THIRD FIVE-YEAR REVIEW REPORT

GEMS LANDFILL SUPERFUND SITE

GLOUCESTER TOWNSHIP, CAMDEN COUNTY, NEW JERSEY

Prepared by

U.S. Environmental Protection Agency

Region 2
New York, New York

Date:

/</
/
Walter E. Mugdan, Director
Emergency and Remedial Response Division

227572
llllllllllllllllllill
THIS PAGE INTENTIONALLY LEFT BLANK
 Table of Contents

Executive Summary i

Five-Year Review Summary Form ii

Introduction . 1

Site Chronology 1

Background........................................... 1
Physical Characteristics 1
Site Geology/Hydrogeology 1
Land and Resource Uses.... ..,.^..,.,.v.,v.).,w......w.v..v...,...w.w.....,.w„....... 2
History of . 2
Initial Response :.. 2
Basisfor Taking Action ..,3

Remedial Actions 3
Remedy Selection 3
Remedy Implementation.....................................................J.,,..........s.... 4
System Operations/Operation and Maintenance ..5

Progress Since the Last Five-Year Review 6

Five-Year Review Process 7

Administrative Components ..........,.,....,.,.,.7
Community Involvement 7
Document Review !, 8
Data Review ! ....8
Site Inspection ,. 10
Interviews . 11

Technical Assessment ,
Question A: Is the remedyfunctioning as intended by the decision documents? 11
Question B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial
action objectives (RAOs) used at the time of the remedy selection still valid? 11
Question C: Has any other information come to light that could call into question the
protectiveness of the remedy? .13
Technical Assessment Summary 13

Issues, Recommendations and Follow-Up Actions ..13

Protectiveness Statement. 15

Next Review 15
Tables
Table 1 - Chronology of Site Events
Table 2 - Data and Information Reviewed in Completing the Five-Year Review

Figures
Figure 1 - Site Map
Figure 2 - Monitoring Well Locations
Figure 3 - VOCs in PM-13
Figure 4 - VOCs in PM-16
Figure 5 - Benzene in PM-19
Figure 6 - VOCs in 102AR
Figure 7 - Benzene in PM-4
 Executive Summary

This is the third five-year review for the GEMS Landfill Superfund site located in Gloucester Township,
Camden County, New Jersey. The purpose of a five-year review is to evaluate the implementation and
performance of a remedy in order to determine if the remedy is and will continue to be protective of
human health and the environment and is functioning as intended by the decision documents. The
triggering action for this policy five-year review is the second five-year review, which was issued in
September 2009.
r '^ " _ -
The site is being addressed as a single operable unit covered by the 1985 Record of Decision. The
remedy has been constructed and is being operated, maintained and monitored in the long-term
operation and maintenance phase.

Based oh this third five-year review, the remedy at the GEMS Landfill Site currently protects human
health and the environment because there is no completed exposure pathway. However, in order for the
remedy to be protective in the long-term, the groundwater plume must be contained. Additional
measures are being investigated and will be designed and implemented, as needed, to ensure long-term
protectiveness.

i
 Five-Year Review Summary Form

SITE IDENTIFICATION

Site Name: GEMS Landfill

EPA ID: NJD980529192

City/County: Gloucester Township, Camden

J Region: 2 State: NJ
County

NPL Status: Final

Multiple OUs? Has the site achieved construction completion?
No Yes

Lead agency: EPA

If "Other Federal Agency" was selected above, enter Agency name: Click here to enter
text
Author name (Federal or State Project Manager): Stephanie Sessoms-Midgett

Author affiliation: Remedial Project Manager, USEPA - Region 2

Review period: 09/2009 - 03/2014

Date of site inspection: September 12,2013

Type of review: Policy
Review number: 3
Triggering action date: 09/22/2009
Due date (fiveyears after triggering action date)'. 09/22/2014

J
 Five-Year Review Summary Form (continued)

Issues/Recommendations

OU(s) without Issues/Recommendations Identified in the Five-Year Review:

N/A
Issues and Recommendations Identified in the Five-Year Review:

OU(s): OU 01 Issue Category: Remedy Performance

Issue: New information since the 2009 five-year review suggests that
> contaminated groundwater at the downgradient end of the plume is not
being captured fully by the groundwater extraction system.
Recommendation Identify and implement additional action(s) to
capture and treat contaminated groundwater at the downgradient end
of the plume, which may include the installation of a horizontal well
proposed by the PRPs, to ensure the long-term effectiveness of the
remedy.
Affect Current Affect Future Implementing Oversight Milestone Date
Protectiveness Protectiveness Party Party
No Yes PRP EPA 08/2015
OU(s): OU 01 Issue Category: Remedy Performance
Issue: New information since the 2009 five-year review suggests that
contaminated groundwater from the site may be flowing below the Holly
Run underdrain and needs to be investigated.
Recommendation Investigate groundwater in the vicinity of the Holly
Run underdrain and identify whether any modifications are needed to
ensure the long-term effectiveness of the remedy.
Affect Current Affect Future Implementing Oversight Milestone Date
Protectiveness Protectiveness Party Party
No ' Yes PRP EPA 08/2015
OU(s): OU 01 Issue Category: Remedy Performance
Issue: The screening level ecological risk assessment indicated the need
for a baseline ecological risk assessment at Holly Run and Briar Lake;
contractor selection has been completed.
Recommendation: Perform a baseline ecological risk assessment for
Holly Run and Briar Lake.
Affect Current Affect Future Implementing Oversight Milestone Date
Proteetiveness Proteetiveness Party Party
No No PRP EPA 08/2015
OU(s): OU 01 Issue Category: Institutional Controls
Issue: There are no deed notices on the landfill property or on the five
adjacent residential properties where components of the remedy are
located and which are within the limits of the Classification Exception
Area established for contaminated groundwater at the site.
Recommendation: Finalize deed notices and engage property owners
for signature and filing.
Affect Current Affect Future Implementing Oversight Milestone Date
Proteetiveness Proteetiveness Party Party
No Yes PRP State 08/2015 '
Site-wide Proteetiveness Statement

