Five-Year Review Report First Five-Year Review Report for Missouri Electric Works Site Cape Girardeau Cape Girardeau County, Missouri September 2004


Five-Year Review Report

First Five-Year Review Report

for

Missouri Electric Works Site
Cape Girardeau
Cape Girardeau Comity, Missouri

September 2004

PREPARED BY:

United States Environmental Protection Agency
Region 1

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Approved by:	Date:

Cecilia Tapia
Director

Superfund Division
U.S. EPA, Region 7

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Table of Contents

List of Acronyiiis .*......¦	i

Executive Summary ###»##*:*l.#*iF#!*:*l.##!# if###**#**##*:###*### ft ft##*##*** ##¦»:## * ###~### ##*# If « *f # It * *> M #: ¦* 1* 1* & # * *f HI
Five-Year Review Summary Form .......									iv

I.	Introduction

II.	Site Chronology

III.	Background

Physical Characteristics 												4

Land and Resource Use 					 4

History of Contamination
Initial Response
Basis for Taking Action

IV.	Remedial Actions

Remedy Selections 												7

Remedy Implementation 											9

System Operations/Opeiation and Maintenance (O&M) 					11

V.	Progress Since the Last Five-Year Review

VI.	Five-Year Review Process

Administrative Components 		

Community Involvement									12

Document Review 												13

Data Review 				..............................						 13

Site Inspection 								 14

Interviews																 14

VII.	Technical Assessment

Question A; Is the remedy functioning as intended by the

decision documents? 						..					.				 14

Question B; Are the exposure assumptions, toxicity data,
cleanup levels and remedial action objectives (RAOs) used at the time

of the remedy still valid? 									 15

Question C: Has any other information come to light that could C* ?
call into question the protectiveness of the remedy? 								 15 5 ?

Technical Assessment Summary 								16

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IX.	Recommendations and Follow-up Actions 	 17

X.	Protectiveness Statement^) 	 18

XL Next Review 	 18

Tables

Table 1 - Chronology of Site Events
Table 2-Issues

Table 3 - Recommendations and Follow-up Actions
Tables A-l to A-14 - Quarterly Groundwater Monitoring Data

Attachments

Attachment 1 - Site Location Map

Attachment 2 - Site Plan
Attachment 3 - Wetland

Attachment 4 - List of Documents Reviewed

Attachment 5 - Applicable or Relevant and Appropriate Requirements (ARARjs)
Attachment 6 - Quarterly Groundwater Monitoring Data (Tables A-l through A-

Groundwater samples

were analyzed for the following compounds:,,, Benzene, Chlorobenzene, Toluene, Chloroform,,,,
Butyl benzyl phthalate, Di-n-butyl phthalate, Bis(2-ethylhexyl phthalate, PCB unfiltered, and
PCBs filtered (see Tables A-l to A-14).

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List of Acronyms

Acronym

Definition

1,1,1-TCA

1,1,1 -Trichloroethane

1,1-DCA

1»1 -Dichloroethane

1,1-DCE

1,1 -Dichioroethene

1,2-DCE

1,2-Dichloroethene

11,2,4-TCB

1,2,4-TrichloTobenzene

11,2-DCB

1,2-Dichlorobenzene

1,3-DCB

1,3 -Dichlorobenzene

1,4-DCB

1,4-Dichlorobenzene

ARAR

Applicable or Relevant and Appropriate Requirement

ATSDR

Agency for Toxic Substances and Disease Registry

BGS

Below Ground Surface

CD

Consent Decree

CERCLA

Comprehensive Environmental Response, Compensation and Liability Act

CIC

Community Involvement Coordinator

EPA

United States Environmental Protection Agency

CFR

Code of Federal Regulations

DOJ

Department of Justice

ESD

Explanation of Significant Differences

FS

Feasibility Study

LTTD

Low Temperature Thermal Desorber

MCL

Maximum Contaminant Level

MCLG

Maximum Contaminant Level Goal

MDNR

Missouri Department of Natural Resources

MEW

Missouri Electric Works

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Acronym

MEWSC

Definition

Missouri Electric Works Steering Committee

MEWSTD

Missouri Electric Works Site Trust Donor

NCP

National Oil and Hazardous Substances Pollution Contingency Plan

NPL

National Priorities List

O&M

Operation and Maintenance

OU

Operable Unit

PCB

Polynuclear Biphenyl

PCE

Perchlorethene

PIC

Product of Incomplete Combustion

PPB

Parts per Billion

PPM

Parts per Million

PRP

Potentially Responsible Party

RA

Remedial Action

RAO

Remedial Action Objective

RD

Remedial Design

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Remedial Investigation

RI/FS

Remedial Investigation/Feasibility Study

ROD

Record of Decision

|tce

Trichlorethene

TSCA

Toxic Substances Control Act

USOS

United States Geological Survey

voc

Volatile Organic Compound

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Executive Summary

The soil remedy for the Missouri Electric Works Superfiind site in Cape Girardeau,
Missouri included excavation, processing, and treating PCB-eontaminated soils using thermal
desorption technology. After treatment and analyses to confirm that treatment standards had
been met, treated soil was used to backfill excavated areas onsite. The entire area was capped
with a contaminant-free soil. The upper foot of cap was enriched to support vegetation. The soil
remedy was complete with the acceptance of the Soil Remedial Action Report during September
2000. The trigger for this five-year review is the start of remedial action (RA) on-site
construction, which occurred June 7,1999.

The groundwater portion of the remedy at the Missouri Electric Works Superfiind site has
not been implemented. After the ROD was signed in 1990, new hydrogeologic information was
obtained by the Missouri Electric Works Steering Committee (MEWSC). This new information
indicated that there was a possibility that PCBs were present in the groundwater at depths greater
than three hundred (300+) feet. Solution features woe encountered at depths of 110,220 and
315 feet below ground surface (bgs). The solution cavities at depths of220 and 315 feet bgs
were mud-filled; the mud and water were contaminated with PCBs. A focused remedial
investigation and feasibility study for groundwater has been conducted for the site. AThe EPA
expects to issue an amendment to the 1990 Record of Decision (ROD) will be issued to address
the "new" groundwater conditions.

The assessment of this five-year review found that the soil remedy was conducted in
accordance with the requirements of the ROD. One Explanation of Significant Differences
(ESD) was issued to include onsite thermal desorption in addition to onsite incineration as
acceptable methods of treating the PCB-contaminated soils. The soil remedy is functioning as

designed.

The threats from groundwater have not been addressed. (There is no human consumption
of groundwater In the immediate area.) All components of the 1990 ROD have not been
implemented; therefore protectiveness has been achieved only for the soils. Additionally, new
policy to assess the potential threat to ecological systems or the environment have been
implemented since 1990. There is a need to perform an investigation to collect data necessaiy
for an Ecological Risk Assessment to determine whether additional efforts are necessaiy to
achieve protectiveness of the environment.

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Five-Year Review Summary Form

Site Name(fTom WasteLAN): Missouri Electric Work*

EPA ID (from WasteLAN): MOD980965982

Region: 7

City/County: Cape Girardeau/Cape Girardeau

xRernediation status (choose all that apply): U Under Construction ~ Operating ~ Complete

Multiple OUs? * [S YES [UNO

Construction Complete Date: / /

Has site been put into reuse? ~ YES IS NO

Lead agency: H EPA Q State Q Tribe f"] Other Federal Agency

Author name: Pautetta It France-lsetts

Author title: Remedial Project Manager

Author affiliation: U.S. EPA, Region 7

Review period: " 12/11/2003 to 08/31/2004

Date(s) of site inspection: 12/11/2003 & 04/19/2004

Types of review:

S Post-SARA	~ Pre-SARA

~	Non-NPL Remedial Action Site

~	Regional Discretion

D NPL-Removal Only
~ NPL State/Tribe-lead

Review number: [X] 1 (first)

C 12(second)

~ 3 (third)

(~| Other(specify)

Triggering Action:

IXi Action RA On-site Construction at OU #1

~	Construction Completion

~	Other (specify)

~ Actual RA Start at OU #	

D Previous Five-year Review Report

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Triggering action date (from WasteLAN): June 7,1999

Due date (five years after triggering action date): June 7,2004

[OU refers to operable unit.]

* [Review period should correspond to the actual start and end dates of the Five-Year Review in WasteLAN,]

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Five-Year Review Summary Form, cont'd.

Issues:

Erosion along the eastern perimeter of the site has caused some of the treated soils and
cap soils to leave the site. The treated soils are highly susceptible to erosion; therefore it
is necessary to maintain the soil cap and vegetative cover.

Institutional controls were not placed on the site with regards to soil contamination since
all soils with PCB concentrations greater than 10 parts per million (ppm) were removed
from the site.

Institutional controls have not been placed on the site with regards to groundwater, this
needs to be done.

A wetland area south of the MEW property has been impacted by contamination from the
site.

Insufficient groundwater monitoring data has been performedcolleeted in the wetland area
to determine whether or not the contaminant plume is migrating.

Insufficient groundwater parameter data has been collected to evaluate whether or not
natural attenuation is occurring.

Recommendations and Follow-up Actions:

The erosional area of concern should be inspected annually. If the slope conditions have
deteriorated, the property owner should repair the slope.

An amendment to tThe 1990 ROD needs toshould be writtenamended to remove the
requirement of institutional controls for the site soils.

Institutional It may be necessary to implement institutional controls for groundwaterose
need to be implemented.

An ecological risk assessment and investigation needed to collect the required data should
be performed. A decision should be made at that time with regards to any additional
actions that may be required for protectiveness of the environment

Additional groundwater data will be collected to evaluate whether or not the contaminant
plume in the wetland area Is migrating.

Additional groundwater data will be collected to evaluate whether or not natural

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attenuation is occurring below the wetland.

Protectiveness Statements):

The soil remedy is protective of human health. Hie groundwater portion of the remedy
has not been implemented. The groundwater could representpresent a risk to human health
through ingestion or inhalation. New standards have been instituted for ecological protectiveness
since the ROD was written. Additional work, needs to be performed to determine whether or not

there is an ecological risk.

