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SUPERFUND PRELIMINARY SUE CLOSE OUT REPORTfor the

LONG-TERM REMEDIAL ACTIONat the

CLEBURN STREET WELL SUPERFUND SITE

GRAND ISLAND, NEBRASKA

PREPARED BY:

U.S. ENVIRONMENTAL PROTECTION AGENCY

REGION VH

KANSAS CITY, KANSAS

AUGUST 2004

40161772

SUPERFUND RECORDS

1.0 INTRODUCTION

This Preliminary Close Out Report documents that the U.S. Environmental Protection

Agency (EPA) completed construction activities at Operable Units (OUs) 1 through 5 at the

Cleburn Street Well Superfund Site in accordance with the Close Out Procedures for National

Priorities List Sites guidance, Office of Solid Waste and Emergency Response Directive 9320.2-

09A-P, January 2000. EPA and the Nebraska Department of Environmental Quality (NDEQ)

conducted a final inspection of the facilities at OUS on June 30, 2004 and determined that the

responsible party - Union Pacific Railroad (UPRR) - has substantially constructed the remedy for

OUS in accordance with the remedial design plans and specifications. After certification that a

small number of minor items had been addressed, the EPA issued a construction completed letter

on August 9, 2004. This is the last OU to be constructed. This constitutes a construction

complete for the site.

The remediation facilities for OU1 and OU2 were completed in August 1998 and were

constructed per the March 9, 1998 approved contract documents developed by EPA (Start-

up/Semi-annual Performance Report, Cleburn Street Site Operable Units 1 & 2, Revision 1,

Sverdrup Environmental, Inc., September 15, 1999). The pre-final inspection for OU1 and OU2

was performed on November 3, 1998 by EPA. A punch list of deficient and outstanding items

was prepared and the items were corrected by the remediation contractor (Interim remedial Action

Report, Cleburn Street Site Operable Units 1 & 2, Revision J, Sverdrup Environmental Inc.,

December 28, 1999).

The remediation activities for OU3 and OU4 were completed with installation ofgroundwater monitoring wells between March 31, 1998 and April 7, 1998. According to theMarch 23, 1999 Final Remedial Action Report for OU3 and OU4 (Sverdrup Environmental, Inc.,

1998) the monitoring wells were installed in accordance with the project planning documents. No

major instances of deviation or non-compliance were noted.

2.0 SUMMARY OF SITE CONDITIONS

2.1 Background Information

The Cleburn Street Well Superfund Site is located in Grand Island, Hall County, Nebraska

and is located approximately two miles north of the Wood River and approximately seven miles

1

northeast of the Platte River. The Cleburn Street Well site encompasses approximately 144 city

blocks in the downtown area and is surrounded by a variety of light industries, commercial

businesses, and residential dwellings. The Site consists of a former municipal water supply well,the Cleburn Street Well, and surrounding groundwater and soils containing volatile organic

compounds (VOCs), primarily tetrachloroethylene (PCE). Results of the remedial investigation

(RI) (Sverdrup Environmental, Inc.,1993) indicated there were four separate source areas

including three dry cleaning facilities and a former solvents distribution facility.

The Cleburn Street Well Superfund site consists of five operable units. OU1 consists of

the subsurface soil at the One Hour Martinizing facility; OU2 consists of the groundwater at the

One Hour Martinizing facility; OU3 consists of the Liberty Cleaners; OU4 consists of the Ideal

Cleaners; and OU5 consists of the former Nebraska Solvent Company facilities. The Nebraska

Solvent Company facilities were located on property owned by the UPRR. One Hour Martinizing

and Nebraska Solvents Company are no longer in business.

The Cleburn Street OU1 and OU2 facilities are located at the southwest corner of 4th Street

and Eddy Street. Cleburn Street OU 3 and OU4, the Liberty Cleaners and the Ideal Cleaners, are

located at the northwest corner of 8th Street and Eddy Street and the southeast corner of 1st Street

and Cedar Street, respectively. Cleburn Street OU5 is located at an area generally bounded by

North Front and South Front Streets from Lincoln Street northwesterly for approximately eight

hundred and fifty feet.

A Record of Decision (ROD) was prepared in April 1996, that addressed only the three dry

cleaning source areas (OU1-4). A ROD was prepared in September 2001 that addressed theformer solvents distribution facility (OU5).

