SECOND FIVE-YEAR REVIEW REPORT FOR

Moyer's Landfill Superfund Site

Montgomery County, Pennsylvania

PREPARED BY:

United States Environmental Protection Agency

Region III

Philadelphia, Pennsylvania

Date:

_ _'".LffAl/_
Table of Contents

List ofAcronyms iii

Executive Summary iv

Five Year Review Summary Form iv

I. Introduction 1

II. Site Chronology 3

III. Background 3

IV. Remedial Actions 6

V. Progress Since Last Five-Year Review 12

VI. Five-Year Review Process 13

VII. Technical Assessment 21

VIII. Issues 22

IX. Recommendations and Follow-Up Actions 22

X. Protectiveness Statement 23

XI. Next Review 23

References for Moyer's Landfill Superfund Site Five-Year Review : 24

Tables

Table 1: Chronology of Site Events

Table 2: Moyer's Landfill Superfund Site Construction Dates

Table 3: Operation and Maintenance Costs

Table 4: Summary of Groundwater Sampling Results- Volatile Organics

Table 5: Summary of Landfill Gas Monitoring, 2010

Table 6: Summary ofLandfill Gas Monitoring, 2012

Table 7: Ambient Air Sampling Results

Table 8: Issues Identified

Table 9: Recommendations and Follow-up Actions

Figures

Figure 1: Site Location Map

Figure 2: Site Layout Map

Figure 3: Groundwater Well and Gas Vent Locations

Figure 4: Summa Canister and Well Locations

Attachments

Attachment 1: Advertisement in the Times Herald

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CERCLA

EPA

ESD

ICs

MCLs

NCP

NPL

OU

O&M

PADEP

PCOR

POTW

RIIFS

ROD

RPM

SARA

USACE

List of Acronyms

Comprehensive Environmental Response, Compensation, and Liability Act

United States Environmental Protection Agency

Explanation of Significant Differences

Institutional Controls

Maximum Contaminant Levels

National Oil and Hazardous Substances Pollution Contingency Plan

National Priorities List

Operable Unit

Operations and Maintenance

Pennsylvania Department ofEnvironmental Protection

Preliminary Close Out Report

Publicly Owned Treatment Works

Remedial Investigation/Feasibility Study

Record ofDecision

Remedial Project Manager

Superfund Amendments and Reauthorization Act of 1986

U.S. Army Corps ofEngineers

111
Executive Summary

The remedy for the Moyer's Landfill Superfund Site in Collegeville, Lower

Providence Township, Montgomery County, Pennsylvania included gradil1g and leveling

the site, constructing retaining walls at highly erodible areas, capping the site with a

RCRA cap, installing a gas vent system that prevents landfill gas accumulation,

collecting surface runoff and discharging it directly into the creek, installing a leachate

collection and removal system, collecting leachate and discharging it to the publicly

owned treatment works, and continuing to monitor groundwater and surface waters. The

Site achieved construction completion with the signing ofthe Preliminary Close-Out

Report (PCOR) on September 17,2002. The trigger for the second five-year review is

the date ofthe first five-year review which was completed on September 26,2007.

This second Five-Year Review for Moyer's Landfill finds that the remedy has

been constructed in accordance with the requirements ofthe ROD and is functioning as

designed. The immediate threats have been address.ed though capping the landfill and

collecting and properly disposing ofthe leachate. Since the Rerriedial Actions at both

Operable Units are protective, the Site is protective of human health and the environment.

Long-term protectiveness ofthe remedy will be maintained by continuing to perform

operation and maintenance ofthe landfill cap and leachate collection system; monitoring

the groundwater and ambient air; and enforcing the institutional controls.

Government Performance and Results Act (GPRA) Measure Review

As part ofthis Five-Year Review, the GPRA Measures have been reviewed. The GPRA

measures and their status are provided as follows:

Environmental Indicators:

Human Health: Human Exposure Under Control (HEUC).

Groundwater Migration: Does not apply.

Site-wide Ready for Anticipated Use (SWRAU):

The Site achieved the SWRAU measure on December 20,2011.

iv
Five-Year Review Summary Form

SITE IDENTIFICATION

Site Name: Moyer's Landfill Superfund Site

EPA 10: PAD980508766

Region: 3

NPL Status: Final

Multiple OUs?

Yes

State: PA City/County: Lower Providence Township,

Montgomery County

SITE STATUS

Has -the site achieved construction completion?

Yes

REVIEW STATUS

Lead agency: EPA

Author name (Federal or State Project Manager): Sharon Fang

Author affiliation: USEPA

Review period: October 2011 - August 2012

Date of site inspection: January 19, 2012

Type of review: Policy

Review number: 2

Triggering action date: 9/26/2007

Due date (five years after triggering action date): 9/26/2012

v
Five-Year Review Summary Form (continued)

Issues/Recommendations

OUts) without Issues/Recommendations Identified in the Five-Year Review:

02 - Leachate CollectiQn System

Issues and Recommendations Identified in the Five-Year Review:

OUts): 01- Landfill Issue CategQry: Site Access/Security

Cap Issue: Frequent trespassing and damage to the fence

Recommendation: Enforcement of Township Ordinance should deter trespassing arid

fence cutting

Affect Current Affect Future Implementing Oversight Party Milestone Date

Protectiveness Protectiveness Party

No No Township EPAIPADEP Ongoing

Issues and Recommendations Identified in the Five-Year Review:

OUts): 01 Issue Category: Operations and Maintenance

Issue: Erosion along the drainage bench-downslope drain transitions occurs more often

than preferable

Recommendation: Replace soil and plant grass at optimal time to establish the transition

area along the grout bag channels

Affect Current Affect Future Implementing Oversight Party Milestone Date

Protectiveness Protectiveness Party

No No PADEP EPA October 2012

Sitewide Protectiveness Statement

Protectiveness Determination:

Protective

Protectiveness Statement:

Addendum Due Date (if applicable):

n/a

This second Five-Year Review for Moyer's Landfill fmds that the remedy has been

constructed in accordance with the requirements ofthe ROD and is functioning as designed.

The immediate threats have been addressed though capping the landfill and collecting and

properly disposing ofthe leachate. Since the Remedial Actions at both Operable Units are

protective, the Site is protective of human health and the environment. Long-term

protectiveness ofthe remedy will be maintained by continuing to perform operation and

maintenance ofthe landfill cap and leachate collection system; monitoring the groundwater

and ambient air; and enforcing the institutional controls.

VI
Second Five-Year Review Report

for

Moyer's Landfill Superfund Site

Lower Providence Township, Montgomery County, Pennsylvania

I. Introduction

The purpose ofthe Five-Year Review is to detennine 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.

EPA guidance on conducting the five-year review is provided by OSWER Directive

9355.7-03B-P, Comprehensive Five-Year Review Guidance (EPA, 2001). EPA personnel

followed the guidance provided in this OSWER directive in conducting the five-year review

perfonned for the Site.

Five-year reviews are conducted either to meet the statutory mandate under the

Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) § 121, or

as a matter of EPA policy. The statutory requirement to conduct a five-year review was added to

CERCLA as part ofthe Superfund Amendments and Reauthorization Act of 1986 (SARA).

