THIRD FIVE-YEAR REVIEW REPORT GEMS LANDFILL SUPERFUND SITE
GLOUCESTER TOWNSHIP, CAMDEN COUNTY, NEW JERSEY
Prepared by
U.S. Environmental Protection Agency Region 2
New York, New York
Date:
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Walter E. Mugdan, Director Emergency and Remedial Response Division
227572
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Table of Contents
Executive Summary i
Five-Year Review Summary Form ii
Introduction . 1
Site Chronology 1
Backg round . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 Physical Characteristics 1 Site Geology/Hydrogeology 1 Land and Resource Uses.... ..,.^..,.,.v.,v.).,w......w.v..v...,...w.w.....,.w„....... 2 History of . 2 Initial Response :.. 2 Basis for Taking Action ..,3
Remedial Actions 3 Remedy Selection 3 Remedy Implementation.....................................................J.,,..........s.... 4 System Operations/Operation and Maintenance ..5
Progress Since the Last Five-Year Review 6
Five-Year Review Process 7 Administrative Components ..........,.,....,.,.,.7 Community Involvement 7 Document Review !, 8 Data Review ! . . . .8 Site Inspection ,. 10 Interviews . 11
Technical Assessment , Question A: Is the remedy functioning as intended by the decision documents? 11 Question B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action objectives (RAOs) used at the time of the remedy selection still valid? 11 Question C: Has any other information come to light that could call into question the protectiveness of the remedy? .13 Technical Assessment Summary 13
Issues, Recommendations and Follow-Up Actions ..13
Protectiveness Statement. 15
Next Review 15
Tables Table 1 - Chronology of Site Events Table 2 - Data and Information Reviewed in Completing the Five-Year Review
Figures Figure 1 - Site Map Figure 2 - Monitoring Well Locations Figure 3 - VOCs in PM-13 Figure 4 - VOCs in PM-16 Figure 5 - Benzene in PM-19 Figure 6 - VOCs in 102AR Figure 7 - Benzene in PM-4
Executive Summary
This is the third five-year review for the GEMS Landfill Superfund site located in Gloucester Township, Camden County, New Jersey. The purpose of a five-year review is to evaluate the implementation and performance of a remedy in order to determine if the remedy is and will continue to be protective of human health and the environment and is functioning as intended by the decision documents. The triggering action for this policy five-year review is the second five-year review, which was issued in September 2009.
r '^ " _ -The site is being addressed as a single operable unit covered by the 1985 Record of Decision. The remedy has been constructed and is being operated, maintained and monitored in the long-term operation and maintenance phase.
Based oh this third five-year review, the remedy at the GEMS Landfill Site currently protects human health and the environment because there is no completed exposure pathway. However, in order for the remedy to be protective in the long-term, the groundwater plume must be contained. Additional measures are being investigated and will be designed and implemented, as needed, to ensure long-term protectiveness.
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Five-Year Review Summary Form
S I T E I D E N T I F I C A T I O N
Site Name: GEMS Landfill
EPA ID: NJD980529192
J Region: 2 State: NJ City/County: Gloucester Township, Camden County
NPL Status: Final
Multiple OUs? No
Has the site achieved construction completion? Yes
Lead agency: EPA If "Other Federal Agency" was selected above, enter Agency name: Click here to enter text
Author name (Federal or State Project Manager): Stephanie Sessoms-Midgett
Author affiliation: Remedial Project Manager, USEPA - Region 2
Review period: 09/2009 - 03/2014
Date of site inspection: September 12,2013
Type of review: Policy
Review number: 3
Triggering action date: 09/22/2009
Due date (fiveyears after triggering action date)'. 09/22/2014
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Five-Year Review Summary Form (continued)
Issues /Recommendat ions
OU(s) without Issues/Recommendations Identified in the Five-Year Review:
N/A
Issues and Recommendations Identified in the Five-Year Review:
OU(s): OU 01
>
Issue Category: Remedy Performance OU(s): OU 01
>
Issue: New information since the 2009 five-year review suggests that contaminated groundwater at the downgradient end of the plume is not being captured fully by the groundwater extraction system.
OU(s): OU 01
>
Recommendation Identify and implement additional action(s) to capture and treat contaminated groundwater at the downgradient end of the plume, which may include the installation of a horizontal well proposed by the PRPs, to ensure the long-term effectiveness of the remedy.
Affect Current Protectiveness
Affect Future Protectiveness
Implementing Party
Oversight Party
Milestone Date
No Yes PRP EPA 08/2015
OU(s): OU 01 Issue Category: Remedy Performance OU(s): OU 01
Issue: New information since the 2009 five-year review suggests that contaminated groundwater from the site may be flowing below the Holly Run underdrain and needs to be investigated.
OU(s): OU 01
Recommendation Investigate groundwater in the vicinity of the Holly Run underdrain and identify whether any modifications are needed to ensure the long-term effectiveness of the remedy.
Affect Current Protectiveness
Affect Future Protectiveness
Implementing Party
Oversight Party
Milestone Date
No ' Yes PRP EPA 08/2015 OU(s): OU 01 Issue Category: Remedy Performance OU(s): OU 01
Issue: The screening level ecological risk assessment indicated the need for a baseline ecological risk assessment at Holly Run and Briar Lake; contractor selection has been completed.
OU(s): OU 01
Recommendation: Perform a baseline ecological risk assessment for Holly Run and Briar Lake.
Affect Current Proteetiveness
Affect Future Proteetiveness
Implementing Party
Oversight Party
Milestone Date
No No PRP EPA 08/2015
OU(s): OU 01 Issue Category: Institutional Controls
Issue: There are no deed notices on the landfill property or on the five adjacent residential properties where components of the remedy are located and which are within the limits of the Classification Exception Area established for contaminated groundwater at the site.
Recommendation: Finalize deed notices and engage property owners for signature and filing.