Proteetiveness Determination: Addendum Due Date

Short-term Protective (if applicable):
Click here to enter date.
Proteetiveness Statement:
Based on this third five-year review, the remedy at the GEMS Landfill site currently protects
human health and the environment because there is no completed exposure pathway.
However, in order for the remedy to be protective in the long-term, the groundwater plume
must be contained. Additional measures are being investigated and will be designed and
implemented, as needed, to ensure long-term proteetiveness.
 ( •

x GEMS Landfill Superfund Site

Gloucester Township, Camden County, New Jersey
Third Five-Year Review Report

Introduction '

The purpose of a five-year review (FYR) is to evaluate the implementation and performance of a remedy
in order to determine if the remedy is and will continue to be protective of human health and the
environment and is functioning as intended by the decision documents. The methods, findings, and
conclusions of reviews are documented in the FYR. In addition, FYR reports identify any issues found
during the review and document recommendations to address them.
r ''

This is the third five-year review for the GEMS Landfill site located in Gloucester Township, Camden
County, New Jersey. This FYR was conducted by the United States Environmental Protection Agency <
(EPA) Remedial Project Manager (RPM) Stephanie Sessoms-Midgett. The review was conducted in
accordance with the Comprehensive Five-Year Review Guidance, OSWER Directive 9355.7-03B-P
(June 2001). This report will become part of the site file.

The triggering action for this policy review is the completion date of the previous FYR (September 22,
2009). A five-year review is required at this site due to the fact that hazardous substances, pollutants or
contaminants remain at the site above levels that allow for unlimited use and unrestricted exposure. The
site consists of one operable unit and all components of the site remedy are addressed in this FYR.

Site Chronology

See Table 1 for the site chronology.

Background

Physical Characteristics

The GEMS Landfill site is an inactive landfill of approximately 60 acres in Gloucester Township,
Camden County, New Jersey (see Figure 1). The landfill is roughly triangular in shape with an estimated
volume of six million cubic yards. The landfill is situated on tax map Block 14003, Lot 26, with
geographical coordinates of 39 degrees, 46 minutes, 48 seconds north and 75 degrees, 01 minutes, 15
seconds west. Holly Run, an intermittent stream to the north and east of the landfill, discharges to Briar
Lake. The site is bounded by New Brooklyn Road (Erial Road) the north and east, Turnersville-
Hickstown Road to the south and undeveloped land to the west.

Site Geology/Hydrogeology

The surficial aquifer beneath the site is the Kirkwood-Cohansey aquifer system, comprised of the
Tertiary-age Cohansey Formation and the underlying Miocene-age Kirkwood Formation. The Kirkwood-
Cohansey aquifer system is the predominant aquifer in the area, underlying approximately 3,000 square
miles of the New Jersey Coastal Plain, a wedge-shaped mass of unconsolidated sediments of clay, silt,
sand and gravel layers that can extend more than 1,000 feet deep. The underlying Wenonah-Mount
Laurel aquifer is separated from the Kirkwood Formation by the Manasquan-Navasink aquitard.

1
The groundwater of the Cohansey Formation extends to about 50 feet below ground surface. Geologic
samples from well borings at the site indicate that the sands of the Cohansey generally decrease in grain
size with depth, which tends to result in a higher permeability in the upper Cohansey than in the lower
Cohansey. The Cohansey Formation is contaminated with organic and inorganic constituents.
Groundwater in wells screened in the Kirkwood Formation in 2002 did not show any volatile organic
compound (VOC) contamination. The underlying Wenonah-Mount Laurel aquifer was not affected.

Groundwater flow in the Cohansey Formation is predominantly to the northwest A secondary local
component of flow is from the northeast part of the landfill towards the relocated Holly Run and
associated marshy areas.

Land and Resource Uses

The landfill area is zoned industrial and is used solely for purposes of remediation. Holly Run and Briar
Lake are used for recreation. The area surrounding the site is predominantly rural and residential. The
closest residences are approximately 300 feet from the base of the landfill. Residential development is
occurring in the area and is expected to continue in the future.

In 2007, the New Jersey Department of Environmental Protection (NJDEP) expanded the
Classification Exception Area (CEA) for contaminated groundwater in the Kirkwood-Cohansey aquifer
system beneath the site. The most recent CEA biennial certification monitoring report is dated July
2012. NJDEP is seeking to obtain deed notices for properties within the CEA (landfill and five
adjacent properties) and the EPA has been assisting with this effort. Outside the CEA, the Mount
Laurel-Wenonah aquifer system is used for public water supply.

Ecological resources include a federally-listed threatened plant species, swamp pink (Helonias
bullata), which was discovered oh the site in 1994. The EPA coordinates with the U.S Fish and
Wildlife Service regarding this resource.

History of Contamination

The GEMS Landfill has been owned by Gloucester Township from at least the late 1950s to the present.
The landfill was operated by various parties as a disposal site for solid, liquid, and hazardous wastes and
substances. Records indicate that a variety of industrial wastes including asbestos, solvents and Other
materials were disposed of at the site between 1970 and 1979. In 1980, sludge from the City of
Philadelphia's northeast wastewater treatment facility was disposed of at the site. Analyses of the sludge
revealed the presence of pesticides. The landfill stopped accepting waste in 1980.

Initial Response
/ '

In 1980, NJDEP sampling confirmed that private water wells near the landfill, Holly Run and Briar
Lake were contaminated by VOCs. Residents were urged to connect to public water supply systems.
NJDEP also opposed installation of new wells within the affected area. In 1983, the EPA removed
debris from the site and constructed a fence, two culverts and a berm. These response actions helped
prevent residents from coming in contact with wastes in the area and controlled drainage from the site.

2
 ' ( •' , • •

The EPA proposed to add the site to the National Priorities List on December 30,1982. The site was
placed on die NPL on September 8,1983.

Basisfor Taking Action

• / '

In October 1983, the EPA began a federally funded remedial investigation/feasibility study to
characterize the site and evaluate clean-up alternatives. Four natural vents discharging the landfill gases
were found to have significant concentrations ofVOCs including benzene, chlorobenzene and
tetrachloroethene. Samples of leachate seep liquid and soils at the landfill were found to contain
polycyclic aromatic hydrocarbons, including benzo-a-pyrene, as well as trace levels of the pesticides
DDE, DDD and DDT. Groundwater samples collected in the Kirkwood-Cohansey aquifer system were
shown to be contaminated with organics and inorganics. Surface water samples from Holly Run were
contaminated with benzene, chlorobenzene, dichloroethane, acetone and xylene. Contaminants in Holly
Run surface waters were found to be volatilizing into the ambient air, which showed gross organic vapor
levels ranging from 10 to 40 parts per million. In 1985, the EPA performed a focused feasibility study to
evaluate remedial action alternatives for contaminated groundwater impacting Holly Run.