CERCLA §121states:

Ifthe 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 jive years after the initiation

ofsuch remedial action to assure that human health and the environment are

being protected by the remedial action being implemented. In addition, ifupon

such review it is the judgment ofthe President that action is appropriate at such

site in accordance with section [104j or [106j, the President shall take or require

such action. The President shall report to the Congress a list offacilitiesfor

which such review is required, the results ofall such reviews, and any actions

taken as a result ofsuch reviews.

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

states:

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

contaminants remaining at the site above levels that allowfor unlimited use and

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

every jive years after the initiation ofthe selected remedial action.

1
The statutory requirement to conduct a five-year review applies to CERCLA §121

remedial actions selected after the effective date of SARA, Octol;Jer 17, 1986. The Moyer's

Landfill Record ofDecision (ROD) was signed on September 30, 1985, which predates the

SARA. For sites where a statutory review is not specifically required, reviews may be conducted

as a matter of policy for any ofthe following type actions:

I. A pre-SARA remedial action that leaves hazardous substances, pollutants,

or contaminants, above levels that allow for unlimited use or unrestricted

exposure.

II. A pre- or post-SARA remedial action that, upon completion, will not leave

hazardous substances, pollutants, or contaminants above levels that allow

for unlimited use or unrestricted exposure, but will take longer that five

years to complete, i.e., achieve the cleanup levels that allow for unlimited

use and unrestricted exposure.

III. A removal action for a site on the NPL that leaves hazardous substances,

pollutants, or contaminants above levels that allow for unlimited use or

unrestricted exposure, and where no remedial action has or will take place.

The pre-SARA remedial action described above (item I) corresponds to the remedy

specified for the Moyer's Landfill Superfund Site; therefore, EPA Region III has conducted this

five-year review ofthe remedy as a matter of policy due to the fact that hazardous substances,

pollutants, or contaminants remain at the Site above levels that allow for unlimited use and

unrestricted exposure.

EPA Region III conducted the five-year review ofthe remedy implemented at the

Moyer's Landfill Superfund Site in Collegeville, Montgomery County, Pennsylvania. This

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

2011 through August 2012. This report documents the results ofthe review.

This is the second five-year review ofthe Moyer's Landfill Superfund Site. The

triggering action for this policy review is the previous five-year review dated September 26,

2007. The five-year review is required due to the fact that hazardous substances, pollutants, or

contaminants remain at the Moyer's Landfill Superfund Site above levels that allow for

unlimited use and unrestricted exposure.

2
II. Site Chronology

Table 1 Chronology of Site Events

Event Date

Disposal in landfills Early 1940s to April 1981

State ordered closure of landfill Early 1981

NPL listing December 30, 1982 (proposed)

September 8, 1983 (final)

Remedial Investigation/Feasibility Study September 30, 1985 completed

Record ofDecision September 30, 1985

Remedial design complete April 20, 1989

Site Maintenance Plan January 1991

Construction complete for landfill cap, OU-l November 24, 1994

PADEP takes over O&M responsibility, EPA

completes one year maintenance period including a May 24,1996

six month extension

Explanation of Significant Differences (ESD)- January 2000 design work begins for leachate storage tanks

Construction start for leachate treatment, OU-2 May 2000

Construction complete for OU-2 August 2002

Preliminary Close-out Report September 17, 2002

Remedial Action Construction Report April 4, 2004

First Five-year Review Report September 26, 2007

Second ESD- Institutional Controls (lCs) September 18, 2009

Five-year Review Addendum July 12,2011

Township ordinance implemented ICs October 20, 2011

III. Background

Physical Characteristics

The Moyer's Landfill Superfund Site is a 65-acre inactive privately owned landfill

located at Moyer Road in Collegeville, Lower Providence Township, Montgomery County,

Pennsylvania. The site is about twenty-seven (27) miles northwest of Philadelphia, Pennsylvania

3
(Figure 1, Site Location Map). According to the 2010 Census, Lower Providence Township has

a population of25,436.

The site area consists of open land surrounded by wooded areas on steep slopes. Located

on the site are leachate collection tanks and a wooden storage shed in the south valley. Runoff

from the landfill slopes flowed westerly into Skippack Creek, until the remedy was built. Now

runoff is directed towards stormwater basins around the perimeter ofthe landfill and routed off

the landfill cap. The Skippack Creek is located about 350 feet north-west ofthe landfill. The

Skippack Creek then discharges into the Perkiomen Creek which eventually discharges into the

Schuylkill River (Figure 2, Site Layout Map).

Land and Resource Use

The landfill is bounded on the north and west by Evansburg State Park, on the east by a

single original home and a new housing development (Valley High Estates) and on the south by

the new housing development and undeveloped land (Figure 2, Site Layout Map). The area

immediately surrounding the landfill is residential. The nearby Skippack Creek flows through

Evansburg State Park and has, in the past, been stocked with trout.

Ground water in the site area occurs in an aquifer which has poor water yields. The

average depth ofthe wells in the area is 151 feet. Wells drilled into the deeper system are often

artesian due to the dense, relatively impermeable layer of bedrock overlying the deep system.

Most ofthe residents in the vicinity ofthe landfill are on public water. There are approximately

ten residential wells along Moyer Road and Visitation Road, which are east ofthe site.

Groundwater flows to the west and south west, towards the Skippack Creek. There are no

residential wells between the landfill and the Skippack Creek.

History ofContamination

The Moyer's Landfill property operated as a municipal landfill from the early 1940s until

April 1981, during which time it received municipal waste, sewage and industrial sludges. The

landfill accepted a variety ofsolid and liquid hazardous wastes, including polychlorinated

biphenyls (PCBs), dioxins, solvents, paints, low-level radioactive wastes, and incinerated

materials in bulk form and/or containerized drums.

The original unlined landfill area was approximately 39 acres in size. In the late 1970s,

the landfill owners submitted a request to expand the landfill boundaries to the northwest. Site

preparation work began on a new area in 1977, and included installation of an asphalt liner prior

to filling. Landfilling was reportedly limited to this new, lined area from the late 1970s to early

1981, at which time an order from the Pennsylvania Department of Environmental Resources

(PADER), now Pennsylvania Department of Environmental Protection (PADEP), closed the

facility.

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Originally, there was no management of leachate from the landfill and the discharge

either seeped into groundwater or discharged directly to the Skippack Creek. In the early 1970's

PADER developed and implemented more comprehensive landfill regulations. As a result, a

leachate collection system was constructed and began operating in 1972. However, leachate still

overflowed continuously from several collection pits located on the property.

Initial Response

In 1981, PADEP closed the facility. The Moyer's Landfill became a Superfund Site

when it was listed on the National Priorities List (NPL) on September 8, 1983. The Remedial

Investigation and Feasibility Study were fund lead.

Basis for Taking Action

In the early 1980s, on-site leachate and seep samples were collected and analyzed. The

samples were contaminated with eighty-six (86) priority pollutants and sixteen (16) metals,

nearly all contaminants of concern. The landfill surface showed a number of leachate and seep

locations which served as a continuous source of pollution to ground and surface waters.

Numerous seeps at the site were seeping lightly or leaching heavily contaminated water from the

landfill.

There was no evidence of any detectable level of air pollution.

Surface water samples were taken from Skippack Creek and the Perkiomen Creek, and

fish samples were taken from Skippack Creek. Contaminants were detected in low

concentrations in both surface water and fish. The contaminants were attributable to the landfill.