Additional sampling and monitoring of the groundwater will be performed to evaluate the
migration of the contaminant plume below the wetland area and to evaluate the potential
of natural attenuation of the contaminants of concern. An investigation will be performed
to gather the data necessary for the Ecological Risk Assessment A determination will be
made after the Ecological Risk Assessment is complete whether or not additional actions
will be required for protectiveness of the environment.

Long-term Protectiveness:

fcThe completion of the soil remedial action (destruction of the PCBs in site soil) has
resulted in the long-term protectiveness of human health by the soil remedial action has
been provided by destruction of the PCOs attached tu llii soil. Lung ienii'protectiveness
ul* human health-ferwith regard to exposure pathways posed by contaminated soil at the
site-

As stated above, due to the post-ROD discovery of contamination at depth in the

groundwater, the groundwater operable unit will be provided by implementing
institutional controls to prohibit use of the ground watu and inunituiiug lu determine rf
the contaminant pi mm is migidlitig.

Loim-tenniemedv selected in the ROD has not been implemented. The responsible

contamination and to present groundwater remedial options. That Groundwater Design
Investigation was recently completed by the MEWSC and submitted to EPA for review.
The EPA anticipates that it will soon select a groundwater remedy for implementation at
the site. The long-term protectiveness of that remedy will presumably be considered in
EPA's next Five-Year Review for the site.

T|yjyong4|CT the environment will be evaluated

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been taken. The long-term protectiveness of the environmentsoil and groundwater

remedies as to the environment will be considered in EPA's next Five-Year Review for
the site.

Other Comments:

AThe EPA expects that there will be an amendment to the 1990 ROD is expected to bi-

signed during December 2004. This amendment will address the groundwater in the karst
bedrock aquifer. Additional studies of the groundwater in the alluvial aquifer below the
wetland will be performed. Another EOD amendment wrtfbe developcdpaaaisd
after sufficient data has been gathered and analyzed.

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Missouri Electric Works Superfund Site
Cape Girardeau, Missouri
First Five-Year Review Report

I. Introduction

The purpose of the five-year review is to determine whether the remedy at a site is
protective of human health and the environment. The methods, findings, and conclusions of
reviews are documented in Five-Year Review reports. In addition, Five-Year Review reports
identify issues, if anv. found during the reviewrffimr, and identify recommendations to address
thcmsuch issues.

The Agency EgA is preparing this Five-Year Review report pursuant to Section 121(c) of
the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA)-§41+S
and the National Oil flftf flflfiardous Substances Pollution Contingency Plan (NCP). CliRCLA §

statcsSection 121 f ct provides:

If the pPresident selects a remedial action that results in any hazardous substances,
pollutants, or contaminants remaining at the site, the President shall review such
remedial action no less often than each five^ years after the initiation of such remedial
action to assure that human health and the environment are being protected by the
remedial action being implemented In addition, if upon such review it is the judgement
of the President that action is appropriate at such site in accordance with sfBectiorrfg
I04f or f!06ofCERCLAl. the President shall take or require such action. The
President shall report to the Congress a list offacilities for which such review is
required the results of all such reviews, and any actions taken as a result ofsuch
reviews.

The AucncvEPA has interpreted this requirement tether in the NCP; 40 GI-'K 5300C.F.R.
U2Q.430(f)(4)(ii) statesorovides:

If a remedial action is selected that results in hazardous substances, pollutants, or
contaminants remaining at the site above levels that allow for unlimited use and
unrestricted exposure, the lead agency shall review such action no less often than every
five years after tbrinitiation of the selected remedial action.

The United States-Environmental Protection Agency (EPA), Region 7, conducted the

fivevt'dr rFive-Year Review of the remedy implemented at the Missouri Electric Works (MEW)

Superfund Site, in Cape Girardeau, Missouri. This review was conducted by the Remedial

Project Manager (RPM) for the entire site from December 2003 through July 2004. This report

documents the results of the review. £"» 5

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This is the first five-year rFive-Year Review for the Missouri Electric Works Site. The A* £

triggering action for this statutory review is the start of RA on-site construction, which occurred
on June 7,1999. The five-year rFive-Year Review is required due to the fact that hazardous ^ 3

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substances, pollutants or contaminants remain at the site above levels that allow for unlimited use
and unrestricted exposure.

II. Site Chronology

Table 1 - Chronology of Site Events

Event

Date

Site ©discovery

10/25/1984

EPA--lead Expanded Site Investigation conducted

05/01/1987

1PRP Ssearch initiated

01/15/1988

1 PRP lead RI/FS initiated

12/31/1988

Site listed on the NPL

02/21/1990 J

Remedial Investigation (RD report submitted to EPA

06/04/1990

Record of Decision (ROD) signed

09/28/1990

Special Notice letters sent

12/21/1990

Good Faith oOffer received

03/04/1991

PRPs perform post-ROD groundwater investigation with EPA oversight

07/06/1991

RD/RA eConsent rfDecree negotiations conclude

09/19/1991

Consent Decree transmitted to all parties for signature

09/26/1991

Signed Consent Decree to sent to DOJ for lodeine in federal court

12/30/1991

PRPs submit groundwater investigation report

01/09/1992

Additional partiesPRPs identified

01/16/1992

EPA "approves" groundwater report after review

03/19/1992

trUnidentified person(s) dumps tons of lime on site (additional material
will require treatment)

05/1992

OSC samples materials dumped on site by persons unknown
Civil investigator attempts to identify person(s) responsible

05/1992

tLate parties signed consent decree

06/15/1992

| DOJ files complaint, lodges Consent Decree

06/291992

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Event

Date

District Court atwrevcsenters Consent Decree

08/29/1994

tiDe minimis parties make payments to MEW trust and Superfund

09/1994

Settling Defendants retain Construction Management Contractor

09/1994

Appeal filed by Interveners

10/28/1994

Settling Defendants submit information on thermal desorbers and request
EPA to review and change ROD

10/1994

McLaren-Hart petitions EPA HQ for National TSCA permit
demonstration at MEW site

10/1994

Availability session in Cape Girardeau to let public know that considering
inclusion of thermal desorbers

12/14/1994

Explanation of Significant Differences to ROD issued bv EPA

02/01/1995

Pilot study using innovative low temperature/high vacuum thermal
desorber unit

05/15/1995

8th Circuit Court of Appeals remands Consent Decree to District Court

08/1995

McLaren-Hart submits report on demonstration test at the MEW site

06/1996

¦B¥rDQJ lodges Consent Decree (second time)

06/29/1996

District court re-enters Consent Decree

08/14/1996

Interveners appeal re-entry of Consent Decree

10/07/1996

8th Circuit Court of Appeals re-affirms District Court's entry of Consent Decree

12/1997

Request for Proposal for soils contractor issued

05/1998

Williams Environmental Services selected as soils contractor

08/25/1998

Preliminary remedial design (RD) submitted

10/01/1998

Pre-final RD and draft Remedial Action Work Plan (RAWP) submitted

12/22/1998

100% RD and revised RAWP submitted

05/19/1999

RA on-site construction start

06/07/1999

Groundwater RI/FS start (OU 2)

06/12/2000

Final Inspection

09/19/2000

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Event

Date

Remedial Action Report final approval

09/29/2000

Groundwater RI submitted (OU2)

08/02/2004

Groundwater FS submitted (OU 2)

07/30/2004

I Amended Record of Decision (anticipated)

12/31/2004

III. Background

Physical Characteristics

Cape Girardeau, Missouri is a thriving community of about 37,000 permanent residents.

Cape Girardeau is located in southeastern Missouri along the Mississippi River, It is a regional
hub for education, commerce and medical care. Southeast Missouri State University is located in
Cape Girardeau. -It is estimated that approximately 50,000 additional people visit Cape
Girardeau daily to work, go to school, get medical care or shop.

Missouri Electric Works, Inc. (MEW) operated on a 6.4 acre tract adjacent to U.S.

Highway 61 (South KjngsMghway)Jn_Cg^O|rarigu. Attachment 1 indicates the location of
the site within the city limits of Cape Girardeau, Missouri. The MEW-site includes all areas
which became contaminated with polychlorinated biphenyls (PCBs) originating from thc-MEWj
operations. Attachment 2 indicates the area that has been impacted by the contamination from
the MEW site. The MEW site is located in a predominately commercial/industrial area of Cape
Girardeau, Missouri. The area surrounding the MEW site has experienced significant
development since die early 1990s when die site was listed on the National Priorities List (NFL).

The MO W-site is situated approximately 1.6 miles west of the Mississippi River, It is Si

located in the hills adjacent to the west valley wall of the Mississippi River flood plain. »L £

Intermittent run-off channels emanate from die north, south and east boundaries of the site and ^

eventually drain into the Cape LaCroix Creek which is located 0.7 miles east of the site. The ^ 3

Cape LaCroix Creek flows 1.1 miles to the southeast and eaters the Mississippi River. The m

property is bounded on the north by retail and warehouse properties, on the south by a residence,
commercial storage and a construction company, and on the east by a warehouse. A wetland is
located approximately 700 feet south of the MEW property. Attachment 3 indicates the
approximate location of the wetland in relation to the MEW srtepropertv and the city of Cape
Girardeau.

Land and Resource Use

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Missouri Electric Works, Inc. purchased the property in 1952. Prior to that-time, it is
believed that the land was used for agricultural purposes. Missouri Electric Works, Inc. operated
an electrical repair, service, and resell business from the location from 1954 to 1992. The facility
has not operated since 1992.

The current land use for the surrounding area is predominantly commercial. There are
recreational soccer fields located east of the MEW site. Significant new business construction
has occurred near the site. It is expected that the land use in the area mil not change
significantly. In establishing cleanup requirements for the site, EPA considered the theoretical
possibility of an on-site residence. The thermally treated soils were used to backfill the
excavations at the site. After soils treatment was complete, a vegetative cover was established to
protect the site from erosion.

