riverfront superfund site new haven, missouri i · riverfront superfund site new haven, missouri ....

I I I Five-Year Review Report

I Riverfront Superfund Site

New Haven, Missouri

I I I I I

N ovem ber 2009

I I Region 7

United States Environmental Protection Agency

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Approved by:

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Superl-tma-Oivis"ion Director

I U.S. EPA, Region 7

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Kansas City, Kansas

II h%~ DatI: 7

30059971

11111111111111111111111111111111111111111111111111 Superfund

I I RIVERFRONT SUPERFUND SITE

FIVE-YEAR REVIEW REPORT

Executive Summary

I A Five Year Review (FYR) has been completed at the Riverfront Site in New Haven, Missouri.

This is the first five year review at the site.

I In \986, the Missouri Department of Natural Resources (MDNR) began testing public-supply

I wells in the state for volatile organic compounds (VOCs) and detected the chlorinated solvent

tetrachloroethene (peE) in New Haven city wells W \ and W2. As a result of numerous

I investigations, six Operable Units (OUs) have been identified as sources of contamination. The

six OUs are identi(ied as:

I OU \: Front Street Site OU2: Kellwood Site OU3: City Dump

I OU4: Maiden Lane Area OU5: Old Hat Factory OU6: Domestic Wells

I I Time critical removal actions have occurred at OU \, OU4, and OU6. Remedies have been

selected and implemented for OU I, OU3, and OU5. A remedy has been recently selected for

OU4, but a remedial action has not begun. This review was conducted from June 2009 through

October 2009.

I OUI (Front Street)

I The OU I 2003 ROD called for a combination of institutional controls to restrict exposure to the

I shallow aquifer and soil contamination, proprietary controls, an environmental covenant and

easement, installation of an Advanced Remedial Technology '(ART) well and associated

I equipment, and extension of the monitoring well network to monitor the plume. Institutional

controls are in place. The OU I remedy was declared to be Operational and Functional (O&F) on

I November 2,2005. The remedial system has operated approximately 73 percent of the time

since initial start up. If the EPA and MDNR conclude that the ART well system is to keep

operating into the State-lead "Operational & Maintenance" phase, the EPA will ensure the I ,

system is functioning properly and operating as designed, before that transition occurs. The

I groundwater pump in the ART system has not been functional for the past year. Therefore if the

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RIVERFRONT SUPERFUND SITE FIVE-YEAR REVIEW REPORT

I ART well is to remain operational, installation of a new pneumatic groun?water pump is.

recommended. All groundwater concentrations are below the Alternate Concentration Levels

I (ACLs) established from site monitoring results indicating that the system is meeting the

performance goals. However, the performance of the ART well is greatly impacted by the

I groundwater elevation, which varies depending on the stage of the nearby Missouri River.

Therefore if the ART well is to remain operational, a remedy optimization study should be

I considered to determine if such activities such as installation of additional instrumentation will

improve the operations and effectiveness of the ART well.

I The 2003 ROD acknowledged ongoing vapor intrusion studies. Initial results from the two

I residences downgradient ofOU I were inconclusive. Research for this Five Year Review (FYR)

located data from the second round of indoor air samples conducted in July 2003 and email

correspondence regarding a meeting conducted in August 2003 to evaluate the results. These

have not been formally documented. The conclusions of the meeting were that the high PCE

I concentration detected initially in the basement of one of residences was the result of indoor

sources, such as cleaning solutions, dry cleaning, or other household products. Data from the

I second residence repeatedly showed no PCE contamination. The team recommended that no

emergency existed at the residence and there was no need to remediate at the time. It also

I recommended additional sampling for a year to evaluate seasonal variations. The follow-on

vapor intrusion studies and team meeting conclusions have not been formally documented.

I OU2 (Kellwood Industries)

I The Remediallnvestigation/Feasibility Study (RIIFS) for OU2 is ongoing; hence, a remedy for

OU2 has yet to be selected. However, OU2 is within an area already protected by an

I institutional control which restricts future well installations.

I OU3 (City Dump)

I The OU3 remedy is functioning as intended. Monitoring of the landfill monitoring wells, surface

seep and nearby domestic wells is occurring per the requirements of the 2003 ROD. Institutional

controls have been implemented at OU3 to enhance the protectiveness of the remedy. The

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I institutional controls restrict installation of wells within the OU3 boundary and within 300 feet

(ft) of the dump.

I The 2003 ROD specified that ifPCE concentrations in groundwater samples remained below the

I maximum contaminant level' (MCL) of 5 J.lg /L after the conclusion of I year of quarterly

sampling, sampling would be reduced to every 5 years. Because PCE was not detected above the

I MCL during the 2003-2004 quarterly monitoring, sampling decreased to once every 5 years.

Groundwater was sampled in May 2008. None of the May 2008 samples from monitoring wells,

I an onsite seep, or nearby domestic wells contained detectable quantities of PCE or other volatile

contaminants of concern listed in the 2003 ROD. However, antimony and boron have previously

I been determined as potential human-health risks. Based on the 2008 sampling, no substantial

changes in water quality have been observed in monitoring wells, seep, or domestic well

samples, and groundwater quality near OU3 appears stable and relatively unchanged.

I OU4 (Maiden Lane Area)

I The 2009 ROD for OU4 (Maiden Lane Area) was just recently issued and the remedy for OU4

has not been implemented. Therefore, any conclusions regarding remedy protectiveness would

I be premature. However, OU4 is within an area already protected by an institutional control

which restricts future well installations.

I I OU5 (Old Hat Factory)

The OU5 2006 ROD documented that while the groundwater below OU5 was contaminated, the

I risk could be addressed with institutional controls and monitoring. Institutional controls are in

place and groundwater monitoring is ongoing. The remedy was determined to be operational

I and functional in May 2009 and post-ROD groundwater monitoring is occurring.

I I The maximum contaminant level (MeL) is the maximum permissible level ofa contaminant in water which is

I delivered to the free-flowing outlet of the ultimate user ofa public water system. MCLs are promulgated by EPA pursuant to the Safe Drinking Water Act, 42 U.S.c. §§300j-26 and are codified at 40 CFR Part 141.

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OU6 (Domestic Wells)

I The RemediallnvestigationfFeasibility Study (RIfFS) for OU6 is ongoing with OU2, hence; a

remedy for OU6 has yet to be selected. However, OU6 is within an area already protected by an

I institutional control which restricts future well installations.

I PROTECTIVENESS STATEMENTS

I The remedies at OU I, OU3 and OU5 are protective of human health and the environment due to

the use of institutional controls will eliminate exposure pathways for the short and long term.

I The 2009 ROD for OU4 was just recently signed and the remedy for OU4 has not been

I implemented. However, OU4 is within an area already protected by an institutional control

which restricts future well installations.

I The RIfFS for OU2 and OU6 is ongoing; hence, a remedy has yet to be selected. However, OU2

I and OU6 are within an area already protected by an institutional control which restricts future

well installations.

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Table of Contents

I Section

I Executive SUlnmary ................................................................................................................... ES-I List of Acronyms ........................................................................................................................... iii Five-Year Review SUlnmary Form ................................................................................................ vi

I 1.0 Introduction ........................................................................................................................ 1 2.0 Site Chronology ..................................................................................................................3

I 3.0 Background ........................................................................................................................6 3.1 Site Name, Location, and Description ...........................................................................6 3.2 Land and Resource Use .................................................................................................7

I 3.2.1 OU I (Front Street) ..........................................................................................7 3.2.2 OU2 (Kellwood Industries) .............................................................................8 3.2.3 OU3 (Old City Dump) ....................................................................................9

I 3.2.4 OU4 (Maiden Lane Area) ............................................................................. 10 3.2.5 OU5 (Old Hat Factory) ................................................................................. 11 3.2.6 OU6 (Domestic Wells) ................................................................................. 12

I 3.3 Site History and Enforcement Activities ..................................................................... 12 3.4 Basis for Taking Action ...............................................................................................20

4.0 Remedial Actions .............................................................................................................22

I 4.1 Operable Unit I (Front Street) ....................................................................................22

4.1.1 Remedial Action Objectives (OU I ) ..............................................................22 4.1.2 Remedy Selection (OU I) ............................................................................. .25 4.1.3 Remedy Implementation (OU I) ................................................................... 27

I 4.1.4 Operational and Functional Activities (OU I) .............................................. .28 4.1.5 Institutional Controls (OU I) .........................................................................30

4.2 Operable Unit 2 (Kellwood Industries) ....................................................................... 30

I 4.3 Operable Unit 3 (Old City Dump) ..............................................................................30 4.3.1 Remedial Action Objectives (OU3) ..............................................................30 4.3.2 Remedy Selection (OU3) ..............................................................................30

I 4.3.3 Remedy Implementation (OU3) ......................... : ......................................... 32 4.3.4 Institutional Controls (OU3) ......................................................................... 34

4.4 Operable Unit 4 (Maiden Lane Area) .........................................................................35

I 4.4.1 Remedial Action Objectives (OU4) ..............................................................35 4.4.2 Remedy Selection (OU4) ..............................................................................36 4.4.3 Remedy Implementation (OU4) ...................................................................38

I 4.4.4 Institutional Controls (OU4) ........................................................................ .38 4.5 Operable Unit 5 (Old Hat Factory) .............................................................................39

4.5.1 Remedial Action Objectives (OU5) ..............................................................39

I 4.5.2 Remedy Selection (OU5) ..............................................................................39 4.5.3 Remedy Implementation (OU5) ........ : ......................................................... .40 4.5.4 Institutional Controls (OU5) ........................................................................ .40

I 4.6 Operable Unit 6 (Kellwood Industries) ...................................................................... .41

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I 5.0 Progress Since Last Review.............................................................................................42 6.0 Five-Year Review Process ...............................................................................................43

6.1 Administrative Components ....................................................................................... .43

I 6.2 Community Involvement .............................................................................................43 6.3 Document Revie\v ........................................................................................................43 6.4 Data Review .................................................................................................................45 6.5 Site Inspection .............................................................................................................. 46

I 6.6 Interviews .....................................................................................................................46 7.0 Technical Assessment ...................................................................................................... 48

7.1 Operable Unit I (Front Street)

I Question A ............................................................................................................ 50 Question B ............................................................................................................. 5 I

.............................................................................................................54Question C

I 7.2 Operable Unit 2 (Kellwood Industries} ....................................................................... 55 7.3 Operable Unit 3 (Old City Dump)

I Question A ............................................................................................................55 Question B .............................................................................................................57 Question C .............................................................................................................59

7.4 Operable Unit 4 (Maiden Lane Area) ........................................................... : ............. 60

I 7.5 Operable Unit 5 (Old Hat Factory) Question A ............................................................................................................60

I Question B .............................................................................................................62 Question C .............................................................................................................64

7.6 Operable Unit 6 (Domestic Wells) .............................................................................65 7.7 Technical Assessment Summary ................................................................................65

I 8.0 Issues .................................................................................................................................68 9.0 Recommendations and Follow-up Actions .......................................................... : ......... 69 10.0 Protectiveness Statements ...............................................................................................70 11.0 Next Review ......................................................................................................................71

I Tables Table I:

I Table 2: Table 3: Table 4:

I Figures Figure I:

I Figure 2: Figure 3:

Chronology of Site Events (Page 3) Site Chronology for Individual OUs (Page 4) Issues (Page 68) Recommendations and Follow-Up Actions (Page 69)

Site Location Special Area 3 ART Well

I Attachments

I Attachment I: Site Inspection Photographs Attachment 2: Site Inspection Checklists and Inspection Rosters Attachment 3: Groundwater Data

I II

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List of Acronyms

I ACL AOC

I ARP ART AS

I bgl

I bgs btoc

CalEPA

I CALM CD CERCLA cis-DCE

I COC COPC

I CSR CT·

I OAF DNAPL DO

I EPA EPC ERA

I ESI ESV

I FS FSP FYR

I gpm

HHRA

I IC

I IDA IWA

I LTM LTRA

I I

Alternate Concentrations Level Administrative Order on Consent American Recreation Products, Inc. Advanced Remediation Technology Air Sparge

below ground level below ground surface below top of casing

California Environmental Protection Agency Cleanup Levels for Missouri Consent Decree Comprehensive Environmental Response, Compensation, and Liability Act cis-I,2-Dichloroethene Chemical of Concern Chemical of Potential Concern Code of (Missouri) State Regulations Carbon Tetrachloride

Dilution Attenuation Factor Dense Non-Aqueous Phase Liquid Dissolved Oxygen

(United States) Environmental Protection Agency Exposure Point Concentration Ecological Risk Assessment Expanded Site Investigation Ecological Screening Values

Feasibility Study Field Sampling Plan Five Year Review

Gallons per minute

Human Health Risk Assessment

Institutional Controls Industrial Development Authority of the City of New Haven In-Well Aeration

Long-Term Monitoring Long-Tenn Response Action

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List of Acronyms (continued)

I I MCL

MDNR MRBCA MSL

I NCP NHMC NPDWS

I NPL

O&F

I O&M ORP OU

I PAH PCE

I PP PPA ppbv

I PRG PRP PVC

I QA/QC

RAGS

I RAO RI RME

I ROD ROI RP

I RSL RSMo RV RWI

I SVE

I TBC TCE

I I I

Maximum Contaminant Level Missouri Department of Natural Resources Missouri Risk Based Corrective Action Mean Seal Level

National Contingency Plan New Haven Manufacturing Company National Primary Drinking Water Standards National Priority List

Operational and Functional Operations and Maintenance Oxidation-Reduction Potential Operable Unit

Polynuclear Aromatic Hydrocarbons Tetrach loroethene Proposed Plan Prospective Purchaser Agreement parts per billion by volume Preliminary Remediation Goal Potentially Responsible Party Polyvinyl Chloride

Quality Assurance/Quality Control

Risk Assessment Guidance for Superfund Remedial Action Objectives Remedial Investigation Reasonable Maximum Exposure Record of Decision Radius-Of-Influence Responsible Party (EPA) Regional Screening Level Missouri Revised Statutes Recreational Vehicle Residential Well Investigation

Soil Vapor Extraction

To-Be-Considered Trichloroethene

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List of Acronyms (continued)

I Ilg/kg Ilg/L

I USACE USGS

I VC VOC

I I I I I I I I I I I I I I

micrograms per kilogram micrograms per liter

United States Army Corps of Engineers United States Geological Survey

Vinyl Chloride Volatile Organic Compound

cubic yard

V



Five-Year Review Summary Form

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,"''ITE I DENT!FICA TION I

Site name (from WasteLAN): Riverfront

EPA ID (/i'om WasteLAN): MOD981720246

Remediation status (choose all that apply): X Under Construction X Operating 0 Complete

Site Wide FYR 0 YES .y NO Construction completion date:

EPA 0 State 0 Tribe 0 Other Federal Agency

Author name: Jeff Field

Author title: Remedial Project Manager Author affiliation: U.S. EPA Region 7

Review period: 06101/2009 to 11/30/2009

Date(s) of site inspection: 06/23/2009

Type of review: Statutory o Policy

.y Post-SARA 0 Pre-SARA o NPL-Removal only o Non-NPL Remedial Action Site o NPL State/Tribe-lead o Regional Discretion

Review number: I (first) 0 2 (second) 0 3 (third) 0 Other (specify)

Triggering action: .y Actual RA Onsite Construction at OU# I o Actual RA Start o Construction Completion o Previous Five-Year Review Report

o Other (speci fy)

Triggering action date (from WasteLAN): 11/09/2004

Due date (five years after triggering action date): 11/09/2009

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Issues:

OU I Issues: I. Previous removal actions and the ongoing ART well have made an impact on the plume. However, the

groundwater tluctuations intluence the overall effectiveness of the system. 2. The groundwater pump in the ART system has not been functional for the past year. 3. The results of follow-on vapor intrusion studies discussed in the ROD need to be formally documented.

OU3 Issues: 1. No written easements with adjacent property owners for access to monitoring wells and sampled private

wells are in place and access continues to be through verbal agreement.

Recommendations and Follow-up Actions:

OU I Recommendations:

I. If the EPA and MDNR conclude that the ART well system is to keep operating into the State-lead "Operational & Maintenance" phase, the EPA will ensure the system is functioning properly and operating as designed, before that transition occurs. Therefore if the ART well is to remain operational, a remedy optimization study should be considered to determine if such activities such as installation of additional instrumentation will improve the operations and effectiveness of the ART well.

2. If the EPA and MDNR conclude that the ART well must be kept operational when MDNR assumes operations and maintenance of OU I, installation of a new pneumatic groundwater pump is recommended.

3. The results of the follow-up vapor intrusion study not formally documented for the public record.

OU3 Recommendations:

I. Obtain access agreements or easements for future well sampling required by the ROD.

Protectiveness Statement(s):

The remedies at OU I, OU3 and OUS currently protect human health and the environment due to the use of institutional controls which eliminate the primary exposure pathway of ingestion.

The ROD for OU4 was just recently signed and the remedy for OU4 has not been implemented. Therefore, any conclusions regarding remedy protectiveness would be premature.

Remedies for OU2 and OU6 have not been selected.

Other Comments: The OUS ROD calls for sampling bi-annually (twice per year) for the first and second years and then annually for the next three years to provide data during the first five-year review for OUS. After the first five-year review, monitoring efforts would then be scaled back to one sampling round every five years to provide a current data set for the next five-year review. The timing of the L TRA sampling events has changed such that the first semi-annual sampling event was conducted in Fall 2008. In lieu of making any premature changes to the ROD, the 2007 L TRA Field Sampling Plan and Quality Assurance Project Plan should be followed until the 2nd FYR and then monitoring efforts be scaled back to annual if data indicates this is appropriate. In accordance with the ROD, increases in groundwater contaminant levels, migration of groundwater contamination off-site, and/or identification of new sources ofOU5 groundwater contamination could result in the implementation of additional remedial actions.

VII



1.0 Introduction

I The purpose of Five Year Reviews is to determine whether the remedy at a site is protective of

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

I 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.

I The United States Environmental Protection Agency (EPA) is preparing this five-year review

I pursuant to the Comprehensive Environmental Response, Compensation, and Liability Act

(CERCLA) Section 121 (c) and the National Contingency Plan (NCP). CERCLA § 121 (c) states:

I If the President selects a remedial action that results in any hazardous substances, pollutants, or

I contaminants remaining at the site. the President shall review such remedial action no less often

than each five years ajier the initiation o.fsuch remedial action to assure that human health and

I the environment are being protected by the remedial action being implemented. In addition. (f

upon such review it is the judgment o.f the President that action is appropriate at such site in

I accordance with section [l04J or [106]. the President shall take or require such action. The

I President shall report to the Congress a list o.ffacilitiesfor which such review is required, the

results ofall such reviews, and any actions taken as a result ofsuch reviews.

I EPA interpreted this requirement further in the NCP; 40 CFR § 300.430(f)(4)(ii) states:

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

remaining at the site above levels that allow for unlimited use and unrestricted exposure, the

I lead agency shall review such action no less often than everyfive years after the initiation ofthe

selected remedial action.

I EPA Region 7 has conducted a five-year review ofthe remedial actions implemented at the

Riverfront Superfund site located in New Haven, Missouri. The site is comprised of six OUs.

I See Figure I.

I I I



The six operable units are identified as:

I OU I: Front Street OU2: Kellwood Site OU3: City Dump

I OU4: Maiden Lane Area OUS: Old Hat Factory OU6: Domestic Wells

I Time critical removal actions have occurred at OU I, OU4, and OU6. Remedies have been

I selected and implemented for OU I, OU3, and OUS. A remedy has been recently selected for

.OU4, but a remedial action has not begun. This review was conducted from June 2009 through

November 2009. This report documents the results of the review.

I This is the first five-year review for the Riverfront Superfund Site. The triggering action for this

I review is the beginning of the start of remedial construction at OU I which was in November

2004. The five-year review is required because hazardous substances, pollutants, or

I contaminants remain on the site above levels that allow for unlimited use and unrestricted

exposure. This FYR is evaluating human health and environmental protectiveness of the

I remedies for OUs 1,3, and 5. A discussion of the other three OUs without remedies in place are

described.

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2.0 Site Chronology

I A chronology of significant site events and dates is provided in the tables below:

Table 1: Chronology of Site Events


OU EVENT DATE Site Wide Contamination Discovered PWS-l PWS-2 1986 Site Wide Preliminary Assessment Completed 1988 Site Wide Site Investigation Completed 1989 Site Wide Expanded Site Inspection Completed 1994 02 PRP Removal Action Completed 1994 02 PRP Monitoring Agreement Established 1995 01 Information Repository Established 11/17/1999 Site Wide Hazard Ranking System Package Completed 2000 01 Remedial Investigation/Feasibility Study Completed 6/2000 03 Remedial Investigation/Feasibility Study Completed 6/2000 Site Wide Proposal to Place on National Priorities List Prepared 7/27/2000 01 Emergency Removal Action Completed 9/2000 Site wide NPL Listing 10/2000 Site Wide Expanded Site Investigation/Remedial Investigation Completed 9/2001 01 Feasibility Study Completed 2002 05 Pre-Remedial Investigation Completed 2002 05 RI Initiated 2002 06 PRP Emergency Removal Began 11/2001 06 Administrative Order of Consent Finalized 5/2002 03 Focused Remedial Investigation Report Completed 1/2003 01 Focused Remedial Investigation Report Completed 1/2003 01 Feasibility Study Report Completed 9/2003 01 Public Meeting Held 7/29/2003 03 Feasibility Study Report Completed 9/2003 01 Record of Decision Finalized 9/2003 03 Record of Decision Finalized 9/2003 01 Consent Agreement Finalized 3/2004 06 PRP Remedial Investigation/Feasibility Study Began 3116/2004 02 PRP Remedial Investigation/Feasibility Study Began 3/16/2004 Site Wide Information Repository Established 7/2004 02 Residential Well Investigation Completed 7/2004 03 Remedial Design Completed 8/2004 01 Remedial Design Completed 9/2004 01 Construction Started (ART well) 11/2004 01 Construction Completed (ART well) 2/2005 01 ART Remedial System Startup 6/02/2005 01 System Operational and Functional (ART well) 11/2005 03 Information Repository Established 9/2006 05 Information Repository Established 11/2006

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05 RIIFS Completed 12/2006 05 Record of Decision Finalized 12/2006 01 Final Long Term Remedial Action Field Sampling Plan

Completed 3/2007

01 Interim Remedial Action Report Completed 6/2007 05 Remedial Action Completed 9/28/2007 04 Removal Action Completed 4/2008 04 RIIFS Completed 12/2008 04 Record of Decision Finalized 3/2009 05 System Operational and Functional 5/2009 03 PRP Remedial Action Competed 7/2009 03 Operation and Maintenance Ongoing 01 Long-Term Remedial Action (L TRA) Ongoing 04 Remedial Design Ongoing

Table 2: Site Chronology for Individual OUs

I I I I

OU EVENT DATE Site Wide Contamination Discovered PWS-I PWS-2 1986 Site Wide Preliminary Assessment Completed 1988 Site Wide Site Investigation Completed 1989 Site Wide Expanded Site Insp_ection Completed 1994 Site Wide Hazard Ranking System Package Com21eted 1999-2000 Site Wide Proposal to Place on National Priorities List Prepared 7/27/2000 Site Wide Listing National Priority List 10/2000 Site Wide Expanded Site Investigation/Remedial Investigation Completed 9/2001 Site Wide Information Repository Established 7/2004

I I I I I I I I

01 Information Repository Established 11/17/1999 01 Remedial Investigation/Feasibility Study Completed 6/2000 01 Emergency Removal Action Completed 9/2000 01 Focused Remedial Investigation Report Completed 1/2003 01 Feasibility Study Report Completed 9/2003 01 Public Meeting Held 7/29/2003 01 Record of Decision Finalized 9/2003 01 Consent Agreement Finalized 3/2004 01 Remedial Design Complete 9/2004 01 Construction Started (ART well) 11/2004 01 Construction Completed (ART well) 2/2005 01 ART Remedial System Startup 6/02/2005 01 System Operational and Functional (ART well) 11/2005 01 Final Long Term Remedial Action Field Sampling Plan Completed 3/2007 01 Interim Remedial Action Report Completed 6/2007 01 Long-Term Remedial Action Ongoing

4

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02 PRP Removal Action Completed 1994 02 PRP Monitoring Agreement Established 1995 02 PRP Remedial Investigation/Feasibility Study Began 3/16/2004 02 Residential Well Investigation Completed 7/2004

I I I I I

03 Remedial Investigation/Feasibility Study Completed 6/2000 03 Focused Remedial Investigation Report Completed 1/2003 03 Feasibility Study Report Completed 9/2003 03 Record of Decision Finalized 9/2003 03 Remedial Design Completed 8/2004 03 Information Repository Established 9/2006 03 PRP Remedial Action Completed 7/2009 03 Operation and Maintenance Ongoing

04 Removal Action Completed 4/2008 04 Remedial Investigation/Feasibility Study Completed 12/2008 04 Record of Decision Finalized 3/2009 04 Remedial Design Ongoing

I I I I I I I I I I I

05 Pre-RI Investigation Completed 2002 05 RI Initiated 2002 05 Information Repository Established 11/2006 05 Remedial Investigation/Feasibility Study Completed 12/2006 05 Record of Decision Finalized 12/2006 05 Remedial Design Completed 12/06/2007 05 Remedial Action Completed 01/30/2008 05 System Operational and Functional 5/2009

06 PRP Emergency Removal Completed 3/2002 06 Administrative Order of Consent Finalized 5/2002 06 PRP Remedial Investigation/Feasibility Study Began 3/16/2004

5



3.0 Background

I 3.1 Site Name, Location, and Description

I The Riverfront Site (CERCLIS # M098 I 720246) is located in New Haven, Missouri (population

I 1,867), along the southern bank of the Missouri River in Franklin County, about 50 miles west of

St. Louis, Missouri. The principal road in the city is State Highway 100, which runs along part

I of an east-west trending ridge about I mile south of the Missouri River (Figure I). The ridge

forms a topographic divide between the Missouri River valley to the north and the BoeufCreek

I valley to the south. The downtown business district is located within a narrow strip of

floodplain and consists of several small shops and restaurants, a few homes, and several small,

old manufacturing facilities. This area of New Haven is surrounded by a flood protection levee

that is maintained by the United States Army Corps of Engineers (USACE). Land use north of

I the State Highway 100, including the downtown area, is mostly residential and light commercial,

and land use outside the city is mostly pasture with some row crops. An industrial park

I (developed in the mid-1970s) containing several large manufacturing facilities is located south of

this ridge and State Highway 100.

I There are two major aquifers in the New Haven Area; the Ozark aquifer and the Missouri River

I alluvial aquifer. Both are used extensively in Missouri; however, in the New Haven area, the

Ozark aquifer is the primary aquifer for domestic, industrial, and public water use. The Missouri

I River alluvial aquifer in the New Haven area contains high concentrations of iron and manganese

and is not used for water supply. The Ozark aquifer is a thick sequence of water-bearing

I dolostone, limestone, and sandstone formations ranging in age from Late Cambrian to Middle

Devonian. Although these units collectively are a regional aquifer, the water-yielding capacity

I of the various individual units is variable. Yields of200 to 1,000 gallons per minute (gpm) are

not unusual for the lower zones in the area.

I During 1986, the Missouri Department of Natural Resources (MDNR) began testing public

I supply wells in the state for VOCs and detected the chlorinated solvent tetrachloroethene (PCE)

in New Haven city wells W I and W2. As a result of numerous investigations, six OUs have

I been identified as sources of contamination.

I 6

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3.2 Land and Resource Use

I 3.2.1 OUI (Front Street)

Land Use:

I The site is located in the eastern part of downtown New Haven. The site was used tor

commercial industrial activities from the 1950s through the 1970s. The area is currently zoned

I commercial. The site is surrounded by residential and commercial property, a parking lot, the

levee and Missouri River to the north, a sanitary sewer lagoon to the east, and a vacant

I lot/commercial property to the west. The reasonably anticipated future land use is greenspace or

park and additional parking spaces.

I I

Groundwater Use:

Groundwater at OU I is from the Missouri River alluvial aquifer. Depth to water ranges from 8

I to 28 feet (ft), and is directly related to the Missouri River stages. The groundwater flow is

generally to the north, toward the Missouri River, at a velocity of between 35 and 60 feet per

I year; however, the flow is highly dependent on the Missouri River water stages; thus, during

high river levels, groundwater flow can reverse directions and flow south. The water contains

I high concentrations of iron and manganese and is considered a non-drinking water aquifer in this

area. There is no surface water at OU I.

I Institutional controls; implemented in layers, were placed at the site. These include a deed

I restriction, Prospective Purchaser Agreement (PPA) which requires: I) only use the site for

surficial uses, 2) not conduct any activities which would disturb contaminated soils, and 3) not

place any well that would penetrate groundwater. In addition to the deed restriction, MDNR

placed a restriction on drilling new wells in the area, and the City of New Haven has a restriction

I which controls subsurface excavations, borings, or wells within 500 feet of the flood control

levee. All ofOU I is within the Special Area 3 as designated by the State of Missouri which

I requires that the MDNR be consulted before construction of a new well. See Figure 2 for the

boundaries for Special Area 3. The MDNR will provide specific guidance on well drilling

I protocol and construction specitications on a case-by-case basis. The MDNR will provide

written approval for all new wells prior to construction. These restrictions will remain with the

I property to prevent future exposure to groundwater.

I 7

I



3.2.2 OU2 (Kellwood Industries>

I Land Use:

OU2 is located in New Haven, Missouri. OU2 includes the historic operations on and in the

I Former Kellwood Facility, located at 202 Industrial Drive, New Haven, Missouri. The facility is

I currently owned and operated by Metalcraft Enterprises. Historical investigative activities have

revealed that there are residual levels oftetrachloroethene (PCE) within OU2 in the soil and

I elevated levels in the groundwater. OU2 is located within an industrial park, in a primarily rural

area. Several residences are located nearby. A RIIFS is currently being completed for OU2.

