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 Chronology ............................................................................................................................. 2 

III. Background ............................................................................................................................... 3 

Physical Characteristics...................................................................................................................... 3 

Land and Resource Use...................................................................................................................... 4 

History of Contamination................................................................................................................... 5 

Initial Response .................................................................................................................................. 6 

Basis for Taking 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. Issues ....................................................................................................................................... 30 

IX. Recommendations and 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 Environmental 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 Site) is located in Perry Township, Armstrong 

County, Pennsylvania. Contamination at the Site resulted from the disposal of drums 

containing still bottoms from Resorcinol production 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 Site. 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 needed 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 excavation and onsite solidification of 

contaminated material and soils. The solidified material was placed in an onsite, 

Resource Conservation and Recovery Act (RCRA)-equivalent landfill. 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 interceptor 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 wetland was constructed onsite to replace a 

smaller area of wetland destroyed during construction of the onsite landfill. Operations 

and Maintenance (O&M) of the remedy consists of semi-annual inspections of the 

landfill and seep interceptor system and groundwater sampling and analysis. 

Construction completion at the Site was achieved with the approval of the December 27, 

1995 Final Close Out Report (FCOR). Because the 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 equivalent to the current Preliminary Closeout 

Report (PCOR) in that it documents construction completion. 

Institutional controls implemented at the Site consist of a Declaration of Restrictions 

attached to the deed informing property owners 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). Additionally, the other seep 

(Seep B) no longer exhibits toxicity and the 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 the previous Five Year Review, dated June 29, 

2004. This Five Year Review has concluded that the physical construction of the remedy 

was completed in accordance with the requirements of the ROD. Additionally, this 

review has indicated that the remedy is functioning as designed, and is protective of 

human health and the environment. 

Government Performance Results 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 Health 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 insufficiently 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 Significant Differences (ESD) to clarify the requirements for the institutional 

controls.

Additionally, EPA is currently reviewing 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 groundwater 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 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 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 and future Site owners of the contaminants onsite and 

restricting landfill and groundwater use. The requirements for the institutional controls 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 determine whether the remedy at a site is 

protective of human health and the environment. The methods, findings, and conclusions 

of reviews are documented in Five Year Review reports. In addition, Five Year Review 

reports identify issues found during the review, 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 remedial action that results in any hazardous substances, 

pollutants, or contaminants remaining at the Site, the President shall review such 

remedial action no less often than each five years after the initiation of such remedial 

action to assure that human health and the environment are being protected by the 

remedial action being implemented. In addition, if upon such review it is the judgment of 

the President that action is appropriate at such Site in accordance with section [104] or 

[106], the President shall take or require such action. The President shall report to the 

Congress a list of facilities for which such review is required, the results of all such 

reviews, and any actions taken as a result of such reviews. 

The agency interpreted this requirement further in the NCP; 40 CFR §300.430(f) (4) (ii) 

states: 

If a remedial action is selected that results in hazardous substances, pollutants, or 

contaminants remaining at the Site above levels that allow for unlimited use and 

unrestricted exposure, the lead agency shall review such action no less often than every 

five years after the initiation of the selected remedial action. 

The United States Environmental Protection Agency (EPA) Region III has conducted a 

Five Year Review of the remedial actions implemented at the Craig Farm Drum 

Superfund Site (the Site) located in Perry Township, Armstrong County, Pennsylvania. 

This review was conducted for the entire Site by the Remedial Project Manager (RPM) 

from June 2008 through June 2009. This report documents the results of the review.

Page 1 
Craig 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, pollutants, 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 for 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 Report by EPA December 1980 

Proposed for National Priorities 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 and Services Inc. (Beazer). January 20, 1989 

Beazer submitted the final RI/FS Report to EPA and PADER. August 1989 

A Special Notice Letter providing the opportunity to make a good faith offer 

was sent to Beazer by EPA. 

August 24, 1989 

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Craig Farm Drum Superfund Site 

Third Five-Year Review 

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Table 1 – Chronology of Site Events 

Event Date 

The RI/FS and the Proposed Plan 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 18, 1990 Consent Decree signed by Beazer for completion of Remedial Design and 

Remedial Action (RD/RA) 

EPA approved Final RD Work Plan January 14, 1991 

July 14, 1993 Operations and Maintenance Plan (O&M Plan) approved by EPA and 

PADER. 

EPA approved Final RD Report September 27, 1993 

May 1994 Onsite mobilization for the RA for Operable Unit 1 (OU-1), Operable Unit 2 

(OU-2), and Operable Unit 3 (OU-3). 

The construction of the remedial action 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 approximately 117 acres 

located in Perry Township, in the vicinity of the village of Fredericksburg, near the 

western border of Armstrong County, Pennsylvania (Figure 1). The Site is located 

approximately two (2) miles east of the Borough of Petrolia and approximately four (4) 

miles south of the town of Parker and the 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. 

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Craig Farm Drum Superfund Site 

Third Five-Year Review 

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Geology at the Site consists of the following 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 coal 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 historically been designated as the upper bedrock aquifer and 

will be referred to as such in this document. 

Groundwater is present at the Site under water 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 twenty (20) percent other use. Land use in the direct vicinity 

of the Site is consistent with that of Armstrong County and consists primarily of farmland 

and limited residential use. Strip mining is currently and has historically been conducted 

in the direct vicinity of the Site as well. Population density estimates range from 65 

persons per square mile (mi2) in Perry Township to 106 persons per mi2 for Armstrong 

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

Page 4 
Craig Farm Drum Superfund Site 

Third Five-Year Review 

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Historically, prior to 1958, the Site was operated as a strip mine working the Upper 

Freeport coal seam. Following the cessation 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, Pennsylvania. Disposal activities were conducted 

from approximately 1958 through 1963, during which time the Site was owned by Mr. 

Paul Craig. Koppers purchased approximately 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 the Site and immediately adjacent 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 unoccupied and groundwater use restrictions 

exist for the Site due to deed restrictions and for the surrounding 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 undeveloped, with the exception of the components of the remedy, 

consisting primarily of a landfill and seep interceptor system. No proposed 

redevelopment plan currently exists for the Site. 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 the Site, commercial or 

residential development potential is limited. 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, the 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 containing still bottom residue from the 

manufacturing of Resorcinol at the nearby Koppers plant were deposited in the 

abandoned former strip mine pits, hereinafter known as the north and south disposal pits. 

Resorcinol, also known as 1,3-Benzenediol, 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 5 
Craig Farm Drum Superfund Site 

Third Five-Year Review 

June 2009

The residue, consisting of Resorcinol and other higher 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 during the time the drums were 

stored onsite, many drums were damaged, resulting 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 Site Identification Report in December 1980. 

Initial Response

Following the completion of the aforementioned Potential Hazardous Waste Site 

Identification Report by EPA in 1980, the Craig Farm Drum Site was proposed for 

placement on the National Priorities List (NPL) 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 PADEP) with a proposal to conduct an 

Environmental Assessment (EA) of the Site. 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 Department of Public Protection issued an 

Emergency Preparedness Plan for the Site. In April 1984, Koppers, under PADER 

oversight, installed a total of fifteen (15) test pits to determine 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 6 
Craig Farm Drum Superfund Site 

Third Five-Year Review 

June 2009

From fall 1984 through November of 1985, Koppers worked with PADER and EPA 

toward the development of a Remedial Investigation/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 characterization as necessary to satisfy RI/FS 

requirements. 

Basis for Taking Action

From February 1986 through November 1987, Keystone 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 contamination. 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 submitted to PADER and EPA in August 1989. 

Source Material Investigation 

Test pits installed in the disposal pits in 1984 prior to the RI/FS indicated the still bottom

residue consisted of black to pink semisolid material with some hardened masses. The 

North disposal pit was observed to be approximately 1.2 to 1.5 acres in lateral extent and 

the South disposal pit was observed to be approximately 0.8 to 1.0 acres in lateral extent. 

Analytical data of samples collected during test pit installation indicated that the source 

material in the disposal pits is located between approximately 2.5 and 6.0 feet below 

ground surface (bgs). Contaminated soil was also observed in the vicinity of the disposal 

pits during test pit installation, particularly in down-slope areas. 

Soil was impacted by the following 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 7 
Craig Farm Drum Superfund Site 

Third Five-Year Review 

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Soil was impacted by the following site-related inorganic compounds: 

 Cadmium. 

Groundwater Quality Findings 

Groundwater quality data collected during the RI/FS indicated the presence of impacted 

groundwater in three (3) water bearing zones at the Site; the unconsolidated materials 

zone, the upper bedrock (shale) aquifer, and 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 zones by the following site-related inorganic 

compounds: 

 Cadmium; 

 Chromium; 

 Copper; 

 Lead; 

 Zinc. 

Impacted groundwater was detected in the unconsolidated materials zone across the 

majority of the Site. Groundwater within this zone is located 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 Creek. 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 zone 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 aquifer was detected from the disposal pit 

areas extending to the immediate east of the Unnamed Creek valley bottom. 

Groundwater within the lower sandstone aquifer is influenced by regional flow patterns 

in the direction of the valley bottom. 

Page 8 
Craig 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 characterized as a lack of macroinvertebrate 

species that are typically an indicator of good water quality. Statistical data indicated that 

of the site-related compounds, THD has the greatest impact on macroinvertebrates. 

However, analysis of tissue samples from macroinvertebrates in the Unnamed Creek did 

not detect any bioaccumulation or biomagnification of site-related compounds. 

No stress was detected in fish species within 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 monitoring 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 health via air transport from site-related 

compounds. 

