.4

<0.79 / 0.88 J <0.79 2.0 J 1.6J <0.79/ <0.79

<0.79 / < 0.79 <0.79 <0.79 <0.79 <0.79/ <0.79

< 1.8 / < 1.8 < 1.8 < 1.8 < 1.8 < 1.8/ < 1.8 < 1.1 / < 1.1 < 1.1 < 1.1 < 1.1 < 1.1 / < 1.1

< 1.1 / < 1.1 < 1.1 < 1.1 < 1.1 < 1.1/ < 1.1

< 1.1 / < 1.1 < 1.1 21 J 1.3J <1.1 / < 1.1 <0.51 / < 0.51 <0.51 <0.51 <0.51 <0.51 / <0.51

< 0.88/ < 0.88 <0.88 <0.88 <0.88 <0.88 / <0.88

3.8J / 4.2J < 1.5 3.4 J 4.0J 5.5J/ 3.8J

16 / 20 4.0J 1~ 22 37 / 19

1.2J / 1.2 J <0.64 1.8 J 1.3J 1.5J / 1.5 J

5.6 / < 1.6 < 1.6 1.6 J < 1.6 < 1.6/ < 1.6

2.6J / 2.4J <0.71 2.4 J 9.3 1.5J / 1.5J

1.2 J / 1.1 J <0.41 1.3 J 1.2J 1.1 J / 1.2J < 1.2 / < 1.2 1.6J 1.7 J < 1.2 <1.2/ < 1.2

<0.84 / 3.1 J <0.99 3.1 J 3.2J 3.1 J / <0.84

< 0.87 / < 0.87 <0.87 2.7 J < 0.87 < 0.87 / < 0.87

<0.70/ <0.70 <0.70 <0.70 <0.70 < 0.70/ < 0.70 <0.69 / 0.72J <0.69 <0.69 0.78J < 0.69 / < 0.69

< 0.93 / < 0.93 <0.93 1.6 J <0.93 < 0.93 / < 0.93

0.86J / 1.1 J <0.59 1.1 J 1.0J 1.0J / 1.0J

0.94J 1.1J <0.75 2.4 J 1.1 J 1.3J / 1.5J < 0.87 / < 0.87 <0.87 7.6 < 0.87 0.93J/ 2.2J

< 0.87 / < 0.87 <0.87 3.6 J < 0.87 <0.87/ 1.2J

1.4J / 1.6J < 1.1 1.7 J 1.8J 1.5J / 1.5J < 0.98 / < 0.98 <0.98 <0.98 <0.98 <0.98/ <0.98

~ Reruns were corrpared to Urited States Envimmental Frotection Agercy (US EPA) Regiooal Screenilg Level (RSL) for lnciJstrial Air with a T..-get Risk for Carcilogens (TRC) of 1.00E-06 and a T..-get Hazard ()Jooent for Noo-Carcirogens (THO) of 0. 1 (J;nay 2015). 1'1 • •. • irdcates lhat an USE PA RSI. has oot )91 been estabished for Iha selocted corrpoo.m. 111 "<'( nci:ates Iha rest.it is less lhan lhe meth:,d detedoo i mit, ·x·. 111 Bold values irdcate an exceedance ol Iha correspooclrg US EPA RSL

II ·x / x· ilclcates lhat a dupicate sarrpe was oolocted at llis locaticn

(g) Sample IA-11 was oolocted from Iha socood floor of the of lice area

C-16

Table C-4: Groundwater Analytical Results for SVMW-1 and SVMW-2

C-17

Well l.D.:

