Third Five-Year Review Report
Palermo Weiifield Superfund Site
Tumwater, Washington
Prepared for
U.S. Environmental Protection Agency
Region 10
1200 Sixth Avenue, Suite 900
Seattle, WA 98101
September 2013
Prepared by
CH2MHILL®
1100 112th Avenue NE, Suite 500
Bellevue, Washington 98004
-------
CITATION
Third Five-Year Review Report
Palermo Wellfield Superfund Site, Tumwater, Washington.
Prepared by CH2M HILL, September 2013.
-------
Third Five-Year Review Report
For
Palermo Wellfield Superfund Site
Tumwater, Washington
(WAD 0000026534)
September 2013
PREPARED FOR:
U.S. Environmental Protection Agency Region 10
Office of Environmental Cleanup
Seattle, Washington
Approved by: Date:
/; "...
, ' y '
Cami Grandinetti, Program Manager
Remedial Cleanup Program
U.S. EPA Region 10
-------
-------
Contents
Section Page
Acronyms vii
Executive Summary ix
Five-Year Review Summary Form xi
1. Introduction 1-1
2. Site Chronology 2-1
3. Background 3-1
4. Remedial Action Objectives and Remedy Selection 4-1
4.1 Remedy Selection 4-2
4.2 Remedy Implementation 4-2
4.2.1 Wellhead Treatment Air Strippers 4-2
4.2.2 Subdrain and Treatment Lagoon 4-3
4.2.3 Standing Water Evaluation 4-3
4.2.4 Soil Vapor Extraction at Southgate Dry Cleaners 4-3
4.2.5 Long-Term Groundwater Monitoring 4-4
4.2.6 Monitoring of Subdrain and Treatment Lagoon Performance 4-5
4.2.7 Public Notice of Contaminated Groundwater 4-6
4.3 System Operation and Maintenance 4-6
4.3.1 Wellhead Treatment Air Stripper Operations 4-6
4.3.2 Subdrain and Treatment Lagoon Operations 4-7
4.3.3 SVE System Operations and Maintenance 4-7
5. Progress Since the Last Five-Year Review 5-1
5.1 Natural Attenuation 5-1
5.2 Dry Cleaner Site Deed Restriction 5-2
5.3 Treatment Lagoon Signage 5-2
5.4 TCE Plume Capture Effectiveness 5-2
5.5 TCE Plume Delineation and Groundwater Monitoring Adequacy 5-3
5.6 Inhalation Risks from Groundwater Vapor Intrusion 5-4
5.7 Ongoing Sources of Contamination 5-5
6. Five-Year Review Process 6-1
6.1 Administrative Components 6-1
6.2 Summary of Community Involvement 6-1
6.3 Document Review 6-1
6.4 Data Review 6-2
6.5 2011 Optimization Evaluation Findings 6-3
6.6 Summary of Site Inspection 6-4
6.6.1 Wellhead Treatment System 6-4
6.6.2 Subdrain System and Treatment Lagoon 6-4
6.6.3 Southgate Dry Cleaners 6-4
ES051313073020SEA/SEA131330001 III
-------
CONTENTS, CONTINUED
Section Page
6.7 Summary of Interviews 6-4
6.7.1 City of Tumwater Personnel 6-5
6.7.2 Washington State Department of Ecology 6-5
6.7.3 Washington State Department of Health 6-6
6.7.4 Washington State Department of Transportation 6-6
7. Technical Assessment 7-1
7.1 Is the Remedy Functioning as Intended by the Decision Documents? 7-1
7.1.1 Wellhead Treatment System 7-1
7.1.2 Wellfield Capture Zone 7-1
7.1.3 Plume Delineation and Long-Term Monitoring Adequacy 7-2
7.1.4 Subdrain System and Treatment Lagoon 7-2
7.1.5 Soil Vapor Extraction System at Southgate Dry Cleaners 7-2
7.1.6 Notification of Contaminated Groundwater 7-2
7.2 Are the Exposure Assumptions, Toxicity Data, Cleanup Levels, and RAOs Used at the Time of
Remedy Selection Still Valid? 7-2
7.2.1 Exposure Assumptions 7-3
7.2.2 Toxicity Data 7-3
7.2.3 Are There Changes in Standards to Be Considered? 7-4
7.2.4 RAOs and Progress of Remedy 7-7
7.2.5 Validity of Assumptions for Remedy Components 7-7
7.3 Has Any Other Information Come to Light That Could Call into Question the Protectiveness of the
Remedy 7-8
7.4 Technical Assessment Summary 7-8
7.4.1 Wellhead Treatment System 7-8
7.4.2 Subdrain System and Treatment Lagoon 7-8
7.4.3 Soil Vapor Extraction System at Southgate Dry Cleaners 7-8
7.4.4 Long-Term Groundwater Monitoring 7-9
7.4.5 Public Notification of Contaminated Groundwater 7-9
8. Issues 8-1
9. Recommendations and Follow-Up Actions 9-1
10. Protectiveness Statement 10-1
11. Next Review 11-1
12. References 12-1
Appendixes
A 2013 Air, Groundwater, and Subdrain Analytical Results
B Third Five-Year Review Interviews
C Third Five-Year Review Site Inspection Checklist
IV
ES051313073020SEA/SEA131330001
-------
CONTENTS, CONTINUED
Tables
2-1 Chronology of Events at Palermo Wellfield Superfund Site 2-2
3-1 Summary of Updated Preliminary Conceptual Site Model 3-1
4-1 Summary of Remedial Action Objectives and Remediation Goals 4-1
6-1 Palermo Documents Reviewed During the 2013 Five-Year Review 6-1
7-1 Key Applicable or Relevant and Appropriate Requirements Status 7-5
7-2 TCE Cleanup Level Comparison 7-6
7-3 EPA Region 10 Recommended Residential Media Concentrations of TCE 7-6
7-4 PCE Cleanup Level Comparison 7-7
8-1 Issues Identified During 2013 Five-Year Review 8-1
9-1 Recommendations and Follow-up Actions 9-1
Figures (provided at the end of the report)
1-1 Site Location Map
3-1 Cross Section Illustration of Site Conceptual Model
4-1 Project Location and Groundwater Monitoring Locations
4-2 Piezometer and Sampling Locations - Palermo Neighborhood
4-3 Concentration Trends for TCE at the Former WSDOT Facility
4-4 Concentration Trends for TCE at the WSDOT Testing Laboratory
4-5 Concentration Trends for PCE at the Southgate Mall
4-6 PCE and TCE Concentrations in Groundwater - Spring 2011
4-7 PCE and TCE Concentrations in Groundwater - Fall 2011
4-8 PCE and TCE Concentrations in Groundwater - Spring 2012
4-9 Subdrain System TCE Concentrations (ng/L) - February 2001 through March 2013
4-10 Subdrain System PCE Concentrations (ng/L) - February 2001 through March 2013
5-1 Notice of Palermo Neighborhood Meeting - July 10, 2013
ES051313073020SEA/SEA131330001
V
-------
-------
Acronyms
Hg/L micrograms per liter
Hg/m3 micrograms per cubic meter
1,2-DCE 1,1-dichloroethene
1,2-DCA 1,2-dichloroethane
ARAR Applicable or Relevant and Appropriate Requirement
ASAOC Administrative Settlement Agreement and Order on Consent
bgs below ground surface
bw/day body weight per day
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
CERCLIS Comprehensive Environmental Response, Compensation, and Liability Information System
CFR Code of Federal Regulations
cis-l,2-DCE cis-l,2-dichlorothene
City City of Turn water
CLARC Cleanup Level and Risk Calculation
COC chemical of concern
CSM conceptual site model
Ecology Washington State Department of Ecology
EPA U.S. Environmental Protection Agency
ESD Explanation of Significant Difference
FS Feasibility Study
ft/day feet per day
gpd/ft gallons per day per foot
gpm gallons per minute
HI hazard index
HQ hazard quotient
IRIS Integrated Risk Information System
MCL maximum contaminant level
mg/kg milligrams per kilogram
mg/L milligrams per liter
MTCA Model Toxics Control Act
NA not applicable
NCP National Oil and Hazardous Substances Pollution Contingency Plan