The OU5 site consists of the west parcel and the east parcel. The west parcel was leased

by the Nebraska Solvent Company from 1936 to 1973 for above ground tank storage and

distribution of organic solvents, including PCE, for industrial use, primarily in the dry cleaning

industry. Prior to 1973, bulk petroleum storage tanks, which stored other solvent cleaning

materials, were located at the west parcel. The west parcel occupies an area approximately 75 feet

by 175 feet just south of the Thompson Company grocery distribution facility and is leased by

Toba, Inc., of Grand Island. The parcel is currently unoccupied and is composed of soil fill with

no asphalt or concrete paving.

The east parcel was leased by the Nebraska Solvent Company until 1973 for warehousing,

handling, truck loading and other activities associated with cleaning solvents distribution, mostly

in drums. The east parcel occupies an area approximately 100 feet by 125 feet. It is currently

leased by the City of Grand Island's Street Department. It now consists of a maintenance office

building, a small sign shop and paved maintenance yard.

PCE was first detected in the drinking water wells of Grand Island, Nebraska in April

1984, by the Nebraska Department of Health (NDOH). In 1986, NDOH found low levels of PCE

in the Lincoln Street Well, which is located in the immediate area of OU5. In March 1986, the

NDOH detected PCE at a concentration of 21.9 micrograms per liter (ug/L) in the Cleburn Street

Well. The NDOH re-sampled the well in April 1986, following a citizen's complaint of poor taste

and odor in the municipal drinking water, and confirmed the presence of PCE at a concentration

of 26.9 ug/L. The Cleburn Street Well was subsequently closed for drinking water purposes. The

Lincoln street well was plugged and abandoned in 1999.

In September 1988, the EPA conducted a soil-gas survey over a large area of downtown

Grand Island and discovered that PCE existed in the soils at the Cleburn Street Well Site. Based

on the findings of the soil gas survey and previous sampling events, the Cleburn Street Well Site

was proposed for the National Priorities List on July 29, 1991. Listing of the Cleburn Street Well

Site was finalized on October 14, 1992.

A remedial investigation of the site was initiated by EPA in September 1991. Phase I field

sampling activities occurred in May/June 1992 and Phase n activities in November 1992. The RI

Report, including a Baseline Risk Assessment, was prepared and submitted to EPA in May 1993(Sverdrup Environmental, Inc., 1993). Phase in field sampling activities occurred in April 1993,to delineate the extent of contamination detected in the previous phases, with an emphasis on the

former One Hour Martinizing source area (OU1 and OU2). Phase I and Phase n of the RI

included a partial characterization of the Nebraska Solvents facility area (OU5).

The UPRR, under EPA oversight via an Administrative Order of Consent, completed the"Remedial Investigation Site Characterization Summary Report, Former Nebraska Solvent Site -

OU5, Cleburn Street Well Superfund Site, Grand Island, Nebraska" (TheroRetec, 1999) in July

1998. The RI confirmed and defined the source, magnitude, and locations of the contamination in

both the soil and groundwater at OU5. A feasibility study (FS) was completed in 2000. In

addition to the RI and FS, UPRR also completed a pilot study in the west parcel to substantiate the

effectiveness of a soil vapor extraction (SVE) system to remove contamination from the soil.

The geology is consistent across the site and is comprised of silty sands to a depth of

approximately 90 feet below ground. This zone comprises the single aquifer (water-bearing) unit

in the vicinity of the site and serves as the source of municipal drinking water for the residents ofGrand Island. Depth to groundwater averages between 18-22 feet below ground surface. Depth to

the clay aquitard unit was encountered between 87 feet and 94 feet below ground surface.

Groundwater flow in the vicinity of the site is in a northeasterly direction.

Chemical analysis of soil samples collected from soil borings and monitoring well borings

indicated the presence of PCE, trichloroethylene (TCE), and compounds commonly associated as

potential degradation products of PCE, including 1,2-dichloroethylene (DCE) and 1,1,1-

trichloroethane, at each of the operable units. Other compounds commonly associated as potential

minor degradation products, 1,1-dichloroethylene, and 1,1,2-trichloroethane were also detected.