Summary of Site Risks 

Based on the 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 9 
Craig Farm Drum Superfund Site 

Third Five-Year Review 

June 2009

Toxicological data for the majority of the organic COCs at the Site is scarce or does not 

exist. Therefore, Resorcinol was utilized as a representative compound based on the 

similarity of its structure to the other site-related organic COCs. The available 

toxicological data for Resorcinol indicates that it 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 migration route analysis identified deep and shallow soils and 

groundwater as potential migration 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 concentrations of all COCs in groundwater. 

The evaluation eliminated surface water, sediments, and ambient air as potential 

migration routes. The decision to eliminate 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 migration 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 ambient air above detection limits or background 

levels and none of the COCs are considered volatile compounds, thereby eliminating 

ambient air as a potential migration pathway. 

Potential Human Exposure Pathways 

The evaluation of potential human exposure pathways included the consideration of 

potential current and future uses of the Site. The Site is currently uninhabited and is 

restricted from recreational use. At the time of the ROD, the remoteness and steepness of 

the slope of the Site was anticipated to preclude any future commercial or residential 

development. Based on this evaluation, the following potential human exposure 

pathways were developed for risk characterization: 

 Incidental ingestion and dermal absorption of COCs in surface soils by 

trespassers; 

 Dermal absorption of COCs in groundwater by hypothetical future miners; 

 Incidental ingestion and dermal absorption of COCs in groundwater by future 

offsite domestic well users. 

At the time of the ROD, the vapor intrusion exposure pathway was not evaluated, 

therefore, a screening evaluation was conducted during this Five Year Review. COCs 

present onsite at high concentrations consist primarily of Resorcinol and THD. During 

the RI/FS, the volatility of Resorcinol and 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 

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aquifer only, both of which discharge onsite to the Unnamed Creek. Benzene was not 

detected in the lower sandstone aquifer in which 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 pathways included the potential 

impact to terrestrial species inhabiting the 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 exposed 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 assessment and risk characterization was conducted for each of the 

identified potential human exposure pathways. The COCs evaluated for each pathway 

varied based on predicted usage patterns. The 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 

Trespassers Dermal Absorption - Soil 0.07 N/A 

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 

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The total hazard indices calculated for each of the potential receptors were less than 1, 

indicating that the estimated intakes for each receptor are less than threshold intake levels 

and that there is no appreciable risk 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 carcinogenic 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 indicates 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, primarily 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 Unnamed Creek is being 

impacted by site-related COCs. Therefore, the selection of the remedy for the Site was 

based on the Site’s impact to the environment 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 defining the operable units and selecting the final remedy for the Site was 

issued September 29, 1989. The goals of the remedial 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 contaminants into nearby surface waters; 

 Control the migration of contaminants 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 Closeout 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. 

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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 disposal 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 via 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 and onsite living organisms; 

 Prevent continued leaching of precipitation and surface waters through 

contaminated landfill material; 

 Eliminate exposure to contaminated groundwater; 

 Minimize risk to human health and the 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 from 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 construction of a one-acre onsite wetland to 

replace wetlands destroyed in construction of the onsite landfill; 

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 Implementation of institutional controls alerting property owners of 

contamination; 

 Passive collection of ground water using a seep interceptor system with offsite 

treatment: 

o Remediation considered complete by analyzing 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 was 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 above, 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 total 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 (HDPE) secondary geomembrane; 

o PN-3000 Geonet leak detection zone; 

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

o GCL (added to minimize potential leachate migration); 

o 60-mil HDPE primary geomembrane; 

o PN-3000 Geonet collection zone (for additional 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 landfill perimeter to prevent disturbance; 

 Installation of collection trenches upslope from and perpendicular 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 the collection sump at the low end of the trench; 

o Sump pump with level control to pump collected groundwater to 40,000- 

gallon storage tank (ten (10) days of storage); 

o Storage tank is emptied weekly by pump truck and transported offsite for 

treatment. 

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 Construction of a one-acre wetland to replace the wetland destroyed during 

construction of the onsite landfill. 

A Groundwater Verification Study (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 contaminant 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 results 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 Plan) 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 piping and tank including 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. Additional 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 plantings to determine if the wetlands are 

meeting performance standards. Currently, 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 conducted by Field and Technical Services, 

LLC (FTS) on behalf of Beazer. 

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The landfill monitoring wells consist of upgradient well LF-1 and downgradient wells 

LF-2, LF-3, and LF-4 (Figure 2). The purpose 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 disposal pits and MW-14B, MW-15B, MW-15C, 

MW-19B, and MW-19C located further downgradient of the former disposal pits (Figure 

2). Wells with an A designation are installed 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. The purpose of these wells is to ensure that 

groundwater contamination is not migrating offsite. 

The surface water component of O&M consisted of sampling the Unnamed Creek and 

water collected by the seep interceptor system 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 with a five (5) percent interest rate. 

Beazer has not furnished actual cost documentation. 

V. Progress Since Last Five-Year Review 

The Second Five-Year Review was completed 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 the environment due to the completion 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 and groundwater use will have to be put in 

place. 

In addition to the lack of institutional controls, 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, unidentified 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. 

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The landfill cap, seep interceptor system, and the monitoring wells have continued to be 

regularly inspected and maintained. Inspections indicate that the 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 PADEP 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 pay the Commonwealth 

$18,118,813.00 to resolve its potential liability under HSCA for 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 prohibiting the use of 

groundwater wells for potable water, and to require property owners to connect to the 

public water system. Construction of the public 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 transported offsite for treatment to Beazer’s 

Petrolia Treatment Facility at the INDSPEC 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 alternative 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. 

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Treatability Studies 

From 1999 through 2005, multiple treatability studies were conducted at the Site by 

Beazer to evaluate alternatives to the currently implemented remedy of seep water 

collection and offsite treatment. A brief summary of the treatability studies is provided 

below: 

Granular Activated Carbon Study 

A 40-day, pilot-scale granular activated carbon (GAC) study was conducted by 

ThermoRetec in 1999. In this study, a GAC column pilot unit was installed at the 

Petrolia treatment facility consisting of two 4-foot long, 2-inch diameter glass columns 

containing two (2) feet of GAC per column. Water from the existing onsite seep 

collection tank was pumped though the system and 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 usage 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 Adventus Americas, Inc. (AAI) in 2004 to 

determine the feasibility of replacing the offsite treatment system with an onsite, in-situ, 

in-line bioreactor system. In this study, a bioreactor was installed in series with the 

onsite collection piping and coupled to a GAC unit. The study indicated that the 

bioreactor reduced COC concentrations, toxicity levels, and total organic carbon 

concentrations in the collected seep water. Based on Microtox IC50 testing conducted on 

the bioreactor system effluent, toxicity 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 the onsite collection piping. The bioreactor’s influent and 

effluent were sampled on a monthly basis for total organic carbon, pH, temperature, 

dissolved oxygen, conductivity, turbidity, and oxygen reduction potential. The pilotscale bioreactor system reduced COC concentrations, toxicity levels, and total organic 

carbon concentrations similar to those observed during the bench-scale study, however, 

according to Microtox IC50 testing, the pilot-scale test only reduced toxicity by a factor 

of 1.93 after three months of operation and monitoring. This result indicated that the 

bioreactor system was not a feasible alternative for treating the seep water. 

Powdered Activated Carbon Treatment Study 

A 50-day bench-scale powdered activated carbon 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, 

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a chronic fathead minnow survival and growth bioassay indicated that a full-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 piping was flushed to remove residual solids 

and, in May 2006, water samples from both Seep 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 concentrations 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 the promulgation of the AMEC AWQC under 25 

Pa. Code Chapter 16 for sulfonates and Resorcinol. 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 samples collected from Seeps A and B in May 2006 by Key Environmental were 

also submitted for a 7-day fathead minnow whole effluent toxicity (WET) test using a 

series of nine (9) effluent dilutions ranging 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 observed 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 chronic toxicity of Seep A using the growth 

endpoint both exceed the PADEP WET screening criteria. 

The results of the testing conducted on the Seep B effluent indicated an observed NOEC 

of 100% (no dilution). Both the acute and chronic toxicity of the Seep B samples were 

below the PADEP WET toxicity screening criteria. 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 Environmental Services (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 stream flow velocity measurement in the 

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Unnamed Creek and Valley Run and flow velocity measurement in Seep A and B 

collection trenches. The field measurements indicated that the average 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 additional remedial alternatives for 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 initial 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 wells, 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 development of water budget. 

A Conceptual Site Model (CSM) was developed with the data collected during the initial 

investigation and conclusions of the model are summarized as follows: 

 Direct correlation of rainfall with flow in Seep A collection trench; 

 Seasonal fluctuation of overburden (approximately 5 ft) and shallow bedrock 

(approximately 1.5 feet) water tables; 

 Overburden groundwater flow is connected to the Unnamed Creek during wet 

periods but there is no flow in the Unnamed Creek during dry periods; 

 Shallow bedrock groundwater is not linked to the Unnamed Creek; 

 Downward vertical groundwater flow gradient; 

 Groundwater flow toward Unnamed Creek (west) in both overburden and shallow 

bedrock aquifers; 

 Preferential flow pathways may 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 water samples during two (2) consecutive 

sampling events. 