NPL National Priorities List
ES051313073020SEA/SEA131330001
-------
ACRONYMS
O&M
operation and maintenance
ORD
Office of Research and Development
PCE
tetrachloroethylene
POC
point of compliance
PPb
parts per billion
ppm
parts per million
QAPP
Quality Assurance Project Plan
RAOs
Remedial Action Objectives
RfC
reference concentration
RfD
reference dose
Rl
Remedial Investigation
ROD
Record of Decision
Site
Palermo Wellfield Superfund Site
SOW
Statement of Work
SVE
soil vapor extraction
TCE
trichloroethylene
trans-l,2-DCE
trans-l,2-dichloroethene
VOC
volatile organic compound
WAC
Washington Administrative Code
WDOH
Washington State Department of Health
WSDOT
Washington State Department of Transportation
VIII
ES051313073020SEA/SEA131330001
-------
Five-Year Review Summary Form
Executive Summary
This report presents the results of the third Five-Year Review of the Palermo Wellfield Superfund Site (Site) in
Tumwater, Washington (Comprehensive Environmental Response, Compensation, and Liability Information
System Identification [CERCLIS ID] Number WAD0000026534). The purpose of this statutory third Five-Year
Review is to determine whether the remedial actions implemented at the Site are protective of human health and
the environment. This report presents issues identified during the review process and provides recommendations
for addressing these issues.
The U.S. Environmental Protection Agency (EPA) Region 10 conducted the third Five-Year Review (hereinafter
2013 Five-Year Review) during the period of February 2013 through September 2013. The triggering action for this
review is the date of the second Five-Year Review for the Site, completed in September 2008 (hereinafter 2008
Five-Year Review). This 2013 Five-Year Review is required because the hazardous substances tetrachloroethylene
(PCE) and trichloroethylene (TCE) remain at the site above the remediation goal concentrations selected in the
1999 Record of Decision (ROD) (EPA, 1999) preventing unlimited use and unrestricted exposure.
The Site lies within the city limits of Tumwater, in the Puget Sound Basin of western Washington. The Site includes
the Palermo Wellfield and the Palermo neighborhood, located within the Deschutes River Valley, and the adjacent
uplands area to the west. Land use at the Palermo Wellfield Superfund Site consists of mixed commercial and
residential development and is not expected to change in the foreseeable future.
PCE and TCE were found to have migrated in the direction of groundwater flow from the uplands area to the
Palermo Wellfield. TCE was detected at a concentration exceeding the federal maximum contaminant level (MCL)
(5 micrograms per liter [|Jg/L]) in the municipal water supply in 1993. In addition, shallow groundwater containing
PCE and TCE was found to surface near and at the base of the Palermo bluff, collecting in yards and crawl spaces
of some residences in the Palermo neighborhood
The remedy selected by the ROD for the Site included a wellhead treatment system (using air stripping
technology) at the Palermo Wellfield, a soil vapor extraction (SVE) system and institutional controls at the
Southgate Dry Cleaner location, a French (subdrain) drain system in the Palermo neighborhood, long-term
groundwater monitoring, and institutional controls (notification of groundwater contamination).
A Five-Year Review site inspection was conducted on April 24, 2013. The Site inspection was attended by
personnel from the City of Tumwater, Washington State Department of Transportation (WSDOT), EPA Region 10,
GeoEngineers, and CH2M HILL. In addition, e-mail interviews were submitted to personnel from the City of
Tumwater and the Washington State Departments of Ecology, Health, and Transportation. Six issues and six
recommendations were identified through the Five-Year Review process. A summary of the results of the 2013
Five-Year Review is provided in the Summary Form provided in this report.
At this time, a protectiveness determination of the remedy at Palermo Wellfield Superfund Site cannot be made
until further information is obtained. A number of actions are planned to make the protectiveness determination.
It is expected that these actions will take approximately 4 years to complete.
Other Comments
Human Exposure Environmental Indicator Status for the Site remains "Insufficient Data to Make a
Determination" until ongoing site investigations are complete.
Groundwater Migration Environmental Indicator Status for the Site remains "Insufficient Data to Make a
Determination" until ongoing site investigations are complete.
ES051313073020SEA/SEA131330001
IX
-------
-------
Five-Year Review Summary Form
Five-Year Review Summary Form
SITE IDENTIFICATION
Site Name: Palermo Wellfield Superfund Site
EPA ID: WAD0000026534
Region: 10
State: WA
City/County: Tumwater/Thurston
NPL Status: Final
Has the site achieved construction
completion?
Yes
REVIEW STATUS
Lead agency: EPA
If "Other Federal Agency" was selected above, enter Agency name:
Author name (Federal or State Project Manager): Claire Hong
Multiple OUs?
No
Author affiliation: EPA Region 10
Review period: 9/30/2008 - 9/30/2013
Date of site inspection: 4/24/2013
Type of review: Statutory
Review number: 3
Triggering action date: 9/30/2008
Due date (five years after triggering action date): 9/30/2013
ES051313073020SEA/SEA131330001
XI
-------
FIVE-YEAR REVIEW SUMMARY FORM
Five-Year Review Summary Form (continued)
Issues/Recommendations
OU(s) without Issues/Recommendations Identified in the Five-Year Review:
None
Issues and Recommendations Identified in the Five-Year Review:
OU(s): Site
Issue Category: Remedy Performance
Issue 1: The potential risks from vapor intrusion in the Palermo
neighborhood remain a concern.
Recommendation 1: Complete evaluation of groundwater-to-indoor-air
pathway and conduct sufficient air monitoring to determine whether TCE
and PCE vapor concentrations in indoor air remain below the remediation
goals of 1.46 micrograms per cubic meter and 4.38 micrograms per cubic
meter, respectively.
Affect Current
Protectiveness
Affect Future
Protectiveness
Implementing
Party
Oversight
Party
Milestone Date
Yes
Yes
WSDOT
EPA
7/31/15
| Issues and Recommendations Identified in the Five-Year Review:
OU(s): Site
Issue Category: Remedy Performance
Issue 2: The effectiveness of the Palermo Wellfield System at capturing
and controlling contaminant migration requires further evaluation.
Recommendation 2: Conduct a three-dimensional capture zone analysis
to assess whether the contaminant plumes are being fully captured by the
operation of the Palermo Wellfield.