Parameter (µgn) 1'1 Target Groundwater 10/31/11 3/27/12

Concentrations ~1

Benzene 2.4 < 0.5 < 0.5 Bromodichloromethane 1.4 < 0.5 < 0.5 Bromoform 210 < 0.5 < 0.5 Bromomethane 2.3 < 0.5 < 0.5 Carbon Tetrachloride 0.63 < 0.5 < 0.5 Chlorobenzene 69 < 0.5 < 0.5 Chloroethane 3,100 < 0.5 < 0.5 Chloroform 1.2 < 0.5 < 0.5 Chloromethane 33 < 0.5 < 0.5 Dibromochloromethane 4.6 < 0.5 < 0.5 1, 1-Dichloroethane 11 < 0.5 < 0.5 1,2-Dichloroethane 3.5 < 0.5 < 0.5 1, 1-Dichloroethene 27 2.1 1.5 cis -1,2-Dichloroethene 1,1 .. < 0.5 < 0.6 trans -1,2-Dichloroethene - 0.8 < 0.5 1,2-Dichloropropane 3.8 < 0.5 < 0.5 cis -1,3-Dichloropropene 7_9 1•1 < 0.5 < 0.5

trans -1,3-Dichloropropene 7_9 1•1 < 0.5 < 0.5 Ethyl benzene 6.0 < 0.5 < 0.5 Methylene Chloride 680 < 0.5 < 0.5 Styrene 1,600 < 0.5 < 0.5 1, 1,2,2-Tetrachloroethane 5.6 < 0.5 < 0.5 Tetrachloroethene 9.6 2.5 < 0.5 Toluene 3,100 < 0.5 < 0.5 1,1, 1-Tnchloroethane 1,100 < 0.5 < 0.5 1, 1,2-Tnchloroethane 1.0 < 0.5 < 0.5

Tnchloroethene 0.81 4.5 3.8 Vinyl Chloride 0.19 < 0.5 < 0.5

m& J>-Xylene 61 l•I < 0.5 < 0.5 o-Xvlene 85 < 0.5 < 0.5

SUMMARY OF GROUNDWATER ANALYTICAL RESULTS VAPOR INTRUSION TO INDOOR AJR ASSESSMENT WELLS

ELEVATOR PLANT SITE GETTYSBURG, PENNSYLVANIA

SVMW-1 (continued)

6/19/12 12/11/12 4/9/13 10/16/13 11/11/14 4/28/15 3/3/05 617/05

<0.5 < 0.5 < 0.5 <0.5 < 0.5 < 0.5 < 0.5 < 0.5 <0.5 < 0.5 < 0.5 <0.5 < 0.5 < 0.5 < 0.5 < 0.5 <0.5 < 0.5 < 0.5 <0.5 < 0.5 < 0.5 < 0.5 < 0.5 <0.5 < 0.5 < 0.5 <0.5 < 0.5 < 0.5 < 0.5 < 0.5 <0.5 < 0.5 < 0.5 <0.5 < 0.5 < 0.5 < 0.5 < 0.5 <0.5 < 0.5 < 0.5 <0.5 < 0.5 < 0.5 < 0.5 < 0.5 <0.5 < 0.5 < 0.5 <0.5 < 0.5 < 0.5 < 0.5 < 0.5 <0.5 < 0.5 < 0.5 <0.5 < 0.5 < 0.5 < 0.5 < 0.5 <0.5 < 0.5 < 0.5 <0.5 < 0.5 < 0.5 < 0.5 < 0.5 <0.5 < 0.5 < 0.5 <0.5 < 0.5 < 0.5 < 0.5 < 0.5 <0.5 < 0.5 < 0.5 <0.5 < 0.5 < 0.5 < 0.5 < 0.5 <0.5 < 0.5 < 0.5 <0.5 < 0.5 < 0.5 < 0.5 < 0.5 2.1 2.1 2.4 1.8 1.7 1.9 < 0.5 < 0.5

< 0.5 < 0.5 0.7 <0.5 <0.5 < 0.5 <0.5 < 0.5 <0.5 0.5 2.7 <0.5 < 0.5 < 0.5 < 0.5 < 0.5 <0.5 < 0.5 < 0.5 <0.5 < 0.5 < 0.5 < 0.5 < 0.5