History of Contamination

Missouri Electric Works, Inc. serviced, repaired, reconditioned and salvaged electrical
equipment from 1954 to 1992. Electrical equipment handled during this time consisted of oil-
filled electrical transformers, electric motors, electrical equipment controls and oil-filled
switches. PCBs, first manufactured in the 1920s, have excellent fire-retardant properties. PCBs
were often added to the dielectric fluid in electrical equipment to minimize the potential for fires.
The Toxic Substance Control Act (TSCA) of 1978 banned the future manufacture of PCBs and
required that electrical equipment containing more than 500 parts per million (ppm) PCB had to
be removed from service. This regulation resulted from studies which indicated that PCBs are a
probable human carcinogen, they are extremely stable in the environment (they do not degrade)
and they bio-accumulate in the food chain. The products of incomplete combustion of PCBs are
dioxins and fiirans.

During its operational history, Missouri Electric Works, Inc. reportedly recycled materials
from old units, selling copper wire and reusing the dielectric fluids from the transformers. The

salvaged transformer oil was filtered through Fuller's earth for reuse. An estimated 90 percent of
the transformer oil was recycled. According to business records obtained from Missouri Electric
Works, Inc., more than 16,000 transformers were repaired or scrapped at the site during its time
of operation. The total amount of transformer oil that was not recycled was estimated to be
28,000 gallons. Information gathered during Interviews of foimer employees indicates that the
majority of the non-recycled oil was disposed of on the site. In 1984, approximately 5,000
gallons of waste oil was removed by a contractor after the TSCA inspection by the Missouri
Department of Natural Resources (MDNR),

Industrial solvents were used to clean the electrical equipment being repaired or serviced.
Solvents were reused until they were no longer effective. Spills and disposal of spent solvents on
the MEW property were described by past employees during EPA-conducted interviews. .The
MEW and adjacent properties have been found to be contaminated with PCBs.

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Initial Response

The site was discovered in 1984 during a TSCA inspection. PCB contaminated soils and
inappropriate storage of over 100 55-gallon drums of PCB-contaminated oils were identified.
EPA performed additional investigations to characterize the amount of contamination between
1985 and 1988. EPA issued an administrative order requiring that the owner/operator of the site
no longer handle any oil-filled electrical equipment with PCB concentrations greater than 2 ppm,
that erosion barriers be placed in all drainage features to minimize the amount of PCB
contamination migrating off-site via storm water runoff, and that vegetables grown on site not be
sold or given away to anyone outside of the site owner's immediate family.

The site was proposed for inclusion on the National Priorities List (NPL) on June 24,
1988, and finalized on the NPL on February 21,1990. Former MEW customers were informed
of their potential liability beginning in June of 1988. A steering committee of former customers
known as the Missouri Electric Works Steering Committee (MEWSC) was formed. The
MEWSC performed a Remedial Investigation/Feasibility Study (RI/FS) during 1989 and 1990.
The RI/FS was made available to the public during June 1990. The Proposed Plan identifying
EPA's preferred remedy was presented to the public during August 1990, starting the period for
public comment.

Basis for Taking Action

Contaminants

Hazardous substances that have been released to the site in each media include:

Soil	Groundwater	'

triehloroethene
trichloroethane
chlorobenzene

methylene chloride

PCBs

1,1 -dichloroethane
trans-1,2-dichloroethene

chlorobenzene,
triehloroethene
tetrachloroethene
benzene

Sediment

A|r

PCBs

PCBs

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The risks to human health and the environment represented by the PCB contamination
were evaluated assuming that the site could be used for recreational, residential, or occupational
use. Exposure routes included inhalation of PCB-contamination dust or PCB vapors, ingestion
of PCB-contaminated soil, or dermal contact with PCB-contamination, Hie health risks
represented by the PCB contamination at the site are unacceptable. The carcinogenic risk
represented by the PCB soil contamination at the site for the current use scenario was estimated
to be lxl0*3, or one additional cancer for every 1,000 persons. The carcinogenic risk represented
by PCB contamination at the site for future residential use of the site was 1x10 "2, or one
additional cancer for every 100 persons,

A Human Health Risk Assessment (HHRA) of the MEW site was performed by the
MEWSC during 1990. The purpose of the Human i lealth Risk Assessing ntHHRA was to assess
the risks posed to human health by the contaminants at the MEW site. Contaminants at the Site
included: PCB-eontaminated soils and sediments, volatile organic compound (VOC)-
contaminated soils and sediments ,and VOC contamination of the mound watcrgroundwater.

The risk assessmentHHRA evaluated both current and future exposure situations. For
purposes of the Risk Assessmcnt|jHf|4» it was assumed that no remedial action wouid be
performed at the site in older to evaluate the possible future risks posed by the contamination.
The following routes of exposure were evaluated; ingestion of PCB-contaminated and VOC
contaminated soil/sediment by children and adults; inhalation of PCB-contaminated and
VOC-contaminated dust particles/vapors by children and adults; dermal (skin) exposuw to
PCB-eontaminated and V OC-contaminated soil/sediment; and ingestion of VOC-contaminated
ground water by children and adults (future use only). It was assumed that these exposures
would occur during the following activities: recreational; residential and occupational (adults
only).

The analyses performcdHHRA indicated that site presented

an unacceptable risk to human health and the environment in 1990. The principal threat from the
site was due to human exposure to the PCB-contaminated soils. The analyses were based on
"most probable case" and "worst case" exposure scenarios. Potential risks associated with
exposure to ground water are attributed to the presence of chlorinated compounds that exist at
concentrations that exceed State maximum contaminant levels (MCLs).

IV. Remedial Actions

Remedy Selection

The Record of Decision (ROD) for the Missouri Electric Wrorks Sitegjjg was sfgnedissued
by EPA on September 28,1990, Remedial Action Objectives (RAOs) were developed as a result C\ 5
of data collected during the Remedial Investigation (RI) to aid in the development and screening 3 g*

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of remedial technology alternatives to be considered in the ROD. EPA's national goal for the
Superfund program is to select remedies that will be protective of human health and the
environment, that will maintain protection over time and that will minimize untreated waste. In
establishing remedial goals for the MCW Sgite, EPA considered applicable or relevant and
appropriate requirements (ARARs) specific to the contaminants of concern; the fttste
AssessmcntHHRA: Maximum Contaminant Levels (MCLs) and Maximum Contaminant Level
Goals (MCLGs) established undo1 die Safe Drinking Water Act; and EPA guidance and policy,
specifically the TSCA PCB Spill Cleanup Policy, 40 C.F.R, Part 761,

Source Control Response Objectives

*	Minimize the migration of contaminants from the proper! vsite soils;

•	Reduce risks to human health by preventing direct contact with and ingestion of
contaminants in tht-site soils; and

•	Minimize the migration of contaminants from the site to the adjacent wetland.
Management of Response Objectives

•	Eliminate or minimize die threat posed to human health and the environment by
preventing exposure to soil, air, and sediment contaminants;

•	Prevent further migration of soil contamination beyond the then current cxtentsite
boundaries: and

• Restore contaminated groundwater to State ARARs-that-hr. which are considered to be
protective of human health and the environment, within a reasonable period of time.

The major components of the source control remedy selected in the ROD include the following:

1.	Preparation of the Ssite will be performed by clearing trees and vegetation in the area
where the incinerator is to be placed;

2.	Excavation and on-site incineration of all soils with PCB concentrations in excess of 10	^
ppm to a depth of four (4) feet and 100 ppm at depths greater than four (4) feet. C7 ^
Excavated soils will be consolidated on-site with provisions to minimize migration of the g m
contaminated materials; ^

3.	Mobilization and set-up of the incinerator at the Ssite;	^ p

4.	Conduct Tirial bura(s) to ensure the operational capabilities of the incinerator;	m

5.	Monitor continuously incinerator feed rates. Frequent monitoring of incinerator
emissions from the incinerator, both ash and gases, to document that destruction
efficiencies and air emissions standards are complied with. Testing of the ash residuals
from the treatment process will be performed to identify leaching characteristics, to

8

-------
identify the compounds within the ash and to verify that the ash contains less than 2 ppm
PCB.

6.	Backfill excavated areas using treated soils, after analytical tests confirm that treatment
standards are met;

7.	De-mobilizaton of the incinerator from site when treatment of PCB-contaminated soils is
complete; and

8.	Restoration and revegetation of the Ssite.

9.	Impose institutional controls, such as deed restrictions and/or zoning restrictions to limit
use of the Ssite to industrial or commercial proposes.

The major components of the migration management remedy selected in the ROD include:

1 . Perform additional investigation of the hydro-geologic regime in the vicinity of the MEW
Sgite to identify the vertical extent of contamination; confirm the presence or absence of a
continuous aquiclude within the upper 200-300 feet of the bedrock;

2.	Perform pump tests to determine the flow rates and hydraulic conductivity of the aquifer
to gather additional data necessary for the design;

3.	Design the extraction well network, including well locations, pump sizes, pumping
frequency, location and sizes of connecting piping;

4.	Sample water extracted during the pump tests for identification of the contaminants and
associated concentrations present in the ground water;

5.	Extract and treat ground watereroundwater utilizing an extraction well network,
temporary storage, followed by removal of volatile organic compounds using an air-
stripper with gas phase carbon adsorption from the air stream; and

6.	Perform Five-yYear $rtc-r£eviews to assess site condition, contaminants distributions,
and any associated site hazards.

An Explanation of Significant Differences (ESD) to the ROD was issued on February 1,
1995. Technologies (thermal desorption) capable of effectively dealing with the contamination
at the MEW S|ite had been developed and demonstrated successfully. The MEWSC provided
tfrc-information supporting the ESD as a focused feasibility study in October 1994. The EPA
reviewed the information and concurred that thermal desorption would be a viable alternative.
The EPA notified the public of the proposed change, conducted a meeting in Cape Girardeau,
Missouri during December 1994 and issued the ESD. The primary changes documented in the
ESD were:

•	Changing on-site incineration to on-site thermal treatment; and

*	Defining on-site thermal treatment to be either incineration or thermal desorption.

