SDMS DocID 2065586

THIRD FIVE-YEAR REVIEW REPORT

BERKS SAND PIT SITE

LONGSWAMP TOWNSHIP, BERKS COUNTY,PENNSYLVANIA

August 2006

PREPARED BY:

United States Environmental Protection AgencyRegion III

Philadelphia, Pennsylvania

Approved by: Date:

Abraham Ferdas, DirectorHazardous Site Cleanup DivisionU.S. EPA, Region III

Table of Contents

List of Acronyms 3 Executive Summary 4 Five Year Review Summary Form 5

I. Introduction 7

II. Site Chronology 8

III. Background 8

IV. Remedial Actions 9

V. Progress Since Last Five-Year Review 12

VI. Five Year Review Process 13

VII. Technical Assessment 15

VIII. Issues 16

IX. Recommendations and Follow-up Actions 16

X. Protectiveness Statement 17

XI. Next Review 17

Tables Table 1: Chronology of Site Events 8

Attachments Figures

Figure 1 - Berks Sand Pit NPL Site Map Figure 2 - Berks Sand Pit: TCA Plume Area Over Time Figure 3 - Berks Sand Pit: DCE Plume Area Over Time

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List of Acronyms

ARARs Applicable or Relevant and Appropriate Requirements AOC Administrative Order on Consent CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CFR Code of Federal Regulations EPA United States Environmental Protection Agency ESD Explanation of Significant Differences FS Feasibility Study HI Hazard Index IC Institutional Control MCLs Maximum Contaminant Levels mg/kg milligrams per kilogram (mg/kg) NCP National Oil and Hazardous Substances Pollution Contingency Plan NPL National Priorities List O&M Operations and Maintenance PADEP Pennsylvania Department of Environmental Protection PADER Pennsylvania Department of Environmental Resources PRP Potentially Responsible Party RA Remedial Action RAO Remedial Action Objective RD Remedial Design RI Remedial InvestigationRI/FS Remedial Investigation/Feasibility Study ROD Record of Decision RP Responsible Party RPM Remedial Project Manager SARA Superfund Amendments and Reauthorization Act of 1986 SDWA Safe Drinking Water Act VOC Volatile Organic Compound

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Executive Summary

The Berks Sand Pit Site is located in Longswamp Township, Pennsylvania. Thelong-term remedy for the Site consists of operating the groundwater pump and treat system andgroundwater monitoring. Groundwater monitoring includes both residential wells andmonitoring wells. This remedy is functioning as designed. The principal contaminants of concerninclude 1,1,1-trichloroethane (TCA) and 1,1-dichloroethene (DCE).

The Environmental Protection Agency (EPA) operated the pump and treat system untilMarch 2005, when the responsibility for the Site was turned over to the Commonwealth ofPennsylvania. The immediate threats have been addressed and the remedy is protective of humanhealth and the environment. Furthermore, the cleanup process has been enhanced by addinginjection of oxidants at the areas of the highest concentration of the plume, in order to destroythe contaminants in place.

The Record of Decision (ROD) for this Site was issued on September 29, 1988. Initialconstruction of the treatment system was completed in April 1993. The extraction system wasexpanded in 1994. The pump and treat system was acknowledged by the PennsylvaniaDepartment of Environmental Resources (PADER), (currently Pennsylvania Department ofEnvironmental Protection (PADEP)), as fully functional on February 16, 1995. The first FiveYear Review was conducted at the Site on December 15, 1995. The second Five Year Reviewwas conducted on July 5, 2001. This Five Year Review covers the time period from July 2001 toAugust, 2006.

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Five-Year Review Summary Form

Site name: BERKS SAND PIT

EPA ID: PAD980691794State: Pennsylvania City/County:Longswamp

Township/Berks County

NPL status: X Final p Deleted n Other (specify)

Remediation status (choose all that apply) n Under Construction JX] Operating n Complete

Multiple OUs?* [xJYes a No Construction Completion date: 06/28/94

Has Site been put into reuse? p Yes |XJ NoREVIEW STATUS

Lead agency: p EPA |x| State a Tribe a Other Federal Agency

Author name: Bruce RundellAuthor title: RPM Author Affiliation: EPA

Review period:** 7 705/01 to 7/05/06

Date(s) of Site Inspection: 2/16/05 & 12/14/05

Type of review:[X] Post-SARA n Pre-SARA a NPL-Removal only n Non-NPL Remedial Action SiteD NPL State/Tribe-lead a Regional Discretion