In the July 1985 RI/FS report, cancer risks and noncancerous health hazards were evaluated under
current and future site conditions. The risk assessment concluded that the following posed unacceptable
risks:
• inhalation ofVOCs in ambient air;
• inhalation of organic compounds in landfill gases (also fire and/or explosion hazard);
• ingestion of benzene, 1,2-dichloroethane, 1,1,1-dichloroethene, acrylonitrile,
trichloroethylene chloroform and PCBs in groundwater,
• ingestion, inhalation or dermal exposure to organics in surface water, sediment and
leachate;
• ingestion of benzene, methylene chloride, chloroform, bis(2-chloroethyl)ether, bis(2-
ethylhexyl)phthalate, lead, arsenic, cadmium and chromium from Holly Run; and
• ingestion of contaminated aquatic receptors in Holly Rim and Briar Lake.
\ '

In addition, acute and chronic toxic effects to aquatic biota in Holly Run and Briar Lake were determined
to be likely. ^

Remedial Actions

Remedy Selection
, ' \ •

On September 27, 1985, the EPA issued a Record of Decision that selected the following
remedial action components for the site:
- . a landfill cap consisting of a multimedia cover on the top of the landfill and a clay cap on the
side slopes;
- an active gas collection and treatment system;
- a groundwater extraction and pretreatment system to treat the entire site including the
contamination of Holly Run, with discharge to the publicly owned treatment works;
- remediation of Holly Run and Briar Lake (i.e., sediment excavation);

3
 - surface water controls;
- a monitoring program;
- a security fence;
- relocation and isolation of Holly Run;
- connection of the potentially affected homes to the existing public water supply system; and
- - operation and maintenance to ensure the effectiveness of the remedy.

Remedial action objectives were not listed in the 1985 Record of Decision as is the EPA's current
practice. Nonetheless, a review of the Record of Decision identified the following remedial action
goals, which are considered the remedial action objectives for the site:
- prevent direct contact with, inhalation and ingestion of contaminants by humans and ecological
receptors;
- stop the generation of leachate by preventing landfill waste from contacting groundwater;
- eliminate surface water and sediment contamination in Holly Run and Briar Lake and prevent
recontamination by stopping contaminated groundwater from discharging into Holly Run and
Briar Lake;
- stop the migration of the contaminant plume (plume containment); and
- eliminate the uncontrolled release of VOCs to the atmosphere.

Remedy Implementation

The remedial action was divided into two phases. Phase I addressed all components of the Record of
Decision except those related to the contaminated groundwater and leachate. In August 1988, the EPA
issued a unilateral administrative order to a group of potentially responsible parties known as the GEMS
Trustees for the remedial design/remedial action of the Phase I work. The Phase I remedial design was
completed in December 1988. The Phase I work was constructed from 1989 to 1994. At the landfill, a
galvanized chain-link fence with three-strand barbed wire and four locked gates was installed for
security. The landfill was capped with two feet of clay, a 40-mil high density polyethylene (HDPE) liner,
a one-foot drainage layer, 18 inches of soil cover and six inches of vegetated topsoil. The landfill gas
collection and treatment system was installed with in-waste gas extraction wells, out-of-waSte perimeter
wells, HDPE collection piping, condensate removal tank and traps and an enclosed gas flare system. At
Holly Run and Briar Lake, contaminated sediments were excavated from both locations and Holly Rim
was rerouted. The Holly Run uhderdrain, an 18-inch perforated corrugated HDPE pipe approximately
4,000 feet in length along the northeastern edge of the landfill, was installed below the water table to
prevent contaminated groundwater from discharging into Holly Run and Briar Lake. Upstream of Briar
Lake, culverts were reconstructed to correct drainage problems. A partial fence along Holly Run and
Briar Lake was installed to restrict access to the surface water bodies. The EPA approved the remedial
action completion report for Phase I in 1995.

Phase II of the remedial action addressed the contaminated groundwater and leachate components of
the Record of Decision. In a Consent Decree signed with the EPA on June 30,1997, the GEMS
trustees agreed to perform the remedial design/remedial action and pay past and future costs for
cleaning up the site. The Phase II work was constructed from 1998 to 1999. The leachate collection
system, comprised of a perimeter collection trench, manholes, pump stations and an underground
double-walled steel storage tank, leads to the treatment system on the west side of the landfill.
Treatment consists of pH adjustment, filtration, granular activated carbon treatment and solids

/ 4
removal followed by discharge to the Camden County Municipal Utilities Authority (CCMUA), the
local publicly owned treatment works. The system is designed to treat up to 200 gallons per minute;
Groundwater extraction wells Were installed at the downgradient edge of the landfill and extracted
groundwater is pumped to the treatment facility. The EPA approved the remedial action completion
report for Phase II in 2007.

In 1999, the EPA determined that remedy construction of Phase I and Phase II was complete and issued
a Preliminary Site ClOse-Out Report. From 1999 to 2005, equipment for Solids removal Was Upgraded
and issues were resolved related to discharge requirements and the publicly owned treatment works
accepting treated water with low-levels of radionuclides. Representatives of the EPA, U.S. Army Corps
of Engineers and NJDEP conducted a precertification inspection in July 2005. Also in July 2005, the
EPA determined that the remedy was operational and functional. Since July 2005, the site has been in
the long-term operation and maintenance phase.

System Operations/Operation and Maintenance

Phase I \ <

The GEMS Trustees are responsible for Phase I system operations/operation and maintenance in
accordance with the Phase I Operation and Maintenance (O&M) Plan. In 2004-2005, the cap drainage
system was improved with the installation of new downchutes, rehabilitation of diversion swales,
construction of new berrns and installation of new subsurface drains. In 2006 and again in 2009, the
discharge permit requirements were updated. In 2008, a vapor intrusion evaluation was completed,
which indicated that the concentrations of VOCs, especially trichloroethylene and tetrachloroethylene,
were below groundwater screening levels identified in the EPA's 2002 Draft Guidancefor Evaluating the
Vapor Intrusion to Indoor Air Pathway from Groundwater and Soils. Therefore, further evaluation of this
pathway is not warranted. In 2009,15 new gas collection wells were installed in-waste to improve
operation of the enclosed flare. In 2010, landfill cap repairs were conducted to remove water collecting
on top of the cap and along the mid-slope swale and to regrade the mid-slope swales that experienced
localized erosion. To prevent reoccurrence of the erosion, the Phase I O&M Plan was modified to add
mowing and seeding of swales. In 2011, a new enclosed flare began operating.