Remedy Implementation

The Consent Decree (CD) signed by the EPA, the Missouri Department of Natural

9

0 5

m

a §

»L tA

S3

CO -n
PO m

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Resources (MDNR), 175 Settling Defendants and 3 Federal Agencies was referred to the
Department of Justice (DO J) on December 30,1991. One hundred thirty-four (! 34) of the
Settling Defendants were de minimis parties that elected to "cash-out" their liability with regards
to either soil or soil and groundwater response actions. The CD was lodged in the Federal

District Court^2l^2LiiSSl^l£iStD£U2£MiSS2UQkS&lltb^S&EIL^il!SlS!L 'n J™® 1992. It was

approved or entered by the Court during August 1994. The CD entry was appealed by a group of
non-settling former MEW customers during October 1994, The I"1 Circuit Court of Appeals

the CD to the Federal District Court during August
1995aferJ|^|ri^||b|^gn; the CD was approved a second time dwmgb2jh^^

Court on August 14,1996. The same group of former customers again appealed the CD entry.

The 8th Circuit Court of Appeals confirmed entry of the CD during December 1997.

The Remedial Design (RD) was conducted in conformance with the soils response
actions identified in the ROD as modified by the ESD. The RD was conditionally approved by
EPA on March 25,1999.

The MEWSC requested that EPA allow it to further investigate groundwater
contamination during late 1990. The purpose of the investigation was to "prove** the presence of
a confining layer (shale) that would inhibit the downward migration of contaminants in the
groundwater. EPA agreed to the investigation. Drilling for the new well began in January 1991.

A pilot hole was drilled to about 220 feet to verify the condition of the limestone bedrock. This
hole was continuously coxed within the bedrock; the quality of the rock was good. The location
of the new monitoring well (MW-11) was approximately 10 feet southwest of the pilot boring.

While drilling, a solution feature was detected at a depth of about 110 feet below ground surface
(B6Sbgs). Casing was "seated'* in the rock below the void; the boring grouted and re-drilled
using a smaller diameter drill bit- A second, larger solution feature about 10 feet high was
detected at a depth of about 220 ft. bp. This void was mud-filled; the mud was sampled, PCB
contamination of the mud and water was detected. Again the casing was "seated" in the rock
below the void; the boring grouted and re-drilled using a smaller diameter drill bit (this is
referred to as telescoping the hole). A third large solution feature was encountered at a depth of
about 315 ft. bgs. This void was also mud-filled. Several thousand gallons of the mud-slurry
material within the hole was pumped and then sampled. PCB contamination of the sediment-
water mixture and water (the solids were removed using a centrifuge) was detected. The hole
was telescoped again. The hole was advanced to a depth of405 ft. bgs. Groundwater was
collected and sampled. PCBs were detected at 2 parts per billion (ppb). (The MCL for PCBs in
groundwater is 0.5 ppb.) ^

-n m

The new groundwater information resulted in the identification of a significant data-gap. S7 ^
yAs a result, the Consent Decree£P provided for the clean-up of the PCB-contaminated soils, in o d
accordance with the ROD, and for a focused investigation and feasibility study of the
groundwater ("additional investigation of the hydro-geologic regime in the vicinity of the MEW --J p
Site will be performed") and treatment of the contaminated groundwater within about 70 feet of w m
the ground surface using pump and treat technology. Groundwater response actions identified in

-------
due to the lack of information needed for

The work identified hi the CD took place in two phases; the first was thermal treatment of
the PCB-contaminated soils and the second was the focused groundwater study. After several
years delay due to legal proceedings, the contract for thermal treatment of the soils was awarded
on August 25,1998. The remedial design was conditionally approved on March 25,1999. On-
site mobilization, clearing and grubbing efforts began on June 7,1999. Thermal treatment of the
PCB-contaminated soils was completed on July 25,2000. The work for the soils operable unit
(OU) was finished with the approval of the Remedial Action Report on September 29,2000. The
major components of the Soils Remedial Action (RA) were:

•	Clearing and grabbing of the site;

•	Construction of concrete pad for the Low Temperature Ttamal Desorption (LTTD) unit;

•	Mobilization and set-up of the LTTD unit;

•	Excavation of PCB-contaminated soils;

•	Screening/processing of PCB-contaminated soils in preparation for thermal desoiption;

•	LTTD trial runs (process had to meet specified destruction criteria and not create products
of incomplete combustion (PICs));

•	Review of LTTD T|rial ftrun(s) data;

•	Approval to treat soils using parameters established during trial runs;

•	Excavation of deep PCB-contamination (up to 25 ft. bgs) - all soils with PCB
concentrations greater than 100 ppm removed from the site (sinkholes were detected on
site, with one being at the location of monitoring wells MW-3, MW-5 and MW-11);

•	Modification of excavation plan to leave habitat for pair of nesting Red-Tailed Hred-
tailed hawks:

•	Production ^treatment of PCB-contaminated soils;

•	Backfill and regrading of site;

•	Re-vegetation of site; and

•	Pre-final/Final Inspection.

The pre-final inspection concluded that the soils RA had been conducted and completed
in accordance with the soils remedial design plans and specifications; a punch list of additional
work items was not needed.

11

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The second phase of the work performed pursuant to fhe CD consisted of the groundwater
investigation and feasibility study. Since the decision was made during the soils RA that all
PCBs in excess of 100 ppm would be removed, the Sgoils RA acted as a source removal for the
groundwater contamination. Upon completion of the thermal desorption activities, the existing
groundwater monitoring wells were sampled on a quarterly basis for about 2 years. During this
time, non-invasive investigations were performed to bitter define the joint patterns within the
bedrock. The purpose of the non-invasive work was an attempt to get data to formulate a model
of the underlying bedrock. This was made extremely difficult by the fact that the bedrock below
the site is karst; solution features have been carved in the bedrock by the groundwater. It is veiy
difficult, if not impossible, to track contaminants within karst bedrock. A model of the bedrock
was created. Additional monitoring wells were installed at those locations most likely to be
contaminated. These wells, along with the original wells, were monitored for 4 quarters.

Groundwater data was analyzed and the decision was made that additional monitoring wells were
needed near the northern edge of the wetland avea. Three (3) nests of wells were installed. All
monitoring wells were sampled quarterly for another year. Chlorinated compounds were
detected in the samples from the wetland wells. Two (2) more sets of nested wells were
installed farther south and west in the wetland area. A third set of nested wells were planned to
monitor groundwater east of the wetland area. These wells were not installed due to lack of
alluvium in this area, A focused remedial investigation and feasibility study werewas then
submitted to EPA.

The EPA and the State of Missouri have determined that all work identified in the CD,
with the exception of implementation of institutional controls, were performed according to
specifications and approved work plans. AThe EPA anticipates that a ROD amendment will be
issued in he near future that will addresses the groundwater and deleting the requirement for
institutional controls fi«r the soil. (PCB-contamination left on-site and at depth does not
represent an unacceptable risk; therefore institutional controls am not needed.)

System Operation/Operation and Maintenance

Representatives of the MEWSTD conducted the monitoring and maintenance activities
with regard to the vegetative cover over the treated soils. About a year after constructing the cap,
a site visit was made to observe the condition of the cap, identify any erosional features and
assess the success of vegetating the cap. Several erosion rills were identified and filled, new
grass seed was planted and erosion barriers (rock-filled gabbions) woe erected along the eastern
-most edge of the site. ^

-n rn

No long-term operation and maintenance activities were identified or described *m the ^

work-to be perfcumedreauired in the CD. There are no operation and maintenance activities o h

being performed. ^

^ p

Ul m

V. Progress Since the Last Five-Year Review

-------
This was

Site,

s-YeaL£eview for the Missouri Electric Works Superfund

VL Five-Year Review Process

Administrative Components

Members of the MEWSTD and the community were notified of the five-year rf ive-Year
Review on March 1,2004. The MEW Five-yYear Review was performed by Pauletta France-
Isetts, EPA Remedial Project Manager (RPM). Don Van Dyke of Missouri Department of
Natural Resources assisted in the review as the representative for the support agency.

The review schedule components included the following:

O	Community tinvolvement;

O	Document Rreview;

O	Data review;

O	Site ^inspection;

O	Local ^interviews; and

O	Five-Year Review ftreport ©development and ftreview.

These efforts were performed from December 11,2003 through August 31,2004.

Community Involvement

Activities to involve the community in the five-vear rFive-Year Review were initiated
with a meeting in February 2004 between the RPM and the Community Involvement Coordinator
(CIC) for the ME W site, A notice was sent to the local »ewspapergnewspaoer in Cape Girardeau
that a live-year rFive-Year Review was to be conducted. A fact sheet was sent to all entities
identified on the MCW site mailing list A letter stating the same was sent to the MEWSTD
project coordinator, MEWSTD chair, MEWSTD legal representative, the City of Cape
Girardeau, Cape Girardeau County Health Department, die State of Missouri Health
Department, the Agency for Toxic Substances and Disease Registry (ATSDR), United States
Geological Survey, and MDNR. The Fact Sheet and letters invited the recipients to submit any
comments to EPA.	^ 5

-n m

On March 20,2004, a notice was sent to the same local newspaper to announce that the ¥ w

isj ^

13

m

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Five-
EPA. the Five-Year

site was underway. ^Following execution bv
t will be available to the public at the Cape Girardeau

Public Library and the EPA Region 7 offic

Document Review

This five-vear rFive-Year Review consisted of a review of relevant documents including
the Remedial Action report and groundwater monitoring data-:^ Applicable clean-up standards
(as listed in the 1990 ROD) were also reviewed. New policy and guidance documents for risks
posed by PCBs, both human health and ecological, were also reviewed. The documents
reviewed are listed in Attachment 4.