< 0.5 < 0.5 < 0.5 <0.5 <0.5 < 0.5 <0.5 < 0.5

< 0.5 < 0.5 <0.5 < 0.5 <0.5 < 0.5 <0.5 < 0.5 <0.5 < 0.5 < 0.5 <0.5 < 0.5 < 0.5 < 0.5 < 0.5 <0.5 < 0.5 < 0.5 <0.5 < 0.5 < 0.5 < 0.5 < 0.5 <0.5 < 0.5 < 0.5 <0.5 < 0.5 < 0.5 < 0.5 < 0.5 <0.5 < 0.5 < 0.5 <0.5 < 0.5 < 0.5 < 0.5 < 0.5 <0.5 < 0.5 < 0.5 <0.5 < 0.5 < 0.5 < 0.5 < 0.5 <0.5 < 0.5 < 0.5 <0.5 < 0.5 < 0.5 < 0.5 < 0.5 <0.5 < 0.5 < 0.5 <0.5 < 0.5 < 0.5 < 0.5 < 0.5 <0.5 < 0.5 < 0.5 <0.5 < 0.5 < 0.5 < 0.5 < 0.5

3.4 3.7 1 4.1 3.8 2.3 < 0.5 2.7 <0.5 < 0.5 < 0.5 <0.5 < 0.5 < 0.5 < 0.5 < 0.5

< 0.5 < 0.5 < 0.5 < 0.5 <0.5 < 0.5 <0.5 < 0.5 <0.5 < 0.5 < 0.5 <0.5 < 0.5 < 0.5 < 0.5 < 0.5

SVMW-2

8/26/05 5/23/06 8116/06 10/17/06 2/22/07 513/07 818/07 11/1/07

< 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 0.7 < 0.5 1 0.9 < 0.5 < 0.5 1.4 0.7

< 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 0.8 0.5 1 1.0 < 0.5 < 0.5 1.8 0.9 0.6 < 0.5 0.7 0.8 < 0.5 < 0.5 1.1 0.6 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5

< 0.5 < 0.5 < 0.5 <0.5 < 0.5 < 0.5 < 0.5 < 0.5

< 0.5 < 0.5 < 0.5 <0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 0.8 0.6 1.1 1.0 < 0.5 < 0.5 1.6 1.0

< 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5

12 7.4 16 18 5.3 2.6 21 11 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5

< 0.5 < 0.5 < 0.5 <0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5

D-1

Appendix D: Site Inspection Checklist

FIVE-YEAR REVIEW SITE INSPECTION CHECKLIST

I. SITE INFORMATION

Site Name: Westinghouse Elevator Co. Plant Date of Inspection: 10/29/2015

Location and Region: Cumberland Township, PA/Region 3

EPA ID: PAD043882281

Agency, Office or Company Leading the Five-Year Review: EPA Region 3

Weather/Temperature: Cloudy/Low 60s

Remedy Includes: (Check all that apply) Landfill cover/containment Monitored natural attenuation Access controls Ground water containment Institutional controls Vertical barrier walls Ground water pump and treatment Surface water collection and treatment Other:

Attachments: Inspection team roster attached Site map attached (See Figure 2 of FYR)

II. INTERVIEWS (check all that apply)

1. O&M Site Manager Name

Title

Date

Interviewed at site at office by phone Phone: Problems, suggestions Report attached:

2. O&M Staff Name

Title

Date

Interviewed at site at office by phone Phone: Problems/suggestions Report attached:

3. Local Regulatory Authorities and Response Agencies (i.e., state and tribal offices, emergency response office, police department, office of public health or environmental health, zoning office, recorder of deeds, or other city and county offices). Fill in all that apply.

Agency Cumberland Township Contact Ben Thomas, Jr.

Name Twp. Manager Title

10/29/15 Date

717-334-6484 Phone No.