I Groundwater Use:

I There are two distinct bedrock flow systems beneath OU2, a shallow flow system and a deep

flow system. The shallow bedrock flow system consists of the Cotter Dolomite and the Jefferson

I City Dolomite. Groundwater flow through the shallow flow system near OU2 is to the south,

towards BoeufCreek. The shallow flow system consists of two sandstone beds, the Upper

Sandstone and the Swan Creek sandstone, which are members of the Cotter Dolomite. With the

exception of the two sandstone units, the Cotter and Jefferson City Dolomites are poor water

I producing formations and typically have low vertical and horizontal conductivity from a regional

scale. The deep bedrock flow system consists of the Roubidoux Formation and older geological

I formations, including the Gasconade, Eminence, and Potosi Dolomite. Groundwater flow

through the deep flow system near OU2 (based on water levels measured in monitoring wells

I installed in the Roubidoux Formation) is to the northeast, towards the Missouri River. The

Roubidoux Formation is located from approximately 350 to 450 ft bgs, or 120 to 220 ft above

I mean sea level (MSL), and is the primary production zone for many of the newer domestic water

supply wells.

I A well inventory performed by EPA and the United States Geological Survey (USGS) in the

I New Haven area found detectable levels of PCE in select residential wells south of OU2. The

area where PCE has been detected in residential wells has been identified as OU6. Since OU2 is

I within Special Area 3 as described in Section 3.2.1, MDNR provides specific guidance on well

I drilling protocol and construction specifications on a case-by-case basis. The MDNR will

provide written approval for all new wells prior to construction.

I 8

I



3.2.3 OU3 (Old City Dump)

I Land Use:

The Old City Dump (OU3) is located in the southeastern part of New Haven along the north side

I of State Highway 100. The Old City Dump is currently used as a yard waste/gravel storage area

I and compost site. The City ofNew Haven Public Works Department maintains OU3 and its

planned future use will remain the same. A gravel storage area located elsewhere in New Haven

I will be consolidated into OU3. The surface of the Site is currently a mixture of gravel, dirt, and

occasional pieces of weathered asphalt and concrete. The area immediately north and west of the

I Old City Dump is covered by dense woods of deciduous trees. The topography immediately

north of the dump is rugged, consisting ofa steep ravine where wastes were dumped until the

I entire upper end of the ravine was filled to its current level. On the east side of the dump, there

is a gravel parking lot. As the city will remain the owner ofOU3 and it intends to maintain the

I current type of use, it is reasonable to expect no development will occur in the foreseeable future.

OU3 is surrounded by a mixture of commercial and residential property.

Groundwater Use:

I Currently there is no surface water or groundwater use at OU3. The contaminants seen in one

monitoring well, BW-03, were detected in "perched" water that is moving along bedding planes

I and fractures in the bedrock above the water table. This is a common occurrence in limestone

aquifers as infiltrating water works its way down to the water table. Well BW-03 is less than

I 250 feet from the Old City Dump, and it is not unusual to find that contaminants have migrated

this short distance in the unsaturated zone. The fact that seeps and the intermittent creeks in the

I steep ravines north and east of the Site have no contaminants suggests that extensive lateral

movement of contaminants is not occurring.

I Several residences, in close proximity to OU3 use domestic wells as their water supply. Most

I domestic wells in the area target the Roubidoux Formation because it is the first unit that yields

appreciable quantities of water for domestic use. Groundwater age dating in the New Haven area

I indicates that most water in the Roubidoux Formation (a permeable sand-rich unit about 300-400

feet deep in the area) is less than 40 years old. Given the age of water and the large amount of

I water produced from the Roubidoux Formation compared to shallower units, it is likely, if the

I 9

I



nearby domestic wells were to' be impacted by the Old City Dump, that impacts would already

I have been seen. It is extremely unlikely that wells would be installed at the Old City Dump Site

to supply water to residents or future workers because 10 CSR 23-3.0 I 0 requires that all new wells

I are located at least 300 feet from a landfill.

I During investigations, nested wells were installed and all domestic wells withiri one-half mile of

I the OU were sampled. Data from the new nested well cluster contirms the suspected direction of

groundwater flow. The high conductance of the wells indicates they are properly placed and

I intercepting typical landfill leachate. The absence of contaminants in the four nearby domestic

wells indicates that widespread groundwater contamination from OU3 has not occurred and is

unlikely in the future.

I 3.2.4 OU4 (Maiden Lane Area)

Land Use:

I OU4 is a I 92-acre area in the north-central part of New Haven. The current OU4 area is

generally bordered on the west by Maupin A venue, on the south by Roberta Street, and extends

I east of Miller Street into undeveloped land within the city limits. OU4 straddles the topographic

divide between the Missouri River to the north and BoeufCreek to the south. Topography is

I asymmetric with steeper slopes to the north and east along the tributaries to the Missouri River

I and shallow slopes to the south. Elevations range from about 690 ft MSL at the fonner

Kellwood Research facility to less than SOO ft MSL in downtown New Haven. The OU4

boundary encompasses a plume of PCE-contaminated groundwater that extends from a source

I area south of Maiden Lane north to the Missouri River. Because OU4 surrounds the i

I groundwater plume in the bedrock aquifer, OU4 actually underlies OUS (Old Hat Factory) and

OU I (Front Street site). PCE contamination emanating from OU4 migrates through the bedrock

aquifer beneath OU I and OUS. The current and historical land use within OU4 primarily is

I residential. Non-residential land use in OU4 includes the Assumption Catholic Church, located

I on a 3.8-acre parcel on the northwest corner of the intersection of Miller Street and Maiden Lane.

Future land use within OU4 is anticipated ~o be similar to its current use.

I I 10

I



Groundwater Use:

I Currently, there is no lise of groundwater within OU4. OU4 is within Special Area 3 as

described in Section 3.2.1. The MDNR will provide specific guidance on well drilling protocol

I and construction specifications on a case-by-case basis. The MDNR will provide written

I approval for all new wells prior to construction. Because of the proximity ofOU4 to the

Missouri River valley, which serves as a drain for regional and shallow groundwater flow, the

PCE detected in the shallow bedrock at OU4 is not a threat to the public supply wells W3 and

I W4 located south of and upgradient from OU4 or domestic wells outside of the city limits.

I 3.2.S OUS (The Old Hat Factory)

I Land Use:

The Old Hat Factory (OU5) is located on a 1.9-acre parcel in a mostly residential area at the

I southeast corner of the intersection of Maupin A venue (west) and Wall Street (north) just south

of downtown New Haven. At the time of the initial field investigation in 2002, OU5 consisted of

a three-story 14,000- ft2 (square foot) brick building at the northwest corner of the property with

an attached 12,000- ft2 one-story metal manufacturing building to the east, and an attached

I 4,200- ft2 one-story oftice bui Iding to the south. The south half of the parcel consisted of an

asphalt parking lot. Most of the building was demolished during 2003-04 and the site was

I extensively re-graded and seeded in 2005. This portion of the parcel is currently a grassed

vacant lot. Future use of the property is anticipated to remain commercial.

I Groundwater Use:

I Currently, there is no groundwater or surface water use at OU5. OU5 is within Special Area 3 as

described in Section 3.2.1. The MDNR will provide specific guidance on well drilling protocol

I and construction specil1cations on a case-by-case basis. The MDNR will provide written

approval for all new wells prior to construction. It is extremely unlikely that wells would be

I installed at OU5 to supply water to residents. The shallow groundwater in the OU5 area is of

low quality and low yield, and any shallow wells would be unable to produce enough water for

I domestic supply. In addition, the area is supplied drinking water from the city wells.

I I II

I



3.2.6 OU6 (Domestic Wells)

I Land Use:

In 1999, PCE was discovered in a residential well approximately 2000 ft downgradient of a

I landfarm area located at the OU2 Kellwood Industries Site. Three additional homes were later

I identified as having contaminated wells. The area with contaminated residential wells has been

identified as OU6. Land use within OU6 is rural and rural residential and will remain so for the

foreseeable future. A RIIFS is currently being completed for OU6 and OU2.

I I

Groundwater Use:

All homes within the OU6 area use residential wells for domestic water. Homes whose wells

I have been contaminated with PCE have been equipped with whole house treatment systems.

OU6 is within Special Area 3 as described in Section 3.2.1, and as designated by the State of

I Missouri which requires that the MDNR be consulted before construction ofa new well. The

MDNR will provide specific guidance on well drilling protocol and construction specifications

on a case-by-case basis. The MDNR will provide written approval for all new wells prior to

construction.

I 3.3 Site History and Enforcement Activities·

I I

The Riverfront Site is contaminated with industrial chemicals, primarily chlorinated volatile

organics. In 1986, MDNR began testing public-supply wells in the state for VOCs and detected

I the chlorinated solvent PCE in New Haven city wells W I and W2. These wells were more than

800 ft deep. Concentrations of PCE in water samples from city well W2 increased steadily with

I time from the initial detection of28 micrograms Pt!r liter (llg/L) to a maximum of 140llgIL

before the well was removed from service in 1993. The concentrations of PCE in water samples

from city well WI generally were less than the federal allowable MCL of 5 Ilg/L. However, well

W I was in the Missouri River floodplain and had a prior history of bacterial contamination

I attributed to a poor surface casing seal that resulted in its removal from service in 1989. During

1988 and early 1994, two additional city wells (wells W3 and W4) were installed in the southern

I part of the city to compensate for the loss of city wells W I and W2. Wells W3 and W4, while

completed within the same aquifer, are cased several hundred feet deeper than wells W I and W2.

I I 12

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Various agencies have sampled city wells W3 and W4; no PCE or other VOCs have been

I detected in those samples.

I Results from several previous investigations resulted in an overall remedial investigation of the

I Riverfront Superfund site. During 1993-94, an Expanded Site Investigation (ESI) was conducted

to collect sufficient data to score the site for possible placement on the National Priorities List

I (NPL) or Superfund. Because several unresolved questions remained after the completion of the

ESI, the EPA conducted an Expanded Site InvestigationlRemediallnvestigation (ESIIRJ) in

I 2000 to collect information on groundwater flow and groundwater contamination in the vicinity

of city well W2.

I Results from the ESIIRI were used to scope the Remedial Investigation (RI) of the site which

I began in 2000 as an investigation into four potential contaminant source areas (operable units)

that by 2003 had expanded into six operable units. The six operable units were identified as:

I OU I: Front Street OU2: Kellwood Industries OU3: City Dump

I OU4: Maiden Lane Area OUS: Old Hat Factory OU6: Domestic Wells

At the start of the EPA RI, little was known about the source of PCE to city wells W I and W2 or

I the potential for future contamination of city wells W3 and W4. By 2007, the EPA had

completed investigations at three of the six operable units (OU I, OU3 and OUS), installed a

I long-term cleanup system for soil and shallow groundwater at one site (OU I), identified and

began cleanup ofa major source of the PCE that closed city wells WI and W2 (OU4), and

I identified a second major PCE source area in the south part of the city, (OU2), that is being

addressed by the Kellwood Company as a Potential Responsible Party (PRP).


I I In 1986, PCE was detected in two public-supply groundwater wells (wells W I and W2) in the

northern part of New Haven. Following the discovery of contamination, two new public-supply

I 13

I

I I


wells were installed in the southern part of the city, and several investigations were conducted to

I identifY the source of the contamination. The Site became known as the Riverfront Site, and in

I December 2000, the PCE contamination prompted the listing ofthe Riverfront Superfund Site on

the National Priorities List (NPL).

I Various industries have operated at the Front Street Site since the 1950s. In the I 950s, the New

I Haven Manufacturing Company (NHMC) began operating at the Site. The NHMC operated at

the Site until 1972. PCE was used as a degreasing solvent in the manufacturing operations of the

I NHMC. The EPA has confirmed that waste PCE was washed out of the south doors of the

building, where it pooled in low areas along the south side of Front Street. NHMC dissolved as a

I Missouri corporation in 1975. From 1983 to 1989, Riverfront Industries operated at OU I. Since

1989, the Site has been occupied by Transportation Specialists, Inc. (1989 - 1993), who did not

use PCE and by Wiser Enterprises. Inc. (1997 - 2004).

I The EPA began a RI in June 2000 and focused this effort at OU 1 (Front Street), and OU3 (City

Dump). A feasibility study (FS) for both areas began in the summer of2002. During July 2000,

I the EPA conducted an emergency removal action at OU I to replace a PCE contaminated water

line that ran beneath Front Street. The water line was made of polyethylene, which is permeable

I to PCE. PCE contamination at OU 1 infiltrated the water supply line in this segment. The

polyethylene water line was replaced with a steel line. During the removal action, the EPA

I removed near surface (less than 8 feet deep) PCE-contaminated soils along the water-line

corridor and in adjacent soils. These soils were some of the most contaminated soils at the site

I with PCE concentrations as high as 6,200,000 micrograms per kilograms (flg/kg). About 300

yd3 (cubic yards) of PCE-contaminated soil, containing an estimated PCE mass of about 70

I kilograms (kg), were removed during this removal action. In addition to mitigating the PCE

contamination in the water line, the removal action provided a corridor of clean soil surrounding

I the water line beneath Front Street and adjacent areas.

I The Record of Decision (ROD) was approved in September 2003 for OU I.

I I 14

I



OU2 (Kellwood Industries)

I Beginning in 1973, Kellwood Company began operating a tube mill (where small diameter

aluminum tubing was made from aluminum coils and a metal fabrication operation where

I aluminum was cut, swaged, bent, and hole-punched) at 202 Industrial Drive_ Kellwood's

I operations on Industrial Drive were sold to American Recreation Products, Inc. (ARP), an

independent company, on September 30, 1985. In November 1988, Kellwood bought ARP. In

March 1989, ARP sold the facility at 202 Industrial Drive to Metalcraft Enterprises.

I In approximately 1990, ARP and Kellwood Company were informed by the State of

I Missouri that a former employee had stated that at some period during the operation of the tube

I mill, one or more employees of the tube mill disposed of cleaning solvent containing PCE or

trichloroethene (TCE) on the City-owned property just to the north of 202 Industrial Drive.

I In April 1994, Kellwood and MDNR entered into an agreement to remediate the soils on the

city-owned property north of the Former Kellwood Facility and to monitor groundwater. In

accordance with this plan, soils with concentrations of PCE exceeding 380,000 micrograms per

kilogram (~lg/kg) were excavated and sent to an off-site incinerator. To meet the remedial

I objective of reducing levels of PCE and its degradation products in the soil to a concentration of

I ,000 ~lg/kg or below, the remaining soil was land-farmed. This work was completed by

I Geotechnology under contract to Kellwood. In addition, Geotechnology installed, at Kellwood's

expense, a French drain system between the land farm and the current Metalcraft facility and

I installed three monitoring wells north of the Former Kellwood Facility (MW-l 0 I, MW-I 02, and

MW-I03). As part of the 1995 agreement with MDNR, municipal well W3, the

I French drain system, and the three monitoring wells north of the Former Kellwood Facility

(MW-I 0 I, MW-I 02, and MW-I 03) were sampled on a quarterly basis until March 2004. In

I June 2004, Kellwood submitted a written request to MDNR to end the 1994 monitoring

agreement, with the understanding that sampling of these wells would be continued as part of the

I RI.

I In 1999, following the land-farming activities, a Phase I and Phase II environmental site

assessment was performed by EMA on behalf of a prospective purchaser on properties near the

I land farm area. PCE was detected in two downgradient monitoring wells, MW-2, MW-2A, and

I 15

I



in a well located approximately 600 feet southwest of the landfarm area (MW-4). Between 1999

I and 2002, USGS installed groundwater monitoring wells, and collected soil, groundwater,

residential well water, sediment, surface water, and tree core samples near the Former Kellwood

I Facility. PCE was detected in each of these media. The entire Riverfront Site was listed on the

National Priorities List (NPL) on October 19,2000.

I I

Currently, the shallow groundwater in portions ofOU2 contains PCE above the MCL. The

current National Primary Drinking Water Regulations (NPDWR or primary standards) for PCE

I and TCE (a breakdown product of PCE) sets the MCL for each of these compounds at 5 ~lgfL.

Based on current information, OU2 is not suspected to have been a source of contamination for

I city wells W I and W2. City well W3 is located 1,000 feet north of the Former Kellwood

Facility. Quarterly sampling performed from 1994 to date at W3 has not shown any

I contamination. OU2 is currently in the RIfFS phase to investigate the nature and extent of

impacted media to develop and evaluate potential remedial alternatives. OU2 may have affected

selected private wells south ofOU2 (i.e., in OU6). peE well above the MCL was discovered in

residential wells approximately 2,000 feet down gradient from a land farm area located at the

I OU2 Kellwood Industries Site. A response action conducted under an Administrative Order of

Consent (AOC) dated March 26, 2002 provided whole-house filtration units for PCE

I contaminated residential wells in OU6. Pursuant to the Order, the whole-house filtration units

are sampled quarterly to ensure no one is exposed to contaminated groundwater.

I Kellwood began the investigation ofOU2 and OU6 with a voluntary Residential Well

I Investigation (R WI). The RWI addresses residential wells south of OU2, which have been

collectively defined as OU6 of the Riverfront Superfund Site. The Interval Screening Phase of

I the R WI was completed between July and August 2004. In addition, two monitoring well

clusters (MWI and MW2) were installed south ofOU2 between September and November 2004.

I OU3 (Old City Dump)

I During the period of the mid-1950s through the early 1970s, the old city dump operated under

private ownership and was used as a community dump for domestic and industrial wastes.

I During its operation, hundreds of drums of industrial waste including industrial dyes and

I 16

I

I I


flammable solvents were reportedly placed in the dump. Reports also indicate that the liquid

I contents of the drums were burned in a pit onsite. The dump was closed in 1972 when the land

I was purchased by the City of New Haven. After its closure, the City of New Haven used the

dump for disposal of demolition debris and yard waste.

I During the RI at OU3, monitoring wells and a seep were sampled. Additional samples were

I collected from trees and seeps along the dump face and from streams and springs near the dump.

Water samples also were collected from a bedrock monitoring well (OU3-BW-03). Domestic

wells near OU3 were also inventoried and sampled during the RI.

I I During the ESIIRI and RI, a total of22 trees and 4 seeps were sampled on and along the slopes

ofOU3. All four seeps were screened for the presence of PCE and other VOCs using the

portable Gc.

I There are no source materials or dense non-aqueous phase liquids (DNAPL) in the groundwater

constituting a principal threat at OU3. Only trace concentrations of PCEwere found in the

I groundwater, surface water, and vegetation samples at this OU. The ROD was approved in

September 2003.


I During the 1980s and 1990s, after two public supply wells for the City of New Haven were

found to be contaminated with PCE, the MDNR and the EPA investigated to determine the

I source of the contamination. In 1998, the EPA requested that the USGS provide technical

assistance in understanding the hydrogeology of New Haven. From 2000 to 2002, the USGS

I conducted an ESI and RI. The investigation included systematically installing bedrock

monitoring wells upgradient of the two contaminated City wells. By 2005, the monitoring well

I investigation led to a focus on an area around Maiden Lane. At that time, EPA was concerned

that PCE disposed of into the City sewer system at OU2 may have leaked from the sewer lines

I around Maiden Lane and created the PCE plume. How,ever, by samplif!g various media (soils,

I tree cores, indoor vapor from homes, sewer water, surface water, and groundwater) and from

discussions with residents, the investigation found that most likely a private citizen had disposed

I 17

I

I I


of significant amounts of peE into his home's grey water (sewer) line, which discharged into a

I low area behind (south of) Maiden Lane. From here the peE migrated through the soils into the

bedrock and then into the bedrock aquifer.

I I

At this time, the peE soil contamination is nearly all confined to this small (less than 0.2 acre)

area south of Maiden Lane. The groundwater plume extends from the shallow groundwater at

I the soil-rock interface below the source area soils through the bedrock to the north, possibly as

far as the Missouri River. Groundwater contamination also extends slightly south of the soil

I source area, due to local topography. Overall, the peE plume extends from the source area to

city wells W I (approximately 3,800 ft downgradient) and W2 (approximately 3,000 ft

downgradient) and probably to the Missouri River (approximately 4,000 ft downgradient).

I I The removal action conducted by EPA at OU4 in 2007 consisted of the injection of sodium

permanganate into the Maiden Lane contaminant source area. While this action resulted in the

breakdown of some of the peE into its nonhazardous constituents, the sampl ing data indicate

that contaminants remain in the soils and that such contaminants continue to mobilize into the

I shallow aquifer and migrate. Because of the proximity ofOU4 to the Missouri River valley,

which serves as a drain for regional and shallow groundwater flow, the peE detected in the

I shallow bedrock at OU4 is not a threat to the public supply wells W3 and W4 located south of

and upgradient from OU4 or domestic wells outside of the city limits.

I In March 2009, a ROD for OU4 was issued.

I OU5 (Old Hat Factory)

I The initial "pre-RI" EPA investigation of the old hat factory was limited because interviews with

I former employees during previous MDNR and EPA investigations did not indicate that peE had

been used at the facility. The pre-RI investigation consisted of a site reconnaissance and the

I installation of a single monitoring well that was expected to "rule out" the old hat factory as a

possible source of the peE contamination. However, water samples collected in 2002 from the

I BW-09A borehole during drilling and from the completed well contained peE concentrations

I 18

I



ranging from 49 to 140 Ilg/L. Because the old hat factory was within 600 ft and upslope of both

I contaminated city wells (WI and W2), the detection ofPCE in samples from monitoring well

BW-09A caused concern that the facility could be a potential source of the PCE contamination in

I the closed city wells. The old hat factory was designated OU5 of the Riverfront Superfund Site

in mid-2002 and a RI was initiated. The primary contaminants at OU5 are PCE and its

I degradation products such as TCE, cis-I ,2-dichloroethene (cis-DeE), and vinyl chloride (VC).

A monitoring well network was established to confirm groundwater contamination and to

I determine ifOU5 was the source of groundwater contamination for the impacted city wells WI

I and W2. Although elevated concentrations of PCE were found in groundwater, and low levels of

PCE were found in soils, it was determined that OU5 was not the source of contamination at the

impacted city wells. An RIIFS was conducted and completed in June 2006.

I The ROD was completed in December 2006.

I OU6 (Domestic Wells)

I OU2 may have affected selected private wells to the south in OU6. peE well above the MCL

was discovered in residential wells approximately 2,000 feet down gradient from a land farm area

I located at the OU2 Kellwood Industries Site. A response action conducted under an

Administrative Order of Consent (AOC) dated March 26, 2002 provided whole-house filtration

I units for PeE-contaminated residential wells in OU6. Pursuant to the Order, the whole-house

filtration units are sampled quarterly to ensure no one is exposed to contaminated groundwater.

I Kellwood began the investigation ofOU2 and OU6 with the voluntary Residential Well

I Investigation (RWI). The RWI addresses residential wells south ofOU2, which have been

collectively defined as OU6 of the Riverfront Superfund Site. The Interval Screening Phase of

I the R WI was completed between July and August 2004. In addition, two monitoring well

clusters (MWI and MW2) were installed south ofOU2 between September and November 2004.

I I I 19

I



3.4 Basis for Taking Action


I I

The basis for action was to prevent human health risks from occurring due to future exposures to

contamination found in groundwater and soil.

I There were no current risks identified from groundwater at the time of the OU I ROD since all

I residences and businesses were on city water. Use of groundwater as a potable source in the

future was assessed to result in significant risks. The primary chemicals of concern (COCs) were

TCE and PCE. VC and benzene also contributed to the estimated risks.

I I There were no current risks identified from contaminated surface soil at the time of the ROD.

Significant risks were estimated for future exposure should the floor slab be removed and the soil

underneath not capped or covered. The primary COCs for future estimated risks were

benzo(a)pyrene, arsenic, and PCE. Other COCs contributing to the overall estimated risk from

I the soil were benzo(b)fluoranthene, benzo(a)anthracene, indeno( I ,2,3-cd)pyrene, TCE, and vc. There were no current exposures to subsurface soil COCs at OU I. In characterizing future

I excavation into contaminated soil, arsenic and PCE were found to be the primary COCs.

I OU2 (Kellwood Industries)

I OU2 is undergoing a remedial investigation. A remedy has not yet been selected.

I OU3 (Old City Dump)

I The basis for action at OU3 was to prevent future human health risks from occurring due to

exposures to contamination found in groundwater and seeps.

I I

There were no current risks identified for OU3. Future potential risks were characterized

assuming residential and commercial uses of contaminated groundwater, with seep water

I 20

I



concentrations representing the exposure point concentrations for the chemicals of potential

I concern (COPCs) - antimony, boron, manganese, nitrate, and PCE. The primary risk drivers were

determined to be antimony, boron, and nitrate in the residential use scenario. For monitoring

I purposes, however, ARARs and/or TBCs were listed in the ROD for all COPCs evaluated.


I The ROD was finalized in March 26, 2009. The design of the remedy is ongoing. No remedial

action has occurred.

I OUS (Old Hat Factory)

I The basis for remedial action at OUS was to prevent future human health risks from occurring

I due to exposures to contamination found in groundwater.

There were no current risks identified from contaminated soil, vapors, or groundwater at OUS.

I Future potential risks were characterized and found to be significant, only if residential and

commercial uses of groundwater occurred. PCE was the primary risk driver, and carbon

I tetrachloride and chloroform were identified as also contributing to significant risks.


I OU6 is undergoing a remedial investigation. A remedy has not yet been selected.

I I 'I II

I 21

I



4.0 Remedial Actions

I Remedial actions have been completed at OU I, OU3, and OUS. The RODs for OU I and OU3

were signed on September 30,2003. The Consent Decree for OU3 was signed by the City of

I New Haven and EPA in May 2007. The ROD for OUS is dated December 7, 2006. OU2 and

OU6 are still undergoing remedial investigations. For completeness of the document, the

I recently selected remedy for OU4 is included although remedial action has not yet been

implemented. The OU4 ROD is dated March 26, 2009.

I 4.1 OUI (Front Street)

I 4.1.1 Remedial Action Objectives (OUI)

RAOs provide a general description of what the response action is expected to accomplish. The

I Remedial Action Objectives (RAOs) for OU I are to: I) prevent use of groundwater with

contaminant levels exceeding MCLs as a drinking water source; 2) prevent further degradation

I of the groundwater below the OU and in the plume; and 3) prevent exposure to soil with

I contaminant concentrations which result in an excess cancer risk greater than I x 10-6 or a Non

Cancer Hazard Index greater than I.

I The EPA generally seeks to return usable groundwater to beneficial use whenever practicable.

I When contaminated groundwater is currently or potentially used as a drinking water source, EPA

typically selects a remedy that will restore the groundwater to achieve MCLs and non-zero

Maximum Contaminant Level Goals (MCLGs) established under the Safe Drinking Water Act.

I Under limited circumstances specified in CERCLA, Alternate Concentration Level (ACLs) may

I be used instead of drinking water standards (typically, MCLs or MCLGs). The use of ACLs

allows flexibility in establishing groundwater cleanup levels under limited circumstances.

The following description presents the specific RAOs and ACLs used in the preferred

I alternative. After the completion of the FS, the EPA and MDNR continued to explore existing

and innovative mechanisms for addressing contamination at OU I. One of the mechanisms

I incorporates the use of ACLs and this mechanism was incorporated into an additional alternative

that became the preferred alternative for OU I.

I I 22

I



The use of ACLs requires that three statutory criteria be met; these criteria are:

I' I) The contaminated groundwater has "known or projected points of entry to a surface water

I body".

I 2) There must be no "statistically significant increases" of contaminants in the surface water

body at those points of entry, or at points downstream.

I 3) It must be possible to reliably prevent human exposure to the contaminated groundwater

through the use of institutional controls.

I The EPA has determined that conditions at OU I meet the criteria to support the use of ACLs.

The following information docUlnents this finding:

I Criteria I: Extensive sampling performed during the RI and during subsequent field

I investigations has defined the contaminant plume boundary with a high degree of confidence.

The contaminated groundwater plume originating at the Front Street Site flows to the northeast

approximately 600 feet where it enters the Missouri River. At the widest cross-section,just

I before entering the Missouri River, the plume attains a maximum width of about 300 feet. The

"core" of this plume, which contains PCE concentrations above 500 flg/L, is less than 100 feet

I wide. Substantial microbial degradation of PCE occurs within the plume, and PCE

concentrations decrease down the plume axis and concentrations of degradation products such as

.1 cis-DCE, VC, and ethene increase. The RI determined that in the more than 30 years since the

. last known use of peE at the facility, the contaminant plume has reached steady-state conditions,

I and concentrations within the plume will remain at their present levels or decrease as the result

of degradation processes within the aquifer.

I Criteria 2: During the RI, surface water and bed-sediment samples were collected from the

I Missouri River upstream, within, and downstream of the "known or projected" point of entry of

the contaminant plume into the river. The water samples were collected during a low stage of

I the river and from the bottom of the river to maximize the potential for detecting the contaminant i

plume discharge. None of the water or bed-sediment samples contained detectable

I concentrations of PCE or its degradation products. A conservative analysis was done to

I 23

I

I I

RIVERFRONT SUPERFUND SITE "FIVE-YEAR REVIEW REPORT

determine the maximum impact that the plume (the contaminated shallow aquifer) could have on

I the Missouri River water quality. The analysis conservatively assumed that the highest

contaminant concentration detected in the core of the plume (11,000 ~g/L PCE) discharges

I directly into the Missouri River. This concentration is several orders of magnitude larger than

I the maximum concentration detected within the groundwater plume in the discharge area along

the Missouri River. The analysis further assumed that this plume discharges continuously for a

I distance of 400 feet along the Missouri River, and that the contaminated water entering the river

does not mix with the overlying water. In fact, turbulent conditions at the base of the river would

I actually result in instantaneous mixing with thousands of cubic feet of surrounding river water,

even during low flow conditions. Using these extremely conservative assumptions, the analysis

I concluded that the maximum PCE concentration that could occur at the downstream limit of the

discharge zone in the Missouri River would be 1.2 ~glL, well below the drinking water MCL

I value and the Missouri Water Quality Standard for protection of aquatic life, which is 5 ~g/L.