Data Review

Remedial Action Report

All soils contaminated with PCBs at concentrations in excess of 10 ppm were to be
excavated and treated. Approximately 38,000 tons of PCB-contaminaled soil were excavated
and thermally treated during the soil remedial action. Confirmation composite samples were
collected within 143 50' x 50' grids. =The average PCB concentration for the confirmation
samples was 1.6 ppm; the mean PCB concentration was 0.7 ppm.

Groundwater Investi gatKffl

Groundwater monitoring, as part of the focused groundwater investigation, has been
conducted at the MOW site since June 2000. No new groundwater monitoring wells were
installed at the MEW site for approximately 2 years following the soil remedial action. The
purpose of the monitoring was to gather data sufficient to evaluate the impact of the PCB source

removal on groundwater quality.

Groundwater samples were analyzed for the following compounds: 1,1,1 -Triehloroethane
(1,1,1-TCA), Trichlorethene (TCE), Perchlorethene (PCE), 1,1-Dichloroethane (1,1-DCA), 1,1-
Dichloroethene (1,1-DCE), 1,2-Dichloroethene(I,2-DCE>, Benzene, Chlorobenzene, Toluene,
Chloroform, 1,2,4-Trichlorobenzene (1,2,4-TCB), 1,2-Dichlorobenzene (1,2-DCB), 1,3-
Dichlorobenzene (1,3-DCB), 1,4-Dichlorobenzene (1,4-DCB), Butyl benzyl phthalate, Di-n-butyl
phthalate, Bis(2-ethylhexyl phthalate, PCB unfiltered., and PCBs filtered (see Tables A-1 to A-14
in Attachment 6). Where detected, the concentrations of the these parameters have decreased or
remained constant, indicating that the majority of the source material was successfully removed.
The following contaminants were detected at or above the maximum contaminant levels (MCL)
as promulgated under the foderalJi^Mnldng Water Act. Public Law 104-182: TCE, PCE,
Benzene, Chlorobenzene, and PCBs (unfiltered).

Ecological Risk Assessment Guidance

-------
FiiialThe EPA issued guidance for Ccologicalgn^g^^fl]ggj^[ Risk Assessment and
Risk Management Principles for Superfund Sites wis issued" fOSWER Directive 9285.7-28 P)

gn October 7,1999s. This documenteuidance states *¥«that "Ms the Superfund program has
matured, it has given more and more consideration to the potential effects of hazardous
substances releases on ecological receptors."

Information regarding the potential toxicity and Mo-accumulation ofPCBs in the food
chain has increased significantly since the ROD was writtenissued in September 1990. There is
concern that the PCB concentrations that remain at the site, particularly in the wetland area,
could represent an ecological threat. Insufficient data is available to perform an ecological risk
assessment

Site Inspection

Inspections at the site were conducted on December 11,2003 by the RPM and during
April 2004 by MDNR representatives. The purpose of the inspections was to assess the
protectiveness of the soil remedial action and to assess the completeness of the groundwater
investigation. The area addressed by the soil remedial action was inspected to assess the integrity
of the cap, the completeness of the vegetative cover, and the stability of the erosion features. The
vegetative cover was well established. There is some erosion that is still occurring along the
eastern edge of the site. The majority of the erosion has been halted by placing rock-filled
gabbions in the erosion features. The cap appears to be intact. The pair of red-tailed hawks are
still nesting in the trees along the eastern perimeter of the site.

The inspection related to groundwater was conducted to ensure that the rate and extent of
contamination, the groundwater flow direction and the groundwater heads were identified for the
remedial investigation and feasibility study.

No institutional controls were placed on the areas addressed by the soil remedial action.
The soils were excavated to PCB-concentrations less than 10 ppm. The ROD identified leaving
PCBs at concentrations of up to 100 ppm at depths below 4 feet. Since no PCB concentrations at
depth exceeded 100 ppm, the need for deed restrictions for soil contamination no longer existed.

Interviews

Interviews were conducted with some parties connected to the site. No significant
problems regarding the site were identified during the interviews.

VII. Technical Assessment

Question A: Is the remedy fanctioninv as intended hv the decision documents?

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The review of documents indicates that the soil remedial action is functioning as intended
by the ROD and ESD. However, due to the discovery of PCBs in the groundwater, at depth, no
remedial action has been taken to address the threat posed by groundwater. Since no remedial
action for groundwater has been implemented, the remedy is not functioning as intended by the
ROD and ESD.

toxicity data, cleanup levels, and
remedial action objectives (RAOs) used at the time of the remedy selection still valid?

The exposure assumptions for human health remain valid. The toxicity data and cleanup
levels for PCBs have not changed much; although there is more data on reproductive toxicity for
PCBs now than there was in 1990. The RAOs for the soil cleanup remain valid.

Changes in Standards To Be Considered

The estimate of ecological risk has been formalized since 1990 when the ROD was
si micd issued. PCBs bio-accumulate and bio-magnify in the food chain. Screening levels for
PCBs are quite low. A formal ecological risk assessment should be performed at the site to
evaluate: the threat, if any. posed by the PCBs. Unacceptable ecological risks will need to be
addressed and/or managed.

Changes in Exposure Pathways, Toxicity, and Other Contaminant Characteristics

PCBs, chlorobenzene, PCE, benzene and TCE was detected in the groundwater within
the area identified as the site. All five contaminants were detected at concentrations above State
and Federal MCLs. The presence of these contaminants in the groundwater needs to be
addressed.

The exposure assumptions used to develop the soils portion of the -Human Health Risk
Assessment included both current and future exposures (child recreational, child residential,
adult recreational, adult residential and adult worker). There have been no changes in the
toxicity factors for the contaminants of concern that were used in the Human Health Risk
Assessment. These assumptions are considered to be conservative and reasonable in evaluating
the human health risk and developing human health risk-based cleanup levels. No changes to
these assumptions, or the cleanup levels developed from them is warranted to protect human 3j

health. c? £

Baseline Risk Assessment now includes human health and ecological risk assessment.

Ecological risk was not estimated in 1990. Investigation of the wetland soils, sediments, surface ^ 3
water and soils within about 4 feet of the ground surface need to be sampled and analyses m

performed to evaluate the risk, if any, to the environment posed by the site.

-------
Question C: Mas am other information come to lieht that could call into question the
protectiveness of the remedy?

Several karst features were detected at, near or below the site after the ROD was
wrrttrmssued. Two (2) sink-holes were found; one off-site and the other near the location of
MW-3, MW-5 and MW-11 A. During the installation ofMW-11A, subsurface voids (solution
features) were encountered at depths of 110 feet below ground surface (bgs), 220 feet bgs and
315 feet bgs. TMs information may result in the groundwater remedial action, selected in 1990,
being impractical to implement

Technical Assessment Summary

According to the data reviewed, the site inspection and the interviews, the soil remedy is
functioning as intended by the ROD, as modified by the BSD. The groundwater remedy has not
been implemented. There have been no changes in the physical conditions of the site that would
affect the protectiveness of the soil remedy. The ARARs for soil contamination cited in the ROD
have been met. There have been no changes in the toxicity factors for the contaminants of
concern that were used in the Human Health Risk Assessment; there has been no change in the
standardized risk assessment methodology for human health. There has been a change in the
standardized methodology for ecological risk; this could impact the protectiveness of the remedy.
New groundwater data has been collected. Modification to the ROD will be needed to address
the groundwater conditions that have been detected. Risk posed by groundwater still exists.

VIH. Issues

Table 2-Issues

Issue

Currently
Affects
Protectiveness
(Y/N)

Affects Future
Protectiveness
(Y/N)

Continuing erosion along the eastern perimeter of the site

Institutional controls not placed with regards to soils

Institutional controls not placed with regards to
1 groundwater

I Ecological risk assessment not conducted for wetland area
1 south of the MEW facility

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Issue

Currently
Affects
Protectiveness

vim

Affects Future
Protectiveness
(Y/N)

Insufficient groundwater monitoring to determine whether
or not plume is migrating

N

Y

Insufficient groundwater parameter data to determine
whether natural attenuation is occurring

N

Y

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18

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mew site file

CP5-I02382

IX. Recommendations and Follow-up Actions

Table 3 - Recommendations and Follow-Up Actions

Issue

Recommendations/Follow-
up Actions

Party Responsible

Oversight

Agency

Milestone

Date

Affects
Protectiveness (Y/N)











Current

Future

Continuing erosion along
the eastern perimeter of the
site

Annual inspections;

repair of slope if
necessary

property owner

State/
EPA

June 30,2005

N

N

Institutional controls not
placed with regards to soils

No action

-

—

—

N

N

Institutional controls not
placed with regards to
groundwater

Have institutional
controls placed on
property to prohibit
groundwater use

property ownerfs^/^rrt-r/Citv

of Cape Girardeau

State/
EPA

September 30,
2005

Y

Y

Ecological risk assessment
not conducted for wetland
K area south of MEW facility

Prepare an Ecological
Risk Assessment after
performing a focused RI
in the wetland area

PRPs

State/
EPA

September 30,
2006

Y

Y

9 Insufficient groundwater
monitoring to determine
whether or not plume is
migrating

Monitor groundwater,
especially in wetland for
an extended period to
determine migration

PRPs

State/
EPA

September 30,
2007

N

Y

Insufficient groundwater
parameter data to determine
whether natural attenuation

Monitor groundwater
for an extended period
of time to evaluate
potential for attenuation

PRPs

State/

EPA

September 30,
2007

N

Y

19

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X- Protectiveness Statement

The soil remedy is protective of human health. The groundwater portion of the remedy
has not been implemented. The groundwater could represent a risk to human health through
ingestion or inhalation. New standards have been instituted for ecological protectiveness since
the ROD was wrttteni||usd. Additional work rmcdsshould to be performed to determine whether
or not there is an ecological risk.

