### Table of Contents Craig Farm Drum Superfund Site Third Five Year Review

Tables, Figures and Attachments ................................................................................................ ............ii List of Acronyms ............................................................................................................... ....................iii Executive Summary .............................................................................................................. .................iv Five-Year Review Summary Form .................................................................................................. ......vi I. Introduction................................................................................................................ .................... 1 II. Site Ch ronology ............................................................................................................ ................. 2 III. Back ground ................................................................................................................ ............... 3 Physical Characteristics....................................................................................................... ............... 3 Land and Resource Use.......................................................................................................... ............ 4 History of Contamination....................................................................................................... ............ 5 Initial Response ............................................................................................................... ................... 6 Basis for Ta king Action........................................................................................................ .............. 7 Source Material Investigation ........................................................................................................ 7 Groundwater Quality Findings ...................................................................................................... 8 Biological Findings ........................................................................................................................ 9 Air Monitoring Findings ................................................................................................................ 9 Summary of Site Risks .................................................................................................................... 9 Potential Migration Pathways ..................................................................................................... 10 Potential Human Exposure Pathways .......................................................................................... 10 Potential Environmental Exposure Pathways .............................................................................. 11 Risk Assessment ........................................................................................................................... 11 IV. Remedial Actions ........................................................................................................... ......... 12 Definition of Operable Units ................................................................................................... ......... 13 Remedial Action Objectives..................................................................................................... ........ 13 Components of Remedy ........................................................................................................... ........ 13 Remedy Implementation .......................................................................................................... ........ 14 System Operations and Maintenance .............................................................................................. . 15 V. Progress Since Last Five-Year Review........................................................................................ 16 Summary of Post-Remedy Studies................................................................................................. .. 17 Treatability Studies ...................................................................................................................... 18 Whole Effluent Toxicity Testing ................................................................................................... 19 Water Balance Study .................................................................................................................... 19 Focused Feasibility Study...................................................................................................... ........... 20 VI. Five-Year Review Process ................................................................................................... ... 22 Administrative Components...................................................................................................... ....... 22 Community Involvement.......................................................................................................... ........ 23 Document Review ................................................................................................................ ............ 23 Data Review .................................................................................................................... ................. 24 Inspections

............................................................................................................................... .... 25 Groundwater Monitoring Data .................................................................................................... 25 Surface Water Monitoring Data .................................................................................................. 26 Site Inspection ................................................................................................................ .................. 27 Interviews ..................................................................................................................... .................... 27 VII. Technical Assessment ...................................................................................................... ....... 28 VIII. I ssues ................................................................................................................... .................... 30 IX. Recommendations an d Follow-up Actions.............................................................................. 30 X. Protectiveness Statement .................................................................................................... ......... 30 XI. Next Review................................................................................................................

............ 31

i

### Tables, Figures and Attachments

Tables

Table 1 Chronology of Site Events

Figures

Figure 1 Site Location Map Figure 2 Site Plan

Attachments

Attachment 1 Institutional Controls Attachment 2 Community Involvement Materials Attachment 3 Groundwater Monitoring Analytical Data Attachment 4 Site Inspection Checklist Attachment 5 Interview Summary

ii

### List of Acronyms

ARARs Applicable or Relevant and Appropriate Requirements BMDSA Benzene Meta Disulfonic Acid BSA Benzene Sulfonic Acid COC Contaminants of Concern CERCLA Comprehensive Enviro nmental Response, Compensation, and Liability Act EA Environmental Assessment EPA Environmental Protection Agency GCL Geosynthetic Clay Liner HDPE High Density Polyethylene NCP National Oil and Hazardous Substances Pollution Contingency Plan NPL National Priorities List O&M Operations and Maintenance OU Operable Unit PADEP Pennsylvania Department of Environmental Protection PADER Pennsylvania Department of Environmental Resources PRP Potentially Responsible Party p-PSA para-Phenolsulfonic Acid PSA Phenolsulfonic Acid RA Remedial Action RAO Remedial Action Objective RCRA Resource Conservation Recovery Act RI/FS Remedial Investigation/Feasibility Study ROD Record of Decision RPM Remedial Project Manager THD Trihydroxydiphenyl

iii

### Executive Summary

The Craig Farm Drum Superfund Site (the S ite) is located in Perry Township, Armstrong County, Pennsylvania. Contamination at the Site resulted from the disposal of drums containing still bottoms from Resorcinol produ ction in two (2) abandoned strip mine pits. Material placed in the disposal pits originated at the nearby Koppers Chemical Company, Inc. (Koppers) facility and Koppers, now Beazer East, Inc. (Beazer), was identified as the Potentially Responsible Party (PRP) for the S ite. The Record of Decision (ROD) for the Site was signed on September 29, 1989.

The Site was divided into three Operable Units (OUs) for remediation (OU-1, OU-2, and OU-3). OU-1 was comprised of contaminated material and soils located in and adjacent to the former strip mine pits, OU-2 consisted of clean soils that n eeded to be moved for access to OU-1 material, and OU-3 consisted of two (2) contaminated seeps located downgradient from the disposal pits.

The remedy for OU-1 consisted of the ex cavation and onsite solidification of contaminated material and soils. The so lidified material was placed in an onsite, Resource Conservation and Recovery Act (RCR A)-equivalent landfil l. No remedial action was required for OU-2. The selected remedy for OU-3 consisted of the treatment of two (2) contaminated seeps via a seep inte rceptor system. Collected water is conveyed to an onsite, aboveground storage tank (AST) and transported offsite for treatment. In addition to the OU remedies, a one-acre wetl and was constructed onsite to replace a smaller area of wetland destroyed during construc tion of the onsite landfill. Operations and Maintenance (O&M) of the remedy cons ists of semi-annual inspections of the landfill and seep interceptor system and groundwater sampling and analysis. Construction completion at the Site was ach ieved with the approval of the December 27, 1995 Final Close Out Report (FCOR). Because th e FCOR was issued prior to the current site closeout guidance, it does not meet the current FCOR criteria, in that it does not document site completion. However, it is equi valent to the current Preliminary Closeout Report (PCOR) in that it documents construction completion.

Institutional controls implemen ted at the Site consist of a Declaration of Restrictions attached to the deed informing property ow ners about contamination remaining onsite and restricting landfill and groundwater use. However, because the requirements for the institutional controls were insufficiently documented by the 1989 ROD, EPA will issue an Explanation of Significant Differences (ESD ) to clarify the requirements and to ensure that they remain in place.

In May 2009, Beazer submitted a Focused Feasibility Study (FFS) for a remedy modification consisting of an impermeable cap and groundwater infiltration system to reduce or eliminate flow to one contaminated seep (Seep A). Additi onally, the other seep (Seep B) no longer exhibits toxicity and th e collection trench will be decommissioned. EPA is currently reviewing the FFS, and if approved, will document the remedy modifications in the aforementioned ESD.

iv

### The trigger for this Five Year Review was th e previous Five Year Review, dated June 29, 2004. This Five Year Review has concluded that the physical cons truction of the remedy was completed in accordance with the require ments of the ROD. Additionally, this review has indicated that the remedy is f unctioning as designed, and is protective of human health and the environment.

Government Performance Resu lts Act (GPRA) Measure Review

As part of this Five Year Review the GPRA Measures were reviewed. The GPRA Measures and their status are provided as follows:

Environmental Indicators

Human Health: Long-Term Human Hea lth Protection Achieved (HHPA) Groundwater Migration: Groundwater Migration Under Control (GMUC)

Sitewide RAU

The Site was determined to be Site-Wide Ready for Anticipated Use (SWRAU) on June 27, 2008.

v

### Five-Year Review Summary Form

SITE IDENTIFICATION

Site name (from WasteLAN ) : Craig Farm Drum Superfund Site
EPA ID (from WasteLAN ) : PAD980508527 Region: 3 State: PA City/County: Perry Township, Armstrong County



### SITE STATUS

NPL status: Final Deleted Other (specify)
Remediation status (choose all that apply) : Under Construction Operating Complete Multiple OUs? * YES NO Construction completion date: 12 / 27 / 1995 Has site been put into reuse? YES NO



### REVIEW STATUS

Lead agency: EPA State Tribe Other Federal Agency ______________________ Author name: John Epps
Author title: Remedial Project Manager Author affiliation: U.S. EPA – Region 3 Review period: ** June 2008 – June 2009 Date(s) of site inspection: September 3, 2008 Type of review: Post-SARA Pre-SARA NPL-Removal only Non-NPL Remedial Action Site NPL State/Tribe-lead Regional Discretion 

### Review number: 1 (first) 2 (second) 3 (third) Other (specify) __________ Triggering action: Actual RA Onsite Construction at OU #

____ Actual RA Start at OU#____ Construction Completion Previous Five-Year Review Report Other (specify) Triggering action date (from WasteLAN) : 6 / 29 / 2004
Due date (five years after triggering action date) : 6 / 29 / 2009 * [“OU” refers to operable unit.] ** [Review period should correspond to the actual start and end dates of the Five-Year Review in WasteLAN.]

vi

### Five-Year Review Summary Form, cont’d.

Issues:

The requirements for institutional controls are insuffici ently documented in the Record of Decision (ROD). Additional documentation is necessary to ensure that the institutional controls remain in place and effective.

Recommendations and Follow-up Actions:

EPA will prepare an Explanation of Sign ificant Differences (ESD) to clarify the requirements for the institutional controls.

Additionally, EPA is currently revi ewing Beazer’s proposal for a remedy modification. If approved, the modification will be documented in the aforementioned ESD and Beazer will prepare a Remedial Design Work Plan. A summary of any additional information relevant to this Five-Year Review will be included in an addendum to this report.

Protectiveness Statement(s):

The remedy at the Craig Farm Drum Site is protective of human health and the environment in the short and long term. Physical construction is complete and institutional controls have been implemented.

Protection of human health and the environment has been achieved by the installation of a RCRA-equivalent landfill to contain waste (OU-1) and a seep interceptor system to collect contaminated ground water for offsite treatment (OU-3). Additionally, protection of human health is enhanced due to the location of the Site within the BCACS, in which all residents are required to conn ect to public water. Currently, design is underway for the modification of the seep interceptor system by the addition of an imperm eable cap and groundwater infiltration system to reduce overburden groundwater flow through contaminated material, further enhancing the protectiveness of the remedy. Finally, the remedy is protective of both human health and the environment in the long-term due to the implementation of institutional controls alerting current an d future Site owners of the contaminants onsite and restricting landfill and groundwater use. The requirements for the institutional contro ls at the Site will be clarified in an ESD to further ensure long-term protectiveness.

Other Comments:

N/A

.

vii

### U.S. Environmental Protection Agency Region III Five Year Review Report Craig Farm Drum Superfund Site Perry Township, Armstrong County, Pennsylvania

I. Introduction

The purpose of Five Year Reviews is to de termine whether the remedy at a site is protective of human health and the environmen t. The methods, findings, and conclusions of reviews are documented in Five Year Revi ew reports. In addition, Five Year Review reports identify issues found during the revi ew, if any, and recommendations to address them.

The Agency is preparing this Five Year Review pursuant to CERCLA §121 and the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). CERCLA §121 states:

If the President selects a re medial action that results in any hazardous substances, pollutants, or contaminants remaining at the Site, the President shall review such remedial action no less often t han each five years a fter the initiation of such remedial action to assure that human health and th e environment are being protected by the remedial action being implem ented. In addition, if upon such review it is the judgment of the President that action is appr opriate at such Site in acco rdance with section [104] or [106], the President sh all 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.

The agency interpreted this re quirement further in the NCP; 40 CFR §300.430(f) (4) (ii)
states:

If a remedial action is sel ected that results in hazardous substances, pollutants, or contaminants remaining at th e 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 the ini tiation of the selected remedial action.

The United States Environmental Protecti on Agency (EPA) Region III has conducted a Five Year Review of the remedial acti ons implemented at the Craig Farm Drum Superfund Site (the Site) located in Perry Township, Armstrong County, Pennsylvania. This review was conducted for the entire S ite by the Remedial Project Manager (RPM) from June 2008 through June 2009. This repor t documents the results of the review

.

Page 1Craig Farm Drum Superfund Site Third Five-Year Review June 2009



### This is the third Five Year Review for the Site, triggered by the date of the second FiveYear Review (June 29, 2004). This Five Year Review is required due to the continued presence of hazardous substances, p ollutants, or contaminants at the Site above levels that allow for unlimited use and unrestricted exposure.

II. Site Chronology

Table 1 lists the chronology of events fo r the Craig Farm Drum Superfund Site:

Table 1 – Chronology of Site Events

Event Date
The Craig Farm Drum Site was operated as an open dump disposal of drums containing still bottom residue from resorcinol manufacturing. The drums were deposited in two (2) abandoned strip mining pits by Koppers Chemical (Koppers). 1958 – 1963

Koppers purchased the Craig Farm Property 1971 and 1985

Potential Hazardous Waste Site Identification Repo rt by EPA December 1980 Proposed for National Prioritie s List (NPL) December 1982 NPL Listing September 8, 1983
Koppers submitted an environmental assessment (EA) of the Site to Pennsylvania Department of Environmental Resources (PADER) including a hydrogeological study, surface water sampling study, stream biological study and an air quality survey. October 31, 1983

Koppers conducted an investigation to determine the approximate extent and condition of the still bottom residue drums at the Site. April 23-24 1984

EPA and PADER offered joint comments on the EA report. April 1, 1985
PADER requested Koppers perform a Remedial Investigation and Feasibility Study (RI/FS) of the Site. August 2, 1985

Keystone Environmental Resources Inc. (Keystone) began working on the RI/FS for Koppers. February 1986

Keystone conducted RI/FS February 1986 – November 1987
Koppers signed a Consent Order and Agreement with PADER to perform a RI/FS of the Site. February 10, 1987

PADER conducted a public meeting to announce the start of the RI/FS. April 7, 1987
Koppers Chemical became Beazer Materials an d Services Inc. (Beazer). January 20, 1989
Beazer submitted the final RI/FS Repor t to EPA and PADE R. August 1989
A Special Notice Letter providing the opportunity to make a good faith offer was sent to Beazer by EPA. August 24, 1989

Page 2Craig Farm Drum Superfund Site Third Five-Year Review June 2009



### Table 1 – Chronology of Site Events

Event Date
The RI/FS and the Proposed Pl an for the Craig Farm Drum Site were released to the public for comment. August 25, 1989 – September 13, 1989 (comment period)
Public Meeting for the Proposed Plan was held. September 13, 1989

EPA issued the Record of Decision (ROD). September 29, 1989 May 1 8, 1990 Consent Decree signed by Beazer for completion of Reme dial Design and Remedial Action (RD/RA)
EPA approved Final RD Work Plan January 14, 1991
Ju ly 14, 1993 Operations and Maintenance Plan (O&M Plan) approved by EPA and PADER.
EPA approved Final RD Report September 27, 1993 May 1 994 Onsite mobilization for the RA for Op erable Unit 1 (OU-1) , Operable Unit 2 (OU-2), and Operable Unit 3 (OU-3).

The construction of the remedial ac tion for OU-1, OU-2, and OU-3 was completed as per Final Close Out Report (FCOR). December 27, 1995

First Five-Year Review completed. April 6, 1999
Second Five-Year Review completed. June 29, 2004



### III. Background

Physical Characteristics

The Craig Farm Drum Superfund Site (the Site) consists of ap proximately 117 acres located in Perry Township, in the vicinity of the village of Fr edericksburg, near the western border of Armstrong County, Pennsylva nia (Figure 1). The Site is located approximately two (2) miles east of the Bor ough of Petrolia and a pproximately four (4) miles south of the town of Parker and th e Allegheny River. Land use surrounding the Site is primarily agricultural and limited residential.

Surface water is present onsite in the form of seepage ditches, forested wetlands, and an Unnamed Creek. Drainage occurs across the Site via the seepage ditches or erosion channels to the southwest into the Unnamed Creek, which flows southeast and discharges to Valley Run, approximately one (1) mile from the Site. From the confluence with the Unnamed Creek, Valley Run flows northeast for approximately one and a half (1.5) miles before discharging to the Allegheny River.

Page 3Craig Farm Drum Superfund Site Third Five-Year Review June 2009



### Geology at the Site consists of the follow ing general sequence, from top to bottom:

 Unconsolidated Materials;

o Mine spoils and native soils cover.  Upper Sandstone;

o Unit above the Upper Freeport Coal,

o Consists primarily of fine to medium grained siliceous sandstone, 30 to 40 feet thick.  Upper Freeport Coal;

o Approximately 24 inches thick.  Upper Shale;

o Gray shale with some thin co al and sandstone stringers,

o Becomes sandier below the Lower Freeport Coal and is 80 feet in thickness.  Lower Freeport Coal;

o Separates Upper Shale zone,

o Approximately 12 inches thick.  Lower Shale;

o Immediately below the Lower Freeport Coal.  Lower Sandstone;

o Fine to medium grained siliceous sandstone,

o Thickness unknown,

o Principle water bearing unit.

The interval extending from immediately below the Upper Freeport Coal to the top of the lower sandstone unit has histor ically been designated as the upper bedrock aquifer and will be referred to as such in this document.

Groundwater is present at the Site under wa ter table conditions in the unconsolidated materials, and under semi-confined conditions in the upper bedrock and lower sandstone aquifers. Flow is generally across the Site to the west -southwest toward the Unnamed Creek in the unconsolidated materials and the upper bedrock aquifer and to the south and southeast in the lower sandstone aquifer

Land and Resource Use

Land use within Armstrong County consists of twenty eight (28) percent farmland, fiftytwo (52) percent forest, and twen ty (20) percent other use. La nd use in the direct vicinity of the Site is consistent with that of Ar mstrong County and consists primarily of farmland and limited residential use. Strip mining is currently and has histor ically been conducted in the direct vicinity of the Site as well. Population density estimates range from 65 persons per square mile (mi 2 

### ) in Perry Township to 106 persons per mi 2 

### for Armstrong County, according to 2000 United States Census Data ( www.census.gov/factfinder ).

Page 4Craig Farm Drum Superfund Site Third Five-Year Review June 2009



### Historically, prior to 1958, the Site was ope rated as a strip m ine working the Upper Freeport coal seam. Following the cessati on of strip mining operations, the abandoned former mining pits were utilized for the disposal of 55-gallon drums containing still bottom residue from the production of Resorcinol at the Koppers Chemical Company (Koppers) plant located in Petrolia, Pennsylva nia. Disposal activities were conducted from approximately 1958 through 1963, during which time the Site was owned by Mr. Paul Craig. Koppers purchased approximate ly 100 acres from Mr. Paul Craig in 1971 and the remaining approximately 17 acres in 1985. On January 26, 1989, Koppers Chemical Company, Inc. became Beazer East, Inc. (Beazer).

Historically, groundwater at th e Site and immediately adjacen t to the Site has not been used for drinking water or irrigation purposes due to poor water quality from historic mining operations. Currently, the Site is uno ccupied and groundwater use restrictions exist for the Site due to deed restrictions and for the surr ounding area due to its location within the Bear Creek Area Chemical Site (BCACS), as defined by the Pennsylvania Department of Environmental Protection (PADEP), pursuant to the Hazardous Sites Cleanup Act (HSCA). The BCACS is discussed in detail in Section V of this document.

Currently, the Site is undev eloped, with the exception of the components of the remedy, consisting primarily of a landfill and s eep interceptor system. No proposed redevelopment plan currently exists for the Si te. At the time of the Record of Decision (ROD), it was anticipated that the Site may be used in the future for recreational purposes. Due to the rural location and steeply sloping nature of th e Site, commercial or residential development potential is limite d. Additionally, institutional controls have been implemented restricting the use of groundwater at the Site and prohibiting disturbance of the landfill cap.