The non-detections of PCE and its degradation products in the river samples collected during the

RI confirm the conservative nature of the analysis and support the "no statistically significant

increase" in contaminant concentrations criteria required for the use of ACLs.

I Criteria 3: To reliably prevent future exposure to contaminated groundwater associated with

I OU I, measures preventing exposure are in place and will be supplemented with additional

institutional controls. The flood protection levee surrounding downtown New Haven is owned

I by the city, but was constructed by the USACE using federal funds. The city is responsible for

maintenance of the levee and ensu,ring that stringent guidelines for construction and other

I activities near the levee are followed. To maintain annual certification from the USACE of the

levee's integrity, the city must ensure that these guidelines are followed; these include

I controlling subsurface excavations, borings, and the installation of wells within 500 feet of the

back of the levee. Before any such activities occur, the city and USACE must review a written

I plan of the activity. The USACE provides technical comments, and the city is responsible for

approving or disapproving the plan and ensuring that USACE guidelines are followed. The city

I public works department is responsible for oversight of subsurface activities near the levee.

I Given the location of the Front Street Site in a highly visible area of downtown New Haven, near

municipal offices and facilities, any subsurface activities conducted at OU 1 would presumably

I 24

I



be readily observable and hence controllable. The city has a large financial interest in

I monitoring subsurface activities near the levee because if the USACE guidelines are not

followed, the levee risks losing USACE certification which would severely affect flood

I insurance rates in the area.

I 4.1.2 Remedy Selection (OUt)

The remedy selected to achieve the remedial action objectives is as follows:

I Institutional controls were implemented at OU I in layers to enhance the protectiveness of the

remedy. The primary form of institutional proprietary control is an environmental covenant and

I easement. This form of proprietary control was selected as it is effective as an informational

device and creates a readily enforceable legal property interest.

I The EPA sought the imposition of an environmental covenant and easement on the Site by the

I landowner. The MDNR was named the grantee of this environmental covenant and easement

and will have the authority to enforce the environmental covenant and easement. The EPA was

I named as a third-party, or intended beneficiary in this instrument so that EPA also had the ability

to enforce the terms of the environmental covenant and easement.

I The objectives of imposing an environmental covenant and easement on OU I were to el iminate

I or minimize exposures to contamination remaining at OU I and to limit the possibility of the

spread of contamination. These objectives were achieved by use of the environmental covenant

I and easement as it: (I) provided notice; (2) limited use; and (3) provided federal and state access.

Specifically, the environmental covenant and easement achieved this by:

• providing notice to prospective purchasers and occupants that there are contaminants in

I soils and the groundwater; • ensuring that future owners are aware of any engineered controls put into place as part of

this remedial action;

I • prohibiting residential, commercial and industrial uses, except those uses which would be consistent ~ith the remedial action;

• limiting the disturbance of contaminated soils;

I • prohibiting the placement of groundwater wells; • prohibiting other ground penetrating activities which may result in the creation of a

hydraulic conduit between water bearing zones;

I • providing access to EPA and the State of Missouri for verifying land use;

I 25

I



I • prescribing actions that must be taken to install and/or maintain engineered controls (if

applicable); and • providing access to EPA and the State of Missouri for sampling and the maintenance of

engineered controls.

I One Advanced Remediation Technology (ART) treatment well and three new monitoring wells

were installed as part of the selected remedy. The ART well is a combination in-situ air-stripper

I well to treat the groundwater and a soil vapor extraction (SVE) well to treat the soil. The

location of the ART well was determined during the remedial design, and is very near the area of

I highest soil contamination (the southeast corner of the Front Street Building). A treatability

study of the ART well was conducted during its first quarter of operation. The treatability study

I determined the effectiveness of the groundwater treatment, confirmed that treatment of the ART

system's off-gas is not required, and was used to determine the site-specific Operations and

I Maintenance (O&M) requirements for the system.

I Three monitoring wells were installed. One well was within the radius of the treatment zone,

I one well was at the edge of the treatment zone, and the last well was at the edge of the plume.

These wells, and existing monitoring well G, were used to determine ifOU I was in compliance

I with the ACLs. All the wells had to comply with the guidelines established by the USACE for

protection ofthe flood control levee.

The selected remedy used monitoring:

I I) to generate the ACLs and then confirm that the ACLs are not being exceeded; 2) to ensure that the groundwater plume does not migrate to new receptors; 3) to determine the effectiveness of the ART well's groundwater treatment;

I 4) to confirm that the off-gas from the ART well does not require treatment; and 5) to confirm that the groundwater plume is not affecting the Missouri River.

I The ACLs were set at one order of magnitude (times 10) above the highest concentration

I detected to continue to protect the Missouri River. After the ACLs were determined, monitoring

results were compared to the ACLs to evaluate if the Missouri River could be affected by the

groundwater contaminant plume.

I I The Missouri River water samples were collected from the bottom of the river where the shallow

aquifer discharges. The samples were collected during the historical lowest flow month. Since

I 26

I



groundwater ACLs were not exceeded during the first five years, the Missouri River sampling

I will be discontinued.

I 4.1.3 Remedy Implementation (OUI)

I Installation of one Advanced Remedial Technology (ART) treatment well (Figure 3)

The ART technology is a proprietary technology supplied by one vendor. The ART well uses in

I situ physical treatment (in-well aeration [IWA] and pumping/air-stripping for groundwater SVE

for soils) to remediate contaminated groundwater and soils. Based on the RI groundwater and

I soil sampling results, the ART well was installed at the head of the groundwater plume. The

head of the plume is very near, but not directly below, the location ofthe highest soil

I contamination found in the RI. The ART well's location was selected to maximize the combined

remediation of groundwater and soil. The work was completed in February 2005. The system

I became operational in May of2005. Samples of the vapor from the ART system were collected

on June 2,2005. The purpose of the vapor samples was to determine if treatment ofthe vapor

released from the ART system would be required to meet the MDNR emission standards. The

results of the vapor sampling indicated that treatment of the vapor would not be required.

I Installation ofthree additional monitoring wells and two piezometers

I One monitoring well was installed in the northeast (downgradient) portion of the OU I source

area to measure the effectiveness of the ART well's treatment. The two piezometers (one

I shallow and one deep) were installed next to (within 5 feet ot) the ART well to measure the flow

through the ART well. The other two monitoring wells were installed downgradient from the

I ART well to monitor the contaminant plume just before it enters the River. The work was

completed in March of2005.

I Institutional controls implemented in layers to enhance the protectiveness ofthe remedy

I The primary form of institutional control to be implemented was a PP A between the United

States, the State of Missouri, and the Industrial Development Authority of the City of New

I Haven (IDA). This PPA was filed in February 2004 with the EPA Region VII Hearing Clerk

under Docket No. CERCLA-07-2004-0004. Pursuant to the PPA, the IDA agreed to, among

I other things:

I 27

I



• only use the site for surficial uses,

I • not conduct any activities which would disturb contaminated soils at the site, and • not place any groundwater wells at the site or otherwise penetrate the groundwater

bearing unit(s) at the site.

I Pursuant to the PPA. the IDA also granted to EPA and the State access to the site for sampling,

monitoring, or the implementation of response actions, and also agreed to provide actual notice

I to any successors-in-interest or lessees of the site of any activity and use limitations on the site.

A copy of the PPA was also recorded by the IDA with the Franklin County Recorder of Deeds.

I Other institutional controls that were implemented were:

I • Including OU I in Special Area 3, as defined in 10 CSR 23-3.100(7), which requires that the MDNR be consulted before construction of any new well in Special Area 3. The MDNR will provide specific guidance on well drilling

I protocol and construction specifications on a case-by-case basis. The MDNR will provide written approval for all new wells prior to construction. The MDNR filed an emergency rule for Special Area 3 on March 21, 2005, which expired at

I the end of six months. The permanent rule was filed on September 27, 2005 and became effective on April 30, 2006.

• City oversight of the area around the flood protection levee. The flood protection

I levee surrounding downtown New Haven is owned by the City, but was constructed by the USACE using federal funds. The City is responsible for maintenance of the levee and ensuring that stringent guidelines for construction

I and other activities near the levee are followed. To maintain annual certification

I from the USACE of the levee's integrity, the City must ensure that certain guidelines are followed; these include controlling subsurface excavations, borings, and the installation of wells within 500 feet of the back of the levee.

I This 500-foot area includes all ofOU I. Therefore, before any excavations, borings, or well installations take place, the City and the USACE must review a written plan of the activity. In this review, the USACE provides technical

I comments, while the City is responsible for approving or disapproving the plan and ensuring that the USACE comments and guidelines are followed. Because OU I is located in a highly visible area next to downtown New Haven, next to the City Maintenance Department and near City Hall and the Police Station, any subsurface activities conducted at OU I would be readily observable and hence

I controllable.

4.1.4 Operational and! Functional Activities (Out)

I The ART well has been active for over four years. During this time, the system has been

I operational for about 3 ofthe past 4 years and it appears that it has been effective.

I 28

I


FIVE·YEAR REVIEW REPORT

Unfortunately, the operation of the system at optimal levels is highly dependent on the

I groundwater table. The efticiency of the system is determined by the river stage and subsequent

changes to the groundwater elevation. Due to proximity to the Missouri River, the water table

I has fluctuated from between 27 to 6 feet below ground level (bgl). During periods of low water

I table the groundwater pump and air sparge (AS) could be affected and during high water level

periods the SVE could be affected. SVE flow is dependent on the geology, the depth to water,

I the amount of exposed screen, and the radius of influence of the vacuum induced by the blower.

When the water table is down, more screen is exposed, there is an increased flow from the

I formation, and the system will operate more effectively. Conversely, when the water table is

high, the amount of screen in the unsaturated zone is decreased and the efticiency and

I effectiveness of the SVE portion of this system is reduced. The amount of vacuum from the

blower also enters into the equation as there is a direct correlation to the amount of vacuum and

I the resulting rise in the water table within the borehole caused by this vacuum. Whenever flow

through the screen is impeded due to either a high water table, high vacuum, or a combination of

both, the SVE portion of the system will not function.

I A review of the system operation relative to groundwater elevation at the ART well indicates

that the groundwater level has played a significant role in the operation of the remedial system.

I From system startup until early in 2007, the SVE portion of the system was operational with at

least 15 feet of screen in the unsaturated zone and the SVE likely operated at maximum

I effectiveness. However, during this period of low groundwater, two of the sampling events

indicated that there was very little water available for the pumping and/or AS portion of the

I system. From the Spring 2007 sampling event until the Fall 2008 sampling event, the SVE

effectiveness likely. dropped off significantly. This was due to a rise in the water table (resulting

I from a rise in the Missouri River water levels) which resulted in a shortening of the screen

available for flow. During three of these quarterly sampling events, it appears that the screen

I was occluded and the SVE likely did not function. Since fall 2008, the ART system has not been

operational due to a pump that is not functioning. Regardless of the problems associated with

I the fluctuations of the water table, all of the Chemicals ofConcem (COCs) remained well below

the ACLs.

I I 29

I



4.1.5 Institutional Controls (OUl)

I Institutional controls have been implemented in layers to enhance the protectiveness of the

remedy. The institutional controls put in place consist of inclusion of the site into Special Area

I 3, as defined in 10 CSR 23-3.100(7), PPAs, and restrictions due to proximity to the levee. The

Institutional Controls are discussed in detail in Section 4.1.3.

I 4.2 OU2 (Kellwood Industries)

I OU2 is undergoing a remedial investigation. Since a remedy has not yet been selected, a review

of protectiveness has not been completed.

I 4.3 OU3 (Old City Dump)

I 4.3.1 Remedial Action Objectives (OU3)

I The RAO for this action is to minimize contact with contaminated groundwater and surface

water. Currently, no exposure exists that represents an unacceptable risk to human health or the

environment, hence there are no Chemicals of Concern (COCs). The chemicals of potential

I concern (COPCs) for the Old City Dump Site include PCE, antimony, nitrate, boron, and

manganese. No Preliminary Remediation Goals (PRGs) have been set for these chemicals, as

I they do not currently require remediation, based on the low levels detected. However,

institutional controls will be used, as well as periodic monitoring of residential wells, one seep,

I and monitoring wells in the vicinity, to limit any potential future exposure to the COPCs.

Antimony and boron present a potential risk to a resident or occupational worker. This response

I action will provide EPA and MDNR the means to evaluate this remedy, monitor any

contaminant migration, and prevent any potential future risks from the Old City Dump Site.

I 4.3.2 Remedy Selection (OU3)

I Institutional controls were implemented at OU3 in layers to enhance the protectiveness of the

I remedy. The primary form of institutional control wi II be a proprietary control, specifically an

I environmental covenant and easement. This form of proprietary control was selected as it is

effective as an informational device and creates a readily enforceable legal property interest.

I 30

I



I The City of New Haven currently owns OU3. The City of New Haven granted the State of

Missouri an environmental covenant and easement. The EPA was named as a third-party

I beneficiary in this instrument so that EPA has the ability to enforce the terms of the

environmental covenant and easement in addition to the State of Missouri. This environmental

I covenant and easement was patterned on the model environmental covenant and easement found

in the Missouri Uniform Environmental Covenants Act (MoECA), Mo. Rev. Stat §§260.1 000-

I 260.1039. The objectives of imposing an environmental covenant and easement on OU3 are to

eliminate or minimize exposures to contamination remaining at OU3 and limiting the possibility

I of the spread of contamination.

I These objectives were achieved by use of the environmental covenant "and easement as it will:

(I) provide notice; (2) limit use; and (3) provide federal and state access.

I Specifically, the environmental covenant and easement achieved this by:

• providing notice to prospective purchasers and occupants that there are contaminants in soils and the groundwater;

I • ensuring that future owners are aware of any engineered controls put into place as part of this remedial action;

I • prohibiting residential, commercial and industrial uses, except those uses which would be

consistent with the remedial action; • limiting the disturbance of contaminated soils; • prohibiting the placement of groundwater wells;

I • prohibiting other ground penetrating activities which may result in the creation of a hydraulic conduit between water bearing zones;

• providing access to EPA and the State of Missouri for verifYing land use;

I • prescribing actions that must be taken to install and/or maintain engineered controls (if applicable); and

I • providing access to EPA and the State of Missouri for sampling and the maintenance of

engineered controls.

I In addition to the above proprietary control, governmental controls operate as effective

institutional controls at OU3. The MDNR has promulgated regulations pertaining to the location

I and construction of wells. These regulations prohibit the placement of a well within 300 feet of a

landfill. This prohibition, found at 10 C.S.R. 23-3.0 I 0, precludes the possibility that any well

I will be located in OU3.

I 31

I



I The EPA will also provide public education through the preparation and distribution ofa

I newsletter on the Site and informational meetings, which may be held every five years. The

public education campaign would be intended to inform citizens ofthe potential health hazards

I associated with exposure to contaminated groundwater and would remind city officials of the

restrictions on OU3.

The selected remedy also uses monitoring to ensure that the contaminants do not migrate from

I the Site and reach new receptors. In the first year, the four existing monitoring wells at the Site

and the most contaminated seep were sampled quarterly. The samples were analyzed for:

I I) YOCs, to confirm that no PCE (or any other YOC) is migrating from OU3 at levels above its MCL.

I 2) Inorganics, to measure the levels of the other COPCs (antimony, boron, manganese, and

I nitrate).

3) Field parameters (dissolved oxygen [DO], iron II, pH, oxidation-reduction potential [ORP], and temperature).

The ROD specified that if peE concentrations in groundwater samples remained below the MeL

I of 5 J.lg/L after the conclusion of I year of quarterly sampling, sampling would be reduced to

every 5 years. Because peE was not detected above the MeL during the 2003-2004 quarterly

I monitoring, sampling decreased to once every 5 years. None of the May 2008 samples from

monitoring wells, Seep M, or nearby domestic wells contained detectable quantities of PCE or

I other volatile contaminants of concern listed in the ROD.

I 4.3.3 Remedy Implementation (OU3)

Institutional controls were put in place through the environmental covenant for the OU3 site filed

I on April 14,2008. The grantor of the covenant is the current property owner and PRP, the City

of New Haven, Missouri. The holder of the covenant is MDNR.

I As specified in the ROD, the selected remedy requires, (I) a year of quarterly monitoring at the

I old city dump (four monitoring wells, seep M, and four nearby domestic wells) to establish

baseline conditions (conducted during 2003-2004), (2) to verify that PCE is not present above

I the MCLs in groundwater at the dump site or at detectable concentrations in nearby domestic

I 32

I



wells, and (3) the City must conduct an annual inspections of the site. Groundwater monitoring

I wells at OU3 are monitored to ensure that migration of contaminants above regulatory levels

does not occur. All groundwater samples are analyzed for a comprehensive suite of inorganic

I constituents and VOCs as specified in the ROD, and the collection procedures described in the

I OU3 Long Term Monitoring Quality Assurance Project Plan and Sampling and Analysis Plan.

All monitoring wells and Seep M were sampled and analyzed quarterly during the first year of

I monitoring (2003-2004) as specified in the ROD to establish baseline conditions. PCE was not

detected above its MCL of 5 flg/L, but has been found in several monitoring wells and seeps at

I concentrations less than 1.0 flg/L. Because no PCE was found above the 5 flg/L MCL, the

monitoring frequency remained at the 5 year interval specified in the ROD (the year preceding

the Five Year Review).

I I On the five-year schedule, domestic well samples are analyzed for the same comprehensive suite

of inorganic constituents and VOCs as the monitoring wells. Inorganic constituents in domestic

I well samples collected every 5 years were compared to baseline concentrations of various

constituents derived during the first year of quarterly RA monitoring. If concentrations of the

suite of inorganic constituents (sodium, chloride, sulfate, nitrate, boron, iron, and strontium)

commonly elevated in monitoring wells at the dump indicated substantial increasing trends, or

I PCE is detected above laboratory reporting levels, the EPA could require annual monitoring of

that particular domestic well or all domestic wells for VOCs or possibly other analytes specified

I in the ROD.

I The first 5 year monitoring event occurred in 2008. None of the 2008 samples from monitoring

wells, Seep M, or nearby domestic wells contained detectable quantities of PCE or other volatile

I contaminants of concern listed in the ROD.

I Concentrations of most chemical constituents that were above background levels in the baseline

sampling event (2003-2004) generally were above background levels in the 2008 sampling and,

I with minor exceptions, generally were within historical ranges and overall no substantive

changes or trends were observed.

I I 33

I



No substantial changes in water quality have been observed in monitoring wells, the seep, or

I domestic well samples, and groundwater quality near OU3 appears stable and relatively

unchanged.

I 4.3.4 Institutional Controls (OU3)

I I

Institutional controls have been implemented at OU3 inlayers to enhance the protectiveness of

the remedy. The primary form of institutional control is proprietary control, specifically an



I The City of New Haven, which currently owns OU3 granted to the State of Missouri an

environmental covenant and easement. The environmental covenant is dated April 14, 2008.

I The EPA was named as a third-party beneficiary in this instrument so that EPA has the ability to

enforce the terms of the environmental covenant and easement in addition to the State of

Missouri. This environmental covenant and easement was patterned on the model environmental

covenant and easement found in the Missouri Uniform Environmental Covenants Act (MoECA),

I Mo. Rev.Stat§§260.1 000-260.1 039.

I In addition to the above proprietary control, governmental controls operate as effective

institutional controls at OU3. The MDNR has promulgated regulations pertaining to the location

I and construction of wells. These regulations prohibit the placement ofa well within 300 feet ofa

landfill. This prohibition, found at 10 C.S.R. 23-3.0 I 0, precludes the possibility that any well

I will be located in OU3.

I As described in the Final Operational and Monitoring Plan and Work Plan for Long-term

Monitoring of Operable Unit 3, Riverfront Site, February 2008, site inspections will be

I conducted annually by City personnel. Completion of the annual site inspection checklist will

I provide verification and documentation that the Institutional Controls meet the stated goals in the

ROD.

I I 34

I



A review of institutional controls conducted by USGS and detailed in the OU3 Monitoring report

I (2008) noted:

• The City of New Haven retains ownership of the dump site, but has no specific city

I ordinance restricting use or activities at the facility,

• No written easements with adjacent property owners for access to private wells or for

I monitoring wells for sampling are in place and access continues to be through verbal

agreement,

I • Missouri regulations preventing the placement of wells within 300 feet ofa landfill continue

I to be in force (10 C.S.R. 23-3.0 I0) and general well drilling regulations are in place. The site

is not within the Special Area 3 as described in 10 C.S.R. 23- 3.100(7).

I 4.4 OU4 (Maiden Lane Area)

I 4.4.1 Remedial Action Objectives (OU4)

I The RAOs developed for OU4 soils are:

• For protection of human health - prevent exposure to soils with contaminant

concentrations which result in an excess cancer risk greater than I x I 0-6 or an HQ

I greater than 1.0, whichever is less.

I • For protection of the environment - reduce the soil contaminant levels and

prevent/reduce migration of soil contaminants to the groundwater.

The RAOs developed for OU4 groundwater are:

I • For protection of human health - prevent exposure to groundwater with

contaminant levels greater than MCLs. For those contaminants without

I established MCLs, prevent exposure to groundwater with contaminant levels

which result in an excess cancer risk greater than I x I 0-6 or an HQ greater than

I 1.0, whichever is less.

• For protection of the environment - minimize further degradation of the local

I groundwater by the contaminants at OU4.

I I 35

I



4.4.2 Remedy Selection (OU4)

I The remedial action selected in the ROD for OU4 addresses contaminated soil and groundwater

I in the fractured bedrock and is summarized below.

I Soils - The hazardous substances in the soils at OU4 are tetrachloroethene (PC E),

I trichloroethene (TCE), and vinyl chloride. The remedial action selected to address

these COCs consists of the injection of a chemical oxidant to enhance chemical

I oxidation of the COCs, monitoring, and institutional controls (ICs). The

contaminated soils at OU4 are considered to be "principal threat" wastes because the

I COCs are considered to be mobile source materials. Although contaminated

groundwater also poses a risk, it is not considered a principal threat as defined by the

I Environmental Protection Agency (EPA) guidance. The most highly contaminated

soils in the source area were treated during an EPA-lead removal action conducted in

I 2007. The residual contamination that remains following that removal action will be

addressed as part of the selected remedy through in situ chemical oxidation. The

injection of chemical oxidants will create an in situ reactive zone where the COCs

will be destroyed. This will result in the remediation ofthe soil source area. EPA

I anticipates that ICs will be effective in reducing the potential for exposure to the

contaminated soils during the remedial action and until the remedial action objectives

I (RAOs) for the soils have been achieved. The primary IC for soils will be

informational and educational. EPA, through the five-year review process, will

I continue to periodically inform and educate the owners of the properties where soil

contamination is present of the potential health hazards posed by the COCs.

I Fractured Bedrock Groundwater - The hazardous substances in the fractured bedrock

I groundwater plume are PCE; TCE; cis-I,2-dichloroethene; and trans-l ,2

dichloroethene. Remediation of the contaminated soil source area will eliminate the

I continued migration of contaminants into the groundwater. It is expected that the

groundwater plume will discharge over time into the nearby Missouri River. (Due to

I the large volume of water in the river and the relatively small quantity ofCOCs being

I 36

I



discharged into the river from the plume, the plume contaminants are not detectable

I in the river and do not appear to pose a threat.) With the remediation of the

contaminant source area, the contaminant levels in the groundwater are expected to

I decrease over time to a level that is protective of human health.

I ICs and long-term groundwater monitoring are also components of the selected remedy for the

I groundwater. Currently, there is no unacceptable groundwater or surface water exposures at

OU4. All of the residences and businesses within OU4 are served by municipal water, and there

I are no known wells providing potable water at OU4. OU4 is within an area designated "Special

Area 3" in the MDNR, Division of Geology and Land Survey, Well Construction Code [10

I C.S.R. 23-3.100(7)]. As a result of this designation, well drilling restrictions are in place that

precludes the installation of any well within or near the plume that may result in an unacceptable

I exposure of humans to groundwater contamination. In addition to these restrictions, EPA,

through the tive-year review process, will continue to periodically inform and educate the

owners of the properties where groundwater contamination is present of the potential health

hazards posed by the COCs and the need to comply with state well installation requirements.

I Long-term groundwater monitoring will be conducted by EPA to track COC movement and

I attenuation by physical processes. The monitoring will serve two functions: (I) it will alert EPA

to any changes in plume migration that may result in unacceptable exposures, enabling EPA to

I take action to prevent such exposures; and (2) it will generate data on the expected physical

attenuation of the COCs in the groundwater plume, thus providing information to EPA regarding

I the potential need for additional soil source area response actions and informing EPA and the

state's consideration of the need for continuing ICs for OU4.

I Groundwater monitoring will be accomplished by obtaining groundwater samples from existing

I bedrock monitoring wells and performing laboratory analysis on the samples for COCs.

Provisions will be made for the abandonment of any monitoring wells, pursuant to MDNR

I requirements, at such time as the RAOs are met or a determination is made by EPA that

monitoring is no longer necessary.

I I 37

I



This selected remedial action provides for the overall protection of human health and the

I environment, a "threshold" criterion for remedy selection as set forth in the NCP; however, it

does not meet the second NCP threshold criterion of compliance with ARARs. Due to the highly

I fractured and variable bedrock conditions found at OU4, compliance with all ARARsthrough

I containment, collection, treatment, or other technologies is technically impracticable from the

engineering perspective as well as disproportionately expensive for any potential benefit

realized. As a result, a waiver for certain chemical-specific ARARs is invoked in this ROD.


I The ROD was finalized in March 26, 2009. The design of the remedy is ongoing.


I The selected remedial alternative uses ICs to safeguard against exposures to the contaminated

groundwater. OU4 is within the previously described Special Area 3 defined by the MDNR,

I Division of Geology and Land Survey, Well Construction Code [10 C.S.R. 23-3.100(7)]. As a

result of this designation, well drilling restrictions are in place to prevent the installation of any

I well within an area of groundwater contamination which may create an unacceptable exposure to

humans to such contamination. It is unlikely that new wells would be installed near OU4 since

I municipal water is readily available in that area. The state regulations will ensure that if any new

well construction or well deepening is planned, state officials will be infonned and can prescribe

I methods for ensuring that no exposures to hazardous substances occur. These regulations should

also be effective in preventing the construction of substandard wells which could spread

contamination at or near OU4. The regulations are considered to be durable, as revocation

would require the affirmative action of the state with notification to interested parties.

I In addition to this restriction, EPA intends to continue its efforts to inform and educate the

I owners of the properties where the groundwater contamination is located of the potential health

hazards posed by the contaminants present at OU4 and the need to comply with state well

I installation requirements. It is expected that EPA will continue to provide public education

through the preparation and distribution of fact sheets and/or a newsletter on the Site and by

I providing informational meetings which may be held every five years. The public education

I 38

I



campaign would be intended to inform citizens of the potential health hazards associated with

I exposure to contaminated groundwater and would remind the city officials and residents of the

restrictions on OU4.

I 4.5 OUS (Old Hat Factory)

I 4.5.1 Remedial Action Objectives (OUS)

The RAOs developed for groundwater at OU5 were: (I) minimize contact with the contaminated

I groundwater exceeding PRGs, and (2) ensure that the contaminant levels in the groundwater

and/or the volume of contaminated groundwater do not increase.

I 4.5.2 Remedy Selection (OUS)

I The selected remedy includes regular groundwater monitoring to track contaminant levels in, and

the location of the plume. The selected remedy also utilizes institutional controls which involve

I the use of existing State of Missouri well construction requirements and public education to

prevent human use of the groundwater at OU5. The State of Missouri has enacted well

I construction requirements for Special Area 3, which includes the area where OU5 is located.

These well construction requirements are embodied in regulations found at 10 C.S.R. 23-

I 3.100(7). They provide that MDNR be consulted before any new well is constructed or any

existing well is deepened within Special Area 3.

I I

It unlikely that new wells would be installed near OU5 since municipal water is available in that

area, and there are currently no known wells in use near OU5. The state regulations will ensure

I that if any new well construction or well deepening is planned, state officials will be informed

and can prescribe methods for ensuring that no exposures to hazardous substances occur. These

regulations should also be effective in preventing the construction of substandard wells which

I could spread contamination at or near OU5. The regulations are considered to be durable, as

revocation would require the affirmative action of the state with notification to interested parties.

I I I 39

I

I I


Increases in groundwater contaminant levels, migration of groundwater off-site, and/or

I identification of new sources ofOUS groundwater contamination may result in the

implementation of additional remedial actions.

I I

EPA will also provide public education through the preparation and distribution of fact sheets

and/or a newsletter on OUS and by providing informational meetings which may be held every

I five years. The public education campaign would be intended to inform citizens of the potential

health hazards associated with exposure to contaminated groundwater and would remind the city

officials and residents of the restrictions on OUS.


I The State of Missouri has enacted well construction restrictions referred to as Special Area 3,

which includes the area where OUS is located. These well construction restrictions are

embodied in regulations found atlO Code of State Regulations (C.S.R.) 23-3.100(7). Special

I Area 3 requirements provide that the Missouri Department of Natural Resources (MDNR) be

consulted before any new well is constructed or any existing well is deepened within Special

I Area 3.

I Groundwater monitoring involves collecting and analyzing groundwater VOC samples from five

site monitoring wells including two newly installed wells. Two rounds of sampling results have

I been reported. The data is used to monitor the contamination levels in the plume and determine

if clean up goals (MCLs) are being achieved for the site. The remedy was determined to be

I operational and functional in May 2009 and post-ROD groundwater monitoring is occurring.


I I

The selected remedy utilizes institutional controls which involve the use of existing State of

Missouri well construction requirements and public education to prevent human use of the

groundwater at OUS. As described above, the State of Missouri has enacted well construction

I requirements for Special Area 3, which includes the area where OUS is located. These well

I 40

I



construction requirements are embodied in regulations found at 10 C.S.R. 23-3.100(7). They

I provide that MDNR be consulted before any new well is constructed or any existing well is

deepened within Special Area 3.