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Based on the data from the initial investigation, an Addendum to Focused Feasibility 

Study Work Plan (FFS Work Plan Addendum) was submitted to EPA by Langan on May 

6, 2008 and approved on June 19, 2008. The following provides a brief summary of the 

FFS Work Plan Addendum tasks: 

 Installation of one (1) permanent shallow bedrock groundwater monitoring well 

upgradient of the former northern disposal pit area; 

 Borehole video logging of select exiting deep bedrock groundwater monitoring 

wells; 

 Aquifer loading test in the Seep A study area consisting of adding potable water 

to an existing deep bedrock groundwater monitoring well; 

 Topographic survey of the Seep A drainage area and new wells to NAV 88 

datum; 

 Installation of test pits in select onsite 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 Design 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 “Revised 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 Infiltration of Upgradient Groundwater. 

The evaluation of the alternatives identified Alternative 3 – Capping and Infiltration of 

Upgradient Groundwater as the preferred remedy 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; 

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 Installation of bioswales or other infiltration features to direct flow from capped 

area; 

 Installation of groundwater drain system upgradient of the former north pit to 

prevent upgradient groundwater flow through north pit materials; 

 Continued maintenance of the Seep A collection 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 trench by closing valves such that the 

system no longer collects water. 

Additional proposed O&M associated with the remedy modification 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, existing Seep A collection 

system, former north and south pit areas, aboveground storage tank, and ancillary 

facilities. 

Based on the results of EPA-approved bioassay testing, Seep B has achieved the 

performance standard specified in the ROD and no longer exhibits toxicity. Therefore, 

no further remedial action was determined to be necessary for the collection and 

treatment of Seep B water. Beazer has proposed to decommission the Seep B collection 

trench via the closure of valves so that the system no longer 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 remedy 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 Differences (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 Gunther, Project Officers for PADEP, and 

Kathleen Patnode, Biologist for the U.S. Fish and Wildlife Service comprised the 

remainder of the team. 

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The Site inspection occurred on September 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 Services (Langan), environmental consultants 

for Beazer. 

Community Involvement

EPA RPM John Epps conducted community interviews door-to-door with residents in the 

immediate vicinity of the Craig Farm Drum Site. One resident was interviewed and 

indicated they were pleased with the remediation of the Site. Additionally, notice of the 

review was provided to Perry Township via telephone, letter, and a visit 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 vicinity 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 Site has been completed. Information on the 

results of the review and the report availability 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 relevant documents, listed 

with the pertinent information 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 protectiveness 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. 

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Craig Farm Drum Superfund Site 

Third Five-Year Review 

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 Operations and Maintenance Plan for 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 Year 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, except 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 the cap or stabilized 

contents of the landfill or would otherwise disturb any component of the remedial 

action/design without prior written approval of the Site owner and EPA; 

 The Site may not be used for the purposes of living, dwelling, or overnight 

accommodations of any type; 

 No action may be taken that will interfere with, obstruct, or disturb the 

performance of any remedial response, including O&M; 

 Any Site owner must provide any purchaser with notice of the terms of the 

Consent Decree prior to transferring any interest in the Site.

However, the institutional controls are only discussed in the declaration of the ROD and 

not in the remedy selection portion. Additionally, the ROD requires deed notices only 

and not the deed restrictions that are currently 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 remain in place. The deed restrictions currently 

implemented at the Site are included as Attachment 1.

Data Review

Data available for review for the Site consists of inspection reports regarding the onsite 

landfill, the wetland mitigation reports prepared by PADEP, and groundwater monitoring 

data collected from the onsite monitoring well networks and seep interceptor system. 

Page 24 
Craig Farm Drum Superfund Site 

Third Five-Year Review 

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Inspections 

Inspections of the onsite landfill (OU-1) have indicated that the landfill cap is functioning 

correctly and the fence surrounding the properly is in good condition. Additionally, an 

inspection of the seep interceptor system indicated the system is functioning properly. 

The historic annual PADEP wetlands inspections indicated that the condition of the 

wetland mitigation area ranged from good to excellent. The hydrophytic vegetation was 

diverse and hydrology had been very good to excellent. Additionally, muskrat, ducks, 

bullfrogs, spring peepers, red- winged blackbirds, deer, herons and various songbirds 

have been observed in the mitigated wetland. PADEP’s and the Fish and Wildlife 

Service’s inspection conducted during the site visit component of this Five Year Review 

confirmed the historic findings. 

Groundwater Monitoring Data 

Groundwater samples were collected from each of the landfill monitoring wells from 

February 1999 through March 2008. The landfill monitoring wells consist of upgradient 

well LF-1 and downgradient wells LF-2, LF-3, and LF-4. Downgradient landfill well 

data indicates a decreasing trend 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 through 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 disposal pits. Wells with an A designation are 

installed 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. 

Groundwater migration monitoring well data generally indicates a decreasing trend in 

site-related COC concentrations from 1999 through 2008, however, multiple wells 

exhibited constant concentration trends or anomalous results, as summarized below. 

In monitoring well M-03B, although the Resorcinol 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 the 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, declining from 811 mg/L to 28 mg/L from 

Page 25 
Craig 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 remained relatively constant throughout the 

monitoring period since the well was first sampled in 2003. The THD concentration has 

also been relatively constant during monitoring 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 concentrations close to 

the detection limit of 0.05 mg/L. However, during the November 2007 sampling event, 

p-PSA was detected at a concentration of 65.2 mg/L and has been detected in three (3) of 

the previous four (4) sampling events after being detected only 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 monitoring 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 concentrations in MW-19C have remained relatively 

constant since monitoring began in 1999, although a slight decline in both compounds 

has been observed since March 2007 with respect to historic high concentrations. 

Surface Water Monitoring Data 

Routine surface water monitoring is no longer required at the Site. Sampling was 

required by the ROD on a quarterly basis for 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 discretion 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 remove residual solids and water samples from 

both Seep 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 

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 have 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 whole effluent toxicity (WET) test using a 

series of nine (9) effluent dilutions ranging from 100% (no dilution) to 0.5% (200x 

dilution) with an endpoints evaluation for growth and survival. 

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Craig Farm Drum Superfund Site 

Third Five-Year Review 

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Based on the results of the testing, the no observed 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 chronic toxicity of Seep A using the growth 

endpoint both exceed the PADEP WET screening criteria. 

The results of the testing conducted on the Seep B effluent indicated an observed NOEC 

of 100% (no dilution). Both the acute and chronic toxicity of the Seep B samples were 

below the PADEP WET toxicity screening criteria. 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 the proposed modification, 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 exposure pathway has not previously been 

evaluated, therefore, a screening evaluation was conducted during 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 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 recommended. 

Site Inspection

The Craig Farm Drum Site inspection was 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 components appeared to be in good condition and 

no issues or deficiencies were observed. The Site inspection checklist is included as 

Attachment 4. 

Interviews

EPA RPM John Epps conducted community interviews door-to-door with residents in the 

immediate vicinity of the Craig Farm Drum Site. One resident was interviewed and 

Page 27 
Craig Farm Drum Superfund Site 

Third Five-Year Review 

June 2009

indicated she was pleased with the remediation of the Site. Additionally, notice of the 

review was provided to Perry Township via telephone, letter, and a visit to the township 

office but no response was received. 

No interview was requested by the Butler Eagle 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 activities at the Site. The interviews indicated that there 

have been no issues associated with maintaining institutional controls at the Site. Mr. 

Hanna also indicated that, at the time of the interview, remedial alternatives for OU-3 

were being explored via a Focused Feasibility Investigation. Interview 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 documents, ARARs, and the results of the Site 

inspection, the physical remedy is functioning as intended by the ROD. Additionally, 

institutional controls identifying contaminants present onsite and restricting the use of the 

landfill and groundwater have been implemented, 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 remedial objectives to control contaminant 

migration offsite, to prevent impacting the Unnamed Creek and living organisms onsite, 

and to prevent continued leaching of precipitation and surface water onsite through 

contaminated landfill material. Currently, the passive collection of seeps by the seep 

interceptor system and subsequent offsite treatment has prevented exposure 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 decommissioning 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. 

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Craig Farm Drum Superfund Site 

Third Five-Year Review 

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

effective. The Site inspection did not identify any issues which would compromise the 

integrity of the landfill cap or the physical protectiveness of the remedy. O&M annual 

costs are consistent with the original estimates when corrected for inflation. 

Question B: Are the exposure assumptions, toxicity 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 Site 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 required 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 Control Program (OU-3); 

 Pennsylvania Clean Stream Law (relating to groundwater - OU-3); 

 Pennsylvania Erosion and Sedimentation Pollution Control (OU-3). 

As previously noted, to eliminate the potential exposure pathway for contaminated 

groundwater, Beazer agreed to fund the construction 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, including Perry Township, to implement a 

model ordinance. The model ordinance prohibits the use of groundwater wells within the 

BCACS for potable water and requires property owners to connect to the public water 

system. 

A vapor intrusion exposure pathway evaluation was conducted for this Site during this 

Five Year Review. The results of the evaluation indicate that the vapor intrusion 

pathway is not a concern, primarily due to the lack of volatile compounds in onsite soil or 

groundwater. 

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Craig Farm Drum Superfund Site 

Third Five-Year Review 

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Question C: Has any other information come to light that could call into question the 

protectiveness of the remedy?

No. The remedy continues to be protective and 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, and, 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 the CD, and are in place and effective, the 

remedy is considered protective in the long-term 

Additionally, a proposed remedy modification currently under review by EPA is expected 

to further enhance the remedy by reducing 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 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. 

X. Protectiveness Statement 

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. 