Affect Current
Protectiveness
Affect Future
Protectiveness
Implementing
Party
Oversight
Party
Milestone Date
Yes
Yes
WSDOT
EPA
12/1/15
| Issues and Recommendations Identified in the Five-Year Review:
OU(s): Site
Issue Category: Remedy Performance
Issue 3: TCE and PCE groundwater plumes need better definition;
characterization of the soil and groundwater is not complete at the three
source areas, and plume capture by the subdrain and wellfield is likely not
complete.
Recommendation 3: Evaluate the lateral and vertical distribution of
contaminants within the aquifer at the three source areas, the subdrain, and
the wellfield.
Affect Current
Protectiveness
Affect Future
Protectiveness
Implementing
Party
Oversight
Party
Milestone Date
No
Yes
EPA/WSDOT
EPA
12/01/16
XII
ES05131307 3020SEA/SEA1313 30001
-------
FIVE-YEAR REVIEW SUMMARY FORM
Issues and Recommendations Identified in the Five-Year Review:
OU(s): Site
Issue Category: Remedy Performance
Issue 4: TCE in soil at the former and current WSDOT facilities and PCE in
soil at Southgate Dry Cleaners may continue to be sources of
contamination to groundwater because it is unknown if significant masses
remain in vadose zone soil or in shallow groundwater. Institutional controls,
such as a deed restriction for the Southgate Dry Cleaners property, may be
needed if investigations determine that residual contamination is present
and poses a potential human health risk.
Recommendation 4: Complete investigations at known and potential
source areas and determine if institutional controls, such as a deed
restriction for the Southgate Dry Cleaners property, are needed.
Affect Current
Protectiveness
Affect Future
Protectiveness
Implementing
Party
Oversight
Party
Milestone Date
No
Yes
EPA/WSDOT
EPA
10/3/17
Issues and Recommendations Identified in the Five-Year Review:
OU(s): Site
Issue Category: Remedy Performance
Issue 5: The long-term groundwater monitoring system requires further
evaluation.
Recommendation 5: Based on the results of evaluations associated with
Recommendations 2, 3, and 4, determine whether the current groundwater
monitoring well network is adequate to monitor plume migration and to
gauge effectiveness of remediation. Install additional monitoring wells, if
necessary.
Affect Current
Protectiveness
Affect Future
Protectiveness
Implementing
Party
Oversight
Party
Milestone Date
Yes
Yes
WSDOT
EPA
8/31/17
Issues and Recommendations Identified in the Five-Year Review:
OU(s): Site
Issue Category: Remedy Performance
Issue 6: New toxicity information on TCE and PCE exists that may affect
the protectiveness of the remedy.
Recommendation 6: Determine whether cleanup levels need to be
modified based on new toxicity information on TCE and PCE.
Affect Current
Protectiveness
Affect Future
Protectiveness
Implementing
Party
Oversight
Party
Milestone Date
No
Yes
EPA
EPA
3/30/16
ES051313073020SEA/SEA131330001
XIII
-------
FIVE-YEAR REVIEW SUMMARY FORM
Operable Unit:
Site
Protectiveness Determination:
Protectiveness Deferred
Addendum Due Date
November 30, 2015
Protectiveness Statement:
At this time, a protectiveness determination of the remedy at the Palermo Wellfield Superfund Site
cannot be made for the Site until further information is obtained. The actions necessary to make the
protectiveness determination and deadlines for completion are above. It is expected that these
actions will take a total of 4 years to complete, at which time a protectiveness determination will be
made.
Other Comments
Human Exposure Environmental Indicator Status for the Site remains "Insufficient Data to Make a
Determination" until ongoing site investigations are complete.
Groundwater Migration Environmental Indicator Status for the Site remains "Insufficient Data to Make a
Determination" until ongoing site investigations are complete.
XIV
ES051313073020SEA/SEA131330001
-------
1. Introduction
This report presents the results of the 2013 Five-Year Review of the Palermo Wellfield Superfund Site in
Tumwater, Washington (CERCLIS ID Number WAD0000026534) (Figure 1-1). The purpose of this Five-Year Review
is to determine whether the remedial actions implemented at the Site are protective of human health and the
environment.
EPA Region 10 conducted the 2013 Five-Year Review during the period February 2013 through September 2013.
Analysis and report preparation support for the 2013 Five-Year Review was provided to EPA Region 10 by CH2M
HILL under EPA Contract 68-S7-04-01.
EPA Region 10 conducted this Five-Year Review pursuant to the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA §121 and the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP). CERCLA §121 states:
If the President selects a remedial action that results in any hazardous substances, pollutants, or
contaminants remaining at the site, the President shall review such remedial action no less often than
each 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 judgment of the President that action is appropriate at such site in accordance with section
[104] or [106], the President shall take or require such action. The President shall report to the Congress a
list of facilities for which such review is required, the results of all such reviews, and any actions taken as a
result of such reviews.
EPA interpreted this requirement further in the NCP, as stated in 40 Code of Federal Regulations (CFR)
§300.430(f)(4)(ii):
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 the initiation of the selected remedial
action.
This is the third Five-Year Review for the Site. The triggering action for this review is the date of the 2008 Five-
Year Review for the Site, performed during the period of February through September 2008. It is required because
hazardous substances remain at the Site above levels that allow for unlimited use and unrestricted exposure. This
2013 Five-Year Review has been prepared in accordance with current EPA guidance on conducting five-year
reviews (EPA, 2001a; 2011a; 2012a; 2012b).
ES051313073020SEA/SEA131330001
-------
-------
2. Site Chronology
The chronology of key Site events is summarized in Table 2-1. The impetus for initial action at the Site was the
detection of TCE in routine water samples collected in 1993 from the City of Tumwater's (also referred to as "the
City") municipal wellfield (the Palermo Wellfield), at a concentration exceeding the federal maximum contaminant
level (MCL). Later in 1993, investigations by the City and the Washington State Department of Ecology (Ecology)
also identified a contaminant source area as the Southgate Dry Cleaners, where PCE had been disposed of in a
drywell. Subsequent investigations identified plumes of dissolved TCE in groundwater emanating from two
WSDOT sources located upgradient of the Palermo Wellfield.
The Site was added to the National Priorities List (NPL) on April 1, 1997. Initial removal actions included
installation of an SVE system at Southgate Dry Cleaners, which began operation on March 24, 1998, and
installation of a wellhead treatment system at the Palermo Wellfield, which began operation in February 1999.
The remedial investigation (Rl) and feasibility study (FS) reports were completed by June 30, 1999 (URS, 1999a,
1999b), and the ROD was signed on November 16, 1999 (EPA, 1999). The remedy selected in the ROD included
continued operation of the SVE and wellhead treatment systems, construction of a French (subdrain) drain and
treatment lagoon to lower contaminated groundwater elevation within the Palermo neighborhood, long-term
groundwater monitoring, and public notice of groundwater contamination. Construction of the remedy was
completed on January 30, 2001.
In 2005, the U.S. Government initiated a cost-recovery case against two potentially responsible parties: WSDOT
and Southgate Development Corp. In 2007, a settlement was finalized with Southgate, and the court issued a
judgment identifying WSDOT as liable for a portion of the past and future response actions related to TCE
contamination at this Site.