Problems/suggestions Report attached: FYR to provide summary Agency Cumberland Township Contact Bill Naugle

Name Zoning/Code Enforcement Officer Title

10/29/15 Date

717-334-6484 Phone No.

Problems/suggestions Report attached: FYR to provide summary Agency Adams County Contact Albert Penksa

Name County Manager Title

10/29/15 Date

717-337-9820 Phone No.

Problems/suggestions Report attached: FYR to provide summary

D-2

Agency Contact

Name Title

Date

Phone No.

Problems/suggestions Report attached: Agency Contact

Name Title

Date

Phone No.

Problems/suggestions Report attached:

4. Other Interviews (optional) Report attached:

III. ON-SITE DOCUMENTS AND RECORDS VERIFIED (check all that apply)

1. O&M Documents

O&M manual Readily available Up to date N/A

As-built drawings Readily available Up to date N/A

Maintenance logs Readily available Up to date N/A

Remarks:

2. Site-Specific Health and Safety Plan Readily available Up to date N/A

Contingency plan/emergency response plan

Readily available Up to date N/A

Remarks:

3. O&M and OSHA Training Records Readily available Up to date N/A

Remarks:

4. Permits and Service Agreements

Air discharge permit Readily available Up to date N/A

Effluent discharge Readily available Up to date N/A

Waste disposal, POTW Readily available Up to date N/A

Other permits: Readily available Up to date N/A

Remarks:

5. Gas Generation Records Readily available Up to date N/A

Remarks:

6. Settlement Monument Records Readily available Up to date N/A

Remarks:

7. Ground Water Monitoring Records Readily available Up to date N/A

Remarks:

8. Leachate Extraction Records Readily available Up to date N/A

Remarks:

D-3

9. Discharge Compliance Records

Air Readily available Up to date N/A

Water (effluent) Readily available Up to date N/A

Remarks:

10. Daily Access/Security Logs Readily available Up to date N/A

Remarks:

IV. O&M COSTS

1. O&M Organization

State in-house Contractor for state

PRP in-house Contractor for PRP

Federal facility in-house Contractor for Federal facility

2. O&M Cost Records

Readily available Up to date

Funding mechanism/agreement in place Unavailable

Original O&M cost estimate: $140,000 Breakdown attached

Total annual cost by year for review period if available

From: 01/01/2011

Date

To: 12/31/2011

Date

$138,000

Total cost

Breakdown attached

From: 01/01/2012

Date

To: 12/31/2012

Date

$82,000

Total cost

Breakdown attached

From: 01/01/2013

Date

To: 12/31/2013

Date

$116,000

Total cost

Breakdown attached

From: 01/01/2014

Date

To: 12/31/2014

Date

$95,000

Total cost

Breakdown attached

From: 01/01/2015

Date

To: 12/31/2015

Date

$170,000

Total cost

Breakdown attached

3. Unanticipated or Unusually High O&M Costs during Review Period

Describe costs and reasons: Additional 2015 costs associated with vapor intrusion study

V. ACCESS AND INSTITUTIONAL CONTROLS Applicable N/A

A. Fencing

1. Fencing Damaged Location shown on site map Gates secured N/A

Remarks: Fencing/gate restricts access to on-site treatment building

D-4

B. Other Access Restrictions

1. Signs and Other Security Measures Location shown on site map N/A

Remarks:

C. Institutional Controls (ICs)

1. Implementation and Enforcement

Site conditions imply ICs not properly implemented Yes No N/A

Site conditions imply ICs not being fully enforced Yes No N/A

Type of monitoring (e.g., self-reporting, drive by): self-reporting

Frequency: during regular site visits for O&M and groundwater sampling

Responsible party/agency: PRP

Contact

Name Title Date Phone no.