Review number: n first D second pd third n other

Triggering action:n Actual RA Onsite Construction at OU#

i—iConstruction Completion

D Actual RA Start at OU#Previous Five-Year Review Report n Other:

Triggering action date (from WasteLAN): 7/05/01

Due Date (five years after triggering action date): 7/05/06

• "OU" refers to operable unit.• ** Review period should correspond to the actual start and end dates of the Five-Year

Review in WasteLAN

Five-Year Review Summary Form, cont'd

Issues:

The pump and treat system was fully functional when the Site was turned over to theCommonwealth of Pennsylvania on March 1,2005. Lack of State funding has delayed PADEPacquisition of an O&M contractor. PADEP is currently reviewing their contractor's O&MWork Plan. The delay in obtaining a contractor has delayed any monitoring at the Site.

The system is currently being operated periodically on a manual basis by PADEP personnel.

The Commonwealth is working on obtaining an easement from the property owner for theoperation of the pump and treat system. The Commonwealth's Site Access Agreement with theproperty owner is being utilized to gain access to the pump and treat system.

Recommendations:

EPA will continue to consultation with PADEP on the Operation and Maintenance of theremedy, and PADEP's efforts on the acquisition of an easement to the property.

Protectiveness Statement(s):

All threats at the Site have been addressed through operation of a treatment plant and by thecommitment of EPA to install carbon units on any resident impacted by the Site wheregroundwater contaminant levels exceed the MCL.

The remedy has achieved short-term protectiveness because exposure pathways that couldresult in unacceptable risks are being controlled. The remedy is expected to be protective ofhuman health and the environment in the long term upon attainment of groundwater cleanupgoals, through utilization of pump-and-treat and oxidant injection processes. These goals areexpected to require 5 to 10 years to achieve.

Current data indicate that the plume remains on Site. The groundwater contaminant area andcontaminant concentrations are diminishing with time. Therefore, the remedy is functioning asrequired to achieve groundwater cleanup goals.

Other Comments:

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Five-Year Review Report For

Berks Sand Pit Longswamp, Pennsylvania

I. Introduction

The purpose of the Five-Year Review is to determine whether the Site remedy isprotective of human health and the environment. The methods, findings, and conclusions ofthese reviews are documented in Five-Year Review reports. In addition, Five-Year Reviewreports identify issues found during the review, if any, and recommendations to address them.

The United States Environmental Protection Agency (EPA) is preparing this Five-YearReview report pursuant to the Comprehensive Environmental Response, Compensation, andLiability Act (CERCLA) § 121 and the National Oil and Hazardous Substances PollutionContingency Plan (NCP). CERCLA § 121 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 suchremedial action no less often than each five years after the initiation of such remedialaction to assure that human health and the environment are being protected by theremedial action being implemented. In addition, if upon such review it is the judgment ofthe 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 theCongress a list of facilities for which such review is required, the results of all suchreviews, and any actions taken as a result of such reviews.

The Agency interpreted this requirement further in the NCP; 40 Code of FederalRegulations § 300.430(f)(4)(ii) states:

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

The EPA Region III has conducted a five-year review of the remedial actionsimplemented at the Berks Sand Pit Site in Longswamp Township, Pennsylvania. This review isappropriate because the response action, pumping and treatment of contaminated groundwatergenerally take longer than five years to complete and is still ongoing. Hazardous substancesremain on Site above levels which allow unlimited use. This document will become part of theSite file.

This is the third five-year review for the Berks Sand Pit Site, and covers the period fromJuly 2001 to August 2006.

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II. Site Chronology

Table 1: Chronology of Site Events

Event Date

Initial discovery of problem or contamination August 01, 1982

Pre-NPL responses April 1983

NPL listing September 21, 1984

Removal actions April 22 1983 to June 15 1984

Remedial investigation/Feasibility Study complete September 29, 1988

ROD Amendments or ESDs February 10, 1994September 14, 2001January 6, 2003

Enforcement documents (CD, AOC, Unilateral, Administrative Order)

Remedial design start December 30, 1988

Remedial design complete June 03, 1989

Superfund State Contract, Cooperative Agreement, or FederalAgreement signature

July 28, 1990

Actual remedial action start August 16, 1991

Construction dates (start, finish) September 10, 1992; June 28, 1994

Construction completion date (Treatment plant operational andfunctional)

February 16, 1995

Final Close-out Report February 2, 1995

Previous five-year reviews December 15, 1995, July 5, 2001

III. Background

Physical Characteristics

The Berks Sand Pit Site is located in Berks County, Longswamp Township, Pennsylvania(Figure 1). The Site is approximately 15 miles northeast of Reading, near the boroughs of HuffChurch, Seisholtzville, and Mertztown. The Site is approximately four acres in size. The Site is ahilly, forested piece of land. Approximately 100 people inhabit the area surrounding the Site.Local residence live mostly in single family houses and occasionally in trailers.