PCE is the primary contaminant of concern and was detected at all of the source areas.

The highest concentration of PCE (9,200,000 micrograms per kilogram {ug/kg}) was detected in

a soil sample collected from the former One Hour Martinizing source area (OU1). Soil samples

collected from the Liberty and Ideal Cleaners source areas (OU3 and OU4) contained PCE

concentrations up to 110 ug/kg and 270 ug/kg, respectively. Soils from the surface to a depth of

20 feet in the west parcel of OU5 contained PCE concentrations ranging from 3,900,000 to

840,000 ug/kg. Likewise, over the same depths, TCE ranged from 39,000 to 2,900 ug/kg and cis-

DCE 23,000 to 2,700 ug/kg. In the east parcel of OU5, over the same depths from in soil, PCE

concentrations were found to range from 420 to 81 ug/kg, TCE from 440 to 28 ug/kg, and cis-

DCE from 110 to 38 ug/kg.

PCE was detected at concentrations exceeding the maximum contaminant level (MCL) ingroundwater samples collected from each of the operable units. The highest concentration of PCE

(170,000 ug/L) was detected in the groundwater sample collected from OU2 source area.

Compounds commonly associated with the natural degradation of PCE in the environment such as

TCE, 1,2-DCE and 1,1,1 -trichloroethane were also detected in the groundwater samples from

OU2 at maximum concentrations of 410 ug/L, 85 ug/L, and 540 ug/L, respectively. Groundwater

at Liberty Cleaners (OU3) and Ideal Cleaners (OU4) was contaminated to a lesser degree than

OU2. The highest PCE concentrations detected at OU3 and OU4 were 65 ug/L and 95 ug/L,

respectively.

PCE was found in the groundwater at OU5 at concentrations of up to 5,000 ug/L in the

west parcel and 1,600 ug/L in the east parcel. TCE was detected in the groundwater at

concentrations of up to 76 ug/L in the west parcel and 100 ug/L in the east parcel. Cis-DCE was

detected in the groundwater at concentrations of up to 11,000 ug/L in the west parcel and 390

ug/L in the east parcel.

2.2 Remedial Construction Activities

A ROD for OU1, OU2, OU3, and OU4 was issued in June 1996. The selected remedy for

the One Hour Martinizing source area (OU1 and OU2) included:

• Monitoring of groundwater, discharge of treated water and air emissions;

• Institutional controls to restrict groundwater use;

• Extraction of subsurface contaminants using soil vapor extraction;

• Treatment of extracted soil vapors by carbon adsorption;• Extraction of groundwater containing contaminants above MCLs for 20 years; and

• Treatment of extracted groundwater by onsite air stripping for 20 years.

The selected remedy for the Liberty Cleaners (OU3) and Ideal Cleaners (OU4) included:

• Construction of groundwater monitoring wells;

• Groundwater monitoring for 10 years (natural attenuation);

• Institutional controls to restrict groundwater use; and

• Soil vapor extraction and treatment as a contingency.

The EPA issued a ROD for the Nebraska Solvents source area (OU5) on September 10,2001. The selected remedy included:

• Construction of a SVE system and air sparging system;

• Groundwater monitoring;

• LNAPL removal from the groundwater by bailing; and

• Institutional controls in the form of deed restrictions to prohibit groundwater use

and improper subsurface construction on the UPRR properties.

Health based performance standards specified in the ROD for the One Hour Martinizing,

Liberty Cleaners, and Ideal Cleaners include attainment of MCLs for the primary contaminants of

concern in the groundwater. Health based performance standards specified in the ROD for the

soil and groundwater at the Nebraska Solvents source area include:

Constituent

1,1,1 - Trichloroethane

1,1 - Dichloroethene

1,2,4 - Trimethylbenzene

1,3,5 - Trimethylbenzene

Benzene

Cis-1,2 - Dichloroethene

Ethylbenzene

Methylene chloride

Tetrachloroethene

Toluene

Trans- 1 ,2-dichloroethene

Trichloroethene

Vinyl chloride

Xylenes

Soil (mg/kg)

28.1

0.0006

11.1

6.9

0.2

3.2

43.2

0.37

0.656

75.5

3.6

0.17

0.12

None

Groundwater (ug/L)

210

0.1

None

None

5

70

700

12.1

5

1,000

100

5

2

10,000

2.2.1 Operable Units 1 and 2

The remedial design for OU1 and OU2 was completed and approved by EPA in

September 1997 (Sverdrup Environmental, Inc., 1993). The design for OU1 included plans and

specifications for the installation of a SVE and treatment system utilizing an existing SVE process

skid with carbon canisters. The design for OU2 included plans and specifications for the

demolition and reconstruction of a portion of the existing building foundation, construction of a

pre-engineered building, and installation of a 100 gallon per minute groundwater extraction and

treatment system. A vendor-supplied air stripping unit was utilized for OU2.