History of Contamination

As discussed above, the Site was historically operated as a strip mine , resulting in two (2) abandoned mine pits following the cessation of operations, prior to 1958. Typical of strip mining operations in the vicinity of the Site, th e mining pits were cut into a hillside where the coal seam outcropped or subcropped. The pit walls were formed by the working face (highwall) of the mine and the spoil piles were staged away from the working face.

From 1958 through 1963, 55-gallon drums contai ning still bottom residue from the manufacturing of Resorcinol at the near by Koppers plant were deposited in the abandoned former strip mine pits, hereinafter kn own as the north and south disposal pits. Resorcinol, also known as 1,3-Benzenedio l, m-Benzenediol, 1,3-Dihydroxybenzene, mDihydroxybenzene, 3-Hydroxyphenol, or m-Hydroxyphenol, is an organic compound used as an adhesive enhancer in the production of automobile tires and in pharmaceuticals.

Page 5Craig Farm Drum Superfund Site Third Five-Year Review June 2009



### The residue, consisting of Resorcinol and ot her h igher polymers, was characterized as a CERCLA hazardous substance but not as a Resource Conservation and Recovery Act (RCRA) hazardous waste. An analysis of the waste indicated the following composition:

Compound Percent of Composition
Resorcinol 5-10% Dihydroxydiphenyls 20-25% Trihydroxydiphenyls 30-35% Higher polymers 30-35%



### Approximately 2,500 tons of material were placed in the pits by Mr. Herman Craig, Site owner Paul Craig’s brother. During deposition and duri ng the time the drums were stored onsite, many drums were damaged, resu lting in a release of the residue to the environment.

Contamination was first discovered at the Site during an EPA site inspection and subsequent Potential Hazardous Waste Si te Identification Report in December 1980.

Initial Response

Following the completion of the aforementioned Potential Hazardous Waste Site Identification Report by EPA in 1980, the Crai g Farm Drum Site was proposed for placement on the National Priorities List (N PL) in December 1982, and listed on the NPL on September 8, 1983.

On February 25, 1983, Koppers presented the Pennsylvania Department of Environmental Resources (PADER, now PA DEP) with a proposal to conduct an Environmental Assessment (EA) of the S ite. The EA consisted of the following components and was submitted to PADER on October 31, 1983:

 Hydrogeologic study;  Surface water sampling study;  Stream biological study;  Air quality survey.

On January 19, 1984, the Armstrong County Depart ment of Public Protection issued an Emergency Preparedness Plan for the Site. In April 1984, Koppers, under PADER oversight, installed a total of fi fteen (15) test pits to determ ine the extent and condition of the still-bottom residue-containing drums. The investigation indicated that the majority of the drums were crushed, broken, or without lids.

On June 29, 1984, EPA and representatives of GCA Corporation (GCA), under contract with EPA, conducted a site visit. GCA also reviewed the Koppers EA and issued draft comments in August 1984. PADER and EPA issued draft comments on the Koppers EA in April 1985.

Page 6Craig Farm Drum Superfund Site Third Five-Year Review June 2009



### From fall 1984 through November of 1985, Ko ppers worked with PADER and EPA toward the development of a Remedial I nvestigation/Feasibility Study (RI/FS) Work Plan. The goal of the RI/FS Work Plan was to utilize as much data from the Koppers EA as possible and also include additional char acterization as necessa ry to satisfy RI/FS requirements.

Basis for Taking Action

From February 1986 through November 1987, Ke ystone Environmental Resources, Inc. (Keystone) performed the RI/FS at the Site , consisting of the following activities:

 Biological survey – four (4) sampling events;  Biota survey – two (2) sampling events;  Surface water and sediment characterization – six (6) sampling events;  Groundwater characterization – four (4) sampling events.

Additional groundwater monitoring wells were installed in November 1988 to further delineate the extent of groundwater contamin ation. The Draft RI and Draft FS Reports were submitted to PADER and EPA in April 1989 and July 1989, respectively. The Revised RI and FS Reports were subm itted to PADER and EPA in August 1989.

Source Material Investigation

Test pits installed in the disposal pits in 1984 prior to the RI/FS i ndicated the still bottom residue consisted of black to pink semisolid material with some hardened masses. The North disposal pit was observed to be approxi mately 1.2 to 1.5 acres in lateral extent and the South disposal pit was observed to be appr oximately 0.8 to 1.0 acres in lateral extent. Analytical data of samples collected during te st pit installation indicated that the source material in the disposal pits is locate d between approximately 2.5 and 6.0 feet below ground surface (bgs). Contaminated soil was also observed in the vicini ty of the disposal pits during test pit installation, pa rticularly in down-slope areas.

Soil was impacted by the followi ng site-related organic compounds:

 Resorcinol;  Trihydroxydiphenyls (THD);  Dihydroxydiphenyls (DHD);  Meta-phenolsulfonic acid (m-PSA);  Para-phenolsulfonic acid (p-PSA);  Benzene sulfonic acid (BSA);  Benzene.

Page 7Craig Farm Drum Superfund Site Third Five-Year Review June 2009



### Soil was impacted by the following site-related inor ganic compounds:

 Cad mium.

Groundwater Quality Findings

Groundwater quality data collected during the RI/FS indicated the presence of im pacted groundwater in three (3) water bearing zones at the Site; th e unconsolidated materials zone, the upper bedrock (shale) aquifer, a nd the lower sandstone aquifer. Groundwater was impacted in these zones by the following site-related organic compounds:

 Resorcinol;  THD;  Meta-phenolsulfonic acid (m-PSA);  Para-phenolsulfonic acid (p-PSA);  Benzene sulfonic acid (BSA);  Benzene meta disulfonic acid (BMDSA);  Benzene;  Phenol.

Groundwater was impacted in these zone s by the following site-related inorganic compounds:

 Cadmium;  Chromium;  Copper;  Lead;  Zinc.

Impacted groundwater was detected in the unconsolidated materi als zone across the majority of the Site. Groundwat er within this zone is locat ed at the overburden/bedrock interface and flows across the bedrock surface before discharging to the west-southwest of the Site in seeps and to the Unnamed Cr eek. The creek is the western boundary of the impact to the unconsolidated materials zone.

Impacted groundwater was also detected in the upper bedrock aquifer across the majority of the Site. Groundwater within this z one flows downward through the shale to the shale/Lower Freeport Coal seam interface and flows across the coal surface toward the Unnamed Creek. The creek is also the western boundary of the impact to the upper bedrock aquifer.

Impacted groundwater in the lower sandstone a quifer was detected from the disposal pit areas extending to the immediate east of the Unnamed Creek valley bottom. Groundwater within the lower sandstone aquife r is influenced by regional flow patterns in the direction of the valley bottom.

Page 8Craig Farm Drum Superfund Site Third Five-Year Review June 2009



### Biological Findings

The biological survey conducted during the RI/FS indicated that macroinvertebrate communities located downstream from the Site in the Unnamed Creek were stressed due to site-related compounds. The stress was ch aracterized as a lack of macroinvertebrate species that are typically an i ndicator of good water quality. St atistical data indicated that of the site-related compounds, THD has the greatest impact on m acroinvertebrates. However, analysis of tissue samples from macroinvertebrates in the Unnamed Creek did not detect any bioaccumulation or biom agnification of site-related compounds.

No stress was detected in fish species w ithin Valley Run and the macroinvertebrate community recovered within one (1) mile of the confluence of Valley Run and the Unnamed Creek.

Air Monitoring Findings

Air m onitoring sampling conducted during the RI /FS did not indicate an impact to Site air quality by any site-related compounds. The survey concluded that in its current condition, there was no threat to human heal th via air transport from site-related compounds.

Summary of Site Risks

Based on th e analysis of groundwater, surface water, sediments, and ambient air during the RI/FS, the following compounds were identified as Contaminants of Concern (COCs):

Organics:  Resorcinol;  THD;  Meta-phenolsulfonic acid (m-PSA);  Para-phenolsulfonic acid (p-PSA);  Benzene sulfonic acid (BSA);  Benzene meta disulfonic acid (BMDSA);  Benzene;  Phenol.

Inorganics:  Cadmium;  Chromium;  Copper;  Lead;  Zinc.

Page 9Craig Farm Drum Superfund Site Third Five-Year Review June 2009



### Toxicological data for the majority of the or ganic COCs at the Site is scarce or does not exist. Therefore, Resorcinol was utili zed as a representative com pound based on the similarity of its structure to the other site-related organic COCs. The available toxicological data for Resorcinol indicates thatit is moderately toxic but is not considered a carcinogen. Benzene is the only known carcinogenic compound present at the Site.

Potential Migration Pathways

The potential COC m igration route analysis identified deep and shallow soils and groundwater as potential migrati on routes. This decision was based on the presence of detectable concentrations of Resorcinol, THD, m-PSA, p-PSA, and Cadmium in soil samples and the presence of detectable con centrations of all CO Cs in groundwater.

The evaluation eliminated surface water, se diments, and ambient air as potential migration routes. The decision to elimin ate surface water as a potential migration pathway was based on the lack of detection of COCs in Valley Run, which is considered the surface water body with potential human exposure pathways. The decision to eliminate sediments as a potential migr ation pathway was based on either the nondetection of COCs, non-repeatable detections of COCs, or suspect detections of COCs. Finally, COCs were not detected in ambi ent air above detection limits or background levels and none of the COCs are consider ed volatile compounds, thereby eliminating ambient air as a potential migration pathway.

Potential Human Exposure Pathways

The evaluation of potential hum an exposure pathways included the consideration of potential current and future us es of the Site. The Site is currently uninhabited and is restricted from recreational use. At the tim e of the ROD, the remoteness and steepness of the slope of the Site was anticipated to pr eclude any future commercial or residential development. Based on this evaluati on, the following potential human exposure pathways were developed fo r risk characterization:

 Incidental ingestion and dermal abso rption of COCs in surface soils by trespassers;  Dermal absorption of COCs in groundw ater by hypothetical future miners;  Incidental ingestion and dermal absorp tion of COCs in groundwater by future offsite domestic well users.

At the time of the ROD, the vapor intr usion exposure pathway was not evaluated, therefore, a screening evalua tion was conducted during this Five Year Review. COCs present onsite at high concentr ations consist primarily of Resorcinol and THD. During the RI/FS, the volatility of Resorcinol a nd THD was evaluated and both compounds were determined to be non-volatile. The only volatile compound historically detected onsite was Benzene. However, Benzene was detected at concentrations below the current Maximum Contaminant Level (MCL) of 5 μg /L in the overburden and upper bedrock

Page 10Craig Farm Drum Superfund Site Third Five-Year Review June 2009



### aquifer only, both of which discharge onsite to the Unna med Creek. Benzene was not detected in the lower sandstone aquifer in wh ich groundwater potentially migrates offsite. Additionally, Benzene has not been detected in onsite monitoring wells since 1987. Finally, as indicated previously, the Site is situated in an extremely rural area and the closest downgradient resident is located approximately 0.9 miles from the Site. Based on this screening evaluation, no potential vapor intrusion concerns exist at the Site and no further investigation is necessary.

Potential Environmental Exposure Pathways

The evaluation of potential environmental exposure pathwa ys included the potential im pact to terrestrial species inhabiting th e primarily wooded Site, amphibious species inhabiting the areas surrounding onsite surface water bodies, and aquatic organisms in Valley Run and the Unnamed Creek.

The evaluation concluded that Site wildlife could potentially be e xposed to site-related COCs by coming into contact with the seeps on the hillside located downgradient of the former disposal pits. Additionally, the lack of benthic macroinvertebrates in the Unnamed Creek indicates that aquatic life in this surface water body is being impacted by site-related COCs from the discharge of contaminants by the aforementioned seeps.

Risk Assessment

An exposure assessm ent and risk charact erization was conducted for each of the identified potential human exposure pathways . The COCs evaluated for each pathway varied based on predicted usage patterns. Th e following hazard indices were calculated for the receptor groups:

Receptor Pathway Non-Cancer Hazard Index Excess Individual Cancer Risk

Incidental Ingestion - Soil 3.28 x 10 -3 N/A

Dermal Absorption - Soil 0.07 N/A Trespassers

Total 0.07 N/A

Hypothetical Future Miners Dermal Absorption - Groundwater 0.43 1.39 x 10 -7

Incidental Ingestion 0.63 N/A

Dermal Absorption 1.39 x 10 -4 N/A Future Offsite Domestic Well User

Total 0.63 N/A

Page 11Craig Farm Drum Superfund Site Third Five-Year Review June 2009



### The total hazard indices calculated for each of th e potential receptors were less than 1, indicating that the estimated intakes for each r eceptor are less than threshold intake levels and that there is no appreciable ri sk of adverse health impacts.

The excess individual cancer risk to future miners, based on potential exposure to benzene in groundwater, was lower than the upper bound of the range recommended by EPA of 10 -4 

### to 10 -6 

### . Excess individual cancer risk was not calculated for future offsite domestic well users because potentially carci nogenic compounds are not present in the lower sandstone aquifer, which is the only aquifer that could potentially be developed for drinking water supply. This evaluation indica tes that there was no appreciable risk of cancer based on the evaluated exposure pathways.

The risk characterization indicated that the overall threat to human health posed by the Craig Farm Drum Site was negligible, prim arily due to the limited exposure likelihood based on the current and future Site uses. The evaluation of potential environmental exposure pathways indicated that aquatic life within the Unna med Creek is being impacted by site-related COCs. Therefore, th e selection of the remedy for the Site was based on the Site’s impact to the environm ent only, and not on the impact to human health. The Site was determined to present an imminent and substantial endangerment to the environment as set forth in Section 106 of CERCLA, 42 U.S.C. Section 9606.

IV. Remedial Actions

The ROD de fining the operable units and se lecting the final remedy for the Site was issued September 29, 1989. The goals of the reme dial action at the Site were defined in the ROD as follows:

 Minimize risk to public health and the environment from direct contact with contaminated material;  Control the migration of contamin ants into nearby surface waters;  Control the migration of cont aminants into groundwater.

The Final Close Out Report (FCOR) was issued on December 27, 1995 documenting completion of construction at the Site. Because the FCOR was issued prior to the current Close Out Procedures for National Priorities List Sites (OSWER Directive 9320.2-09AP, January 2000) guidance, it does not meet the current FCOR criteria. However, it is equivalent to the current Preliminary Clos eout Report (PCOR) in that it documents construction completion. Under the current guidance, an FCOR documents site completion, which has not yet been achieved at this site.

Page 12Craig Farm Drum Superfund Site Third Five-Year Review June 2009



### Definition of Operable Units

The operable units (OUs) at the Craig Farm Drum Site were identified as follows:

 Operable Unit #1 (OU-1)

o Distillation residue material in former disposal pits;

o Adjacent contaminated soils containing detectable concentrations (>50 parts per million (ppm)) of Resorcinol.

 Operable Unit #2 (OU-2)

o Remaining portions of former dispos al pit areas not included in OU-1;

o Overburden and adjacent soils that are analytically clean but need to be moved to access OU-1 materials;

o No remediation of OU-2 materials was necessary.

 Operable Unit #3 (OU-3)

o Seeps A and B, located downgradient of former disposal pits.

Remedial Action Objectives

The Remedial Action Objectives (RAOs) outlined in the ROD are as follows:

 Control contaminant migration offsite vi a containment of contaminated landfill soil and waste material;  Prevent offsite migration of site-related COCs and prevent site-related COCs from impacting the Unnamed Creek a nd onsite living organisms;  Prevent continued leaching of preci pitation and surface waters through contaminated landfill material;  Eliminate exposure to co ntaminated groundwater;  Minimize risk to human health and th e environment by eliminating potential direct contact exposure pathways.

Components of Remedy

The following remedy components were specified by the ROD:

 Excavation of 32,000 cubic yards of soil fr om the disposal pits and surrounding
areas;  Onsite solidification of excavated material;  Placement of the solidified material in an onsite RCRA equivalent, double lined, fenced landfill;  Wetland delineation and subsequent constr uction of a one-acre onsite wetland to replace wetlands destroyed in c onstruction of the onsite landfill;

Page 13Craig Farm Drum Superfund Site Third Five-Year Review June 2009



###  Im plementation of institutional cont rols alerting property owners of contamination;  Passive collection of ground water using a seep intercep tor system with offsite
treatment:

o Remediation considered complete by an alyzing water quality and toxicity of wastewater using a bioassay test for Resorcinol.  Monitoring of both onsite and offsite groundwater and surface water.

Remedy Implementation

The Consent Decree (CD) for the Site wa s entered on October 9, 1990. The Remedial Action (RA) at the Site began in May 1994 and was completed on December 27, 1995 and documented in an FCOR. As discussed ab ove, because it was issued prior to current guidance, the FCOR is the equivalent of a PCOR in that it documented construction completion rather than site completion. The summary of RA tasks is provided below:

 Excavation and onsite solidification of a to tal of 29,200 tons of material from the former disposal pits;  Backfilling of the former disposal pits with clean fill and seeding to produce a vegetative cover;  Placement of solidified soils in an onsite two-acre , double-lined, RCRAequivalent landfill consisting of the following components, from bottom to top in order of installation:

o Six-inch compacted clay sub-base;

o Geosynthetic clay liner (GCL);

o 60-mil high density polyethylene (H DPE) secondary geomembrane;

o PN-3000 Geonet leak detection zone;

o Four-ounce-per-square-yard non-wove n needle-punched geotextile;

o GCL (added to minimize potential leachate migration);

o 60-mil HDPE primary geomembrane;

o PN-3000 Geonet collection zone (for a dditional drainage and protection of primary geomembrane);

o Sixteen-ounce-per-square -yard non-woven needle-punched geotextile.  Installation of four (4) landfill monitoring wells around the landfill perimeter to monitor contaminant migration;  Installation of a fence around the landf ill perimeter to prevent disturbance;  Installation of collection tr enches upslope from and pe rpendicular to groundwater seep locations consisting of the following components:

o Sloped trench;

o Conducting zone comprised of perforated piping and gravel to collect and channel groundwater to th e collection sump at the low end of the trench;

o Sump pump with level control to pump collect ed groundwater to 40,000- gallon storage tank (ten ( 10) days of storage);

o Storage tank is emptied weekly by pu mp truck and transported offsite for
treatment.

Page 14Craig Farm Drum Superfund Site Third Five-Year Review June 2009



###  Constructio n of a one-acre wetland to replace the wetland destroyed during construction of the onsite landfill.

A Groundwater Verification St udy (GVS) was conducted during Remedial Design (RD) in July 1991 to determine if groundwater at the Site would require further remediation. The results of the GVS indicated that cont aminant levels in groundwater did not differ significantly from those detected during the RI and would therefore not pose a significant risk to human health. Based on the resu lts of the GVS, no additional groundwater remediation was recommended.

System Operations and Maintenance

Long-term monitoring and maintenance at the Site is conducted in accordance with the Operations and Maintenance Plan (O&M Pl an) submitted on July 14, 1993 and approved by EPA. The O&M Plan consists of the following components, conducted on a semiannual basis unless otherwise noted:

 Inspection of the landfill cap with regard to vegetative cover, settlement, stability, erosion, and to determine need for corrective action;  Inspection of the seep collection pi ping and tank includ ing the following:

o Clean out of caps and locks,

o Visual inspection of collection trench surfaces to repair erosion or vegetative cover damage.  Inspection of sediment basins to ensure adequate capacity;  Inspection of the condition of landfill monitoring and groundwater migration monitoring wells;  Groundwater sampling and analysis;

o Semi-annual sampling will continue until four (4) consecutive sampling events indicate COC concentrations are below detection limits, after which samples will be collected every five (5) years to coincide with Five-Year Reviews.  Surface water sampling and analysis on a quarterly basis for the first year following completion of construction, semi-annually for the second year, and annually during the third year. Additi onal sampling is conducted at EPA and Beazer’s discretion for the purposes of evaluating completion of the remedy;  Annual inspection of the engineered wetlands from 1997 through 2004 to assess weed control needs and the survival of pl antings to determine if the wetlands are meeting performance standards. Curren tly, wetlands inspections are conducted concurrently with Five Year Reviews.