Inspections occur on a regular basis to ensure that the perimeter security fence is maintained and that
there are no issues with the landfill cap and landfill gas collection and treatment system.

A swamp pink monitoring plan was approved in 1997 and modified most recently in 2013 in consultation
with U.S. Fish and Wildlife Service. Swamp pink parameters (number of rosettes, number of leaves per
rosette, leaf length) are measured in June along transects in both study and reference locations, and
wetland piezometers measure depth to groundwater. The monitoring results are reported annually, with
the most recent report submitted in August 2013.
\ - *

Phase II -• ' .
f' ' '

The GEMS Trustees are responsible for Phase II system operation/operation and maintenance in
accordance with the 1999 Phase II O&M Plan and the Industrial Discharge Permit issued by CCMUA.

5
In 2006, the extraction well network was reduced from the initial eight wells to the four eastern
extraction wells (EX-1, EX-2, EX-3, EX-4) at the request of U.S Fish and Wildlife Service to help
preserve swamp pink habitat. In 2009, EW-3 and EW-4 were replaced with new extraction wells (20 foot
off-set) due to encrustation that decreased well yield. Regular operation and maintenance includes
methods to help maintain well yield in the extraction wells. A total of 62,3 million gallons of
groundwater were removed and treated during the seventh year of operation and more than 360 million
gallons since startup in July 2005.

The onsite groundwater and Jeachate pretreatment system is operated, maintained and monitored in
accordance with the discharge permit requirements of the CCMUA. Effluent monitoring Water quality
data (consisting of 24-hour composite samples, grab samples, and once per two week samples as well as
continuous flow measurements) are submitted to CCMUA in monthly industrial discharge monitoring
reports. The monthly reports are posted by the GEMS Trustees at http;//www.gemssuperfundsite.org.
There have been no concentrations above any of the discharge parameters since operations began in July
2005. The CCMUA separately analyzes samples of the effluent and conducts annual inspections, and no
deficiencies or violations have been identified.

Groundwater is monitored to the northeast of the landfill along the Holly Run underdrain to evaluate
capture of the VOC-Contaminated groundwater so that it does not migrate under Holly Run. Groundwater
also is monitored to the west of the landfill (sidegradient) and northwest (downgradient) to evaluate
capture of the plume. The monitoring data are discussed in the Data Review section.

Progress Since Last Five-Year Review

The Second five-year review conducted in September 2009 contained the following protectiveness
statements:

• The remedy at GEMS Landfill is expected to be or is protective of human health and the
environment, and in the interim, exposure pathways that could result in unacceptable risks are
being controlled.

• The assessment of the five-year review found that the remedy was constructed in accordance
With the requirements of the Record of Decision. The remedy at the GEMS Landfill Superfund
site is functioning as designed and has been fully implemented with the exception of the on­
going evaluation of the Holly Run and Briar Lake remediation, A few contaminants displayed
elevated levels in sediment of Holly Run and Briar Lake. There is limited sediment available to
the ecological community in Holly Run and Briar Lake and the elevated levels appear to be an
isolated event and most likely do not represent an impact to the protectiveness of the site. The
site is protective in the short term pending further evaluation of the data in the screening level
ecological risk assessment. The remedy in the Record of Decision is protective of human health
and the environment. Measures such as the landfill cap, fencing, use of public water supplies, and
the Classification Exception Area have interrupted potential exposure pathways. The
implementation of the groundwater remedy is functioning as intended and has also reduced
potential exposures in Holly Run and Briar Lake.

6
Recommendations identified in the September 2009 were as follows:

• Obtain NJDEP approval of the site deed notices and file with the township.
• Perform Step 3 of the screening level ecological risk Assessment to evaluate the potential
ecological risk at Briar Lake and Holly Run.

The deed notices for the landfill and five adjacent properties have not been put in place as recommended
in the last five-year review. The EPA is taking a more active role in helping the NJDEP and GEMS
Trustees obtain the deed notices. This five-year review continues to recommend filing of the deed
notices.

The screening level ecological risk assessment Was performed by the EPA in 2010. Based on December
2006 sediment samples from Holly Run and Briar Lake, the screening level ecological risk assessment
concluded that a baseline ecological risk assessment should be performed to evaluate cadmium, iron and
selenium in Holly Run and to evaluate cadmium, arsenic, iron, selenium and zinc in Briar Lake. The
screening level risk assessment concluded that the onsite concentrations of these inorganics are
consistent with background levels; however, data will be collected as part of the baseline ecological risk
assessment to confirm that conclusion. In addition, the baseline ecological risk assessment will analyze
samples using more sensitive detection limits to evaluate whether there is potential ecological risk from
the organic constituents 2,4-dinitrophenol, 4-nitrophenol, hexachloropentadiene, 2-methylphenol and
carbon disulfide, which were identified in the screening level risk assessment as having practical
quantification limits above screening levels. Because these organics have not been identified in other
media as being site-related and all samples Were reported as non-detect, they are considered unlikely to
pose an unacceptable ecological risk; however, the baseline ecological risk assessment will collect
additional data to confirm this. In June 2013, the EPA requested that the GEMS Trustees perform the
baseline ecological risk assessment (steps 3 through 7) for Holly Run and Briar Lake. In August 2013,
the GEMS Trustees informed the EPA in writing that they would perform the assessment. They have
identified a contractor and the baseline ecological risk assessment is in development. This five-year
review continues to identify potential ecological risk as an issue .and recommends completion of foe
baseline ecological risk assessment.