Affect Current Proteetiveness
Affect Future Proteetiveness
Implementing Party
Oversight Party
Milestone Date
No Yes PRP State 08/2015 '
Si te-wide Protee t iveness Sta tement
Proteetiveness Determination: Addendum Due Date Short-term Protective (if applicable):
Click here to enter date.
Proteetiveness Statement: Based on this third five-year review, the remedy at the GEMS Landfill site currently protects human health and the environment because there is no completed exposure pathway. However, in order for the remedy to be protective in the long-term, the groundwater plume must be contained. Additional measures are being investigated and will be designed and implemented, as needed, to ensure long-term proteetiveness.
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x GEMS Landfill Superfund Site Gloucester Township, Camden County, New Jersey
Third Five-Year Review Report
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 is and will continue to be protective of human health and the environment and is functioning as intended by the decision documents. The methods, findings, and conclusions of reviews are documented in the FYR. In addition, FYR reports identify any issues found during the review and document recommendations to address them.
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This is the third five-year review for the GEMS Landfill site located in Gloucester Township, Camden County, New Jersey. This FYR was conducted by the United States Environmental Protection Agency < (EPA) Remedial Project Manager (RPM) Stephanie Sessoms-Midgett. The review was conducted in accordance with the Comprehensive Five-Year Review Guidance, OSWER Directive 9355.7-03B-P (June 2001). This report will become part of the site file.
The triggering action for this policy review is the completion date of the previous FYR (September 22, 2009). A five-year review is required at this site due to the fact that hazardous substances, pollutants or contaminants remain at the site above levels that allow for unlimited use and unrestricted exposure. The site consists of one operable unit and all components of the site remedy are addressed in this FYR.
Site Chronology
See Table 1 for the site chronology.
Background
Physical Characteristics
The GEMS Landfill site is an inactive landfill of approximately 60 acres in Gloucester Township, Camden County, New Jersey (see Figure 1). The landfill is roughly triangular in shape with an estimated volume of six million cubic yards. The landfill is situated on tax map Block 14003, Lot 26, with geographical coordinates of 39 degrees, 46 minutes, 48 seconds north and 75 degrees, 01 minutes, 15 seconds west. Holly Run, an intermittent stream to the north and east of the landfill, discharges to Briar Lake. The site is bounded by New Brooklyn Road (Erial Road) the north and east, Turnersville-Hickstown Road to the south and undeveloped land to the west.
Site Geology/Hydrogeology
The surficial aquifer beneath the site is the Kirkwood-Cohansey aquifer system, comprised of the Tertiary-age Cohansey Formation and the underlying Miocene-age Kirkwood Formation. The Kirkwood-Cohansey aquifer system is the predominant aquifer in the area, underlying approximately 3,000 square miles of the New Jersey Coastal Plain, a wedge-shaped mass of unconsolidated sediments of clay, silt, sand and gravel layers that can extend more than 1,000 feet deep. The underlying Wenonah-Mount Laurel aquifer is separated from the Kirkwood Formation by the Manasquan-Navasink aquitard.
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The groundwater of the Cohansey Formation extends to about 50 feet below ground surface. Geologic samples from well borings at the site indicate that the sands of the Cohansey generally decrease in grain size with depth, which tends to result in a higher permeability in the upper Cohansey than in the lower Cohansey. The Cohansey Formation is contaminated with organic and inorganic constituents. Groundwater in wells screened in the Kirkwood Formation in 2002 did not show any volatile organic compound (VOC) contamination. The underlying Wenonah-Mount Laurel aquifer was not affected.
Groundwater flow in the Cohansey Formation is predominantly to the northwest A secondary local component of flow is from the northeast part of the landfill towards the relocated Holly Run and associated marshy areas.
Land and Resource Uses
The landfill area is zoned industrial and is used solely for purposes of remediation. Holly Run and Briar Lake are used for recreation. The area surrounding the site is predominantly rural and residential. The closest residences are approximately 300 feet from the base of the landfill. Residential development is occurring in the area and is expected to continue in the future.
In 2007, the New Jersey Department of Environmental Protection (NJDEP) expanded the Classification Exception Area (CEA) for contaminated groundwater in the Kirkwood-Cohansey aquifer system beneath the site. The most recent CEA biennial certification monitoring report is dated July 2012. NJDEP is seeking to obtain deed notices for properties within the CEA (landfill and five adjacent properties) and the EPA has been assisting with this effort. Outside the CEA, the Mount Laurel-Wenonah aquifer system is used for public water supply.
Ecological resources include a federally-listed threatened plant species, swamp pink (Helonias bullata), which was discovered oh the site in 1994. The EPA coordinates with the U.S Fish and Wildlife Service regarding this resource.
History of Contamination
The GEMS Landfill has been owned by Gloucester Township from at least the late 1950s to the present. The landfill was operated by various parties as a disposal site for solid, liquid, and hazardous wastes and substances. Records indicate that a variety of industrial wastes including asbestos, solvents and Other materials were disposed of at the site between 1970 and 1979. In 1980, sludge from the City of Philadelphia's northeast wastewater treatment facility was disposed of at the site. Analyses of the sludge revealed the presence of pesticides. The landfill stopped accepting waste in 1980.
Initial Response / '
In 1980, NJDEP sampling confirmed that private water wells near the landfill, Holly Run and Briar Lake were contaminated by VOCs. Residents were urged to connect to public water supply systems. NJDEP also opposed installation of new wells within the affected area. In 1983, the EPA removed debris from the site and constructed a fence, two culverts and a berm. These response actions helped prevent residents from coming in contact with wastes in the area and controlled drainage from the site.
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The EPA proposed to add the site to the National Priorities List on December 30,1982. The site was placed on die NPL on September 8,1983.