Off-site residential wells bordering the landfill were sampled for priority pollutants,

metals, organics, PCBs, dioxins, and beta radiation. These wells did not show any detectable

levels of organic or inorganic pollution. The residential groundwater met all EPA Drinking

Water Standards at the time. Shallow monitoring wells installed around the periphery ofthe

landfill showed concentrations of contaminants above risk based numbers.

The groundwater contamination was mostly due to surface water percolation through the

landfill and into the groundwater. The groundwater level is lower than the bottom ofthe landfill.

Site contaminants were transported directly to the surface water bodies via surface water runoff

and indirectly through contaminated groundwater (upper aquifer) discharged to the creeks. The

deeper aquifer was not contaminated.

The ROD identified the following contaminants which were above acceptable levels:

arsenic, barium, lead, manganese, nickel, zinc, beta radiation, trichloroethylene (TCE), toluene,

xylene, di-n-octylphthalate, 2-hexanone, 2-butanone, bis (2-ethylhexyl) phthalate, acetic acid and

methylester.

5
IV. Remedial Actions

Remedy Selection

The ROD for the Moyer's Landfill Site is a pre-SARA ROD and thus does not contain

the same information or level of detail as a more current ROD. The ROD stated the Remedial

Action Objectives in the following manner: "The overall strategy is to mitigate and minimize

harm to the public health and the environment. This should include minimizing further upper

aquifer contamination and the possibility of direct contact with the waste. Leachate control is an

integral part ofthe overall scheme in order to eliminate the continuing migration of contaminants

across the site and offthe site to the Skippack Creek." Because EPA is responsible for

protecting the human health and environment, EPA conducted remedial actions such as capping

the landfill and collecting landfill leachate and routing it for treatment. These actions prevented

direct contact with the waste and contaminated leachate and prevent off-site migration of

contamination via surface runoff and groundwater movement.

The 1985 ROD identified a'primary and a contingent remedy. The major components of

the primary remedy were as follows: '

• Soil cover with permeability of 10-4/1 0-5 em/sec;

• Erosion and sedimentation control measures;

• Surface water diversion;

• Leachate collection, on-site treatment and discharge to surface water;

• Methane gas recovery and sale;

• Security/fencing measures;

• Groundwater monitoring; and

• All closure activities in compliance with Resource Conservation and Recovery Act

(RCRA) at conclusion of gas generation phase (10 to 20 years)

The implementation ofthis remedy depended on the success ofthe gas

generation/recovery program. The gas recovery system was not feasible due to diminishing gas

generation, thus the contingency alternative was implemented. The major components ofthe

contingency remedy include:

• Miscellaneous work preparatory to installation ofRCRA cap: grading, flattening ofsteep

slopes, retaining walls and installation ofrip-rap at areas that are most likely to be

eroded;

• Construction ofRCRA cap;

• Gas venting and gas monitoring;

• Surface water collection and discharge to Skippack Creek;

• Security/fencing measures;

6
• Leachate collection and on-site treatment that will meet the 10-6 risk level in the

groundwater and discharge requirements in the stream; and

• Operation and Maintenance: ground and surface water monitoring, maintenance ofthe

cap and treatment of leachate on-site.

In January 2000, EPA issued an Explanation of Significant Differences (ESD) which

modified the leachate treatment portion ofthe remedy. The ESD changed the leachate treatment

portion ofthe remedial action from on-site leachate treatment to leachate collection with

treatment at an existing Publicly Owned Treatment Works (POTW). This change better

protected the surface waters and the environment from the potential failure of an undersized

treatment plant. In addition, routing the leachafe to the POTW was shown to be more cost

effective than building and operating a leachate treatment facility.

In September 2009, EPA issued a second Explanation of Significant Differences (ESD)

to require Institutional Controls (ICs) as part ofthe remedy. ICs are non-engineered instruments,

such as administrative and legal controls, that are necessary for the protection of the integrity of

the remedial measures on-site to ensure long-term protection of human health and the

environment. ICs play an important role in site remedies because they reduce exposure to

contamination by limiting land or resource use and guide human behavior at a site.

Remedy Implementation

Implementation of the Remedial Action

EPA executed an Interagency Agreement with the U.S. Army Corps of Engineers

(USACE) for the design ofthe remedial action, which was completed on April 20, 1989. EPA

executed another Interagency Agreement with the USACE for the construction ofthe Remedial

Action. After beginning construction, local residents expressed concerns regarding truck traffic.

In response, EPA then directed USACE to redesign a partial cap (instead of a full cap) with a

perimeter leachate collection trench. A partial cap meant that less fill was needed for

construction, thus reducing the truck traffic. Less cover, however, also led to steeper slopes for

the redesigned landfill cap. The redesign was completed in November 1992 and construction of

the redesigned landfill cap was completed in November 1994. The Remedial Action Report for

the landfill cap, Operable Unit 1 (OUl) was completed in December 1996.

EPA identified the leachate collection and treatment portion ofthe remedial action as

Operable Unit 2 (OU2). In January 2000, EPA issued an Explanation of Significant Differences

(ESD) which changed the leachate treatment portion ofthe Remedial Action from on-site

leachate treatment to leachate collection with treatment at an existing POTW. The modified

Remedial Action was originally described in the ROD, but was infeasible because the sewer line

was not available near the site when the ROD was issued. The construction ofthe OU2 remedial

action was initiated in 2000 and completed in August 2002. OU2 responsibility was divided as

7
follows: 1) Montgomery County constructed the municipal interceptor, 2) EPA via USACE

constructed the necessary leachate equalization tanks, and 3) PADEP was responsible for

collecting and transferring the leachate to the equalization tanks and from the tanks to the

municipal interceptor. The Remedial Action Report for the leachate collection and treatment

system (OU2) was completed in April 2004.

Below is a table listing the key dates for construction activities at Moyer's Landfill

Superfund Site.

Table 2 Moyer's Landfill Superfund Site Construction Dates

Construction Event Date

Remedial Design Analysis Report April 20, 1989

Selected construction contractor October 13, 1989

Construction start, landfill cap OUI January 4, 1990

Partially terminate contract About October 1, 1990

El?A directed USACE to redesign cap October 8, 1990

Non-terminated portion of construction July 13, 1992

completed

Redesign Analysis Report completed November 13, 1992

Final inspection January 22, 1993

Selected redesign construction contractor April 23, 1993

Redesign construction start May 23, 1993

Pre-final inspection November 14, 1994

Redesign construction completed November 24, 1994

Post Maintenance period inspection May 15,1996

Maintenance period ends May 24,1996

Remedial Action Report, OUI December 19, 1996

EPA issues an Explanation of Significant January 2000

Difference (ESD)

EPA begins constructing leachate storage May 2000

tanks OU2

Construction ofleachate storage tanks August 2000

complete

Completion Report, OU-l September 29,2000

Sewer line interceptor complete March 2002

Leachate flowing from Pump Stations 1 & 2 May 2002

New flowmeters installed June 2002

Pump Station #3 on-line- OU2 construction August 2002

complete

Preliminary Close-out Report September 17, 2002

Remedial Action Report, OU2 April 4, 2004

8
Final Inspection

For the original construction contract, a punch list inspection was conducted at the Site

by EPA, PADER, the USACE, and the contractor, Chemical Waste Management (CWM), Inc.,

on June 30, 1992. Punch lists oftasks to be accomplished before the final inspection were

generated and the punch list tasks were executed. The final inspection was performed on

January 22,1993 by the USACE and CWM.