Five-Year Review Process

Administrative Components

The five-year review team included Stephanie Sessoms-Midgett (EPA RPM), Michael Scorca (EPA
Geologist), Marian Olsen (EPA Human Health Risk Assessor), Michael Clemetson (EPA Ecological
Risk Assessor) and Natalie Loney (EPA Community Involvement Coordinator). This is a PRP-lead
site.
J v /•

Community Involvement

The EPA Community Involvement Coordinator for the GEMS Landfill site, Natalie Loney, arranged
to have an announcement published on the Gloucester Township's website (www.glotwp.com) on
December 4,2013, notifying the community of foe initiation of the five-year review process. The
notice indicated that upon completion of foe five-year review, the document Would be available to foe

7
public at the project website, http://www.epa.gov/refflon02/superfimd/npl/0200627c.htmand at the
site repository located as follows:

Gloucester Township Municipal Building

1261 Chews Landing Road (at Hider Lane)
Laurel Springs, New Jersey 08021.

The notice included the RPM's name, address and telephone number for questions related to the five-
year review process of the GEMS Landfill Superfund site. The EPA will inform local public officials
and the community of the results of this five-year review.

Document Review

The documents, data and information that were reviewed in completing this third five-year review are
listed in Table 2.

Data Review

Groundwater Monitoring
Groundwater monitoring has been conducted at the GEMS Landfill site since the 1980s. Groundwater
monitoring is conducted on a semi-annual basis and reported annually. The monitoring well locations are
shown in Figure 2.
i

At the downgradient end of the plume (to the north and northwest of the landfill), monitoring wells PM-
13 and PM-16 are screened in the lower Cohansey Formation. During the past five years, groundwater
samples from these wells have shown elevated but declining concentrations from approximately 200
micrograms per liter (ug/L) to 100 ug/L of benzene, from approximately 950 ug/L to 50 ug/L of
chlorobenzene and from approximately 1,300 ug/L to 50 Ug/L of xylene (Figures 3 and 4).

In 2013, groundwater samples from eight geoprobe borings downgradient of the extraction wells and
performance monitoring wells indicated that VOCs and landfill-related parameters (chloride, sulfate,
ammonia, total dissolved solids, chemical oxygen demand and total organic carbon) are present in the
lower Cohansey about 40 feet below ground surface. Groundwater at one location, CEG-6, also had high
concentrations in shallower intervals. These observations show that contamination in the lower Cohansey
is not being fully captured by the groundwater extraction well network. The GEMS Trustees have
proposed installation of a horizontal well, the addition of which is expected to result in full capture of the
contaminated groundwater at the downgradient end of the plume.

Groundwater samples from well PM-19, which is located to the northeast of the landfill but on the far
side of Holly Run underdrain and is screened in the upper Cohansey Formation, also has shown elevated
but declining concentrations of benzene, ranging from approximately 60 ug/L to 45 ug/L (Figure 5).
However, in the same well cluster at PM-19 on the far side of Holly Rim but screened in the lower
Cohansey, monitoring well 102AR has shown increasing concentrations of benzene, ranging from
approximately 25 ug/L to 50 ug/L, while concentrations of 1,2-dichlorethane and methylene chloride
have been decreasing from approximately 10 ug/L to 1 ug/L and approximately 3 ug/L to 2 Ug/L
respectively (Figure 6).

8
The groundwater data from wells PM-16 and 102AR suggest a potential for contaminated groundwater
in the lower Cohansey to flow beneath the Holly Run underdrain. The effectiveness of the Holly Run
underdrain in capturing contaminated groundwater in the lower Cohansey is not folly understood and is
being further examined.
I
To the west of the landfill, monitoring well PM-4 is screened in the lower Cohansey. It has shown
generally declining concentrations of benzene in foe approximately 2.5 ug/L to 1.5 ug/L range, slightly
elevated compared to the NJGWQC of 1 ug/L.

Levels of arsenic above foe NJGWQC of 3 ug/L have been observed in the upper Cohansey at well PM-
19, but concentrations have shown a decline during the last five years. In the Iowa- Cohansey, elevated
arsenic levels were observed at wells PM-13, PM-16, and 102AR. Wells PM-3 and 102AR are located
within the capture zone and well PM-16 is located outside of the capture zone. Other common inorganic
landfill-leachate related parameters were observed at varying concentrations in samples from the full
site-wide sampling network including iron, aluminum, sodium and manganese as well as sporadic
detections ofberyllium, thallium* barium, cadmium, chromium and lead.

Treatment System Flow Rates

The pumping rates of the four operating extraction wells have decreased with time (possibly due to
encrustration) to a combined flow of less than 8 gallons per minute, which is well below the design rate,
thereby reducing the effectiveness of the remedy. Regular operation and maintenance includes methods
to maintain well yield. In addition, the GEMS Trustees have proposed to install a horizontal well as an
option to mitigate fouling on a more permanent basis.

The flow rate from the Holly Run underdrain is over 100 gallons per minute and is designed to intercept
shallow groundwater in the upper Cohansey at the northeast Side of the landfill.

Surface Water/Sediment
No surface or sediment monitoring is required under the O&M plans. The last sampling was conducted
in 2006 and those data were used in performing the 2010 screening level ecological risk assessment. The
need for any monitoring of surface water or sediment in Holly Run or Briar Lake will be evaluated after
completion of the baseline ecological risk assessment.

Swamn Pink
In 2010, sampling revealed some of the best sampling measurements obtained from the Colony III and
Campus swamp pink colonies, with nearly 70% of the plants determined to be in good health at Colony
III and 60% of the plants in good health at Campus (reference area). However, by the spring of 2013,
these numbers were reduced to approximately 30% and 20% respectively. It should be noted that the
Campus reference area has experienced greater volatility in the health of the individual plants on a year
to year basis.
f

Sampling of the herbaceous layer has not revealed any clear trends in comparing the Campus and Colony
III areas. Sampling completed during the 2012-2013 sampling season indicated a slightly more dense
coverage at the Campus reference area. However, foe previous four years were split evenly between foe
two locations with Colony III having more dense coverage in 2008-2009 and 2011-2012. During this
period, annual percent cover of swamp pink has remained slightly higher at foe Campus reference area.

9
Sampling during the last five years of the woody species comprising the shrub layer, however, has
indicated greater density at Campus reference area throughout the period. Sampling in June 2012
indicated 92.8% shrub layer coverage at Campus, as opposed to 66.9% coverage at Colony III.
Piezometer monitoring has indicated that water level observations at both locations continue to be stable
and quite similar to the measurements obtained during baseline sampling. While there are some
fluctuations at each piezometer, the maximum changes in the wetlands were much less than the
transitions and upland zones, which showed distinct seasonal patterns.