Basis for Taking Action • / '
In October 1983, the EPA began a federally funded remedial investigation/feasibility study to characterize the site and evaluate clean-up alternatives. Four natural vents discharging the landfill gases were found to have significant concentrations ofVOCs including benzene, chlorobenzene and tetrachloroethene. Samples of leachate seep liquid and soils at the landfill were found to contain polycyclic aromatic hydrocarbons, including benzo-a-pyrene, as well as trace levels of the pesticides DDE, DDD and DDT. Groundwater samples collected in the Kirkwood-Cohansey aquifer system were shown to be contaminated with organics and inorganics. Surface water samples from Holly Run were contaminated with benzene, chlorobenzene, dichloroethane, acetone and xylene. Contaminants in Holly Run surface waters were found to be volatilizing into the ambient air, which showed gross organic vapor levels ranging from 10 to 40 parts per million. In 1985, the EPA performed a focused feasibility study to evaluate remedial action alternatives for contaminated groundwater impacting Holly Run.
In the July 1985 RI/FS report, cancer risks and noncancerous health hazards were evaluated under current and future site conditions. The risk assessment concluded that the following posed unacceptable risks:
• inhalation ofVOCs in ambient air; • inhalation of organic compounds in landfill gases (also fire and/or explosion hazard); • ingestion of benzene, 1,2-dichloroethane, 1,1,1-dichloroethene, acrylonitrile,
trichloroethylene chloroform and PCBs in groundwater, • ingestion, inhalation or dermal exposure to organics in surface water, sediment and
leachate; • ingestion of benzene, methylene chloride, chloroform, bis(2-chloroethyl)ether, bis(2-
ethylhexyl)phthalate, lead, arsenic, cadmium and chromium from Holly Run; and • ingestion of contaminated aquatic receptors in Holly Rim and Briar Lake.
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In addition, acute and chronic toxic effects to aquatic biota in Holly Run and Briar Lake were determined to be likely. ^
Remedial Actions
Remedy Selection , ' \ •
On September 27, 1985, the EPA issued a Record of Decision that selected the following remedial action components for the site:
- . a landfill cap consisting of a multimedia cover on the top of the landfill and a clay cap on the side slopes;
- an active gas collection and treatment system; - a groundwater extraction and pretreatment system to treat the entire site including the
contamination of Holly Run, with discharge to the publicly owned treatment works; - remediation of Holly Run and Briar Lake (i.e., sediment excavation);
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- surface water controls; - a monitoring program; - a security fence; - relocation and isolation of Holly Run; - connection of the potentially affected homes to the existing public water supply system; and
- - operation and maintenance to ensure the effectiveness of the remedy.
Remedial action objectives were not listed in the 1985 Record of Decision as is the EPA's current practice. Nonetheless, a review of the Record of Decision identified the following remedial action goals, which are considered the remedial action objectives for the site:
- prevent direct contact with, inhalation and ingestion of contaminants by humans and ecological receptors;
- stop the generation of leachate by preventing landfill waste from contacting groundwater; - eliminate surface water and sediment contamination in Holly Run and Briar Lake and prevent
recontamination by stopping contaminated groundwater from discharging into Holly Run and Briar Lake;
- stop the migration of the contaminant plume (plume containment); and - eliminate the uncontrolled release of VOCs to the atmosphere.
Remedy Implementation
The remedial action was divided into two phases. Phase I addressed all components of the Record of Decision except those related to the contaminated groundwater and leachate. In August 1988, the EPA issued a unilateral administrative order to a group of potentially responsible parties known as the GEMS Trustees for the remedial design/remedial action of the Phase I work. The Phase I remedial design was completed in December 1988. The Phase I work was constructed from 1989 to 1994. At the landfill, a galvanized chain-link fence with three-strand barbed wire and four locked gates was installed for security. The landfill was capped with two feet of clay, a 40-mil high density polyethylene (HDPE) liner, a one-foot drainage layer, 18 inches of soil cover and six inches of vegetated topsoil. The landfill gas collection and treatment system was installed with in-waste gas extraction wells, out-of-waSte perimeter wells, HDPE collection piping, condensate removal tank and traps and an enclosed gas flare system. At Holly Run and Briar Lake, contaminated sediments were excavated from both locations and Holly Rim was rerouted. The Holly Run uhderdrain, an 18-inch perforated corrugated HDPE pipe approximately 4,000 feet in length along the northeastern edge of the landfill, was installed below the water table to prevent contaminated groundwater from discharging into Holly Run and Briar Lake. Upstream of Briar Lake, culverts were reconstructed to correct drainage problems. A partial fence along Holly Run and Briar Lake was installed to restrict access to the surface water bodies. The EPA approved the remedial action completion report for Phase I in 1995.
Phase II of the remedial action addressed the contaminated groundwater and leachate components of the Record of Decision. In a Consent Decree signed with the EPA on June 30,1997, the GEMS trustees agreed to perform the remedial design/remedial action and pay past and future costs for cleaning up the site. The Phase II work was constructed from 1998 to 1999. The leachate collection system, comprised of a perimeter collection trench, manholes, pump stations and an underground double-walled steel storage tank, leads to the treatment system on the west side of the landfill. Treatment consists of pH adjustment, filtration, granular activated carbon treatment and solids
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removal followed by discharge to the Camden County Municipal Utilities Authority (CCMUA), the local publicly owned treatment works. The system is designed to treat up to 200 gallons per minute; Groundwater extraction wells Were installed at the downgradient edge of the landfill and extracted groundwater is pumped to the treatment facility. The EPA approved the remedial action completion report for Phase II in 2007.
In 1999, the EPA determined that remedy construction of Phase I and Phase II was complete and issued a Preliminary Site ClOse-Out Report. From 1999 to 2005, equipment for Solids removal Was Upgraded and issues were resolved related to discharge requirements and the publicly owned treatment works accepting treated water with low-levels of radionuclides. Representatives of the EPA, U.S. Army Corps of Engineers and NJDEP conducted a precertification inspection in July 2005. Also in July 2005, the EPA determined that the remedy was operational and functional. Since July 2005, the site has been in the long-term operation and maintenance phase.