For the redesigned portion ofthe landfill cap, a pre-final inspection was conducted by

EPA, PADER, the USACE, and the contractor, Conti Environmental Inc., on November 14,

1994. A post-maintenance period inspection was conducted between USACE and Conti in May

1996 and a follow-up post-maintenance period inspection was conducted by USEPA, USACE,

and PADEP in August 1996.

Inspection ofthe leachate storage system (OU2) was conducted in August 2000. A

punch list was established at that time and all the issues were addressed by November 2000.

Between August 2000 and August 2002, the sewer line was constructed and the leachate transfer

system'was updated. An additional inspection and training session was held in May 2002.

EPA and PADEP conducted a final inspection ofthe entire site on August 30, 2002 and

determined that the remedy had been constructed in accordance with the Remedial Design plans

and specifications and that no further response is anticipated for this site. The Moyer's Landfill

Superfund Site achieved construction completion when the Preliminary Close-out Report was

signed on September 17, 2002.

The performance standards attained during the remediation were documented in the

Remedial Action Completion Reports dated December 19, 1996 and April 4, 2004.

Implementation ofInstitutional Controls

The September 2009 ESD required ICs as part ofthe remedy. ICs are legal controls, such

as title restrictions, restrictive covenants, etc., to protect the integrity ofthe remedial measures

on-site in such a way as to prevent or reduce exposure to hazardous substances. In October

2011, the Lower Providence Township approved an ordinance which serves as the IC for the

Moyer's Landfill Site, which states:

9
It shall be unlawful for any Owner, lessor, lessee or occupier ofthe Property, or any other

Person to engage in any activities on the Property that would in any manner disturb or

interfere with the environmental remedial systems at the Property, including, without

limitation, the landfill cap, gas vents, monitoring wells, leachate collection and

conveyance system, and security measures, such as fencing, that prevent access to the

Property. The prohibited activities include, but are not limited to the following:

A. Digging in or disturbance of the landfill cap, tampering with hardware or

equipment associated with the gas vents, monitoring wells, leachate collection and

conveyance systems or the security fencing.

B. Any use of leachate generated at the Property including, without limitation, any

activities that could cause exposure to contaminants in the leachate via ingestion,

vapor inhalation or derma! contact.

C. Digging in or disturbance of the landfill cap including, without limitation, any

activities that could result in contact with contaminants in the soils at the Property

through ingestion, inhalation or dermal contact.

System Operation/Operation and Maintenance

The USACE was responsible for maintenance ofthe landfill for the first eighteen months.

A Site Maintenance Plan, dated January 1991, documented the expected activities to maintain

and monitor the integrity ofthe Site, i.e. monitor the leachate, the groundwater in both the

shallow and deep zones, and the gas vents on a quarterly basis, visual inspections ofthe cap area

and associated drainage/collection systems with corrective actions for identified problems.

However, the plan states that "the number ofmonitoring locations, analytical parameters, and

sampling frequencies may be modified during the maintenance period by PADER..." PADEP

took responsibility for the landfill cap maintenance in May 1996.

The responsibility for operations and maintenance (O&M) ofthe leachate storage and

transfer system has always been with PADEP. EPA provided training on the system for PADEP

and PADEP has been operating the system since start-up. The leachate currently is permitted by

the Oaks POTW to meet their pretreatment program standards.

PADEP currently reports O&M status and issues to EPA. PADEP O&M consists ofthe

following activities and annual O&M costs are shown in Table 3:

1) Site Inspections: Routine site inspections include observations ofthe fence

line, road, soil cap and functioning ofthe leachate collection system at

least once per month. The leachate collection system is inspected

specifically for integrity ofthe leachate holding tanks, the leachate level in

the manholes, the flow meter reading, and the state ofthe discharge pipe.

Typically, inspections are performed twice a month (once by DEP, once

by DEP's contractor).

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2) Leachate Monitoring: Monitoring leachate involves taking a monthly

reading ofthe leachate volume discharged to the POTW, and reporting

infonnation on total gallons per month and average daily flow rate to the

POTW on a monthly basis, by the 15th ofthe month.

3) Grass cutting: The grass at the site needs to be cut no less than twice a

year in order to discourage the growth ofsmall trees and shrubs, and also

to aid in the identification ofsoil erosion. The landfill cap and surface

water management features are inspected prior to each mowing.

4) Cap Repairs:Jdeally, this task is perfonned during the growing season as

needed to ensure integrity ofthe HDPE cap, as it is vitally important to

reestablish vegetation on any soil repairs to limit additional erosion.

5) Perimeter Road Repairs: Areas to be repaired are noted during site

inspections and repaired accordingly. This task includes the "bridge

crossings" over surface drainage features.

6) Fence Repairs: Holes in the fence or damage from fallen trees are noted

during site inspections and repaired as needed. Holes in the fence or

damage from trespassers shall be enforced per local ordinance. Local law

enforcement will identify trespassers in order to prosecute or receive

compensation to perfonn the repair.

7) Tree removal: This task is limited to trees that have dam~ged the

perimeter fence or have the potential to damage the cap. Trees to be

removed are identified during the site inspections.

8) Sampling: Groundwater and air monitoring/gas vent sampling will be

collected by Department personnel and analyzed by the PADEP's Bureau

of Laboratories at least every other year. Infonnation on the

environmental monitoring is included in the Data Review section ofthis

five-year review. The two sampling events in this five-year review period

occurred in December 2010 and February 2012.

a) Groundwater monitoring - Five monitoring wells, and the leachate

sump in the South Valley are analyzed for volatile organics, TAL

metals, and cyanide. The leachate may also be analyzed for other

parameters requested by the POTW.

b) Air monitoring - Eight Summa canisters are deployed around the

hmdfill (upwind.and downwind) in order to identify concentrations of

volatile organic compounds. In addition, the Department also deploys

11
up to six smaller, silica-lined Summa canisters to sample directly from

active gas vents on the site.

Table 3 Operation and Maintenance Costs (in $)

*- Only Jan -Apnl 20 II data avatlable for Sewer, Electnc, and Telephone; 20 II costs are Jan-Apr costs multlphed by three.

2007 2008 2009 2010 2011*

O&M 96,371 15,704 157,999 27,634 44,809

Sewer 22,342 18,194 29,531 21,899 21,533

Electricity 1,326 2,120 3,779 1,839 2,187

Telephone 354 392 437 418 421

Total Annual Cost 120,393 36,410 191,747 51,790 68,951 . .

V. Progress Since Last Five-Year Review

This is the second five-year review for the Moyer's Landfill Superfund Site. The first

five-year review's protectiveness statement is as follows:

This first Five-Year Review for Moyer's Landfill finds that the remedy has been

constructed in accordance with the requirements ofthe ROD and is functioning as

designed. The immediate threats have been addressed though capping the landfill

and collecting and properly disposing ofthe leachate.

However, a short-term protectiveness determination ofthe remedy cannot be

made until further information is obtained. This information will be obtained by

taking appropriate ambient air samples to ensure landfill gas migration is not an

issue to the adjacent residents. It is expected that these actions will take

approximately 6 910nths to complete, at which time a protectiveness

determination will be made.