The groundwater component of O&M consists of semi-annual sampling and analysis of four (4) landfill monitoring and nine (9 ) groundwater migration monitoring wells. Sampling began in 1999 and is currently c onducted by Field and Technical Services, LLC (FTS) on behalf of Beazer.

Page 15Craig Farm Drum Superfund Site Third Five-Year Review June 2009



### The landfill monitoring wells consist of upgr adient well LF-1 and downgradient wells LF-2, LF-3, and LF-4 (Figure 2). The purpos e of the wells is to monitor contaminant migration from the landfill to ensure that the landfill is functioning correctly.

The groundwater migration monitoring wells consist of MW-3A, MW-3B, MW-5A, and MW-5B located closest to the former dis posal pits and MW-14B, MW-15B, MW-15C, MW-19B, and MW-19C located further downgradie nt of the former disposal pits (Figure 2). Wells with an A designation are installe d in the overburden unconsolidated material, B designation wells are installed in the upper aquifer, and C designation wells are installed in the lower sandstone aquifer. Th e purpose of these wells is to ensure that groundwater contamination is not migrating offsite.

The surface water component of O&M consis ted of sampling the Unnamed Creek and water collected by the seep interceptor syst em on a quarterly basis following completion of construction, semi-annually for the second year, and annually during the third year. Since that time, the Unnamed Creek has not been sampled, Seep A has been sampled once (May 2006) and Seep B has been sampled twice (May 2006 and September 2008).

The ROD estimated that the annual cost for O&M is approximately $49,000.00 per year. At the time of the ROD, the total present worth of this alternative was approximately $3,807,000.00 assuming a thirty (30) year duration w ith a five (5) percent interest rate. Beazer has not furnished actual cost documentation.

V. Progress Since Last Five-Year Review

The Second Five-Year R eview was comple ted in June 2004. The Protectiveness Statement from that review indicated that the remedy at the Site is protective in the short term of human health and th e environment due to the comp letion of physical construction at the Site. However, the review indicated that in order for the remedy to be protective in the long-term, institutional controls must be implemented alerting Site owners of the contaminants onsite and prohibiting landfill a nd groundwater use will have to be put in place.

In addition to the lack of institutional cont rols, the Second Five Year Review identified the following issues:

 Damage to monitoring well caps and locks;  One (1) unlabeled drum identified in wetland area;  Seep collection tank volume indicator non-functional;  Two (2) unlabeled drums in seep collection tank area.

According to the undated “Addendum to Craig Farm Five Year Review,” the issues associated with the well caps and locks, unide ntified drums in the wetlands and adjacent to the seep collection tank, and the seep collection tank indicator were addressed on March 4, 2004. Institutional controls were implemented at the Site on September 23, 2004 and are attached herein as Attachment 1.

Page 16Craig Farm Drum Superfund Site Third Five-Year Review June 2009



### The landfill cap, seep interceptor system, and the monitoring wells have continued to be regularly inspected and maintained. Inspecti ons indicate that th e remedy continues to operate as intended.

In addition to onsite remedial action, the Site is located within the Bear Creek Area Chemical Site (BCACS), as defined by P ADEP pursuant to the Pennsylvania Hazardous Sites Cleanup Act (HSCA). On May 5, 2003, PADEP executed a Consent Order and Agreement (COA) with Beazer in which Beazer agreed to pa y the Commonwealth $18,118,813.00 to resolve its potential liability under HSCA fo r chemical releases to environmental media within the BCACS. The COA acknowledged PADEP’s commitment to implement the Operable Unit 2 Public Water Supply Remedial Response (Public Water Supply). Subsequent to 2003, PADEP executed contracts to construct a public water supply within the BCACS, to require communities therein, including Perry Township, Armstrong County, to implement a model ordinance proh ibiting the use of groundwater wells for potable water, and to require property owners to connect to the public water system. Construction of the publ ic water supply was completed in 2007 and all known residents within Perry Township in the vicinity of the Site are currently connected to the system.

Summary of Post-Remedy Studies

Currently, water collected by the System is tr ansported offsite for treatment to Beazer’s Petrolia Treatment Facility at the IND SPEC Chemical Corporation (INDSPEC) Plant located approximately 2 miles from the Site . Historically, groundwater from both the Craig Farm Site and the INDSPEC Plant was treated at the Petrolia Treatment Facility, however, groundwater from the INDSPEC Plant no longer requires treatment. Due to the relatively small volume of water treated from the Craig Farm Site compared to that treated from the INDSPEC Plant, operating the Petrolia Treatment Facility to treat only Craig Farm wastewater is not cost-effective.

Since the previous Five Year Review in 2004, the following studies have been conducted at the Site to evaluate water quality and alternat ive treatment technologies:

 Treatability Studies;  Seep A and B Water Quality Analysis;  Whole Effluent Toxicity Testing;  Water Balance Study.

The previously completed studies are summarized below.

Page 17Craig Farm Drum Superfund Site Third Five-Year Review June 2009



### Treatability Studies

From 1999 through 2005, multiple treatability st udies were conducted at the Site by Beazer to evaluate alternatives to the cu rrently implemented remedy of seep water collection and offsite treatment. A brief summ ary of the treatability studies is provided below:

Granular Activated Carbon Study

A 40-day, pilot-scale granular activ ated carbon (GAC) study was conducted by Therm oRetec in 1999. In this study, a GAC column pilot unit was installed at the Petrolia treatment facility c onsisting of two 4-foot long, 2-inch diameter glass columns containing two (2) feet of GAC per colum n. Water from the ex isting onsite seep collection tank was pumped though the system a nd sampled before and after treatment. The effluent sample was also submitted for toxicity analysis. The study indicated that toxicity was the rate-limiting factor for the us age of a GAC treatment system and that the system was not a feasible alternative remedy.

Aquamend Bioreactor Study

A bench-scale study was conducted by Adve ntus Am ericas, Inc. (AAI) in 2004 to determine the feasibility of replacing the offs ite treatment system with an onsite, in-situ, in-line bioreactor system. In this study, a bioreactor was in stalled in series with the onsite collection piping and coupled to a GAC unit. The study indicated that the bioreactor reduced COC con centrations, toxicity levels , and total organic carbon concentrations in the collected seep wate r. Based on Microtox IC50 testing conducted on the bioreactor system effluent, toxi city was reduced by a factor of 2.64.

Based on the results of the bench-scale study, a pilot-scale aerobic Aquamend bioreactor was installed in-line with th e onsite collection piping. Th e bioreactor’s influent and effluent were sampled on a monthly basis for total organic carbon, pH, temperature, dissolved oxygen, conductivity, turbidity, a nd oxygen reduction potential. The pilotscale bioreactor system reduced COC concentr ations, toxicity levels, and total organic carbon concentrations similar to those observed during the bench-scale study, however, according to Microtox IC50 testing, the pilot-sc ale test only reduced toxicity by a factor of 1.93 after three months of operation and m onitoring. This result indicated that the bioreactor system was not a feasible a lternative for treating the seep water.

Powdered Activated Carbon Treatment Study

A 50-day bench-scale powdered activated ca rbo n treatment (PACT) treatability study was conducted by U.S. Filter/Zimpro (Zimpro) in 2005. In this study, water from the seep interceptor system treated with a 100 mg/L dose of powdered activated carbon exhibited concentrations of p-PSA and THD below the method detection limit. However,

Page 18Craig Farm Drum Superfund Site Third Five-Year Review June 2009



### a chronic fathead minnow survival and growth bioassay indicated that a f ull-scale PACT system was not optimal for treating the seep water.

Seep A and B Water Quality Analysis

In May 2005, the seep interceptor system pi ping was flushed to remove residual solids and, in May 2006, water samples from both S eep A and Seep B were collected by Key Environmental. The sampling results indicated the presence of Resorcinol and THD in Seep A and THD in Seep B at concentr ations exceeding the respective laboratory reporting limits. The resorcinol concentration detected in Seep A was below the most conservative bioassay-based ambient water quality criteria (AWQC) developed for Beazer by AMEC Earth & Environmental, Inc. (AMEC). No bioassay criteria have been developed for THD.

Following the sampling, on March 7, 2007, Beazer and its representatives met with PADEP to discuss the submission of a rulemaking petition to the Pennsylvania Environmental Quality Board to request th e promulgation of the AMEC AWQC under 25 Pa. Code Chapter 16 for sulfonates and Reso rcinol. A copy of the AWQC development report was submitted to Denise Hakowoski of US EPA Region III Water Quality Division following the meeting.

Whole Effluent Toxicity Testing

The sam ples collected from Seeps A and B in May 2006 by Key Environmental were also submitted for a 7-day fathead minnow w hole effluent toxicity (WET) test using a series of nine (9) effluent dilutions ra nging from 100% (no dilution) to 0.5% (200x dilution) with an endpoints evaluation for growth and survival.

Based on the results of the testing, the no obser ved effect concentration (NOEC) for Seep A effluent was 25% (4x dilution) and the half maximal effect concentration (EC50) was estimated to be 32%. The acute and chroni c toxicity of Seep A using the growth endpoint both exceed the PADEP WET screening criteria.

The results of the testing c onducted on the Seep B effluent indicated an observed NOEC of 100% (no dilution). Both the acute and ch ronic toxicity of the Seep B samples were below the PADEP WET toxicity screening crit eria. Based on this result, additional sampling was recommended and implemented as described under the Focused Feasibility Study section of this document to confirm that Seep B water remains below toxicity screening criteria.

Water Balance Study

Langan Engineering and Environm ental Serv ices (Langan) conducted a water balance study at the Site from May through June 2006. The study consisted of the collection of site-wide groundwater elevation data and st ream flow velocity measurement in the

Page 19Craig Farm Drum Superfund Site Third Five-Year Review June 2009



### Unnamed Creek and Valley Run and flow velocity m easurement in Seep A and B collection trenches. The field measurements i ndicated that the averag e flow velocity of Seep A was 5.4 gallon per minute (gpm) and the average flow velocity of Seep B was 0.42 gpm.

Focused Feasibility Study

From March 2007 through September 2008, Beazer conducted a Focused Feasibility Study (FFS) to evaluate additi onal remedial alternatives fo r the wastewater collected by the seep interceptor system (OU-3).

A Focused Feasibility Study Work Plan (FFS Work Plan) was submitted to EPA by Langan on March 29, 2007 and implemented from September 2007 through January 2008. The results of the init ial investigation were presented to EPA on February 28, 2008 and data from the investigation was submitted to EPA on April 10, 2008. The following provides a brief summary of the FFS Work Plan tasks:

 Installation of 16 groundwater monitoring we lls, 11 stream gauges, a precipitation gauge, a flow meter in Seep A, and pressure transducers;  Site-wide groundwater and surface water gauging;  Survey and sampling of 28 onsite wells for site-related COCs;  WET testing of Seep B water;  Hydraulic analysis and deve lopment of water budget.

A Conceptual Site Model (CSM) was developed with the data collected during the initial investigation and conclusions of th e model are summarized as follows:

 Direct correlation of rainfall with flow in Seep A collection trench;  Seasonal fluctuation of overburden (appr oximately 5 ft) and shallow bedrock (approximately 1.5 feet) water tables;  Overburden groundwater flow is connect ed to the Unnamed Creek during wet periods but there is no flow in the Unnamed Creek during dry periods;  Shallow bedrock groundwater is no t linked to the Unnamed Creek;  Downward vertical grou ndwater flow gradient;  Groundwater flow toward Unnamed Creek (west) in both overburden and shallow bedrock aquifers;  Preferential flow pathways ma y exist in overburden groundwater;  COC concentrations are highest in overburden and deep bedrock;  Seep A drainage area is approximately 10 acres and Unnamed Creek drainage area is approximately 120 acres;  Trench flow equivalent to approximately 1.5 acres;  No observed toxicity in Seep B wate r samples during two (2) consecutive sampling events.

Page 20Craig Farm Drum Superfund Site Third Five-Year Review June 2009



### Based on the data from the initial investig ation, an Addendum to Focused Feasibility Study W ork Plan (FFS Work Plan Addendu m) was submitted to EPA by Langan on May 6, 2008 and approved on June 19, 2008. The fo llowing provides a brief summary of the FFS Work Plan Addendum tasks:

 Installation of one (1) pe rmanent shallow bedrock groundwater monitoring well upgradient of the former northern disposal pit area;  Borehole video logging of select exiti ng deep bedrock groundwater monitoring wells;  Aquifer loading test in the Seep A stu dy area consisting of adding potable water to an existing deep bedrock groundwater monitoring well;  Topographic survey of the Seep A dr ainage area and new wells to NAV 88 datum;  Installation of test pits in select ons ite areas (“borrow areas”) to determine suitability of material for use in a synthetic cap.

Although test pit installation was included in the FFS Work Plan Addendum, this task had not been completed at the time of this Five Year Review and will instead be conducted during Remedial Desi gn for the remedy modification.

The results of the Focused Feasibility Study were presented to EPA in the December 11, 2008 “Focused Feasibility Study Report” (FFS Report) and in a December 16, 2008 meeting. EPA issued comments on the FFS Report on February 17, 2009, which Langan addressed in the May 6, 2009 “R evised Focused Feasibility Study Report” (Revised FFS Report).

The FFS Report/Revised FFS Report evaluated the following remedial alternatives:

 Alternative 1 – Continuation of Seep Interceptor and Treatment Systems;  Alternative 2 – Continuation of Seep Interceptor and Offsite Disposal;  Alternative 3 – Capping and Infiltra tion of Upgradient Groundwater.

The evaluation of the alternatives identified Alternative 3 – Capping and Infiltration of Upgradient Groundwater as the preferred re medy modification. This proposed remedy modification consists primarily of the following components:

 Installation of an impermeable cap on the 3-acre, former north pit area comprised of the following:

o Geotextile mat on ground surface;

o 60-mil HDPE geomembrane liner;

o Single-sided geocomposite consisting of geonet and geotextile for drainage;

o Minimum 2-feet of clean fill with vegetation.  Excavation/fill of existing ground surface in vicinity of former north pit to required grade;

Page 21Craig Farm Drum Superfund Site Third Five-Year Review June 2009



###  Installation of bioswales or other infiltration features to direct flow from capped
area;  Installation of groundwater dr ain system upgradient of the former north pit to prevent upgradient groundwater fl ow through north pit materials;  Continued maintenance of the Seep A co llection trench, piping, and storage tank to collect contaminated overburden groundwater;  Treatment of collected Seep A water at an alternative offsite treatment facility;  Decommissioning of the Seep B collection tr ench by closing valves such that the system no longer collects water.

Additional proposed O&M associated with the remedy modificati on consists of the following tasks:

 Removal and offsite disposal of leachate from the onsite landfill;  Semi-annual gauging of onsite groundwater wells;  Annual inspection of the cap, bioswales, onsite landfill, existi ng Seep A collection system, former north and south pit areas , aboveground storage tank, and ancillary facilities.

Based on the results of EPA-approved bi oassay testing, Seep B has achieved the performance standard specified in the ROD and no longer exhi bits toxicity. Therefore, no further remedial action was determined to be necessary for the collection and treatment of Seep B water. Beazer has pr oposed to decommission the Seep B collection trench via the closure of valv es so that the system no longe r collects water, however, the collection trench will remain in place as a contingency measure.

Implementation of this remedy modification will be more cost effective than the continued operation of the Petrolia Treatment Facility. Total cost to implement the remedy is estimated to be approximately $1,078,754.00. This cost estimate may change based on the amount of water that continues to flow to the Seep A collection trench requiring alternative offsite treatment.

EPA is currently evaluating the proposed re medy modification and the final components of the remedy and O&M are subject to change . If the modification is approved, EPA will issue an Explanation of Significant Differen ces (ESD) and Beazer will submit a Remedial Design Work Plan to EPA and PADEP prior to implementation.

VI. Five-Year Review Process

Administrative Components

The Craig Farm Five Year Review team was led by John Epps, EPA Remedial Project Manager (RPM) for the Craig Farm Drum Superfund Site. Mindi Snoparsky, EPA Hydrologist, Annette Paluh and Barbara G unther, Project Officers for PADEP, and Kathleen Patnode, Biologist for the U.S. Fish and Wildlife Service comprised the remainder of the team.

Page 22Craig Farm Drum Superfund Site Third Five-Year Review June 2009



### The Site inspection occurred on Septem ber 3, 2008 and was conducted by the team (with the exception of Ms. Snoparsky) with Jane Patarcity from Beazer and Jason Hanna of Langan Engineering and Environmental Servic es (Langan), environmental consultants for Beazer.

Community Involvement

EPA RPM John Epps conducted community interv iews door-to-door with residents in the immediate vicinity of the Craig Farm Drum Site. One resident was interviewed and indicated they were pleased w ith the remediation of the Site . Additionally, notice of the review was provided to Perry Township via te lephone, letter, and a vi sit to the township office but no response was received.

An advertisement explaining the Five Year Review process, providing point of contact information, and identifying the location of information repositories for the Site was placed in the September 3, 2008 edition of the Butler Eagle Newspaper. In response to the newspaper advertisement, one comment was received from an area resident via email. The resident indicated they hunt deer in the vi cinity of the Site and are pleased with the improvement in water quality within the Unnamed Creek.

Another notice will be sent to the same newspaper to announce that the Five Year Review report for the Craig Farm Drum S ite has been completed. Information on the results of the review and the report availa bility will be included in the announcement.

Community Involvement materials are included in Attachment 2.

Document Review

The Five Year Review consisted of a review of the following rele vant documents, listed with the pertinent informati on contained in each report:

 Remedial Investigation and Feasibility Study;

o Risk assessment results.  

### Record of Decision;

o 

### RAOs,

o ARARs,

o Cleanup goals.  

### Final Close-Out Report;

o 

### Equivalent to PCOR under current guidance;

o 

### RA summary.  

### First and Second Five Year Review Reports;

o 

### Past issues with and prot ectiveness of Site remedy.  

### Addendum to Craig Farm Five Year Review;

o 

### Resolution of issues identified in Second Fiver Year Review Report,

o Attached Deed Restriction document.

Page 23Craig Farm Drum Superfund Site Third Five-Year Review June 2009

 

### Operations and Maintenance Plan fo r the Craig Farm Remediation Site;

o 

### RA summary.  

### Historic Annual Wetland Mitigation Assessment Status Reports from PADEP;

o 

### Status of manufactured wetlands area.  

### Quarterly and Semi-Annual Groundwater Monitoring Reports;

o 

### Groundwater quality data.

The ROD for the Site requires that institutional controls be placed on the Site to preserve the remedy. According to the undated “Addendum to Craig Farm Five Year Review,” prepared after the June 2004 Second Five Y ear Review, institutional controls were implemented at the Site on September 23, 2004. The institutional controls consisted of the following restrictions:

 No groundwater beneath the Site may be used and no wells may be installed on the Site for human consumption, irrigation, or other purpose that may bring it into contact with humans, excep t for testing purposes as required by law, remedial action/design, or the terms of the Consent Decree;  No structure may be placed on the Site that would disturb th e cap or stabilized contents of the landfill or would otherwis e disturb any component of the remedial action/design without prior written a pproval of the Site owner and EPA;  The Site may not be used for the purpos es of living, dwelling, or overnight accommodations of any type;  No action may be taken that will inte rfere with, obstruct, or disturb the performance of any remedial response, including O&M;  

### Any Site owner must provide any purchas er with notice of the terms of the Consent Decree prior to transferring any interest in the Site.