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Craig Farm Drum Superfund Site 

Third Five-Year Review 

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Page 31 

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 groundwater 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 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 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 and future Site owners of the 

contaminants onsite and restricting landfill and groundwater use. The requirements for 

the institutional controls at the Site will be clarified in an ESD to further ensure long-term 

protectiveness. 

XI. Next Review 

The next Five-Year Review for the Craig Farm Drum Superfund Site is required by June 

19, 2014, five years from the date of this review. 
Figures 
Approximate 

Site Location
Adapted from Langan Figure 2 Site PlanAerial photograph provided by PAMAP Program 20Color Orthophoto of Pennsylvania
Attachment 1 – Institutional Controls 
DECLARATION OF RESTRICTIONS

THIS DECLARATION OF RESTRICTIONS is made this 23rd day of

September 2004 by Beazer East, Inc. (formerly known as Koppers Company, Inc.), a

Delaware corporation, having an address of One Oxford Centre, Suite 3000, Pittsburgh,

PA 15219-6401 (the "Declarant").

WITNESSTH:

WHEREAS, Koppers Company, Inc. acquired in three separate transactions

property located in Perry Township, Armstrong County, Pennsylvania more particularly

described in Exhibit A attached hereto and made a part hereof (such real property being

hereinafter referred to as the "Site") by: (1) deed of January 5, 1972 from Herman G.

Craig and Betty L. Craig to Declarant and recorded in the Office of the Recorder of

Deeds of Armstrong County, Pennsylvania, in Deed Book Volume 538 beginning at Page

244; (2) deed of February 27, 1985 from Herman G. Craig to Declarant and recorded in

the Office of the Recorder of Deeds of Armstrong County, Pennsylvania, in Deed Book

Volume 653 beginning at Page 31; and (3) deed of June 13, 1985 from Carl E. Switzer

and Charlene Switzer to Declarant and recorded in the Office of the Recorder of Deeds of

Armstrong County, Pennsylvania, in Deed Book Volume 669 beginning at Page 215;

WHEREAS, beginning in 1958 a waste hauler for Koppers used the Site to

dispose of industrial waste from Koppers' manufacturing plant in Petrolia, Pennsylvania,

including hazardous waste from the production of rcsourcinol and"constituents thereof;

WHEREAS, in 1989, Koppers Company, Inc. changed its name to Beazer

Materials and Services, Inc. and in 1990, Beazer Materials and Services, Inc. changed its

name to Beazer East, Inc.;

WHEREAS, in May of 1990, a Consent Decree was signed and entered with the

United States District Court for the Western District of Pennsylvania addressing

implementation of a Remedial Design and Remedial Action ("RD/RA") at the Site and

payment of certain response costs;

WHEREAS, pursuant to the Consent Decree, Declarant has implemented the

RD/RA at the Site, and as part of the remedial action Declarant created a landfill to

contain the hazardous waste that was disposed on-site ("the Landfill");

WHEREAS, the Consent Decree for the Site requires implementation of

institutional controls restricting future use of the Site, which controls may include

restrictive covenants; and

WHEREAS, it is in the intention of Declarant to create restrictions on the Site that

will run with the land and bind future owners, tenants, subtenants, licensees or other users

of any and ail portions of the Site.
NOW, THEREFORE, Declarant hereby imposes the following restrictions on the

Site, which shall be enforceable by Declarant and its successors and assigns, the

Environmental Protection Agency, the Pennsylvania Department of Environmental

Protection Agency and all other governmental agencies with jurisdiction over the

environmental conditions on the Site.

1. Purposes

The purpose of this Declaration is to restrict certain use and development

activities at the Site so as to prevent any uses of the Site which would be

inconsistent with the RD/RA for the Site and create a risk to human health or the

environment and to fulfill Declarant's commitments under the Consent Decree.

2. Specific Prohibitions

(a) No groundwater underneath the Site may be used for human consumption,

irrigation or other purposes that might bring it into contact with humans

(except for testing purposes required by law, the RD/RA or the terms of the

Consent Decree) and neither the owner, occupant nor any other user of the

Site shall drill or install any wells on the Site for the purpose of extracting

groundwater underneath the Site for human consumption, irrigation, or other

purposes that might bring it into contact with humans (except for testing

purposes as required by law. the RD/RA or the terms of the Consent

Decree).

(b) No building, structure or other object shall be built or placed on the Site that

would disturb the cap or stabilized contents of the Landfill or would

otherwise disturb any component of the RD/RA at the Site without the prior

written approval of Declarant or its successors and assigns and the

Environmental Protection Agency.

(c) The Site shall not be used for the purposes of personal living, dwelling, or

overnight accommodations, whether such uses are in single family

residences, apartments, duplexes or other multiple residential dwellings,

trailers, trailer parks, camping sites, hotels, motels, or any other dwelling

use of any kind, or for child care, schools, parks or other nomndustnal uses,

by the owner or occupant of the Site, or anyone occupying the Site with the

permission of the owner of the Site.

(d) No action shall be taken at the Site to interfere with, obstruct, disturb the

performance, support or supervisions of any remedial response actions taken

or to be taken at the Site, including any operation or maintenance activities.

(e) Any subsequent owner of the Site shall provide a purchaser with notice of

the terms of the Consent Decree prior to transferring any interest in the Site.
3. Access

The employees, agents and contractors of the Declarant and its successors and

assigns shall have the right of ingress and egress from and movement on the Site

sufficient to conduct, maintain, monitor and secure the integrity of the remedy set

forth in the RD/RA, to take other actions required or authorized under applicable

federal and state laws and to monitor and enforce compliance with the terms of

this Declaration. Declarant acknowledges that, notwithstanding any other

provision of this Declaration, the Environmental Protection Agency retains all of

its access authorities and rights, as well as its right to require land/water use

restrictions, including enforcement authorities related thereto, under applicable

statutes and/or regulations.

4. Enforceability

(a) The covenants, conditions and restrictions of this Declaration shall be

enforceable by Declarant and its successors and assigns.

(b) Such covenants, conditions and restrictions shall run with the land, shall be

binding upon any and all successors in interests, and all assignees, lessees,

sub-lessees, operators, tenants, licensees, agents and any and all persons

who acquire any interest in the Site.

(c) Violation of covenants, conditions and restrictions contained herein shall

give Declarant and its successors and assigns in addition to all other

remedies, the right to enter upon the land upon or as to which such violation

exists and summarily to abate and remove, at the expense of the owner

thereof, any structure, thing or condition that may be or exist thereon

contrary to the intent and meaning of the provision of this Declaration.

(d) Declarant and it successors and assigns shall be entitled to enforce the terms

of this Declaration by specific performance or legal process. All remedies

available hereunder shall be in addition to any other remedies at law or in

equity. Enforcement of the terms and conditions of this Declaration shall be

at the discretion of Declarant and its successors and assigns and any

forbearance, delay or omission to exercise its rights under this Declaration

in the event of a breach of any term of this Declaration shall not be deemed

to be a waiver by Declarant or its successors and assigns of such term or of

any subsequent breach of the same or any other term, or of any of the rights

of such parties under this Declaration.

5. Miscellaneous

(a) Modifications. This Declaration may be modified or terminated, in whole or

in part by the Declarant or it successors or assigns, provided that a written

Modification of Termination Notice in the Office of the Recorder of Deeds
of Armstrong County, Pennsylvania is filed and provided that Declarant or

its successors or assigns obtain written approval from the Environmental

Protection Agency at least thirty (30) days prior to filing such notice.

(b) Reservation of Rights. Declarant hereby reserves unto itself, its successors

and assigns, all rights and privileges in and to the use of the Site which are

not incompatible with the covenants, conditions and restrictions established

herein.

(c) No Public Access. No right of access or use by the general public to any

portion of the Site is conveyed by this Declaration.

(d) Governing Law. The interpretation and performance of this Declaration

shall be governed by the law of Pennsylvania,

(e) Rules of Construction. Any general rule of construction to the contrary,

notwithstanding, this instrument shall be liberally construed in favor of the

grant to affect the purpose of this Declaration and the policy and purpose the

Comprehensive Environmental Response, Compensation and Liability Act,

42 U.S.C. § 9601 et seq. If any provision of this Declaration is found to be

ambiguous, an interpretation consistent with the purpose of this Declaration

that would render the provision valid shall be favored over any

interpretation that would render it invalid.

(f) Severability. If any provision of this Declaration, or the application of it to

any person or circumstance, is found to be invalid, the remainder of the

provisions of this Declaration, or the application of such provisions to

persons or circumstances other than those to which it is found to be invalid,

as the case may be, shall not be affected thereby.

(g) Entire Agreement. This Declaration sets forth the entire undertaking and

agreement of Declarant with respect to rights and restrictions created

hereby, and supersedes all prior discussions, negotiations, understandings,

or agreements relating hereto, all of which are merged herein.

(h) No Forfeiture. Nothing contained herein will result in a forfeiture or

reversion of title in any respect.

(i) Successors. The covenants, terms, conditions and restrictions of this

Declaration shall be binding upon, and inure to the benefit of, Declarant and

its successors and assigns and shall continue as a servitude running in

perpetuity with the Site.

(j) Termination of Rights and Obligations. The rights and obligations of the

owner(s) from time to time of the Site under this Declaration terminate upon
transfer of the party's interest in the Site, except that liability for acts or

omissions occurring prior to transfer shall survive transfer.

(k) Captions. The captions in this Declaration have been inserted solely for

convenience of reference and are not a part of this Declaration and shall

have no effect upon construction or interpretation.