I I

It is expected that the EPA will also provide public education through the preparation and

distribution of fact sheets and/or a newsletter on OU5 and by providing informational meetings

I which may be held every five years. The public education campaign would be intended to

inform citizens of the potential health hazards associated with exposure to contaminated

groundwater and would remind the city officials and residents of the restrictions on OU5.

I I

Institutional controls have been implemented in layers to enhance the protectiveness of the

remedy. One of the institutional controls is applicable to several site OUs: Special Area 3, as

I defined in 10 CSR 23-3.100(7), which requires that the MDNR be consulted before construction

a new well in Special Area 3. The MDNR will provide specific guidance on well drilling

protocol and construction specifications on a case-by-case basis. The MDNR will provide

written approval for all new wells prior to construction.

I 4.6 OU6 (Domestic Wells)

I OU6 is undergoing a remedial investigation. Since a remedy has not yet been selected, a review

of protectiveness has not been completed.

I I I I I I I 41

I'

I I

RIVERFRONT SUPERFUND SITE FIVE-'{EAR REVIEW REPORT

I 5.0 Progress Since Last Review

This is the first Five Year Review for the Riverfront Site.

I I I I I I I I I I I I I I I 42

I·

I I


6.0 Five-Year Review Process

I 6.1 Administrative Components

I The five-year review process was conducted by the U.S. Army Corps of Engineers, Phil

I Rosewicz, Greg Hattan, Debra Snodgrass and Amy Darpinian in support of the Region 7

Remedial Project Manager (RPM) for the site, JetT Field.

The Review components included:

• Community Involvement

I • Document Review

• Data Review

I • Site Inspection

• Interviews

I • Five-Year Review Report Development and Review

I 6.2 Community Involvement

Activities to involve the community in the five-year review were initiated with a meeting in May

'I 2009 between the RPM and the Community Involvement Coordinator for the Site. The notice

announcing the commencement of the five-year review process was published in the local

I newspaper on June 3, 2009. On June 5, 2009, a notice stating the same was sent to the local and

state health department, county commissioners, city council members, and other local and state

I officials. A fact sheet was also made available on the EPA's Web site on June 2, 2009.

I 6.3 Document Review

Documents reviewed as part ofthe Five Year Review included the following:

Site-Wide - Documents Reviewed • Missouri Well Construction Rules, MDNR April 2009 (Contains Special Area 3) • Remedial Investigation Administrative Letter Report (USGS, January 200 I)

I • Site Summary, (EPA Region 7, February 2009) • Expanded Site Inspection Report (Jacobs Engineering Group Inc.)

I Operable Unit I - Documents Reviewed • Baseline Risk Assessment, Operable Unit I (Missouri Department of Health (MDOH),

Jan 2003)

I • Actual ACL Calculations, OU I (EPA, July 16, 2003)

I 43

I

I I, RIVERFRONT SUPERFUND SITE


• ROD (EPA, September 30, 2003)

I • Sampling Data Evaluation Report, Spring 2007 (Black & Veatch., January 11,2008) • Final Data Evaluation Report, Operable Unit l(Black & Veatch, November 7,2006) • Interim Remedial Action Report, Operable Unit I (Black & Veatch, June 29, 2007»

I • Final Long-Term Remedial Action Field Sampling Plan (Black & Veatch, March 2007) • Final Winter 2007 Sampling Data Evaluation Report Operable Unit I (Black & Veatch,

June 14,2007) .

I • Final Summer 2007 Sampling Data Evaluation Report Operable Unit I (Black & Veatch, January 18, 2008)

I • Final Spring 2009 Sampling Data Evaluation Report Operable Unit I (Black & Veatch,

September 8, 2009)

Operable Unit I and 3 - Documents Reviewed

I • Focused Remedial Investigation of Operable Units OU I And OU3 (USGS and Black & Veatch, January 2003)

• Feasibility Study Report (Black & Veatch, February 28, 2003)

I Operable Unit 3 - Documents Reviewed • Baseline Risk Assessment, Operable Unit 3 (MDOH, January 2003)

I • ROD (EPA, September 30,2003) • Consent Decree, OU3 (US District Court, Sept 6, 2007)

I • Operational and Monitoring Plan for Operable Unit 3 (Old City Dump) (The City Of

New Haven, January 16, 2007) • 2008 Environmental Monitoring Report For Operable Unit 3 (Old City Dump) (City of

New Haven, October 21, 2008)

I Operable Units 2 and 6 - Documents Reviewed

I • Statement Of Work, Remedial Investigation/Feasibility Study, Riverfront Superfund Site,

Operable Unit No.2 (EPA Region 7) • Revised Final Remedial Investigation/Feasibility Study Work Plan, Operable Unit No.2

(Parsons, February 2, 2006)

I • Final Administrative Order on Consent (AOC) For Whole-House Filtration For Residences

In The South New Haven Area (EPA, March 25, 2002)

I • Figure I, Monitoring and Domestic Well Locations, OU2/0U6 (Parsons, provided by

EPA on July 20, 2009) • Tables I through 4, Summary of Data From Quarterly Sampling (last sampled February

2009), OU2/0U6, (Parsons and provided by EPA on July 20, 2009)

I Operable Unit 4 - Documents Reviewed • Final Human Health Risk Assessment Report, OU4 (Black & Veatch, July 2008)

I • Final Feasibility Study Operable Unit 4 (Black & Veatch, November 12,2008) • Focused Remedial Investigation Of Operable Unit 4 (USGS, September, 2008)

I • Final Fractured Bedrock Technical Impracticability Evaluation Report Operable Unit 4,

(Black & Veatch, January 29, 2009) • ROD, OU4 (EPA Region 7, March 26, 2009)

I 44

I



I Operable Unit 5 - Documents Reviewed • ROD OU5, (EPA Region 7, December 7,2006)

I • Final Long-Term Remedial Action Field Sampling Plan OU5 (Black & Veatch,

September 26,2007) • Baseline Human Health Risk Assessment For OU5 (Missouri Department Of Health,

January 2006)

,I • Final Fall 2008 Sampling Data Evaluation Report OU5 (Black & Veatch, April 13,2009) • Focused Remedial Investigation ofOU5 (USGS, June 2006) • Feasibility Study OU5 (Black & Veatch, June 27, 2006)

I 6.4 Data Review

I Data reviewed for the five year review consisted of the following:

OUI

I For OU I groundwater data, the sampling commencing after the RI (July 23,2002) until current

(Sept. 8, 2009), and the remedial action vapor system results from start-up (June 2, 2005) until

I current (Sept. 8, 2009) were described in the Final Spring 2009 Sampling Data Evaluation

Report Operable Unit I (Black & Veatch, September 8, 2009).

I OU2

OU2 and OU6 monitoring well data was summarized in the RIIFS work plan, including

I groundwater treatment plant discharge, soil, surface water, sanitary sewer, tree core, and RWI

sampling conducted in December 2004 and February 2005. The Revised Final RIfFS Work Plan,

I Operable Unit No.2 was prepared by Parsons and dated February 2, 2006.

I OU3

For OU3 groundwater data, the sampling beginning with the LTM (2003-2004) through current

I May 21, 2008 was described in the 2008 Environmental Monitoring Report For Operable Unit 3

(Old City Dump) (City of New Haven, October 21,2008).

I OU4

I OU4 sample data reviewed was from the tree cores (2000-2007), surface water and springs

(2000-2005), well water (2000-2007), soil (2001-2005), sanitary sewer samples (2001-2004),

I I 45

I,

I I


and indoor air (2002-2004). All these data are in the Focused Remedial Investigation of

I Operable Unit 4 (USGS, September 2008).

I OUS

I OU5 data was found in the Final Fall 2008 Sampling Data Evaluation Report OU5 (Black &

Veatch, April 13,2009) which included historical PCE data from 2004 through 2008 for site

I COCs. RI data for soil (2001-2003), groundwater (2002-2005), sanitary sewer (2002-2004), and

stream sampling (2000-2005) was found in the Focused Remedial Investigation ofOU5 (USGS,

June 2006).

I I OU6

OU2 and OU6 monitoring well data was summarized in the RIIFS work plan, including

groundwater treatment plant discharge, soil, surface water, sanitary sewer, tree core, and RWI

sampling conducted in December 2004 and February 2005. The Revised Final RIfFS Work Plan,

I Operable Unit No.2 was prepared by Parsons and dated February 2,2006. OU6 quarterly data

from Jan 15,2002 through current (Feb 25,2009) was provided by EPA as Quarterly Residential

I Summary data tables.

I 6.S Site Inspection

I A site inspection was held on June 23, 2009. All six OUs were visited. Participants in the site

inspection included Jeff Field, EPA Region 7 RPM for the site, Evan Kifer, MDNR PM for the

I site, Rob Blake, an employee of Black & Veatch, EPA's consultant for the site and Phil

Rosewicz, Greg Hattan, Debbie Snodgrass and Amy Darpinian from USACE Kansas City

I District. A tour ofOU2 and OU6 was provided by Lee Gorday, an employee of Parsons

Environmental, the consultant for the PRP. Site Photographs and Site Inspection Checklists can

I be found in Attachment I and 2.

6.6 Interviews

I Interviews were conducted during the site visit for OU I, OU3, OU4 and OU5 where remedies

have been selected. OU2 and OU6 do not have remedies selected to be reviewed. Those

I I 46

I



interviewed included Rob Blake and Evan Kifer. A brief summary of these interviews is

I provided below:

I Individual Interviewed: Evan Kifer - PM for MDNR

Mr. Kifer was interviewed regarding about OUI, OU3, OU4 and OUS. Mr. Kifer had no

I concerns regarding these OUs. He indicated that he has been kept well informed and

information had been provided in a timely manner.

I Individual Interviewed: Rob Blake - Black & Veatch Employee and EPA's Consultant for

the Site.

I Mr. Blake was interviewed concerning OU I and OUS. Mr. Blake felt the remedy at OU I was

I functioning adequately and groundwater monitoring at OUS is effective assessing the migration

of the plume.

I I I I I I I ·1 I I 47

I


FIVE-'lEAR REVIEW REPORT

I 7.0 Technical Assessment

I The Five Year Review must determine whether the remedy at a site is protective ofhumim health

I and the environment. The EPA guidance describes three questions used to provide a framework

for organizing and evaluating data and information and to ensure all relevant issues are

I considered when determining the protectiveness ofa remedy. These questions are assessed in

the following paragraphs for OU I, OU3 and OU5 where remedies have been selected and

I implemented. No remedies have been selected for OU2 or OU6. The OU4 remedy has recently

been selected but not yet implemented. At the end of the section is a summary of the technical

assessment.

I 7.1 OPERABLE UNIT 1 (Front Street)

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

Yes, the remedial action is functioning as intended.

I • Remedial Action Performance (OUt) and Monitoring Results

I The Remedial Action ofOU I is operating as designed; however, current subsurface and

I mechanical conditions, as described in previous sections, prevent the system from operating as

efficiently or effectively. The ROD called for a combination of institutional controls to control

I exposure to shallow aquifer and soil consisting of proprietary controls, an environmental

covenant and easement; installation of an ART well and associated equipment, and additional

monitoring wells and follow up sampling to monitor the plume. The OU I remedy was declared

I to be O&F on November 2,2005. The remedial system has operated approximately 73 percent

of the time since initial start up. All groundwater concentrations are below the ACLs, so the

I system is meeting the performance goals. Total air effiuent concentrations are below regulatory

levels under the Missouri Air Pollution Program.

I The selected remedy (ART well) has been put in place and OU I is in the L TRA phase ofthe

cleanup process. On-going sampling is being conducted as described in the Final Long-Term

I I 48

I



Remedial Action Field Sampling Plan (FSP) for Riverfront Site, au I (March 2007). During the

I quarterly and bi-annual sampling events, groundwater and soil gas samples are collected using

the procedures outlined in the L TRA FSP. During the winter sampling events, when the river's

I level is usually lowest, the Missouri River samples are collected. The contaminant concentration

I in groundwater samples from nearby monitoring wells has fluctuated overtime. The fluctuations

in contaminant levels appear to correlate with the fluctuations of water table due to changes in

the river stage.

I I

The most recent data available for this review was the Spring 2009 Sampling Data report dated

September 2009. Because the river samples are only collected in winter, that data was captured

I in the Winter 2007 Sampling Data report dated June 2007. The Missouri River sampling results

for all samples (upstream and immediately downstream) continue to be all non-detect for the site

cacs.

I • System Operations and Maintenance (OUI)

The ART well has been active for over four years. The system has been operational for about

I three out of the last four years and has operated at less than optimal performance due to

fluctuations in the groundwater levels. The system is currently not operational due to an issue

I with the groundwater pump.

I Soil vapor extraction flow is dependent on the geology, the depth to water, the amount of

I exposed screen, and the radius of influence of the vacuum induced by the blower. When the

water table goes down, more of the screen is exposed, hence, there is an increase of flow from

the formation, and the system will operate more effectively. Early in the operational period this

I was the case. Conversely, when the water table is high, the amount screen in the unsaturated

I zone is decreased and the efficiency and effectiveness are reduced. The amount of vacuum from

the blower also enters into the equation as there is a direct correlation to the amount of vacuum

I and a resulting rise in the water table within the borehole caused by this vacuum. When the

elevated water table impedes flow through the screen, either from a high water table, high

vacuum, or a combination of both, the SVE system will not function as designed. A review of

I historical groundwater level measurements indicates that the screened interval was occluded

I 49

I



during the sampling period for 3 quarters out of the last 6 quarters (5/22/2007 event, 611712008

I event, and 5/26/2009 event). It is likely the SVE portion of the system functioned at a reduced

rate or was not functional during this period. The entire system has been down since the Fall of

I 2008.

I Despite the reduced effectiveness of the ART system, the overall monitoring well analytical data

I over the remedial period indicates that contamination levels of the entire plume is less than the

ACLs.

I • Early Indicators of Potential Issues (OU I)

Research for this FYR located data and correspondence regarding the follow-on vapor intrusion

I studies. The results have not been formally documented in the administrative record.

I • Implementation ofInstitutional Controls and Other Measures (OUI)

Institutional controls, implemented in layers, were placed at the site. These include a deed

I restriction PPA which requires I) use of the site only for surficial uses, 2) not to conduct any

I activities which would disturb contaminated soils, and 3) not place any well that would penetrate

groundwater. In addition to the deed restriction, MDNR placed a restriction on drilling new

I wells in the area, and the City of New Haven has a restriction which controls subsurface

excavations, borings, or wells within 500 feet of the flood control levee. All ofOU I is within

the restricted area.

I I The ROD for OU I specifies that quarterly groundwater monitoring is to be conducted for the

first two years followed by semi-annual monitoring. ACLs, also a component ofthe selected

remedy, were calculated with the first two years of sampling results from downgradient wells

along with sample results from the RI. The current measured groundwater concentrations are

I well below the established ACLs. Since the release was many years ago and there is no expected

future source of contamination, the groundwater concentrations should remain below these

I levels.

I I 50

I



I Question B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial

-I action objectives (RAOs) used at the time of the remedy selection for OUt still valid?

Yes, the assumptions are still valid.

• Changes in Exposure Pathways (OUt)

.1 The human health baseline risk assessment (HHRA) evaluated receptors for potential exposures

to contaminants in groundwater and soil. Future residents were assumed potentially exposed

J through the following pathways: ingestion of COPCs in groundwater used as a

potable/household water source; dermal contact with COPCs in water while showering;

I inhalation of vapors while showering; incidental ingestion of mixed contaminated soil at the

surface; dermal contact with mixed soil, and inhalation of vapors and particulates from mixed

I soil. Current and future full-time workers were evaluated for ingestion ofCOPCs in

groundwater and for exposures to soil through ingestion, dermal contact, and inhalation of

I vapors and particulates. Current trespassers and future recreationists were evaluated for surface

I soil exposures through incidental ingestion, dermal contact, and inhalation exposure pathways.

Future construction/utility workers were assumed exposed to subsurface soil through incidental

I ingestion, inhalation of vapors and particulates, and dermal contact exposure pathways. The

HHRA used standard default values for exposure parameters (e.g., ingestion, inhalation rates,

I exposure frequency and duration, etc.) and accepted statistical and modeling methods to estimate

exposure point concentrations (EPCs) that, when combined, resulted in conservative, reasonable

I maximum exposures (RMEs) for each exposure pathway. No change to these potential exposure

pathways was identified that would result in greater exposure opportunity than what was

I evaluated in the HHRA. In fact, with implementation of institutional controls, these exposure

pathways become incomplete.

One pathway not evaluated in the HHRA was potential inhalation of vapors migrating from

I subsurface contamination and entering the breathing zone of a building. The HHRA (September

2003) identified two residences northeast ofOU 1 and stated that indoor air sampling studies for

I OU I were inconclusive and ongoing. PCE was not detected in indoor air in one of the homes

and measured at 590 ~lg/m3 in the basement air ofthe other. The ROD acknowledged ongoing

I studies and stated that response measures would be implemented through a CERCLA removal

I 51

I



action if necessary to reduce risk concluded from this pathway.

I Research for this FYR located data and email correspondence regarding the follow-on vapor

I intrusion studies. Additional sampling occurred in July 2003 at the two residences. On August

26,2003 the Riverfront site team met with representatives from the EPA Vapor Intrusion team to

I evaluate the indoor air results. Indoor air sampling results for one of the homes repeatedly

I showed no PCE contamination; PCE was again measured in the other. However, the joint team

concluded that the previously elevated detection of PCE in the basement air likely represented a

I concentration based on a source material within the residence and that the second round of data

represented indoor air after the homeowner removed the source. It was found unreasonable to

I conclude that subsurface sources were contributing to the concentration measured in the living

room (i.e., 29 /lg/m3), since the two basement sample results were much lower, 3 L (L meaning

I biased low) and 1.7 /lg/m3. Variations in the indoor air results were attributed to cleaning

solutions, dry cleaning, or other household products. The team concluded that no emergency

I existed at the residence and there was no need to remediate at the time. The team recommended

additional sampling for a year to evaluate seasonal variations. The indoor air sampling results

and joint team meeting conclusions have not been formally documented.

I As discussed in Section 7.1, institutional controls are currently preventing exposure to OU I

contaminated groundwater and surface soils. These controls should also prevent future exposure

I to the contaminants in both media.

I • Changes in Land Use (OUI)

I There have been no changes in land use that impact the protectiveness of the remedy. Land use

is zoned "light industrial" by the City of New Haven. With the layered institutional controls in

I place, changes in land use that might result in potential exposures to contaminated groundwater

or soil are restricted.

I • Changes in Standards, Newly Promulgated Standards, TBCs (OUI)

I EPA determined for the ROD that OU I conditions met the criteria to allow Alternate

I 52

I



Concentrations Levels (ACLs) to be established for groundwater chemicals of concern - PCE,

I TCE, VC, and benzene - after two years of monitoring data were collected.

I For soil, Cleanup Levels for Missouri (CALM) for Scenario A (residential) were identified for

arsenic (II mg/kg) and indeno(J ,2,3-cd)pyrene (3 mg/kg), respectively. CALM was never

I promulgated by the state and subsequent to-be-considered (TBC) criteria are found in Missouri

I Risk-Based Corrective Action (MRBCA) guidance. Comparable levels in MRBCA to Scenario

A levels in CALM are for residential land use - Soil Type I (sandy), which are 3.89 mglkg for

I arsenic and 3.77 mg/kg for indeno(1 ,2,3-cd)pyrene. MRBCA levels for industrial land use - Soil

Type I (sandy) are 15.9 mg/kg for arsenic and 12.8 mg/kg for indeno(1 ,2,3-cd)pyrene. EPCs for

I surface and subsurface soil listed in the ROD indicate that neither arsenic or indeno( I ,2,3

cd)pyrene are above the MRBCA guidance values.

I • Changes in Toxicity and Other Contaminant Characteristics (OUI)

I Since the time of the OU I HHRA, there have been changes in published toxicity values for PCE,

I TeE, benzene, and the polynuclear aromatic hydrocarbons (PAHs). While some toxicity values

now indicate greater health concerns, others indicate less. However, changes do not impact the

overall protectiveness ofthe remedy since institutional controls require any land use to be

consistent with the remedy and thus exposure pathways are incomplete.

I Although the inhalation data summarized for the HHRA differ from currently published values

I for PCE and TCE, information found on the evaluation of indoor air samples collected in July

2003 indicates that toxicity values used by the EPA indoor air workgroup are likely the same as

I those currently published. For example, the level of PCE considered acceptable in reviewing the

indoor air results was 0.3 micrograms per cubic meter (llg/m3) based a one-in-a-million excess

I cancer risk. This compares to 0.4 Ilg/m3 allowable level based on the inhalation cancer unit risk

factor currently used.

I I I 53

I



• Changes in Risk Assessment Methods (OUI)

I I

In July 2004, EPA finalized Risk Assessment Guidance for Superfund (RAGS): Volume I -

Human Health Evaluation Manual, Part E, Supplemental Guidance for Dermal Risk Assessment.

I There were no significant changes from the interim guidance followed in conducting the OU 1

HHRA.

I In January 2009, EPA issued RAGS: Part F, Supplemental Guidance for Inhalation Risk

I Assessment. The intent of Part F is to achieve consistency between how inhalation exposure

concentrations are estimated and how inhalation toxicity values are developed. The use of

RAGS Part F would result in slightly lower estimated health risks, thus slightly higher allowable

screening levels.

I No other changes to exposure factors and risk assessment methods have been identified that have

I an impact on the protectiveness of the remedy.

I Question C: Any Other Information That Could Call Into Question the Protectiveness of

the Remedy?

I • Ecological Risks (OUI)

I The ecological risk assessment (ERA) conducted in 2002 for the entire Riverfront Site complied

with the latest methodology, "Ecological Risk Assessment Guidance for Superfund: Process for

I. Designing and Conducting Ecological Risk Assessments" (EPA 1997). The ERA considered

stream sediment and surface water in the Missouri River as direct contact media for exposure to

I chlorinated solvents and hydrocarbons. Chemical-specific ecological screening values (ESVs)

for sediment were compared to the results of river sediment samples. Of the few concentrations

I of toluene detected, none was above the ESVs. Chemical-specific ESVs for surface water were

compared to the results of river water samples, and again, the few concentrations of toluene

I detected were below the ESVs. The ERA concluded that there were no significant ecological

I risks posed by these media. Also assessed was a food chain ingestion model for herbivores

consuming contaminated vegetation. The results of tree core samples, analyzed with a portable

I 54

I



GC, were converted to average daily doses for representative mammal and bird species. The

I doses were compared to wildlife ESVs and it was concluded that there were insignificant risks

posed through the food chain pathway.

I The 2006 and 2007 annual Missouri River sampling events show all VOCs continue to be

I nondetect in surface water; similar results would be expected for river sediments due to mass

I balance and chemicophysical properties ofVOCs. Additionally, since contaminant mass

continues to be reduced in soil and groundwater at OU I, tree uptake of VOCs would be expected

I to decline. Based on a review of this most recent data, the conclusions of the 2002 ERA remain

current and valid.

I There is no other information known that could call into question the protectiveness of the

remedy.

I 7.2 OPERABLE UNIT 2 (Kellwood Industries)

I OU2 is undergoing a remedial investigation. Since a remedy is not in place, no evaluation of

protectiveness has been conducted.

I 7.3 OPERABLE UNIT 3 (Old City Dump)

I Question A: Is the remedy functioning at OU3 as intended by the decision documents?

Yes, the remedy is functioning as intended.

I • Remedial Action Performance and Monitoring Results (OU3)

I Institutional controls have been implemented at OU3in layers to enhance the protectiveness of

the remedy. The primary form of institutional control is proprietary control, specifically an



I The City of New Haven currently owns OU3. The City of New Haven granted to the State of

Missouri an environmental covenant and easement. The environmental covenant is dated April

I 14,2008. The EPA was named as a third-party beneficiary in this instrument so that EPA has

I 55

I



the ability to enforce the terms of the environmental covenant and easement in addition to the

I State of Missouri.

I The MDNR has promulgated regulations pertaining to the location and construction of wells.

These regulations prohibit the placement of a well within 300 feet of a landfill. This prohibition,

I found at 10 C.S.R. 23-3.0 I 0, precludes the possibility that any well will be located in OU3.

I Implementation of the LTM began in 2003 when the EPA installed three additional monitoring

I wells (BW-31, BW-31 A, and BW-32) at the site followed by I year of quarterly monitoring of a

seep, monitoring wells, and the collection of baseline water-quality samples from four nearby

I domestic wells. The ROD specified that ifPCE concentrations in groundwater samples

remained below the MCL of 5 /!glL after the conclusion of I year of quarterly sampling,

I sampling would be reduced to every 5 years. Because PCE was not detected above the MCL

during the 2003-2004 quarterly monitoring, sampling decreased to once every 5 years. None of

I the May 2008 samples from monitoring wells, Seep M, or nearby domestic wells contained

detectable quantities of PCE or other volatile contaminants of concern listed in the ROD.

Concentrations of most chemical constitutes that were above background in baseline sampling

I (2003-2004) generally were above background in the May and August 2008 sampling, and with

I minor exceptions, generally were within historical ranges and overall no substantive changes or

trends were observed. The trace elements antimony and boron contributed to the potential

human health risk at OU3 (EPA, 2003a) and, as such, are important constituents for long-term

I monitoring of the site. The concentration of antimony in the May 2008 sample from Seep M

I (15.7 /!g/L) exceeded the 6/!g/L MCL. Antimony concentrations in several previous samples

from this seep also exceeded the MCL, with a maximum concentration of 82 /!g/L detected in the

I initial sample from 1999. Antimony has been detected only in one other sample from OU3 and

that was 4 /!g/L in the December 2003 sample from monitoring well BW-03. The reporting level

for antimony decreased from I /!g/L to 0.1 /!g/L in 2008, and the absence of detections in

I samples from sites other than Seep M during 2008 indicates antimony has not migrated beyond

its extent since long-term monitoring began in 2003. Boron concentrations in all 2008

I monitoring well samples and both Seep M samples exceeded background levels with the largest

I 56

I



concentration in the sample from Seep M (1,600 Ilg/L) followed by 455 ~lg/L in the sample from

I BW-31 and 379 Ilg/L in the sample from BW-03_ Although substantially above background

levels, boron concentrations in samples from May 2008 were within historical ranges in

I monitoring well and Seep M samples, but slightly higher in domestic well JS-28. The May 2008

sample from JS-28 contained boron at 13.2 IlglL as compared to 10 Ilg/L in April 2003. This

I increase is slight and likely within natural variability or possibly analytical or sampling error,

and not related to effects from OU3.

I I

• Early Indicators of Potential Issues (OU3)

No written easements with adjacent property owners for access to private wells.or monitoring

I wells for sampling are in place and access is granted through verbal agreements prior to

sampling.

I • Implementation of Institutional Controls and Other Measures (OU3)

Institutional controls prescribed in the ROD are in place.

I I Question B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial

action objectives (RAOs) used at the time of the remedy selection for OU3 still valid?

Yes, the assumptions are still valid.

I • Changes in Exposure Pathways (OU3)

I The HHRA for OU3 was completed in 2002 and assessed hypothetical exposure pathways

assuming potable/domestic use of groundwater. Current residential exposure was assessed for

I ingestion of inorganics detected in a domestic well located just west ofOU3. A future

residential scenario assessed the following exposure pathways as complete: ingestion ofCOPCs

I in groundwater, dermal contact and vapor inhalation while showering. A future worker scenario

included ingestion of contaminants in groundwater. There were no exposure pathways evaluated

I for soil; based on the tree coring data, it was concluded in the RI that soil was not the source of

peE groundwater contamination for the Riverfront Site.

I I 57

I



The environmental covenant eliminated exposure opportunities to groundwater by prohibiting

I placement of groundwater wells on the property, and minimized exposure opportunities to soil

by limiting disturbance.

I Note that the HHRA did not quantify potential risk from recreational exposure to ephemeral seep

I water since contact would be sporadic and incidental. This exposure pathway was considered

incomplete. This conclusion remains valid.

I • Changes in Land Use (OU3)

I There have been no changes in land use that would impact the protectiveness of the remedy.

Currently, the Old City Dump is used for surface disposal of trees and yard waste. This land use

I is consistent with the environmental covenant filed at the Franklin County Recorder of Deeds

office on April 14, 2008, limiting disturbance of contaminated soils and prohibiting placement of

I groundwater wells on the property. Missouri regulations restrict placement of wells within 300

feet ofa landfill, which assures that groundwater use immediately downgradient ofOU3 will not

I change. There are no controls beyond 300 ft that would prevent future changes in land or water

I use.

• Changes in Standards, Newly Promulgated Standards, TBCs (OU3)

Federal MCLs were listed in the ROD as standards for antimony (6 ~g/L), nitrate (I 0,000 ~glL),

I and PCE (5 ~g/L). The standard listed for manganese (50 ~g/L) was taken from Missouri 10

CSR 20.7, Water Quality Criteria for Designated Uses. For boron, a TBC value of 600 ~g/L was

I set based on the Federal Lifetime Health Advisory Level. The basis for the listed concentrations

has not changed and there are no newly promulgated standards for these chemicals.

I • Changes in Toxicity and Other Contaminant Characteristics (OU3)

I Since OU3 HHRA was completed, there have been changes in published toxicity values for PCE.

However, changes to toxicity values for PCE do not impact the protectiveness of the remedy

I since there have been no recent detections of PCE. Toxicity values for antimony, boron,

manganese, and nitrate have not changed. While the MCL for antimony was listed in the ROD,

I the allowable tapwater level based on current toxicity information is 0.66 ~g/L to protect to a one

I 58

I



in a million excess risk leveL

I • Changes in Risk Assessment Methods (OU3)

I I

There were no significant changes in risk assessment methodologies that would affect the

protectiveness of the remedy_ While EPA finalized Risk Assessment Guidance for Superfund

I (RAGS): Volume I - Human Health Evaluation Manual, Part E, Supplemental Guidance for

Dermal Risk Assessment in July 2004, there were no significant changes from the interim

guidance, which was followed in the OU3 HHRA (EPA 2003)_


the Remedy at OU3?