Additional sampling and monitoring of the groundwater will be performed to evaluate the
migration of die contaminant plume below the wetland area and to evaluate the potential of
natural attenuation of the contaminants of concern. An investigation will be performed to gather
the data necessary for the Ecological Risk Assessment. A determination will be made after the
Ecological Risk Assessment is complete whether or not additional actions will be required for
protectiveness of the environment

XI, Next Review

The next five-year rFive-Year Review for the Missouri Electric Works Superfund Site is
required by August 2009, five years from the date of this review.

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NOTES:

i; BASE MAP f ROM U5GS 7,5 MINUTE CAPE GIRARDEAU

QUADRANGLE <1965, REVISED MM).
2; ALL LOCATIONS ARE APPROXIMATE..

APPROXIMATE SCALE IN MILES

9.5

Missouri Electric Works (MEW) - Site Location Map

-------
ATTACHMENT 2

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MEW SITE FILE

CF5-I02387

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MISSOURI ELECTRIC WORKS (MEW) - SITE PLAN

Indicating Estimated Extent of PCB concentration prior to the Soil Remedial Action
(from 1990 Remedial Investigation Report)

-------
WEW SITE FILE

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ATTACHMENT 3

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MEW SITE FILE

CFD-102390

MEW

Praperti

Note:

Viow trom fcm.th
Vertical exaggeration
approximately UJtiiws

Missouri Electric Works (MEW) - Location of Wetland Area

-------
ATTACHMENT 4

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ATTACHMENT 4
List of Documents Reviewed

Missouri Electric Works Remedial Design for Thermal Desorption of Contaminated Soils, Williams
Environmental, March 1999

Missouri Electric Works Soils Remedial Action Report, September 2000

Missouri Electric Works Quarterly Groundwater Monitoring Reports, 2001,2002,2003 and 2004

Missouri Electric Works Groundwater Remedial Investigation, July 2004

Missouri Electric Works Record of Decision, September 1990

Missouri Electric Works Explanation of Significant Differences, Februaiy 1995

Ecological Risk Assessment Guidance for Superfund, OSWER Directive 9285.7-28P, October 1999

Preliminary Remediation Goals for Ecological Endpoints, ES/ER/TM-162/R2, August 1997

Remedial Investigation Report, Missouri Electric Works site, Cape Girardeau, Missouri, The Earth Technology
Corporation, July 1990

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ATTACHMENT 5
ARARs Identified in the 1990 Record of Decision

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MEW SITE FILE

CFD-102394

FEDERAL CHEMICAL-SPECIFIC ARARs
MISSOURI ELECTRIC WORKS SITE

STANDARD,
REQUIREMENTS,
CRITERIA, OR LIMITATION

CITATION

DESCRIPTION

APPLICABLE
RELEVANT AND
APPROPRIATE

COMMENT

National Primary Drinking Water
Standards

40 CFR Part 141

Establishes health-based standards for
public water systems (maximum
contaminant) levels).

Yif

The MCLs for organic and
inorganic contaminants are
relevant and appropriate for
ground water.

National Secondary Drinking
Water Standards

40 CFR Part 143

Establishes welfare-based standards for
public water (secondary maximum
contaminant levels).

Yes

Secondary MCLs for these
parameters/ contaminants

maybe

relevant and appropriate for
ground water.

Maximum Contaminant Level
Goals

40 CFR Part 141

Establishes drinking water quality goals
set at levels of no known or anticipated
adverse health effects with an adequate
margin of safety.

Yes

Proposed MCLGs for organic
contaminants should be
treated as

"other criteria, advisories
and guidance".

Water Quality Criteria

48 CFR Part 131
Quality Criteria
for Water, 1986

Sets criteria for water quality based on
toxicity to aquatic organisms and human
health.

Yes

AWQCs may be relevant and
appropriate for surface water
discharges.

Releases from Solid Waste
Management Units

40 CFR Part 2(4
Subpart F

Establishes maximum contaminant

concentrations that can be released from
hazardous waste units in Part 264,
Subpart F.

Yes

Onsite hazardous waste
management unit may be
considered. Same levels as
MCLs,

National Ambient Air Quality
Standards

40 CFR Part SO

Establishes primary (health based) and
secondary (welfare based) standards for
air quality.

Yes

Standards for particulate
matter must be monitored
during some remedial
activities.

National Emission Standards
1 for Hazardous Air Pollutants

40 CFR Part 61

Establishes emission levels for certain
hazardous air pollutants.

Yes

Standards for some chemicals
may relevant and appropriate
to the site.

Federal Cbemcial Specific ARARs
Missouri Electric Worics Site

I

-------
STANDARD,
REQUIREMENTS,
CRITERIA* OR LIMITATION

Occupational Health And Safety
Regulations

CITATION

19CFR 1910.1000
Subpart Z

CFD-102395

Establishes permissible exposure limits
for work-place exposure to many
chemicals.

APPLICABLE
RELEVANT AND
APPROPRIATE

Yes

COMMENT

Listed chemicals detected
on-site. Standards applicable
to remedial worker exposure.

Toxic Substances Control Act
(TSCA)

40 CFR Part 761

Establishes prohibitions of and
requirements for the manufacture,
processing, distribution in commerce,
use disposal, storage and marking of
PCB items. Sets forth PCB Spill
Cleanup Policy.

Ves

The PCB Spill Cleanup Policy
(Part 761.25) is a TBC which
establishes cleanup guidelines
for nonregulated access areas.
Part 761.60 requirements for
the storage and disposal of
PCs-contaminated soil and
provides a basis for utilizing
alternative
technologies for PCB
treatment

Part 761.70 establishes
requirements for PCB incin-
erators, which are applicable
if onsite or ofTsite incineration
is involved.

Part 761.75 establishes
requirements for chemical
waste landfills for land
disposal of PCBs at
concentrations of less than
500 ppm.

Federal Chemcial Specific AR ARs
Missouri Electric Works Site

2

-------
mew sm FILE

CFD-102396

STANDARD,
REQUIREMENTS,
CRITERIA, OR LIMITATION

CITATION

DESCRIPTION

APPLICABLE
RELEVANT AND
APPROPRIATE

COMMENT 1

Toxic Pollutant

40 CPU Part 129

Establishes effluent standards or
prohibitions for certain toxic pollutants:
aldrin/dieldrin, DDT, endrin* toxaphene,
benzidine, PCBs.

No

These pollutants were not
detected In ground water
samples.

Identification and Listing
(RCRA Waste)

40 CPE Part 261

Defines those solid wastes of Hazardous
Waste which are subject to regulation a*
hazardous under 40 CFR Parts 262-265
and Parts 124,270,271.



Applicability of RCRA
regulations to wastes found at
tfie site is

pending resolution.

Federal Chemcial Specific ARAfts
Missouri Electric Works Site

3

-------
MEW SITE FILE

CFD-I02397

STATE CHEMICAL-SPECIFIC ARARs
MISSOURI ELECTRIC WORKS SITE

STANDARD,
REQUIREMENTS,
CRITERIA, OR LIMITATION

CITATION

DESCRIPTION

APPLICABLE
RELEVANT AND
APPROPRIATE

COMMENT

Missouri Safe Drinking Water
Act and Missouri Water Quality
Standards

10 CSR 20-7.031

Maximum chemical contaminant levels
and monitoring requirements

Ves

The requirements may be
relevant and appropriate for 1
the MEW site, |

Missouri Hazardous Waste
I Management Regulations

10 CSR 25-7.264

Standards for owner operators of
hazardous waste treatment storage, and
disposal facilities.

—

Applicability of regulation to |
wastes found at site is pending
resolution

I Missouri Hazardous Waste
Management Regulations

10 CSR 25-10.010

Procedures for obtaining state approval
for remedial actions at abandoned or
uncontrolled sites.

Yes

The requirements may
applicable for the MEW site.

Missouri Hazardous Waste
Management Regulations

10 CSR 25-11.010

Procedures and requirements for
managing waste oil, which are in
addition to Federal requirements on
used oiL

Yes

These procedures may be
applicable for the MEW site if
removal of non
PCB-contaminated oil is
involved as a remedial action.

Missouri Hazardous Waste
Management Regulations

10 CSR 25-13.810

Standards for management of waste
materials or waste manufactured items
containing PCBs at concentrations of
fifty parts per million or more.

Yes

These standards may be
applicable or relevant and
appropriate requirements for
the MEW site.

Missouri Hazardous Waste
Management Regulations

10 CSR 25-6.263

Standards for Transporters of
Haiardous Waste

Yes

These requirements may be
applicable for the MEW site if
removal offsite of hazardous
waste non-PCB oils or PCB
materials.

i

-------
FEDERAL LOCATION-SPECIFIC ARAMS
MISSOURI ELECTRIC WORKS SITE

MEW SITE FILE

CFD-102398

STANDARD,
REQUIREMENTS,
CRITERIA, OR LIMITATION

CITATION

DESCRIPTION

APPLICABLE
RELEVANT AND
APPROPRIATE

COMMENT

Protection of Wetlands

Exee. Order No.
11,99#

40 CFR 6302(a)
and Appendix A

Requires Federal agencies to avoid, to
the extent possible, flic advene impacts
associated with the destruction or lots of
wetlands and to avoid support of new
construction In wetlands If a practical
alternative exists.

Ves

Tlie U.S. Army Corps of
Engineers has identified a
jurisdictional wetland near the
MEW site

1

-------
mew site file
CP5-I02399

STATE LOCATION-SPECIFIC ARARs
MISSOURI ELECTRIC WORKS SITE

STANDARD,
REQUIREMENTS,
CRITERIA, OR LIMITATION

CITATION

DESCRIPTION

APPLICABLE
RELEVANT AND
APPROPRIATE

COMMENT 1

Protection of Lakes and Streams

Missouri Water
Quality Standards
10 CSR 20-7.031

Promulgates mle$ to protect quality of
lakes and streams. Beneficial uses of
Cape La Croix Creek listed as livestock
and wildlife watering and warm water
fishing.

Yes

Chemical specific ARARs are
listed previously.