In August 2011, EPA Region 10 conducted an Optimization Evaluation to consider the goals of the Site's remedy
based on available site data, its conceptual site model (CSM), and remedy performance to date. The Optimization
Evaluation was performed by Tetra Tech GEO, in consultation with EPA Region 10 and EPA's Office of Superfund
Remediation and Technology Innovation. A report summarizing the Optimization Evaluation findings and
recommendations was completed in November 2011 (EPA, 2011b).
In July 2012, an Administrative Settlement Agreement and Order on Consent (ASAOC or Agreement) was entered
into by EPA Region 10 and WSDOT (CERCLA Docket No. 10-2012-0149) (EPA and WSDOT, 2012). The agreement
provides for the performance of a supplemental RI/FS at the Site and the reimbursement for future response
costs incurred by EPA in connection with the Agreement. The stated objectives of the ASAOC are as follows:
a. To further investigate the nature and extent of contamination and any threat to the public health, welfare, or
the environment caused by the release or threatened release of hazardous substances, pollutants, or
contaminants at or from the Site, by conducting a supplemental Remedial Investigation as more specifically
set forth in the Statement of Work (SOW) for the ASAOC.
b. To evaluate the current remedy and to identify additional remedial alternatives to prevent, mitigate, or
otherwise respond to or remedy any release or threatened release of hazardous substances, pollutants, or
contaminants at or from the Site, by conducting an FS as more specifically set forth in the SOW for the ASAOC.
In response to the SOW, WSDOT has prepared a series of work plans and quality assurance project plans
(QAPPs) to address the requirements of the SOW and to complete the supplemental RI/FS. Air and
groundwater monitoring activities associated with these documents were initiated in March 2013.
ES051313073020SEA/SEA131330001
2-1
-------
2. SITE CHRONOLOGY
TABLE 2-1
Chronology of Events at Palermo Wellfield Superfund Site
Palermo Wellfield Superfund Site, Tumwater, Washington
Event
Date
Initial discovery of TCE exceeding the maximum contaminant level at the Palermo
Wellfield
Pre-National Priorities List investigations and responses
Final National Priorities List listing
Soil vapor extraction removal action at Southgate Dry Cleaners
Wellhead treatment removal action (construction complete)
Initial Remedial Investigation/Feasibility Study complete (URS, 1999a,b)
Record of Decision signed (EPA, 1999)
Subdrain and treatment lagoon remedial design started
Use of soil vapor extraction system terminated
Subdrain and treatment lagoon remedial design completed
Subdrain and treatment lagoon remedial action construction notice to proceed
Subdrain and treatment lagoon construction dates (start and finish)
Subdrain and treatment lagoon construction acceptance date
Preliminary closeout report signed
EPA performs one-year validation period on subdrain and treatment lagoon
EPA begins semi-annual long-term groundwater monitoring of the Site with periodic
indoor air monitoring
Washington State Department of Ecology begins operation and maintenance of subdrain
and treatment lagoon, transferring some responsibilities to the City of Tumwater
First five-year review (URS, 2003)
Second five-year review (Parametrix, 2008)
Integrated Risk Information System reassessment of TCE and PCE
Optimization Evaluation
EPA and WSDOT enter into Administrative Settlement Agreement and Order on Consent
for Response Actions
Draft Summary of Existing Information Report, Palermo Wellfield Superfund Site,
Tumwater, Washington (GeoEngineers, 2013a)
Sampling and Analysis Plan, Air Monitoring (GeoEngineers, 2013b)
Quality Assurance Project Plan, Air Monitoring (GeoEngineers, 2013c)
Field Sampling Plan, Semiannual Groundwater Monitoring (GeoEngineers, 2013d)
Amendment, Operations and Maintenance Manual, Subdrain System and Treatment
Lagoon (GeoEngineers, 2013e)
Palermo neighborhood air monitoring investigation for vapor intrusion commences
Third five-year review
1993
1993 to 1997
April 1, 1997
March 24,1998
February 1999
June 30,1999
November 16,1999
November 1999
June 2000
June 9, 2000
July 25, 2000
August 8, 2000, to January 9, 2001
January 30, 2001
February 22, 2001
February 2001 to January 2002
August 2001
February 2002
September 2003
September 2008
2011 and 2012, respectively
December 14, 2011
July 6, 2012
January 31, 2013
February 15, 2013
February 15, 2013
February 15, 2013
February 15, 2013
March 2013
September 2013
EPA = U.S. Environmental Protection Agency, PCE = tetrachloroethylene, TCE = trichloroethylene, WSDOT = Washington State
Department of Transportation
ES051313073020SEA/SEA131330001
-------
3. Background
This section presents the background for the Palermo Wellfield Site, which includes a summary of physical
characteristics, land uses, and history of actions taken to respond to contamination. The background information
is presented in the context of the updated CSM. The CSM is three-dimensional integration of all relevant
information assembled for the purposes of investigating or remediating a site. A preliminary CSM for the Site was
initially prepared as part of the 1999 Rl Report (URS, 1999a). The 1999 CSM has been updated, as summarized in
this section, to include additional information about source areas, remedial system components, long-term
monitoring results, and other Site-specific conditions. This information is summarized in Table 3-1 and a cross-
sectional schematic of the updated preliminary CSM is depicted on Figure 3-1. The CSM remains preliminary
because several investigations to fill data gaps concerning indoor air quality, source area characterization, and
hydrogeologic conditions are ongoing. As the understanding of current Site conditions and characteristics
improves, the CSM will be refined.
TABLE 3-1
Summary of Updated Preliminary Conceptual Site Model
Palermo Wellfield Superfund Site, Tumwater, Washington
CSM Element
Description3
Site Description, Land
Uses, and Boundaries
The Site is located within the City of Tumwater, Washington. The western portion of the Site consists of an
uplands area straddling Interstate 5. The uplands contain a variety of commercial land uses and businesses,
including government facilities such as the former and current WSDOT materials labs, current and former dry
cleaners, restaurants, gas stations, and other small businesses. The Southgate Mall, located in the middle of
the Site, houses many of these businesses. A prominent 60-foot bluff separates the western uplands from the
eastern lowland portion of the Site, which rests in the Deschutes River Valley and includes a residential
neighborhood of approximately 50 houses and the Palermo Wellfield. The wellfield consists of three active
water supply wells that provide a portion of the drinking water for the City. The north-flowing Deschutes River
forms the eastern boundary of the Site (EPA, 1999).
Remediation Systems
PCE and TCE were found to have migrated in the direction of groundwater flow from the uplands area to the
Palermo Wellfield, where TCE was detected in the municipal water supply in 1993. The ROD (EPA, 1999)
reported an estimated volume of contaminated groundwater in the range of 53 to 196 million gallons.
Potential receptors for this plume of contaminated groundwater included the human users of the drinking
water supply and aquatic receptors in the Deschutes River. In spring 1999, EPA began operating an air-
stripping treatment system at the Palermo Wellfield to remove PCE and TCE contamination from the water
supply. The City began to operate this system in 1999.