In order for the remedy to be protective in the long-term, institutional controls

will need to be implemented as part ofthe remedy and ambient air monitoring

will need to be performed. Continued operation and maintenance ofthe landfill

cap and leachate collection system; and monitoring the groundwater and ambient

air will ensure the remedy's long-term protectiveness.

The first five five-year review cited the following recommendations:

I. An O&M Plan should be developed to document the activities to be performed for the

Site and frequency expected. An annual report should be submitted each year in order to

document what O&M activities were performed.

12
2. The remedy should be modified to include ICs. A plan should be developed to identify

how the institutional controls for the Site will be implemented in accordance with the

modified remedy.

3. To further stabilize the drainage bench-downslope drain transition, low-growing prairie

grass should be planted to establish the transition area along the grout bag channels.

4. Ambient air monitoring should be performed in order to determine if landfill gas

migration is an issue for adjacent residents. Also, continued groundwater monitoring and

data evaluation is essential to ensure vapor migration is not an issue.

The recommendations have been resolved as follows:

1. In February 2012, EPA approved PADEP's O&M Plan which documents the activities

and frequency oftasks performed for the Site. An annual report will be submitted each

year in order to document what O&M activities were performed.

2. An ESD was issued in September 2009 to include ICs in the remedy. The township

implemented the ICs via local ordinance in October 2011.

3. To further stabilize the drainage bench-downslope drain transition, PADEP decided to

continue using standard contractor vegetation mixes that were heavy on perennial rye and

red fescues. Finding suppliers for prairie grass plugs proved more difficult than

expected, and the pricing proved prohibitively high. PADEP found that properly timing

the construction and reseeding was more important to establishing new vegetation than

the type of vegetation used.

4. Ambient air monitoring was performed in December 2010. A five-year review

addendum was issued in July 2011 which stated that landfill gas migration is not an issue

for adjacent residents.

VI. Five-Year Review Process

Administrative Components

The five-year review team included Sharon Fang, EPA Remedial Project Manager

(RPM), Bruce Rundell, EPA hydrogeologist, Dawn loven, EPA toxicologist, Betsy Lukens, EPA

counsel, Tim Cherry, PADEP HSCA supervisor, Colin Wade, PADEP project manager, Dennis

Kutz, PADEP project manager, Tim Gallagher, EPA RPM, and Patricia Flores, EPA air

specialist. The review began in October 2011.

13
Community Involvement

To infonn the community ofthe five-year review EPA placed an advertisement in the

Times Herald on January 23, 2012 notifying area residents ofthe five-year review (Attachment

1). The advertisement explained what a five-year review consists of, why EPA was conducting a

five-year review and provided both the RPM and Community Involvement Coordinator (CIC) as

contact people for questions or comments. Neither the RPM nor the CIC received any questions

or comments as a result ofthe advertisement.

Document Review

The five-year review consisted of a review ofrelevant documents including the RIIFS;

the ROD; two ESDs; the Consent Decree; Site Maintenance Plan; the Preliminary Closeout

Report (PCOR); the Remedial Action Completion Reports; and data provided by PADEP.

Data Review

Environmental data provides infonnation to assess and demonstrate that the remedy is

achieving the perfonnance standards described in the ROD, and provides information for the

five-year review. Listed below is a summary ofthe monitoring events performed at the Site.

Groundwater Monitoring

Groundwater monitoring is performed in order to confirm that there is no migration of

contamination from the landfill. The following locations were sampled in December 2010 and

February 2012:

LS-1

MW4

MW5

MW-R1

MW-R2

Manhole in the south valley, pumps to leachate tanks

4" Well @ South Valley Outside Fence

4" Well @ Roadside Between Sedimentation Basins #2 & #3

6" Well @ Visitation Road and Grange Ave

4" Well @ Visitation Road and Grange Ave

Figure 3 is a map showing the on-site groundwater well locations, site features, and

monitoring points. Groundwater flows towards the Skippack such that wells MW-4 and MW-5

are on the downgradient edge ofthe plume, and wells MW-R1 and MW-R2 are upgradient.

Samples taken at LS-1 are samples ofthe leachate that is then collected in the tanks and treated

at the POTW.

The groundwater monitoring wells were analyzed for volatile organic compounds

(VOCs). The leachate discharge and South Valley manhole (LS-1) were analyzed for volatile

organic compounds, metals, cyanide, oil & grease and general chemistry. The groundwater and

leachate were not analyzed for radiation because subsequent to the ROD, EPA determined that

14
the levels ofradiation found during the remedial investigation are within acceptable range.

Table 4 summarizes the volatile organic contaminants that were detected during groundwater

sampling and list the EPA drinking water standards, Maximum Contaminant Level (MCL). For

example, nothing is listed for MW-4 in 2010 because no contaminants were detected.

Table 4 Summary of Groundwater Sampling ResultsVolatile Organics (ug/l)

Location (year)

MW-R1 MW-5 MW-R1 MW-R2 MW-5

Analyte name (2010) (2010) (2012) (2012) (2012) MeL

t-Butyl Alcohol 5.4 * Chlorobenzene 0.55 100

cis-I,2-Dichloroethene 4.7 2.9 70

I,I-Dichloroethane 0.51 * Ethylbenzene 0.66 700

m/p-Xylene 1.9 +

o-Xylenes 0.6 +

Tetrahydrofuran 3.7 4.1 * Toluene 3.6 1.6 1,000

Trichloroethene 0.61 2.7 4.8 5

Vinyl Chloride 1.9 1.9 2

Acetone 3 4.3 *

* = MCL does not exist for these constituents

-- = Not detected

+ = Total Xylenes MCL is 10,000

Residential Groundwater

Most residents in the area receive water from the local public water supply. No

residential wells exist between the landfill and the downgradient monitoring wells.

In January 2001, PADEP sampled ten home wells along Moyer Road and Visitation Road

for volatile organics and bacteria. At the time, there was a problem with runofffrom the thenactive pig farm. All but two home wells were non-detect for volatiles; ofthese, one was below

the MCL, the other was higher than results from the landfill monitoring wells. This particular

home on Visitation Road is occupied by an older couple who operate a welding/metal working

business out oftheir home. At the time, they reported that they did not drink the water without

treating it first. Extending a public water line was not an option at the time. Of eight homes

tested for coliform bacteria, five showed detections that were above Montgomery County Health

Department criteria. These results were reported to the Health Department. One resident used a

filter and UV light to treat his water. These residents are side-gradient from the direction of

groundwater flow and are not expected to be impacted by the landfill. No residential well

sampling was conducted as part ofthis five-year review.

15
Stream Sampling

Upon review ofthe current leachate and groundwater sampling, there is no data that

indicates that contaminants are migrating from the Site at concentrations that may be negatively

impacting Skippack Creek.

Even after PADEP connected the leachate collection system to the POTW in 1999, some

leachate continued to discharge to the Skippack Creek from the NW Valley outfall. From 2000

to 2006, PADEP sampled the Skippack Creek as part of O&M. Stream water was collected at

two locations, upstream (SW4) and downstream (SW5) ofthe observed leachate outfall and was

analyzed for volatile organics, semi-volatile organics, inorganics, pesticides, total PCBs,

coliform and other chemical parameters. Since DEP did not note any discernible difference

between the upstream and downstream samples during sampling, they concluded there was no

ongoing impact from the leachate outfall. PADEP discontinued sampling in 2006. No sediment

samples from the creek were taken.