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The Berks Sand Pit was created by the removal of sand and gravel. The size of the pitwas approximately 100 feet in diameter and 30 feet deep. The pit was reportedly used by arearesidents for the disposal of refuse. Industrial waste was also allegedly disposed in and aroundthe pit area. The pit was eventually backfilled. Homes with private wells were constructed in theimmediate vicinity of the sand pit beginning in 1978. One home was built directly on top of thepit.

Groundwater at the Site is found within the saprolitic soils, weathered bedrock, andunweamered, fractured bedrock. Most water bearing zones appear to be interconnected. Thebedrock underlying the Site is a moderately to highly fractured granitic gneiss. Weatheredbedrock is generally encountered within 30 feet of the ground surface and continues as deep as100 feet below ground surface. Fractured bedrock is encountered beneath this layer.

History of Contamination

In January 1982, local residents identified groundwater contamination in the vicinity ofan abandoned sand pit. During an emergency action, the pit was partially excavated andbackfilled with clean soil. No pockets of contamination or buried drums were found during thisaction. A water supply well was installed by EPA during the removal action to supplyuncontaminated drinking water to four area residences.

The Berks Sand Pit Site was listed on the National Priorities List (NPL) on September 1,1984. PADER conducted a Remedial Investigation (RI) and Feasibility Study (RI/FS) of the Sitein 1987 and 1988. A Record of Decision was issued by the EPA on September 29, 1988 toaddress the risk to human health, welfare and the environment. The principal contaminants ofconcern include 1,1,1-trichloroethane (TCA) and 1,1-dichloroethene (DCE).

Basis for Taking Action

The contaminant plume at the time of discovery extended from the residential areaslocated along Benfield and Walker Roads to the West Branch of Perkiomen Creek. Themaximum concentrations were 7,310 µg/1 and 3,500 µg/1 for TCA and DCE, respectively.Three residential wells had been severely contaminated with TCA and DCE. Contaminant levelsin these wells exceeded the Maximum Contaminant Levels (MCL) for at least one of thesecompounds. The groundwater contamination had a significant potential to adversely impactresidents using residential wells. Exposure to surface water and sediments were also found topotentially pose a risk.

IV. Remedial Actions

Remedy Selection

EPA issued a ROD in 1988 to address the risk to human health, welfare, and theenvironment. The major components of the selected remedy include the following:

• Installation and operation of a groundwater extraction system;

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• Construction and operation of an air stripper with vapor phase carbon absorptionto treat extracted groundwater, with discharge of the treated water to the aquiferthrough reinjection wells;

• Chemical monitoring of surface and ground water;

• Local restrictions to prevent additional drinking water wells in the contaminatedareas of the aquifer;

• Construction of an alternate water supply system; and

• Excavation of contaminated sediments and off-site treatment and disposal byincineration;

Several of the ROD components, listed above, were not implemented or were modified.EPA issued four Explanations of Significant Differences (ESDs) to explain modifications of theremedy. They are summarized below:

• The first ESD, signed on February 2, 1994, changed three components of theROD. These were; the elimination of the water supply system which was opposedby area residents, the elimination of excavation and off-site incineration ofsediments which was determined to be unnecessary, and the modification of theremedy to allow effluent discharge to the West Branch of the Perkiomen Creek inlieu of reinjection .

• A second ESD was signed On September 14, 2001. This ESD removed the localrestrictions on ground water usage from the ROD, and committed the Agency toinstall carbon filters on any existing or new drinking water well that becomesimpacted by Site related groundwater contamination above MaximumContaminant Levels (MCL).

• The third ESD, signed on January 6, 2003, determined that the continuedoperation of the vapor phase carbon absorption was no longer justified, due thevery low levels of contaminations being captured. Removal of the carbon unitsreduced the costs of the remedy by removing the requirement for continuouslyheating the air stream before the carbon units.