The EPA's contractor prepared a bid package that included plans and specifications for the

remedial action at OU1 and OU2. The procurement was advertised and the remedial action

contractor was selected. Construction began in March 1998, and was completed in August 1998.

The SVE system and groundwater extraction system were constructed per the March 9, 1998

conformed contract documents. EPA completed a pre-final inspection of the facilities on

November 3, 1999. Remaining activities at the OU1 and OU2 sites include continued operation

of the SVE system and the groundwater extraction and treatment facilities.

The NDEQ is responsible for operation and maintenance of the OU1 SVE. The SVE

system has not been operated since late September 2002. The NDEQ installed soil borings at

OU1 during the spring of 2004 to determine if the soils met the remediation goals and is planning

to restart the system in the near future.

The EPA has operated the OU2 groundwater extraction and treatment system since July

2000. VOC concentrations, including PCE and TCE, in the OU2 groundwater monitoring wells,

extraction wells, and Cleburn Street Well, which is not currently being used for drinking water

purposes, continue to exceed MCLs.

2.2.2 Operable Units 3 and 4

Two additional groundwater monitoring wells were constructed at both OU3 and OU4.

There were two existing groundwater monitoring wells at each operable unit. The installation and

development of the wells was performed during the period from March 31 to April 7, 1998.

Monitoring wells 1C and ID were installed at OU3 and monitoring wells 4C and 4D were

installed at OU4. Monitoring well 1C is approximately 28 feet deep and screened from 13.5 feet

below ground surface (bgs) to the bottom of the well. Monitoring well ID is approximately 88

feet deep and screened from 78 feet bgs to the bottom. Monitoring well 4C is approximately 32.5

feet deep and screened from 17.5 feet bgs to the bottom of the well. Monitoring well 4D is

approximately 95 feet deep and screened from 85 feet bgs to the bottom of the well.

The EPA's contractor sampled the four wells at each of the operable units for VOCs on a

quarterly basis from April 1998 through July 1999. Responsibility for sampling of these wells has

been transferred to the NDEQ. The University of Nebraska at Kearney, under a cooperative

agreement with NDEQ, sampled the monitoring wells for VOCs on a semi-annual basis through

October 2002.

The PCE concentrations at OU3 decreased from a maximum of 77 ug/L in March 2000 to

concentrations between 15 ug/L in MW-1A and 26 ug/L in MW-1C during the October 2002

sampling event. PCE concentrations at OU4 steadily decreased from 13 ug/L in March 2000 to

less than 2 ug/L (detection limit) in October 2002. From September 2001 through October 2002,

all of the VOCs in groundwater samples at OU4 have been below MCLs.

2.2.3 Operable Unit 5

The UPRR managed the design and construction of the soil and groundwater treatment

facilities at OU5. The soil remedy, construction of a SVE system, was managed in two phases.

Phase 1 of the SVE system was constructed as part of a SVE treatability study and consisted oftwo extraction wells, piping, an air compressor, a vacuum blower, an oil / water separator,

activated carbon filter, coalescing / particulate filter, and a blower building. The extraction wells

were installed in June 1999 and the remaining Phase 1 facilities were constructed in November

1999. Phase 2 consisted of the addition of five new SVE wells (four in the west parcel and one in

the east parcel), the associated piping, sixteen [16] air sparging wells, a temporary building, an air

compressor, a thermal oxidizer [short term], two [2] granulated activated carbon filters [long

term], control and gaging network, and the associated hardware. The remedial design for the

remainder of the SVE system in the east and west parcels and the air sparging system was

submitted in July 2003 and was approved by EPA in January 2004. UPRR's consultant prepared

a bid package that included plans and specifications for the remedial action. A remedial action

contractor was selected and began construction in April 2004. Construction, including meshing of

the two phases of the remedial action at OU5, was completed in June 2004. The EPA conducted

site visits during April 13 and 14, 2004; May 5 and 6, 2004; May 17, 2004; May 18 and 19, 2004;

and June 3, 2004 to observe the installation of the SVE system and the air sparging system ({four

reports} Black & Veatch, 2004).