Landfill Gas Monitoring

In December 2010 and February 2012, PADEP performed sampling of ambient air, gas

vents and groundwater monitoring wells. All the samples were analyzed by PADEP's Bureau of

Laboratories in Harrisburg, PA.

In 2010 and 2012, ambient air sampling was performed at seven locations around the

perimeter ofthe landfill (Summa 1 - Summa 3, Summa 5 - Summa 8) and one location at the

apex ofthe landfill (Summa 4). See Figure 4 for 2012 locations. All ambient air samples were

taken with standard Summa canisters fitted with 8- hour regulators.

In March 2011 and March 2012, PADEP forwarded the data from the sampling events to

EPA in units ofppbv. To enable comparison to the June 2011 Regional Screening Levels

(RSLs), EPA converted detected data to units of ug/m3

. The Regional Screening Levels (RSLs)

are risk-based concentrations derived from standardized equations combining exposure

information assumptions with EPA toxicity data. EPA considers RSLs to be protective for

humans over a lifetime. They are calculated for a Carcinogenic Target Risk oflE-06, and/or a

Noncancer Hazard Index (HI) of 1. Tables 5 and 6 summarize the data from the two sampling

events and compares them to the Regional Screening Levels.

16
Table 5 Summary of Landfill Gas Monitoring, 2010 (mg/m3

)

Summll Summ;l Summ:l Summ3 Summa Summ;z Summ:a Summ;a

RSL If001 1002 1003 '004 1005 M006 11007 .008

An:llvte ug/m3 uglirl3 ualm3 UCI!m3 uglm3 uatm3 ug/m3 ualm3 uaJm3

!>enzene 031 C 0.35 035 0.32 J 0.32 030 J 0.35 0.35 0.35

IOluene 5200 n 0..29 J 0.30 J 0.30 J 0.26 J 0.24 J 0.26 J 0.28 J 0.26 J

Irlcl)lOronuoromelhilne 730 n I.S7 1.57 1.52 1.46 1.51 1.51 157 1.52

dlclllorQdllluoromellk\ne 100 n 2.97 2.97 2.43 1.56 2.62 3.02 3,07 297

chloromelhane 94 n 1.30 1.37 0.91 1.18 1.43 124 1.35

cillUon teu<lchlOrlCle 0.011 c 0.63 J 0.62 J 0.59 J 0.62 J 0.62 J 0.62 J 0.63 J 0.60 J

1.1.2·trlChloro-l.2.2-lrlOuoroelllaoe 31000 n 0.1>9 J 0.70 J 0.601 J 066 J 0.&9 J 0.71 J 0.72 J 070 J

IDrooene 3100 n 091 050 0.16 a.OJ 0.86

Regional Screening Levels (RSLs) are from the June 2011 table.

RSL cancer values (c) are listed at 1E-06 and non-cancer values (n) are listed at a HI =1.

Analyte concentrations flagged with a "J" are estimated values below the laboratory's reporting limit

Very few VOCs were detected in the ambient air. Most ofthe VOCs that were detected

were below the RSLs, however, some ofthe samples had ambient air concentrations of acrolein,

benzene and carbon tetrachloride over their respective RSLs. All ofthe carbon tetrachloride

sample results were flagged with a 'J' because the contaminant was detected at a value below the

laboratory reporting limit and is considered to be estimated.

Table 6 Summary of Landfill Gas Monitoring, 2012 (mg/m3

)

RSL S.01 8-02 S.03 S-64 S-65 S-06 S·07 5-08

Analyte uglm3 ug/m3 U2/m3 U21m3 u2lmJ ull!m3 UItIrn3 u,vm3 ug/m3

Benzene 0.31 c 0.43 0.4] 0.40 0.39 0.49 J 0.44 0.41 0.42

Toluene 5200 n 0.22 J 0.23 J 0.21 J 0.23 J 0.29 J 0.24 J 0.22 J 0.23 1

Acrolein 0.021 n 0.92 0.43 0.57 0.45 0.61 U 0.78 0.50 0.64

Acetone 32000 n 15.46 Q 6.76 or 10.17 Q 7.04 pE 7.13 B 11.76 Q 8.14 Q 13.00 Q

TRlCHLOROFLUOROMETHANE 730 n 1.23 Lt9 1.19 1.20 1.51 1.32 1.26 1.29

DJCKLORODIFLUOROMITTHANl1- 100 n 2.34 2.36 2.34 2.34 2.77 2.38 2.45 2.36

2-Butanone (MEK) 5200 n 2.20 QE 0.89 B 1.46 I) 0.78 B 0.77 JB 1.10 R 0.88 B 2.03 13

Chloromethane 94 n 1.14 1.23 Q 1.25 Q 1.25 Q 1.24 l.ll 1.12 1.10

CARBON TETRACHLORIDE 0.41 c 0.48 J 0.48 J 0.47 1 0.48 J 0.58 J 0.50 J 0.52 J 0.52 J

1,1.2·TRICHLOROTRlfLUOROETHANE 31000 n 0.60 J 0.57 J 0.58 J 0.61 J 2.04 U 0.61 J 0.59 J 0.61 J

Propene 3JOO n 1.09 Q 0.83 1.01 Q 0.84 \.00 1.02 Q 0.85 0.99

RegIonal Screenmg Levels (RSLs) are from the November 2011 table

RSL cancer values (c) are listed at IE-06 and non-cancer values (n) are listed at HI=I

J- indicates an estimated value, below the quantification limit, but above the method detection limit

Q- This flag identifies the average of multiple results from multiple analysis, or the average ofthe averages of duel column

analysis methods.

B-This flag is used when the analyte is found in the associated blank as well as in the sample.

U- Indicates compound was analyzed for but not detected. The sample quantitation limit is reported.

PADEP has sited four air toxic samplers in Montgomery County near the Moyer's

Landfill. The samplers are located in Spring City, Trappe, Collegeville, and Evansburg.

PADEP's Collegeville Area Air Monitoring Project - Third Report, November 17,2009, lists

17
annual average concentrations for VOCs sampled in 2007 and 2008. The report can be found at:

http://www.dep.state.pa.us/dep/deputatelairwaste/aq/toxics/projectslcollegeville/

collegevilleJinal_111709.pdJ Table 7 contains data for benzene and carbon tetrachloride for the

four air toxic monitoring sites as well as the maximum concentrations measured at the Moyer

Landfill.

Table 7

Moyer's Landfill and PADEP Collegeville Area Air Monitoring Project

Sampling Results for Benzene and Carbon Tetrachloride

RSL Moyer's Moyer's Collegeville Evansburg Spring Trappe

(ug/m3

) Landfill Landfill (ug/m3

) (ug/m3) City (ug/m3)

2010 2012 (ug/m3

)

VOC (ug/m3

) (ug/m3

)

benzene 0.31 0.35 0.49J 0.54 0.51 0.57 0.61

carbon 0.41 0.63 J 0.58 J 0.50 0.57 0.50 0.69 tetrachloride

Concentrations of benzene and carbon tetrachloride observed in ambient air at the site

were very similar to those measured at PADEP air monitoring stations in nearby towns

(Collegeville, Evansburg, Spring City and Trappe). This implies that conditions around the

landfill do not differ significantly from the background air quality in this area.