However, the institutional controls are only di scussed in the declar ation of the ROD and not in the remedy selection portion. Additi onally, the ROD requires deed notices only and not the deed restrictions that are curren tly implemented at the Site. Due to these issues, the institutional controls are considered to be insufficiently documented. In order to correct these inconsistencies, EPA will issue an ESD to clarify the requirements for the institutional controls and ensure that they rema in in place. The deed restrictions currently implemented at the Site are included as Attachment 1.

Data Review

Data available for review for the Site consis ts of inspection reports regarding the onsite landfill, the wetland mitigation reports prep ared by PADEP, and groundwater monitoring data collected from the onsite monitoring we ll networks and seep interceptor system.

Page 24Craig Farm Drum Superfund Site Third Five-Year Review June 2009



### Inspections

Inspections of the onsite landfill (OU-1) have indicated that the landfill cap is functioning correctly and the fence surrounding the prope rly is in good condition. Additionally, an inspection of the seep interceptor system i ndicated the system is functioning properly.

The historic annual PADEP wetlands inspecti ons indicated that the condition of the wetland mitigation area ranged from good to ex cellent. The hydrophytic vegetation was diverse and hydrology had been very good to excellent. Additionally, muskrat, ducks, bullfrogs, spring peepers, red- winged blac kbirds, deer, herons and various songbirds have been observed in the mitigated wetland. PADEP’s and the Fish and Wildlife Service’s inspection conducted dur ing the site visit component of this Five Year Review confirmed the historic findings.

Groundwater Monitoring Data

Groundwater sam ples were collected from each of the landfill monitoring wells from February 1999 through March 2008. The landfil l monitoring wells c onsist of upgradient well LF-1 and downgradient wells LF-2, LF- 3, and LF-4. Downgradient landfill well data indicates a decreasing tr end in site-related COC concentrations from 1999 through 2008. Data and graphs for monitoring wells are included as Attachment 3.

Groundwater samples have been collected from each of the groundwater migration monitoring wells from February 1999 th rough March 2008. The groundwater migration monitoring wells consist of MW-3A, MW-3B, MW-5A, AND MW-5B located closest to the former disposal pits and MW-14B , MW-15B, MW-15C, MW-19B, and MW-19C located further downgradient of the former dis posal pits. Wells with an A designation are installed in the overburden unconsolidated mate rial, B designation wells are installed in the upper aquifer, and C designati on wells are installed in the lower sandstone aquifer.

Groundwater migration monitoring well data ge nerally indicates a decreasing trend in site-related COC concentrations from 1999 through 2008, however, multiple wells exhibited constant concentra tion trends or anomalous results, as summarized below.

In monitoring well M-03B, although the Reso rcinol concentration has decreased with respect to historic levels, the concentration has remained relatively constant, with only minor fluctuations, since 2003. Additionally, a similar trend was observed in the THD concentrations detected in this well, where th e levels have remained relatively constant since 2005.

The Resorcinol and THD concentrations have also remained relatively constant in M05A since 2006. However, prior to 2006, THD concentrations exhibited large fluctuations between sampling events, de clining from 811 mg/L to 28 mg/L from

Page 25Craig Farm Drum Superfund Site Third Five-Year Review June 2009



### November 2001 to April 2002, then increasing to 599 mg/L in June 2005. This well has not been sampled since June 2007, due to insufficient water.

In M-05B, the p-PSA concentration has re m ained relatively constant throughout the monitoring period since the well was first sa mpled in 2003. The THD concentration has also been relatively constant during monitori ng remaining below or close to the detection limit of 0.05 mg/L, with the exception of an anomalous concentration of 7,520 mg/L detected in June 2006.

In M-15C, p-PSA has historically been non-detect or present at con centrations close to the detection limit of 0.05 mg/L. However, during the November 2007 sampling event, p-PSA was detected at a concen tration of 65.2 mg/L and has been detected in three (3) of the previous four (4) sampling events after being detected on ly three (3) of the previous 17 sampling events.

An anomalous THD concentration of 2,590 mg /L was reported in M-19B during June 2006. Throughout the remainder of the mon itoring period, THD was only reported above the detection limit of 0.05 mg/L in one (1) out of 22 sampling events.

Both the Resorcinol and THD concentrati ons in MW-19C have remained relatively constant since monitoring began in 1999, although a slight decline in both compounds has been observed since Marc h 2007 with respect to hist oric high concentrations.

Surface Water Monitoring Data

Routine surf ace water monitoring is no longe r required at the Site. Sampling was required by the ROD on a quarterly basis fo r the first year following completion of construction, semi-annually for the second year, and once during the third year. Subsequent sampling was to be conducted at EPA and Beazer’s discre tion to determine if the remedy was complete.

In May 2006, as a component of treatability studies conducted on the seep interceptor system, the piping system was flushed to rem ove residual solids and water samples from both Seep A and Seep B were collected by Key Environmental. The sampling results indicated the presence of Re sorcinol and THD in Seep A and THD in Seep B at concentrations exceeding the respective laboratory reporting limits. The resorcinol concentration detected in Seep A was below the most conservative bioassay-based AWQC. No bioassay criteria ha ve been developed for THD.

The samples collected from Seeps A and B in May 2006 by Key Environmental were also submitted for a 7-day fathead minnow w hole effluent toxicity (WET) test using a series of nine (9) effluent dilutions ra nging from 100% (no dilution) to 0.5% (200x dilution) with an endpoints evaluation for growth and survival.

Page 26Craig Farm Drum Superfund Site Third Five-Year Review June 2009



### Based on the results of the testing, the no obser ved effect concentration (NOEC) for Seep A effluent was 25% (4x dilution) and the half maxim al effect concentration (EC50) was estimated to be 32%. The acute and chroni c toxicity of Seep A using the growth endpoint both exceed the PADEP WET screening criteria.

The results of the testing c onducted on the Seep B effluent indicated an observed NOEC of 100% (no dilution). Both the acute and ch ronic toxicity of the Seep B samples were below the PADEP WET toxicity screening crit eria. An additional sample was collected from Seep B in January 2008, indicating the same result. Based on these results, Langan recommended no further action for Seep B as a component of a proposed remedy modification. EPA is currently reviewing th e proposed modificati on, and, if approved, will document the change in an ESD.

Vapor Intrusion Pathway Evaluation

As discussed in the Potential Human Exposure Pathways Section of this document, at the time of the ROD, the vapor intrusion e xposure pathway has not previously been evaluated, therefore, a screen ing evaluation was conducted duri ng this Five Year Review. COCs present onsite at high concentrations consist primarily of Resorcinol and THD, both of which were determined during the RI/FS to be non-volatile. Historically, the only volatile COC at the Site was Benzene. However, Benzene was detected only sporadically during the RI/FS and has not been detected in onsite wells since 1987. Additionally, Benzene has never been detected in the deep sandstone aquifer, the only onsite aquifer in which groundwater potentially migrates offsite. Finally, as indicated previously, the Site is situated in an extremely rural area and the closest downgr adient resident is located approximately 0.9 miles from the Site. Ba sed on this screening evaluation, no potential vapor intrusion concerns exis t at the Site and no further investigation is recommended.

Site Inspection

The Craig Farm Drum Site inspection wa s conducted on September 3, 2008. The onsite inspection team consisted of John Epps, EPA RPM for the Site, Annette Paluh and Barbara Gunther, Project Officers for PADEP, Kathleen Patnode, Biologist for the Fish and Wildlife Servise, Jane Patarcity of Beazer , and Jason Hanna of Langan, consultant to Beazer.

The Site inspection consisted of a visual inspection of the cap, seep interceptor system, and wetlands area. All of the inspected com ponents appeared to be in good condition and no issues or deficiencies we re observed. The Site inspection checklist is included as Attachment 4.

Interviews

EPA RPM John Epps conducted community interv iews door-to-door with residents in the immediate vicinity of the Craig Farm Drum Site. One resident was interviewed and

Page 27Craig Farm Drum Superfund Site Third Five-Year Review June 2009



### indicated she was pleased with the remediati on of the Site. Additionally, notice of the review was provided to Perry Township via te lephone, letter, and a vi sit to the township office but no response was received.

No interview was requested by the Butler Eagl e newspaper as a result of the publication of the Five Year Review public notice

Jane Patarcity, RP representative, and Jason Hanna, RP consultant project manager were interviewed by EPA RPM John Epps regarding the implementation of institutional controls and continued O&M activ ities at the Site. The interviews indicated that there have been no issues associated with maintain ing institutional contro ls at the Site. Mr. Hanna also indicated that, at the time of th e interview, remedial alternatives for OU-3 were being explored via a Focused Feasibili ty Investigation. In terview summary sheets are included as Attachment 5.

VII. Technical Assessment

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

Yes. Based on a review of available docum ents, ARARs, and the resu lts of the Site inspection, the physical remedy is functioni ng as intended by the ROD. Additionally, institutional controls identifying contaminants present onsite and restri cting the use of the landfill and groundwater have been impleme nted, thereby preserving the long-term protectiveness of the remedy.

However, as discussed previously, the requirements for institutional controls are insufficiently documented in the ROD, therefore, EPA will issue an ESD to clarify the requirements for the controls and ensure that they remain in place.

The landfill and cap have achieved the reme dial objectives to control contaminant migration offsite, to prevent impacting th e Unnamed Creek and living organisms onsite, and to prevent continued leaching of pr ecipitation and surface water onsite through contaminated landfill material. Currently, the passive collection of seeps by the seep interceptor system and subsequent offsite tr eatment has prevented e xposure of humans to contaminated groundwater and migration of contaminated water to the Unnamed Creek, as outlined in the ROD.

A proposed remedy modification, consisting of an impermeable cap, continued operation of the seep interceptor system, and decommi ssioning of the Seep B collection trench, will continue to achieve the remedial objectives described above. The Seep A collection trench will remain in place and continue to operate until testing indicates that the collected water no longer exhibits toxicity. EPA is currently evaluating this modification and, if approved, will issue an ESD to document the decision.

Page 28Craig Farm Drum Superfund Site Third Five-Year Review June 2009



### O&M of the landfill cap, seep interceptor system, and replacement wetlands has been ef

fective. The Site inspection did not iden tify any issues which would compromise the integrity of the landfill cap or the physic al protectiveness of the remedy. O&M annual costs are consistent with the original estimates when corrected for inflation.

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

Yes. There have been no changes to the Si te that would impact exposure or toxicity assumptions and calculations as presented in the ROD. The remedy has progressed as expected and RAOs continue to be met. Additionally, the following ARARs identified in the ROD continue to be met:

 Pennsylvania Water Quality Criteria (OU-1);  Clean Stream Law (OU-1);  Wetlands Management Act (OU-1);  Pennsylvania Solid Waste Management Act (OU-1);  Clean Water Act (OU-1);  National Primary Drinking Water Standards (OU-3);  National Secondary Drinking Water Standards (OU-3);  National Water Quality Criteria (OU-3);  Executive Order on Protection of Wetlands (OU-3).

Additional ARARs were require d to be met during the construction phase of the remedy but are no longer relevant to the Site. The above ARARs will continue to be met following the remedy modification, with the addition of the following item:

 Underground Injection C ontrol Program (OU-3);  Pennsylvania Clean Stream Law (re lating to groundwater - OU-3);  Pennsylvania Erosion and Sediment ation Pollution Control (OU-3).

As previously noted, to eliminate the pot ential exposure pathway for contaminated groundwater, Beazer agreed to fund the cons truction of a public drinking water supply system for residents in the vicinity of the BCACS, including the Craig Farm Site. Construction of the system began in 2003 and was completed in 2007. PADEP also required communities within the BCACS, in cluding Perry Township, to implement a model ordinance. The model ordinance prohib its the use of groundwater wells within the BCACS for potable water and requires propert y owners to connect to the public water system.

A vapor intrusion exposure pathway evaluati on was conducted for this Site during this Five Year Review. The results of the ev aluation indicate that the vapor intrusion pathway is not a concern, primarily due to th e lack of volatile compounds in onsite soil or groundwater.

Page 29Craig Farm Drum Superfund Site Third Five-Year Review June 2009



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

No. The rem edy continues to be protective a nd has been enhanced since the most recent Five Year Review by the implementation of institutional controls in September 2004 to further limit potential exposure. Currently, the requirements for the institutional controls are insufficiently documented by the ROD, a nd, as discussed above, EPA will prepare an ESD to correct this issue. However, because institutional controls are currently required by the declaration section of the ROD, by th e CD, and are in place and effective, the remedy is considered protective in the long-term

A dditionally, a proposed remedy modification currently under review by EPA is expected to further enhance the remedy by reduci ng the amount of contaminated shallow groundwater generated at the Site for disposal.

VIII. Issues

Issues Affects Current Protectiveness (Y/N) Affects Future Protectiveness (Y/N)

1 Requirements for institutional controls are insufficiently documented by the ROD. N N



### IX. Recommendations and Follow-up Actions

Affects Protectiveness (Y/N) Issue Recommendations and Follow-up Actions Party Responsible Oversight Agency Milestone Date
Current Future

1 ESD to fully document requirement for institutional controls. EPA N/A December 2009 N N



### Additionally, EPA is currently reviewing B eazer’s proposal for a remedy modification. If approved, the modification will be docum ented in the aforementioned ESD and Beazer will prepare a Remedial Design Work Plan. A summary of any additional information relevant to this Five-Year Review will be included in an addendum to this report.

X. Protectiveness Statement

The rem edy at the Craig Farm Drum Site is protective of human health and the environment in the short and long term. Physical construction is complete and institutional controls have been implemented.

Page 30Craig Farm Drum Superfund Site Third Five-Year Review June 2009

Page 31 

### Protection of human health and the environm ent has been achieved by the installation of a RCRA-equivalent landfill to contain waste (OU-1) and a seep interceptor system to collect contaminated groundwater for offsite treatment (OU-3). Additionally, protection of human health is enhanced due to the loca tion of the Site within the BCACS, in which all residents are required to connect to public water. Currently, design is underway for the modification of the seep interceptor system by the addition of an impermeable cap and groundwater infiltration system to reduce overburden groundw ater flow through contaminated material, further enhancing the protectiveness of the remedy. Finally, the remedy is protective of both human health a nd the environment in the long-term due to the implementation of institutional controls alerting current and future Site owners of the contaminants onsite and restri cting landfill and groundw ater use. The requirements for the institutional controls at the Site will be cl arified in an ESD to further ensure long-term protectiveness.

XI. Next Review

The next Fiv e-Year Review for the Craig Farm Drum Superfund Site is required by June 19, 2014, five years from the date of this review.

# FiguresCraig Farm DrumSuperfund SiteUS EPAREGION III1650 Arch StreetPhiladelphia, Pennsylvania 19103Figure 1Site Location MapApproximateSite LocationCraig Farm DrumSuperfund SiteUS EPAREGION III1650 Arch StreetPhiladelphia, Pennsylvania 19103Figure 2Site PlanAdapted from Langan Figure 2 Site PlanAerial photograph provided by PAMAP Program 2005Color Orthophoto of Pennsylvania

# Attachment 1 – Institutional Controls

## DECLARATIO N O F RESTRICTION S

THI S DECLARATIO N O F RESTRICTION S i s mad e thi s 23r d da y o f Septembe r

200 4 b y Beaze r

East

, Inc

. (formerl y know n a s Kopper s Company

, Inc.)

, a Delawar e corporation

, havin g a n addres s o f On e Oxfor d Centre

, Suit e 3000

, Pittsburgh

, P A 15219-640 1 (th e "Declarant")

.

WITNESSTH :

WHEREAS

, Kopper s Company

, Inc

. acquire d i n thre e separat e transaction s propert y locate d i n Perr y Township

, Armstron g County

, Pennsylvani a mor e particularl y describe d i n Exhibi t

A attache d heret o an d mad e a par t hereo f (suc h rea l propert y bein g hereinafte r

referre d t o a s th e "Site" ) by : (1 ) dee d o f Januar y 5

, 197 2 fro m Herma n G

. Crai g an d Bett

y L

. Crai g t o Declaran t

an d recorde d i n th e Offic e o f th e Recorde r

o f Deed s o f Armstron g County

, Pennsylvania

, i n Dee d Boo k Volum e 53 8 beginnin g a t Pag e 244 ; (2 ) dee d o f

Februar y 27

, 198 5 fro m Herma n G

. Crai g t o Declaran t an d recorde d i n th e Offic e o f

th e Recorde r

o f Deed s o f Armstron g County

, Pennsylvania

, i n Dee d Boo k Volum e 65 3 beginnin g a t Pag e 31 ; an d (3 ) dee d o f Jun e 13

, 198 5 fro m Car l E

. Switze r and Charlen e Switze r

to Declaran t

and recorde d in the Offic e of the Recorde r

of Deed s of Armstron g County

, Pennsylvania

, i n Dee d Boo k Volum e 66 9 beginnin g a t Pag e 215 ;

WHEREAS

, beginnin g i n 195 8 a wast e haule r fo r Kopper s use d th e Sit e t o dispos e o f

industria l wast e fro m Koppers ' manufacturin g plan t i n Petrolia

, Pennsylvania

, includin g hazardou s wast e fro m th e productio n o f rcsourcino l and"constituent s thereof ;

WHEREAS

, i n 1989

, Kopper s Company

, Inc

. change d it s nam e t o Beaze r Material s an d Services

, Inc

. an d i n 1990

, Beaze r Material s an d Services

, Inc

. change d it s

nam e t o Beaze

r East

, Inc. ;

WHEREAS

, i n Ma y o f

1990

, a Consen t

Decre e wa s signe d an d entere d wit h th e Unite d State s Distric t

Cour t fo r th e Wester

n Distric t

o f Pennsylvani a addressin g implementatio n o f

a Remedia l Desig n an d Remedia l Actio n ("RD/RA" ) a t th e Sit e an d
paymen t o f certai n respons e costs ;

WHEREAS

, pursuan t

t o th e Consen t

Decree

, Declaran t

ha s implemente d th e RD/R A a t

th e Site

, an d a s par t

o f th e remedia l actio n Declaran t create d a landfil l t o contai n th e hazardou s wast e tha t wa s dispose d on-sit e ("th e Landfill") ;

WHEREAS

, th e Consen t Decre e fo r

th e Sit e require s implementatio n o f institutiona l control s restrictin g futur e us e o f th e Site

, whic h control s ma y includ e restrictiv e covenants ; an d

WHEREAS

, i t

i s i n th e intentio n o f

Declaran t

t o creat e restriction s o n th e Sit e tha t wil l ru n wit h th e lan d an d bin d futur e owners, tenants , subtenants

, licensee s o r othe r user s

o f an y an d ai l portion s o f

th e Site

.NOW

, THEREFORE

, Declaran t hereb y impose s th e followin g restriction s o n th e Site

, whic h shal l b e enforceabl e b y Declaran t an d it s successor s an d assigns

, th e Environmenta l Protectio n Agency

, th e Pennsylvani a Departmen t o f Environmenta l Protectio n Agenc y an d al l othe r governmenta l agencie s wit h jurisdictio n ove r th e environmenta l condition s o n th e Site

.

1

. Purpose s

Th e purpos e o f

thi s Declaratio n i s t o restric t certai n us e an d developmen t activitie s a t

th e Sit e s o a s t o preven t an y use s o f

th e Sit e whic h woul d b e inconsisten t

wit h th e RD/R A fo r

th e Sit e an d creat e a ris k t o huma n healt h o r

th e environmen t

an d t o fulfil l Declarant' s commitment s unde r th e Consen t

Decree

.