In addition to the TCE detected at the Palermo Wellfield, shallow groundwater containing PCE and TCE was
found to surface near and at the base of the Palermo bluff, accumulating in yards and crawl spaces beneath
some of the residences in the Palermo neighborhood. Ponded water in the crawl spaces poses a potential risk
to human health because of the potential for PCE and TCE to volatilize from the water into the air inside the
homes. In 2000, in accordance with the remedy selected in the ROD, EPA installed a subdrain system and
treatment lagoon to intercept and treat this shallow groundwater. The subdrain system was installed west of
the residences located along the western side of Rainier Avenue. The purpose of the subdrain system is to
lower the groundwater table to prevent water containing PCE and TCE from collecting in the crawl spaces
below the residences along Rainier Avenue. Water collected by the subdrain system is conveyed by
underground piping to a treatment lagoon located at the City of Tumwater Municipal Golf Course. This water
is treated by surface aeration and discharged into the Deschutes River via an existing watercourse.
EPA installed an SVE system to remove PCE from the soil near Southgate Dry Cleaners in 1998. The system
operated from March 1998 until June 2000. An estimated 400 pounds of PCE were recovered during its
operation.
Chemicals of Concern
(COCs)
TCE, PCE, and breakdown products (cis- and trans-l,2-dichloroethene [1,2-DCE] and vinyl chloride)
Confirmed Sources
• Southgate Dry Cleaners (PCE), 5141 Capitol Blvd
• WSDOT materials testing laboratory (TCE), 1655 South 2nd Avenue
• Former WSDOT facility located at the southwest corner of the intersection of Little Rock Road and
Trosper Road
ES051313073020SEA/SEA131330001
3-1
-------
3. BACKGROUND
TABLE 3-1
Summary of Updated Preliminary Conceptual Site Model
Palermo Wellfield Superfund Site, Tumwater, Washington
CSM Element
Description3
Potential Additional
Sources
Chevron station at 670 Trosper Road was initially identified as a release site for TCE, but subsequent studies
determined the source was upgradient from the Chevron facility at the former WSDOT testing laboratory.
Former Binger's Gull Station, Brewery City Pizza, Cattin's Family Dining Restaurant, and a Texaco service
station (now a Shell station) were also investigated. None of these additional potential sources is currently
considered a source of contamination at the Site.
Site Characteristics
Topography
The elevation of the uplands area is approximately 60 feet higher than the river valley. The Deschutes River
Valley trends north-south. The river flows north-northwest towards Puget Sound.
Land Use
Land use at the Site currently consists of mixed commercial and residential development within the city limits
of Tumwater and is not expected to change in the foreseeable future. The Palermo Valley residential
neighborhood near the wellfield has been present for approximately 40 years. The neighborhood is bordered
by the Palermo Valley bluff to its west, Valley Athletic Club is present to the north, and the Tumwater
Municipal Golf Club to the east. A wooded, undeveloped area is situated between the wellfield and the bluff.
Geology
Geology of the area consists of Deschutes River alluvium that has cut into older glacial deposits. Glacial
sediments consist of the Vashon Recessional Outwash, Vashon Till, and the older Penultimate Drift. Glacial
deposits are generally flat in the uplands area with localized relief comprising Tertiary basalt or marine
sandstone. Fluvial sediments in the valley are unconsolidated sands and gravels with minor silty interbeds.
Alluvium deposits range from approximately 100 feet to greater than 186 feet thick. Upland deposits, west of
the valley, include recessional outwash deposits from the Vashon Drift. These deposits are reported to be
predominantly sand. Vashon Till, a dense, poorly sorted sand with variable amounts of silt and gravel, is found
beneath the recessional outwash in the southwestern portion of the Deschutes River Valley. Bedrock in the
study area is described as Tertiary sediments and basalt.
Hydrogeology
Two regional aquifer systems are reported in the study area. The uppermost aquifer system is the Deschutes
River Alluvium and the Vashon Drift. This system is considered to be unconfined (Vashon Drift in the uplands)
to semi-confined (Deschutes River Alluvium in the valley). The Palermo Wellfield wells are completed within
the Deschutes River Alluvium at depths ranging from 70 to 120 feet below ground surface (bgs). Static water
levels within the Palermo Wellfield wells are generally less than 10 feet bgs. The difference in the depth to the
screened water-bearing zone and the depth to water in the completed wells suggests semi-confined
conditions in the valley. Groundwater surface elevations in the uplands are comparable to elevations in the
valley. This suggests that the Vashon recessional outwash in the uplands is unconfined and hydraulically linked
to the Deschutes River Alluvium. Groundwater flow across the study area is approximately due east with a
hydraulic gradient of approximately 0.03 feet per foot with some radial flow from Barnes Lake. The combined
transmissivity of the Vashon Recessional Outwash/Alluvium hydrogeologic unit is estimated at approximately
5,800 square feet per day. All of the Site wells are completed in the upper-most aquifer system. Depth to
groundwater in the upland Site wells appears to be approximately 35 to 55 feet bgs. Depth to groundwater in
valley wells appears to be approximately 1 to 8 feet bgs, with artesian conditions observed in two monitoring
wells (MW-ES-09 and MW-ES-10) in the Palermo neighborhood.
The lower aquifer is identified as the Penultimate Drift, located beneath the interglacial, fine-grained deposits
of the Kitsap Formation. The Kitsap Formation is reportedly a confining layer to the Penultimate Drift. Static
water levels for wells completed within the Penultimate Drift have been reported ranging from 100 feet bgs to
hydraulic heads above the ground surface.
Surface Water
Within the river valley, the closest immediate surface water feature is the aeration lagoon northeast of the
Palermo neighborhood, which accepts water collected by the subdrain system and other nearby areas. The
outfall from this lagoon runs approximately 2,000 feet to the north, where it enters the Deschutes River
(which also flows northward away from the Palermo neighborhood) at the Tumwater Municipal Golf Course.
The Deschutes River is the dominant drainage feature of the lower portion of the Site, as it runs through the
golf course, approximately 1,200 feet to the east of the residential neighborhood. Other key surface drainage
features of the residential neighborhood are a series of groundwater seeps at the base of the bluff along the
western and southwestern portion of the residential neighborhood. The subdrain system is designed to collect
surface water and transport it around the northern perimeter of the residential neighborhood to the aeration
lagoon. In addition, groundwater seeps/springs south of the neighborhood drain to a culvert behind the
3-2
ES051313073020SEA/SEA131330001
-------
3. BACKGROUND
TABLE 3-1
Summary of Updated Preliminary Conceptual Site Model
Palermo Wellfield Superfund Site, Tumwater, Washington
CSM Element
Description3
pocket park just west of the Palermo Wellfield.
The dominant surface water feature of the upland area is Barnes Lake, located less than 50 feet north and at a
lower elevation than the parking lot of the WSDOT materials testing laboratory. Trosper Lake is located
upgradient of the TCE and PCE plume, roughly 0.7 mile west/southwest of the WSDOT materials testing
laboratory. Stormwater runoff from the developed upland portion of the Site is collected in catch basins and
transported by the City of Tumwater's storm drain system for treatment and discharge to the Deschutes River.
Stormwater that is not collected runs off towards Barnes Lake on the western portion of the uplands, or down
the Palermo Valley bluff and infiltrates into the ground east of the wellfield.
Nature and Extent of
Contamination b
Soil
The Rl found limited shallow contamination in soil in the upland portion of the Site. Subsequent remedial
actions taken at the Southgate Dry Cleaners removed over 400 pounds of PCE contamination. The amount of
residual soil contamination at Southgate Dry Cleaners and at the WSDOT facilities will be evaluated as part of
upcoming investigations.