I I

• Ecological Risks (OU3) The ecological risk assessment (ERA) conducted in 2002 for the entire Riverfront Site complied

I with the latest methodology, "Ecological Risk Assessment Guidance for Superfund: Process for

Designing and Conducting Ecological Risk Assessments" (EPA 1997). For OU3, analytical

I results were evaluated for the sediment and surface water samples collected from the drainage

located to the north. No chlorinated ethenes or other contaminants were detected in either media;

therefore, it was concluded that neither media posed significant ecological risks. PCE, cis-DCE,

benzene and toluene were detected in tree core samples at OU3 and the estimated average daily

I doses for the representative mammal and bird species were compared to ESVs. Based on this

comparison none of these VOCs was present at levels that indicated significant risk to

I herbivores. The overall conclusion of the ERA was that risks were minimal at OU3.

I As previously discussed, the first five-year monitoring event for OU3 occurred in 2008. None of

the samples from groundwater or seep water contained detectable quantities of peE or other

I VOCs of concern listed in the ROD. Based on a review of these results, the conclusions of the

2002 ERA remain current and valid.

I I

There is no other information known that could call into question the protectiveness of the

remedy.

I 59

I



I 7.4 OPERABLE UNIT 4 (Maiden Lane Area)

I OU4 recently had a remedy selected, but the remedy is not yet in place. Since a remedy is not in

place, no evaluation of protectiveness has been conducted.

I 7.5 OPERABLE UNIT 5 - OLD HAT FACTORY

I Question A: Is the remedy functioning at OU5 as intended by the decision documents?

Yes, the remedial action is functioning as intended.

I • Remedial Action Performance and Monitoring Results (OU5)

I The ROD was signed in December 2006. The ROD documented that while the groundwater

I below OUS was contaminated, the risk could be addressed with institutional controls and

monitoring.

I The selected remedy utilizes institutional controls which involve the use of existing State of

I Missouri well construction requirements and public education to prevent human use of the

groundwater at OUS. The State of Missouri has enacted well construction requirements for

Special Area 3, which includes the area where OUS is located. These well construction

requirements are embodied in regulations found in 10 C.S.R. 23-3.100(7) and provides that

I MDNR is to be consulted before any new well is constructed or any existing well is deepened

within Special Area 3. The MDNR will provide specific guidance on well drilling protocol and

I construction specifications on a case-by-case basis. The MDNR will provide written approval

for all new wells prior to construction.

I Groundwater sampl ing and analysis was conducted in the Fall of 2008 as part of a formal

I monitoring program for LTRA efforts to evaluate the contamination levels present at OUS. The

extent of contamination in groundwater at the OUS site was evaluated from the monitoring wells

I on site. The three original wells (BW-9, -9A, and -12A) were sampled at one interval. The two

wells installed for the LTRA, BW-IS and BW-16, were sampled at multiple intervals. The wells

I were sampled and analyzed for the presence of VOCs: the COCs at the site are PCE, Carbon

I 60

I



Tetrachloride (CT), and chloroform. During the Fall 2008 event, PCE and CT were detected, but

I chloroform was not. Trichloroethene was also detected in one well. All other VOCs that were

analyzed for in the samples were non-detect.

I The PCE concentration in BW-9A has fluctuated since sampling began in July 2002. The

I variation in PCE data could be related to precipitation events because there appears to be perched

water at BW-9A. The Fall 2008 water level at BW-9A was 4 feet higher than at BW-12A and 34

I feet higher than at BW-16, which is located approximately 150 feet north of BW-9A.

I Samples from BW-16 and BW-9A contained PCE above its MCL of5 Ilg/L. PCE was not

detected in the background well, BW-15, or in the sidegradient well, BW-12A. The BW-9A PCE

I concentration was 30 IlglL and was collected at 40 ft btoc. The BW-16 PCE concentrations were

27 and 32 Ilg/L, collected at 73 and 76 ft btoc, respectively. The PCE concentration in the Fall

I 2008 sample was similar to, although a bit lower than, the concentrations in the grab sample

collected from BW-16 in January 2008, 49 Ilg/L. PCE was also detected in BW-9 at 0.59 Ilg/L at

I 166.1 ft bgs which was below the PCE MCL. The carbon tetrachloride concentration in BW-16

was 7.7 Ilg/L and 8.8 Ilg/L at depths of 73 and 76 ft btoc, respectively. These concentrations

I exceed the 5 Ilg/L MCL for CT. As expected, the installation of BW-15 has provided a

background well that does not contain any ofthe OU5 COCs.

BW-16 was installed in an attempt to define the downgradient end of the plume. However, the

I initial COC concentrations indicate the plume extends beyond the location of BW-16. The exact

flow path to and from BW-16 is unknown due to the highly weathered bedrock encountered as

I BW-16 was installed and the unknown nature of the fracture and joint system in the bedrock.

I The ongoing monitoring appears to adequately track contaminant levels in, and the location of

the plume. However, the downgradient end of the plume has not been defined. During the site

I inspection, it was pointed out that installation of additional downgradient wells is not possible

due to a steep drop in elevation at the site boundary. OU5 is also within the boundary ofOU4

I which has a technical impracticability waiver for certain chemical-specific ARARs within the

fractured bedrock.

I I 61

I



• Opportunities for Optimization (OU5)

I The OUS remedy should continue to be monitored as described in the ROD.

I • Early Indicators of Potential Issues (OU5)

The ROD called for sampling biannually (twice per year) for the first and second years and then

I annually for the next three years to provide data during the first five-year review for OUS. After

the first five-year review, monitoring efforts would then be scaled back to one sampling round

I every five years to provide a current data set for the next five-year review. The timing of the

I LTRA sampling events has changed such that the first biannual sampling event was conducted in

Fall 2008. In lieu of making any premature changes to the ROD, it is recommended that the

I 2007 LTRA Field Sampling Plan and Quality Assurance Project Plan be followed until the 2nd

FYR and then monitoring efforts can be scaled back to annually if the data indicates this is

I appropriate. In accordance with the ROD, increases in groundwater contaminant levels,

migration of groundwater off-site, and/or identification of new sources ofOUS groundwater

contamination could result in the implementation of additional remedial actions.

I • Implementation of Institutional Controls and Other Measures (OU5)

The institutional controls that were put in place as described in the ROD minimize future contact

I with the contaminated groundwater exceeding PRGs.

I Question B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial

action objectives (RAOs) used at the time of the remedy selection for OU5 still valid?

I Yes, the assumptions are still valid.

I • Changes in Exposure Pathways (OU5)

The 2006 HHRA assessed potentially completed exposure pathways to COPCs in soil and

I groundwater. Current workers and future residents, workers, and construction workers were

assumed exposed through ingestion, dermal contact, and vapor inhalation pathways. Vapors that

I may intrude into buildings were modeled from groundwater, and vapors that could migrate into

the breathing zone of outdoor workers were modeled from soil. Since public water is currently

I available, only future residents and workers were assumed to use groundwater as a potable or

I 62

I

I I


domestic source.

I There have been no known changes in exposure pathways since the time of the OU5 HHRA.

I • Changes i!l Land Use (OU5)

I There have been no changes in land use since completion of the HHRA. Most of the old hat

factory buildings have been torn down with the exception of the historic opera house section,

I which has been undergoing renovation. Future land use is expected to remain commercial.

I OU5 is within an area designated by Missouri as Special Area 3 under the Well Construction

Code [I OC.S.R. 23-3.100(7)]. This designation restricts well drilling and is designed to preclude

I the installation of wells within an area of groundwater contamination. In addition to this

restriction on groundwater use, institutional controls in the ROD include continued efforts by

I EPA to inform and educate property owners where groundwater contamination is located and the

associated potential health risks from exposure.

I • Changes in Standards, Newly Promulgated Standards, TBCs (OU5)

I PCE was the risk driver. Its MCL is 5 Ilg/L. The only other contaminants in groundwater that

contributed to excess cancer risk above one-in-a-million (I X 10-6) were carbon tetrachloride and

I chloroform. The MCL for carbon tetrachloride is 5 Ilg/L. The MCL and MCL goal were both

listed for chloroform, 80 Ilg/L and 70 Ilg/L. The former applies to total trichloromethanes that

I may be detected in water. These standards have not changed and there are no newly

promulgated standards.

I Since there were no signiticant risks from exposures to soil, there were changes to be evaluated.

I • Changes in Toxicity and Other Contaminant Characteristics (OU5)

I An oral slope factor from CalEPA is now available for assessing ingestion/dermal exposures to

chloroform. The EPA Regional Screening Level (RSL) (April 2009) of 0.19 Ilg/L for screening

I tap water is based on this slope factor. The only detection in groundwater at OU5 was 0.29

I 63

I



~lg/L, and this concentration was qualified with a J, meaning it was estimated. Considering the

I MCL for chloroform is identified in the ROD, this change in available toxicity information has

no impact on the protectiveness of remedy.

I • Changes in Risk Assessment Methods (OU5)

I I There were no significant changes in risk assessment methodologies that would affect the

protectiveness of the remedy. While EPA finalized Risk Assessment Guidance for Superfund

(RAGS): Volume I - Human Health Evaluation Manual, Part E, Supplemental Guidance for

Dermal Risk Assessment in July 2004, there were no significant changes from the interim

I guidance, which was followed in the OU3 HHRA (EPA 2003).


the Remedy at OU5?

I • Ecological Risks (OU5)

I The ecological risk assessment (ERA) conducted in 2002 for the entire Riverfront Site complied

with the latest methodology, "Ecological Risk Assessment Guidance for Superfund: Process for

I Design ing and Conducting Ecological Risk Assessments" (EPA 1997). Since OU5 was not

identified as a potential source area of contamination at the time of the ERA, the 2006 OU5 RI

I compared OU5 data to that collected from OU 1, which is located within 500 yards. Data from

the Missouri River samples and the absence ofVOC detections in surface water samples

I collected from creeks located near OU5, supported the conclusion that there were no significant

ecological risks being posed from surface water in the vicinity ofOU5. The food chain

I modeling conducted for the 2002 ERA was also assessed in the 2006 OU5 RI. Since

concentrations of VOCs in soil and groundwater were considerably less than those detected at

I OU 1, it was reasonable to expect that there would be less contamination and therefore no

significant risk to herbivores at OU5.

I I I 64

I



Recent groundwater monitoring results show VOCs less than those detected at OU I during the

I time in which the 2002 ERA was conducted. Therefore, the conclusions drawn from the 2002

ERA and the 2006 OU5 ERA update remain current and valid.

I I

There is no other information known that could call into question the protectiveness of the

remedy.

I 7.6 OPERABLE UNIT 6 (Domestic Wells)

OU6 is undergoing a remedial investigation. Since a remedy is not in place, no evaluation of

I protectiveness has been conducted.

I 7.7 Technical Assessment Summary


The OU I remedy was declared to be Operational and Functional (O&F) on November 2,2005.

I All groundwater concentrations are below the ACLs so the remedy is meeting the performance

goals. The ROD called for a combination of institutional controls to restrict exposure to shallow

I aquifer and soil, proprietary controls, an environmental covenant and easement, installation of an

Advanced Remedial Technology (ART) well and associated equipment, and extension of the

I monitoring well network to monitor the plume. Institutional controls have been implemented.

The ART well has been operational for about 3 of the past 4 years and it appears that it has been

I effective when operational.

I The exposure assumptions, toxicity data, cleanup levels, and remedial action objectives (RAOs)

used at the time of the remedy selection for OU I are still valid. No change to potential exposure

I pathways was identified that would result in greater exposure opportunity than what was

evaluated in the HHRA. In fact, with implementation of institutional controls, these exposure

I pathways become incomplete. There have been no changes in land use that would impact the

protecti veness of the remedy.

I I 65

I



OU2 (Kellwood Industries)

I No remedy has been selected. However, OU2 is within Special Area 3 and is therefore already

protected by an institutional control which restricts future well installations.

I I

OU3 (Old City Dump)

The remedy is functioning as intended. Institutional controls have been implemented at OU3 to

I enhance the protectiveness of the remedy. The City of New Haven granted to the State of

Missouri an environmental covenant and easement. The environmental covenant is dated April

14,2008.

I The ROD specified that if PCE concentrations in groundwater samples remained below the MCL

of 5 flg/L after the conclusion of I year of quarterly sampling, sampling would be reduced to

I every 5 years. Because PCE was not detected above the MCL during the 2003-2004 quarterly

monitoring, sampling decreased to once every 5 years. None of the May 2008 samples from

I monitoring wells, Seep M, or nearby domestic wells contained detectable quantities of PCE or

other volatile contaminants of concern listed in the ROD.

I The exposure assumptions, toxicity data, cleanup levels, and remedial action objectives (RAOs)

I used at the time of the remedy selection for OU3 are still valid. Exposure pathways have

changed in a positive way. Opportunities for exposure to all media (soil, groundwater, and seep

I water) have been minimized or eliminated by institutional controls. There were no significant

I changes in risk assessment methodologies that would affect the protectiveness of the remedy.

There have been no changes in land use that would impact the protectiveness of the remedy.

OU4 (Maiden Lane Area)

I The ROD for OU4 was just recently signed and the remedy for OU4 has not been implemented.

Therefore, any conclusions regarding remedy protectiveness would be premature. However,

I OU4 is within Special Area 3 and is therefore already protected by an institutional control which

restricts future well installations.

I I I 66

I



OUS (Old Hat Factory)

I The remedy is functioning as intended. The ROD documented that while the groundwater below

OU5 was contaminated, the risk could be addressed ~ith institutional controls and monitoring.

I Institutional controls have been implemented at OU5 and monitoring is ongoing. The exposure

assumptions, toxicity data, cleanup levels, and remedial action objectives (RAOs) used at the

I time of the remedy selection for OU5 are still valid. Changes at OU5 are likely to result in less

exposure opportunity than what was conservatively characterized in the HHRA. There were no

I significant changes in risk assessment methodologies that would affect the protectiveness of the

remedy. There have been no changes in land use that would impact the protectiveness of the

I remedy.


No remedy has been selected. However, OU6 is within Special Area 3 and is therefore already

I protected by an institutional control which restricts future well installations.

I I I I I I I I I 67

I

I I


8.0 Issues

I Table 3: Issues

I I I I I I I I

Issue # Issue Affects Protectiveness

(yIN) Current Future

OUI ISSUES

I

Previous removal actions and the ongoing ART well have made an impact on the plume. However, the groundwater fluctuations have made it difficult to determine the overall effectiveness of the system.

No No

2 The groundwater pump in the ART system has not been functional for the past year.

No No

3 The results of follow-on vapor intrusion studies have not been formally documented.

No No

OU3 ISSUES

4

No written easements with adjacent property owners for access to monitoring wells and sampled private wells are in place and access continues to be through verbal agreement.

No No

OUS ISSUES None


The RIfFS for OU2 and OU6 has not been completed. Therefore, remedies for OU2 and OU6

I have not yet been selected.

I I I I I 68

I

I I


9.0 Recommendations and Follow-Up Actions

I Below is a list of recommended actions to address the issues identified in section 8.0 above.

I T a ble 4 : Recommend f o UJPa Ions and F II ow- Ac Ions t'

I I I I I I I I I I I I I I 69

I

Issue #

I

2

3

4

Recommendations/ Follow-up Actions Party Oversight Milestone Responsible A2ency Date

OUI RECOMMENDATIONS

If the EPA and MDNR conclude that the ART well system is to keep operating into the State-lead "Operational & Maintenance" phase, the EPA will ensure the system is functioning properly and operating as designed, before that transition occurs." Therefore if the ART EPA MDNR Nov 2011 well is to remain operational, a remedy optimization study should be considered to determine ifactivities such as installation of additional instrumentation will improve the operations and effectiveness of the ART well. If the EPA and MDNR conclude that the ART well system is to keep operating into the State-lead "Operational & Maintenance" phase, the EPA will ensure the system is functioning properly and

EPA MDNR Nov 2010 operating as designed, before that transition occurs." Therefore if the ART well is to remain operational, installation of a new pneumatic groundwater pump is recommended. The results of the follow-up vapor intrusion study should be formally EPA MDNR Nov 2010 documented in the public record. OU3 RECOMMENDATIONS Obtain access agreements or easements for future well sampling required by the EPA MDNR Nov2013 ROD.

I I


10.0 Protectiveness Statements

I The remedies at OU I, OU3 and OUS are protective of human health and the environment based

on the nine criteria used in the selection of the remedies and due to the use of institutional

I controls will eliminate exposure pathways for the short and long term.


Therefore, any conclusions regarding remedy protectiveness would be premature. However,

I OU4 is within an area already protected by an institutional control which restricts future well

installations.

I Remedies for OU2 and OU6 have not been selected. However, OU2 and OU6 are within Special

I Area 3 and are already protected by this institutional control which restricts future well

installations.

I I I I I I I I I I 70

I

I I


11. Next Review

I The next five-year review for the Riverfront Site in New Haven, Missouri is required by

November 9,2014, five years from the date of this review.

I I I I I I I I I I I I I I I 71

I

I I I I I I FIGURES


------------------

/

NORTH B peE PLUME

r---~-L ---..........

,

/.. /

: (,. \

"- .... \ OU2

/

J

\ I OU6

/

,....

r.s ~ ~ ~

r:

I

\.

/ ~ . ,/

I -,--------I SOUTH BEDROCK peE PLUME

E -P A . TJO T (I 2.000 4.000 FEET

L\' I.·\'\'l~ C t'r U\!ll 1...._ ..1 P RAB E t 'rr 4 (OU)

RO-\

HKiH \ \)"

-TRtA 1

PLBlJ( -. LPPL\ UR I DL RI.\L Ll. 1\0 mE :-nFIFR BU L I Dl(AI L , 0 pc.~ DlTl(TE!:>, GREC [l. 'OIl.. Tl p( I:

[)[TLCTlD BL . l : II A D l' ) \Hl it KJR.-\ \ LJ lR

FIGURE 1: Site Figure, Riverfront Superfund Site Source: Record of Decision, Riverfront Site, Operable Unit 4, March 2009

\10 nOR! WFl l p.. RfDRI I\. D TOE :TIFlfR RrD

I I I I I I I I I I I I All of

Twn 44 N

I Rng3W Sec 11 nurfrlof Beauf Creek

I I I I Source: Missouri Well Regulations (4-09)

I I

Special Area 3

~I of Twn 44 1\ h'ng ~ W ~-ec 2

WeSI Half Twn 44 N Rng3W Sec I

AJI--;r--1V\.'est Helf Twn44 N I=Ing3W Sp.f.·12 north of ,,/ B~uuf / C,Eek /....--:;. _/.r

Figure 2: Special Area 3 Riverfront Superfund Site

I I I· I I

Air Sparging

Vault

Contaminated air fro"- BolI.nd strip""" groundwater

I I

Mound"" ground1IO'!!!!Llnirn IIndvICuum

I I I I I

Source: Operable Unit I RA Report

I I I I I I

Grada

p'Jrr....... _ .. _ .. _ .. _ .. -

Vapor Extraction 1§"'i":;~RY ,..........--.._ .. _.. _.. _.. -Air Stripping Recirc. Recirculation

Figure 3: ART Well Typical ART well Operations Diagram Riverfront Superfund Site

I ,I I I I ATTACHMENT 1

SITE INSPECTION PHOTOGRAPHS

I I I I I I I I I I I I I 1

I I I I I I I I I I OU l Front Street Site - Bird' s eye view with north at top (Bing Maps 2009).

I I I I I I I I I

OU 1 Front Street Site (June 24, 2009) - View between two onsite structures of white bam and one of two residences located north of site.

I I I I I I I I I I I I I I I I I I I

au I Front Street Site (June 24, 2009) - ART Treatment System Shed (facing NE from concrete area).

aUI Front Street Site (June 24, 2009) - rnterior ART Treatment System Shed.


OU2 Kellwood Site - Bird's eye view with north at top (Bing Maps 2009).

OU2 Kellwood Site (June 24, 2009) - Facing south along Industrial Drive.

I I I I I I I I I OU2 Kellwood Site (June 24, 2009) - Area of interim action (facing east).

I I I I I I I

OU2 Kellwood Site (June 24, 2009) - Monitoring well and former landfarm area

I north of interim action area shown in previous photograph.

I I

-, - ;!l •

• k, ,. t «.

;


OU3 Old City Dump Site - Bird's eye view with north at top (Bing Maps 2009).

OU3 Old City Dump Site (June 24, 2009) - Entrance along Highway C (facing west).


OU3 Old City Dump Site (June 24, 2009) - Access Gate (facing north).

OU3 Old City Dump Site (June 24, 2009) - Composting project in background (facing north).

I I I I I I I I I I I ,I I I I I I I I

OU4 Maiden Lane Site - Bird' s eye view with north at top (Bing Maps 2009).

OU4 Maiden Lane Site (June 24, 2009) - Street view of 104 Maiden Lane (facing south).


OU4 Maiden Lane Site (June 24, 2009) - Interim action area in background (facing south).

OU4 Maiden Lane Site (June 24, 2009) - View to west of TeE hotspot.


OUS Old Hat Factory Site - Bird's eye view with north at top (Bing Maps 2009).

OUS Old Hat Factory Site (June 24, 2009) - Remaining historic opera house section remains along Maupin Street (facing north).


OUS Old Hat Factory Site (June 24, 2009) - View from former main production building area facing east and the intersection of Washington and Wall Streets.

OUS Old Hat Factory Site (June 24, 2009) - Monitoring Well .


OU6 Domestic Well Removal Site - Bird's eye view of residence near intersection of Highway C and Wildcat Creek Lane. Wells on property bound eastern extent of groundwater plume associated with OU2 Kellwood Site (north at top) (Bing Map 2009).

OU6 Domestic Well Removal Site (June 24,2009) - Residence on Bouef Lutheran Drive. (View south from OU2 Kellwood Site.)

I I I I I ATTACHMENT 2

SITE INSPECTION CHECKLISTIINSPECTION ROSTER


I I

Site Inspection Checklist (OUI)

I I. SITE INFORMATION

Site name: Riverfront OU I Front Street Site Date of inspection: June 24, 2009

I Location and Region: New Haven, County, Missouri EPA 10: MOD007452154

Agency, office, or company leading the five-year

I Weather/temperature: Sunny, 90s

review: USACE-NWK

Remedy Includes: (Check all that apply) D Landfill cover/containment D Monitored natural attenuation [8J Access controls D Groundwater containment

I [8J Institutional controls D Vertical barrier walls

I D Groundwater pump and treatment D Surface water collection and treatment [8J Other: Remedy includes Advanced Remedial Technology (ART) Treatment System

Attachments: [8J I nspection team roster attached D Site map attached

I I. O&M site manager

II. INTERVIEWS (Check all that apply)

Rob Blake Black and Veatch Corl! 6/24/2009

I Name Title

Interviewed [8J at site D at office D by phone Problems, suggestions; D Report attached

Phone no. 913-458-6681 Date

I I

3. Local regulatory authorities and response agencies (i.e., State and Tribal offices, emergency response office, police department, office of public health or environmental health, zoning office, recorder of deeds, or other city and county offices, etc.) Fill in all that apply.

Agency US EPA

I Contact Jeff Field Remedial Project Mgr

Name Title Problems; suggestions; D Report attached _None

June 24, 2009 Date

!913l551-7548 Phone no.

I 4. Other interviews toptional) D Report attached. Evan Kiffer MDNR

I I I I Five-year Review Report - I

I I


III. ON-SITE DOCUMENTS & RECORDS VERIFIED (Check all that apply)

I. O&M Documents ~ O&M manual ~ Readily available ~ Up to date DN/A ~ As-built drawings ~ Readily available ~ Up to date DN/A ~ Maintenance logs ~ Readily available ~ Up to date DN/A Remarks Insl2ection/maintenance logs dating back to s~stem startul2. Instruction for insl2ection and

maintenance I2rocedures I2rovided on logs. BSCO electric O&M

2. Site-Specific Health and Safety Plan ~ Readily available ~ Up to date DN/A ~ Contingency plan/emergency response plan ~ Readily available ~ Up to date DN/A Remarks Insl2ection checklist identifies contact numbers in case of I2roblems.

3. O&M and OSHA Training Records ~ Readily available o Up to date DN/A Remarks o &M Records

4. Permits and Service Agreements o Air discharge permit o Effluent discharge o Waste disposal, POTW o Other permits

o Readily available o Readily available o Readily available o Readily available

o Up to date o Up to date o Up to date o Up to date

~N/A ~N/A ~N/A ~N/A

Remarks with CilY

5. Gas Generation Records o Readily available o Up to date ~N/A Remarks

6. Settlement Monument Records o Readily available o Up to date ~N/A Remarks

7. Groundwater Monitoring Records ~ Readily available ~ Up to date DN/A Remarks

8. Leachate Extraction Records o Readily available o Up to date ~N/A Remarks

9. Discharge Compliance Records DAir o Readily available o Up to date ~N/A o Water (effluent) o Readily available o Up to date ~N/A Remarks

10. Daily Access/Security Logs ~ Readily available ~ Up to date DN/A Remarks

Five-year Review Report - 2

I I I IV. O&M COSTS

I I. O&M Organization

D State in-house D Contractor for State D PRP in-house D Contractor for PRP D Federal Facility in-house D Contractor for Federal Facility [8J Other EPA lead :Contractor Black and Veatch

I 2. O&M Cost Records

[8J Readily available [8J Up to date

I D Funding mechanism/agreement in place Original O&M cost estimate D Breakdown attached

I 3. Unanticipated or Unusually High O&M Costs During Review Period Describe costs and reasons: PumQ reQlacement after 4 ~ears

I I V. ACCESS AND INSTITUTIONAL CONTROLS [8J Applicable DN/A

A. Fencing

I I. Fencing damaged D Location shown on site map D Gates secured [8J N/A Remarks

I B. Other Access Restrictions

I I. Signs and other security measures [8J Location shown on site map DN/A

Remarks Lock on remedial building. Part ofSQecial Area 3, Qublic notification well restictions, drilling restrictions

I I I I I Five-year Review Report - 3

I I


C. Institutional Controls (ICs)

I. Implementation and enforcement Site conditions imply ICs not properly implemented DYes [8] No ON/A Site conditions imply ICs not being fully enforced DYes [8] No ON/A

Type of monitoring (e.g., self-reporting, drive by) Scheduled Bi-annual monitoring Frequency Weekl~ OMM checks Responsible party/agency EPA Region 7 Contact Jefferx Field Remedial Project Manager June 24, 2009 (913/5517548

Name Title Date Phone no.

Reporting is up-to-date [8] Yes ONo ON/A Reports are verified by the lead agency [8] Yes ONo ON/A

Specific requirements in deed or decision documents have been met [8] Yes ONo ON/A Violations have been reported DYes ONo [8] N/A Other problems or suggestions: o Report attached

2. Adequacy .I8l ICs are adequate o ICs are inadequate ON/A Remarks Within SDecial Area 3

D. General

I. Vandalism/trespassing o Location shown on site map [8] No vandalism evident Remarks

2. Land use changes on site 0 N/ A Remarks There had been no change in land use on site.

3. Land use changes ofT siteD N/A Remarks No a(![1arent change in land use in vicini!X of site.

VI. GENERAL SITE CONDITIONS

A. Roads [8] Applicable ON/A

I. Roads damagedl o Location shown on site map t8l Roads adequate ON/A Remarks



B. Other Site Conditions

Remarks None

I. Treatment Train (Check components that apply) D Metals removal D Oil/water separation D Bioremediation ~ Air stripping ~ Carbon adsorbers D Filters D Additive (e.g.. chelation agent. flocculent) D Others D Good condition D Needs Maintenance D Sampling ports properly marked and functional ~ Sampling/maintenance log displayed and up to date ~ Equipment properly identified D Quantity of groundwater treated annually NA D Quantity of surface water treated annually Remarks ART Well (Not fullX ol2erational at the time of insl2ection I

2. Electrical Enclosures and Panels (properly rated and functional) DN/A ~ Good condition D Needs Maintenance Remarks

3. Tanks, Vaults, Storage Vessels DN/A ~ Good condition D Proper secondary containment D Needs Maintenance Remarks

4. Discharge Structure and Appurtenances DN/A ~ Good condition D Needs Maintenance Remarks SVE Effluent

5. Treatment Building(s) DN/A ~ Good condition {esp. roof and doorways) D Needs repair D Chemicals and equipment properly stored Remarks

6. Monitoring Wells (pump and treatment remedy) ~ Properly secured/locked ~ Functioning ~ Routinely sampled ~ Good condition ~ All required wells located D Needs Maintenance DN/A Remarks

D. Monitoring Data -


I I I I I I I I I I I I I I I I I Five-year Review Report - 6

I I

I.Mo nitoring Data [8J Is routinely submitted on time [8J Is of acceptable quality

2. Mo nitoring data suggests: [8J Groundwater plume is effectively contained [8J Contaminant concentrations are declining

E. Monitored Natural Attenuation

I. Monitoring Wells (natural attenuation remedy) D Properly secured/locked D Functioning D Routinely sampled D Good condition D All required wells located D Needs Maintenance DN/A Remarks Yes, molar stud:L but not Qart of the remed:L

X. OTHER REMEDIES

If there are remedies applied at the site which are not covered above, attach an inspection sheet describing the physical nature and condition of any facility associated with the remedy. An example would be soil vapor extraction.

I ,

I I I I I I I I I I I I I I I I Five-year Review Report - 7

I I

XI. OVERALL OBSERVATIONS

A. Implementation of the Remedy

B.

Describe issues and observations relating to whether the remedy is effective and functioning as designed. Begin with a brief statement of what the remedy is to accomplish (i.e., to contain contaminant plume, minimize infiltration and gas emission, etc.).