[SIGNATORIES APPEAR ON FOLLOWING PAGE|
EXHIBIT A

BEGINNING at an iron pin comer on line of land of Earl A. Bailey, formerly M.S. and

George Shakley, said point being a Southwest corner and common to land now of W.P.

Vance, formerly E.S. Golden, and the herein described tract; thence by land of Earl. A.

Bailey and G. Pearl Johns, North 7° 08' 20" East, a distance of 3267.00 feet to a Stone

corner on line of land of G. Pearl Johns, and being common to land now of John H.

Hood, formerly Jacob Steel, and the herein described tract; thence by land of John H.

Hood, South 85 06' 30" East, a distance of 1378.77 feet to an iron pin corner on line of

land of John H. Hood, and being common to land now of David E. Frazier (Allotment

"B"), and the herein described tract, thence by land of David E. Frazier, South 00° 39'

West, a distance of 1014.52 feet to an Iron Pin corner on West line of an improved Public

Road passing through the Northeast section of land conveyed herein, and known as

Legislative Route 03030 and being common to an area of land to" be retained by Grantor

and the herein described tract; thence by land to be retained by Herman G. Craig, South

68° 30' West, a distance of 899.00 feet to an Iron Pin comer; thence by land of same,

South 26° 57' 30" East, a distance of 1312.23 feet to an Iron Pin corner; thence by land of

same North 89° 00' East, a distance of 224.66 feet to an iron pin corner on line of land of

David E. Frazier and being along the West line of aforesaid Improved Public Road and

being common to land to be retained by Herman G. Craig, and the herein described tract;

thence by land of David E. Fraizer, South 00° 39' West, a distance of 765.45 feet to an

iron pin corner on line of land now of W.P. Vance, formerly E.S. Golden, and common to

land of David E. Frazier and the herein described tract; thence by land of W.P. Vance,

North 85° 03' West a distance of 1749.00 feet to an iron pin corner, the place of

beginning. CONTAINING 99.899 acres, more or less, as surveyed by EJ. Weibel, a

registered surveyor, November 26, 1971.

BEGINNING at an iron pin corner on line of land now of David E. Frazier, said point

being South 0° 39' West, a distance of 1014.52 feet from the northeast corner of the land

formerly conveyed by Herman G. Craig, et ux., to Koppers Company, Inc. by Deed dated

January 5, L972, and being the northeast comer of the herein described tract; thence by

land of David E. Fraizer (formerly Allotment "B"), South 00° 39' West, a distance of

1495.28 feet to an iron pin corner on line of said land and being common to land

conveyed to Koppers Company, Inc., as aforesaid; thence by said land heretofore

conveyed to Koppers Company, Inc., by Herman G. Craig, et ux., as aforesaid, South 89°

00' West, a distance of 224.66 feet to an iron pin corner; thence by same, north 26° 57'

30" West, a distance of 1312.23 feet to an iron pin corner; thence by same, North 68° 30"

East, a distance of 899.00 feet to an iron pin corner on line of land of David E. Fraizer,

the place of beginning. CONTAINING 17.333 acres, more or less, as surveyed by E.J

Weibel, R.S., December 1, 1971.

{DESCRIPTION CONTINUED OiN NEXT PAGE}
BEGINNING at an iron pin comer along the edge of the Queenstown-Bruin Road, a

Public Road, being known as Legislative Route #03030: Said point being the south-east

comer of the herein described tract; thence west, through land of Herman G. Craig and

Betty L. Craig, his wife, of which this is a part, a distance of two hundred twenty-five

- (225) feet to an iron pin corner; thence North through land of same, a distance of two

hundred fifty (250) feet to an iron pin corner, thence east, through land of Herman G.

Craig and Betty L. Craig, his wife, a distance of two hundred sixty-sive (265) feet to an

iron pin corner at edge of Legislative Route 03030; thence South; along edge of

Legislative Route 03030, a distance of two hundred fifty (250) feet to a point, the place of

beginning.
IN WITNESS WHEREOF, BEAZER EAST, INC. has caused its common and corporate

seal to be affixed to these presents by the hand of its , who is

duly authorized to execute this Declaration on behalf of the corporation, and the same

being duly attested to by its Secretary on the day and year first above written, intending

to be legally bound hereby.

ATTEST: BEAZER EAST, INC., a Delaware

Corporation

Secretary

[CORPORATE SEAL HERE]

STATE OF /^^^t^ J^TL^L^ )

COUNTY OF &&di^uf> )

On this 23rd day of September, 2004 before me, a Notary Public, the undersigned

officer, personally appeared ^rbsffl-fflgsJ/eMdjL^ , who acknowledged himself to be

the /%£*.- fr^dt^t. of BEAZER EAST, INC., a Delaware Corporation, and that

such officer,-being authorized to do so, executed the foregoing instrument as the

' Tx^xu^n^of BEAZER EAST, INC. for the purposes therein contained.

IN WITNESS WHEREOF, I hereunto set my hand and official seal.

Notary Public

My commission expires:

COMMONWEALTH OF PENNSYLVANIA

Notarial Seal

Maureen M. Ststzar, Notary PuMc

Oty Of Rttsbugh, Ateghony County

My Commtaton Expta Ju<y 3,2006

, f*«nniytv»nl« Aiiociatton Of Nottrie*
Attachment 2 – Community Involvement 

Materials 
By ASSOCIATED PRESS

PHILADELPHIA — Two

brothers who ran a pair of

funeral 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 allegations

read in court drew gasps, murmurs and tears from about two

dozen people who had entrusted the bodies of their loved

ones to the Garzones’ facilities

in Philadelphia.

The mastermind of the

scheme, 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 New

York, New Jersey and Pennsylvania. Mastromarino paid the

Garzones and their partner,

James 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 head

and 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 — Tires 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 games

at 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 4

and 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 of

truck 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 a

Next 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, of

Bruin 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, of

Pittsburgh was arrested for suspicion of DUI on Route 8 in Center Township.

Sunday — Nothing was reported taken in a burglary between

Aug. 26 and Sunday at an unoccupied farmhouse and storage

shed on Marwood Road in Winfield Township.

Sunday — A gray, 1948 Ford

tractor was stolen at a camp on

Watson 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 Restaurant

on Route 356 in Winfield Township and took $110. A window

also sustained $250 in the burglary between 9:15 p.m. Aug. 26

and 5:30 a.m. Aug. 27.

State Police,

Franklin

Tuesday — Christina Richter of

Grove City told police that $100

was taken from her purse in an

unlocked vehicle parked on Gibb

Road in Barkeyville. The theft

occurred between 12:30 and 2:45

p.m.

State Police,

New Castle

3 p.m. Tuesday — Lenny Jay

Staples, 41, of New Castle was

arrested for the alleged sexual

assault of a 38-year-old woman

at an undisclosed location on

Hogue Road in Slippery Rock

Township, Lawrence County.

Police said the woman suffered

minor injuries but did not seek

medical treatment.

Staples was arraigned on

charges of rape, aggravated

indecent assault and indecent

assault, and placed in the

Lawrence County Jail on $10,000

bond.

POLICE REPOR POLICE REPORTS

Wednesday, September 3, 2008 - BUTLER EAGLE 7

 996859

 993012

 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”

 DOGGIE FUN DAY OGGIE FUN DAY Sunday, September 14 Suunnddaayy,, SSeepptteemmbbeerr 1144

 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)

 ALAMEDA FALL FEST ALLAAMMEEDDAA FFAALLLL FFEESSTT & FISHING TOURNAMENT & & FFIISSHHIINNGG TTOOUURRNNAAMMEENNTT

 Sunday, Sept. 21 Suunnddaayy,, SSeepptt.. 2211

 996741

Attachment 3 – Groundwater Monitoring 

Analytical Data 
Summary of Analytical Data

Craig Farm Superfund Site

1999 through 2008

Sample 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 5/25/200BENZENE 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 Sample Date: 4/17/2002 11/12/2002 4/15/2003 4/15/2003 12/18/20BENZENE ug/l 1 U 1 U 1 U 1 U 1 U BENZENE METADISULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U BENZENE MONOSULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U P-PHENOL SULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.058 RESORCINOL mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U TRIHYDROXYDIPHENYL mg/l 0.05 0.05 U 0.05 U 0.05 U 0.05 U Sample Location: LF-01 LF-01 LF-01 LF-01 LF-01-DUSample Date: 12/6/2004 6/9/2005 12/7/2005 6/6/2006 6/6/200BENZENE 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 3/10/200BENZENE 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 U

U - Indicates non-detected

J - Indicates estimate

D - Indicates result is from analysis of a secondary dillution 

F:\Craig Farm\FYR 2009\Summary Table_Wells Combined_063008 
Concentration Trends for LF-01 1999 though 2007

0123456

1/1/1999 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)

0246811

BENZENE MONOSULFOP-PHENOL SULFONIC ACTRIHYDROXYDIPHENYL 

NOTES:-Open Symbols are non-detects.-Non-detects were replaced with half tlimit.