Groundwater
The known extent of the volatile organic compound (VOC) plume (incorporating both TCE source areas and
plumes and the PCE source area and plume) is approximately 3,000 feet long and over 600 feet wide at its
broadest point in the upland portion of the Site, and extends all the way to the wellfield.
A preliminary capture zone analysis for the Palermo Wellfield was performed as part of evaluating the nature
and extent of contamination at the Site. The preliminary capture zone analysis used estimated upper aquifer
transmissivities and wellfield pumping rates to generate two-dimensional regional potentiometric surface
maps for the upper aquifer. In both transmissivity scenarios that were evaluated, the plume fell within the
estimated capture zone. However, there was insufficient information about the Site to evaluate the extent of
the capture zone relative to the vertical distribution of the plumes within the aquifer. Investigations are
planned to collect additional hydrogeologic and analytical data to support a three-dimensional capture zone
analysis.
Surface Water
The principal source of surface water contamination is assumed to come from shallow groundwater migration
from the bluff to the west of the Site. PCE- and TCE-contaminated groundwater is partially captured by the
subdrain system and transported to the treatment lagoon. The highest concentrations of contamination
reported in the most recent round of surface water samples were reported in a subdrain cleanout upstream
from the treatment lagoon. In addition, surface water from four seep locations at the base of the bluff, along
with the treatment lagoon sampling stations on the eastern side of the residential neighborhood and subdrain
cleanout sampling stations on the western side of the residential neighborhood are sampled as part of long-
term monitoring activities. In general, results for the seeps and treatment lagoon effluent show no detectable
concentrations of TCE, PCE, or other chlorinated solvents. PCE and TCE are regularly detected in several of the
subdrain cleanout locations.
Air
The potential for vapor intrusion from residual soil and groundwater contamination at Southgate Dry Cleaners
will be evaluated as part of an upcoming investigation. Only limited shallow soil contamination was found in
the upland area above the bluff during the Rl. Subsequent remedial actions taken at the Southgate Dry
Cleaners removed over 400 pounds of PCE contamination, reducing the likelihood of PCE and TCE vapor
intrusion into indoor commercial spaces in the area atop the bluff.
Groundwater exits from several surface seeps along the base of the bluff to the west of the Palermo
neighborhood and shallow groundwater containing PCE and TCE has been reported at levels less than 3 feet
bgs in the Palermo neighborhood. Approximately a dozen residences could lie above shallow PCE and TCE
contamination, which could volatilize and migrate into the crawl spaces beneath and living spaces within
these homes. The goal of the subdrain remedy is to reduce the potential for exposure to PCE and TCE in
indoor air by lowering the overall groundwater elevation to reduce the potential for vapor intrusion into the
homes. The subdrain has not been completely effective at lowering the water table throughout the
neighborhood. Consequently, a more rigorous indoor air sampling program has been implemented in the
neighborhood.
Fate and Transport of
COCs
Site soils are relatively permeable (described as sands) and low in organic carbon. The releases in some cases
may have occurred approximately 40 to 50 years ago. PCE and TCE reaching the groundwater in a source area
would dissolve to some degree. Since the Site is generally an unconfined aquifer (groundwater flow is
generally unimpeded into and out of the area), the solubility limit of groundwater for PCE and TCE would likely
September 2008 | 415-2328-007 (041/FR01)
3-3
-------
3. BACKGROUND
TABLE 3-1
Summary of Updated Preliminary Conceptual Site Model
Palermo Wellfield Superfund Site, Tumwater, Washington
CSM Element
Description3
not be reached. As the density of non-aqueous phases of both PCE and TCE are greater than water, any
undissolved PCE or TCE would sink through the saturated zone as a dense non-aqueous phase liquid. These
factors contributed to relatively low concentrations of VOCs observed in soil samples during the Rl and may
have resulted in continuing sources of dissolved groundwater contamination at the identified sources listed
above. The relatively high groundwater flow rates and low organic carbon both contributed to contaminant
flushing over 40 to 50 years from the time of the original releases until the present. As a result, the majority of
contamination associated with the original releases may have migrated away from the source areas. However,
one or more of the historic source areas may be continuing to impact groundwater. Investigations are planned
to characterize residual contamination in the known and suspected source areas.
The fate of contaminated groundwater includes its surfacing through groundwater seeps near the Palermo
neighborhood, some of which is collected and treated by the subdrain and lagoon system. COC transport is
also affected by groundwater withdrawal from the wellfield. Groundwater migrates beyond the neighborhood
towards the Deschutes River approximately 1,200 feet to the east. Due the relatively eastern location of the
main PCE source area (Southgate Dry Cleaners), it appears that the PCE has remained sufficiently shallow to
be captured by the subdrain system, as indicated by PCE detections in the subdrain and the absence of PCE
detections in groundwater downgradient of the subdrain. The removal of water from the subdrain and the
surface expression of seeps due to the abrupt change in regional topography appear to result in an upward
gradient in the Palermo Valley such that TCE is closer to the ground surface in the Palermo neighborhood and
is captured by the wellfield.
Degradation of chlorinated solvents in groundwater can occur as a result of naturally occurring and manmade
processes through chemical or physical means. Based on a review of groundwater analytical results for the
Site, natural attenuation is not a significant process at this Site because typical degradation products of TCE
and PCE are mostly absent from groundwater. In addition, the results of an isotope analysis of TCE and PCE in
groundwater conducted as part of the March 2006 long-term monitoring event confirmed that natural
attenuation is not a significant mechanism for reducing TCE and PCE concentrations in groundwater at the
Site.
Potential Exposure
Pathways and Receptors
The following potential exposure pathways and receptors have been identified based on current and
anticipated future uses:
• Groundwater to indoor air (residents) in the Palermo neighborhood.
• Groundwater ingestion (residents and occupational workers) from the Palermo Wellfield.
• Groundwater exposure (inhalation and dermal contact) to excavation/construction workers in the
Palermo neighborhood.
• Surface water to ecological receptors in the Deschutes River Valley.
• Groundwater and soil to indoor air (occupational workers) in the uplands.
• Groundwater ingestion (residents and occupational workers) from future and hypothetical private
drinking water wells.
• Soil and groundwater-to-indoor air (hypothetical future residents) in the uplands.
• Subsurface soil exposure (ingestion and dermal contact) to excavation/construction workers in the
uplands.
3 Primary sources of information presented in this table include Draft Summary of Existing Information (GeoEngineers, 2013a), Final 2011 Annual
Groundwater Long-term Monitoring Report (Parametrix, 2012a), Final Late Spring 2012 Groundwater Long-term Monitoring Report (Parametrix, 2012b),
and the Optimization Evaluation (EPA, 2011b).
b Detailed information about the distribution of COCs in site media, changes in concentrations over time, and remedial system performance is provided in
Section 4.2 of this report.
bgs = below ground surface
COC = chemical of concern
CSM = conceptual site model
DCE = dichloroethene
EPA = U.S. Environmental Protection Agency
mg/L = milligrams per liter
PCE = tetrachloroethylene
ROD = Record of Decision
TCE = trichloroethylene
VOC = volatile organic compound
WSDOT = Washington State Department of Transportation
3-4
ES051313073020SEA/SEA131330001
-------
4. Remedial Action Objectives and Remedy
Selection
The ROD established the following remedial action objectives (RAOs) for the Site:
• Clean up aquifer.