2

. Specifi c Prohibition s

(a ) N o groundwate r

underneat h th e Sit e ma y b e use d fo r huma n consumption

, irrigatio n o r

othe r purpose s tha t

migh t brin g i t int o contac t

wit h human s (excep t fo r testin g purpose s require d b y law

, th e RD/R A o r th e term s o f

th e Consen t Decree ) an d neithe r

th e owner , occupan t

no r an y othe r

use r o f th e Sit e shal l dril l o r

instal l an y well s o n th e Sit e fo r th e purpos e o f

extractin g groundwate r

underneat h th e Sit e fo r

huma n consumption

, irrigation

, o r othe r purpose s tha t

migh t brin g i t int o contac t

wit h human s (excep t

fo r testin g purpose s a s require d b y law

. th e RD/R A o r th e term s o f

th e Consen t Decree)

.
(b ) N o building

, structur e o r othe r objec t shal l b e buil t

o r place d o n th e Sit e tha t woul d distur b th e ca p o r stabilize d content s o f

th e Landfil l o r

woul d otherwis e distur

b an y componen t

o f th e RD/R A a t

th e Sit e withou t

th e prio r writte n approva l o f

Declaran t

o r it s successor s an d assign s an d th e Environmenta l Protectio n Agency

.
(c ) Th e Sit e shal l no t

b e use d fo r

th e purpose s o f

persona l living

, dwelling

, o r overnigh t accommodations

, whethe r suc h use s ar e i n singl e famil y residences

, apartments , duplexe s o r othe r multipl e residentia l dwellings

, trailers

, traile r

parks

, campin g sites

, hotels

, motels

, o r an y othe r

dwellin g

us e o f an y kind

, o r

fo r chil d care , schools

, park s o r othe r nomndustna l uses , b y th e owne r

o r occupan t o f th e Site

, o r

anyon e occupyin g th e Sit e wit h th e permissio n o f

th e owne r

o f th e Site

. (d ) N o actio n shal l b e take n a t th e Sit e t o interfer e with

, obstruct

, distur b th e performance

, suppor t

o r supervision s o f

an y remedia l respons e action s take n

o r t o b e take n a t

th e Site

, includin g an y operatio n o r maintenanc e activities

.
(e ) An y subsequen t

owne r o f th e Sit e shal l provid e a purchase r wit h notic e o f th e term s o f

th e Consen t

Decre e prio r

t o transferrin g an y interes t i n th e Site

.3

. Acces s

Th e employees

, agent s an d contractor s o f th e Declaran t

an d it s successor s an d assign s shal l hav e th e righ t o f ingres s an d egres s fro m an d movemen t o n th e Sit e sufficien t t o conduct

, maintain

, monito r an d secur e th e integrit y o f th e remed y se t fort h i n th e RD/RA

, t o tak e othe r action s require d o r

authorize d unde r

applicabl e federa l an d stat e law s an d t o monito r an d enforc e complianc e wit h th e term s o f thi s Declaration

. Declaran t acknowledge s that

, notwithstandin g an y othe r provisio n o f

thi s Declaration

, th e Environmenta l Protectio n Agenc y retain s al l o f it s acces s authoritie s an d rights

, a s wel l a s it s righ t t o requir e land/wate r

us e restrictions

, includin g enforcemen t authoritie s relate d thereto

, unde r applicabl e statute s and/o r

regulations

.

4

. Enforceabilit y

(a ) Th e covenants , condition s an d restriction s o f thi s Declaratio n shal l b e enforceabl e b y Declaran t

an d it s successor s an d assigns

.
(b ) Such covenants , condition s an d restriction s shal l ru n wit h th e land

, shal l b e bindin g upo n an y an d al l successor s i n interests

, an d al l assignees, lessees

, sub-lessees

, operators , tenants , licensees

, agent s an d an y an d al l person s wh o acquir e an y interes t

i n th e Site

.
(c ) Violatio n o f

covenants , condition s an d restriction s containe d herei n shal l giv e Declaran t

an d it s successor s an d assign s i n additio n t o al l othe r remedies

, th e righ t

t o ente r upo n th e lan d upo n o r

a s t o whic h suc h violatio n exist s an d summaril y t o abat e an d remove , a t th e expens e o f

th e owne r thereof

, an y structure , thin g o r conditio n tha t

ma y b e o r

exis t thereo n contrar y t o th e inten t

an d meanin g o f

th e provisio n o f

thi s Declaration

.
(d ) Declaran t

an d i t successor s an d assign s shal l b e entitle d t o enforc e th e term s

o f thi s Declaratio n b y specifi c performanc e o r lega l process

. Al l remedie s availabl e hereunde r

shal l b e i n additio n t o an y othe r remedie s a t

la w o r i n equity

. Enforcemen t

o f th e term s an d condition s o f thi s Declaratio n shal l b e

a t th e discretio n o f

Declaran t

an d it s successor s an d assign s an d an y forbearance

, dela y o r

omissio n t o exercis e it s right s unde r thi s Declaratio n i n th e even t

o f a breac h o f

an y ter m o f

thi s Declaratio n shal l no t b e deeme d
t o b e a waive r

b y Declaran t

o r it s successor s an d assign s o f suc h ter m o r

o f

an y subsequen t

breac h o f th e sam e o r

an y othe r

term , o r o f an y o f th e right s

o f suc h partie s unde r

thi s Declaration

.

5

. Miscellaneou s

(a ) Modifications

. Thi s Declaratio n ma y b e modifie d o r terminated

, i n whol e o r i n par t b y th e Declaran t

o r i t successor s o r

assigns

, provide d tha t

a writte n Modificatio n o f

Terminatio n Notic e i n th e Offic e o f th e Recorde r

o f Deed so f Armstron g County

, Pennsylvani a i s file d an d provide d tha t Declaran t

o r it s successor s o r

assign s obtai n writte n approva l fro m th e Environmenta l Protectio n Agenc y a t

leas t thirt y (30 ) day s prio r

t o filin g suc h notice

.
(b ) Reservatio n o f

Rights

. Declaran t

hereb y reserve s unt o itself

, it s successor s

an d assigns

, al l right s an d privilege s i n an d t o th e us e o f th e Sit e whic h ar e

no t incompatibl e wit h th e covenants , condition s an d restriction s establishe d herein

.
(c ) N o Publi c Access

. N o righ t o f acces s o r

us e b y th e genera l publi c t o an y portio n o f th e Sit e i s conveye d b y thi s Declaration

.
(d ) Governin g Law

. Th e interpretatio n an d performanc e o f thi s Declaratio n shal l b e governe d b y th e la w o f Pennsylvania

,
(e ) Rule s o f

Construction

. An y genera l rul e o f constructio n t o th e contrary , notwithstanding

, thi s instrumen t shal l b e liberall y construe d i n favo r o f th e gran t t o affec t th e purpos e o f

thi s Declaratio n an d th e polic y an d purpose th e Comprehensiv e Environmenta l Response

, Compensatio n an d Liabilit y Act

, 4 2 U.S.C

. § 960 1 e t

seq

. I f an y provisio n o f

thi s Declaratio n i s foun d t o b e ambiguous

, a n interpretatio n consisten t wit h th e purpos e o f

thi s Declaratio n tha t woul d rende r

th e provisio n vali d shal l b e favore d ove r an y interpretatio n tha t

woul d rende r

i t invalid

.
(f ) Severability

. I f

an y provisio n o f

thi s Declaration

, o r

th e applicatio n o f

i t t o

an y perso n o r

circumstance

, i s foun d t o b e invalid

, th e remainde r o f th e provision s o f

thi s Declaration

, o r

th e applicatio n o f

suc h provision s t o person s o r

circumstance s othe r

tha n thos e t o whic h i t

i s foun d t o b e invalid

, a s th e cas e ma y be

, shal l no t b e affecte d thereby

. (g ) Entir e Agreement

. Thi s Declaratio n set s fort h th e entir e undertakin g an d
agreemen t

o f Declaran t

wit h respec t

t o right s an d restriction s create d hereby

, an d supersede s al l prio r discussions

, negotiations

, understandings

, o r agreement s relatin g hereto

, al l o f whic h ar e merge d herein

.
(h ) N o Forfeiture

. Nothin g containe d herei n wil l resul t i n a forfeitur e o r reversio n o f

titl e i n an y respect

.
(i ) Successors

. Th e covenants , terms , condition s an d restriction s o f thi s Declaratio n shal l b e bindin g upon , an d inur e t o th e benefi t of

, Declaran t

an d it s successor s an d assign s an d shal l continu e a s a servitud e runnin g i n perpetuit y wit h th e Site

. (j ) Terminatio n o f

Right s an d Obligations

. Th e right s an d obligation s o f th e owner(s ) fro m tim e t o tim e o f th e Sit e unde r

thi s Declaratio n terminat e upo ntransfer o f th e party' s interes t

i n th e Site

, excep t

tha t liabilit y fo r

act s o r omission s occurrin g prio r t o transfe r

shal l surviv e transfer

.
(k ) Captions

. Th e caption s i n thi s Declaratio n hav e bee n inserte d solel y fo r convenienc e o f

referenc e an d ar e no t

a par t o f thi s Declaratio n an d shal l hav e n o effec t

upo n constructio n o r

interpretation

.
[SIGNATORIE S APPEA R O N FOLLOWIN G PAGE |EXHIBI T A

BEGINNIN G a t

a n iro n pi n come r

o n lin e o f

lan d o f Ear l A

. Bailey

, formerl y M.S

. an d Georg e Shakley

, sai d poin t bein g a Southwes t

corne r an d commo n t o lan d no w o f W.P

. Vance

, formerl y E.S

. Golden

, an d th e herei n describe d tract ; thenc e b y lan d o f Earl

. A

. Baile y an d G

. Pear l Johns

, Nort h 7 ° 08 ' 20 " East

, a distanc e o f 3267.0 0 fee t

t o a Ston e

corne r o n lin e o f

lan d o f G

. Pear l Johns

, an d bein g commo n t o lan d no w o f Joh n H

. Hood

, formerl y Jaco b Steel

, an d th e herei n describe d tract ; thenc e b y lan d o f Joh n H

. Hood

, Sout h 8 5 06 ' 30 " East

, a distanc e o f 1378.7 7 fee t

t o a n iro n pi n corne r

o n lin e o f lan d o f Joh n H

. Hood

, an d bein g commo n t o lan d no w o f Davi d E

. Frazie r

(Allotmen t "B")

, an d th e herei n describe d tract , thenc e b y lan d o f Davi d E

. Frazier

, Sout h 00 ° 39 ' West

, a distanc e o f

1014.5 2 fee t

t o a n Iro n Pi n corne r

o n Wes t lin e o f a n improve d Publi c Roa d passin g throug h th e Northeas t sectio n o f

lan d conveye d herein

, an d know n a s Legislativ e Rout e 0303 0 an d bein g commo n t o a n are a o f lan d to " b e retaine d b y Granto r

an d th e herei n describe d tract ; thenc e b y lan d t o b e retaine d b y Herma n G

. Craig

, Sout h 68 ° 30 ' West

, a distanc e o f 899.0 0 fee t

t o a n Iro n Pi n comer ; thenc e b y lan d o f same , Sout h 26 ° 57 ' 30 " East

, a distanc e o f 1312.2 3 fee t

t o a n Iro n Pi n corner ; thenc e b y lan d o f

sam e Nort h 89° 00' East

, a distanc e of 224.6 6 fee t

to an iro n pin corne r

on lin e of

lan d of Davi d E

. Frazie r

an d bein g alon g th e Wes t lin e o f aforesai d Improve d Publi c Roa d an d bein g commo n t o lan d t o b e retained b y Herma n G

. Craig

, an d th e herei n describe d tract ; thenc e b y lan d o f

Davi d E

. Fraizer

, Sout h 00 ° 39 ' West

, a distanc e o f 765.4 5 fee t

t o a n iro n pi n corne r

o n lin e o f

lan d no w o f

W.P

. Vance

, formerl y E.S

. Golden

, an d commo n t o lan d o f Davi d E

. Frazie r

an d th e herei n describe d tract ; thenc e b y lan d o f W.P

. Vance

, Nort h 85 ° 03 ' Wes t

a distanc e o f

1749.0 0 fee t

t o a n iro n pi n corner , th e plac e o f beginning

. CONTAININ G 99.89 9 acres , mor e o r less

, a s surveye d b y EJ

. Weibel

, a registere d surveyor , Novembe r 26

, 1971

.

BEGINNIN G a t

a n iro n pi n corne r

o n lin e o f

lan d no w o f

Davi d E

. Frazier

, sai d poin t bein g Sout

h 0 ° 39 ' West

, a distanc e o f 1014.5 2 fee t

fro m th e northeas t

corne r o f th e lan d formerl y conveye d b y Herma n G

. Craig

, e t ux. , t o Kopper s Company

, Inc

. b y Dee d date d Januar y 5

, L972

, an d bein g th e northeas t come r o f th e herei n describe d tract ; thenc e b y lan d o f Davi d E

. Fraize r

(formerl y Allotmen t

"B")

, Sout h 00 ° 39 ' West

, a distanc e o f 1495.2 8 fee t

t o a n iro n pi n corne r

o n lin e o f

sai d lan d an d bein g commo n t o lan d
conveye d t o Kopper s Company

, Inc.

, a s aforesaid ; thenc e b y sai d lan d heretofor e conveye d t o Kopper s Company

, Inc.

, b y Herma n G

. Craig

, e t ux. , a s aforesaid

, Sout h 89 ° 00 ' West

, a distanc e o f

224.6 6 fee t

t o a n iro n pi n corner ; thenc e b y same , nort h 26 ° 57 ' 30 " West

, a distanc e o f

1312.2 3 fee t

t o a n iro n pi n corner ; thenc e b y same , Nort h 68 ° 30 " East

, a distanc e o f

899.0 0 fee t

t o a n iro n pi n corne r

o n lin e o f

lan d o f Davi d E

. Fraizer

, th e plac e o f

beginning

. CONTAININ G 17.33 3 acres , mor e o r less

, a s surveye d b y E. J Weibel

, R.S.

, Decembe r

1

, 1971

.
{DESCRIPTIO N CONTINUE D Oi N NEX T PAGE }BEGINNIN G a t a n iro n pi n come r

alon g th e edg e o f

th e Queenstown-Brui n Road

, a Publi c Road

, bein g know n a s Legislativ e Rout e #03030 : Sai d poin t bein g th e south-eas t

come r o f th e herei n describe d tract ; thenc e west , throug h lan d o f Herma n G

. Crai g an d Bett y L

. Craig

, hi s wife

, o f whic h thi s i s a part , a distanc e o f tw o hundre d twenty-fiv e

- (225 ) fee t

t o a n iro n pi n corner ; thenc e Nort h throug h lan d o f same , a distanc e o f

tw o hundre d fift y (250 ) fee t

t o a n iro n pi n corner , thenc e east , throug h lan d o f Herma n G

. Crai g an d Bett y L

. Craig

, hi s wife

, a distanc e o f tw o hundre d sixty-siv e (265 ) fee t t o a n iro n pi n corne r

a t edg e o f Legislativ e Rout e 03030 ; thenc e South ; alon g edg e o f Legislativ e Rout e 03030

, a distanc e o f tw o hundre d fift y (250 ) fee t t o a point

, th e plac e o f beginning

.I N WITNES S WHEREOF

, BEAZE R EAST

, INC

. ha s cause d it s commo n an d corporat e

sea l t o b e affixe d t o thes e present s b y th e han d o f it s , wh o i s dul y authorize d t o execut e thi s Declaratio n o n behal f o f th e corporation

, an d th e sam e bein g dul y atteste d t o b y it s Secretar y o n th e da y an d yea r

firs t abov e written

, intendin g t o b e legall y boun d hereby

.

ATTEST : BEAZE R EAST

, INC.

, a Delawar e Corporatio n

Secretar y [CORPORAT E SEA L HERE ]

STAT E O F /^^^t ^ J^TL^L ^ )

COUNT Y O F &&di^uf > )

O n thi s 23r d da y o f

September

, 200 4 befor e me , a Notar y Public

, th e undersigne d officer

, personall y appeare d ^rbsffl-fflgsJ/eMdjL ^

, wh o acknowledge d himsel f t o b e th e /%£*.

- fr^dt^t

. o f BEAZE R EAST

, INC.

, a Delawar e Corporation

, an d tha t

suc h officer,-bein g authorize d t o d o so , execute d th e foregoin g instrumen t a s th e

' Tx^xu^n^o f

BEAZE R EAST

, INC

. fo r th e purpose s therei n contained

.

I N WITNES S WHEREOF

, I hereunt o se t m y han d an d officia l seal

.

Notar y Publi c

M y commissio n expires :

COMMONWEALT H O F PENNSYLVANI A

Notaria l Sea l Mauree n M

. Ststzar

, Notar y PuM c Ot y O f Rttsbugh

, Ateghon y Count y M y Commtato n Expt

a Ju< y 3,200 6

, f*«nniytv»nl « Aiiociatto n O f Nottrie *

# Attachment 2 – Community Involvement MaterialsBy ASSOCIATED PRESS
PHILADELPHIA — Two brothers who ran a pair offuneral homes and a crematorium admitted Tuesday they sold corpses to a company that trafficked in stolen body parts.

Louis and Gerald Garzone pleaded guilty to charges including conspiracy, theft, abusing corpses and welfare fraud.

The gruesome allegationsread in court drew gasps, murmurs and tears from about twodozen people who had entrusted the bodies of their loved ones to the Garzones’ facilities in Philadelphia.

The mastermind of thescheme, Michael Mastromarino, pleaded guilty Friday to hundreds of charges that could send him to prison for life. He is already serving 18 to 54 years for running the scam in New York.

Mastromarino’s company,Fort Lee, N.J.-based Biomedical Tissue Services, took bodies from funeral homes in NewYork, New Jersey and Pennsylvania. Mastromarino paid the Garzones and their partner, J ames McCafferty, more than$245,000 for at least 244 cadavers between February 2004 and October 2005, prosecutors said. 

### Brothers admit selling dead bodies These items have been collected from various police departments.
**Butler Police** Saturday — An unknown thief overnight stole a red picnic table and benches from the front porch of an East Brady Street home. Tamara Brunetti owns the stolen property, valued at $125.

Saturday — About 25 compact discs valued at $250 and about $15 was taken from a vehicle parked at the Brown Avenue home of Roxanna Kamerer.

10:20 a.m. Friday — David L. Weisenstein, 38, was arrested for allegedly punching his girlfriend, Candace Nase, 25, in the headand face during a domestic dispute at their West Penn Street home. Weisenstein is charged with simple assault; he is free on $5,000 unsecured bond.

Friday — An unknown burglar apparently used a brick to smash a window and break into Dubrook Inc. on Bantam Avenue. The suspect tried but failed to break into a safe. Nothing was reported taken from the business.

9:30 p.m. Thursday — James C. Bender Jr., 53, is accused of hitting 41-year-old Barbara Hazlett in the head with a plastic garbage can during a reported domestic dispute at their East Jefferson Street home. Bender was arrested and charged with simple assault, and was released from the Butler County Prison after posting a $2,500 bond.

Thursday — An unknown thief removed a catalytic converter, valued at $200, from a vehicle parked at Butler Tire on Route 8 South. Zack Malis of Summit Township, who owns the vehicle, told police the theft occurred sometime within the past “few weeks.”