The Consent Decree stipulated that a reduction in monitoring may be warranted if the data suggests. In
December 2012, de maximis, inc., on behalf of the GEMS Trustees, requested several modifications to
the monitoring plan: 1) a cessation of herbaceous/shrub vegetation monitoring activities, based on the
data collected thus far showing little Variation from sampling event to sampling event, and the fear that
monitoring activities themselves could be causing physical harm to individual swamp pink plants; 2) an
end to annual qualitative swamp pink monitoring, which takes place in March of each year, due to their
belief that the effects of herbivory (primarily from white-tail deer) were negatively affecting these
measurements, making them meaiiingless in assessing impacts to Colony in from operation of the
groundwater pump and treat remedy; and 3) an end to monthly piezometer readings, again due to the
potential for impact to individual swamp pink plants while collecting these readings.

After a review of all available information, and in consultation with the U.S. Fish and Wildlife Service,
in July 2013 the EPA determined that the requested modifications were appropriate. Henceforth, all
vegetation monitoring will take place in a single annual sampling event in June that will include
herbaceous and shrub layer monitoring, as well as qualitative and quantitative swamp pink
monitoring.. Also, the frequency of piezometer readings will be decreased to quarterly from monthly.

Monitoring of swamp pink in both the Colony III and Campus locations has shown a general decline in
the health of the populations. However, there has been no indication that groundwater levels in the
colonies are bang affected by operation of the remedy, or that the impacts noted are in any way related
to operation of the remedy.

Site Inspection

The inspection of the site was conducted on September 12,2013. In attendance were RPM Stephanie
Sessoms-Midgett, Michael Clemetson and Michael Scorca, with expertise in risk assessment and
hydrology, respectively. Greg Giles of NJDEP assisted in the review as the representative of
the support agency. William Lee of de maximis, inc. was the representative on behalf of the GEMS
Trustees along with William Soukup of Cornerstone Environmental Group, LLC (consultant
contractor for the GEMS;Trustees).

No significant issues were identified at the time of the inspection regarding the cap, the drainage
structures or the fence. The cap and the surrounding area were undisturbed, and no significant
problems were noted with the gas collection system. No activities were observed that would have
compromised the groundwater CEA or the planned deed notices.

10
Interviews

No interviews were conducted during the FYR process. The EPA has established a community
involvement plan and provides updates to the community as needed. The Mayor of Gloucester
receives the quarterly progress reports directly. In addition, the quarterly progress reports and the
monthly discharge reports are available to the local community and others at
http://www.gemssuperfundsite.org.

Technical Assessment

Question A: Is the remedyfunctioning as intended by the decision documents?

Most components of the remedy are either completed or are being operated, maintained and monitored as
intended by the Record of Decision, including repairs to the landfill cap as needed. The onsite
groundwater and leachate pretreatment system is operated, maintained and monitored in accordance with
the discharge permit requirements. The new flare has been permitted and successfully stack tested. The
security fence is intact.
i

However, the groundwater monitoring well data indicates that the extraction well network is not
capturing the groundwater plume fully in two locations: the downgradient end of the plume to the
north/northwest of the landfill and under the Holly Run underdrain to the east of the landfill. Data
contained in the June 2013 Downgradient Groundwater Investigation Report suggests that contaminated
groundwater may be flowing beneath the Holly Run underdrain:
- Elevated levels of benzene, chlorobenzene and xylene have been observed in the lower Cohansey
(wells PM-13 and PM-16);
- Elevated levels of arsenic have been observed in the upper Cohansey (well PM-19) and in the
lower Cohansey (wells PM-13, PM-16, and 102AR); and
- Elevated levels of benzene have been observed in the upper Cohansey (well PM-19) and,have
been observed to be increasing over the last five years in the lower Cohansey near the Holly Run
underdrain (well 102AR).

The GEMS Trustees have proposed construction of a horizontal well and the EPA is reviewing a work
plan submitted in February 2014.

There is no direct human exposure to contaminated groundwater. All groundwater users are on public
water supply and groundwater use is restricted by a classification exception area at the site. The EPA is
assisting the NJDEP and GEMS Trustees in placing deed restrictions on properties impacted by the site.

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

The exposure assumptions, toxicity data, cleanup levels and remedial action objectives used at the
time of the remedy are still valid, as outlined below. i

11
Soil: The land use considerations and potential exposure pathways in the 1985 Record of Decision are
consistent with the current and anticipated future land uses of the landfill. The remedy included the
capping of the landfill and ongoing maintenance to prevent potential direct contact with the landfill
waste and soils. In addition, the site is surrounded by a fence, two culverts and a berm to prevent and
restrict potential exposures through direct contact with the landfill in the event of trespassing.
Therefore, direct exposures are not expected to occur. There are no significant changes in site use
expected over the next five years. The area surrounding the site is predominatly rural and residential.
Additional residential development is occurring in the area and is expected to continue in the future;
consistent with the 1985 Record of Decision. These development activities do not impact the remedy
at the site. -

Sediments/Surface Water: For potential risks to human health, the exposure assumptions, toxicity
data, cleanup levels and remedial action objectives are still valid. Potential risks to ecological
receptors are being evaluated in a baseline ecological risk assessment, which is under
development. Sediment and surface water data from 2006 was used for the screening level ecological
risk assessment performed in 2010. The screening level ecological risk assessment concluded that a
baseline ecological risk assessment should be performed to evaluate cadmium, iron and selenium in
Holly Run and to evaluate cadmium, arsenic, iron, selenium and zinc in Briar Lake. The screening
level risk assessment concluded that the onsite concentrations of these inorganics are consistent with
background levels; however, data will be collected as part of the baseline ecological risk assessment to
confirm that conclusion. In addition, the baseline ecological risk assessment will analyze samples
using more sensitive detection limits to evaluate whether there is potential ecological risk from die
organic constituents 2,4-dinitrophenol, 4-nitrophenol, hexachloropentadiene, 2-methylphenol and
carbon disulfide, which were identified in the screening level risk assessment as having practical
quantification limits above screening levels. Because these organics have not been identified in other
media as being site-related and all samples were reported as non-detect, they are considered unlikely
to pose an unacceptable ecological risk; however, additional data will be collected to perform the
baseline ecological risk assessment and refine the results of the screening level risk assessment.