• A fourth ESD is currently being prepared by EPA. This ESD will enhance thegroundwater remedy by adding in-situ chemical oxidation (ISCO). In-situtreatment is intended to address the remaining area of contaminated groundwaternot efficiently captured by the extraction system. Injections of the oxidizing agentwill be utilized simultaneously with the operation of the groundwater extractionsystem. This ESD will also allow the extraction system to be operatedintermittently during the period required to meet the objectives. Intermittentoperation of the extraction system will be done to maximize the remedyefficiency. Continued monitoring of surface water and sediment will also be

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removed from the remedy. This will be done because the low levels ofcontaminants remaining in the groundwater do not have a detrimental impact onthe surface water at the Site.

Remedy Implementation

When contaminated groundwater was discovered in 1982, 4 residences in the immediatevicinity of the Site were temporarily connected to an upgradient supply well installed by EPA.EPA completed a Remedial Design Basis Report in January 1990, based on the RODrequirements. A contract was awarded September 28, 1990, and construction of a groundwaterextraction system began December 17, 1990. Construction of the groundwater treatment facilitywas completed in April 1993. A second set of extraction wells was added to the system in 1994.The final inspection by EPA and PADEP was conducted on February 2, 1995. PADEPacknowledged that the system was operational and functional on February 16, 1995. Thealternative water system became unnecessary in 1993. This was due to the shrinking size of theplume that resulted from the start up of the treatment system. Residences began again to use theirresidential wells for potable water.

System Operation and Maintenance

The Remedial Action Objectives (RAOs) of the ROD consisted of reducing thecontaminants in ground water to the MCL for both TCA (200 µg/1) and DCE (7 µg/1). The RODalso provides secondary target levels, to be used as guidelines, for tetrachloroethylene (PCE) andDCE. The secondary target is to decrease the concentration of these contaminants to below 1.0µg/1 which would approximate analytical detection limits.

During the Remedial Design ("RD"), the following performance standards wereidentified for the groundwater treatment system:

• Contaminant discharge levels in effluent from the air stripper were establishedbetween PADEP and EPA. The levels were set at 5 µg/1 for DCE, and 5 µg/1 forTCA. The groundwater treatment system was designed to meet theserequirements. Operating data have consistently shown that the discharge from thesystem has been below the required levels. EPA and PADEP agreed that vaporphase carbon would be utilized to capture VOCs in the vapor discharge from theair stripper.

• The groundwater treatment system was constructed with two vapor phase carbonabsorbers. Continued operation of the pump and treat system has resulted indecreases in the concentration of groundwater contaminants. These decreases ingroundwater contaminant concentration have resulted in corollary decreases incontaminant concentrations being removed from the groundwater by the airstripper and trapped by the vapor phase granular activated carbon (VPGAC).Based on the decrease in contaminant level treated, EPA determined that thecontinued operation of the VPGAC was no longer justified. A third ESD, issuedon January 6, 2003, determined that the continued operation of the VPGAC wasno longer justified. The VPGAC was removed from the remedy.

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• EPA committed to the residents that noise would be minimized. This wasaccomplished by housing all components inside the building, providing additionalinsulation in the building, and installing a silencer on the air stripper blower. EPAcommitted to the residents that the facility would be constructed to blend in withthe, surroundings as much as possible. The building was designed and located tomatch the surrounding terrain and was built using earth-tone colored, scored andtextured block on the exterior.

The groundwater treatment facility was tested at the design flow rate of 165 gallons perminute on June 26, 1994. Effluent sampling documented that all contaminants were below the 5µg/1 standard, demonstrating that the system operates as designed.

The final inspection of the Berks Sand Pit Site took place on February 2, 1995. OnFebruary 16, 1995 PADEP acknowledged that the groundwater treatment facility was fullyfunctional.

Throughout most of the period of operation, both the influent and effluent concentrationshave been monitored on a monthly basis. This was reduced to quarterly sampling in 2003.Annual sampling of residential wells and monitoring wells was conducted annually by EPAUntil Site O&M was turned over to the Commonwealth in March 2005. Local springs were alsosampled when flowing during annual sampling events. Sampling of springs stopped with theissuance of the fourth ESD. During the period EPA operated the pump and treat system,contaminant concentrations data, along with water level measurements in monitoring wells wasreviewed on a regular basis. These reviews demonstrated a continuous decrease in the area ofgroundwater contamination and a decrease in the contaminant concentrations (Figure 2 andFigure 3). The last round of sampling was conducted in January 2005. The highest concentrationat that time for TCA was 410 ppb (MW-3D) and 34 ppb for DCE (MW-12D). As a result ofthese reviews, the pumping rate of individual extraction wells has been modified to maximize theefficiency of the pump and treat system. Recovery Well 1I (RW-1I ) is the only extraction wellcurrently being utilized. When operating the pumping rate of RW-1I is sixty gallons per minute.