Designed to remove mass at the head of the [!Iume. O[!erating as designed with [!eriodic re[!airs -remedial wells screens are acid washed regularl:>:::

Adequacy ofO&M

Describe issues and observations related to the implementation and scope ofO&M procedures. In particular, discuss their relationship to the current and long-term protectiveness of the remedy.

Yes, continue to work on egui[!ment long term with regular acidification of remedial well screen.


I I

C. Early Indicators of Potential Remedy Problems

Describe issues and observations such as unexpected changes in the cost or scope ofO&M or a high frequency of unscheduled repairs, that suggest that the protectiveness of the remedy may be compromised in the future.

Acidification is necessary for continued well function

D. Opportunities for Optimization

Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy. As above

I I

Site Inspection Checklist (OU3)


Site name: Riverfront OU3 Front Street Site Date of inspection: June 24, 2009

I Location and Region: New Haven, County, Missouri EPA 10: MOD007452154

Agency, office, or company leading the five-year

I Weather/temperature: Sunny. 90s

review: USACE-NWK

Remedy Includes: (Check all that apply) o Landfill cover/containment o Monitored natural attenuation ~ Access coritrols o Groundwater containment

I ~ Institutional controls o Vertical barrier walls o Groundwater pump and treatment

I o Surface water collection and treatment ~ Other: Monitoring

Attachments: ~ Inspection team roster attached o Site map attached

I II. INTERVIEWS (Check all that apply)

1. O&M site manager John Schumacher USGS Name Title Date

Interviewed 0 at site 0 at office 0 by phone Phone no.

I Problems, suggestions; 0 Report attached Not Interviewed

I 3. Local regulatory authorities and response agencies (i.e .• State and Tribal offices, emergency response office. police department. office of public health or environmental health, zoning office. recorder of deeds, or other city and county offices. etc.) Fill in all that apply.

I Agency US EPA

I Contact JeITField Remedial Project Mgr June 24, 2009 19131551-7548

Name Title Date Phone no. Problems; suggestions;·O Report attached

None

I 4. Other interviews (optional) 0 Report attached.

I Evan KilTer - MDNR RPM - No problems noted

I I I Five-year Review Report - I

I I



I. 0&1'1 Documents [8] O&M manual [8] Readily available [8] Up to date DN/A D As-built drawings D Readily available D Up to date [8] N/A [8] Maintenance logs [8] Readily available [8] Up to date DN/A Remarks Info not (!resent at ins(!ection but forwarded shortlx after ins(!ection

2. Site-Specific Health and Safety Plan D Readily available D Up to date DN/A D Contingency plan/emergency response plan D Readily available [8] Up to date DN/A Remarks Well sam(!ling and walk through ins(!ections

3. 0&1'1 and OSHA Training Records [8] Readily available D Up to date DN/A Remarks [n(!section re(!orts avai lable

4. Permits and Service Agreements D Air discharge pennit D Readily available D Up to date [8] N/A D Effiuent discharge D Readily available D Up to date [8] N/A D Waste disposal, POTW D Readily available D Up to date [8] N/A D Other permits D Readily available D Up to date [8] N/A Remarks with City

5. Gas Generation Records D Readily available o Up to date [8] N/A Remarks

6. Settlement Monument Records D Readily available o Up to date [8] N/A Remarks

7. Groundwater Monitoring Records [8] Readily available [8] Up to date DN/A Remarks

8. Leachate Extraction Records D Readily available D Up to date [8] N/A Remarks

9. . Discharge Compliance Records DAir D Readily available o Up to date [8] N/A D Wateqeffiuent) D Readily available DUpto date [8] N/A Remarks

10. Daily Access/Security Logs D Readily available D Up to date [8] N/A Remarks


I I I' I I I I I I I I I

IV. O&M COSTS

I. O&M Organization D State in-house D Contractor for State D PRP in-house rgJ Contractor for PRP D Federal Facility in-house D Contractor for Federal Facility rgJ Other Joint Insl2ections with Ciy of New Haven and contractor (USGS)

2. O&M Cost Records D Readily available D Up to date rgJ Funding mechanism/agreement in place Original O&M cost estimate D Breakdown attached

3. Unanticipated or Unusually High O&M Costs During Review Period Describe costs and reasons: None

V. ACCESS AND INSTITlITIONAL CONTROLS rgJ Applicable DN/A

A. Fencing

I. Fencing damaged D Location shown on site map rgJ Gates secured DN/A Remarks Fencing intact

~

B. Other Access Restrictions

I. Signs and other security measures D Location shown on site map DN/A Remarks_Gated and locked, no trespassing and site description signs in place


I I

I I I I I I I I I I I I I I I

C. Institutional Controls (lCs)

I. Implementation and enforcement Site conditions imply ICs not properly implemented DYes [8] No DN/A Site conditions imply ICs not being fully enforced DYes [8] No DN/A

Type of monitoring (e.g., self-reporting, drive by) _inspection annually and groundwater monitoring every 5

Responsible party/agency Ci!): ofNew Haven/EPA

Contact Jeffe!}: Field Remedial Project Manager June 24, 2009 (913)551-7548 Name Title Date Phone no.

Reporting is up-to-date [8] Yes DNo DN/A Reports are verified by the lead agency [8] Yes DNo DN/A

Specific requirements in deed or decision documents have been met [8] Yes DNo DN/A Violations have been reported DYes [8] No DN/A Other problems or suggestions: D Report attached

2. Adequacy .I8l. I Cs are adequate D ICs are inadequate DN/A Remarks: Restrictive covenant filed by city in place. Site on the Missouri Regist!}: of Confirmed Abandoned or Uncontrolled Hazardous Waste Disposal Sites. An~ substantial change in property use mllst be approved by MDNR.

D. General

I. Vandalism/trespassing D Location shown on site map [8] No vandalism evident Remarks

2. Land use changes on site D NIA Remarks There had been no change in land lise on site.

3. Land use changes off site D N/ A Remarks No apparent change in land use in vicinity of site.


A. Roads [8] Applicable DN/A

I. Roads damaged D Location shown on site map [8] Roads adequate DN/A Remarks

I I Five-year Review Report - 4

I I


I I


Remarks None

VII. LANDFILL COVERS o Applicable [8:] N/A

A. Landfill Surface: Inspected but landfill cover requirement not spelled out in ROD

I. Settlement (Low spots) o Location shown on site map [8:] Settlement not evident Areal extent Depth

Remarks

2. Crat'ks o Location shown on site map [8:] Cracking not evident Lengths W idths Depths

Remarks

3. Erosion o Location shown on site map [8:] Erosion not evident Areal extent Depth Remarks

4. Holes o Location shown on site map [8:] Holes not evident Areal extent Depth Remarks

5. Vegetative Cover [8:] Grass [8:] Cover properly established [8:] No signs of stress ~G Trees/Shrubs (indicate size and locations on a diagram) Remarks

6. Alternative Cover (armored rock, concrete, etc.) DN/A Remarks

7. Bulges o Location shown on site map [8:] Bulges not evident Areal extent Height Remarks

I I I I I

8. Wet AreasIWater Damage [gJ Wet areas/water damage not evident D Wet areas D Location shown on site map Areal extent D Ponding D Location shown on site map Areal extent [gJ Seeps D Location shown on site map Areal extent D Soft subgrade D Location shown on site map Areal extent Remarks SeeQs QreviouslX identified in ROD and samQling reguired.

9. Slope Instability D Slides D Location shown on site map [gJ No evidence of slope instability Areal extent Remarks

I B. Benches D Applicable [gJ N/A

I (Horizontally constructed mounds of earth placed across a steep landfill side slope to interrupt the slope in order to slow down the velocity of surface nmoffand intercept and convey the runoff to a lined channel.)

I C. Letdown Channels D Applicable [gJ N/A

(Channel lined with erosion control mats, riprap, grout bags, or gabions that descend down the steep side slope of the cover and will allow the runoff water collected by the benches to move off of the landfill cover without creating erosion gullies.)

I I I I I I I I I Five-year Review Report - 6

I I

I I

I I

D. Cover Penetrations 0 Applicable IZI N/A

I I I I

I I I I

E. Gas Collection and Treatment o Applicable IZI N/A

F. Cover Drainage Layer o Applicable IZI N/ A Existing Drainage Adequate

G. Detention/Sedimentation Ponds o Applicable IZI N/A

H. Retaining Walls o Applicable IZI N/A

I. Perimeter Ditches/OfT-Site Discharge o Applicable IZI N/A )

I. Siltation o Location shown on site map IZI Siltation not evident Areal extent Depth Remarks

2. Vegetative Growth o Location shown on site map ON/A IZI Vegetation does not impede flow Areal extent Type Remarks

3. Erosion o Location shown on site map IZI Erosion not evident Areal extent Depth Remarks

4. Discharge Structure IZI Functioning ON/A Remarks_Adequate surface drainage

VIII. VERTICAL BARRIER WALLS o Applicable IZI N/A

IX. GROUNDWATERlSlJRFACE WATER REMEDIES o Applicable ~N/A

X. OTHER REMEDIES


I I I I Five-year Review Report - 7·

I I


I I

XI. OVERALL ORSERVATIONS


R.


Restrictive Covenant in glace. No contamination in adjacent wells

Adequacy of O&M


None


I I


D.


None

Opportunities for Optimization

Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy. Site Currentlx used as tree and brush site and coml2ost facilitx. CitX would like to

store sand and gravel at the site

I

I I



Site name: Riverfront Site - OU4 Date of inspection: June 24, 2009

Location and Region: New Haven. Franklin County, EPA 10: MOD981720246 Missouri

I Weather/temperature: Sunny, 80s

review: U.S. EPA Region 7 Agency, office, or company leading the five-year

Remedy Includes: (Check all that apply) D Landfill cover/containment D Monitored natural attenuation

I I:8l Access controls D Groundwater containment

I D Institutional controls D Vertical barrier walls D Groundwater pump and treatment D Surface water collection and treatment I:8l Other: Soil source area treatment with in situ chemical oxidation

I:8l Other: Groundwater long-term monitoring

I Attachments: I:8l I nspection team roster attached D Site map attached

II. INTERVIEWS (Check all that apply)

I 1. O&M site manager NA Name Title Date

Interviewed D at site D at office D by phone Phone no. Problems, suggestions; D Report attached Remedx not im~lemented Xet

I I 2. O&M staff

Name Title Date Interviewed D at site D at office D by phone Phone no.

I Problems, suggestions; D Report attached

I 3. Local regulatory authorities and response agencies (i.e., State and Tribal offices, emergency response

office, police department, office of public health or environmental health, zoning office, recorder of deeds, or other city and county offices, etc.) Fill in all that apply.

I Agency USEP A Region 7 Contact Jeff Field, Remedial Project Manager _June 24, 2009 __ 913-551-7548

I Name Title Date Phone no.

Problems; suggestions; D Report attached _Project is in RD phase to develop soil source chemical oxidation design and Long term monitoring plan.

4. Other interviews (optional) D Report attached. Evan Kiffer

I Five-year Review Report - 1

I I

I

I I I I I I I I I


OU4 is in the RD phase for soil source treatment and L TM Plan development. No On-site documents are available to review yet.

IV. O&M COSTS

OU4 is in the RD phase for soil source treatment and L TM Plan development. No On-site documents are available to review yet.

V. ACCESS AND INSTITUTIONAL CONTROLS [8J Applicable DN/A

A. FenCing

I. Fencing damaged D Location shown on site map D Gates secured [8J N/A

"

B. -

Other Access Restrictions

I. Signs and other security measures D Location shown on site map [8J N/A

I I I I I I I


I. Implementation and enforcement Site conditions imply ICs not properly implemented Site conditions imply ICs not being fully enforced

DYes [8J No D N/A DYes [8J No D N/A

Type of monitoring (e.g., self-reporting, drive by) Visual inspection ofOU4 area. Frequency Inspections as part of tile Five year review process. Responsible party lagency -,=,-E~PN'-"-'S"-'t""at"'e-'o'-'-fc'-'MC-"i"'-ss",o'-"u"-'ri'-_____,.......,....,...,...,--_______-:-_ Contact Jeff Field, Remedial Project Manager _June 24, 2009__ 913-551-7548


Reporting is up-to-date Reports are verified by the lead agency

Specific requirements in deed or decision documents have been met Violations have been reported Other problems or suggestions: D Report attached

[8J Yes D No D N/A [8J Yes D No D N/A

[8J Yes D No D N/A DYes D No [8J N/A

__OU4 is contained with Special Area 3. Area 3, as defined in 10 CSR 23-3.100(7), which requires that the MDNR be consulted before construction a new well in Special Area 3. The MDNR will provide specific guidance on well drilling protocol and construction specifications on a case-by-case basis. The MDNR will provide written approval for all new wells prior to construction. The MDNR first filed Special Area 3 on March 21, 2005, and re-filed on September 27, 2005. Special Area 3 became effective on April 30, 2006. _______________________

I Five-year Review Report - 2

I I


2. Adequacy r8lICs are adequate D ICs are inadequate DN/A Remarks Reviewed text of 10 CSR 23-3.1 OO(7t

D. General

I. Vandalism/trespassing D Location shown on site map ~ No vandalism evident Remarks

2. Land use changes on site ~ N/ A Remarks There had been no change in land use on site.

3. Land use changes off site ~ N/ A Remarks No aggarent change in land use in vicini~ of site.


A. Roads ~ Applicable DN/A

I. Roads damaged D Location shown on site map ~ Roads adequate DN/A Remarks Roads used to access OU4 area during insgection were adeguate.


Remarks All areas insgected were in very good condition and aggeared to be well maintained.

VII. LANDFILL COVERS D Applicable ~ N/A

VIII. VERTICAL BARRIER WALLS D Applicable ~N/A

IX. GROlINDWATERISURFACE WATER REMEDIES ~ Applicable DN/A

A. Groundwater Extraction Wells, Pumps, and Pipelines D Applicable ~N/A

B. Surface Water Collection Structures, Pumps, and Pipelines D Applicable ~N/A

C. Treatment System D Applicable ~N/A

D. Monitoring Data - L TM Plan is still under development. Monitoring wells were observed and are in good condition.

E. Monitored Natural Attenuation or LTM ~ Applicable DN/A

I. Monitoring Wells (natural attenuation remedy or L TM Plan) ~ Properly secured/locked D Functioning D Routinely sampled D Good condition D All required wells located D Needs Maintenance DN/A Remarks_Wells needed for L TM are not yet defined.



I I

x. OTHER REMEDIES D Applicable I:8J N/A


I I I I I I I




NA

B. Adequacy ofO&M


NA

I I I

I I I I I I Five-year Review Report - 5

I I


D.

Describe issues and observations such as unexpected changes in the cost or scope ofO&M or a high frequency of unscheduled repairs that suggest that the protectiveness of the remedy may be compromised in the future.

NA

Opportunities for Optimization

Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy.

I I



Site name: Riverfront Site - OU5

I Location and Region: New Haven, Franklin County, Missouri

I Agency, office, or company leading the five-year review: U.S. EPA Region 7

Remedy Includes: (Check all that apply)

Date of inspection: June 24, 2009

EPA 10: MOD981720246

Weather/temperature: Sunny, 80s

o Landfill cover/containment o Monitored natural attenuation

I o Access controls o Groundwater containment [8J Institutional controls o Vertical barrier walls o Groundwater pump and treatment

I o Surface water collection and treatment . [8J Other: Lon g term monitoring

Attachments: [8J Inspection team roster attached o Site map attached

I II. INTERVIEWS (Check all that apply)

I. O&M site manager Robert Blake Black and Veatch 6124/2009

I Name Title Date Interviewed [8J at site 0 at office 0 by phone Phone no. Problems, suggestions; 0 Report attached

I I

3. Local regulatory authorities and response agencies {i.e., State and Tribal offices, emergency response office, police department, office of public health or environmental health, zoning office, recorder of deeds, or other city and county offices, etc.) Fill in all that apply.

Agency USEP A Region 7

I Contact Jeff Field, Remedial Project Manager June 24, 2009 913-551-7548

I Name Title Date Phone no.

Problems; suggestions; 0 Report attached Sampling is ongoing under the Long Term Remedial Action Sampling Plan.

4. Other interviews (optional) 0 Report attached. Evan Kiffer

I I I I Five-year Review Report - I

I I


III. ON-SITE DOCLIMENTS & RECORDS VERIFIED (Check all that apply)

I. O&M Documents No on-going O&M at OUS. LTM Plan in place for remedy.

2. Site-Specific Health and Safety Plan ~ Readily available D Up to date DN/A D Contingency plan/emergency response plan D Readily available D Up to date DN/A Remarks_A site-specific health and safety plan for L TRA was prepared by Black and Veatch in 2007 and is available for review and use.

3. OSHA Training Records ~ Readily available D Up to date DN/A Remarks

4. Permits and Service Agreements D Air discharge permit D Effluent discharge D Waste disposal, POTW D Other permits Remarks

D Readily available D Readily available D Readily available D Readily available

D Up to date ~N/A D Up to date ~N/A D Up to date' ~N/A D Up to date ~N/A

5. Gas Generation Records D Readily available D Up to date ~N/A Remarks

6. Settlement Monument Records D Readily available D Up to date ~N/A Remarks

7. Groundwater Monitoring Records ~ Readily available ~ Up to date DN/A Remarks

8. Leachate Extraction Records D Readily available D Up to date ~N/A Remarks

9. Discharge Compliance Records DAir D Readily available D Up to date ~N/A D Water (effluent) D Readily available D Up to date ~N/A Remarks

10. Daily Access/Security Logs D Readily available D Up to date ~N/A Remarks


I I I

I.

I I

2.

I I 3.

I I

A.

I. I

B.I I.

I

IV. O&M COSTS

O&M Organizati~n o State in-house o Contractor for State o PRP in-house o Contractor for PRP o Federal Facility in-house o Contractor for Federal Facility I:8J Other: Contractor to EPA

O&M Cost Records I:8J Readily available I:8J Up to date o Funding mechanism/agreement in place Original O&M cost estimate o Breakdown attached

Unanticipated or Unusually High O&M Costs During Review Period Describe costs and reasons: _None _Sampling only__

V. ACCESS AND INSTITUTIONAL CONTROLS I:8J Applicable

Fenring

Fenring damaged Remarks

Other Access Restrictions

Signs and other security measures Remarks



I I

DN/A

o Location shown on site map o Gates secured I:8J N/A

o Location shown on site map I:8J N/A


I. Implementation and enforcement Site conditions imply ICs not properly implemented DYes [8J No DN/A Site conditions imply ICs not being fully enforced DYes [8J No DN/A

Type of monitoring (e.g., selt:'reporting, drive by) _ Visual Inspection ofOU5 area. Frequency Inspections as part regular sampling events and the Five xear review process. Responsible party/agency EPA/State of Missouri Contact Jeff Field, Remedial Project Manager _June 24, 2009 __ 913-551-7548 -


Reporting is up-to-date ~Yes DNo DN/A Reports are verified by the lead agency ~ Yes DNo DN/A

Specific requirements in deed or decision documents have been met ~ Yes DNo DN/A Violations have been reported DYes DNo ~N/A Other problems or suggestions: o Report attached __OU5 is contained with Spe<;:ial Area 3. Area 3, as defined in 10 CSR 23-3.100(7), which requires that the MDNR be consulted before construction a new well in Special Area 3. The MDNR will provide specific guidance on well drilling protocol and construction specifications on a case-by-case basis. The MDNR will provide written approval for all new wells prior to construction. The MDNR first filed Special Area 3 on March 21, 2005, and re-filed on September 27,2005. Special Area 3 became effective on April 30, 2006.

2. Adequacy t8lICs are adequate o ICs are inadequate DN/A Remarks Reviewed text of 10 CSR 23-3.100(7).

D. General

I. Vandalism/trespassing o Location shown on site map .~ No vandalism evident Remarks

2. Land use changes on site 0 N/A Remarks_Land use was previouslX commercial. Construction is on-going on site for site redevelopment.

3. Land use changes off site 0 N/ A Remarks No apparent change in land use in vicini!X of site.


A. Roads [8J Applicable DN/A

I. Roads damaged o Location shown on site map ~ Roads adequate DN/A Remarks Roads used to access OU5 during insgection were adeguate.




I I

Remarks All areas insl2ected were in ve~ good condition and al2l2eared to be well maintained.

VII. LANDFILL COVERS o Applicable ~N/A

VIOl. VERTICAL BARRIER WALLS o Applicable ~N/A

IX. GROUNDWATER/SURFACE WATER REMEDIES ~ Applicable DN/A

A. Groundwater Extraction Wells, Pumps, and Pipelines o Applicable ~N/A

B. Surface Water Collection Structures, Pumps, and Pipelines o Applicable ~N/A

C. Treatment System o Applicable ~N/A

D. Monitoring Data

I.Mo nitoring Data ~ Is routinely submitted on time ~ Is of acceptable quality

2. Mo nitoring data suggests: ~ Groundwater plume is effectively contained o Contaminant concentrations are declining

E. Monitored Natural Attenuation or LTM ~ Applicable DN/A

I. Monitoring Wells (natural attenuation remedy or L TM Plan) ~ Properly secured/locked ~ Functioning ~ Routinely sampled ~ Good condition o All required wells located o Needs Maintenance DN/A Remarks

X. OTHER REMEDIES


I I I I I





Monitoring is conducted Qer ROD & Ie's in Qlace

B. Adequacy ofO&M


Contamination in farthest down gradient well but no room for additional wells down gradient due to tOQograQhy:. Contamination in down gradient would be detected in

fuQgradient well of OU 1



None noted

D. Opportunities for Optimization

Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy.

None Noted


I I I I I I I I I

Site Inspection Team Roster

Personnel Representing Phone Number

Jeff Field EPA 913-551-7548

Robert Blake B lack and Veatch 816-458-6681

Evan KifeT MDNR 573-751-1990

Lee Gorday (OU2 & OU6 only) Parsons 314-576-7330

Phil Rosewicz USACE 816-389-3902

Greg Hattan USACE

,

816-389-3579

Debra Snodgrass USACE 816-389-3574

Amy Darpinian USACE 816-389-3897

I I I I I I I I Five-year Review Report - 7

I I

I I I I I ATTACHMENT 3

GROUNDWATER DATA


I I I I I OU1

I Final Spring 2009 Sampling Data Evaluation Report

Riverfront Superfund SiteI New Haven, Missouri

I Operable Unit 1 Front Street Site


I I I I I I I I I I I I SCALE

o lOO 200 FEET

I -- STREAM o NEW RA MONITORING WELLS (TW-H, -\ AND -J)

-- BUILDING OU I-TW-A 0 EXISTING MONITORING WELL

AND NUMBER

I -- FRONT STREET S[TE PROPERTY LINE e ART WELL, ART- I AND PIEZOMETERS PZ-l AND PZ-2

THE MCL OF 5.0 MICROGRAMS PER LITER APPROXIMATE AREA CONTAINING COCs ABOVE

I APPROXIMATE AREA CONTAINING COCs ABOVE 500 MICROGRAMS PER LITER

I FIGURE 1 NOTE: APPROXIMATE EXTENT OF peE I. COCs ARE PCE, TCE, C-DCE AND VC GROUNDWATER PLUME,

I 2. WELL G SHOWN IN THE CORE OF THE MAY 2009

PLUME EVEN THOUGH IT'S COCs ONLY OPERABLE UNIT 1 TOTAL 90 ugiL

3. HIGH GROUNDWATER LEVELS MAY HAVE RIVERFRONT SUPERFUND SITE BIASED THE SAMPLE OPERABLE UNIT I LTRA

o

SOURCE: USGS OUI RI

Core of Plume (COCs > 500 ugIL)

0 "" ",

OUI-TW-B :'

, ......'

RJv

~'f ", ,, , , ,

" " , , " "" ,, ,

" " BOAT RAMP,

EXPLANATION

I RESULTS LOW, ESPECIALLY AT WELLS B, C, AND D. Z :1044722INEW HAVENOUIIUSGSICOO08420 07/0112009

I

- - - - - - - - - - - - - - - - - - -Table 2 au 1 Remedial Action Groundwater Results From the End of RI Sampling (7/23/02) to Spring (5/26/09) 2009 Sampling

Well A

Parameter Date 7/2312002

Pump 7/24/2003

Pump 4/21/2005

Pump 5/31/2005 9/20/2005

PDB 12/13/2005

PDSUnits cis-1,2-Dichloroethene ug/L 1 U 1 U 10 U NS 5 U 1 UJ Tetrachloroethene uQ/L 1 U 1 U 10 U NS 5 U 1 U Trichloroethene ug/L 1 U 1 U 10 U NS 5 U 1 UJ Vinyl Chloride ug/L 2 U 2 U 10 U NS 5 U 1 U


PDS 5/23/2006

PDB 8/15/2006

PDS 11/14/2006

PDSUnits cis-1,2-Dichloroethene ug/L 0.5 U 1 U 1 U 0.5 U Tetrachloroethene ug/L 1.3 1 U 1 U 0.5 U Trichloroethene UQ/L 0.5 U 1 U 1 U 0.5 U Vinyl Chloride ug/L 0.5 U 1 UJ 1 U 0.5 U

Parameter Date 3/8/2007

PDS 5/22/2007

PDS 8/14/2007

PDS 3/11/2008

PDS PDB 10/27/2008

Upper Pump Lower Pump Units cis-1,2-Dichloroethene uQ/L 0.5 U 1 U 1 U 1 U 1 U 1 U 1 U Tetrachloroethene ug/L 0.5 U 1 U 10 U 1 U 1 U 1 U 1 U ITrichloroethene ug/L 0.5 U 1 U 1 U 1 U 1 U 1 U 1 U IVinyl Chloride ug/L 0.5 U 1 U 1 U 1 U 1 U 1 U 1 U


PDSUnits Icis-1,2-Dichloroethene ug/L 0.5 U Tetrachloroethene ug/L 0.5 U Trichloroethene ug/L 0.5 U Vinyl Chloride ug/L 0.5 U

In February 2006, Acetone was detected at 7.9 ug/L and Cyclohexane was detected at 0.56 ug/L. In November 2006, Cyclohexane was detected at 1.7 ug/L. In March 2007, Cyclohexane was detected at 2.1 ug/L. PDS - Passive Diffusion Bag In May 2009, Acetone was detected at 12 ug/L. Pump - Perstaltic Pump For all PDS samples, Well A was sampled at 31 ft. NS - Not Sampled U - Not detected. Number is the detection limit. UJ - Not detected. Number is the detection limit. The detection limit is an estimate.

9/9/2009 1 of 14

- - - - - - - - - - - - - - - - - - -Table 2 (Continued) au 1 Remedial Action Groundwater Results From the End of RI Sampling (7/23/02) to Spring (5/26/09) 2009 Sampling

Well B


Pump 7/24/2003

Pump 4/21/2005

Pump 5/31/2005 9/20/2005

PDB 12/13/2005

PDBUnits cis-1,2-Dichloroethene ug/L 1 U 1· U 10 U NS 5 U 1.5 Tetrachloroethene ug/L 0.32 J 1 U 10 U NS 5 U 4.7 Trichloroethene ug/L 1 U 1 U 10 U NS 5 U 1.5 J Vinyl Chloride ug/L 2 U 2 U 10 U NS 5 U 1 U Methyl Tert-Butvl Ether ug/L 2 U 2 U 10 U NS 5 U 1.8 J


PDB 5/23/2006

PDB 8/15/2006

PDB 11/14/2006

PDBUnits cis-1,2-Dichloroethene ug/L 3.6 1 U 1.2 1.1 Tetrachloroethene ug/L 11 7.3 3.3 4.9 Trichloroethene ug/L 3 1 U 1.2 1 Vinyl Chloride ug/L 0.5 U 1 UJ 1 U 0.5 U Methyl Tert-Butvl Ether ug/L 0.5 U 1 UJ 1 U 0.77


PDB 5/22/2007

PDB 8/14/2007

PDB 3/11/2008

PDB PDB 10/28/2008

Upper Pump Upper Pump COUP) Lower Pump Units is-1,2-Dichloroethene ug/L 0.67 1 U 1 U 1.1 1 U 1 U 1 U 1 U

Tetrachloroethene ug/L 7 1 U 1.3 2.1 1 U 3.0 2.9 2.7 Trichloroethene ug/L 0.68 1 U 1 U 1 U 1 U 1 U 1 U 1 U Vinyl Chloride ug/L 0.5 U 1 U 1 U 1 U 1 U 1 U 1 U 1 U Methyl Tert-Butyl Ether ug/L 0.89 1.5 1.6 3.6 2.3 1.8 1.8 1.8

5/26/2009Date PDB DUP Parameter PDBUnits

ug/Lcis-1,2-Dichloroethene 0.5 U 0.5 U ug/L 0.5 U 0.5 UTetrachloroethene

Trichloroethene ug/L 0.5 U 0.5 U lVinyl Chloride ug/L 0.5 U 0.5 U

ug/L 2 2MethylTert-Butyl Ether

In February 2006, Acetone was detected at 60 ug/L and Cyclohexane at 0.93 ug/L. NS - Not Sampled In November 2006, Cyclohexane at 2.8 ug/L. U - Not detected. Number is the detection limit. In May 2007, Bromoform was detected in the sample and in the LDL trip blank at 1.2 ug/L. J - Result is an estimate. In May 2009, Cyclohexane at 0.6 ug/L. For all PDB samples, Well B was sampled at 31 ft. Pump - Perstaltic Pump PDB - Passive Diffusion Bag

9/9/2009 2 of 14


Well C

In December 2005, Acetone was detected at 7.6 ug/L. PDS - Passive Diffusion Sag In May 2006, Acetone was detected at 480 J ug/L. Pump - Perstaltic Pump In October 2008, t-DCE was detected in the Primary sample at 6.2 ug/L and in the duplicate sample at 6.0 ug/L. In May 2009, methylene chloride was detected in the duplicate sample at 5.4 ug/L. For the PDS samples through May 2006, Well C was sampled at 30 fl. U - Not detected. Number is the detection limit. • - Results may be biased low. Vial cap was not tight. J - Result is an estimate . •• - Results may be inaccurate or biased low, since PDS was not completely submerged.