1

-------
MEW SITE FILE

CFD-102400

FEDERAL ACTION-SPECIFIC ARARs

MISSOURI ELECTRIC WORKS SITE

STANDARD,
REQUIREMENTS,
1 CRITERIA, OR LIMITATION

CITATION

DESCRIPTION

APPLICABLE

RELEVANT AND
APPROPRIATE

COMMENT

CLEAN WATER ACT

33 USC 1251-1376







I National Pollutant Discharge
| Elimination System (NPDES)

40 CFR Part 125

Requires permits for the discharge of
pollutants for any point source Into
waters of the United States.

Ves

Permit not required for
CERCLA activities; however,
technical requirements for
discharge must be met if onsite 1

water treatment occurs and is 1
discharged to surface water |

National Pretreatment Standards

40 CFR Part 403

Set standards to control pollutants which
pass through or interfere with treatment
processes fat public treatment works or
which may contaminate sewage sludge.

Yes

Only if the treated ground 1
water is discharged to a
publicly owned treatment

works (P0TW).

SOLID WASTE DISPOSAL ACT
(SDWA)

42 USC 6901 - 6987







I Criteria for Classification of Solid
1 Waste Disposal Facilities and Practices

40 CFR Part 257

Establishes criteria for use In
determining shkh solid waste disposal
facilities and practices pose a reasonable
probability of adverse effects on public
health or the environment and thereby
constitute prohibited open dumps.

Yes

The soil selected remedy will
Involve onsite disposal of

incinerator ash. I

Standards Applicable to Generators of
Hazardous Waste

40 CFR Part 262

Establishes standards for generators of
hazardous waste.

No

The selected remedies do not
involve offiiite transportation
of either soil or ground water I
or treatment or disposal. |

I Standards Applicable to Transporters
I of Hazardous Waste

40 CFR Part 263

Establishes standards which apply to
transporters of hazardous waste within
the US if the transportation requires a
manifest under 40 CFR Part 262

No

The selected remedies do not I
involve ofliste transportation I
of hazardous wastes for |
treatment and/or disposal. f

Federal Action-Specific ARARs
Missouri Electric Worts site.

1

-------
MEW SITE FILE

CFD-102401

STANDARD,
REQUIREMENTS,
CRITERIA, OR LIMITATION

CITATION

DESCRIPTION

APPLICABLE
RELEVANT AND
APPROPRIATE

COMMENT

Contingency Plan and Emergency
Procedures

Subpart D

Establishes standards which apply to
transporters of hazardous waste within
the US if tbe transportation requires a
manifest under 40 CPE Part 262

Yes

If onsite ground water
treatment system produces
hazardous waste. 1

Manifest System, Record

Subpart E

Establishes standards which apply to
transporters of hazardous waste within
the US if the transportation requires a
manifest under 40 CFR Part 262

Ves

If the selected remedies
involve the ofTsite transport of
hazardous waste.

1 Use and Management of Containers

Subpart I

Establishes standards which apply to
transporters of hazardous waste within
the US if the transportation requires a
manifest under 40 CFR Part 262

Ye»

If the selected remedies
Involve storage of containers.

Tanks

Subpart J

Establishes standards which apply to
transporters of hazardous waste within
tbe US if the transportation requires a
manifest under 40 CFR Part 262

Yes

If the selected remedies
Involve the sue of tanks to
treat or store hazardous
materials.

1 Waste Piles

Subpart L>

Establishes standards which apply to
transporters of hazardous waste within
the US if the transportation requires a
manifest under 40 CFR Part 262

Yes

If the selected remedies would 1
treat or store hazardous 1
materials in piles.

Incinerators

Subpart O

Establishes standards which apply to
transporters of hazardous waste within
the US if the transportation requires a
manifest under 40 CFR Part 262

Yes

The selected remedy for soils
Is onsite incineration. Abo
covered by CFR 761.70.

Land Disposal

40 CFR Part 268

Establishes restriction for burial of
wastes and other hazardous materials.

Yes

If tbe selected remedies would 1
offsite burial of contaminated 1
soils or residues containing
prohibited waste, a CERCLA
waiver may be required.











Federal Action-Specific ARARs
Missouri Electric Works site.

2

-------
MEW SITE FILE

CFD-102402

1 STANDARD,

REQUIREMENTS,
CRITERIA, OR LIMITATION

CITATION

DESCRIPTION

APPLICABLE
RELEVANT AND
APPROPRIATE

COMMENT

OCCUPATIONAL SAFETY AND
HEALTH ACT (OSHA)

29 USC 651 - 678
29 CFR Part 1910

Regulates work health and safety at
hazardous waste sites.

Yes

Under 4# CFR 300J8,
requirements of the Act apply
to all response activities under
the NCP.

HAZARDOUS MATERIALS
TRANSPORTATION ACT

49 USC 1801 -1813







Hazardous Materials Transportation
Regulations

49 CFR Parts If 1 -
178

Regulates transportation of hazardous
materials.

Yes

If selected remedy would 1
involve transportation of 1
hazardous materials. |

TOXIC SUBSTANCES CONTROL
ACT

13 USC SIC 2601
-2629







PCB Requirements

40 CFR Part 761

Establishes storage and disposal
requirements for PCBs.

Yes

Treatment and disposal
methodologies must meet
substantive requirements set
forth by 40 CFR 761.

PCB Spiii Cleanup Policy

40 CFR Part 761

Establishes cleanup procedures for PCB
spills.

Yes

Specifies soil cleanup levels
and excavation requirements.

Federal Action-Specific ARARs
Missouri Electric Wotte site.

3

-------
Quarterly Groundwater Monitoring Data

-------
Table A-l - Quarterly Comparison of Groundwater Concentrations

Contaminant: 1,1,1 TCA

Well

No.

MCL: 200ppb

Concentration in ppb

04/2001

<5.0

07/2001

<5.0

1W2001

<5.0

<5.0

-------
Table A-2 - Quarterly Comparison of Groundwater Concentrations

Contaminant: TCE	MCL: S ppb

^mnai ¦ i n hi ii ¦ ¦¦¦11111	i 11 taBagBBBgopawwMMWMMWMWBBWWMBBfeMBBi

Well

No.

04/2001

07/2001

imm

0112002

Cc

05(2002

incentra
00/2002

tion in p
10(2002

pb

02(2003

05(2003

08(2003

10(2003

02(2004

3

<5.0

<5.0

<5.0

<5.0

<5.0

<1.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

4

<5.0

<5.0

<5.0

<5.0

5.0

3J

1.4

4J

3J

3J

5.2

5.1

5

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

6A

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0





7

<5.®

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

9

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0





10

7.2

7.9

5.9

9.3

13

12

12

10

8.7

5.6

4J

4J

11

<5.0

<5.0

<5.0

<5.0

<5.0

<5,0

3.2

2J

<5.0

23

5.6

5.4

I 11A

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

Jwsw

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

2J

—

—

5J

3J

4J

8 12

These wells were installed during late November -early December
2002. They were first sampled on December 11,2002. TCE
concentrations were less than 5.0 ppb.

<5.0

<5.0

<5.0

<5.0

<5.0

1 13

<5.0

<5.0

<5.0

<5.0

<5.0

14

<5.0

<5.0

<5.0

<5.0

<5.0

ISA

These wells were installed

during late August to 							•—................—		....

early September 2003.

They were first sampled 						

September IS or 16,2003.



<5.0

<5.0

15B



<5.0

<5.0

1 16A



<5.0

<5.0

| 16B

i we concentrations were

<5.0 ppb with the
exception of MW-I6B and
MW-16C which had



				...........



9.5

7.4

16C



9.9

9.2

17A
17B

concentrations oi v.i ppo
and 9.1 ppb respectively.





<5.0

<5.0





<5.0

<5.0

IS





<5.0

<5.0

20A
I 20B
20C

These wells were installed
daring April 2004. They
were first sampled April
19 or 20,2004, TCE
concentrations were <5.0
ppb.

	......			...........			

—			 n s

™n n

a t

21A
21B



		*—¦ )*

O -

			 r\> n

o i

-------
Table A-3 - Quarterly Comparison of Groundwater Concentrations

Contaminant: PCI

Well

No.

MCL: 5 ppb

'¦h' ii in ' 'r ft—l—

Concentration in ppb

04/2001

<5.0

07/2001

<5.0

10/2001

<5,0

01/2002

<5,0

<5.0

<5.0

<5.0

<5.0

<5.®

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

3J

8.6

2.4

<5*0

41

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

«A

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5*0

<5.0

<5.0

<8.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

-------
Table A-4 - Quarterly Comparison of Groundwater Concentrations

Contaminant: 1,1-DCA

MCL:

II Well









Concentration in ppb









No,

04/2001

07/2001

1012001

01/2002

05/2002

081002

1MO02

02(1003

05/2003

08/1001

10/2003

02/2004

3

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5,0

<5.0

<5,0

<5.0

4

19

as

<5.0

13

15

34

I?

fS

18

t.»

15

22

5

<5.0

-------
Table A-5 - Quarterly Comparison of Groundwater Concentrations
Contaminant: 1,1-DCE		MCL: -

Well

No.

04/2001

<5.0

07/2001

<5.0

1W2001

<5.0

MMM

<5.0

Concentration in ppb
05/2002

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

7.7

<5.0

<5.0

6.4

93

6.1

2.2

7.0

<5.0

5.2

5.1

9.8

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

6A

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5,0

<5.0

<5.0

<5.0

<5.0 <5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

-------
Table A-4 - Quarterly Comparison of Groundwater Concentrations

Contaminant: 1,2-DCE	MCL: -

Well

No.

(mm

0712001

1QQ0Q1

01/2002

Cc
05/2002

incentra
08/2002

tion in p

10/2002

pb

02(2003

05/2003

08/2003

1QQ003

mm

3

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

4

<5.0

<5.0

-------
Table A-7 - Quarterly Comparison of Groundwater Concentrations

Contaminant: Benzene

Wei!

No.