Groundwater: The exposure assumptions, toxicity data, cleanup levels and remedial action objectives
used at the time of the remedy are still valid. For this FYR, an evaluation of the direct contact pathway
with site groundwater showed that this is not a completed pathway given all nearby residents are
connected to a public water supply. In addition, a CEA is in place to prevent new water supply wells
from being drilled. The planned deed notices will ensure an additional layer of protection when filed.
The EPA will continue to assist NJDEP and the GEMS Trustees in this effort.

Vapor Intrusion: As discussed in the previous FYR, a vapor intrusion investigation was conducted in
2008 and concentrations in the groundwater were not found to be of concern for vapor intrusion. Site
conditions have not changed, and all of the assumptions used for the previous vapor intrusion
assessment, including land use, remain valid.

In sum, the FYR exposure assumptions and toxicity data were reviewed as part of this FYR and they
remain valid. There have been no changes in the toxicity factors for the contaminants of concern that
were evaluated in the FYR. These assumptions are considered to be conservative and reasonable in
evalutating risk. The remedial action objectives associated with the 1985 Record of Decision are still
valid.

12
 Question C: Has any other information come to light that could call into question the
protectiveness of the remedy?

No information other than that discussed in Question A has come to light that could call into
question the protectiveness of the remedy.

Technical Assessment Summary

Most components of the remedy are either completed or are being operated, maintained and monitored as /
intended by the Record of Decision, with the exception of the groundwater extraction well network
which is not capturing the plume fully at the downgradient end of the plume and under the Holly Rim
underdrain. Further investigation of these two areas is required and modification to the groundwater
extraction system is anticipated.

The exposure assumptions, toxicity data, cleanup levels and remedial action objectives used at the time
of the remedy are still valid. The GEMS Trustees are developing a baseline ecological risk assessment to
characterize risks to ecological receptors at Holly Run and Briar Lake.

In order to address previous recommendations, the EPA will continue to assist NJDEP and the GEMS
Trustees in securing deed notices for the landfill and five adjacent properties.

1 n
Issues, Recommendations and Foliow-Up Actions

ukifiT*Tr(^.W£WTUW<M<I©NSl

« ?w»'9i7. •swwic
1 New information Identify and GEMS EPA August N Y
since the 2009 five- implement Trustees 2015
year review additional action(s)
suggests that to capture and treat
contaminated contaminated
groundwater at the groundwater at the
downgradient end downgradient end
of the plume is not of the plume,
being captured fully which may include
by the groundwater the installation of a
y

extraction system. horizontal well

proposed by the
PRPs, to ensure the
long-term
effectiveness of the
remedy.

13
 iKlilestone-
BRESRONSIBBEl •Egggft v'ErM

1 New information Investigate GEMS EPA August ,N Y

since the 2009 five- groundwater in the Trustees 2015
year review vicinity of the Holly
suggests that Run underdrain and
contaminated' identify whether any
groundwater from modifications are
the site may be needed to ensure the
flowing below the long-term
Holly Run effectiveness of the
underdrain and remedy.
needs to be
investigated.
1 The screening level Perform a baseline GEMS EPA August N N '
ecological risk ecological risk Trustees 2015
assessment assessment for Holly
indicated the need Run and Briar Lake.
for a baseline
ecological risk 1 )
assessment at Holly -

Run and Briar Lake;

contractor selection
has been completed.
1 There are no deed Finalize deed GEMS NJDEP August N Y
notices on the notices and engage Trustees 2015
landfill property or property owners for
on the five adjacent signature and
residential filing.
properties where
components of the
remedy are located
and which are
within the limits of
the CEA.

14
 r

Protectiveness Statement

Site-wide Protectiveness Statement

Protectiveness Determination: Addendum Due Date

Short-term Protective (if applicable):
08/31/2015 j ~ •
Protectiveness Statement:
Based on this third five-year review, the remedy at the GEMS Landfill site currently protects
human health and the environment because there is no completed exposure pathway.
However, in order for the remedy to be protective in the long-term, the groundwater plume
must be contained. Additional measures are being investigated and will be designed and
implemented, as needed, to ensure long-term protectiveness.

Next Review • <- .

The next five-year review for the GEMS Landfill Superfund site is required by five years from the
completion date of this review.

15
Table 1: Chronology of Site Events
Event DATE(S)
NJDEP began testing private water wells in the area for volatile organic January 1980
chemicals
NJDEP expanded its testing to include surface water and found leachate June 1980
contamination in Holly Run and Briar Lake
New Jersey Department of Health and Camden County Health Department April & December
conducted a health survey of the population living near the GEMS Landfill 1982
Site
The EPA initiated actions at the site by installing culverts at the head of Holly February 1983
Rim and by fencing a portion of Holly Run and Briar Lake
GEMS Landfill placed on National Priorities List September 1983
Remedial Investigation and Feasibility Study conducted by the EPA Fall 1983
Focused Feasibility Study conducted by the EPA to identify and evaluate July 1985
remedial action alternatives for groundwater contamination impacting Holly
Run
Record of Decision signed September 27,1985
Interim Remedial Measures performed by NJDEP, including installation of September 1985 -
security fence around the landfill, residential water connections to municipal February 1987
water supply, small scale vapor extraction system, relocation and isolation of
Holly Run and minor soil erosion measures were installed
The EPA issued Unilateral Administrative Order requiring construction of August 1988
Phase I by GEMS Trustees
Phase I Remedial Design completed for NJDEP by TAMS Consultants, Inc. December 1988
Administrative Consent Order signed by responsible parties with the NJDEP January 1989
for the Phase I Construction
Phase I Construction complete r July 1993
Threatened plant species, "Swamp Pink" discovered ofi site July 1994
EPA, NJDEP and Settling Defendants (the GEMS Trustees) and DeMinimis June 27,1997
Settling Defendants lodged a Consent Decree with the federal court to
construct and operate Phase II Remedial Action
Construction completion of Phase II groundwater extraction and onsite pre- April 1999
treatment system with startup schedule for June 1999
Camden County Municipal Utilities Authority issued a permit for discharge May 17,1999
from the pre-treatment system at the site
Based on a study by the United States Geological Survey, CCMUA required May 1999
sampling of the site for radionuclides
Radium and uranium detected in site groundwater at levels higher than June 15,1999
expected background levels. CCMUA issued a cease discharge notice to the
GEMS Trustees to prevent discharge into the CCMUA system.
To assist in characterizing the levels of radionuclides in the groundwater, a April-December
temporary surface water discharge with solids removal was implemented 2002
EPA, NJDEP and CCMUA in discussions Under the auspices of the Federal February 2003 -
Court, to implement the remedy outlined in the Consent Decree. May 11,2005