Pump 4/912003

Pump 7/24/2003

Pump 4/21/2005

Pump 5/31/2005

PDS' Pump 9/20/2005

PDS 12/13/2005

PDS ••Units cis-1,2-Dichloroethene ug/L 23 21 6.5 3,700 250 180 470 310 Tetrachloroethene ug/L 23 14 10 5,000 140 410 320 260 Trichloroethene ug/L 9.5 4.8 3.6 2,300 140 150 210 220 ~inyl Chloride ug/L 0.69 J 1 J 2 U 1000 U 2.5 U 7.6 U 5 U 5 U


Sailer 5/23/2006

PDS 8/15/2006

PDS 11/14/2006

PDS 318/2007

PDS 5/22/2007

PDS PDS DUP 8/14/2007

PDSUnits cis-1,2-Dichloroethene ug/L 610 130 110 94 170 79 77 7.9 Tetrachloroethene ug/L 1,100 150 210 180 500 330 320 48 Trichloroethene ug/L 170 110 60 20 150 79 80 8 Vinyl Chloride ug/L 10 U 5 U 5 U 5 U 5 UJ 5 U 5 U 5 U


PDS PDS DUP PDS 10/29/2008

Pump Pump DUP Units is-1,2-Dichloroethene ug/L 39 35 340 1,000 1,100

Tetrachloroethene ug/L 190 210 160 450 450 Trichloroethene ug/L 40 35 110 300 300 Vinyl Chloride ug/L 5 U 5 U 5 U 5 U 5 U

5126/2009Date Parameter Units PDS PDS DUP

ug/Lcis-1,2-Dichloroethene 25 22 Tetrachloroethene ug/L 200 200 Trichloroethene ug/L 25 25 Vinyl Chloride ug/L 5 U 5 U

9/9/2009 3 of 14


Well 0


Pump 4/912003

Pump 7/24/2003

Pump 4/21/2005

Pump 5/31/2005 9/20/2005

PDB 12/13/2005

PDBUnits cis-1,2-Dichloroethene ug/L 1.1 1.6 0.98 J 10 U NS 5 U 1 U Tetrachloroethene ug/L 1.5 1 U 0.27 J 10 U NS 5 U 1 U Trichloroethene ug/L 0.44 J 0.87 J 0.38 J 10 U NS 5 U 1 UJ rvinyl Chloride ug/L 1 U 2 U 2 U 10 U NS 5 U 1 U

!Parameter Date 2115/2006

PDB 5/23/2006

PDB 8/15/2006

PDB 11/14/2006

PDB 318/2007

PDB 5/22/2007

PDB 8/14/2007

PDBUnits cis-1,2-Dichloroethene uQ/L 0.8 1.3 1 U 0.77 2.2 1 U 1.7 Tetrachloroethene uQ/L 0.5 U 1 U 1 U 0.5 U 0.5 U 1 U 1 U Trichloroethene uQ/L 0.5 U 1 U 1 U 0.5 U 0.5 U 1 U 1 U ',.Ijnyl Chloride ug/L 0.5 U 1 UJ 1 U 0.5 U 0.5 U 1 U 1 U Cyclohexane ug/L 0.93 1 U 1 U 4.2 0.5 U 1 U 1 U


PDB PDB 10/28/2008

Upper Pump Lower Pump Units cis-1,2-Dichloroethene ug/L 1 U 1 1.3 1.1 Tetrachloroethene ug/L 1 U 1 U 1 U 1 U Trichloroethene ug/L 1 U 1 U 1 U 1 U ',.Ijnyl Chloride ug/L 1 U 1 U 1 U 1 U Cyclohexane ug/L 1.4 1 U 1 U 1 U


PDBUnits cis-1,2-Dichloroethene ug/L 0.63 Tetrachloroethene ug/L 0.5 U Trichloroethene ug/L 0.5 U ['.tinyl Chloride ug/L 0.5 U Cyclohexane ug/L 1.1

In February 2006, Acetone was detected at 6.6 ug/L. PDB - Passive Diffusion Bag For the PDB samples, Well 0 was sampled at 28 ft. Pump - Perstaltic Pump NS - Not Sampled U - Not detected. Number is the detection limit. J - Result is an estimate.

9/9/2009 4 of 14

-------------------Table 2 (Continued) au 1 Remedial Action Groundwater Results From the End of RI Sampling (7/23/02) to Spring (5/26/09) 2009 Sampling

Well E


Pump 7/24/2003

Pump 4/21/2005

Pump 5/31/2005

Bailer 9/20/2005

Dry 12/13/2005

DryUnits cis-1,2-Dichloroethene ug/L 52 91 45 75 NS NS Tetrachloroethene ug/L 210 260 70 220 NS NS Trichloroethene ug/L 36 72 45 59 NS NS Vinyl Chloride ug/L 10 U 13 U 10 U 3.8 U NS NS


Dry 5/23/2006

Bailer 8/15/2006

Dry 11/14/2006

DryUnits cis-1 ,2-Dichloroethene ug/L NS 5.8 NS NS Tetrachloroethene ug/L NS 130 NS NS Trichloroethene ug/L NS 15 NS NS Vinyl Chloride ug/L NS 1 UJ NS NS


Dry 5/22/2007

Bailer 8/14/2007

Bailer 3/11/2008

Bailer 10/29/2008

BailerUnits cis-1,2-Dichloroethene ug/L NS 13 5 U 15 49 Tetrachloroethene ug/L NS 130 95 86 110 Trichloroethene ug/L NS 16 10 9 15 Vinyl Chloride ug/L NS 1 U 5 U 5 U 5 U


BailerUnits cis-1,2-Dichloroethene ug/L 23 Tetrachloroethene ug/L 62 Trichloroethene ug/L 11 Vinyl Chloride ug/L 5 U

Pump - Perstaltic Pump NS - Not Sampledl Dry Well Dry - Well dry, unable to sample. U - Not detected. Number is the detection limit.

9/9/2009 5 of 14

-------------------Table 2 (Continued) OU 1 Remedial Action Groundwater Results From the End of RI Sampling (7/23/02) to Spring (5/26/09) 2009 Sampling

Well F


Pump 7/24/2003

Pump 4/21/2005

Pump 5/31/2005 9/20/2005

PDB 12/13/2005

Units cis-1,2-Dichloroethene ug/L 1 U 0.21 J 10 U NS 5 U NS Tetrachloroethene ug/L 1 U 1 U 10 U NS 5 U NS Trichloroethene ug/L 1 U 1 U 10 U NS 5 U NS Vinxl Chloride ug/L 2 U 2 U 10 U NS 5 U NS

Parameter Date 2115/2006 5/23/2006 8/15/2006 Well

Permanently Closed, October

2006

Units cis-1,2-Dichloroethene ug/L NS NS NS Tetrachloroethene ug/L NS NS NS Trichloroethene ug/L NS NS NS Vinyl Chloride ug/L NS NS NS

PDB - Passive Diffusion Bag NA - Not Analyzed Pump - Perstaltic Pump NS - Not Sampled For the PDB samples, Well F was sampled at 33 ft. U - Not detected. Number is the detection limit.

9/9/2009 6 of 14

-------------------Table 2 (Continued)· au 1 Remedial Action Groundwater Results From the End of RI Sampling (7/23/02) to Spring (5/26/09) 2009 ~ampling

Well G

Parameter cis-1,2-Dichloroethene Tetrachloroethene Trichloroethene Vinyl Chloride

Date Units ug/L ug/L ug/L ug/L

5/9/2002 Pump

370 41 17 71

5/17/2002 Pump

170 40 18 13

7/23/2002 Pump Pump

370 380 130 150 45 48 25 J 25 J

4/912003 Pump

190 2.1 J 1.2 J 60

Pump 190 1.8 J 1.3 J 61

7/24/2003 Pump

250 65 27 37


Pump 12/13/2005

PDS 211512006

PDS 5/23/2006

PDS 8/15/2006

PDS 11/14/2006

PDSUnits cis-1,2-Dichloroethene ug/L 160 420 260 120 260 330 Tetrachloroethene ug/L 20 U 100 25 U 5 U 37 8.5 Trichloroethene ug/L 20 U 53 25 U 5.6 18 5 U IVinyl Chloride ug/L 25 28 52 35 55 110


PDS 5/22/2007

PDSUnits cis-1,2-Dichloroethene ug/L 140 28 Tetrachloroethene ug/L 5 U 5 U Trichloroethene ug/L 5 U 5.9 Vinyl Chloride ug/L 21 J 5 U

ACLs 8114/2007

PDS 3/11/2008

PDS 10/29/2008

PDS Pump 140,000 120 62 150 210

11,000 16 5 U 5 U 23 8,600 9.7 5 U 5 U 13 9,000 5 U 9.9 49 22


PDSUnits cis-1,2-Dichloroethene ug/L 37 Tetrachloroethene ug/L 5 U Trichloroethene ug/L 5 U Vinyl Chloride ug/L 53

For the PDB samples, Well G was sampled at 38 ft. ACLs - Alternate Concentration Limits, in ug/L In May 2009, Methylene Chloride detected at 15 ug/L. There is also an ACL for t-DCE of 6,700 ug/L. PDB - Passive Diffusion Bag U - Not detected. Number is the detection limit. Pump - Perstaltic Pump J - Result is an estimate. NA - Not Analyzed Well G was not sampled on May 31, 2005 or on September 20, 2005.

919/2009 7 of 14

- - - - - - - - - - - - - - - - - - -Table 2 (Continued) au 1 Remedial Action Groundwater Results From Baseline Sampling (4/21/05) to Spring (5/26/09) 2009 Sampling

WeliH Dale 4/2112005

Pump PDB PDB

9/20/2005

PBD PBD PBD

12/13/2005

PBD' PBD Sample Melhod

Parameler Unils 38' bloc 19' bloc 24' bloc 28' bloc 34' bloc 39' bloc 28' bloc 39' bloc cis-1,2-Dichloroelhene ug/L 81 8.7 62 81 140 140 43 230 Irans-1,2-Dichloroelhene ug/L 10 U 5 U 5 U 5 U 7.2 7.6 5 U 13 Telrach!oroelhene ug/L 85 140 200 240 430 400 350 540 Trichloroelhene ug/L 20 18 38 52 85 92 65 130 ['{i1lY1 Chloride ug/L 10 U 5 U 5 U 5 U 5 U 5 U 5 U 5 U

Dale 2115/2006

PDB

5/23/2006

PDB

8/15/2006

PDB

11/14/2006

PDB

318/2007

PDB

5/22/2007

PDB Sample Melhod

Parameler Unils 39' bloc 39' btoc 39' bloc 39' btoc 39' btoc 39' btoc cis-1,2-Dichloroethene ug/L 280 83 210 260 29 15 trans-1,2-Dichloroethene ug/L 19 5 U 9.6 14 5 U 5 U Tetrachloroethene ug/L 250 180 440 310 65 68 Trichloroethene ug/L 71 44 61 91 12 14 Vinyl Chloride ug/L 10 U 5 U 12 5 U 5 UJ 5 U

Dale

ACLs

8114/2007

PDB

3/11/2008

PDB Upper PDB

10/29/2008

Lower PDB Upper Pump Lower Pump Sample Method

Parameter Unils 34' btoc 34' btoc 34' bloc 39' btoc 22' btoc 32' bloc cis-1,2-Dichloroethene ug/L 140,000 51 53 83 82 100 110 Irans-1,2-Dichloroethene ug/L 6,700 5 U 5 U 5 U 5 U 5 U 5 U Tetrachloroelhene ug/L 11,000 160 120 190 J 150 150 190 Trichloroethene ug/L 8,600 34 31 28 20 30 34 Vinyl Chloride ug/L 9,000 5 U 5 U 5 U 5 U 5 U 5 U

Dale 5/26/2009 Sample Method Upper PDB Lower PDB

Parameter Units 34' btoc 39' btoc cis-1,2-Dichloroethene ug/L 35 34 Irans-1,2-Dichloroethene UQ/L 5 U 5 U Telrachloroethene ug/L 110 76 Trichloroethene ug/L 20 15 Vinyl Chloride ug/L 5 U 5 U

In December 2005, Acetone was detected in the 28' sample at 7.7 ug/L and in the 39' sample at 7.0 ug/L. In November 2006, Cyclohexane was delected at 6.7 ug/L. PDB - Passive Diffusion Bag In May 2009, Melhylene Chloride was delected at 8.4 ug/L. Pump - Perstaltic Pump U - Not detected. Number is the detection limit. btoc - below top of casing • - Results may be inaccurate or biased low, since PDB was not completely submerged.

9/9/2009 8 of 14


Weill Date 4121

Pump

12005

Pump PDS PDS

912012005

PDS PDS PSD PDS'

1211312005

PDS PDS Sample Method

Parameter Units 38' btoc 38' bloc DUP 19'btoc 24' btoc 28' btoc 34' btoc 39' btoc 28' btoc 39' btoc 39' btoc DUP cis-1,2-Dichloroethene uglL 3,600 3.800 150 2.800 4,100 6.100 6,400 4.800 8.300 8.300 rans-1.2-Dichloroethene uglL 4B 39 5 U 13 19 26 22 14 11 10

[Tetrachloroethene uglL 720 720 210 610 950 1,100 900 790 100 120 [Trichloroethene uglL 450 460 44 420 700 860 690 420 14 18 rvinyl Chloride uglL 75 76 5 U 17 36 62 110 120 340 350 1,1-Dichloroethene uglL 5 U 5 U 5 U 5 U 5 U 5 U 5 U 11 11 10

Date 211512006

PDS PDS

512312006

PDS

811512006

PDS

1111412006

PDS

31812007

PDS

512212007

PDS Sample Method

Parameter Units 39' btoc 39' btoc DUP 39' btoc 39' btoc 39' btoc 39' btoc 39' btoc cis-1,2-Dichloroethene uglL 12.000 12,000 1.600 14,000 14,000 1,100 990 trans-1,2-Dichloroethene uglL 670 U 55 15 21 35 15 9.9 T etrachloroethene uglL 670 U 11 950 200 650 J 540 620 Trichloroethene uglL 670 U 35 660 190 460 J 360 300 rvinyl Chloride ug/L 670 U 340 J 8.1 900 J 430 J 5 UJ 26 1 ,1-Dichloroethene ug/L 670 U 28 5 U 68 30 5 U 5 U

Date

ACLs

8114/2007

PDS

311112008

PDS Upp_er PDS

1012912008

Lower PDS U!>!>.er Pump Lower Pump Sample Method

Parameter Units 34' btoc 34' btoc 34' btoc 39' btoc 22.9' btoc 32.9' btoc cis-1,2-Dichloroethene uglL 140.000 2,200 770 2.500 2,900 1,800 2,500 trans-1.2-Dichloroethene uglL 6.700 6.1 8 5 U 7.1 16 17

etrachloroethene uglL 11,000 650 680 390 430 J 620 J 620 J richloroethene uglL 8.600 200 260 23 110 210 230

Vinyl Chloride uglL 9.000 180 8 1.100 680 330 360 1,1-Dichloroethene uglL 5 U 5 U 6 7.9 5 U 5.8

Date 512612009 Sample Method Upper PDS LowerPDS

Parameter Units 34' btoc 39' btoc cis-1,2-Dichloroethene ug/L 550 540 trans-1.2-Dichloroethene ug/L 5U 5 U

etrachloroethene uglL 350 180 richloroethene ug/L 110 89

Vinyl Chloride ug/L 26 62 1,1-Dichloroethene uglL 5 U 5U

In December 2005. Acetone was detected in the 28' sample at 6.7 uglL and in the 39' sample at 7.4 uglL (7.2 uglL in the Duplicate). In November 2006. Cyctohexane was detected at 13 uglL. PDS - Passive Diffusion Sag Weill was not sampled in May 2005. Pump - Perstaltic Pump U - Not detected. Number is the detection limit. btoc - below top of casing • - Results may be inaccurate or biased low. since PDS was not completely submerged.

9 of 14 91912009


WellJ Date 4/2112005

Pump

5/31/2005

PDB Pump PDB

9/20/2005

PDB PDB PDB

12/13/2005

PDB' PDB Sample Method

Parameter Units 30' btoc 30' btoc 30' btoc 20' btoc 25' btoc 25' btoc Dup 30' btoc 25' btoc 30' btoc cis-1,2-Dichloroethene ug/L 1,700 870 2,000 140 1,200 1,300 1,100 370 660 trans-1,2-Dichloroethene ug/L 15 NA NA 5 U 10 10 8 5 U 5 U Tetrachloroethene ug/L 6,200 3,300 4,800 880 3,200 3,200 6,200 1,000 300 Trichloroethene ug/L 3,000 920 2,700 110 520 540 770 150 .110 Vinyl Chloride ug/L 30 NA NA 5 U 5 U 5 U 10 5 U 70

Date 2115/2006

PDB

5/23/2006

POB PDB Dup

8/15/2006

poe

11/14/2006

POB poe Dup Sample Method

Parameter Units 30' btoc 30' btoc 30' btoc 30' btoc 30' btoc 30' btoc cis-1,2-Dichloroethene ug/L 680 300 300 1,000 1,300 1,100 trans-1,2-Dichloroethene ug/L 67 U 5 U 5 U 10 14 13 Tetrachloroethene ug/L 170 1,300 1,400 1,100 1,500 1,200 Trichloroethene ug/L 140 290 290 360 310 270 Vinyl Chloride ug/L 67 U 5 U 5 U 46 15 15

Date 318/2007

PDB PDB (DUP)

5/2212007

PDB

8/14/2007

PDB

3/11/2008

PDB Upper PDB

10/29/2008

Lower PDB Upper Pump Lower Pump Sample Method

Parameter Units 30' btoc 30' btoc 30' btoc 25' btoc 25' btoc 25' btoc 30' btoc 23.5' btoc 29,5' btoc cis-1,2-Dichloroethene ug/L 320 290 110 95 1,300 120 450 1,200 2,500 trans-1,2-Dichloroethene ug/L 50 U 50 U 5 U 5 U 11 5 U 6.8 39 42 Tetrachloroethene ug/L 2,300 2,300 920 870 2,600 1,200 J 1,300 J 3,000 6,800 Trichloroethene ug/L 320 310 130 100 1,200 170 250 710 1,400 Vinyl Chloride ug/L 50 UJ 50 UJ 5 U 5 U 20 5 U 5 U 11 12

5126/2009Date Sample Method LowerPDB

Parameter Upper PDB

29,5' btoc cis-1,2-Dichloroethene

Units 25' btoc 720

rans-1,2-Dichloroethene ug/L 340

5 U Tetrachloroethene

ug/L 5 U 2,200

Trichloroethene ug/L 590

580 Vinyl Chloride

ug/L 180 ug/L 5 U5 U

In December 2005, Acetone was detected in the 30' sample at 7.4 ug/L and in the 25' sample at 6.0 ug/L. In November 2006, 1,1,2-TCAwas detected at 12 ug/L in the primary sample and 11 ug/L in the duplicate sample, btoc - below top of casing -U - Not detected, Number is the detection limit. PDB - Passive Diffusion Bag • - Results may be inaccurate or biased low, because PDB was not submerged, Pump - Perstaltic Pump

9/9/2009 10 of 14

-------------------Table 2 (Continued) au 1 Remedial Action Groundwater Results From Baseline Sampling (4/21/05) to Spring (5/26/09) 2009 Sampling

PZ - 1

Parameter Date 4/2112005 5/31/2005

Pump 9/20/2005 12/13/2005 211512006

Bailer 5/23/2006

PDB 8/15/2006

PDB 11/14/2006

PDBUnits cis-1,2-Dichloroethene ug/L NS 2,750 NS NS 90 630 550 400 trans-1,2-Dichloroethene ug/L NS NA NS NS 25 U 6.4 5 U 6.7 Tetrachloroethene ug/L NS 23,500 NS NS 220 1,100 2,300 1,400 Trichloroethene ug/L NS 2,480 NS NS 28 320 310 160 Vinyl Chloride ug/L NS NA NS NS 25 U 5 U 5 U 5 U


PDB 5/22/2007

PDB 8/14/2007

PDB 3/11/2008

PDS 6/17/2008

PDB PDB (DUP) 10/29/2008

PDB PumpUnits cis-1,2-Dichloroethene ug/L 110 68 30 99 1,100 1,100 3,900 1,600 trans-1,2-Dichloroethene ug/L 5 5 U 5 U 5 U 11 17 29 13 Tetrachloroethene ug/L 430 470 42 2,100 4,700 J 4,300 J 9,300 J 4,000 J Trichloroethene ug/L 42 42 18 121 1,300 J 1,200 J 3,100 1,300 Vinyl Chloride ug/L 5 UJ 5 U 5 U 5 U 5 U 5 U 5 U 5 U


PDSUnits cis-1,2-Dichloroethene ug/L 850 trans-1,2-Dichloroethene ug/L 5 U Tetrachloroethene ug/L 2,900 Trichloroethene ug/L 600 Vinyl Chloride ug/L 5 U

In Novemeber 2006, 1,1,2-TCA was detected at 12 ug/L. Pump - Perstaltic Pump In June 2008, bromodichloromethane was detected in the Primary sample at 12 ug/L and in the duplicate sample at 11 ug/L. For the PDB samples, Well PZ-1 was sampled at 28 ft. NS- Not sampled. PDB - Passive Diffusion Bag U - Not detected. Number is the detection limit.

9/9/2009 11 of 14

-------------------Table 2 (Continued) au 1 Remedial Action Groundwater Results From Baseline Sampling (4/21/05) to Spring (5/26/09) 2009 Sampling

ART -1

Parameter Date 4/2112005 5/31/2005

Pump 9/20/2005

Pump 12/13/2005

Units cis-1,2-Dichloroethene ug/L NS 10,475 2,100 NS Tetrachloroethene ug/L NS 6,000 1,900 NS Trichloroethene ug/L NS 898 330 NS Vinyl Chloride ug/L NS NA 13 NS

Parameter Date 2115/2006 5/23/2006

Pump 8/15/2006

Pump Pump Dup 11/14/2005

PumpUnits cis-1,2-Dichloroethene ug/L NS 140 420 410 54 Tetrachloroethene ug/L NS 160 400 400 230 J Trichloroethene ug/L NS 43 150 150 25 J [Vinyl Chloride ug/L NS 5 U 5 U 5 U 5 U


Pump 5/22/2007

Pump 8/14/2007

PDB 3/1112008 6/17/2008

Pump 10/29/2008

PumpUnits cis-1,2-Dichloroethene ug/L 200 11 5 U NS 190 290 Tetrachloroethene ug/L 210 62 J 5 U NS 260 J 290 J Trichloroethene ug/L 72 8.6 5 U NS 110 J 62 Vinyl Chloride ug/L 5 UJ 5 U 5 U NS 5 U 5 U


BailerUnits cis-1,2-Dichloroethene ug/L 260 Tetrachloroethene ug/L 820 Trichloroethene ug/L 270 Yinyl Chloride ug/L 5 U

Pump - System's Well Pump NS - Not Sampled The ART system's pump intake is approximately 29 feet bgs. U - Not detected. Number is the detection limit.

9/9/2009 12 of 14

- - - - - - - - .- - - - - - - - - - -Table 2 (Continued) au 1 Remedial Action Groundwater Results From Baseline Sampling (4/21/05) to Spring (5/26/09) 2009 Sampling

PZ - 2


Bailer 8/14/2007

BailerUnits cis-1,2-Dichloroethene ug/L 3,300 11,000 trans-1,2-Dichloroethene ug/L 23 50 rretrachloroethene ug/L 2,600 7,600 Trichloroethene ug/L 950 3,600 Vinyl Chloride ug/L 5 UJ 5 U 1,1-Dichloroethene ug/L 5 U 8


Bailer 6/17/2008

Bailer 10/29/2008

PumpUnits cis-1,2-Dichloroethene ug/L 25,000 2,100 13,000 trans-1,2-Dichloroethene ug/L 320 13 81 Tetrachloroethene ug/L 11,000 3,900 J 17,000 J Trichloroethene ug/L 8,700 640 J 13,000 Vinyl Chloride ug/L 7.7 5 U 9.5 1,1-Dichloroethene ug/L 10 5 U 20


BailerUnits cis-1,2-Dichloroethene ug/L 9,500 trans-1,2-Dichloroethene ug/L 56 Tetrachloroethene ug/L 7,800 Trichloroethene ug/L 5,100 Vinyl Chloride ug/L 5 U 1,1-Dichloroethene ug/L 5 U

U - Not detected. Number is the detection limit. Well PZ-2 was not sampled in 2005, 2006, or March 2007 because it was dry.

9/9/2009 13 of 14

- - - -- - - -- - - - -------Table 2 (Continued) OU 1 Remedial Action Groundwater Results From Baseline Sampling (4/21/05) to Spring (5/26/09) 2009 Sampling

Quality Control - Trip Blanks

Parameter Date 4/2112005 5/31/2005 9/20/2005 12/13/2005 Units

cis-1,2-Dichloroethene ug/L 10 U 10 U 5 U 5 U trans-1,2-Dichloroethene ug/L 10 U 10 U 5 U 5 U Tetrachloroethene ug/L 10 U 10 U 5 U 5 U Trichloroethene ug/L 10 U 10 U 5 U 5 U '{iQY! Chloride ug/L 10 U 10 U 5 U 5 U


Normal LDL 5/23/2006



Normal LDLUnits cis-1,2-Dichloroethene ug/L 10 U 0.5 U 5 U 1 U 5 U 1 U 5 U 0.5 U trans-1,2-Dichloroethene ug/L 10 U 0.5 U 5 U 1 U 5 U 1 U 5 U 0.5 U Tetrachloroethene ug/L 10 U 0.5 U 5 U 1 U 5 U 1 U 5 U 0.5 U Trichloroethene ug/L 10 U 0.5 U 5 U 1 U 5 U 1 U 5 U 0.5 U ['{iQY! Chloride ug/L 10 U 0.5 U 5 U 1 UJ 5 U 1 UJ 5 U 0.5 UJ

IParameter Date 3/8/2007



Normal LDLUnits is-1,2-Dichloroethene ug/L 5 U 0.5 U 5 U 1 U 5 U 1 U

trans-1,2-Dichloroethene ug/L 5 U 0.5 U 5 U 1 U 5 U 1 U Tetrachloroethene ug/L 5 U 0.5 U 5 U 1 U 5 U 1 U Trichloroethene ug/L 5 U 0.5 U 5 U 1 U 5 U 1 U ['{iQY! Chloride ug/L 5 UJ 0.5 U 5 U 1 U 5 U 1 U



Normal 10/29/2008

Normal 10/27/2008

LDLUnits cis-1,2-Dichloroethene ug/L 5 U 1 U 5 U 5 U 1 U trans-1,2-Dichloroethene ug/L 5 U 1 U 5 U 5 U 1 U Tetrachloroethene ug/L 5 U 1 U 5 U 5 U 1 U Trichloroethene ug/L 5 U 1 U 5 U 5 U 1 U Vinyl Chloride ug/L 5 U 1 U 5 U 5 U 1 U

5126/2009 LDL

5 U Normal

0.5 U 5 U 0.5 U 5 U 0.5 U 5 U 0.5 U 5 U 0.5 U

In December 2005, Acetone was detected at 5.1 ug/L. LDL - Low Detection Limits In May 2007, Bromoform was detected in the LDL trip blank at 1.2 ug/L. U - Not detected. Number is the detection limit. NA - Not Analyzed

9/9/2009 14 of 14

I I I I I QU3

I 2008 ENVIRONMENTAL MONITORING REPORT FOR OPERABLE UNIT 3

(OLD CITY DUMP), RIVERFRONT SITE,

I NEW HAVEN, MISSOURI

I I I I I I I I I I I I

II II

Table E1. Summary of ground-watar quality data for 003. 1MCL, __lIIIII:aw....._.CInI,..-_...-...~_.ZJ__ .........~Dor:

II ~ ...... ...,.,~1IIr:-.IIO-= .._IIe:E. __Gi_" ...... J........~ .............._~R.~_,,_Gi....._, .... ~__~

La.llndlilfla; ........ - ..._--."................___................ _ .......__ IICIJ

1,3,5-T.......OIII•• T.... "......... ~ ~CIIJIIIII

II ~-..

.(IIg.2) 0.. nn. (PeE). ugII. ago\. ugII. .... 1.1111 mgIl

iJ8EPlaet' 8 ,1&11 • USEPA--,. ........• .u.aurt fllllIoIndaI' DmrII-.utr- a.cIIgraund 11.-and

II lilii8i'i,1..,EdrIIBd ...~ _ gJaIId

.....1IIicqnIInI.