MCLi 5 ppb

¦¦¦BBBBSSBJBSBSS

Concentration in ppb

04/2001

5J

07/2001

5,6

10/2001

16

01/2002

14

If

11

¦*0

73

11

10/2001 02/2004

<5.0

<5.0

<5.0

<5.0

<5.0

-------
Table A~8 - Quarterly Comparison of Groundwater Concentrations

Contaminant: Chlorobenzene	MCL: 20 ppb

I Wen









Concentration in ppb









No.

04/2001

07/2001

10/2001

mam

ossoot

08/2002

100002

02/2003

05/2003

08/2003

10/2003

mm

3

51®

320

1,400

1,600

uoo

590

630

800

630

420

250

690

4

30

63

15

21

42

<5.0

<5.0

17

14

5J

41

39

5

19

<5.0

16

29

45

120

130

44

7.9

38

32

20

6A

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0

<5.0





7

<5.0

<5.0

<5.0

5.6

9.8

<5.0

<5.0

<5.0

<5.0

2J

<5.0

-------
Table A-9 - Quarterly Comparison of Groundwater Concentrations

MCL: TO ppb

Well









Concentration in ppb









No.

04/2001

07/2001

1012001

0112002

030002

08/2002

10/2002

02/2003

05/2003

08/2003

10/2003

02/2004

3

<10

<10

<10

<10

<10

<10

<10

<10

<10

<10

<10

<10

4

41

<10

18

li

30

30

<10

20

22

u

«

45

*

<10

<10

<10

<10

<10

<10

<10

<10

<10

<10

<10

<10

6A

<10

<10

<1#

<10

<10

<10

<10

<10

<10

<10





7

24

<10

<10

<10

16

28

8J

IS

SI

m

1«

13

9

<10

<10

<10

<10

<10

<10

<10

<1®

<10

<10





10

31

31

28

18

10

13

12

M

7J

4J

4J

3J

1 11

<10

<10

<10

<10

<10

<10

<10

<10

<10

<10

<10

<10

1 UA

<10

<10

<10

<10

<10

<10

<10

<10

<10

<10

<10

<10

wsw

<10

<10

<10

<10





<10





<10

<10

<10

12

These wells were installed during late November -early December
2002. They were first sampled on December 11,2002.1,2,4-TCB
concentrations were less than 10 ppb with the exception of MW-

2fi

<10

lti

1«

11

13

<10

<10

<10

<10

<10

14

ia wukb no a tuncciiiniuvii ui Jv





<10

<10

<10

2J

2J

ISA
15B

These wells were installed
during late August to
early September 2003.
They were first sampled
September IS or 16,2003.
1,2,4-TCB concentrations
were <10 ppb.



—







—	

—...—

<10
<10

<10 I

<10

16A















<10

(

<10 ¦
*

16B















<10

<10

16C





















2J

<10

17A





















<10

<10

17B





















<10

<10

18









<10

<10 |

^ %
-n 2
C7 €

.K w>

H

Si

20C

These wells were installed
daring April 2004. They
were first sampled April
19 or 20,2004. 1,2,4-TCB
concentrations were <10
ppb.

21A

21B

-------
Table A-10 - Quarterly Comparison of Groundwater Concentrations

< Contaminant: 1,2-DCB	MCL; -

mmit II I In lil 	

WeB

No.

3

04/2001

07/2001

KM2001

01/2002

e«

05/2002

tncentra
08/2002

lion In p
10/2002

pb

02/2003

08(2003

08(2003

10(2003

01(2004

<19

<10

<10

<10

<10

<10

2J

2J

<10

2J

2J

2J

4

A

—4

O

<10

<10

3J

<10

su

41

2J

<10

<10

SJ

SJ

5

<10

<10

<10

<10

<10

<10

<10

<10

<10

<10

<10

<10

«A

<10

<10

<10

<10

<10

<10

<10

<10

<10

<10





7

<10

<10

<10

<10

<10

<10

<10

<10

<10

2J

<10

<10

9

<10

<10

<10

<10

<10

<10

<10

<10

<10

<10





10

<10

<10

<10

<10

<10

<10

<10

<10

<10

<10

<10

<10

11

<10

<10

<10

<10

<10

<10

su

<10

<10

<10

<10

<10

11A

<10

<10

<10

<10

<10

<10

<10

<10

<10

<10

<10

<10

wsw

<10

<10

<10

<10





<10





<10

<10

<10

12

13

14

These wells were installed daring late November -early December
2002. They were first sampled on December 11,2002.1,2-DCB
concentrations were less than 10 ppb with the exception of MW-
12 which had a concentration of 33ppb.

28

«

19

17

IS

<10

<10

<10

<10

<10

<10

<10

<10

2J

2J

Il5A

These wells were Installed

during late August to 	—		——-	*	..........	.........

early September 2003,

<10

<10

1 isb

<10

<10

I HA

1 ney were nrw sampieu 	

September 15 or 16,2003.

1,2-DCB concentrations 		*	*—*	*	*	*		

were <10 ppb.



<10

-------
Table A-ll - Quarterly Comparison of Groundwater Concentrations
Contaminant: 13-PCB	MCL: •

11 Well









Concentration in ppb









8 No.

04(2001

0712001

10/2001

91/2002

05/2002

08f20Q2

10(2002

02(2003

0K2008

mam

10(2001

02(2004

3

<10

<10

<10

<10

6J

6J

m

M

<10

w

W

41

4

13'

<10

<10

<10

8J

<10

511

93

7J

10

7J

16

B 5

<10

<10

<10

<10

<10

<10

<10

1J

8J

<10

<10

<10

|| 6A

<10

<10

<10

<10

<10

<10

<10

<10

<10

<10





7

<10

<10

<10

<10

<10

<10

<10

2J

4J

4J

2J

<10

9

<10

<10

<10

<10

<10

<10

<10

<10

<10

<10





10

<10

<10

<10

<10

<10

<10

<10

<10

<10

<10

<10

<10

11

<10

<10

<10

<10

<10

<10

5U

<10

<10

<10

<10

<10

11A

<10

<10

<10

<10

<10

<10

<10

<10

<10

<10

<10

<10

wsw

<10

<10

<10

<10





<10





<10

<10

<10

12

These wells were installed during late November -early December
2002. Tltey were first sampled on December 11,2002.1,3-DCB
concentrations were less than 10 ppb with the exception of MW-

100

37

71

47

51

13

<10

<10

<10

<10

<10

14

is wnicu niu a cunceaimuun 01 yo ppo.





<10

<10

<10

2J

2J

15A

These wells were installed
during late August to
early September 2003,
They were first sampled
September 15 or 16,2003,

1,3-DCB concentrations

were <10 ppb.















<10

<10

15B















<10

<10 -

16A















<10

<10 „
*

16B















<10

<10 I

16C





















3J

1 1

3J

17A





















<10

<10

17B





















<10

<10

18





















<10

<10



20A

20B
20C

21A
21B

These wells were installed
daring April 2004, They
were first sampled April
19 or 20,2004 1,3-DCB
concentrations were <10
PPfc

-------
Table A-12 - Quarterly Comparison of Groundwater Concentrations
Contaminant: 1,4-DCB	MCL: 750 ppb

Well
No.

Concentration in ppb

042001

25

07/2001

16

10/2001

17

01/2002

12

If

18

21

24

16

<1®

<10

<10

13

4J

7J

3J

21

<10

<10

<10

<10

<10

SJ

§J

7J

21

<10

<10

6A

<10

<10

<10

<10

<10

<10

<10

<10

<10

<10

<10

<10

<10

<10

<10

<10

<10

3J

4J

2J

2J

<10

<10

<10

<10

<10

<10

<10

<10

<10

<10

10

<10

<10

<10

<10

<10

IS

<10

1J

<10

<10

<10

<10

II

<10

<10

<10

<10

<10

<10

<10

<10

<10

<10

<10

11A

<10

<10

<10

<10

<10

<10

<10

<10

<10

<10

<10

<10

wsw

<10

<10

<10

<10

<10

<10

<10

<10

12

13

14

These wells were installed during late November -early December

2002. They were first sampled on December 11,2002.1,4-DCB
concentrations were less than 10 ppb with the exception of MW«
12 which had a concentration of 120 ppb.

100

43

77

72

<10

<10

<10

<10

<10

2J

4J

4J

<10

41

ISA

J5B

16A

16B

16C

17A

17B

18

These wells were installed
during late August to
early September 2003.
They were first sampled
September 15 or 16,2003.
1,4-DCB concentrations
were <10 ppb witb the
exception of MW-16C
which had a
concentration of 2J.

<10

<10

<10

<10

2J

<10

<10

<10

<10

<10

<10

<10

<10

<10

<10

<10

20A

20B

20C

21A
21B

These wells were installed
daring April 2004. They
were first sampled April
19 or 20,2004. 1,4-DCB
concentrations were <10
ppb.

Ci :
-n (

0	¦

1

»-*
o

ro

i—*

ui

-------
Table A-13 - Quarterly Comparison of Groundwater Concentrations
^ntaminant^POT^iA^brJl^uttfil^re^

I Well
No.

Concentration In ppb

04/2001

4?

0712001

1.1

1WM01

<0.50

1.2

<#3©

0.7

2.1

<0.50

«flLsa

<0.50

02/2004

-------
Table A-14 - Quarterly Comparison of Groundwater Concentrations

Contaminant: PCB (Aroclor 1260 filtered)	MCL: -

| Well









Concentration in ppb









No.

04/2001

07/2001

10/2001

mmm

05/2002

08/2002

10/2002

02/2003

mmm

08Q003

10M3

020004

3

<0.2®

<0.50

NA

<0.50

NA

0J0U

NA

NA

NA

NA

NA

NA

4

NA

NA

NA

NA

NA

NA

0.20U

NA

NA

NA

NA

NA

5

<0.50

<0.50

<0.50

<0.50

<0.50

<0.50

<0.50

<0.50

<0.50

<0.50

<0.50

<0.50

6A

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA





7

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

<0.50

NA

!9

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA





10

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

11

<0,50

<0.50

<0.50

-------
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