16
 Table 1: Chronology of Site Events (continued)
First Five-Year Review completed September 2004
First Five-Year Review revised in order to clarify several statements March 2005
CCMUA issued permit to allow discharge of the treated water to the June 2005
Gloucester Township Municipal Utilities Authority sewage system
Extraction, pre-treatment and treatment process systems began operations July 11,2005
Holy Run/Briar Lake sediment sampling conducted December 2006
Vapor intrusion evaluation completed March 2008
Court ordered reduction of non-radionUclides monitoring parameters to once December }7,2008
every two weeks. Gross alpha monitoring reduction to weekly and uranium
only if gross alpha levels exceed the EPA drinking water standards of 15
pCi/L
Second Five-Year Review1started January 2009
Installation of gas extraction wells January 2009
Holy Rim/Briar Lake sediment investigation sampling March 2009
Extraction Wells EX-3 and EX-4 re-drilled June 2009
Second Five-Year Review completed September 2009
The EPA notified of washout on the cover and drainage system that overlay March 18,2010
the protective landfill cap due to heavy rains
GEMS submitted Construction Certification Report with as-built drawings for March 4,2011
landfill cap repairs performed in 2010
GEMS submitted draft Work Plan for groundwater downgradient February 16,2011
investigation for site
Title V permit application for operation of the new flare issued. Flare was September 2012
successfully stack tested j

GEMS submitted Technical Memorandum to the EPA and the USFWS December 20,2012
proposing modifications to the Swamp Pink Monitoring Plan
Seventh Annual Groundwater Progress Report completed April 2013
Third Five-Year Review started June2013
Downgradient Groundwater Investigation Report completed June 4,2013
EPA sends letter to GEMS requesting performance of a Baseline Ecological June 20,2013
Risk Assessment based on the results of the 2010 Screening Level Ecological
Risk Assessment at Briar Lake and Holly Run
Swamp Pink Monitoring reduction approved by the EPA; notification sent to July 24,2013
GEMS Trustees /
Swamp Pink Monitoring Plan Annual Report submitted August 1,2013
The EPA contacted GEMS advising the Trustees to delay implementation of August 1,2013
the horizontal well installation until further review and more detailed
information has been provided
The EPA, NJDEP and GEMS meeting regarding Groundwater Downgradient August 22,2013
Investigation Report and proposal to install horizontal well
GEMS provided written confirmation of their intention to conduct the BERA August 28,2013
requested by the EPA
GEMS submitted supplemental data in connection with the proposed September 8,2013
horizontal well.

17
Table 1: Chronology of Site Events (continued)
Five-Year Review site inspection September 12,2013
Results of Field Demonstration Test of Proposed Horizontal Well submitted October 23,2013
EPA sent letter to GEMS Trustees requesting additional information December 2013
regarding proposal to install the horizontal well
GEMS Trustees submitted Offsite Groundwater Investigation and Horizontal February 9,2014
Well Work Plan
EPA received NJDEP's comments on Offsite Groundwater Investigation and March 18,2014
Horizontal Well Work Plan

18
Table 2: Documents, Data and Information Reviewed in Completing the Five-Year Review
Document Title, Author Submittal Date
Remedial Investigation/Feasibility Study, EPA July 1985
Record of Decision, EPA September 1985
Unilateral Administrative Order, EPA August 1988
Consent Decree, USDOJ June 1997
First Five-Year Review, EPA September 2004
Second Five-Year Review, EPA September 2009
Technical Memo, GEMS Trustees April 2010
Screening Level Ecological Risk Assessment, GEMS Trustees September 2010
Seventh Annual Groundwater Report, GEMS Trustees September 2012
Downgradient Groundwater Investigation Report, GEMS Trustees June 2013
Swamp Pink Monitoring Plan-Quarterly Reports, de maximus, inc. for April 2013 &
GEMS Trustees August 2013
Power Point Presentation on Groundwater Investigation, GEMS Trustees August 2013
Supplemental Data - Design Basis for Proposed Horizontal Well at the September 2013
GEMS Landfill, GEMS Trustees

19
Figure 1: Site Map

20
Figure 2: Monitoring Well Locations

VOC Exceedances of Groundwater Quality Criteria

m2

North

21
Figure 3: VOCs in PM-13

VOCs in PM-13 -m~ 3h*ye*enr'

« </*•«
2 00

a
iS.
2 •00

£y
u&
1 00 —

&> & & vo v<»

„<S •>
^ O- -A
J *>* J

.aji • • > Cta

<jT \ \ .
\ CORNERSTONE
ef , 111
H I « r l « < « | (J f •« f

22
Figure 4: VOCs in PM-16

VOCs 111 PM-16

» . <iL. ' * * • » «

3000 -7

2300 f

i M'JJ
9

1500

IOCO t-

50C I*

S* •>. "V o
^f J <r jr

Dfjt
-hs
J' SO*
s.
CORNERSTONE
e I• 0 Uimmf, ELI.

23
Figure 5: Benzene in PM-19

Benzene in PM-19 V »l«tf *kn

-r

A
JSt
n.
- £ t .

I
.A
V / \
\ / \
\/ \
c

4 /\
\
©
u •
.

4C I -V- J \ >"

•
*

O xV
lp J? jf J?
<* ^

Dm

J' ••
H • •> tffrcORNfcRSIONL

24
Figure 6: VOCs in 102AR

VOCs 111 102AR i X- Ciirj- —

J
*
t
i

^ •

•A1 i -;v <4

* 4* V* S
Oat*
vv?^ *. • Xv j .
Mj* * X,

e
- x •'
>. J*: COKNtRSTONK
1•tint r>>« U>tt», I I t

25
Figure 7: Benzene in PM-4

Benzene 111 PM-4

3:

|
75 I—
I .1
W

06 ~t
0 J- x o- o>
f f ./ J / / s /

?-*• »
« N
V

e
*<»
VJ*
a
V

..
• \
X CORNERSTONE
. ttl icii r | Uimi. LLC

26