• Prevent ingestion of, or exposure to, groundwater containing carcinogens in excess of applicable or relevant
and appropriate requirements (ARARs) and total excess cancer risk greater than 10"4 to 10 s.
• Prevent inhalation of chemical of concern (COC) vapors from surface water in residential crawl spaces at
concentrations that result in a total excess cancer risk greater than 10 s
• Prevent discharge of groundwater containing COCs to the Deschutes River at concentrations in excess of
ARARs or resulting in ecological hazard index (HI) greater than 1.
• Reduce the potential for PCE in soils under the Southgate Dry Cleaners to reach the groundwater.
The RAOs and associated remediation goals are summarized in Table 4-1.
TABLE 4-1
Summary of Remedial Action Objectives and Remediation Goals
Palermo Wellfield Superfund Site, Tumwater, Washington
RAO
Medium
COC
Remediation
Goal
Source of
Remediation Goal
Point of Compliance
Clean up aquifer.
Groundwater
PCE
TCE
1 1
LO LO
Federal Safe Drinking
Water Act MCLs
Groundwater
throughout the aquifer
Prevent ingestion of, or exposure to,
groundwater containing carcinogens in
excess of ARARs and total excess cancer
risk greater than 10"4 to 10"6.
Groundwater
PCE
TCE
1 1
LO LO
Federal Safe Drinking
Water Act MCLs
Palermo Wellfield
wellheads
Prevent inhalation of COC vapors from
surface water in residential crawl spaces
at concentrations that result in a total
excess cancer risk greater than 10"6
Shallow
Groundwater/
Surface Water
PCE
TCE
0.05b |jg/L
0.27b |jg/L
Calculation from
acceptable risk levels
Shallow groundwater
or water ponded
beneath residences
Prevent discharge of groundwater
containing COCs to the Deschutes River
at concentrations in excess of ARARs or
resulting in ecological HI greater than 1.
Groundwater/
Surface Water
PCE
TCE
0.8 |J.g/L
2.7 |_ig/L
National Toxics Rule3
for consumption of
water and organisms
Point of discharge to
Deschutes River.
Reduce the potential for PCE in soils
under the Southgate Dry Cleaners to
reach the groundwater.
Soil
PCE
TCE
0.0858 mg/kg
0.398 mg/kg
MTCA Method B
Entire soil column to
prevent groundwater
contamination
aNational Toxics Rule - Federal Clean Water Act, National Toxics Rule 40 CFR 131.36(b)(1) Human Health (10 6 cancer risk).
bThe remediation goals listed are below standard analytical detection limits. The actual remediation goal will be the method detection limit
for the analytical method used. These remediation goals were established to help assure that MTCA Method B air cleanup levels for TCE
and PCE are met in the residences along Rainier Avenue (1.46 pg/m3 for TCE and 4.38 |ag/mB for PCE). Until the remediation goals for
surface water in residential crawl spaces is met, the measure of effectiveness of the remedy for surface water will be maintenance of the
depth to shallow groundwater beneath the residences at a minimum of 18 inches.
Notes:
ARAR - applicable or relevant and appropriate requirements mg/kg - milligrams per kilogram or parts per million (ppm)
COC - chemical of concern MTCA - Model Toxics Control Act
HI - hazard index PCE -tetrachloroethylene
MCL - maximum contaminant level POC - point of compliance
^g/L - micrograms per liter or parts per billion (ppb) RAO - remedial action objective
^g/m3 - micrograms per cubic meter TCE -trichloroethylene
ES051313073020SEA/SEA131330001
4-1
-------
4. REMEDIAL ACTION OBJECTIVES AND REMEDY SELECTION
4.1 Remedy Selection
The Site remedy specified in the ROD (EPA, 1999) was selected by EPA based on consideration of CERCLA
requirements, the analysis of alternatives presented in the FS (URS, 199b), and on public comment. The remedy
consisted of the following components:
1. An air-stripping system at the Palermo Wellfield to treat contaminated groundwater to levels no greater than
MCLs for TCE and PCE prior to distribution into the municipal drinking water system.
2. A French drain (subdrain) system that lowers the water table to a depth of 18 inches below the bottom of the
crawl spaces under residences along the west side of Rainier Avenue. The subdrain collects shallow
groundwater, routes it to the Tumwater Municipal Golf Course, treats it by surface aeration in a lagoon, and
then discharges it into the Deschutes River via an existing stormwater ditch. The treated water in the
stormwater ditch meets National Toxics Rule water quality standards of 0.8 and 2.7 ng/L for PCE and TCE
respectively, which are protective of human consumption of water and aquatic organisms.
3. Investigate the presence of standing water in crawl spaces under homes east of Rainier Avenue in the
Palermo Community. Sample the water for PCE and TCE if it is encountered and assess potential risk to
affected residents using the same methodology used in the Rl human health risk assessment. Take remedial
action if unacceptable risks are found by either lowering the water table or by venting. The choice between
these two remedies is made based upon cost effectiveness.
4. Operate the SVE system at the Southgate Dry Cleaners until the soil cleanup goal for PCE (0.0858 milligrams
per kilogram (mg/kg) is met. Collect confirmatory soil samples; if samples exceed the remediation goal,
establish a deed restriction to reduce potential for site work that could encourage the transfer of
contaminants from soil to groundwater.
5. Implement a long-term groundwater monitoring system using existing wells to track the contaminant plume
until levels of TCE and PCE are consistently less than their MCLs throughout the aquifer at the site. Wells that
are not needed for the long-term monitoring program will be abandoned in accordance with ARARs.
Groundwater samples are analyzed for PCE, TCE, and breakdown products.
6. Implement a sampling program to determine the effectiveness of the subdrain system focusing on depth to
groundwater to demonstrate that a minimum 18-inch depth of dewatering is maintained.
7. Monitor the discharge from the aerated lagoon to confirm that the treated water meets applicable water
quality standards prior to discharge to the Deschutes River.
8. Provided public notification to property owners, well drillers, and local officials regarding the specific location
of the groundwater contaminant plume and information advising that the groundwater is not safe for
domestic use without treatment.
9. Monitor trends in TCE and PCE concentrations in groundwater and surface water, the effects of natural
attenuation, and the effectiveness of the treatment systems.
4.2 Remedy Implementation
This section discusses the implementation of the remedy components selected by the 1999 ROD (EPA, 1999).
4.2.1 Wellhead Treatment Air Strippers
The selected remedy for groundwater includes capture of contaminated groundwater at the Palermo Wellfield
and treatment with air-stripping to reduce the levels of TCE and PCE below MCLs. The wellhead treatment system
includes two air-stripper towers with associated blowers, an underground clear well, and pumps and piping. The
treatment system is designed to remove TCE contamination in ground water. In addition to removing TCE from
the City's water supply, the air-stripper system also removes natural carbon dioxide which helps to increase the
pH and reduce levels of certain metals at water taps in the City's distribution system. These air strippers have
been in operation since 1999. The system effectively treats influent water to below the MCLs for PCE and TCE and
4-2
ES051313073020SEA/SEA131330001
-------
4. REMEDIAL ACTION OBJECTIVES AND REMEDY SELECTION
has the means to provide treatment of higher volatile organic compound (VOC) concentrations than have been
detected at the wellfield so far.