F:\Craig Farm\FYR 2009\Summary Table_Wells Combined_063008 
Summary of Analytical Data

Craig Farm Superfund Site

1999 through 2008

Sample Location: LF-02 LF-2 LF-2 LF-2 LF-02 Sample Date: 5/12/1999 12/6/1999 5/25/2000 11/30/2000 4/16/200BENZENE ug/l 1 U 1 U 1 U 1 U 1 U BENZENE METADISULFONIC ACID mg/l 10 U 0.05 U 0.05 U 0.05 U 0.05 U BENZENE MONOSULFONIC ACID mg/l 10 U 0.05 U 0.05 U 0.05 U 0.05 U P-PHENOL SULFONIC ACID mg/l 10 U 0.137 0.12 0.177 0.069 RESORCINOL mg/l 1.2 U 0.05 U 0.05 U 0.05 U 0.05 U TRIHYDROXYDIPHENYL mg/l 0.9 0.125 0.05 U 0.05 U 0.05 U Sample Location: LF-2 LF-2 LF-02 LF-02 LF-02 Sample Date: 4/17/2002 11/12/2002 4/15/2003 12/17/2003 6/16/200BENZENE ug/l 1 U 1 U 1 U 1 U 1 U BENZENE METADISULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U BENZENE MONOSULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U P-PHENOL SULFONIC ACID mg/l 0.05 U 0.072 0.05 U 0.05 U 0.05 RESORCINOL mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U TRIHYDROXYDIPHENYL mg/l 0.05 0.05 U 0.05 U 0.05 U 0.05 U Sample Location: LF-02 LF-02 LF-02 LF-02-110606 LF-2-0319Sample Date: 6/9/2005 12/6/2005 6/6/2006 11/6/2006 3/19/200BENZENE ug/l 1 U 1 U 1 U 1 U 1 U BENZENE METADISULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U BENZENE MONOSULFONIC ACID mg/l 0.05 U 0.05 0.05 U 0.05 U 0.05 U P-PHENOL SULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U RESORCINOL mg/l 0.05 0.05 U 0.05 U 0.05 U 0.05 U TRIHYDROXYDIPHENYL mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U Sample 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 U

U - Indicates non-detected

J - Indicates estimate

D - Indicates result is from analysis of a secondary dillution 

F:\Craig Farm\FYR 2009\Summary Table_Wells Combined_063008 
Concentration Trends for LF-02 1999 though 2007

0123456

01/01/99 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 P-PHENOL SULFONIC ACID RESORCINOL mg/lTRIHYDROXYDIPHENYL mg

NOTES:-Open Symbols are no-Non-detects were replimit.

F:\Craig Farm\FYR 2009\Summary Table_Wells Combined_063008 
Summary of Analytical Data

Craig Farm Superfund Site

1999 through 2008

Sample Location: LF-03 LF-3 LF-3 LF-3 LFSample Date: 5/12/1999 12/6/1999 5/25/2000 11/30/2000 4/16/BENZENE ug/l 1 U 1 U 1 U 1 U 1 BENZENE METADISULFONIC ACID mg/l 10 U 0.05 U 0.05 U 0.05 U 0.05 BENZENE MONOSULFONIC ACID mg/l 10 U 0.05 U 0.05 U 0.05 U 0.05 P-PHENOL SULFONIC ACID mg/l 10 U 0.05 U 0.05 U 0.05 U 0.05 RESORCINOL mg/l 1.2 U 0.05 U 0.05 U 0.05 U 0.05 TRIHYDROXYDIPHENYL mg/l 0.5 U 0.05 U 0.05 U 0.05 U 0.05 Sample Location: LF-3 LF-3 LF-03 LF-03 LFSample Date: 4/17/2002 11/12/2002 4/15/2003 12/17/2003 6/16/BENZENE ug/l 1 U 1 U 1 U 1 U 1 BENZENE METADISULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 BENZENE MONOSULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 P-PHENOL SULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 RESORCINOL mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 TRIHYDROXYDIPHENYL mg/l 0.05 0.05 U 0.05 U 0.05 U 0.05 Sample Location: LF-03 LF-03 LF-03 LF-03-110606 LF-3-0Sample Date: 6/9/2005 12/6/2005 6/6/2006 11/6/2006 3/19/BENZENE ug/l 1 U 1 U 1 U 1 U 1 BENZENE METADISULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 BENZENE MONOSULFONIC ACID mg/l 0.05 U 0.05 0.05 U 0.05 U 0.05 P-PHENOL SULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 RESORCINOL mg/l 0.05 0.05 U 0.05 U 0.05 U 0.05 TRIHYDROXYDIPHENYL mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 Sample 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 U

U - Indicates non-detected

J - Indicates estimate

D - Indicates result is from analysis of a secondary dillution 

F:\Craig Farm\FYR 2009\Summary Table_Wells Combined_063008 
Concentration Trends for LF-03 1999 though 2007

0123456

01/01/99 01/01/00 01/01/01 01/01/02 01/01/03 01/01/04 01/01/05 01/01/06 01/01/07 01/01/0

Concentration (mg/L)

BENZENE MONOSULFONIC AP-PHENOL SULFONIC ACID mRESORCINOL mg/lTRIHYDROXYDIPHENYL mg/l

NOTES:-Open Symbols are non-det-Non-detects were replaced limit.

F:\Craig Farm\FYR 2009\Summary Table_Wells Combined_063008 
Summary of Analytical Data

Craig Farm Superfund Site

1999 through 2008

Sample Location: LF-04 LF-4 LF-4 LF-4 LF-4 Sample Date: 5/12/1999 12/6/1999 5/25/2000 11/30/2000 4/16/200BENZENE ug/l 1 U 1 U 1 U 1 U 1 U BENZENE METADISULFONIC ACID mg/l 10 U 0.05 U 0.05 U 0.05 U 0.05 U BENZENE MONOSULFONIC ACID mg/l 10 U 0.05 U 0.05 U 0.05 U 0.05 U P-PHENOL SULFONIC ACID mg/l 10 U 0.05 U 0.05 0.157 0.081 RESORCINOL mg/l 1.2 U 0.05 U 0.05 U 0.05 U 0.05 U TRIHYDROXYDIPHENYL mg/l 2.1 0.05 U 0.05 U 0.05 U 0.05 U Sample Location: LF-4 LF-4 LF-04 LF-04 LF-04 Sample Date: 4/17/2002 11/12/2002 4/15/2003 12/17/2003 6/16/200BENZENE ug/l 1 U 1 U 1 U 1 U 1 U BENZENE METADISULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U BENZENE MONOSULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U P-PHENOL SULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.062 0.095 RESORCINOL mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U TRIHYDROXYDIPHENYL mg/l 0.262 0.05 U 0.186 0.05 U 0.05 U Sample Location: LF-04 LF-04 LF-04 LF-4-0319Sample Date: 6/9/2005 12/6/2005 6/6/2006 3/19/200BENZENE ug/l 1 U 1 U 1 U 1 U 1 U BENZENE METADISULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U BENZENE MONOSULFONIC ACID mg/l 0.05 U 0.05 0.05 U 0.05 U 0.05 U P-PHENOL SULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U RESORCINOL mg/l 0.05 0.05 U 0.05 U 0.05 U 0.05 U TRIHYDROXYDIPHENYL mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U Sample 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 U

U - Indicates non-detected

J - Indicates estimate

D - Indicates result is from analysis of a secondary dillution 

LF-04-110606

11/6/2006

F:\Craig Farm\FYR 2009\Summary Table_Wells Combined_063008 
Concentration Trends for LF-04 1999 though 2007

0123456

01/01/99 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 MONOSULFONP-PHENOL SULFONIC ACRESORCINOL mg/lTRIHYDROXYDIPHENYL m

NOTES:-Open Symbols are non-Non-detects were replalimit.

F:\Craig Farm\FYR 2009\Summary Table_Wells Combined_063008 
Summary of Analytical Data

Craig Farm Superfund Site

1999 through 2008

Sample Location: M-03B M-03B M-03B DUP M-03B M-03B DUP Sample Date: 2/10/1999 7/20/1999 7/20/1999 3/1/2000 3/1/2000 BENZENE ug/l 1 U 1 U 1 U 10 U 10 U BENZENE METADISULFONIC ACID mg/l 10 U 10 U 10 U 0.05 UJ 0.066 J BENZENE MONOSULFONIC ACID mg/l 10 U 10 U 10 U 0.05 U 0.05 U P-PHENOL SULFONIC ACID mg/l 10 U 10 U 10 U 0.95 0.981 RESORCINOL mg/l 300 U 300 U 300 U 41.9 40.3 TRIHYDROXYDIPHENYL mg/l 600 D 610 D 560 D 384 389 

Sample Location: WELL-M-3B M-3B M-3B M-3B M-03B Sample Date: 4/17/2001 11/15/2001 4/18/2002 11/13/2002 4/16/2003 BENZENE ug/l 1 U 1 U 1 U 1 U 1 U BENZENE METADISULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U BENZENE MONOSULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U P-PHENOL SULFONIC ACID mg/l 0.916 0.637 0.188 0.46 0.409 RESORCINOL mg/l 26.7 29 17.9 36.1 25.1 TRIHYDROXYDIPHENYL mg/l 270 249 191 J 327 272 Sample Location: M-03BDUP M-03B M-03B M-03B M-03B Sample Date: 12/18/2003 6/14/2004 12/7/2004 6/8/2005 12/6/2005 BENZENE ug/l 1 U 1 U 1 U 1 U 1 U BENZENE METADISULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.344 J BENZENE MONOSULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 UJ P-PHENOL SULFONIC ACID mg/l 0.362 0.22 J 0.443 J 0.438 J 0.297 RESORCINOL mg/l 22.2 25.7 26.3 20.7 J 29.7 TRIHYDROXYDIPHENYL mg/l 306 296 288 211 287 J Sample 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 20.6TRIHYDROXYDIPHENYL mg/l 197 202 243 226 183

U - Indicates non-detected

J - Indicates estimate

D - Indicates result is from analysis of a secondary dillution 

F:\Craig Farm\FYR 2009\Summary Table_Wells Combined_063008 
Concentration Trends for M-03B 1999 though 2007

0

100200300400500600700

01/01/99 01/01/00 01/01/01 01/01/02 01/01/03 01/01/04 01/01/05 01/01/06 01/01/07 01/01/0

Concentration (mg/L)

P-PHENOL SULFONIC ACID RESORCINOL mg/lTRIHYDROXYDIPHENYL mg

NOTES:-Open Symbols are non-Non-detects were replalimit.