In 2012, acrolein was detected in 7 of 8 ambient air samples at concentrations up to 0.92

ug/m3 and the concentrations in the landfill gas were similar, implying that the acrolein in the

landfill gas is not a significant contributor to the ambient air. Acrolein has not been measured in

the past by PADEP, however, it is a ubiquitous chemical in the ambient air found in all areas of

the country.

Although exceedances ofRSLs were noted for acrolein, benzene, and carbon

tetrachloride, no chemicals were detected in any ambient air samples at concentrations that

would pose an unacceptable risk under a residential exposure scenario. In summary, the results

ofPADEP's sampling ofthe landfill gas vents and perimeter ambient air monitoring at the

Moyer's Landfill show that the landfill gas emissions are not adversely impacting the ambient air

quality.

Gas samples were collected directly from five ofthe passive gas vents. Several chemicals

measured directly at the on-site gas vents exceeded RSLs, sometimes by two orders of

magnitude or more. However, these concentrations are not indicative of exposure under current

land use conditions. Dilution ofthe vent gases appears to be occurring rapidly, as demonstrated

by ambient air samples collected at the landfill.

18
Site Inspection

A key component ofthe five-year review at the Moyer's Landfill Superfund Site is the

physical inspection ofthe landfill cap, the leachate holding tanks, and the leachate collection

system, fence, groundwater monitoring wells and landfill gas vents. The EPA and PADEP

project managers met on January 19,2012 to inspect the site. During the inspection, the weather

was sunny and windy and the temperature was approximately 30° Fahrenheit. The inspection

consisted of walking the landfill cap, inspecting the surface water detention structures, inspecting

the leachate tanks and viewing the perimeter fence.

Inspection ofMoyer's Landfill Superfund Site

For this inspection EPA used the relevant portion ofthe checklist in EPA's Five-Year

Review Guidance. EPA relied on PADEP's institutional knowledge ofthe current operations

and maintenance ofthe site. The following is a list of items identified during inspection:

Fence

• Access hole cut in fence at NE comer. Evidence of vehicular traffic at this spot.

• Approximately Ipm, we saw an all-terrain vehicle on the top ofthe landfill. PADEP

contacted the township to notify them.

• One fence post on the west side ofthe cap was displaced by a fallen tree.

Landfill Cap

• Ponding (frozen) along a few landfill benches indicates minor settlement.

• Some woody growth on the cap. All seem to have trunk diameters ofless than 2."

• No bulges or cracking ofthe cap were evident. No evidence ofslope instability.

• No issues noted with gas vents.

• Vegetative cover appears satisfactory.

Access Roads

• South side access road has erosion, approximately 250' long, with variable width

(maximum 10" wide) and variable depth (maximum 12" deep). The erosion doesn't

appear to be interfering with the remedy.

• North access road has erosion. The erosion doesn't appear to be interfering with the

remedy.

Downslope drains

• Numerous areas of undermining at transition points between bench and downslope drain,

particularly on south side facing the leachate tanks. EPA and PADEP discussed the need

to replace soil and attempt to vegetate during optimal growing times.

• Numerous instances of undercutting the downslope concrete mats.

• Sediment build-up in one eastern downslope drain, which interferes with design flow of

stormwater. EPA and PADEP discussed the need to remove sediment and repair the

19
downslope drain. This appears to be the cause ofthe erosion ofthe south side access

road.

• Sediment build-up in one northern downslope drain, which caused minor ponding

upslope of the drainage structure.

Leachate Collection

• Minor leak in the valve of one leachate tank. Leak could potentially escape secondary

containment via a floor drain near the leachate that was frozen.

On March 23,2012, PADEP reported the following response to several ofthe items

identified during the January 19,2012 inspection:

• The fence was repaired on March 1,2012; as of March 20, 2012, the perimeter fence was

intact.

• The leaking valve was repaired on March 1,2012

• The erosion issues had yet to be addressed, but discussions were underway between

PADEP and their contractor.

Interviews

On January 19,2012, EPA and PADEP met with the Lower Providence Township

representatives (Interim Township Manager Geri Golas, Chairman ofthe Board of Supervisors

Rick Brown, Township Solicitor Mike Sheridan, and Grants/Project Coordinator Casey Snyder)

to discuss the five-year review process and solicit feedback on the Moyer's Landfill Site. The

following topics were discussed:

• Ownership: The Lower Providence representatives voiced a concern with the ownership

ofthe landfill. The township would like to purchase the landfill in order to protect it

from inappropriate use. The township has applied for a solar panel grant with hopes of

installing solar panels on the Site.

• Ordinance: The township also discussed enforcement ofthe local ordinance to protect

the landfill and prevent trespassers. The township committed to letting the police know

about the ordinance and requesting they perform periodic patrol for trespassers.

• Communication: The township appears pleased with the communication about the Site.

They perceive the landfill ,as a non-issue as they are not receiving any complaints about

the landfill.

20
• Discharge: The township asked ifthe discharge is clean enough to send to the Creek

instead ofthe POTW. PADEP replied that while the discharge quantity and contaminant

levels continue to decrease, direct discharge is unlikely at this point.

VII. Technical Assessment

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

The review ofrelevant documents and reports and the site inspection indicate that the

remedy is functioning as intended by the ROD. The landfill cap and drainage structures are

functioning properly with some minor deficiencies, e.g., erosion ofthe road on the South side of

the cap, and minor water pooling on benches. The leachate collection system is being operated

and maintained. The data shows that contaminant levels are generally decreasing.

Institutional controls are currently required by the ROD and implemented by township

ordinance. Site inspections confirm that on-site groundwater is not being consumed; there have

been no earth moving activities on-site not associated with the maintenance ofthe remedy; and

the land use has not changed.

Question B: Are the exposure assumptions, toxicity data, cleanup levels, and RAOs used at the

time ofthe remedy still valid?

Applicable or relevant and appropriate Federal public health or environmental standards

are identified in the ROD. Many ofthese standards were met during construction ofthe remedy

and the remaining standards are being achieved during the operation and maintenance ofthe Site.

While there have been changes in toxicity values and exposure assumptions since the ROD was

issued, these changes do not affect the protectiveness ofthe remedy. The remedy remains

protective.

Question C: Has any other information corne to light that could caU into question the

protectiveness ofthe remedy?

No. The post-construction sump and groundwater sampling has confirmed that the remedy has

reduced surface water and groundwater contamination. Also, EPA has confirmed that the

remedy is not affecting ambient air.

Technical Assessment Summary

The remedy has been constructed in accordance with the requirements ofthe ROD and is

functioning as designed. The immediate threats have been addressed though capping the landfill

and collecting and properly disposing ofthe leachate. Since the Remedial Actions at both

Operable Units are protective, the Site is protective of human health and the environment. Long21
term protectiveness ofthe remedy will be maintained by continuing to perform operation and

maintenance ofthe landfill cap and leachate collection system; monitoring the groundwater and

ambient air; and enforcing the institutional controls.