Reporting is up to date Yes No N/A

Reports are verified by the lead agency Yes No N/A

Specific requirements in deed or decision documents have been met Yes No N/A

Violations have been reported Yes No N/A

Other problems or suggestions: Report attached

2. Adequacy ICs are adequate ICs are inadequate N/A

Remarks:

D. General

1. Vandalism/Trespassing Location shown on site map No vandalism evident

Remarks:

2. Land Use Changes On Site N/A

Remarks: CBS Corporation (formerly Westinghouse) recently sold the elevator Plant property to Logistics Resource, LLC, operated by Moran Industries, a logistics provider. The Plant is undergoing some improvements and end use is unknown at this time. The Plant building is not currently occupied.

3. Land Use Changes Off Site N/A

Remarks: The Herff Jones property, where the off-Plant groundwater treatment building is located, was sold to Adams County on October 30, 2015. The building will be renovated and used for county offices. Other residential development is taking place in areas east of the Westinghouse Elevator Co. Plant site.

VI. GENERAL SITE CONDITIONS

A. Roads Applicable N/A

1. Roads Damaged Location shown on site map Roads adequate N/A

Remarks:

B. Other Site Conditions

Remarks:

D-5

VII. LANDFILL COVERS Applicable N/A

A. Landfill Surface

1. Settlement (low spots) Location shown on site map Settlement not evident

Arial extent: Depth:

Remarks:

2. Cracks Location shown on site map Cracking not evident

Lengths: Widths: Depths:

Remarks:

3. Erosion Location shown on site map Erosion not evident


Remarks:

4. Holes Location shown on site map Holes not evident


Remarks:

5. Vegetative Cover Grass Cover properly established

No signs of stress Trees/shrubs (indicate size and locations on a diagram)

Remarks:

6. Alternative Cover (e.g., armored rock, concrete) N/A

Remarks:

7. Bulges Location shown on site map Bulges not evident

Arial extent: Height:

Remarks:

8. Wet Areas/Water Damage

Wet areas/water damage not evident

Wet areas Location shown on site map Arial extent:

Ponding Location shown on site map Arial extent:

Seeps Location shown on site map Arial extent:

Soft subgrade Location shown on site map Arial extent:

Remarks:

9. Slope Instability Slides Location shown on site map

No evidence of slope instability

Arial extent:

Remarks:

B. Benches Applicable N/A

(Horizontally constructed mounds of earth placed across a steep landfill side slope to interrupt the slope in

D-6

order to slow down the velocity of surface runoff and intercept and convey the runoff to a lined channel.)

1. Flows Bypass Bench Location shown on site map N/A or okay

Remarks:

2. Bench Breached Location shown on site map N/A or okay

Remarks:

3. Bench Overtopped Location shown on site map N/A or okay

Remarks:

C. Letdown Channels Applicable N/A

(Channel lined with erosion control mats, riprap, grout bags or gabions that descend down the steep side slope of the cover and will allow the runoff water collected by the benches to move off of the landfill cover without creating erosion gullies.)

1. Settlement (Low spots) Location shown on site map No evidence of settlement


Remarks:

2. Material Degradation Location shown on site map No evidence of degradation

Material type: Arial extent:

Remarks:

3. Erosion Location shown on site map No evidence of erosion


Remarks:

4. Undercutting Location shown on site map No evidence of undercutting


Remarks:

5. Obstructions Type: No obstructions

Location shown on site map Arial extent:

Size:

Remarks:

6. Excessive Vegetative Growth Type:

No evidence of excessive growth

Vegetation in channels does not obstruct flow

Location shown on site map Arial extent:

Remarks:

D. Cover Penetrations Applicable N/A

1. Gas Vents Active Passive

Properly secured/locked Functioning Routinely sampled Good condition

D-7

Evidence of leakage at penetration Needs maintenance N/A

Remarks:

2. Gas Monitoring Probes



Remarks:

3. Monitoring Wells (within surface area of landfill)



Remarks:

4. Extraction Wells Leachate



Remarks:

5. Settlement Monuments Located Routinely surveyed N/A

Remarks:

E. Gas Collection and Treatment Applicable N/A

1. Gas Treatment Facilities

Flaring Thermal destruction Collection for reuse

Good condition Needs maintenance

Remarks:

2. Gas Collection Wells, Manifolds and Piping


Remarks:

3. Gas Monitoring Facilities (e.g., gas monitoring of adjacent homes or buildings)

Good condition Needs maintenance N/A

Remarks:

F. Cover Drainage Layer Applicable N/A

1. Outlet Pipes Inspected Functioning N/A

Remarks:

2. Outlet Rock Inspected Functioning N/A

Remarks:

G. Detention/Sedimentation Ponds Applicable N/A

1. Siltation Area extent: Depth: N/A

Siltation not evident

D-8

Remarks:

2. Erosion Area extent: Depth:

Erosion not evident

Remarks:

3. Outlet Works Functioning N/A

Remarks:

4. Dam Functioning N/A

Remarks:

H. Retaining Walls Applicable N/A

1. Deformations Location shown on site map Deformation not evident

Horizontal displacement: Vertical displacement:

Rotational displacement:

Remarks:

2. Degradation Location shown on site map Degradation not evident

Remarks:

I. Perimeter Ditches/Off-Site Discharge Applicable N/A

1. Siltation Location shown on site map Siltation not evident

Area extent: Depth:

Remarks:

2. Vegetative Growth Location shown on site map N/A

Vegetation does not impede flow

Area extent: Type:

Remarks:

3. Erosion Location shown on site map Erosion not evident

Area extent: Depth:

Remarks:

4. Discharge Structure Functioning N/A

Remarks:

VIII. VERTICAL BARRIER WALLS Applicable N/A

1. Settlement Location shown on site map Settlement not evident

Area extent: Depth:

Remarks:

2. Performance Monitoring Type of monitoring:

Performance not monitored

Frequency: Evidence of breaching

D-9

Head differential:

Remarks:

IX. GROUND WATER/SURFACE WATER REMEDIES Applicable N/A

A. Ground Water Extraction Wells, Pumps and Pipelines Applicable N/A

1. Pumps, Wellhead Plumbing and Electrical

Good condition All required wells properly operating Needs maintenance N/A

Remarks:

2. Extraction System Pipelines, Valves, Valve Boxes and Other Appurtenances


Remarks:

3. Spare Parts and Equipment

Readily available Good condition

Requires upgrade Needs to be provided

Remarks:

B. Surface Water Collection Structures, Pumps and Pipelines Applicable N/A

1. Collection Structures, Pumps and Electrical


Remarks:

2. Surface Water Collection System Pipelines, Valves, Valve Boxes and Other Appurtenances


Remarks:

3. Spare Parts and Equipment

Readily available Good condition

Requires upgrade Needs to be provided

Remarks:

C. Treatment System Applicable N/A

1. Treatment Train (check components that apply)

Metals removal Oil/water separation Bioremediation

Air stripping Carbon adsorbers

Filters:

Additive (e.g., chelation agent, flocculent):

Others:


Sampling ports properly marked and functional

Sampling/maintenance log displayed and up to date

D-10

Equipment properly identified

Quantity of ground water treated annually: Between 3.4 and 4.2 million gallons

Quantity of surface water treated annually:

Remarks:

2. Electrical Enclosures and Panels (properly rated and functional)

N/A Good condition

Needs maintenance

Remarks: Electricity for treatment Plant recently separated from the main Plant building (due to sale of the property)

3. Tanks, Vaults, Storage Vessels

N/A Good condition

Proper secondary containment Needs maintenance

Remarks:

4. Discharge Structure and Appurtenances

N/A Good condition

Needs maintenance

Remarks: Did not view discharge point of effluent

5. Treatment Building(s)

N/A Good condition (esp. roof and doorways)

Needs repair

Chemicals and equipment properly stored

Remarks: Should consider raising the height of the exterior vent on the northern wall of the treatment building to avoid the possibility of snow cover

6. Monitoring Wells (pump and treatment remedy)

Properly secured/locked Functioning

Routinely sampled Good condition

All required wells located Needs maintenance N/A

Remarks: Two wells were found unsecured during the site visit. One of the unsecured wells (PMW-13) will require a repair of the hinged cover.