System Operations/Operation and Maintenance
Phase I \ <
The GEMS Trustees are responsible for Phase I system operations/operation and maintenance in accordance with the Phase I Operation and Maintenance (O&M) Plan. In 2004-2005, the cap drainage system was improved with the installation of new downchutes, rehabilitation of diversion swales, construction of new berrns and installation of new subsurface drains. In 2006 and again in 2009, the discharge permit requirements were updated. In 2008, a vapor intrusion evaluation was completed, which indicated that the concentrations of VOCs, especially trichloroethylene and tetrachloroethylene, were below groundwater screening levels identified in the EPA's 2002 Draft Guidance for Evaluating the Vapor Intrusion to Indoor Air Pathway from Groundwater and Soils. Therefore, further evaluation of this pathway is not warranted. In 2009,15 new gas collection wells were installed in-waste to improve operation of the enclosed flare. In 2010, landfill cap repairs were conducted to remove water collecting on top of the cap and along the mid-slope swale and to regrade the mid-slope swales that experienced localized erosion. To prevent reoccurrence of the erosion, the Phase I O&M Plan was modified to add mowing and seeding of swales. In 2011, a new enclosed flare began operating.
Inspections occur on a regular basis to ensure that the perimeter security fence is maintained and that there are no issues with the landfill cap and landfill gas collection and treatment system.
A swamp pink monitoring plan was approved in 1997 and modified most recently in 2013 in consultation with U.S. Fish and Wildlife Service. Swamp pink parameters (number of rosettes, number of leaves per rosette, leaf length) are measured in June along transects in both study and reference locations, and wetland piezometers measure depth to groundwater. The monitoring results are reported annually, with the most recent report submitted in August 2013.
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Phase II - • ' . f ' ' '
The GEMS Trustees are responsible for Phase II system operation/operation and maintenance in accordance with the 1999 Phase II O&M Plan and the Industrial Discharge Permit issued by CCMUA.
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In 2006, the extraction well network was reduced from the initial eight wells to the four eastern extraction wells (EX-1, EX-2, EX-3, EX-4) at the request of U.S Fish and Wildlife Service to help preserve swamp pink habitat. In 2009, EW-3 and EW-4 were replaced with new extraction wells (20 foot off-set) due to encrustation that decreased well yield. Regular operation and maintenance includes methods to help maintain well yield in the extraction wells. A total of 62,3 million gallons of groundwater were removed and treated during the seventh year of operation and more than 360 million gallons since startup in July 2005.
The onsite groundwater and Jeachate pretreatment system is operated, maintained and monitored in accordance with the discharge permit requirements of the CCMUA. Effluent monitoring Water quality data (consisting of 24-hour composite samples, grab samples, and once per two week samples as well as continuous flow measurements) are submitted to CCMUA in monthly industrial discharge monitoring reports. The monthly reports are posted by the GEMS Trustees at http;//www. gemssuperfundsite.org. There have been no concentrations above any of the discharge parameters since operations began in July 2005. The CCMUA separately analyzes samples of the effluent and conducts annual inspections, and no deficiencies or violations have been identified.
Groundwater is monitored to the northeast of the landfill along the Holly Run underdrain to evaluate capture of the VOC-Contaminated groundwater so that it does not migrate under Holly Run. Groundwater also is monitored to the west of the landfill (sidegradient) and northwest (downgradient) to evaluate capture of the plume. The monitoring data are discussed in the Data Review section.
Progress Since Last Five-Year Review
The Second five-year review conducted in September 2009 contained the following protectiveness statements:
• The remedy at GEMS Landfill is expected to be or is protective of human health and the environment, and in the interim, exposure pathways that could result in unacceptable risks are being controlled.
• The assessment of the five-year review found that the remedy was constructed in accordance With the requirements of the Record of Decision. The remedy at the GEMS Landfill Superfund site is functioning as designed and has been fully implemented with the exception of the ongoing evaluation of the Holly Run and Briar Lake remediation, A few contaminants displayed elevated levels in sediment of Holly Run and Briar Lake. There is limited sediment available to the ecological community in Holly Run and Briar Lake and the elevated levels appear to be an isolated event and most likely do not represent an impact to the protectiveness of the site. The site is protective in the short term pending further evaluation of the data in the screening level ecological risk assessment. The remedy in the Record of Decision is protective of human health and the environment. Measures such as the landfill cap, fencing, use of public water supplies, and the Classification Exception Area have interrupted potential exposure pathways. The implementation of the groundwater remedy is functioning as intended and has also reduced potential exposures in Holly Run and Briar Lake.
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Recommendations identified in the September 2009 were as follows:
• Obtain NJDEP approval of the site deed notices and file with the township. • Perform Step 3 of the screening level ecological risk Assessment to evaluate the potential
ecological risk at Briar Lake and Holly Run.
The deed notices for the landfill and five adjacent properties have not been put in place as recommended in the last five-year review. The EPA is taking a more active role in helping the NJDEP and GEMS Trustees obtain the deed notices. This five-year review continues to recommend filing of the deed notices.
The screening level ecological risk assessment Was performed by the EPA in 2010. Based on December 2006 sediment samples from Holly Run and Briar Lake, the screening level ecological risk assessment concluded that a baseline ecological risk assessment should be performed to evaluate cadmium, iron and selenium in Holly Run and to evaluate cadmium, arsenic, iron, selenium and zinc in Briar Lake. The screening level risk assessment concluded that the onsite concentrations of these inorganics are consistent with background levels; however, data will be collected as part of the baseline ecological risk assessment to confirm that conclusion. In addition, the baseline ecological risk assessment will analyze samples using more sensitive detection limits to evaluate whether there is potential ecological risk from the organic constituents 2,4-dinitrophenol, 4-nitrophenol, hexachloropentadiene, 2-methylphenol and carbon disulfide, which were identified in the screening level risk assessment as having practical quantification limits above screening levels. Because these organics have not been identified in other media as being site-related and all samples Were reported as non-detect, they are considered unlikely to pose an unacceptable ecological risk; however, the baseline ecological risk assessment will collect additional data to confirm this. In June 2013, the EPA requested that the GEMS Trustees perform the baseline ecological risk assessment (steps 3 through 7) for Holly Run and Briar Lake. In August 2013, the GEMS Trustees informed the EPA in writing that they would perform the assessment. They have identified a contractor and the baseline ecological risk assessment is in development. This five-year review continues to identify potential ecological risk as an issue .and recommends completion of foe baseline ecological risk assessment.