Thursday — T ires on two vehicles parked on Hickory Street were cut on consecutive nights. Joseph Pellegrini had two tires cut overnight Thursday at his home and Tracy Graham had one tire cut overnight Wednesday at her home.

Wednesday — Someone overnight used a BB gun to shoot out the windshield of a car parked on West Patterson Avenue. Damage was estimated at $400.

Wednesday — Stacey Reynolds of Butler reported that her unlocked car on Apple Avenue was broken into, and about $10 in change was taken.

12:58 a.m. Aug. 15 — Colin S. Kelly, 27, of Butler was arrested for driving under the influence on North Main Street hill. Police said Kelly also was cited for driving with a suspended license and careless driving. **Butler Twp**

**Police**2:25 p.m. Sunday — Tina Gibson, 31, of Butler is accused of retail theft for allegedly shoplifting about $277 worth of video gamesat the Target store in Butler Commons.

6:10 p.m. Friday — Donna Digiacomo, 39, of Eau Claire faces theft and drug-related charges after she was allegedly caught stealing jewelry at the Wal-Mart in Butler Commons.

Police said Digiacomo placed the jewelry in her purse and left the store without paying for the items. Officers searched the woman’s purse and also found two stamp bags of suspected heroin, three crack pipes and a syringe.

Digiacomo is charged with a felony count of retail theft since this is her third related offense, according to court records She also is charged with possession of a controlled substance and drug paraphernalia. **Grove City Police**

Aug. 31 — Steven Allen Johnson, 20, of Grove City was charged with two outstanding traffic warrants.

7:45 p.m. Aug. 30 — Theresa Stull of 229 Grace St., Apt 1, reported $450 cash was stolen from her residence between 4and 7 p.m. Anyone with information is asked to call police.

Aug. 28 — Kenneth Miller of Grove City reported that his brown 2000 Dodge Neon was stolen from his residence between 1 a.m. and 6:50 a.m. Anyone with information is asked to call police.

Aug. 28 — Police are investigating a vandalism complaint at 700 S. Center St. The garage door of the residence was kicked several times between 6 and 9 p.m., severely damaging the door. A repair estimate has yet to be determined. The residence belongs to Risa Eiger and Gary McPartlin.

Aug. 28 — Doug Bennett, 39, of Grove City reported a pair oftruck keys and three fleece jackets valued at $20 each were taken from a vehicle in the driveway of 414 E. Main St. between 4 and 4:45 a.m.

Aug. 28 — Scott Smith, 19, a student at Grove City College,reported his silver colored Olympus digital camera was stolen from his dorm room sometime between Aug. 23 and Aug. 28. The camera is valued at $274. Anyone with information is asked to call police.

Aug. 25 — Someone entered 433 McConnell St. through an open window on the second floor, where 22 prescription pills were taken from a bedroom of the homeowner. Also taken were two packs of Kool menthol 100s cigarettes. The home was entered sometime between 8:30 and 10:30 p.m. while the home was unoccupied. Anyone with information is asked to call police.

Aug. 24 — Police recovered aNext 20-inch bicycle by the railroad tracks on Erie Street. It can be identified and claimed at the police department. **State Police, Butler**  4:51 p.m. Tuesday — A car driven by Ryan Conto, 17, ofBruin crashed into an embankment and rolled onto its side on Route 268 in Fairview Township. Police said Conto was cited for driving too fast for conditions.

2 a.m. Tuesday — Justin D. Hiles, 25, of Butler was arrested for suspicion of driving under the influence on Hazelnut Road in Fairview Township.

Monday — An unknown thief stole a 1993 Ford truck tailgate valued at $250 from the 422 Auto Auction on Fisher Road in Muddy Creek Township.

Sunday — Kelli L. Reitz, 25, ofPittsburgh was arrested for suspicion of DUI on Route 8 in Center Township.

Sunday — Nothing was reported taken in a burglary betweenAug. 26 and Sunday at an unoccupied farmhouse and storageshed on Marwood Road in Winfield Township.

Sunday — A gray, 1948 Ford tractor was stolen at a camp onWatson Road in Marion Township. Robert Lang of Fair Oaks,Allegheny County, owns the tractor, which was taken between July 6 and Sunday.

Friday — Someone between 8 and 9:30 p.m. tried to break into the Hooker Road home of Scott Crooks in Karns City.

Aug. 27 — An unknown burglar broke into Davison’s Restauran ton Route 356 in Winfield Township and took $110. A windo walso sustained $250 in the burglary between 9:15 p.m. Aug. 2 6 and 5:30 a.m. Aug. 27. **State Police,**

**Franklin** Tuesday — Christina Richter o f Grove City told police that $10 0 was taken from her purse in an unlocked vehicle parked on Gibb Road in Barkeyville. The thef t occurred between 12:30 and 2:45 p.m. **State Police, New Castle**  3 p.m. Tuesday — Lenny Ja y Staples, 41, of New Castle wa s arrested for the alleged sexual assault of a 38-year-old woman at an undisclosed location on Hogue Road in Slippery Roc k Township, Lawrence County.

Police said the woman suffered minor injuries but did not see k medical treatment.

Staples was arraigned on charges of rape, aggravated indecent assault and indecen t assault, and placed in the Lawrence County Jail on $10,00 0 bond. POLICE REPOR POLICE REPOR T S **W e**  **d nes**  **d ay,**  **S eptem**  **b er 3, 2008 -**  **BUTLER EAGLE**  **7**

996859993012 724-843-4131 F or more information on any of these programs, call 724-284-5383 www.co.butler.pa.us ( Parks & Recreation ) **BUTLER COUNTY PARKS AND RECREATION DEPARTMENT**  Now seeking individual & business sponsors for the Fall Festival. Please call for information.996838 “Leading The Way” 

## D

O

G

G

I

E F U

N D A

Y OGGIE FUN DAY

S u n d a y , S e p t e m b e r 1 4 S u n d a y , S e p t e m b e r 1 4 unday, September 14 Alameda Park • 9 am - 5 pm **Bring your dog & enjoy activities in the park.**

Your dog can swim in Alameda Pool from 1-4:30 pm ($5.00 Canine Admission) A L A M E D A F A L L F E S T A L A M E D A F A L L F E S T LAMEDA FALL FEST & F I S H I N G T O U R N A M E N T & F I S H I N G T O U R N A M E N T & FISHING TOURNAMENT S u n d a y , S e p t

. 2 1 S u n d a y , S e p t

. 2 1 unday, Sept. 21

996741

# Attachment 3 – Groundwater Monitoring Analytical DataSummary of Analytical DataCraig Farm Superfund Site1999 through 2008Sample Location: LF-01 LF-1-DUP LF-1 LF-1-DUP LF-1Sample Date: 5/12/1999 5/12/1999 12/6/1999 12/6/1999 5/25/2000BENZENE ug/l 1 U 1 U 1 U 1 U 1 UBENZENE METADISULFONIC ACID mg/l 10 U 10 U 0.05 U 0.05 U 0.05 UBENZENE MONOSULFONIC ACID mg/l 10 U 10 U 0.05 U 0.05 U 0.05 UP-PHENOL SULFONIC ACID mg/l 10 U 10 U 0.205 0.187 0.295RESORCINOL mg/l 1.2 U 1.2 U 0.05 U 0.05 U 0.05 UTRIHYDROXYDIPHENYL mg/l 0.95 0.95 0.075 0.094 0.05Sample Location: LF-1 LF-1 LF-01 LF-01 Dup LF-01 LF-01Sample Date: 4/17/2002 11/12/2002 4/15/2003 4/15/2003 12/18/2003 6/15/2004BENZENE ug/l 1 U 1 U 1 U 1 U 1 U 1 UBENZENE METADISULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UBENZENE MONOSULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UP-PHENOL SULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.058 0.179RESORCINOL mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UTRIHYDROXYDIPHENYL mg/l 0.05 0.05 U 0.05 U 0.05 U 0.05 U 0.055Sample Location: LF-01 LF-01 LF-01 LF-01 LF-01-DUPSample Date: 12/6/2004 6/9/2005 12/7/2005 6/6/2006 6/6/2006BENZENE ug/l 1 U 1 U 1 U 1 U 1 UBENZENE METADISULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UBENZENE MONOSULFONIC ACID mg/l 0.05 U 0.05 U 0.05 0.05 U 0.05 UP-PHENOL SULFONIC ACID mg/l 0.157 0.117 0.05 U 0.05 U 0.05 URESORCINOL mg/l 0.05 U 0.05 0.05 U 0.05 U 0.05 UTRIHYDROXYDIPHENYL mg/l 0.05 U 0.05 U 0.05 U 0.05 U 9930Sample Location: LF-01-110606 LF-01-DUP-110606 LF-1-032107 LF-01 LF-01Sample Date: 11/6/2006 11/6/2006 3/21/2007 11/6/2007 3/10/2008BENZENE ug/l 1 U 1 U 1 U 1 1 UBENZENE METADISULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UBENZENE MONOSULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UP-PHENOL SULFONIC ACID mg/l 0.056 0.056 0.05 U 0.05 U 0.05 URESORCINOL mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UTRIHYDROXYDIPHENYL mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UU - Indicates non-detectedJ - Indicates estimateD - Indicates result is from analysis of a secondary dillutionF:\Craig Farm\FYR 2009\Summary Table_Wells Combined_063008Page 1 of 24Concentration Trends for LF-01 1999 though 200701234561/1/1999 1/1/2000 1/1/2001 1/1/2002 1/1/2003 1/1/2004 1/1/2005 1/1/2006 1/1/2007 1/1/2008

Concentration of BSA and p-PSA (mg/L)020004000600080001000012000 Concentration of THD (mg/L)BENZENE MONOSULFONIC ACID mg/lP-PHENOL SULFONIC ACID mg/lTRIHYDROXYDIPHENYL mg/lNOTES:-Open Symbols are non-detects.-Non-detects were replaced with half the detectionlimit.F:\Craig Farm\FYR 2009\Summary Table_Wells Combined_063008Page 2 of 24Summary of Analytical DataCraig Farm Superfund Site1999 through 2008Sample Location: LF-02 LF-2 LF-2 LF-2 LF-02 LF-2Sample Date: 5/12/1999 12/6/1999 5/25/2000 11/30/2000 4/16/2001 11/14/2001BENZENE ug/l 1 U 1 U 1 U 1 U 1 U 1 UBENZENE METADISULFONIC ACID mg/l 10 U 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UBENZENE MONOSULFONIC ACID mg/l 10 U 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UP-PHENOL SULFONIC ACID mg/l 10 U 0.137 0.12 0.177 0.069 0.202RESORCINOL mg/l 1.2 U 0.05 U 0.05 U 0.05 U 0.05 U 0.055TRIHYDROXYDIPHENYL mg/l 0.9 0.125 0.05 U 0.05 U 0.05 U 1.25Sample Location: LF-2 LF-2 LF-02 LF-02 LF-02 LF-02Sample Date: 4/17/2002 11/12/2002 4/15/2003 12/17/2003 6/16/2004 12/6/2004BENZENE ug/l 1 U 1 U 1 U 1 U 1 U 1 UBENZENE METADISULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UBENZENE MONOSULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UP-PHENOL SULFONIC ACID mg/l 0.05 U 0.072 0.05 U 0.05 U 0.05 0.067RESORCINOL mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UTRIHYDROXYDIPHENYL mg/l 0.05 0.05 U 0.05 U 0.05 U 0.05 U 0.05 USample Location: LF-02 LF-02 LF-02 LF-02-110606 LF-2-031907 LF-02Sample Date: 6/9/2005 12/6/2005 6/6/2006 11/6/2006 3/19/2007 11/6/2007BENZENE ug/l 1 U 1 U 1 U 1 U 1 U 1.3BENZENE METADISULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UBENZENE MONOSULFONIC ACID mg/l 0.05 U 0.05 0.05 U 0.05 U 0.05 U 0.05 UP-PHENOL SULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U 0.05 URESORCINOL mg/l 0.05 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UTRIHYDROXYDIPHENYL mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U 0.05 USample Location: LF-02Sample Date: 3/10/2008BENZENE ug/l 1 UBENZENE METADISULFONIC ACID mg/l 0.05 UBENZENE MONOSULFONIC ACID mg/l 0.05 UP-PHENOL SULFONIC ACID mg/l 0.05 URESORCINOL mg/l 0.05 UTRIHYDROXYDIPHENYL mg/l 0.05 UU - Indicates non-detectedJ - Indicates estimateD - Indicates result is from analysis of a secondary dillutionF:\Craig Farm\FYR 2009\Summary Table_Wells Combined_063008Page 3 of 24Concentration Trends for LF-02 1999 though 2007012345601/01/99 01/01/00 01/01/01 01/01/02 01/01/03 01/01/04 01/01/05 01/01/06 01/01/07 01/01/08

Concentration (mg/L)BENZENE MONOSULFONIC ACID mg/lP-PHENOL SULFONIC ACID mg/lRESORCINOL mg/lTRIHYDROXYDIPHENYL mg/lNOTES:-Open Symbols are non-detects.-Non-detects were replaced with half the detectionlimit.F:\Craig Farm\FYR 2009\Summary Table_Wells Combined_063008Page 4 of 24Summary of Analytical DataCraig Farm Superfund Site1999 through 2008Sample Location: LF-03 LF-3 LF-3 LF-3 LF-3 LF-3Sample Date: 5/12/1999 12/6/1999 5/25/2000 11/30/2000 4/16/2001 11/14/2001BENZENE ug/l 1 U 1 U 1 U 1 U 1 U 1 UBENZENE METADISULFONIC ACID mg/l 10 U 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UBENZENE MONOSULFONIC ACID mg/l 10 U 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UP-PHENOL SULFONIC ACID mg/l 10 U 0.05 U 0.05 U 0.05 U 0.05 U 0.05 URESORCINOL mg/l 1.2 U 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UTRIHYDROXYDIPHENYL mg/l 0.5 U 0.05 U 0.05 U 0.05 U 0.05 U 0.05 USample Location: LF-3 LF-3 LF-03 LF-03 LF-03 LF-03Sample Date: 4/17/2002 11/12/2002 4/15/2003 12/17/2003 6/16/2004 12/6/2004BENZENE ug/l 1 U 1 U 1 U 1 U 1 U 1 UBENZENE METADISULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UBENZENE MONOSULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UP-PHENOL SULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 0.082RESORCINOL mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UTRIHYDROXYDIPHENYL mg/l 0.05 0.05 U 0.05 U 0.05 U 0.05 U 0.05 USample Location: LF-03 LF-03 LF-03 LF-03-110606 LF-3-031907 LF-03Sample Date: 6/9/2005 12/6/2005 6/6/2006 11/6/2006 3/19/2007 11/6/2007BENZENE ug/l 1 U 1 U 1 U 1 U 1 U 2.2BENZENE METADISULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UBENZENE MONOSULFONIC ACID mg/l 0.05 U 0.05 0.05 U 0.05 U 0.05 U 0.05 UP-PHENOL SULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U 0.05 URESORCINOL mg/l 0.05 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UTRIHYDROXYDIPHENYL mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U 0.05 USample Location: LF-03Sample Date: 3/10/2008BENZENE ug/l 1 UBENZENE METADISULFONIC ACID mg/l 0.05 UBENZENE MONOSULFONIC ACID mg/l 0.05 UP-PHENOL SULFONIC ACID mg/l 0.05 URESORCINOL mg/l 0.05 UTRIHYDROXYDIPHENYL mg/l 0.05 UU - Indicates non-detectedJ - Indicates estimateD - Indicates result is from analysis of a secondary dillutionF:\Craig Farm\FYR 2009\Summary Table_Wells Combined_063008Page 5 of 24Concentration Trends for LF-03 1999 though 2007012345601/01/99 01/01/00 01/01/01 01/01/02 01/01/03 01/01/04 01/01/05 01/01/06 01/01/07 01/01/08

Concentration (mg/L)BENZENE MONOSULFONIC ACID mg/lP-PHENOL SULFONIC ACID mg/lRESORCINOL mg/lTRIHYDROXYDIPHENYL mg/lNOTES:-Open Symbols are non-detects.-Non-detects were replaced with half the detectionlimit.F:\Craig Farm\FYR 2009\Summary Table_Wells Combined_063008Page 6 of 24Summary of Analytical DataCraig Farm Superfund Site1999 through 2008Sample Location: LF-04 LF-4 LF-4 LF-4 LF-4 LF-4Sample Date: 5/12/1999 12/6/1999 5/25/2000 11/30/2000 4/16/2001 11/14/2001BENZENE ug/l 1 U 1 U 1 U 1 U 1 U 1 UBENZENE METADISULFONIC ACID mg/l 10 U 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UBENZENE MONOSULFONIC ACID mg/l 10 U 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UP-PHENOL SULFONIC ACID mg/l 10 U 0.05 U 0.05 0.157 0.081 0.05 URESORCINOL mg/l 1.2 U 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UTRIHYDROXYDIPHENYL mg/l 2.1 0.05 U 0.05 U 0.05 U 0.05 U 0.05 USample Location: LF-4 LF-4 LF-04 LF-04 LF-04 LF-04Sample Date: 4/17/2002 11/12/2002 4/15/2003 12/17/2003 6/16/2004 12/6/2004BENZENE ug/l 1 U 1 U 1 U 1 U 1 U 1 UBENZENE METADISULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UBENZENE MONOSULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UP-PHENOL SULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.062 0.095 0.05RESORCINOL mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UTRIHYDROXYDIPHENYL mg/l 0.262 0.05 U 0.186 0.05 U 0.05 U 0.05 USample Location: LF-04 LF-04 LF-04 LF-4-031907 LF-04Sample Date: 6/9/2005 12/6/2005 6/6/2006 3/19/2007 11/6/2007BENZENE ug/l 1 U 1 U 1 U 1 U 1 U 1.7BENZENE METADISULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UBENZENE MONOSULFONIC ACID mg/l 0.05 U 0.05 0.05 U 0.05 U 0.05 U 0.05 UP-PHENOL SULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U 0.05 URESORCINOL mg/l 0.05 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UTRIHYDROXYDIPHENYL mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U 0.05 USample Location: LF-04 LF-04-DUPSample Date: 3/10/2008 3/10/2008BENZENE ug/l 1 U 1 UBENZENE METADISULFONIC ACID mg/l 0.05 U 0.05 UBENZENE MONOSULFONIC ACID mg/l 0.05 U 0.05 UP-PHENOL SULFONIC ACID mg/l 0.05 U 0.05 URESORCINOL mg/l 0.05 U 0.05 UTRIHYDROXYDIPHENYL mg/l 0.05 U 0.05 UU - Indicates non-detectedJ - Indicates estimateD - Indicates result is from analysis of a secondary dillutionLF-04-11060611/6/2006F:\Craig Farm\FYR 2009\Summary Table_Wells Combined_063008Page 7 of 24Concentration Trends for LF-04 1999 though 2007012345601/01/99 01/01/00 01/01/01 01/01/02 01/01/03 01/01/04 01/01/05 01/01/06 01/01/07 01/01/08