CI cl <I~f:::-.I_ 'M Ui cl el cl Al

II aw.cD. HIDID 1431 ... <I <I <I tl.J6 aw.cD 0711WD lIDO cl <1 <1 <1 17.33 2.2 aw.cD 071JW2 lC1110 <I <I cl cl .5 BW4I 12I1IMD 14110 <1 <1 <I <I 1111.13 ..J aw.cD O4I'\MM lao <I <I 14.112 5.., 8W4I 07.,,104 14311 .., <1 8434 .1'" '" aw.cD D5IlIllD1 lIDO <1 <I .ZlIJ a.u .2'"II

'"

..,BW-31 07aMD 1110 <I <I 2 BW-31 1211II1II 14311

'" el el el .., II.1II - •

BW-31 12t111111 I"" el el el <I II.1II IIW-3I 041'\4104 1410 el el el .., 14.14

•.5

BW-31 071lIII04 I !lOll .2J el <I <I lUI ..JII ..,BW41 OS/2CMII 1445 el <I el 13.7 A

..,1IW-31A 07123otD3 2000 el el el .7 BW-31A 1211II1II 14311 el <1 <1 5.0.., ..., -..,1IW-31A 041'\Il104 ISID <1 el <I lA 1IW-31AG.op CNiIIl104 1515 CI el <1 <f 31.13 fAII ..,BW41A 07.,,104 11111 ... el <I _AI 1 1IW-31A OS/211D1 14110 el el <1 10 3714 1.0

.., ..,IIW-32 071ZW3 1455 el <1 23.21 1.5 BW-32 1211II1II 1230 el <I <1 <f 211. 1.5II ,_8W-32 041'\4104 I"" el el <I <f 2DAf 11 BW-32 071D1104 1210 el <I et el 21M 2.5 8W-32 0lIl21_ ei el .15J el 17.7 35

S-.. 1145 .11 el <1 el S- .. 04I'\1/D'I 1401 el <1 <I <1

07"'"

DIIIIIDI 1Il10 .U el II

S-.. ..,..... '" 03I131D1Z 1..0 el elII ..... '" "" 07GoWZ 1015 el ..., el

s- .. 041'\l1li3 13111 el <1 <1 1.0..... "" '"

"" ..,07aMD 17» el S- .. 12A'113 13111 .., 0.11 cl .., 8.0..... lUll .., rn <1 ..,041'\3104 .U .2..... .., elII 07-" 1330 .., I .., ..., '" ...M-duII 071lIII04 1345 "I

0II211D1 141. el ..., ..., ..., 7.D s- .. 4ip 0II211D1 1411 el ..., 7.0 ..... el Z

,_ '" '" JWI 112m1lll 1230 el "'1 170 UII '"

II '"

"" JS.2II 041'\l1li3 ei el 2.5"" ...,J8..2II 05121/111 1733 <I el 4.0"" J8..2II 01llW1 11., <I <I <I <I ..,J8.a 04I'\\IID 17211 el <1 el .3 .1648 0\IIZ2IDI 1411 el <1 <I .8'"

II JS.11 4llmaaJ 15411 el <I <1 el I.S JS.31 0II271D1 l11S el <I <I <I 3 JlB.I7 03/3W11 18111 el el el'" ...,JlB.17 041'\l1li3 1145 el 13D.5 3.5'" "" 1'8-17 0lIl21. 1155 el <I <I

II ""

II II

OU3_VOC_tabIe-2OO8d.xll Table EUaport-table-2OO8 10r7

I

_____

- - -- -

II II II II II

TIbia E1. Summary rA ground-watar quality data for OU3 -COntinued. 11ICL_-*-....-"""""-·QaL...-.c.~ .............._.21.......c-...&VL.......... IIII'IIIr: ................-. -. ...... c._-...:E. __aa_....J, ____ -IIIr....... ~R..._-ID-=-'.-'IiiII---......_.... _...-:____-,._..___-~_IIId ~

-'II1II.2) 0. pH (lib) . OiEplaa' IJIIEM .....,1ImI8nI. ~(;IIiIIIInIIIInI'

0.11 ~t.dIgrDund(I n aIhII8. I.., !*'-'........ -1IftIIIIIII__~.

SID II II 41 1.7

1m II II 2.1 ~lR*1U~--~~wwn}~w.~------------------------~~----------------------~~----~~------~~:&__ damadc ..... -..,. 'lIS 13 " IA

aURIS iiil&l 1IW41' MI2IIDO IIW41 071JW11 70 1,341)

'.517,. '.140I_,..,5 I. '.au I,IJD I_ I..., l.au

1.210 I,ZlI) l,am l,am ,JIiD 1,11D

",,0 IJIII I.., IJIII UID

,' ---IA4CI

'.7!0 lAID 1.1111

' ' 1.720 1.720 1,4ID 1,4ID

'4.7 IIW41 0'7I240Q2 14.1 2 BW43 1:M1M13 70 •

11'21 141 III ZI

IIW41 0111"" 7.1 III a IIW41 07111T104 71

".1 '21 111 117 811 1.11

IIW41 CIII2WI 7.0 7.1 111.2',Il10 '4A 2.0''311

aw.31 07/ZMD 7.5 lSA lal

•III u

aw.31 12I1M1S 7.1 lA118'4A IIW-JI 12t1M1S 7.1 14A 113 'A•,eABW31 01114104 7.1 1A BW31 071lIII04 7.0

94'21 leA U

BW-31 111112111111 7.0 III U

1.88au1.110 11.2 125

sw.',A 07/ZMD 7.1 1011a17" •BW-31A 12t111D3 U 13.1 14'M '.It 1.1

BW-31~ 01115004 7.0 BW-31A 0II1MM 7.0 lU 123 811

113 1.8 BW-31~ 07m7104 7.1

811'23,... 1.8 1IW-31A 0lIl21. 7.1

14'14 11.2 1.81.110 118 II'

IIW-32 07/ZMD fA 1.8 IIw.32 I2IIMIS 7.0

14.1 127 12 17

IIW-32 01114104 7.0 11a".7 II'

14.7 71 1A IIw.32 071U8104 7.2

122 11.1 71 1.3

IIw.32 7.0 7.1 "11

0.71111m. 123 78.81.270 13

18 '141 I 40I.07/'''' - ••""M 0II1M11 -""M

7.0

.... W 051111111

.... W 1D/131111 -21

011181113 7" 0711W2 I.D

ILl""M""M....W O71ZMD II al" 12IIIIIII:I 7.0 la.I""Ma.pM 7.:1 12.1

IIMpM 07,.,.,. 7.? 0111""

'8" IIMpIUup 07,.,.,. 7.7 lU

1,485 18 a.pM. DIn1. fA 7.1 a.pM 05121. fA 7.1

- 18'.481

'22 I. 143 125

'74 IU 1111

lIS 77 111 II 71 II II

17 ZI 22 ,.1 27 21 21

21.8185 511.3 1114 55.1 2U ..... OJRn• U 7.1 178 14' e:u au 1.3..... 0II1M1S 7.J .. '4.2 13 41 1A..... OS/21. 7.J 7.1 178 178 14.8 111.7 10.8 1.4..... OllMOI..... 0II1M1S 7.8 117 147 l1li 40 14..... CIIII22IDI U 7.1 121 5311 ,4.1 13.1 42.2 1.1

J5-l1 41IMIIIIJ 7J 14.6 76 57 IAl1l/I7.JS.31 7.2 7.3 117 1117 ,1.5 12 80 'A P&-17 1DI31111 PB-I7 0II1M1S 7A 1!8 14A 12 41 lA 1'8-17 0lIl21. 7A 18 810 14.8 IIS.I l1li7 1.5 -

2of7

I

- - - -

••II II II II II II II I

II II II II II II I

Table E1. Summary of ground-watar quaDty data for QU3 -ContInued. 11ICL. ___....GW.,.....-.CInL..--III-....-..-••....,..CIIIu;UJIIL..............-. ...............-.-....-=c, __E. ____._,J.__--._IIIr.....___R.~- ..--..i--....---....._.... _..-:......~__--._ot_......._-._--~--11111

~.pHU"9'L ~.1IrIIIan 1bItIan8II.wu.da ~ ........ b(llg.21 Da IodIwft. mgII. c.co3 II9'lc.cos dplJldmgll II9'l mgII. ".1I9'l iJ88iiWi' 4U9EPA......, 1IIrIIIIId' 210 2

0miIi...,.......... ow iIIInIImd' .......ern-a 4

lIIID 431 1.2 0.1'--,., • .. EIInIId .... """"... .,aund--*JpDund' 10 410 410 141 0.2•~UIIIl'~")'1nB'"11IInm ....~wdI ...... I] 4IM 41] 5CM 17 U 14

aw:as 1IW4S" IIW4S IIW4S IIW4S

'1IW4S IIW4S 8W4I

JlW.31 JlW.31 JlW.31 JlW.31 JlW.31 JlW.31

JlW.31" BW-31" aw.31" JlW.31M1up JlW.31M1!1p BW41"

JIW.32 BW-32 JIW.32 JIW.32 JIW.32

a.pM a.pM a.pM a.pM "",M a.pM a.pM a.pM a.pM a.pM .........." a.pM a.pModup

.IJI.2I J8.2I J8.2I J8.2I J8.21 JS.2I .!WI JS-li ...,7 ....u ....,7

iiOBi ftIDII 07/JU1O - 0712W2 IUIMIS 0411.. O71fn104 0lIl21l1li

07l231li3 12I15IDS 12I1M13 1MI14IIM 07,.". 01lI2IIIOI

0712M13 12I1M13 0411...,. 0411...,. 07NnI04 01121101

0712M13 12115101 04114104 07111MM 0!I21101

0711_ O4IIMlI 0II1W'1 03111102 O712WZ O4IIM13 0712M13 l:v.m O4IIMI' 07/11lI0II O71DMM 0!I21101 0lIl21101

I11III7. 1.31 331 04111103 I 371 0lIl21101 1.71 01/~I

04111103 2.4 247 01I/22I1II 2.11

flI 411 IS 457

411 flII :MIl 411 IJa 1211

0.1 I I. 0.1 14

I •71 a:s

410 452 433 as - 414

IISZ 200 01 DO.11 lao 0.1 17 1111 2Q3 0.11 I ...

12 71 71

••flI. 10 21 21 211 211 2U

43

•41 40 5U

107

---D

•12 eo 71 110 110

•11.1

411 47!1 II1II 407 - 4. 407 - 4. 483 412 511 473 473 fl17

- !lID It4

421 431 S2II 110 513 125.. 510 122 101 510 122.. 508 120

- - ."

113 141 -441 454 1liioi l1li fl15 7112 512 511 1liioi - IISZ 7115

I - - -- - -- - -- - -412 - l1li II. m .. 471 4D 180 lID .. 181 110 111 .. 140 143 III 140 143 ID

- 127 143

- - -

170 0.2 20 110 0.2 18 150 0.2 18 lao 0.2 21 tao 0.2 211 till 0.22 t8.2

17 0.2

1 • 111 o.t 11

211 0.1 14 18 0.1 14 11 01 14

2U 1 0.11 12.7

51 0.2 211 71 0.1 11 51 01 27 10 0.2 24

311.7 022 32.8

I 113 I 0.2 I 11.7 I- - -- - -- - -1211 0.1 I 11 I 170 G.1 13 tlO 0.1 14 210 o.t I 17 I 100 0.1 12 110 0.2

1 17

1110 0.2 17 D.7 !O.I2 10.3 D.I EO." IDA

14 411 4Z1 51] :zo 0.1 I]

11 312 27 0.11 13.3=1 .. 03/31,. 1MI1M13 I.e 51 441 4A 0.1 14 0lIl21101 I'- m 412 4.l1li 017 1303

321 410 312 461

250 305 211 :sa

-

CUD 0.2 13. 4.2 G.1 13 373 0.11 11.8

2.2 C.l0 1.11 1.7 EO 12 114

3of7

••

--

II II Table E1. Summary of ground-watar quality data for OU3 -continued.11ICL __...._..--.CIand....-_n_por_.2I__ .... -.....porMr.ft9L, ........por-.~

.... --.,_... _.-_.....-.; ............__.Irdc*I __

IIuIIII, AInrIIriI. fGtH02. ~.mglLOO.........1III I'tIaIpIaw, 0IgInIc

-. ..-. ... ___E.---.-._______ .I. ....... - __-IDrClllD"~II, ...........--...- .....1oICI.I---..........• ._NSllCIII.2) Ddt ...._N aN •• mglLaP mgIL cnan.nv'l AnIrnorIr. UD'•

I DiEPXaa' USEPA ---, aImIdaId I IiIIIIauII GN.a.ndInI'

II o.k.....1IICIrFIUIIII c.... II1II .... 1818) ~ ........ _QnIIIIIIIo

-~. fUPiIII'~I&_ua--.....n..... 16 OeM 2.1 cl

,aas ,liii 8 :eo

lD.DO I

11 O.as 1.50 c.03 2JI cl

II CI.04 2 c.03 3.8 Cl

II IiWJ BWG3"

BWG3 BWG3 BWG3

II BWG3 BWG3 BWG3

BW-31 8W-31 8W-31 8W-31 ~ 8W-31 8W-31

8W-31A 8W-31A 8W-31A 8W-31A41p~ ISVN',..

II ISVN'A

8W-32 BW-32

II BW-32 BW-32 IJW.32

BeepM BapM BapM

I II

BapM BapM BapM BeepM !lapM lapM !lapM !lap lokIup SeepM SeepMo4IupII .... JW8.... JW8....II .... JS.l1

II JSJI PB-17 PB-17 PB-17

iJiiIBi R'2OOO 07124Q)--rn- e.Gl 1:MIIIID 1111 .a 0411l1li4 74 .oz 07ft11l04 ,. .G1 0lIl21l1li 11..2 cO.QZ

c,01

1211_ O712MD 110

110 .1M 12115l1li c,01

04114104 liD 1:111 .oz

071OM14 c,011:111 127 cO.QZCIIWIIIII8

MI c,01

0411&104 1211Il103

220 .ozmmmrn c,01

0411&104 220 .G1 07107104 220 .G1 115/21l1li 1.1 B1.G11

c.G1 12t'15103 14 c,01

04114104 41 c.G1 071OM14 47 c,01

0lIl21l1li 42.2 cO.C12 -rn 07"_ - .oz 04111101 Cllltll111 CIIt1J111Z 071J41D2 1:111 .oz 0411Il103 210 .11 O712MD 170 .",.12111M1:1 c.G1 0411l1li4 .10 071OM14

:140 :IIID .as

07liliiii4 :IIID .III 0lIl21l1li :all .oz 0!II211111 ZM .III

0ZftI1a1 !.II .III 0411Il103 7 ,04 05121l1li 7.41 cO.oz 01l241li1 0411Il103 1.8 D.G3 CISIZIIII8 cO.QZ" D.DJ41II1D1Jrn I18127III8 Z2 c.oz 03131II1II 0411l1li3 1.8 0.114 011/211118 UI cD.C12

[]] ...01 ...01 ...01 ...01

C.11112

5.10 UO 540 lAO .111 170

...01

...01 c.ol c.01 c.ol

CI.OO3

c.oz cOl c.oz e.Gl c.oz Clll c.oz clll c.oz e.II'

CO.IM o.ooz UII c.ol rn cOl

...0, 2111 cO,

c.11112I. t.. 0007

...01 0.0'0 rn 0.010 c.01

0.G3D c.01 ...01

0.- 0.004 0.- 0.004

UI cOO, 1.511 c,01

'.74 cOO2

Il.Ol ...01 0.111 c.11112 2J

2.77 c.11112

t.l0 c.ot UI c.11112

EO.IIDII

0JIZ2

EO.G04

O.on

O.oz1

0.l13li 0.D41

OJlOll

EOO4

E.OO4 c.olO E.OOI

.0

c..CI2 .aa

c.oz c..CI2 c,04

.D4

.G3

.oz c.02 .oz

EO.03

.DB c.Q2

c.oz c.oz c.oz c.D4

.01

.21 c.oz c.oz .aa

21 311.0

:u

... 1.4 1.2 1.3 3JI

.8

.8

.4

.4 3.2

480 .8 U 3.7

7.8

C1 4

C1 C1 c.l

C1 C1 C1 C1 C1 c.l

C1 C1 cl C1 Cl C.l

cl cl cl C1

c.'

a

-.DB .115 .aa

c.oz .aa .'0 111 .os .DB

cO2 cOl

c.oz c.D4 c.1II c.OI

c.02 c,04

4.7 28.G 7.0

u•• :l1li.0 11.0

.2

C.l

.J

.2

CDcl 3 2 I

, ..7 , ..t

c1.00 C1 c.t

C1 c.l CI c.l

ct C.l

II 003_VOC_lab1e-2OO8dJdl Table EUaport-tabl.2008 4of7

II I

.. II

•••II f ~

-: ~

\ .. ~

.. .. II II II I

__ .."_....___...........

8l1li(110.21 OIEpXua u

om ~ugII

10 a.un. ...

i6I

a.,tIun..., a

1IanIn. ... C8dndum.

19'1 i

a-mom.... CIlbIII. ugII

1110 CappIr.... ,.. han, ugII

USE"" -*'1IIndIInI' 1,I11III 3011 ~GW-.oImd· so 2DOO 4 2IIDO II 1110 10D0 1,3011 3011 o.rto ....~(tn. 1IId .... 18111} cl 1110 cO.I C20 Cl ca 43 17 CI4 EIImIIId New 1tIWn_ ~bIcIo;nIund' cl 130 cl 1:1.11 C1 ca 43 21 10

Table E1. Summary of ground-water quality data for OU3 -Continued. 11IICL...-an_...IMIIftIIIIId_CllnL...._In_..,_.ZI..--=....___..._........-.....-. -.nodlll: c.- E.--...... ... ---__........ I11111*'.......,..nd; 11. ....... 111 __Ll.1IIIII--'------,-... --IIftIIIIId--..: .........----1ICI.I

~Hfiii"="'"...... .:. IN cl 12 C.I CI <I 10 S"" dW!ib aw-03 • aw.o:s aw.o:s aw.o:s aw.o:s aw.o:s aw.o:s BW-31 ~1

1IW31 1IW31 1IW31 1IW31

1IW31,. BW-31,. ~1" BW-311041up BW-31,... BW-31"

8Wo3Z BW-32 awa BW-32 BW-32

a.pM&.pMa.pMa.pM a.p .. a.p ....... a.pM a.p ....... llelpMoclup

1IeIp" lIeIp"odup.... J8.2I J8.2II JS.a JS.2I J8.2I JS.JI JS.l1 1'&17 PB-17 1'&17

iiih&ii 6IIIZOIID 117/21M1O -I17I2C11112

I... 130

170 130

10 C4 I 120

cl c.8 cl C1 C2 , lV11M13 cl c.ll C1 UI C2 314 CI4t1M14 cl <.I C1 cl C2 C2 I17I117IC4 C1 C.l C1 C1 C2 C2 lIII/21a CI.1 111 c.2 BUM 004 .2 ED.IIIO EllI 'a I II7I2MD C4 lIS c1 c.5 C1 cl C2 II 121111m C4 12 C1 c.1I I cl C2 10 1211MD C4 <1 c.5 C1 cl C2 I

4 1DO C1 c.8 Cl cl C2 4:n~1 II 17 cl c.ll C1 c, C2 C2 IIiI/2IIIIII D.II <.2 EII.04 004 .5 U <I.,• rn II7I2MD C4 40 <I 22 C.I Cl C1 C2 778 1211MD C4 :17 cl 11 c.5 Cl C1 C2 11,540 1MI1M141 4 34 cl <.5 <1 cl C2 2.720 CI4t1M14 ... 34 cl <,5 cl cl C2 2.I7DBB 117111711141 7 cl "11 c,5 cl C1 C2 152•0III21a 0.1 31.1 c.2 11.1 EDJIZ CI.2 JI cl 2.110

II7I2MD C4 72 cl 17 c.e cl C2 I 121111m C4 47 C1 12 c.5 cl C2 1!111 CI4t141D4 C4 70 C1 c5 cl <1 C2 I I17I11MM I U C1 II c.ll C1 cl C2 7 0lIl21. 0.2 1117 c.2 111.1 BIJI3 1.1 .1 cl E5bid I17I1I11U cl 111 cl.1 I !ino I 2 1.7 C1.oo II C10 CI4t1M11 IIMIID1 1I3I1M12 07l241li2 C4 111 C1 c.5 Cl cl C2 I IMI1MD C4 110 C1

1.111D 1.110 0.1 Cl c, C2 4 I.... <.5 Cl cl 2 II17ID103 ... ,DO cl .,c,121IIIIII:II C4 C.I Cl cl C2 C2

CI4t1M14 C4 '30 140 cl l.uo C.I cl a.o C2 14

117_ 7 c.ll cl 1.0 :a ZI 117_ I

1.1M11120 cl c,III c.5 1.0 4 22

IIIIIIl.u I c.2 120 cl

1.II1II 004 EO.l A Z.ll I!I•0SI21.u 0.1 17.7 c.2 1.II1II 0.31 EO.l A 2.53 EI

1121117,a C2 4U cl.1 E12 cl.DO C.I cl.DO 10.1 E5 IMI1I1m ... 11 C1 I c.e C1 Cl 7 C2 OIII21a 0.1 C8 c.2 lD.4 c,Q4 :I .1 4.17 cI 01Q4101 IMI1I1m C4 140 C1 10 c.5 cl cl C2 :I OS/22IIIB 0.2 III c.2 13.2 c.Q4 ED.l .1 10W 1. 4Il~ C4 59 <I 10 c, <I <I 6 cJ 0III27~1 CI.2 17 c2 71 om 03 CI.2 3 113131111 1MI1M13 C4 cl I c.5 cl cl 2 C2•0lIl21. .1 41.1 c,2 1.1 c,Q4 CI.2 .1 247 cI

OU3_VOC_IBbIe-2OO8d.xll Table EUaport-tabl.2008 5of7

--

II ,

• Table E1. Summary of ground-wetar quaBty data for OU3 -Continued. 11oICL. ____.... rM....._Cllnd....-_n_..._.21__CoIDa.&9L.......- ...-...... ~1III'1IIor: - ...-.c,_v-E. ___.-..", __........_IIr_~A.~.....__*'i._...... ___.....-La._-.__ __....,._..........__--.IiaIiIIIcaIi'id__-_1oO.l~

~. "l1li- 2) DIll ..... 19'1 Ltinl.19'I ........-. ugII 10'1 NlcMl,uaII "'.19'1 BmdUn.ugII Thdurn....,1• DiEPXMa' U8EPA--.,~i

• MIIIaurI GW 1IIIIIIIIId' o.t& ~,,1IIICIIgna.ind ('"-II1II ....,. .,.......".....- -QIIIIiIIdo-.........' I1lJjii'UiiII "5lIfJiRii 111)111"'"11Ia--.............. iW!iB 1IW4S• IIW4S , 8W4I IIW4S IIW4S BW43 BW43

BW41 BW41 BW41 BW31 1IW41 BW-31 ~ BW41A BW41A BW41A BW41A4Up

I ~ BW41A4Up

1IW41A

IIW-:I2 IIW-32 IIW-:I2 IIW-32 IIW-32

a.p .. a.p .. a.p .. ~ a.p .. IlelpM lIMp"",MI

I ..... lIMp" a.p .. a.p.....", a.pM a.pM-4iIpII .-..... .-.. .1&-. JI.3I.. .... JS.31 JS.31

II 1'8-17 P&17 P&17

Sliili& 6/IIZOIIII Cl71:M11111 Cl7QWZ IMam 0411-" 1171117/04 05121l1li

II7IZMD 12111m 12111m 04114/04 GJIIIII/04 IIIII2IMJI

I17I23m 12111m 04I11MM 0411Il104 1171117/04 011/21l1li

I17I23m 12111m 04114/04 GJIIIII/04 05I21D1

GJI1M111 O4I1M11 ClMI~

Cl3MMIZ 117/J11m O4I1om GJIZMD 12.'lIlIIII3 0111-" I17IDM14 I17IDM14 0M11111 01121.

ClllCl7I1111 IMIlom 1IIIIZ1D1 011J011D1 OII1om IIII/22IIII 4I16IlIIID Cllll27D1 l13l:I1. 04I1M13 1III/Z1D1

so 100 III !II 100 so

ClO q Z cIa ClO cl

cl0 II :a Cl

c:a 2 ci Cl cl cl

:I cZ cZ cZ R

C2 cZ cZ cZ cZ R

cZ cZ cZ C2 cZ R

cZ cZ C2 cZ R

CI.CID

C2 cZ C2 cZ cZ cZ ,.z R R

CI.CID cZ R

,.z R C2 11.2

cZ R

2 cZ cl 1.1. C2 cl

:I cZ Cl :a cZ cl

1.4 c.2 c.l[] I i I

4 C2 cl C2 CI• cZ cl•2 cZ Cl

:I cZ I cl II &1.1 4.1 C.l

[] ITJ 45 14 C2 c,., [J

cl

cZ cl., cZ cl II C2 cl TI 11.2 c.lD •

II cZ Cl 12 cZ cl 4 cZ cl 4 C2 cl 1 EII.2 c,IOJ ITJ

13 147 3.7 23.1 CIa

7 CIII cZ 13

•..m cZ CI 12 15•

el 4

cZ el

14

• 22 C2

,.z el12loaD el

In ,.z IIIHI I

elI. I. 1.1 11.5 c.l10•

CII. I 11.120

E2 ClO cl.0 C'I.GD CI.a 2 CI cZ el el 2 U EII.l 0.1 e.I

2 CI cZ cl el :II .. .3 C.l Z cl Cl cl cl -:II I 0.4 Ell 1 U c.I

2 el ,.z el CI 2 EII.2 BI.2 .7 e.l

Z

2

IZ cl

TI cZ

124 <I

cZ

cZ cZ

c.IMI ~ I cZ

cZ cZ cZ[I] cZ

cZ EII.112

1111 1111 1111 1111 170 117

cZ cZ cZ cZ cZ

c.IM

cZ cZ cZ

cMrn cZ

4311 c.1II

370 4111 400 2411 410 170 l1li 411 4111

cZ cZ

.cZ cZ cZ cZ cZ

EII.112 c.IM

...I 100 101

c.1II cZ

cM

17 i& IlO 140

cZ ..,1)4

<I cJM

100 cZ 102 c.IM

OU3_VOC_labl&-2OO8d.xll TIJbIe EUaport-tabl.2008 San

II I

II

II ~

• T.bIe E1. Summary of ground-water quafrty data far OU3 -Continued. 11IICL __IMtGW ...... _Cllnd. ....._In_,._.:zs-.--...... __.. -. ................. -. .._ ... _IWI;E. ____._,..I,_.............____=""'--'=R.............--..,........----.....

LA. .........................---.,--·......__--.s...........---....-MCIJ

8l1liII1II.2)

O&EPAad' USEPA--., ......•

• -..-.. GW.....s.nt· QrM..,........... (.....• .......,.'~ .......... -graInI_ .......a

1JIjjIIniiII~iIn& I......_~..u ....... IiW8i IIW.(I3 •

IIW.(I3

IIW-CI3 BWG3 BW4iI IIW.(I3

IIW.(I3

BW-31 BW-31 BW-31 1ML31 BW-31 BW-31

BW-31A BW031A BW-31A BW-31Aoc1up BW-311Wup BWo31A

aw..:a aw..:a aw..:a aw..:a BW-32

a.pM a.pM e.pM &.pM a.p .. a.p .. a.p .. e.p .. a.p .. e.p .. lIIIIII ....p e.p .. a.p .. -cIup .... JII.2II JII.2II.... JII.2II

Js.J1 4fldmIIIl cl 1.1 -JII-.J1 l1li27_ 40 PB-17 01131111 PB-17 D4I111m C1 III PI-17 l1li/21l1li.1 ZI , D.l b:au.,.'" p;;;a;;x;;:;;,__a ...........7I'JIIIii • .....".....'5 _ £ ..==II1II___ Z........ ~tJI .........--.-.-.,.......-.l71ZM1a. ~n.... W~o.:.'I0c20-7IIpt11

:IE--... 'Z5 ....... tJI..~aan ........... ___ IIr .......aIIIIIrIlla):IpedIc_-.......... tJll........_ damIiIIc.... (IJIIEM, lIIIDIi~

4....CllllldmDam_......................~~IIIIII"IIaIq..........._ ....(........... '211,OODUIIIlI ... ..".-(........... UCID I9'lJ.

7of7

I

I I I I I OU5

FinalI Fall 2008 Sampling Data Evaluation Report Riverfront Superfund Site

I New Haven, Missouri

Operable Unit 5I Old Hat Factory Site


----------

I I Table 4-2

Historical peE Data Summary Riverfront OU5 Site

I I I I I I I

Well Number Sample Date peE (ug/L)

BW-09 1

10127/04 0.46 J 02101/05 0.49 J 09121/05 0.70 J 10129/07 2.3

1012312008 z 0.87 J 10128108 0.59

BW-09A 1

07129/02 49 37 27 110 52 47 24

30(26)

08/12103 08119/04 02101/05 06/14/05 09121/05 10125/07 10128/08

BW-12A '

04126104 1.0 U 08119/04 0.49 J 02101/05 0.23 J 09121/05 1.0 U 09120/06 1.0 U 10128/08 0.5 U

BW-15 01/30/08 0.5 U 10128108 0.5 U

BW-16 01/30/08 48(00 10128108 32

1 - All peE data except from 10128108 provided by USGS 2009.

2 - Data collected by USGS.

U '" Not detected at Of' above the reportable level shown.

J '" The associated numerical value Is an estimated quantity.

ugIl. =micrograms per liter

Shaded results Indicate where contaminant was detected

above cleanup level (PCE and Carbon Tetrachloride - 5 ugIl).

Duplicate sample results in parentheses.

Riverfront Site - OU5 044752 LTRA 4-7 April 2009

I I I I I I I. I I I I I I I I I I

Riverfront Site OUS

I LTRA

I

Table 4-3 COC Results Summary - Fall 2008

Riverfront OUS Site

Well Number PeE

(ug/L)

Carbon Tetrachloride (ug/L)

October 2008 October 2008

Groundwater Sample Depth

(ft btoc)

BW-9 166 0.59 0.5 U BW·9A 40 .(21) 0.5 u 8W-12A 40 0.5 U 0.5 U

8W-15

70.5 NS NS 73.5 0.5 U 0.5 U 76.5 0.5 U 0.5 U 79.5 0.5 U 0.5 U

BW-16 70 NS NS 73 %I 7:1 76 12 U

ug/L = micrograms per fiter

Shaded results indica1e where contaminant was detected above cleanup level

(PCE and Carbon Tetrachloride =5 ugIl).

Chlorfrom was not detected. ReWt U =Not detected at Of above the reportable level shown.

Duplicate sample results in parentheses.

NS =Not Available to be sampled because of low water level.

ft btoc =feet below top d casing

Other VOCs deteded infrequently at low concentrations indude:

TeE was detected at 3.2 ugIl in the primary sample for Well BW-9A and at 3.1 ugIl

in the 8W-9A duplicate sample.

4-8 April 2009 044752