Five-Year Review Process
Administrative Components
The five-year review team included Stephanie Sessoms-Midgett (EPA RPM), Michael Scorca (EPA Geologist), Marian Olsen (EPA Human Health Risk Assessor), Michael Clemetson (EPA Ecological Risk Assessor) and Natalie Loney (EPA Community Involvement Coordinator). This is a PRP-lead site.
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Community Involvement
The EPA Community Involvement Coordinator for the GEMS Landfill site, Natalie Loney, arranged to have an announcement published on the Gloucester Township's website (www.glotwp.com) on December 4,2013, notifying the community of foe initiation of the five-year review process. The notice indicated that upon completion of foe five-year review, the document Would be available to foe
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public at the project website, http://www.epa.gov/refflon02/superfimd/npl/0200627c.htmand at the site repository located as follows:
Gloucester Township Municipal Building 1261 Chews Landing Road (at Hider Lane)
Laurel Springs, New Jersey 08021.
The notice included the RPM's name, address and telephone number for questions related to the five-year review process of the GEMS Landfill Superfund site. The EPA will inform local public officials and the community of the results of this five-year review.
Document Review
The documents, data and information that were reviewed in completing this third five-year review are listed in Table 2.
Data Review
Groundwater Monitoring Groundwater monitoring has been conducted at the GEMS Landfill site since the 1980s. Groundwater monitoring is conducted on a semi-annual basis and reported annually. The monitoring well locations are shown in Figure 2.
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At the downgradient end of the plume (to the north and northwest of the landfill), monitoring wells PM-13 and PM-16 are screened in the lower Cohansey Formation. During the past five years, groundwater samples from these wells have shown elevated but declining concentrations from approximately 200 micrograms per liter (ug/L) to 100 ug/L of benzene, from approximately 950 ug/L to 50 ug/L of chlorobenzene and from approximately 1,300 ug/L to 50 Ug/L of xylene (Figures 3 and 4).
In 2013, groundwater samples from eight geoprobe borings downgradient of the extraction wells and performance monitoring wells indicated that VOCs and landfill-related parameters (chloride, sulfate, ammonia, total dissolved solids, chemical oxygen demand and total organic carbon) are present in the lower Cohansey about 40 feet below ground surface. Groundwater at one location, CEG-6, also had high concentrations in shallower intervals. These observations show that contamination in the lower Cohansey is not being fully captured by the groundwater extraction well network. The GEMS Trustees have proposed installation of a horizontal well, the addition of which is expected to result in full capture of the contaminated groundwater at the downgradient end of the plume.
Groundwater samples from well PM-19, which is located to the northeast of the landfill but on the far side of Holly Run underdrain and is screened in the upper Cohansey Formation, also has shown elevated but declining concentrations of benzene, ranging from approximately 60 ug/L to 45 ug/L (Figure 5). However, in the same well cluster at PM-19 on the far side of Holly Rim but screened in the lower Cohansey, monitoring well 102 AR has shown increasing concentrations of benzene, ranging from approximately 25 ug/L to 50 ug/L, while concentrations of 1,2-dichlorethane and methylene chloride have been decreasing from approximately 10 ug/L to 1 ug/L and approximately 3 ug/L to 2 Ug/L respectively (Figure 6).
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The groundwater data from wells PM-16 and 102AR suggest a potential for contaminated groundwater in the lower Cohansey to flow beneath the Holly Run underdrain. The effectiveness of the Holly Run underdrain in capturing contaminated groundwater in the lower Cohansey is not folly understood and is being further examined.
I To the west of the landfill, monitoring well PM-4 is screened in the lower Cohansey. It has shown generally declining concentrations of benzene in foe approximately 2.5 ug/L to 1.5 ug/L range, slightly elevated compared to the NJGWQC of 1 ug/L.
Levels of arsenic above foe NJGWQC of 3 ug/L have been observed in the upper Cohansey at well PM-19, but concentrations have shown a decline during the last five years. In the Iowa- Cohansey, elevated arsenic levels were observed at wells PM-13, PM-16, and 102AR. Wells PM-3 and 102AR are located within the capture zone and well PM-16 is located outside of the capture zone. Other common inorganic landfill-leachate related parameters were observed at varying concentrations in samples from the full site-wide sampling network including iron, aluminum, sodium and manganese as well as sporadic detections ofberyllium, thallium* barium, cadmium, chromium and lead.
Treatment System Flow Rates The pumping rates of the four operating extraction wells have decreased with time (possibly due to encrustration) to a combined flow of less than 8 gallons per minute, which is well below the design rate, thereby reducing the effectiveness of the remedy. Regular operation and maintenance includes methods to maintain well yield. In addition, the GEMS Trustees have proposed to install a horizontal well as an option to mitigate fouling on a more permanent basis.
The flow rate from the Holly Run underdrain is over 100 gallons per minute and is designed to intercept shallow groundwater in the upper Cohansey at the northeast Side of the landfill.
Surface Water/Sediment No surface or sediment monitoring is required under the O&M plans. The last sampling was conducted in 2006 and those data were used in performing the 2010 screening level ecological risk assessment. The need for any monitoring of surface water or sediment in Holly Run or Briar Lake will be evaluated after completion of the baseline ecological risk assessment.
Swamn Pink In 2010, sampling revealed some of the best sampling measurements obtained from the Colony III and Campus swamp pink colonies, with nearly 70% of the plants determined to be in good health at Colony III and 60% of the plants in good health at Campus (reference area). However, by the spring of 2013, these numbers were reduced to approximately 30% and 20% respectively. It should be noted that the Campus reference area has experienced greater volatility in the health of the individual plants on a year to year basis.