VIII. Issues

Table 8 Issues Identified

Affects Current Affects Future

Issues Protectiveness Protectiveness

(YIN) (YIN)

Frequent trespassing and damage to the fence. N N

Erosion along drainage bench-downslope drain N N transitions and access roads

IX. Recommendations and Follow-Up Actions

Table 9 Recommendations and Follow-up Actions

Affects

Recommendations Party Oversight Milestone Protectiveness

Issue and Follow-up Responsible Agency Date (YIN) Actions Current Future

Frequent Enforcement of

Township trespassing and Ordinance should Township EPA! Ongoing N N damage to the deter trespassing PADEP

fence and fence cutting

Erosion along

drainage bench- Replace soil and October downslope drain plant grass at PADEP EPA 2012 N N

transitions and optimum time

access roads

22
X. Protectiveness Statement

This second Five-Year Review for Moyer's Landfill finds that the remedy has been

constructed in accordance with the requirements ofthe ROD and is functioning as designed. The

immediate threats have been addressed though capping the landfill and collecting and properly

disposing ofthe leachate. Since the Remedial Actions at both Operable Units are protective, the

Site is protective ofhuman health and the environment. Long-term protectiveness ofthe remedy

will be maintained by continuing to perform operation and maintenance ofthe landfill cap and

leachate collection system; monitoring the groundwater and ambient air; and enforcing the

institutional controls.

XI. Next Review

The next five-year review for the Moyer's Landfill Superfund Site is required by August 2017,

five years from the date ofthis review.

23
References for Moyer's Landfill Superfund Site Five-Year Review

U.S. Environmental Protection Agency, Record ofDecision, Moyer's Landfill Superfund Site,

Collegeville, Montgomery County, Pennsylvania, September 1985.

IMS Engineers Architects, Remedial Investigation - Feasibility Study, Moyer's Landfill Site,

Collegeville, Pennsylvania, January 1986.

Paul C. Rizzo Associates, Inc., Site Maintenance Plan, Moyer's Landfill Superfund Site,

Montgomery County, Pennsylvania, January 1991.

U.S. Army Corps of Engineers, Remedial Action Report, Moyer's Landfill Superfund Site,

Montgomery County, Pennsylvania, December 1996. .

U.S. Environmental Protection Agency, Preliminary Close Out Report, Moyer's Landfill

Superfund Site, Lower Providence Township, Pennsylvania, September 2002.

U.S. Army Corps ofEngineers, Remedial Action Report, Moyer's Landfill Superfund Site,

Montgomery County, Pennsylvania, April 2004.

24
!.

Schuylkill River

Stony Creek

Perkiomen Creek

Skippack Creek

Sawmill Run

Crow Creek

Trout Creek

Mine Run

Plymouth Creek

Valley Creek

Indian Creek

Mingo Creek

Pickering Creek

Crossmans Run

French Creek

I 276

I 476

Egypt

I 76

Main

US Hwy 422

Germantown

Skippack

3rd

Township Line

1st

Trappe

Trooper

Dekalb

Whitehall

Park

Swede

4th

Marshall

Gulph

Nutt

Lewis

Butler

2nd

Burnside

Markley

Gay

State Hwy 23

Allendale

Morris

Elm

New Hope

Conshohocken

State

Fornance

US Hwy 202

Starr

Front

Walton

Bechtel

Collegeville

Black Rock

Rittenhouse

Pothouse

Swedeland

Schuylkill River

Whitehorse

Baptist

Old Arch

Johnson

Fairfield

River

Valley Forge

Fayette

Valley Forge

I 476

I 276

Main

Gulph

Main

I 476

Valley Forge

I 76

US Hwy 422

I 476

I 76

Valley Forge

Map created September 2007

0 0.25 0.5 1 1.5 2 2.5

Miles

 ̄

Legend

Railroads

StreetsGDT

MajorHighwaysGDT

NationalHydrographyDataset

NationalHydrographyDatasetWaterBodies

Parks

States

Moyers Landfill Superfund Site Location Map

!.

Overview Map

Moyers

Landfill

Evansburg State Park

Valley Forge National

Historic Park

P h o e n i x v i l l e P h o e n i x v i l l e

N o r r i s t o w n N o r r i s t o w n

Figure 1
Skippack Creek

Visitation Rd.

Moyer Rd.

Barrington Rd.

Grange Ave.

Map created September 2007

0 105 210 420 630 840Feet

 ̄

Legend

StreetsGDT

NationalHydrographyDataset

NationalHydrographyDatasetWaterBodies

Parks

Moyers Landfill Superfund Site, Site Layout

Evansburg State Park

Figure 2
(

Figure 3 Moyers Landfill

Groundwater Well and Gas Vent Locations

\ .. \

\\ ' \ \\ . ,<\. !J\:l ND;

• G(OTtCHr*e.-.l. ItORlp.tC

(!],,, WAHHClC.

P\."loIf' S'AilQN

• CAS II'OfT

+ (X!1t.ACnOH ""'£U

1BI S(~..c"'(HT ;>u,tt:

nST PH

@J

It!

8 Manhole

Monitoring W,:,li

. Surface Wa!p.f

Figure adapted by US EPA from one

provided by Rust Environment &

Infrastructure Inc.
Moyer Landfill - Summa Canister and Well Locations 

February 21, 2012 and February 28, 2012

Pennsylvania Department of Environmental Protection

Environmental Clean-Up & Brownfields
EPA PUBLIC NOTICE Serfund Site

U.S. Environmental Protection Agency

Reviews Cleanup at Moyers Landfill Site

The U.S. Environmental Protection Agency (EPA) is conducting its second Five-Year Review of the 

Moyers Landfill Superfund Site located in Eagleville, Montgomery County. This review seeks to 

confirm that the cleanup conducted at the site, which included capping the landfill and collecting and 

properly disposing the leachate, continues to be protective of human health and the environment. A 

previous EPA review of the site conducted in 2007 confirmed the remedy was functioning as 

designed. Most recently, institutional controls (restrictions of future use) were put in place to ensure 

the continued, long-term protectiveness of the remedy.

What is an EPA Five-Year Review? 

EPA inspects Superfund sites every five years to ensure that cleanups conducted remain fully 

protective of human health and the environment. These regular reviews, which are required by 

federal law when contaminants remain at a site, include:

 Inspection of the site and cleanup technologies; 

 Review of monitoring data, operating data, and maintenance records, and 

 Determination if any new regulatory requirements have been established since EPA’s 

original cleanup decision was finalized. 

When will EPA’s Five-Year Review Report be available? 

The Five-Year Review report will be finalized and made available online at http://epa.gov/5yr in 

June 2012. 

There are several ways to review information on this site. The Administrative Record (AR), which includes EPA 

decision documents used for selecting the cleanup 

remedy, is available for public review at 

www.epa.gov/arweb and at the Lower Providence 

Township Building. You may also review the AR and 

additional site information at the following locations: 

Lower Providence Township Building

100 Parkland Drive 

Eagleville, PA 19403 

Phone: (610) 539-8020 

EPA Region 3 Public Reading Room

Attn: Paul Van Reed (3HS42) 

1650 Arch Street, 6th floor

Philadelphia, PA 19103 

Phone: (215) 814-3157 (Call to make an appointment) 

David Polish

Community Involvement Coordinator

U.S. EPA Region 3 (3HS52)

1650 Arch Street 

Philadelphia, PA 19103

Phone: (215) 814-3327 or (800) 553-2509

Email: polish.david@epa.gov

Sharon Fang

Remedial Project Manager

U.S. EPA Region 3 (3HS21)

1650 Arch Street 

Philadelphia, PA 19103

Phone: (215) 814-3018 

Email: fang.sharon@epa.gov

 

 

For more information You may also contact

For comprehensive information on the site, please also visit:

www.epa.gov/reg3hwmd/super/sites/PAD980508766/index.htm