F:\Craig Farm\FYR 2009\Summary Table_Wells Combined_063008 
Summary of Analytical Data

Craig Farm Superfund Site

1999 through 2008

Sample 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 Sample Date: 4/18/2001 11/15/2001 4/17/2002 4/16/2003 1BENZENE ug/l 1 U 1 U 1 U 1 U BENZENE METADISULFONIC ACID mg/l 0.05 U 0.056 0.05 U 0.05 U 0BENZENE MONOSULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0P-PHENOL SULFONIC ACID mg/l 0.167 0.512 0.05 U 0.082 0RESORCINOL mg/l 7.93 38.9 1.03 0.632 2TRIHYDROXYDIPHENYL mg/l 161 811 28 J 52.5 Sample 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 144 186 185

U - Indicates non-detected

J - Indicates estimate

D - Indicates result is from analysis of a secondary dillution 

M-05A-032007

3/20/2007

F:\Craig Farm\FYR 2009\Summary Table_Wells Combined_063008 
Concentration Trends for M-05A 1999 though 2007

0

200400600800

100012001400

07/20/99 07/20/00 07/20/01 07/20/02 07/20/03 07/20/04 07/20/05 07/20/06 07/2

Concentration (mg/L)

BENZENE METADISULFONIC BENZENE MONOSULFONIC AP-PHENOL SULFONIC ACID mRESORCINOL mg/lTRIHYDROXYDIPHENYL mg/

NOTES:-Open Symbols are non-Non-detects were replalimit.

F:\Craig Farm\FYR 2009\Summary Table_Wells Combined_063008 
Summary of Analytical Data

Craig Farm Superfund Site

1999 through 2008

Sample 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 Sample Date: 6/9/2005 6/7/2006 11/8/2006 3/20/2007 BENZENE ug/l 1 U 1 U 1 U 1 U BENZENE METADISULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U BENZENE MONOSULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U P-PHENOL SULFONIC ACID mg/l 0.574 J 0.0726 0.366 0.127 RESORCINOL mg/l 0.05 UJ 0.211 B 0.05 U 0.05 U TRIHYDROXYDIPHENYL mg/l 0.05 U 7520 0.873 0.184 Sample 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 0.144

U - Indicates non-detected

J - Indicates estimate

D - Indicates result is from analysis of a secondary dillution 

F:\Craig Farm\FYR 2009\Summary Table_Wells Combined_063008 
Concentration Trends for M-05A 1999 though 2007

0

10002000300040005000600070008000

12/18/03 12/18/04 12/18/05 12/18/06 12/18/07

Concentration (mg/L)

P-PHENOL SULFONIC ACRESORCINOL mg/lTRIHYDROXYDIPHENYL 

NOTES:-Open Symbols are non-Non-detects were replalimit.

F:\Craig Farm\FYR 2009\Summary Table_Wells Combined_063008 
Summary of Analytical Data

Craig Farm Superfund Site

1999 through 2008

Sample Location: M-14B M-14B DUP M-14B M-14B M-1Sample Date: 2/10/1999 2/10/1999 7/20/1999 3/2/2000 7/26/BENZENE ug/l 1 U 1 U 1 U 1 U 1 BENZENE METADISULFONIC ACID mg/l 10 U 10 U 10 U 0.05 U 0.05 BENZENE MONOSULFONIC ACID mg/l 10 U 10 U 10 U 0.05 U 0.05 P-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 TRIHYDROXYDIPHENYL mg/l 23 D 23 D 4.3 0.372 0.05 Sample Location: M-14B M-14B M-14B M-14B M-1Sample Date: 4/18/2001 11/16/2001 4/18/2002 11/14/2002 4/17/BENZENE ug/l 1 U 1 U 1 U 1 U 1 BENZENE METADISULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 BENZENE MONOSULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 P-PHENOL SULFONIC ACID mg/l 0.442 0.21 0.05 U 0.05 U 0.05 RESORCINOL mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 TRIHYDROXYDIPHENYL mg/l 0.337 0.05 U 0.05 UJ 0.058 0.1 Sample Location: M-14B M-14B M-14B M-14B-110806 M-14B-Sample Date: 6/8/2005 12/7/2005 6/6/2006 11/8/2006 3/20/BENZENE ug/l 1 U 1 U 1 U 1 U 1 BENZENE METADISULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 BENZENE MONOSULFONIC ACID mg/l 0.05 U 0.05 UJ 0.05 U 0.05 U 0.05 P-PHENOL SULFONIC ACID mg/l 0.148 0.05 U 0.05 U 0.141 0.05 RESORCINOL mg/l 0.05 0.05 U 0.05 U 0.05 U 0.05 TRIHYDROXYDIPHENYL mg/l 0.05 U 0.092 J 0.05 U 0.111 0.05 Sample 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 U

U - Indicates non-detected

J - Indicates estimate

D - Indicates result is from analysis of a secondary dillution 

F:\Craig Farm\FYR 2009\Summary Table_Wells Combined_063008 
Concentration Trends for M-05A 1999 though 2007

05

10152025

01/01/99 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 RESORCINOL mg/lTRIHYDROXYDIPHENYL m

NOTES:-Open Symbols are non-de-Non-detects were replacelimit.

F:\Craig Farm\FYR 2009\Summary Table_Wells Combined_063008 
Summary of Analytical Data

Craig Farm Superfund Site

1999 through 2008

Sample Location: M-15B M-15B M-15B M-15B M-15BSample Date: 2/11/1999 7/20/1999 3/2/2000 7/26/2000 7/26/BENZENE ug/l 1 U 1 U 1 U 1 U 1 BENZENE METADISULFONIC ACID mg/l 10 U 10 U 0.05 U 0.055 0.055 BENZENE MONOSULFONIC ACID mg/l 10 U 10 U 0.05 U 0.05 U 0.05 P-PHENOL SULFONIC ACID mg/l 10 U 10 U 0.201 0.117 J 0.123 RESORCINOL mg/l 1.2 U 1.2 U 0.126 0.05 U 0.05 TRIHYDROXYDIPHENYL mg/l 1.8 1.2 0.95 0.05 U 0.05 Sample Location: M-15B M-15B M-15B M-15B M-1Sample Date: 11/16/2001 4/18/2002 11/14/2002 4/17/2003 12/18BENZENE ug/l 1 U 1 U 1 U 1 U 1 BENZENE METADISULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 BENZENE MONOSULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 P-PHENOL SULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 RESORCINOL mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 TRIHYDROXYDIPHENYL mg/l 0.05 U 0.159 J 0.05 U 0.116 0.05 Sample Location: M-15B M-15B M-15B M-15B M-15B-Sample Date: 12/8/2004 6/8/2005 12/8/2005 6/6/2006 11/6/BENZENE ug/l 1 U 1 U 1 U 1 U 1 BENZENE METADISULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 BENZENE MONOSULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 P-PHENOL SULFONIC ACID mg/l 0.05 0.05 U 0.05 U 0.05 U 0.05 RESORCINOL mg/l 0.05 U 0.05 0.05 U 0.05 U 0.05 TRIHYDROXYDIPHENYL mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 Sample 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 U

U - Indicates non-detected

J - Indicates estimate

D - Indicates result is from analysis of a secondary dillution 

F:\Craig Farm\FYR 2009\Summary Table_Wells Combined_063008 
Concentration Trends for M-15B 1999 though 2007

0123456

01/01/99 01/01/00 01/01/01 01/01/02 01/01/03 01/01/04 01/01/05 01/01/06 01/01/07 

Concentration (mg/L)

BENZENE METADISULFONP-PHENOL SULFONIC ACIRESORCINOL mg/lTRIHYDROXYDIPHENYL m

NOTES:-Open Symbols are non-de-Non-detects were replaced limit.