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Sampling of the herbaceous layer has not revealed any clear trends in comparing the Campus and Colony III areas. Sampling completed during the 2012-2013 sampling season indicated a slightly more dense coverage at the Campus reference area. However, foe previous four years were split evenly between foe two locations with Colony III having more dense coverage in 2008-2009 and 2011-2012. During this period, annual percent cover of swamp pink has remained slightly higher at foe Campus reference area.
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Sampling during the last five years of the woody species comprising the shrub layer, however, has indicated greater density at Campus reference area throughout the period. Sampling in June 2012 indicated 92.8% shrub layer coverage at Campus, as opposed to 66.9% coverage at Colony III. Piezometer monitoring has indicated that water level observations at both locations continue to be stable and quite similar to the measurements obtained during baseline sampling. While there are some fluctuations at each piezometer, the maximum changes in the wetlands were much less than the transitions and upland zones, which showed distinct seasonal patterns.
The Consent Decree stipulated that a reduction in monitoring may be warranted if the data suggests. In December 2012, de maximis, inc., on behalf of the GEMS Trustees, requested several modifications to the monitoring plan: 1) a cessation of herbaceous/shrub vegetation monitoring activities, based on the data collected thus far showing little Variation from sampling event to sampling event, and the fear that monitoring activities themselves could be causing physical harm to individual swamp pink plants; 2) an end to annual qualitative swamp pink monitoring, which takes place in March of each year, due to their belief that the effects of herbivory (primarily from white-tail deer) were negatively affecting these measurements, making them meaiiingless in assessing impacts to Colony in from operation of the groundwater pump and treat remedy; and 3) an end to monthly piezometer readings, again due to the potential for impact to individual swamp pink plants while collecting these readings.
After a review of all available information, and in consultation with the U.S. Fish and Wildlife Service, in July 2013 the EPA determined that the requested modifications were appropriate. Henceforth, all vegetation monitoring will take place in a single annual sampling event in June that will include herbaceous and shrub layer monitoring, as well as qualitative and quantitative swamp pink monitoring.. Also, the frequency of piezometer readings will be decreased to quarterly from monthly.
Monitoring of swamp pink in both the Colony III and Campus locations has shown a general decline in the health of the populations. However, there has been no indication that groundwater levels in the colonies are bang affected by operation of the remedy, or that the impacts noted are in any way related to operation of the remedy.
Site Inspection
The inspection of the site was conducted on September 12,2013. In attendance were RPM Stephanie Sessoms-Midgett, Michael Clemetson and Michael Scorca, with expertise in risk assessment and hydrology, respectively. Greg Giles of NJDEP assisted in the review as the representative of the support agency. William Lee of de maximis, inc. was the representative on behalf of the GEMS Trustees along with William Soukup of Cornerstone Environmental Group, LLC (consultant contractor for the GEMS;Trustees).
No significant issues were identified at the time of the inspection regarding the cap, the drainage structures or the fence. The cap and the surrounding area were undisturbed, and no significant problems were noted with the gas collection system. No activities were observed that would have compromised the groundwater CEA or the planned deed notices.
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Interviews
No interviews were conducted during the FYR process. The EPA has established a community involvement plan and provides updates to the community as needed. The Mayor of Gloucester receives the quarterly progress reports directly. In addition, the quarterly progress reports and the monthly discharge reports are available to the local community and others at http://www.gemssuperfundsite.org.
Technical Assessment
Question A: Is the remedy functioning as intended by the decision documents?
Most components of the remedy are either completed or are being operated, maintained and monitored as intended by the Record of Decision, including repairs to the landfill cap as needed. The onsite groundwater and leachate pretreatment system is operated, maintained and monitored in accordance with the discharge permit requirements. The new flare has been permitted and successfully stack tested. The security fence is intact.
i
However, the groundwater monitoring well data indicates that the extraction well network is not capturing the groundwater plume fully in two locations: the downgradient end of the plume to the north/northwest of the landfill and under the Holly Run underdrain to the east of the landfill. Data contained in the June 2013 Downgradient Groundwater Investigation Report suggests that contaminated groundwater may be flowing beneath the Holly Run underdrain:
- Elevated levels of benzene, chlorobenzene and xylene have been observed in the lower Cohansey (wells PM-13 and PM-16);
- Elevated levels of arsenic have been observed in the upper Cohansey (well PM-19) and in the lower Cohansey (wells PM-13, PM-16, and 102AR); and
- Elevated levels of benzene have been observed in the upper Cohansey (well PM-19) and,have been observed to be increasing over the last five years in the lower Cohansey near the Holly Run underdrain (well 102AR).
The GEMS Trustees have proposed construction of a horizontal well and the EPA is reviewing a work plan submitted in February 2014.
There is no direct human exposure to contaminated groundwater. All groundwater users are on public water supply and groundwater use is restricted by a classification exception area at the site. The EPA is assisting the NJDEP and GEMS Trustees in placing deed restrictions on properties impacted by the site.
Question B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action objectives used at the time of the remedy still valid?
The exposure assumptions, toxicity data, cleanup levels and remedial action objectives used at the time of the remedy are still valid, as outlined below. i
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Soil: The land use considerations and potential exposure pathways in the 1985 Record of Decision are consistent with the current and anticipated future land uses of the landfill. The remedy included the capping of the landfill and ongoing maintenance to prevent potential direct contact with the landfill waste and soils. In addition, the site is surrounded by a fence, two culverts and a berm to prevent and restrict potential exposures through direct contact with the landfill in the event of trespassing. Therefore, direct exposures are not expected to occur. There are no significant changes in site use expected over the next five years. The area surrounding the site is predominatly rural and residential. Additional residential development is occurring in the area and is expected to continue in the future; consistent with the 1985 Record of Decision. These development activities do not impact the remedy at the site. -
Sediments/Surface Water: For potential risks to human health, the exposure assumptions, toxicity data, cleanup levels and remedial action objectives are still valid. Potential risks to ecological receptors are being evaluated in a baseline ecological risk assessment, which is under development. Sediment and surface water data from 2006 was used for the screening level ecological risk assessment performed in 2010. The screening level ecological risk assessment concluded that a baseline ecological risk assessment should be performed to evaluate cadmium, iron and selenium in Holly Run and to evaluate cadmium, arsenic, iron, selenium and zinc in Briar Lake. The screening level risk assessment concluded that the onsite concentrations of these inorganics are consistent with background levels; however, data will be collected as part of the baseline ecological risk assessment to confirm that conclusion. In addition, the baseline ecological risk assessment will analyze samples using more sensitive detection limits to evaluate whether there is potential ecological risk from die organic constituents 2,4-dinitrophenol, 4-nitrophenol, hexachloropentadiene, 2-methylphenol and carbon disulfide, which were identified in the screening level risk assessment as having practical quantification limits above screening levels. Because these organics have not been identified in other media as being site-related and all samples were reported as non-detect, they are considered unlikely to pose an unacceptable ecological risk; however, additional data will be collected to perform the baseline ecological risk assessment and refine the results of the screening level risk assessment.