D. Monitoring Data

1. Monitoring Data

Is routinely submitted on time Is of acceptable quality

2. Monitoring Data Suggests:

Ground water plume is effectively contained*

*There are some off-Plant areas where COC concentrations exceed MCLs or other screening criteria.

Contaminant concentrations are declining*

E. Monitored Natural Attenuation

D-11

1. Monitoring Wells (natural attenuation remedy)


All required wells located Needs maintenance N/A

Remarks:

X. OTHER REMEDIES If there are remedies applied at the site and not covered above, attach an inspection sheet describing the physical nature and condition of any facility associated with the remedy. An example would be soil vapor extraction.

XI. OVERALL OBSERVATIONS A. Implementation of the Remedy

Describe issues and observations relating to whether the remedy is effective and functioning as designed. Begin with a brief statement of what the remedy is designed to accomplish (e.g., to contain contaminant plume, minimize infiltration and gas emissions). Based on available analytical data, the groundwater pump-and-treat system is functioning as designed. Highest contaminant concentrations are contained on site. The treatment system is effectively treating contaminated groundwater, with treated effluent meeting NPDES discharge criteria. The PRPs in a letter to USEPA dated November 20, 2015 indicated their plan to install a VI mitigation system for the Plant building. The potential for VI to indoor air of the on-site Plant building was recently evaluated. The PRP committed to install a VI mitigation system for the Plant. Institutional controls are in place to restrict groundwater use and maintain the integrity of the remedy.

B. Adequacy of O&M Describe issues and observations related to the implementation and scope of O&M procedures. In particular, discuss their relationship to the current and long-term protectiveness of the remedy. O&M activities appear adequate at this time. Recommendations for securing monitoring wells and potentially raising the height of an exterior vent along the treatment building will be included in the FYR.

C. Early Indicators of Potential Remedy Problems Describe issues and observations such as unexpected changes in the cost or scope of O&M or a high frequency of unscheduled repairs that suggest that the protectiveness of the remedy may be compromised in the future. There are no early indicators of potential remedy problems; however, VI pathways have been identified, a mitigation system needs to be installed or a further VI evaluation will need to be carried out depending on the future use of the Plant building

D. Opportunities for Optimization Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy. The off-site groundwater treatment Plant has not been used in about a decade because off-site contaminant concentrations are primarily below MCLs. Although Adams County, the new owner of the property on which the off-site treatment Plant is located, has not requested its removal, there is no indication that the off-Plant groundwater treatment system will be needed in the future,

Site Inspection Participants: Bhupi Khona, EPA RPM Asuquo Effiong, PADEP Doug Spicuzza, Woodard & Curran (contractor for CBS Corporation) Chris Kuzmkowski, Woodard & Curran Ryan Burdge, Skeo Solutions Jill Billus, Skeo Solutions

E-1

Appendix E: Site Inspection Photographs

View of the former manufacturing building, facing west

View of the church on an adjacent property, facing south

E-2

On-Plant groundwater treatment system building

Air stripper inside the on-Plant treatment system building

E-3

Interior of the on-Plant treatment system building

Exterior air intake of the on-Plant treatment system building

E-4

Unsecured monitoring well (PMW-13)

View of parking area in the northern portion of the Site, facing west

E-5

View of Wells PMW-12A and PMW-12B on the eastern portion of the Plant property, facing

Biglerville Road to the east

View of Wells PMW-25A and PMW-25B at the former Herff Jones property

E-6

Off-Plant treatment system building on the former Herff Jones property

Parking area of the former Herff Jones property

E-7

Northern tributary of Rock Creek near the off-Plant treatment system building

Off-Plant Extraction Well EW-6, not currently in operation