A final inspection of the SVE system and the air sparging system was performed on

June 30, 2004. The EPA determined that the SVE system and the air sparging systems had been

constructed substantially in accordance with the plans and specifications and a three (3) itempunch list was developed and submitted to the UPRR for action. Participants who performed the

final inspection included Dr. Brian Zurbucken of NDEQ; David Sanders of Black & Veatch; Mike

Mason of the Forrester Group; Cliff Hillin of Geotechnical Services, Inc.; and Glenn Curtis and

John Cook of the EPA. Because the construction was so near complete, it was decided that an on-

site final inspection was not required. In place of that inspection it was decided by EPA that a

letter from the UPRR, certifying that all three of the punch list items had been properly addressed,

would suffice for the on-site final inspection of the facilities. In an August 9, 2004 letter to

UPRR, the EPA accepted the construction of the SVE system and the air sparging system.

3.0 DEMONSTRATION OF CLEAN-UP ACTIVITY QA/QC

At OU1 and OU2, EPA developed a Construction Quality Assurance Plan (CQAP) dated

September 16, 1997, as part of the Final Remedial Design Report for OU1 and OU2 (Sverdrup

Environmental, Inc., 1997). The CQAP addressed both the SVE system and the air stripping

system. The EPA provided oversight during construction of the facilities (Sverdrup

Environmental, Inc., 1997). All construction appeared to have been completed in accordance with

the ROD. The approved plans and specifications and any minor variations were approved by the

EPA.

The EPA installed groundwater monitoring wells MW-1C and MW-1D at OU3 and MW-

4C and MW-4D at OU4. According to the March 23, 1999, Final Remedial Action Report for

OU3 and OU4 (Sverdrup Environmental, 1999), compliance with the project planning documents

was achieved. No major instances of deviation or non-compliance were noted.

UPRR's consultant submitted a CQAP as part of the final design documents for both the

SVE system and the air sparging system at OU5. UPRR's consultant also provided oversight

during the construction of the facilities. The CQAP was used throughout the construction

activities. Site QA/QC audits were provided by UPRR's consultant. In addition, oversight visits

were conducted on four [4] occasions during April through June of 2004 to observe the progress

of the work and trip oversight reports ({four reports} Black & Veatch, 2004) were filed. All

construction appeared to have been completed in accordance with the ROD and the approved

plans and specifications. Accordingly, the work was approved by the EPA.

4.0 ACTIVITIES AND SCHEDULE FOR SITE COMPLETION

Pre-final and final inspections were completed for the SVE system and the groundwater

extraction and treatment facilities at OU1 and OU2. The NDEQ is responsible for the operation

and maintenance of the OU1 SVE. The SVE system has not operated since September 2002. The

NDEQ installed soil borings at the OU1 site during the spring of 2004 to determine if the soils

met the remediation goals.

The EPA has performed operation and maintenance of the facilities at OU2 since July

2000 and performs quarterly monitoring of the groundwater monitoring wells, the influent to the

air stripping unit, and the effluent from the air stripping unit ({multiple reports} Black & Veatch,

2002 - 2004). Quarterly monitoring reports have been submitted to the EPA through April 2004

and are scheduled to continue through June 2005 when EPA's current contract ends. A new

contract to continue this effort will be instituted at that time.

A pre-fmal inspection was performed for both the SVE system and the air sparging system

at OU5. The EPA, in a letter dated August 8, 2004, accepted as complete the construction of the

SVE system and the air sparging system at OU5.

The following activities and associated schedule are estimated for the life of the project.

ACTIVITY

NDEQ will continue to sample the SVE and air sparging

wells at OU1

EPA will continue to sample the groundwater monitoringwells, and the influent and effluent from the air stripping

unit at OU2.