The Commonwealth of Pennsylvania assumed responsibility for the remedial action atthe Site in March 2005. Since assuming responsibility for the Site the Commonwealth has onlyoperated the pump and treat system manually for brief periods of time by PADEP personnel.PADEP has acquired a contractor to operate the pump and treat system and is currentlyfinalizing the operations work plan. A number of maintenance issues have occurred since theCommonwealth assumed responsibility for the pump and treat system. These problems will becorrected by the operations contractor. No sampling of groundwater has occurred since January2005. The Commonwealth is also working on acquiring easements from the property owner forthe treatment system.

V. Progress Since Last Five-Year Review

An Engineering Evaluation and Cost Analysis of the groundwater treatment system wascompleted in February 2000. The purpose of this study was to explore options to expedite Siterestoration. The findings of this evaluation recommended further evaluation of injecting

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oxidizing agents into the wells to destroy the contaminants in the aquifer. For this purpose, EPAconducted three pilot studies to investigate In-Situ Chemical Oxidation (ISCO).

The first pilot study event was conducted in June 2001. This study targeted groundwatercontamination extending from 58 to 155 feet below ground surface (bgs). Fenton's reagent wasselected as the oxidizing agent. Fenton's reagent is a strong oxidizing reaction that results fromthe chemical reaction of hydrogen peroxide and ferrous iron. Fenton's reagent was injected intomonitoring wells with high and low concentrations of contaminants. Fenton's reagent was alsoinjected into both screened wells and older open-borehole wells. The goal of this study was todetermine if Fenton's reagent could oxidize TCA and to gain an understanding of it's migrationin the aquifer. The pilot study resulted in decreases in contaminant concentrations in theinjection wells and nearby monitoring wells. Questions remained about the distribution of thereagents, especially with respect to injection in to older open-borehole wells. The open-boreholemonitoring wells were surveyed in 2003 by the USGS, in order to identify individual waterbearing zones. Utilizing this information the open-borehole wells were re-completed as nestedshallow and deep screened well pairs. In addition to re-completing the open-borehole well, ninehistorically clean monitoring well and three unused extraction wells were abandoned in 2003.

A second pilot study, performed in March 2004, focused on the area of highestcontamination. A modified Fenton's reagent was injected through two of the more highlycontaminated well pairs. Modified Fenton's process utilizes catalysts and chelating agents toslow the Fenton's reaction. This increases the persistence of the reagents and enables thechemical reaction to be transported further from the point of injection. This study resulted inincreased distribution of the reagents and potentially identified an area of residual contamination.

A third pilot study, performed in December 2004, again included injection of modifiedFenton's reagent into the same two well pairs. The results of the third study showed significantdecreases in TCA and DCE concentrations at the point of injection and in downgradientmonitoring wells. The objectives of these actions were to find the most suitable oxidizing agentthat could destroy both TCA and DCE, and optimize its application at the Site. Results of thetests were positive, and resulted in the preparation of ESD 4, which added the option of ISCO tothe remedy.

VI. Five-Year Review Process

Administrative Components

The Berks Sand Pit review team was led by Bruce Rundell, Remedial Project Manager,and included members of EPA Region III Technical Support Staff, Biological TechnicalAssistance Group and Community Involvement Coordinator. PADEP was represented by EliseJuers, Remedial Project Manager.

EPA transferred the operation and maintenance of the pump and treat system to PADEPon March 1, 2005.

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Community Involvement

Activities to involve the community in the last five years included discussion with thelocal citizens, Township representatives and property owners.

A notice was sent to the local newspaper On March 25, 2005 to announce the beginningof the Five-Year process. No concerns regarding the Site were expressed by the community.

Document Review

This five-year review consisted of a review of relevant documents including O&Mrecords, monitoring data, and two injection event reports. Applicable groundwater cleanupstandards, as listed in the 1988 ROD, were reviewed.