Groundwater: The exposure assumptions, toxicity data, cleanup levels and remedial action objectives used at the time of the remedy are still valid. For this FYR, an evaluation of the direct contact pathway with site groundwater showed that this is not a completed pathway given all nearby residents are connected to a public water supply. In addition, a CEA is in place to prevent new water supply wells from being drilled. The planned deed notices will ensure an additional layer of protection when filed. The EPA will continue to assist NJDEP and the GEMS Trustees in this effort.
Vapor Intrusion: As discussed in the previous FYR, a vapor intrusion investigation was conducted in 2008 and concentrations in the groundwater were not found to be of concern for vapor intrusion. Site conditions have not changed, and all of the assumptions used for the previous vapor intrusion assessment, including land use, remain valid.
In sum, the FYR exposure assumptions and toxicity data were reviewed as part of this FYR and they remain valid. There have been no changes in the toxicity factors for the contaminants of concern that were evaluated in the FYR. These assumptions are considered to be conservative and reasonable in evalutating risk. The remedial action objectives associated with the 1985 Record of Decision are still valid.
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Question C: Has any other information come to light that could call into question the protectiveness of the remedy?
No information other than that discussed in Question A has come to light that could call into question the protectiveness of the remedy.
Technical Assessment Summary
Most components of the remedy are either completed or are being operated, maintained and monitored as / intended by the Record of Decision, with the exception of the groundwater extraction well network which is not capturing the plume fully at the downgradient end of the plume and under the Holly Rim underdrain. Further investigation of these two areas is required and modification to the groundwater extraction system is anticipated.
The exposure assumptions, toxicity data, cleanup levels and remedial action objectives used at the time of the remedy are still valid. The GEMS Trustees are developing a baseline ecological risk assessment to characterize risks to ecological receptors at Holly Run and Briar Lake.
In order to address previous recommendations, the EPA will continue to assist NJDEP and the GEMS Trustees in securing deed notices for the landfill and five adjacent properties.
Issues, Recommendations and Foliow-Up Actions 1 ukifiT*Tr(^.W£WTUW<M<I©NSl
« ?w»'9i7. •swwic n 1 New information
since the 2009 five-year review suggests that contaminated groundwater at the downgradient end of the plume is not being captured fully by the groundwater extraction system.
Identify and implement additional action(s) to capture and treat contaminated groundwater at the downgradient end of the plume, which may include the installation of a horizontal well proposed by the PRPs, to ensure the long-term effectiveness of the remedy.
GEMS Trustees
EPA August 2015
N Y
y
13
BRESRON SIB BEl iKlilestone-•Egggft v'ErM
1 New information since the 2009 five-year review suggests that contaminated' groundwater from the site may be flowing below the Holly Run underdrain and needs to be investigated.
Investigate groundwater in the vicinity of the Holly Run underdrain and identify whether any modifications are needed to ensure the long-term effectiveness of the remedy.
GEMS Trustees
EPA August 2015
,N Y
1 The screening level ecological risk assessment indicated the need for a baseline ecological risk assessment at Holly Run and Briar Lake; contractor selection has been completed.
Perform a baseline ecological risk assessment for Holly Run and Briar Lake.
1 )
GEMS Trustees
EPA August 2015
N N ' 1 The screening level ecological risk assessment indicated the need for a baseline ecological risk assessment at Holly Run and Briar Lake; contractor selection has been completed.
Perform a baseline ecological risk assessment for Holly Run and Briar Lake.
1 )
GEMS Trustees
EPA August 2015
-
1 There are no deed notices on the landfill property or on the five adjacent residential properties where components of the remedy are located and which are within the limits of the CEA.
Finalize deed notices and engage property owners for signature and filing.
GEMS Trustees
NJDEP August 2015
N Y
14
r
Protectiveness Statement
Si te-wide Protec t iveness Sta tement
Protectiveness Determination: Addendum Due Date Short-term Protective (if applicable):
08/31/2015 j ~ •
Protectiveness Statement: Based on this third five-year review, the remedy at the GEMS Landfill site currently protects human health and the environment because there is no completed exposure pathway. However, in order for the remedy to be protective in the long-term, the groundwater plume must be contained. Additional measures are being investigated and will be designed and implemented, as needed, to ensure long-term protectiveness.
Next Review • <- .
The next five-year review for the GEMS Landfill Superfund site is required by five years from the completion date of this review.