NDEQ will continue to sample monitoring groundwater

wells at OU3 and OU4

UPRR will perform performance monitoring of the influent

and exhaust from the SVE air treatment facilities at OU5.

UPRR will perform monitoring of the in-situ vapor

monitoring points and SVE wells at OU5.

UPRR will perform ambient air sampling at the site forVOCs at OU5.

UPRR will sample total flow from the knockout tank atOU5.

UPRR will sample groundwater monitoring wells at OU5.

EPA will review data from the SVE system and the air

sparging system at OU5 to determine if confirmation

sampling of soil may proceed at OU5 and whether eitherthe SVE systems or groundwater systems may be shut

down.

SCHEDULE

Quarterly

Quarterly

Quarterly

Weekly until the system is shut

down

Quarterly until the system is shut

down

Quarterly until the system is shutdown

Weekly until the system is shutdown

Quarterly

Ongoing

10

EPA will review data from the SVE system and the air

stripping units at OU1 and OU2, the groundwater

monitoring wells at OU2 to determine if the remedial

action at OU1 and OU2 are completed.

EPA will review data from the groundwater monitoring

wells to determine that the remedial action at OU3 and

OU4 are completed.

UPRR notifies EPA and NDEQ that the remedial action

work is completed at OU5.

EPA and NDEQ conduct an inspection at OU5 in response

to the RA completion notification.

EPA produces and signs final close-out report for OU5.

EPA performed the first 5-year review.

EPA will perform the second 5-year review .

Ongoing

Ongoing

Tentatively July 2005

Tentatively August 2005

Tentatively September 2005

September 2003

September 2008

The schedule listed above is based upon the assumption that the SVE system and the air

sparging system as designed for OU5 will achieve the soil and groundwater cleanup goals within a

one [1 yr.] year period after construction is completed. It is possible that the SVE and air sparging

systems could take longer to reach the cleanup goals. In that event, the systems will continue to

operate or EPA, NDEQ, and UPRR will discuss the options required to modify the remedy, as

needed, to achieve the remedial action objectives as expeditiously as practicable.

5.0 SUMMARY OF REMEDIATION COSTS

The costs associated with the remediation of the Cleburn Street Well Site are shown

below.

CATEGORY

Total Capital Costs of SVE and AirStripping Systems at OU1

Annual O&M costs of SVE and AirStripping Systems for OU1

Total Capital Costs of groundwaterpumping and monitoring at OU2

COST ESTIMATE ($)

$74,478'

$87,848'

$370,072'

ACTUAL COST

$69,6833

$82,0627

$364,2493

11

Annual O&M costs of groundwater

pumping and monitoring OU2

Total Capital Costs of OU3 and OU4

Annual O&M costs for OU3 and OU4

Total Capital Costs of SVE and Air

Sparging Systems for OU5

Annual O&M Costs of SVE and Air

Sparging Systems for OU5

$150,0743

$101,600'

$38,464'

$421,2542

$218,8382

$89,9685

$85,072"

$12,1057

$431,9506

Not yet available

1 Source: June 1996 Record of Decision.2 Source: September 2001 Record of Decision.3 Source: Interim Remedial Action Report, Cleburn Street Site, Operable Units 1 & 2; December 28, 1999.4 Source: Final Remedial Action Report, Cleburn Street Site, Operable units 3 & 4, March 23, 1999.5 Source: B&V RAC Invoices 2000 - 2004 (Average report cost for last four [4 yrs.] years).6 Source: UPRR Internal Construction Analysis 2004.7 Source: Cooperative Agreement Between NDEQ and University of Nebraska - Kearney 12-15-99

VI. FIVE- YEAR REVIEW

Section 121 (c) of the Comprehensive Environmental Response, Compensation, and

Liability Act (CERCLA), as amended, and Section 300.430(f)(4)(ii) of the National Contingency

Plan (NCP) require that periodic reviews (at least once every five years) be conducted for sites

where hazardous substances, pollutants, or contaminants remain at the site above levels that allow

for unlimited use or unrestricted exposure following the completion of all remedial actions for thesite. This type of five-year review is referred to as a statutory review.

The first five year review for the Cleburn Street Well was completed on September 30,

2003. The second five year review will be due in September 2008.

Cecil

Director

Superfund Division

Date

12