Data Review Groundwater monitoring

Groundwater contaminate concentrations continued to decline during the last five years.The last round of groundwater sampling was conducted by EPA in January 2005. Eighteenresidential wells are sampled during these rounds. No contaminants of concern were detecting infifteen of these residential wells during this period of review. Contaminant concentrations in thethree residential wells were well below the MCL. The highest contaminant concentration inresidential wells during this period of review was 6.7 ppb TCA and 0.9J DCE. Thirty sixmonitoring wells are sampled annually. Eight monitoring wells had DCE concentrations abovethe MCL, and three wells had TCA concentrations above the MCL. The table below lists the tenhighest concentrations of DCE and TCA measured in January 2005.

January 2005 Contaminant Concentrations

DCE MCL - 7ppb 34 28 16 15 13 9J 7J 7J 6J 6J

TCA MCL - 200 ppb 410 300 220 120 77 64 40 33 29 27

Surface Water and Sediment Monitoring

During the period of operation of the pump and treat system, surface water and sedimentmonitoring was conducted. Review of this data indicated that contaminant levels in the WestBranch of Perkiomen Creek have not exceeded the biological screening values since 1992. Thisreview determined that the Site posed no risk to the surface water or sediments in the WestBranch of Perkiomen Creek. Surface water and sediment monitoring will be removed from theremedy by ESD 4.

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Site Inspection

Inspection of the Site was conducted on February 16th and December 14th 2005 by theEPA RPM and PADEP representative, Elise Juers. The purpose of the inspection was to assessthe protectiveness of the remedy and document the functionality of the treatment system.

No significant issues were identified regarding the extraction wells and the treatmentplant. The treatment system was functional and the Commonwealth was working on acquiring anO&M contractor.

Interviews

Interviews were conducted with nearby residents throughout the five year period. Nosignificant problems regarding the Site were identified during these interviews.

VII. Technical Assessment

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

Yes, the review of documents, Applicable, Relevant, Appropriate Regulations (ARARs),risk assumptions and the results of the Site inspection indicate that the remedy is functioning asintended by the ROD, as modified by the ESDs. Operation and maintenance of the treatmentplant is being implemented by the Commonwealth.

System optimization included modification of pumping rates, decrease in frequency ofinfluent and effluent sampling, and treatability studies to investigate ISCO as a viable approachto remediate areas of elevated groundwater contamination not effectively captured by thegroundwater extraction system. These studies have shown ISCO to be an effective amendment tothe remedy. ISCO will be added to the groundwater remedy in the forth ESD.

Question B: Are the exposure assumptions, toxicity data, cleanup levels, and RAOsused at the time of the remedy still valid?

Yes, there have been no changes in the physical conditions of the Site that would affectthe protectiveness of the remedy. Toxicity data, cleanup levels and RAOs remain valid.

Question C: Has any other information come to light that could call into questionthe protectiveness of the remedy?

No.

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VIII. Issues

Issues Affects CurrentProtectiveness

(Y/N)

Affects FutureProtectiveness

(Y/N)

The pump and treat system was fully functional whenthe Site was turned over to the Commonwealth ofPennsylvania on March 1, 2005. Lack of State fundinghas delayed PADEP acquisition of an O&M contractor.PADEP is currently reviewing their contractor's O&MWork Plan. The delay in obtaining a contractor hasdelayed any monitoring at the Site.

N Y

The Commonwealth is currently working on obtainingan easement from the property owner for the operationof the pump and treat system. The Commonwealth'sSite Access Agreement with the property owner isbeing utilized to gain access to the pump and treatsystem.

N Y

IX. Recommendations and Follow-Up Actions

Issue Recommendationsand Follow-up

Actions

PartyResponsible

OversightAgency

MilestoneDate

AffectsProtectiveness

(Y/N)

Current Future

1. EPA will continueconsultation withPADEP to ensure theyperform Operationand Maintenance ofthe remedy.

PADEP EPA 12/30/2006 N Y

2. EPA will continueconsultation withPADEP to verify thatan easement to theproperty has beenobtained.

PADEP EPA 12/30/2007 N Y

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X. Protectiveness Statement

The remedy is expected to be fully protective of human health and the environment in thelong term upon attainment of groundwater cleanup goals, through utilization of pump-and-treatand oxidant injection processes. The remedy is protective in the short term because exposurepathways that could result in unacceptable risks are being controlled. Current data indicate thatthe plume remains on site, and its area and contaminant concentrations are diminishing withtime. Therefore, the remedy is functioning as intended to achieve groundwater cleanup goals.

XI. Next Review

The next five-year review for the Berks Sand Pit Site is required five years from the dateof this review.

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Attachments