F:\Craig Farm\FYR 2009\Summary Table_Wells Combined_063008 
Summary of Analytical Data

Craig Farm Superfund Site

1999 through 2008

Sample Location: M-15C M-15C M-15C M-15C WELL-Sample Date: 2/11/1999 7/20/1999 3/2/2000 7/26/2000 4/18/BENZENE ug/l 1 U 1 U 1 U 1 U 1 BENZENE METADISULFONIC ACID mg/l 10 U 10 U 0.05 U 0.05 U 0.05 BENZENE MONOSULFONIC ACID mg/l 10 U 10 U 0.05 U 0.05 U 0.05 P-PHENOL SULFONIC ACID mg/l 10 U 10 U 0.099 J 0.05 U 0.05 RESORCINOL mg/l 1.2 U 1.2 U 0.05 U 0.05 U 0.05 TRIHYDROXYDIPHENYL mg/l 0.5 U 0.5 U 0.05 U 0.05 U 0.05 Sample Location: M-15C M-15C DUP M-15C M-15C M-15CSample Date: 11/16/2001 11/16/2001 4/18/2002 11/14/2002 11/14BENZENE ug/l 1 U 1 U 1 U 1 U 1 BENZENE METADISULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 BENZENE MONOSULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 P-PHENOL SULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 RESORCINOL mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 TRIHYDROXYDIPHENYL mg/l 0.05 U 0.05 U 0.05 0.05 U 0.05 Sample Location: M-15C M-15C M-15C M-15C M-1Sample Date: 4/17/2003 12/17/2003 6/16/2004 12/8/2004 6/8/2BENZENE ug/l 1 U 1 U 1 U 1 U 1 BENZENE METADISULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 BENZENE MONOSULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 P-PHENOL SULFONIC ACID mg/l 0.084 0.05 U 0.05 UJ 0.078 J 0.05 RESORCINOL mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 TRIHYDROXYDIPHENYL mg/l 0.117 0.05 U 0.421 0.05 U 0.05 Sample Location: M-15C M-15C-032007Sample Date: 6/6/2006BENZENE ug/l 1 U 1 U 1 U 1 U 1 BENZENE METADISULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 BENZENE MONOSULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 P-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 TRIHYDROXYDIPHENYL mg/l 0.05 U 0.883 0.05 U 0.05 U 0.05 

U - Indicates non-detected

J - Indicates estimate

D - Indicates result is from analysis of a secondary dillution 

M-15C-110806

11/8/2006 3/20/2007

M-1

11/7/2007 3/11/

M-15C

F:\Craig Farm\FYR 2009\Summary Table_Wells Combined_063008 
Concentration Trends for M-15C 1999 though 2007

0

10203040506070

01/01/99 01/01/00 01/01/01 01/01/02 01/01/03 01/01/04 01/01/05 01/01/06 01/0

Concentration (mg/L)

P-PHENOL SULTRIHYDROXYD

NOTES:-Open Symbols are no-Non-detects were replimit.

F:\Craig Farm\FYR 2009\Summary Table_Wells Combined_063008 
Summary of Analytical Data

Craig Farm Superfund Site

1999 through 2008

Sample Location: M-19B M-19B DUP M-19B M-19B M-1Sample Date: 2/10/1999 2/10/1999 7/20/1999 3/1/2000 7/25/BENZENE ug/l 1 U 1 U 1 U 1 U 1 BENZENE METADISULFONIC ACID mg/l 10 U 10 U 10 U 0.05 U 0.05 BENZENE MONOSULFONIC ACID mg/l 10 U 10 U 10 U 0.05 U 0.05 P-PHENOL SULFONIC ACID mg/l 10 U 10 U 10 U 0.174 0.05 RESORCINOL mg/l 1.2 U 1.2 U 1.2 U 0.05 U 0.05 TRIHYDROXYDIPHENYL mg/l 0.5 U 0.5 U 0.5 U 0.05 U 0.05 Sample Location: WELL-M-19B M-19B M-19B M-19B M-1Sample Date: 4/17/2001 11/15/2001 4/18/2002 11/13/2002 4/16/BENZENE ug/l 1 U 1 U 1 U 1 U 1 BENZENE METADISULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 BENZENE MONOSULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 P-PHENOL SULFONIC ACID mg/l 0.169 0.05 U 0.05 U 0.05 U 0.05 RESORCINOL mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 TRIHYDROXYDIPHENYL mg/l 0.05 U 0.05 U 0.05 UJ 0.079 0.05 Sample Location: M-19B M-19B M-19B DUP M-19B M-19BSample Date: 6/14/2004 12/7/2004 12/7/2004 6/8/2005 6/8/2BENZENE ug/l 1 U 1 U 1 U 1 U 1 BENZENE METADISULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 BENZENE MONOSULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 P-PHENOL SULFONIC ACID mg/l 0.05 UJ 0.089 J 0.065 J 0.05 U 0.05 RESORCINOL mg/l 0.05 U 0.05 U 0.05 U 0.05 UJ 0.05 TRIHYDROXYDIPHENYL mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 Sample 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 BENZENE METADISULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 BENZENE MONOSULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 P-PHENOL SULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 RESORCINOL mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 TRIHYDROXYDIPHENYL mg/l 2590 0.05 U 0.05 U 0.05 U 0.05 

U - Indicates non-detected

J - Indicates estimate

D - Indicates result is from analysis of a secondary dillution 

11/8/2006 11/7/2007

M-19B 

M-19B

11/7/

F:\Craig Farm\FYR 2009\Summary Table_Wells Combined_063008 
Concentration Trends for M-19B 1999 though 2007

0123456

01/01/99 01/01/00 01/01/01 01/01/02 01/01/03 01/01/04 01/01/05 01/01/06 01/01/07 0

Concentration of p-PSA (mg/L)

P-PHENOL SULFOTRIHYDROXYDIPH

NOTES:-Open Symbols are non-Non-detects were repllimit.

F:\Craig Farm\FYR 2009\Summary Table_Wells Combined_063008 
Summary of Analytical Data

Craig Farm Superfund Site

1999 through 2008

Sample Location: M-19C M-19C DUP M-19C M-19C DUP M-1Sample Date: 2/10/1999 2/10/1999 7/20/1999 7/20/1999 2/29/BENZENE ug/l 1 U 1 U 1 U 1 U 10 BENZENE METADISULFONIC ACID mg/l 10 U 10 U 10 U 10 U 0.07 BENZENE MONOSULFONIC ACID mg/l 10 U 10 U 10 U 10 U 0.05 P-PHENOL SULFONIC ACID mg/l 10 U 10 U 10 U 2500 U 1.7 RESORCINOL mg/l 300 U 300 U 300 U 300 U 50.6 TRIHYDROXYDIPHENYL mg/l 550 D 570 D 620 D 550 D 443 Sample 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-1Sample Date: 4/16/2003 12/15/2003 6/14/2004 12/7/2004 6/8/2BENZENE ug/l 1 U 1 U 1 U 1 U 1 BENZENE METADISULFONIC ACID mg/l 0.068 0.055 0.055 0.056 0.05 BENZENE MONOSULFONIC ACID mg/l 0.05 U 0.05 U 0.05 U 0.05 U 0.05 P-PHENOL SULFONIC ACID mg/l 1.59 0.638 0.663 J 0.885 J 1.33 RESORCINOL mg/l 34.3 33.1 39.9 40 29 TRIHYDROXYDIPHENYL mg/l 375 501 409 395 328 Sample Location: M-19C M-19C-032007Sample Date: 6/6/2006BENZENE ug/l 1 U 1 U 1 U 1 U 1 BENZENE METADISULFONIC ACID mg/l 0.0665 0.0779 0.05 U 0.05 U 0.05 BENZENE MONOSULFONIC ACID mg/l 0.0576 0.05 U 0.05 U 0.05 U 0.05 P-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 305 401 316 303 297

U - Indicates non-detected

J - Indicates estimate

D - Indicates result is from analysis of a secondary dillution 

M-19C-110806

11/8/2006 3/20/2007

M-1

11/7/2007 3/12/

M-19C

F:\Craig Farm\FYR 2009\Summary Table_Wells Combined_063008 
Concentration Trends for M-19C 1999 though 2007

0

200400600800

100012001400

1/1/1999 1/1/2000 1/1/2001 1/1/2002 1/1/2003 1/1/2004 1/1/2005 1/1/2006 1/1/2007 

Concentration (mg/L)

P-PHENOL SULFONIC ACRESORCINOL mg/lTRIHYDROXYDIPHENYL BENZENE MONOSULFONBENZENE METADISULFO

NOTES:-Open Symbols are non-det-Non-detects were replaced limit.

F:\Craig Farm\FYR 2009\Summary Table_Wells Combined_063008 
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 company leading the five-year 

review: EPA 

Weather/temperature: Sunny, ~85o

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, zoning 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 estimate $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. Institutional Controls (ICs)

1. Implementation and enforcement 

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

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

Type of monitoring (e.g., self-reporting, drive by): Self-reporting: 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 runoff and intercept and convey the runoff to a lined 

channel.) 

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

Remarks__________________________________________________________________________ 

_________________________________________________________________________________ 

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

Remarks__________________________________________________________________________ 

_________________________________________________________________________________ 

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

Remarks__________________________________________________________________________ 

_________________________________________________________________________________ 

C. Letdown Channels Applicable N/A 

(Channel lined with erosion control mats, riprap, grout bags, or gabions that descend down the steep side 

slope of the cover and will allow the runoff water collected by the benches to move off of the landfill 

cover without creating erosion gullies.) 

1. Settlement 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 displacement_______________ 

Rotational displacement____________ 

Remarks__________________________________________________________________________ 

_________________________________________________________________________________ 

2. Degradation Location shown on site map Degradation not evident 

Remarks__________________________________________________________________________ 

_________________________________________________________________________________ 

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

1. Siltation Location shown on site map Siltation not evident 

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 collection 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 treated 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 declining 
D. 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 associated with the remedy. An example would be soil 

vapor extraction. 

XI. OVERALL OBSERVATIONS

A. Implementation of the Remedy

Describe issues and observations relating to whether the remedy is effective and functioning as designed. 

Begin with a brief statement of what the remedy is 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 prevent 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 areas was solidified onsite and placed into an onsite 

landfill. Monitoring wells are installed onsite downgradient 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 trench. Contaminant concentrations in groundwater 

monitoring wells have generally declined site-wide or remained relatively stable and contaminant 

concentrations in landfill monitoring wells indicate that 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 requirements of the ROD for this seep. Samples from 

Seep A indicate the water continues to be toxic. Design 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 identified 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 she 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 Chemical Site (BCACS). The BCACS encompasses multiple inactive chemical 

disposal sites and active chemical manufacturing plants. In 2003, all residences 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