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Table 1: Chronology of Site Events Event DATE(S)
NJDEP began testing private water wells in the area for volatile organic chemicals
January 1980
NJDEP expanded its testing to include surface water and found leachate contamination in Holly Run and Briar Lake
June 1980
New Jersey Department of Health and Camden County Health Department conducted a health survey of the population living near the GEMS Landfill Site
April & December 1982
The EPA initiated actions at the site by installing culverts at the head of Holly Rim and by fencing a portion of Holly Run and Briar Lake
February 1983
GEMS Landfill placed on National Priorities List September 1983 Remedial Investigation and Feasibility Study conducted by the EPA Fall 1983 Focused Feasibility Study conducted by the EPA to identify and evaluate remedial action alternatives for groundwater contamination impacting Holly Run
July 1985
Record of Decision signed September 27,1985 Interim Remedial Measures performed by NJDEP, including installation of security fence around the landfill, residential water connections to municipal water supply, small scale vapor extraction system, relocation and isolation of Holly Run and minor soil erosion measures were installed
September 1985 -February 1987
The EPA issued Unilateral Administrative Order requiring construction of Phase I by GEMS Trustees
August 1988
Phase I Remedial Design completed for NJDEP by TAMS Consultants, Inc. December 1988 Administrative Consent Order signed by responsible parties with the NJDEP for the Phase I Construction
January 1989
Phase I Construction complete r July 1993 Threatened plant species, "Swamp Pink" discovered ofi site July 1994 EPA, NJDEP and Settling Defendants (the GEMS Trustees) and DeMinimis Settling Defendants lodged a Consent Decree with the federal court to construct and operate Phase II Remedial Action
June 27,1997
Construction completion of Phase II groundwater extraction and onsite pre-treatment system with startup schedule for June 1999
April 1999
Camden County Municipal Utilities Authority issued a permit for discharge from the pre-treatment system at the site
May 17,1999
Based on a study by the United States Geological Survey, CCMUA required sampling of the site for radionuclides
May 1999
Radium and uranium detected in site groundwater at levels higher than expected background levels. CCMUA issued a cease discharge notice to the GEMS Trustees to prevent discharge into the CCMUA system.
June 15,19 99
To assist in characterizing the levels of radionuclides in the groundwater, a temporary surface water discharge with solids removal was implemented
April-December 2002
EPA, NJDEP and CCMUA in discussions Under the auspices of the Federal Court, to implement the remedy outlined in the Consent Decree.
February 2003 -May 11,2005
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Table 1: Chronology of Site Events (continued) First Five-Year Review completed September 2004 First Five-Year Review revised in order to clarify several statements March 2005 CCMUA issued permit to allow discharge of the treated water to the Gloucester Township Municipal Utilities Authority sewage system
June 2005
Extraction, pre-treatment and treatment process systems began operations July 11,2005 Holy Run/Briar Lake sediment sampling conducted December 2006 Vapor intrusion evaluation completed March 2008 Court ordered reduction of non-radionUclides monitoring parameters to once every two weeks. Gross alpha monitoring reduction to weekly and uranium only if gross alpha levels exceed the EPA drinking water standards of 15 pCi/L
December }7,2008
Second Five-Year Review1 started January 2009 Installation of gas extraction wells January 2009 Holy Rim/Briar Lake sediment investigation sampling March 2009 Extraction Wells EX-3 and EX-4 re-drilled June 2009 Second Five-Year Review completed September 2009 The EPA notified of washout on the cover and drainage system that overlay the protective landfill cap due to heavy rains
March 18,2010
GEMS submitted Construction Certification Report with as-built drawings for landfill cap repairs performed in 2010
March 4,2011
GEMS submitted draft Work Plan for groundwater downgradient investigation for site
February 16,2011
Title V permit application for operation of the new flare issued. Flare was successfully stack tested j
September 2012
GEMS submitted Technical Memorandum to the EPA and the USFWS proposing modifications to the Swamp Pink Monitoring Plan
December 20,2012
Seventh Annual Groundwater Progress Report completed April 2013 Third Five-Year Review started June2013 Downgradient Groundwater Investigation Report completed June 4,2013 EPA sends letter to GEMS requesting performance of a Baseline Ecological Risk Assessment based on the results of the 2010 Screening Level Ecological Risk Assessment at Briar Lake and Holly Run
June 20,2013
Swamp Pink Monitoring reduction approved by the EPA; notification sent to GEMS Trustees /
July 24,2013
Swamp Pink Monitoring Plan Annual Report submitted August 1,2013 The EPA contacted GEMS advising the Trustees to delay implementation of the horizontal well installation until further review and more detailed information has been provided
August 1,2013
The EPA, NJDEP and GEMS meeting regarding Groundwater Downgradient Investigation Report and proposal to install horizontal well
August 22,2013
GEMS provided written confirmation of their intention to conduct the BERA requested by the EPA
August 28,2013
GEMS submitted supplemental data in connection with the proposed horizontal well.
September 8,2013
(
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Table 1: Chronology of Site Events (continued) Five-Year Review site inspection September 12,2013 Results of Field Demonstration Test of Proposed Horizontal Well submitted October 23,2013 EPA sent letter to GEMS Trustees requesting additional information regarding proposal to install the horizontal well
December 2013
GEMS Trustees submitted Offsite Groundwater Investigation and Horizontal Well Work Plan
February 9,2014
EPA received NJDEP's comments on Offsite Groundwater Investigation and Horizontal Well Work Plan
March 18,2014
J
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Table 2: Documents, Data and Information Reviewed in Completing the Five-Year Review
Document Title, Author Submittal Date
Remedial Investigation/Feasibility Study, EPA July 1985
Record of Decision, EPA September 1985
Unilateral Administrative Order, EPA August 1988
Consent Decree, USDOJ June 1997
First Five-Year Review, EPA September 2004
Second Five-Year Review, EPA September 2009
Technical Memo, GEMS Trustees April 2010
Screening Level Ecological Risk Assessment, GEMS Trustees September 2010
Seventh Annual Groundwater Report, GEMS Trustees September 2012
Downgradient Groundwater Investigation Report, GEMS Trustees June 2013
Swamp Pink Monitoring Plan-Quarterly Reports, de maximus, inc. for GEMS Trustees
April 2013 & August 2013
Power Point Presentation on Groundwater Investigation, GEMS Trustees August 2013
Supplemental Data - Design Basis for Proposed Horizontal Well at the GEMS Landfill, GEMS Trustees
September 2013
19
Figure 1: Site Map
20
Figure 2: Monitoring Well Locations
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