Concentration (mg/L)BENZENE MONOSULFONIC ACID mg/lP-PHENOL SULFONIC ACID mg/lRESORCINOL mg/lTRIHYDROXYDIPHENYL mg/lNOTES:-Open Symbols are non-detects.-Non-detects were replaced with half the detectionlimit.F:\Craig Farm\FYR 2009\Summary Table_Wells Combined_063008Page 8 of 24Summary of Analytical DataCraig Farm Superfund Site1999 through 2008Sample Location: M-03B M-03B M-03B DUP M-03B M-03B DUP M-03BSample Date: 2/10/1999 7/20/1999 7/20/1999 3/1/2000 3/1/2000 7/25/2000BENZENE ug/l 1 U 1 U 1 U 10 U 10 U 1 UBENZENE METADISULFONIC ACID mg/l 10 U 10 U 10 U 0.05 UJ 0.066 J 0.05 UBENZENE MONOSULFONIC ACID mg/l 10 U 10 U 10 U 0.05 U 0.05 U 0.05 UP-PHENOL SULFONIC ACID mg/l 10 U 10 U 10 U 0.95 0.981 0.355 URESORCINOL mg/l 300 U 300 U 300 U 41.9 40.3 34.3TRIHYDROXYDIPHENYLmg/l 600 D 610 D 560 D 384 389 290Sample Location: WELL-M-3B M-3B M-3B M-3B M-03B M-03BSample Date: 4/17/2001 11/15/2001 4/18/2002 11/13/2002 4/16/2003 12/18/2003BENZENE ug/l 1 U 1 U 1 U 1 U 1 U 1 UBENZENE METADISULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UBENZENE MONOSULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UP-PHENOL SULFONIC ACID mg/l 0.916 0.637 0.188 0.46 0.409 0.376RESORCINOL mg/l 26.7 29 17.9 36.1 25.1 21.9TRIHYDROXYDIPHENYLmg/l 270 249 191 J 327 272 318Sample Location: M-03BDUP M-03B M-03B M-03B M-03B M-03BSample Date: 12/18/2003 6/14/2004 12/7/2004 6/8/2005 12/6/2005 6/6/2006BENZENE ug/l 1 U 1 U 1 U 1 U 1 U 1 UBENZENE METADISULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.344 J 0.05 UBENZENE MONOSULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UJ 0.05 UP-PHENOL SULFONIC ACID mg/l 0.362 0.22 J 0.443 J 0.438 J 0.297 0.0953RESORCINOL mg/l 22.2 25.7 26.3 20.7 J 29.7 8.24TRIHYDROXYDIPHENYLmg/l 306 296 288 211 287 J 74.6Sample Location: M-03B-110806 M-03B-032007 M-03BDUP01-032007 M-03B M-03BSample Date: 11/8/2006 3/20/2007 3/20/2007 11/7/2007 3/12/2008BENZENE ug/l 1 U 1 U 1 U 1 U 1 UBENZENE METADISULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UBENZENE MONOSULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UP-PHENOL SULFONIC ACID mg/l 0.05 U 0.222 0.207 0.304 0.275RESORCINOL mg/l 15 22.1 24 25 20.6TRIHYDROXYDIPHENYLmg/l 197 202 243 226 183U - Indicates non-detectedJ - Indicates estimateD - Indicates result is from analysis of a secondary dillutionF:\Craig Farm\FYR 2009\Summary Table_Wells Combined_063008Page 9 of 24Concentration Trends for M-03B 1999 though 2007010020030040050060070001/01/99 01/01/00 01/01/01 01/01/02 01/01/03 01/01/04 01/01/05 01/01/06 01/01/07 01/01/08

Concentration (mg/L)P-PHENOL SULFONIC ACID mg/lRESORCINOL mg/lTRIHYDROXYDIPHENYL mg/lNOTES:-Open Symbols are non-detects.-Non-detects were replaced with half the detectionlimit.F:\Craig Farm\FYR 2009\Summary Table_Wells Combined_063008Page 10 of 24Summary of Analytical DataCraig Farm Superfund Site1999 through 2008Sample Location: M-05A M-05A DUP M-05A M-05ASample Date: 7/20/1999 7/20/1999 3/1/2000 7/26/2000BENZENE ug/l 1 U 1 U 10 U 1 UBENZENE METADISULFONIC ACID mg/l 10 U 10 U 0.05 U 0.05 UBENZENE MONOSULFONIC ACID mg/l 10 U 10 U 0.05 U 0.05 UP-PHENOL SULFONIC ACID mg/l 10 U 2500 U 0.05 U 0.261RESORCINOL mg/l 300 U 300 U 6.79 15.7TRIHYDROXYDIPHENYL mg/l 390 D 360 D 121 287Sample Location: WELL-M-5A M-5A M-5A M-05A M-05ASample Date: 4/18/2001 11/15/2001 4/17/2002 4/16/2003 12/18/2003BENZENE ug/l 1 U 1 U 1 U 1 U 1 UBENZENE METADISULFONIC ACID mg/l 0.05 U 0.056 0.05 U 0.05 U 0.05 UBENZENE MONOSULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UP-PHENOL SULFONIC ACID mg/l 0.167 0.512 0.05 U 0.082 0.05 URESORCINOL mg/l 7.93 38.9 1.03 0.632 2.37TRIHYDROXYDIPHENYL mg/l 161 811 28 J 52.5 104Sample Location: M-05A M-05A M-05A M-05ASample Date: 6/15/2004 12/7/2004 6/8/2005 12/7/2005BENZENE ug/l 1 U 1 U 1 U 1 UBENZENE METADISULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 UBENZENE MONOSULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05P-PHENOL SULFONIC ACID mg/l 0.05 0.05 0.073 0.092RESORCINOL mg/l 7.21 9.29 19.2 2.08TRIHYDROXYDIPHENYL mg/l 221 314 599 96.8Sample Location: M-05A M-05A-110606Sample Date: 6/6/2006 11/6/2006BENZENE ug/l 1 U 1 U 1 UBENZENE METADISULFONIC ACID mg/l 0.05 U 0.05 U 0.05 UBENZENE MONOSULFONIC ACID mg/l 0.05 U 0.05 U 0.05 UP-PHENOL SULFONIC ACID mg/l 0.05 U 0.05 U 0.05 URESORCINOL mg/l 3.7 3.85 4.12TRIHYDROXYDIPHENYL mg/l 144 186 185U - Indicates non-detectedJ - Indicates estimateD - Indicates result is from analysis of a secondary dillutionM-05A-0320073/20/2007F:\Craig Farm\FYR 2009\Summary Table_Wells Combined_063008Page 11 of 24Concentration Trends for M-05A 1999 though 2007020040060080010001200140007/20/99 07/20/00 07/20/01 07/20/02 07/20/03 07/20/04 07/20/05 07/20/06 07/20/07

Concentration (mg/L)BENZENE METADISULFONIC ACID mg/lBENZENE MONOSULFONIC ACID mg/lP-PHENOL SULFONIC ACID mg/lRESORCINOL mg/lTRIHYDROXYDIPHENYL mg/lNOTES:-Open Symbols are non-detects.-Non-detects were replaced with half the detectionlimit.F:\Craig Farm\FYR 2009\Summary Table_Wells Combined_063008Page 12 of 24Summary of Analytical DataCraig Farm Superfund Site1999 through 2008Sample Location: M-05B M-05B M-05B-DUP M-05BSample Date: 12/18/2003 6/15/2004 6/15/2004 12/8/2004BENZENE ug/l 1 U 1 U 1 U 1 UBENZENE METADISULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 UBENZENE MONOSULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 UP-PHENOL SULFONIC ACID mg/l 0.44 0.828 J 0.201 J 0.05 UJRESORCINOL mg/l 0.05 U 0.05 U 0.05 U 0.05 UTRIHYDROXYDIPHENYL mg/l 0.05 U 0.05 U 0.05 U 0.186Sample Location: M-05B M-05B M-05B M-05B M-05BSample Date: 6/9/2005 6/7/2006 11/8/2006 3/20/2007 11/7/2007BENZENE ug/l 1 U 1 U 1 U 1 U 1 UBENZENE METADISULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UBENZENE MONOSULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UP-PHENOL SULFONIC ACID mg/l 0.574 J 0.0726 0.366 0.127 0.156RESORCINOL mg/l 0.05 UJ 0.211 B 0.05 U 0.05 U 0.05 UTRIHYDROXYDIPHENYL mg/l 0.05 U 7520 0.873 0.184 0.05 USample Location: M-05BSample Date: 3/11/2008BENZENE ug/l 1 UBENZENE METADISULFONIC ACID mg/l 0.05 UBENZENE MONOSULFONIC ACID mg/l 0.05 UP-PHENOL SULFONIC ACID mg/l 0.277RESORCINOL mg/l 0.05 UTRIHYDROXYDIPHENYL mg/l 0.144U - Indicates non-detectedJ - Indicates estimateD - Indicates result is from analysis of a secondary dillutionF:\Craig Farm\FYR 2009\Summary Table_Wells Combined_063008Page 13 of 24Concentration Trends for M-05A 1999 though 200701000200030004000500060007000800012/18/03 12/18/04 12/18/05 12/18/06 12/18/07

Concentration (mg/L)P-PHENOL SULFONIC ACID mg/lRESORCINOL mg/lTRIHYDROXYDIPHENYL mg/lNOTES:-Open Symbols are non-detects.-Non-detects were replaced with half the detectionlimit.F:\Craig Farm\FYR 2009\Summary Table_Wells Combined_063008Page 14 of 24Summary of Analytical DataCraig Farm Superfund Site1999 through 2008Sample Location: M-14B M-14B DUP M-14B M-14B M-14BSample Date: 2/10/1999 2/10/1999 7/20/1999 3/2/2000 7/26/2000BENZENE ug/l 1 U 1 U 1 U 1 U 1 UBENZENE METADISULFONIC ACID mg/l 10 U 10 U 10 U 0.05 U 0.05 UBENZENE MONOSULFONIC ACID mg/l 10 U 10 U 10 U 0.05 U 0.05 UP-PHENOL SULFONIC ACID mg/l 10 U 10 U 10 U 0.05 U 0.48RESORCINOL mg/l 3.9 3.9 1.2 U 0.05 U 0.05 UTRIHYDROXYDIPHENYL mg/l 23 D 23 D 4.3 0.372 0.05 USample Location: M-14B M-14B M-14B M-14B M-14B M-14BSample Date: 4/18/2001 11/16/2001 4/18/2002 11/14/2002 4/17/2003 12/8/2004BENZENE ug/l 1 U 1 U 1 U 1 U 1 U 1 UBENZENE METADISULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UBENZENE MONOSULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UP-PHENOL SULFONIC ACID mg/l 0.442 0.21 0.05 U 0.05 U 0.05 U 0.064RESORCINOL mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UTRIHYDROXYDIPHENYL mg/l 0.337 0.05 U 0.05 UJ 0.058 0.1 0.05 USample Location: M-14B M-14B M-14B M-14B-110806 M-14B-032007 M-14BSample Date: 6/8/2005 12/7/2005 6/6/2006 11/8/2006 3/20/2007 11/7/2007BENZENE ug/l 1 U 1 U 1 U 1 U 1 U 1 UBENZENE METADISULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UBENZENE MONOSULFONIC ACID mg/l 0.05 U 0.05 UJ 0.05 U 0.05 U 0.05 U 0.05 UP-PHENOL SULFONIC ACID mg/l 0.148 0.05 U 0.05 U 0.141 0.05 U 0.05 URESORCINOL mg/l 0.05 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UTRIHYDROXYDIPHENYL mg/l 0.05 U 0.092 J 0.05 U 0.111 0.05 U 0.05 USample Location: M-14BSample Date: 3/11/2008BENZENE ug/l 1 UBENZENE METADISULFONIC ACID mg/l 0.05 UBENZENE MONOSULFONIC ACID mg/l 0.05 UP-PHENOL SULFONIC ACID mg/l 0.0653RESORCINOL mg/l 0.05 UTRIHYDROXYDIPHENYL mg/l 0.05 UU - Indicates non-detectedJ - Indicates estimateD - Indicates result is from analysis of a secondary dillutionF:\Craig Farm\FYR 2009\Summary Table_Wells Combined_063008Page 15 of 24Concentration Trends for M-05A 1999 though 2007051015202501/01/99 01/01/00 01/01/01 01/01/02 01/01/03 01/01/04 01/01/05 01/01/06 01/01/07 01/01/08

Concentration (mg/L)P-PHENOL SULFONIC ACID mg/lRESORCINOL mg/lTRIHYDROXYDIPHENYL mg/lNOTES:-Open Symbols are non-detects.-Non-detects were replaced with half the detectionlimit.F:\Craig Farm\FYR 2009\Summary Table_Wells Combined_063008Page 16 of 24Summary of Analytical DataCraig Farm Superfund Site1999 through 2008Sample Location: M-15B M-15B M-15B M-15B M-15B-DUPSample Date: 2/11/1999 7/20/1999 3/2/2000 7/26/2000 7/26/2000BENZENE ug/l 1 U 1 U 1 U 1 U 1 U 1 UBENZENE METADISULFONIC ACID mg/l 10 U 10 U 0.05 U 0.055 0.055 0.05 UBENZENE MONOSULFONIC ACID mg/l 10 U 10 U 0.05 U 0.05 U 0.05 U 0.05 UP-PHENOL SULFONIC ACID mg/l 10 U 10 U 0.201 0.117 J 0.123 J 0.081RESORCINOL mg/l 1.2 U 1.2 U 0.126 0.05 U 0.05 U 0.05 UTRIHYDROXYDIPHENYL mg/l 1.8 1.2 0.95 0.05 U 0.05 U 0.101Sample Location: M-15B M-15B M-15B M-15B M-15B M-15BSample Date: 11/16/2001 4/18/2002 11/14/2002 4/17/2003 12/18/2003 6/16/2004BENZENE ug/l 1 U 1 U 1 U 1 U 1 U 1 UBENZENE METADISULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UBENZENE MONOSULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UP-PHENOL SULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U 0.05RESORCINOL mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UTRIHYDROXYDIPHENYL mg/l 0.05 U 0.159 J 0.05 U 0.116 0.05 U 0.05 USample Location: M-15B M-15B M-15B M-15B M-15B-110606 M-15B-032007Sample Date: 12/8/2004 6/8/2005 12/8/2005 6/6/2006 11/6/2006 3/20/2007BENZENE ug/l 1 U 1 U 1 U 1 U 1 U 1 UBENZENE METADISULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UBENZENE MONOSULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UP-PHENOL SULFONIC ACID mg/l 0.05 0.05 U 0.05 U 0.05 U 0.05 U 0.05 URESORCINOL mg/l 0.05 U 0.05 0.05 U 0.05 U 0.05 U 0.05 UTRIHYDROXYDIPHENYL mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U 0.05 USample Location: M-15B M-15BSample Date: 11/7/2007 3/10/2008BENZENE ug/l 1 U 1 UBENZENE METADISULFONIC ACID mg/l 0.05 U 0.05 UBENZENE MONOSULFONIC ACID mg/l 0.05 U 0.05 UP-PHENOL SULFONIC ACID mg/l 0.05 U 0.05 URESORCINOL mg/l 0.05 U 0.05 UTRIHYDROXYDIPHENYL mg/l 0.05 U 0.05 UU - Indicates non-detectedJ - Indicates estimateD - Indicates result is from analysis of a secondary dillutionWELL-M-15B4/18/2001F:\Craig Farm\FYR 2009\Summary Table_Wells Combined_063008Page 17 of 24Concentration Trends for M-15B 1999 though 2007012345601/01/99 01/01/00 01/01/01 01/01/02 01/01/03 01/01/04 01/01/05 01/01/06 01/01/07 01/01/08

Concentration (mg/L)BENZENE METADISULFONIC ACID mg/lP-PHENOL SULFONIC ACID mg/lRESORCINOL mg/lTRIHYDROXYDIPHENYL mg/lNOTES:-Open Symbols are non-detects.-Non-detects were replaced with half the detectionlimit.F:\Craig Farm\FYR 2009\Summary Table_Wells Combined_063008Page 18 of 24Summary of Analytical DataCraig Farm Superfund Site1999 through 2008Sample Location: M-15C M-15C M-15C M-15C WELL-M-15CSample Date: 2/11/1999 7/20/1999 3/2/2000 7/26/2000 4/18/2001BENZENE ug/l 1 U 1 U 1 U 1 U 1 UBENZENE METADISULFONIC ACID mg/l 10 U 10 U 0.05 U 0.05 U 0.05 UBENZENE MONOSULFONIC ACID mg/l 10 U 10 U 0.05 U 0.05 U 0.05 UP-PHENOL SULFONIC ACID mg/l 10 U 10 U 0.099 J 0.05 U 0.05 URESORCINOL mg/l 1.2 U 1.2 U 0.05 U 0.05 U 0.05 UTRIHYDROXYDIPHENYL mg/l 0.5 U 0.5 U 0.05 U 0.05 U 0.05 USample Location: M-15C M-15C DUP M-15C M-15C M-15C_DUPSample Date: 11/16/2001 11/16/2001 4/18/2002 11/14/2002 11/14/2002BENZENE ug/l 1 U 1 U 1 U 1 U 1 UBENZENE METADISULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UBENZENE MONOSULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UP-PHENOL SULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 URESORCINOL mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UTRIHYDROXYDIPHENYL mg/l 0.05 U 0.05 U 0.05 0.05 U 0.05 USample Location: M-15C M-15C M-15C M-15C M-15C M-15CSample Date: 4/17/2003 12/17/2003 6/16/2004 12/8/2004 6/8/2005 12/8/2005BENZENE ug/l 1 U 1 U 1 U 1 U 1 U 1 UBENZENE METADISULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UBENZENE MONOSULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UJP-PHENOL SULFONIC ACID mg/l 0.084 0.05 U 0.05 UJ 0.078 J 0.05 U 0.05 URESORCINOL mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UJ 0.05 UTRIHYDROXYDIPHENYL mg/l 0.117 0.05 U 0.421 0.05 U 0.05 U 0.05 USample Location: M-15C M-15C-032007Sample Date: 6/6/2006BENZENE ug/l 1 U 1 U 1 U 1 U 1 UBENZENE METADISULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UBENZENE MONOSULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UP-PHENOL SULFONIC ACID mg/l 0.05 U 0.118 0.05 U 65.2 0.093RESORCINOL mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UTRIHYDROXYDIPHENYL mg/l 0.05 U 0.883 0.05 U 0.05 U 0.05 UU - Indicates non-detectedJ - Indicates estimateD - Indicates result is from analysis of a secondary dillutionM-15C-11080611/8/2006 3/20/2007M-15C3/11/200811/7/2007M-15CF:\Craig Farm\FYR 2009\Summary Table_Wells Combined_063008Page 19 of 24Concentration Trends for M-15C 1999 though 200701020304050607001/01/99 01/01/00 01/01/01 01/01/02 01/01/03 01/01/04 01/01/05 01/01/06 01/01/07 01/01/08

Concentration (mg/L)P-PHENOL SULFONIC ACID mg/lTRIHYDROXYDIPHENYL mg/lNOTES:-Open Symbols are non-detects.-Non-detects were replaced with half the detectionlimit.F:\Craig Farm\FYR 2009\Summary Table_Wells Combined_063008Page 20 of 24Summary of Analytical DataCraig Farm Superfund Site1999 through 2008Sample Location: M-19B M-19B DUP M-19B M-19B M-19BSample Date: 2/10/1999 2/10/1999 7/20/1999 3/1/2000 7/25/2000BENZENE ug/l 1 U 1 U 1 U 1 U 1 UBENZENE METADISULFONIC ACID mg/l 10 U 10 U 10 U 0.05 U 0.05 UBENZENE MONOSULFONIC ACID mg/l 10 U 10 U 10 U 0.05 U 0.05 UP-PHENOL SULFONIC ACID mg/l 10 U 10 U 10 U 0.174 0.05 URESORCINOL mg/l 1.2 U 1.2 U 1.2 U 0.05 U 0.05 UTRIHYDROXYDIPHENYL mg/l 0.5 U 0.5 U 0.5 U 0.05 U 0.05 USample Location: WELL-M-19B M-19B M-19B M-19B M-19B M-19BSample Date: 4/17/2001 11/15/2001 4/18/2002 11/13/2002 4/16/2003 12/15/2003BENZENE ug/l 1 U 1 U 1 U 1 U 1 U 1 UBENZENE METADISULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UBENZENE MONOSULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UP-PHENOL SULFONIC ACID mg/l 0.169 0.05 U 0.05 U 0.05 U 0.05 U 0.05 URESORCINOL mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UTRIHYDROXYDIPHENYL mg/l 0.05 U 0.05 U 0.05 UJ 0.079 0.05 U 0.05 USample Location: M-19B M-19B M-19B DUP M-19B M-19BDUP M-19BSample Date: 6/14/2004 12/7/2004 12/7/2004 6/8/2005 6/8/2005 12/6/2005BENZENE ug/l 1 U 1 U 1 U 1 U 1 U 1 UBENZENE METADISULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UBENZENE MONOSULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UJP-PHENOL SULFONIC ACID mg/l 0.05 UJ 0.089 J 0.065 J 0.05 U 0.05 U 0.05 URESORCINOL mg/l 0.05 U 0.05 U 0.05 U 0.05 UJ 0.05 UJ 0.05 UTRIHYDROXYDIPHENYL mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U 0.05 USample Location: M-19B M-19B-032007 M-19B-110806Sample Date: 6/6/2006 3/20/2007BENZENE ug/l 1 U 1 U 1 U 1 U 1 U 1 UBENZENE METADISULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UBENZENE MONOSULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UP-PHENOL SULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U 0.053RESORCINOL mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UTRIHYDROXYDIPHENYL mg/l 2590 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UU - Indicates non-detectedJ - Indicates estimateD - Indicates result is from analysis of a secondary dillution11/8/2006 11/7/2007M-19B M-19B3/11/2008M-19BDUP11/7/2007F:\Craig Farm\FYR 2009\Summary Table_Wells Combined_063008Page 21 of 24Concentration Trends for M-19B 1999 though 2007012345601/01/99 01/01/00 01/01/01 01/01/02 01/01/03 01/01/04 01/01/05 01/01/06 01/01/07 01/01/08

Concentration of p-PSA (mg/L)050010001500200025003000 Concentration of THD (mg/L)P-PHENOL SULFONIC ACID mg/lTRIHYDROXYDIPHENYL mg/lNOTES:-Open Symbols are non-detects.-Non-detects were replaced with half the detectionlimit.F:\Craig Farm\FYR 2009\Summary Table_Wells Combined_063008Page 22 of24Summary of Analytical DataCraig Farm Superfund Site1999 through 2008Sample Location: M-19C M-19C DUP M-19C M-19C DUP M-19C M-19CSample Date: 2/10/1999 2/10/1999 7/20/1999 7/20/1999 2/29/2000 7/25/2000BENZENE ug/l 1 U 1 U 1 U 1 U 10 U 1 UBENZENE METADISULFONIC ACID mg/l 10 U 10 U 10 U 10 U 0.07 0.295BENZENE MONOSULFONIC ACID mg/l 10 U 10 U 10 U 10 U 0.05 U 0.05 UP-PHENOL SULFONIC ACID mg/l 10 U 10 U 10 U 2500 U 1.7 0.489RESORCINOL mg/l 300 U 300 U 300 U 300 U 50.6 34.8TRIHYDROXYDIPHENYL mg/l 550 D 570 D 620 D 550 D 443 311Sample Location: WELL-M-19C M-19C M-19C M-19CSample Date: 4/17/2001 11/15/2001 4/18/2002 11/13/2002BENZENE ug/l 1 U 1 U 1 U 1 UBENZENE METADISULFONIC ACID mg/l 0.059 0.063 0.05 U 0.05BENZENE MONOSULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 UP-PHENOL SULFONIC ACID mg/l 2.2 2.13 0.751 2.09RESORCINOL mg/l 36.4 31.5 26.4 41.1TRIHYDROXYDIPHENYL mg/l 343 247 213 399Sample Location: M-19C M-19C M-19C M-19C M-19C M-19CSample Date: 4/16/2003 12/15/2003 6/14/2004 12/7/2004 6/8/2005 12/6/2005BENZENE ug/l 1 U 1 U 1 U 1 U 1 U 1 UBENZENE METADISULFONIC ACID mg/l 0.068 0.055 0.055 0.056 0.05 U 0.648 JBENZENE MONOSULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UJP-PHENOL SULFONIC ACID mg/l 1.59 0.638 0.663 J 0.885 J 1.33 J 1.7RESORCINOL mg/l 34.3 33.1 39.9 40 29 J 38TRIHYDROXYDIPHENYL mg/l 375 501 409 395 328 315 JSample Location: M-19C M-19C-032007Sample Date: 6/6/2006BENZENE ug/l 1 U 1 U 1 U 1 U 1 UBENZENE METADISULFONIC ACID mg/l 0.0665 0.0779 0.05 U 0.05 U 0.05 UBENZENE MONOSULFONIC ACID mg/l 0.0576 0.05 U 0.05 U 0.05 U 0.05 UP-PHENOL SULFONIC ACID mg/l 0.636 1.11 1.26 0.885 0.701RESORCINOL mg/l 36.2 25.2 30.2 30.7 30.1TRIHYDROXYDIPHENYL mg/l 305 401 316 303 297U - Indicates non-detectedJ - Indicates estimateD - Indicates result is from analysis of a secondary dillutionM-19C-11080611/8/2006 3/20/2007M-19C3/12/200811/7/2007M-19CF:\Craig Farm\FYR 2009\Summary Table_Wells Combined_063008Page 23 of 24Concentration Trends for M-19C 1999 though 200702004006008001000120014001/1/1999 1/1/2000 1/1/2001 1/1/2002 1/1/2003 1/1/2004 1/1/2005 1/1/2006 1/1/2007 1/1/2008

Concentration (mg/L)P-PHENOL SULFONIC ACID mg/lRESORCINOL mg/lTRIHYDROXYDIPHENYL mg/lBENZENE MONOSULFONIC ACID mg/lBENZENE METADISULFONIC ACID mg/lNOTES:-Open Symbols are non-detects.-Non-detects were replaced with half the detectionlimit.F:\Craig Farm\FYR 2009\Summary Table_Wells Combined_063008Page 24 of 24

# Attachment 4 – Site Inspection Checklist

### Site Inspection Checklist

I. SITE INFORMATION

Site name: Craig Farm Drum Date of inspection: 09/03/2008
Location and Region: Region III: Perry Township, PA EPA ID: PAD980508527
Agency, office, or compan y leading the five-year review: EPA Weather/temperature: Sunny, ~85 o

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

_____________________________________________________________________________ Attachments: Inspection team roster attached Site map attached

II. INTERVIEWS (Check all that apply)

1. O&M site manager Jason Hanna Project Manager 09/03/2008 Name Title Date Interviewed at site at office by phone Phone no. ______________ Problems, suggestions; Report attached ________________________________________________

__________________________________________________________________________________

2. O&M staff

____________________________ ______________________ ____________ Name Title Date Interviewed at site at office by phone Phone no. ______________ 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, zoni ng office, recorder of deeds, or other city and county offices, etc.) Fill in all that apply.

Agency: United States Fish and Wildlife Service Contact: Kathleen Patnode Environmental Contaminants Specialist 09/03/08 304-234-0238 Name Title Date Phone no. Problems; suggestions; G Report attached _______________________________________________

__________________________________________________________________________________ Agency: Pennsylvania Department of Environmental Protection Contact: Annette Paluh Environmental Protection Specialist 09/03/08 412-442-4158 Name Title Date Phone no. Problems; suggestions; G Report attached _______________________________________________

__________________________________________________________________________________ Agency: Pennsylvania Department of Environmental Protection Contact: Barbara Gunther Project Officer 09/03/08 Name Title Date Phone no. Problems; suggestions; G Report attached _______________________________________________

__________________________________________________________________________________ Agency ____________________________ Contact ____________________________ __________________ ________ ____________ Name Title Date Phone no. Problems; suggestions; G Report attached _______________________________________________

__________________________________________________________________________________

4. Other interviews (optional) Report attached.
Jane Patarcity, Beazer East, Inc. (no report)
Georgia L. Horner, area resident (report attached)III. ON-SITE DOCUMENTS & RECORDS VERIFIED (Check all that apply)

1. O&M Documents

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

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

G Maintenance logs G Readily available G Up to date N/A Remarks__________________________________________________________________________

_ 

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

G Contingency plan/emergency response plan G Readily available G Up to date N/A Remarks__________________________________________________________________________

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

_________________________________________________________________________________ 4. Permits and Service Agreements

G Air discharge permit G Readily available G Up to date N/A

G Effluent discharge G Readily available G Up to date N/A

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

G Other permits_____________________ G Readily available G Up to date N/A Remarks__________________________________________________________________________

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

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

_________________________________________________________________________________ 7. Groundwater Monitoring Records G Readily available G Up to date N/A Remarks__________________________________________________________________________

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

_________________________________________________________________________________ 9. Discharge Compliance Records

G Air G Readily available G Up to date N/A

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

_________________________________________________________________________________ 10. Daily Access/Security Logs G Readily available G 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 Other__________________________________________________________________________

_________________________________________________________________________________ 2. O&M Cost Records

G Readily available G Up to date

G Funding mechanism/ agreement in place Original O&M cost estim ate $500,000/year G Breakdown attached

Total annual cost by year for review period if available

From__________ To__________ __________________ G Breakdown attached Date Date Total cost From__________ To__________ __________________ G Breakdown attached Date Date Total cost From__________ To__________ __________________ G Breakdown attached Date Date Total cost From__________ To__________ __________________ G Breakdown attached Date Date Total cost From__________ To__________ __________________ G Breakdown attached Date Date Total cost

3. Unanticipated or Unusually High O&M Costs During Review Period Describe costs and reasons: N/A_______________________________________________________

_________________________________________________________________________________

_________________________________________________________________________________

_________________________________________________________________________________

_________________________________________________________________________________

_________________________________________________________________________________ V. ACCESS AND INSTITUTIONAL CONTROLS Applicable N/A
A. Fencing

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

_________________________________________________________________________________ B. Other Access Restrictions

1. Signs and other security measures Location shown on site map N/A Remarks__________________________________________________________________________

_________________________________________________________________________________C. Institutiona l 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-reportin g: site inspection, groundwater sampling Frequency: Annual site inspection, semi-annual sampling Responsible party/agency : Beazer East, Inc. Contact: Jane Patarcity Manager-Environmental & Technical Services 09/03/08 412-208-8813 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: G 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: A Focused Feasibility Study is currently being conducted to optimize the remedy. The optimization is anticipated to include an impermeable cap over a portion of the site and installation of a contingency surface water containment system.

3. Land use changes off site N/A Remarks__________________________________________________________________________

_________________________________________________________________________________ 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



### ______________________________________________________________

____________________________________________________________________

____________________________________________________________________

____________________________________________________________________

____________________________________________________________________

____________________________________________________________________

VII. LANDFILL COVERS Applicable N/A

A. Landfill Surface

1. Settlement (Low spots) Location shown on site map Settlement not evident Areal 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 Areal extent______________ Depth____________ Remarks__________________________________________________________________________

_________________________________________________________________________________ 4. Holes Location shown on site map Holes not evident Areal extent______________ Depth____________ 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 (armored rock, concrete, etc.) N/A Remarks__________________________________________________________________________

_________________________________________________________________________________ 7. Bulges Location shown on site map Bulges not evident Areal extent______________ Height____________ Remarks__________________________________________________________________________

_________________________________________________________________________________

8. Wet Areas/Water Damage Wet areas/water damage not evident Wet areas Location shown on site map Areal extent______________ Ponding Location shown on site map Areal extent______________ Seeps Location shown on site map Areal extent______________ Soft subgrade Location shown on site map Areal extent______________ Remarks__________________________________________________________________________

_________________________________________________________________________________9. Slope Instability Slides Location shown on site map No evidence of slope instability Areal extent______________ Remarks__________________________________________________________________________

_________________________________________________________________________________ B. Benches Applicable N/A (Horizontally constructed mounds of earth placed across a steep landfill side slope to interrupt the slope in order to slow down the velocity of surface runo ff 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 co llected by the benches to move off of the landfill cover without creating erosion gullies.)

1. Settlement Location shown on site map No evidence of settlement Areal extent______________ Depth____________ Remarks__________________________________________________________________________

_________________________________________________________________________________ 2. Material Degradation Location shown on site map No evidence of degradation Material type_______________ Areal extent_____________ Remarks__________________________________________________________________________

_________________________________________________________________________________ 3. Erosion Location shown on site map No evidence of erosion Areal extent______________ Depth____________ Remarks__________________________________________________________________________

_________________________________________________________________________________4. Undercutting Location shown on site map No evidence of undercutting Areal extent______________ Depth____________ Remarks__________________________________________________________________________

_________________________________________________________________________________ 5. Obstructions Type_____________________ G No obstructions Location shown on site map Areal 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 Areal extent______________ Remarks__________________________________________________________________________

_________________________________________________________________________________ D. Cover Penetrations Applicable N/A

1. Gas Vents Active Passive Properly secured/locked Functioning Routinely sampled Good condition Evidence of leakage at penetration Needs Maintenance N/A Remarks__________________________________________________________________________

_________________________________________________________________________________ 2. Gas Monitoring Probes Properly secured/locked Functioning Routinely sampled Good condition Evidence of leakage at penetration Needs Maintenance N/A Remarks__________________________________________________________________________

_________________________________________________________________________________ 3. Monitoring Wells (within surface area of landfill) Properly secured/locked Functioning Routinely sampled Good condition Evidence of leakage at penetration Needs Maintenance N/A Remarks_



### __________________________________________________________

_________________________________________________________________ 4. Leachate Extraction Wells Properly secured/locked Functioning Routinely sampled Good condition Evidence of leakage at penetration Needs Maintenance N/A 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 Good condition Needs Maintenance 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 Areal extent______________ Depth____________ N/A Siltation not evident Remarks__________________________________________________________________________

_________________________________________________________________________________ 2. Erosion Areal 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 disp lacement_______________ 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 Areal extent______________ Depth____________ Remarks__________________________________________________________________________

_________________________________________________________________________________ 2. Vegetative Growth Location shown on site map N/A Vegetation does not impede flow Areal extent______________ Type____________ Remarks__________________________________________________________________________

_________________________________________________________________________________ 3. Erosion Location shown on site map Erosion not evident Areal 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 Areal extent______________ Depth____________ Remarks__________________________________________________________________________

_________________________________________________________________________________ 2. Performance Monitoring Type of monitoring__________________________ Performance not monitored Frequency_______________________________ Evidence of breaching Head differential__________________________ 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 Surface/seep water collecti on trench system with storage tank. Good condition Needs Maintenance Sampling ports properly marked and functional Sampling/maintenance log displayed and up to date Equipment properly identified Quantity of groundwater treated annually________________________ Quantity of surface water trea ted annually_____

___________________ Remarks__________________________________________________________________________

_________________________________________________________________________________ 2. Electrical Enclosures and Panels (properly rated and functional) N/A Good condition Needs Maintenance Remarks__________________________________________________________________________

_________________________________________________________________________________ 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__________________________________________________________________________

_________________________________________________________________________________ 5. Treatment Building(s) N/A Good condition (esp. roof and doorways) Needs repair Chemicals and equipment properly stored Remarks__________________________________________________________________________

_________________________________________________________________________________ 6. Monitoring Wells (pump and treatment remedy) Properly secured/locked Functioning Routinely sampled Good condition All required wells located Needs Maintenance N/A Remarks: Additional monitoring wells installed during Focused Feasibility Study in 2007/2008.
D. Monitoring Data 1. Monitoring Data Is routinely submitted on time Is of acceptable quality 2. Monitoring data suggests: Groundwater plume is effectively contained Contaminant concentrations are decliningD. Monitored Natural Attenuation

1. Monitoring Wells (natural attenuation remedy) Properly secured/locked Functioning Routinely sampled Good condition All required wells located Needs Maintenance N/A Remarks__________________________________________________________________________

_________________________________________________________________________________ X. OTHER REMEDIES
If there are remedies applied at the site which are not covered above, attach an inspection sheet describing the physical nature and condition of any facility asso ciated 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 to accomplish (i.e., to contain contaminant plume, minimize infiltration and gas emission, etc.):

The purpose of the remedy is to intercept onsite seeps to preven t shallow groundwater/surface water from reaching the onsite Unnamed Creek. A seep collection system consisting of two collection trenches feeding into an above ground storage tank were installed to meet this remedial goal. Additionally, waste excavated from two former onsite waste disposal ar eas was solidified onsite and placed into an onsite landfill. Monitoring wells are installed onsite downgr adient of the former disposal pits and surrounding the landfill to monitor contaminant migration. The remedy is functioning as designed. Surface water and shallow groundwater contamination is effectively being contained by the seep collection tr ench. Contaminant concentrations in groundwater monitoring wells have generally declined site-wide or remained relatively stable and contaminant concentrations in landfill monitoring wells indicate th at contamination is effectively contained within the landfill. Samples collected from Seep B indicate that the seep water is no longer toxic for two consecutive sampling events, thereby fulfilling the require ments of the ROD for this seep. Samples from Seep A indicate the water continues to be toxic. De sign is currently underway for a modification to the remedy consisting of an impermeable cap and groundwater infiltration system to reduce contaminated overburden groundwater.

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:

No issues were identifie d with respect to the currently implemented O&M at the site. The remedy appears to be effective in both the short and the long term. The PRP is currently designing a remedy modification and may eliminate the need for certain O&M tasks, such as disposal of seep water collected by the aboveground storage tank. The revised O&M plan will be evaluated when the remedy optimization is complete.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.

No indications of potential issues with the remedy were observed



### .

D. Opportunities for Optimization
Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy:

As noted above, the PRP is currently designing a remedy modification to be completed in 2009.

# Attachment 5 – Interview Summary

## INTERVIEW RECORD

Site Name: Craig Farm Drum Superfund Site EPA ID No.: PAD980508527
Subject: Five Year Review Time: 1300 Date: 09/03/08
Type: Telephone Visit Other Location of Visit:  Incoming  Outgoing



### Contact Made By:

Name: John Epps Title: Remedial Project Manager Organization: EPA


### Individual Contacted:

Name: Georgia L. Horner Title: Area Resident Organization: N/A
Telephone No: Fax No: E-Mail Address: Street Address: 388 Bruin-Queenstown Road City, State, Zip: Parker, PA 16049



### Summary Of Conversation

The resident indicated that sh e was pleased with the remediation of the site but was disappointed that she was not allowed to have a water supply well and was required to be connected to public water.

Note: The site is located within the area designated by the Pennsylvania Department of Environmental Protection (PADEP) as the Bear Creek Area Chem ical Site (BCACS). The BCACS enco mpasses multiple inactive chemical disposal sites and active chemical manuf acturing plants. In 2003, all residen ces within the BCACS were required to connect to public water and abandon existing wells.

### INTERVIEW DOCUMENTATION FORM
The following is a list of individual interviewed for this five-year review. See the attached contact record(s) for a detailed summary of the interviews.

_ Georgia L. Horner

_ Name __ Area Resident

__ Title/Position _______ N/A

______ Organization ___ 09/03/2008

___ Date

_________________ Name _________________ Title/Position _________________ Organization _________________ Date

_________________ Name _________________ Title/Position _________________ Organization _________________ Date

_________________ Name _________________ Title/Position _________________ Organization _________________ Date

_________________ Name _________________ Title/Position _________________ Organization _________________ Date

_________________ Name _________________ Title/Position _________________ Organization _________________ Date