The wellhead treatment system was constructed as part of a removal action in advance of the ROD and was
incorporated as part of the selected remedy. The wellhead treatment system was constructed between February
1998 and February 1999, when the system was substantially complete. Testing and optimization of the treatment
system's effectiveness occurred between January and June 1999. Operation and maintenance (O&M) of this
system was transferred to the City in April 1999. As reported by the City, operation of this system has been
without significant incident, other than the loss of historical pumping rate data caused by destruction of the
system's telemetry computer hard drive during a snow and ice storm in January 2012. The system effectively
treats influent water to below the MCLs for PCE and TCE. More information about wellfield treatment system
performance is provided in Section 4.3.1.
4.2.2 Subdrain and Treatment Lagoon
The subdrain system and treatment lagoon portion of the remedy was constructed between August 8, 2000 and
January 9, 2001. The costs of designing and installing this system were higher than estimated in the ROD because
of the need to construct a pipeline beneath M Street (rather than tying into the existing storm drain pipe) and
difficult construction conditions behind the Rainier Avenue homes. Design data also revealed that a deeper,
longer drain located closer to the homes would be required to meet the project objectives, which increased the
design and construction costs over the ROD estimate.
Once the subdrain and treatment lagoon system was constructed, EPA performed a one-year performance
validation from February 2001 through January 2002. The ROD goal for the subdrain performance was to lower
the groundwater elevation to 18 inches below the crawl space floors for the homes west of Rainier Avenue. The
floors of these crawl spaces were conservatively estimated to be 18 inches below ground surface (bgs). The
performance goal is therefore often described as "three feet below ground surface."
Following construction and performance validation of the subdrain system and treatment lagoon components of
the remedy, Ecology assumed responsibility for performing O&M of these facilities. Ecology then transferred
some O&M responsibilities to the City of Tumwater. The City assumed physical maintenance responsibility for the
property easements, equipment, and structures that make up the system. Until 2009, Ecology was responsible for
water quality sampling and measurement of parameters, such as groundwater depths and water flow rate, which
demonstrate the performance of the system and its protectiveness of human health and the environment. These
responsibilities were transferred back to EPA in 2009, then to WSDOT in 2012 as part of the ASAOC (EPA and
WSDOT, 2012). More information about the O&M and performance monitoring programs is provided in
Sections 4.2.6 and 4.3.2.
4.2.3 Standing Water Evaluation
The presence or absence of standing water in residential crawl spaces within the Palermo neighborhood was
evaluated as part of the subdrain design investigations. Where standing water was found, it was sampled and the
conclusions drawn from this assessment were used during design of the subdrain. The design concluded that only
the homes along the west side of Rainier Avenue currently required drainage, but that the conveyance piping
beneath Rainier Avenue and M Street should be oversized to allow future expansion of the drain system, if
necessary. The subdrain design was expected to have some influence beneath homes along the east side of
Rainier Avenue, with a decreasing influence farther east.
4.2.4 Soil Vapor Extraction at Southgate Dry Cleaners
The SVE system was installed near the Southgate Dry Cleaners PCE source in 1998 and was operated from March
1998 until June 2000. The system consisted of a total of four SVE wells spaced approximately 50 feet apart in the
parking lot and one well within Southgate Dry Cleaners. The SVE wells were screened on average from between
7 feet and 20 feet bgs. The piping to the wells was underground except for the pipe to the well inside the building,
which entered through the roof. The piping from the wells was plumbed to a manifold that provided valving and
sample ports to allow control and sampling of the vapor flow from each well. After the manifold, the combined
vapor flow entered the extraction blower, which created the vacuum to pull vapors from the soil. After passing
ES051313073020SEA/SEA131330001
4-3
-------
4. REMEDIAL ACTION OBJECTIVES AND REMEDY SELECTION
through the blower, the vapor entered a moisture knock-out canister to remove water. The vapor was then
treated using a series of granular activated carbon filters. The treated vapor was discharged to the atmosphere
through a 20-foot-tall emission stack. Water removed by the knock-out canister was periodically pumped to a
temporary storage tank. Most of the treatment components of the system were housed within a shipping
container placed next to the building. The carbon canisters and the temporary water storage tank were located
outside the container within a fenced compound.
The SVE system was operated from March 1998 through June 2000. In the preliminary closeout report (EPA,
2001b) the following was reported regarding the implementation of the SVE system:
The SVE system began operation on March 24,1998, and removed approximately 425 pounds ofPCE
before it was decommissioned in June 2000, based on comparing the results of vapor samples collected
from the system at startup to those collected just prior to decommissioning. The highest concentration of
PCE in soil beneath Southgate Dry Cleaners prior to remediation was 63.2 mg/kg. By applying the ratio of
the PCE concentration in vapor samples at startup and just prior to decommissioning to the concentration
in soils prior to remediation, an average PCE concentration remaining in soil within the area of SVE system
influence is estimated at 0.013 mg/kg. This is below the soil remediation goal of 0.0858 mg/kg. However,
the one confirmation soil sample collected in the same area following decommissioning of the SVE system
indicated a concentration of 0.232 mg/kg PCE. This indicates the presence of isolated areas of soil beneath
Southgate Dry Cleaners containing PCE concentrations still in excess of the remediation goal and therefore
requires a deed restriction on the property in accordance with the ROD.
Because contamination remains at the site, the ROD requires a deed restriction. The County has no record of any
deed restriction or easement recorded on any parcel or account number associated with this site or any site with
the name Southgate, Southgate Development Company, or Southgate Dry Cleaners located at the addresses
provided in the 2008 Pacific Northwest Title Insurance Company's title search (CH2M HILL, personal
communication, 3/21/2013, telephone call to Customer Service, Thurston County Auditor). At the time of
preparation of this 2013 Five-Year Review report, the deed restriction required by the ROD is not yet in place.
The effectiveness of the historic SVE system at remediating soils was revisited as part of the Optimization
Evaluation (EPA, 2011b). The Optimization Evaluation concluded that the remaining soil contamination may be
sufficient to cause vapor intrusion concerns or to act as a continuing source of dissolved groundwater
contamination. The EPA (as lead agency for the Southgate Dry Cleaners portion of the Site) is planning to conduct
an investigation of the area in 2013. The overall objectives of the 2013 PCE investigation are to characterize
residual levels of PCE and other contaminants in soil and groundwater in the vicinity of Southgate Dry Cleaners,
evaluate risks to human health, and support development of potential remedial alternatives if additional active
remediation is required.
4.2.5 Long-Term Groundwater Monitoring
A long-term groundwater monitoring program was initiated in 2001, with the first sampling event conducted in
August 2001. Semi-annual groundwater monitoring events continue to be conducted on a relatively regular
schedule, with the most recent event occurring in March 2013. Water levels are also collected semi-annually at
the monitoring wells and piezometers. Annual long-term monitoring reports are generated detailing the results of
the sampling. WSDOT is currently responsible for long-term groundwater monitoring activities.
The long-term groundwater monitoring network through 2011 consisted of 15 monitoring wells, 3 shallow
piezometers in the Palermo neighborhood, and 3 City production wells in the Palermo Wellfield. The monitoring
program was expanded in 2012 to include a total of 48 groundwater monitoring locations (30 monitoring wells, 15
piezometers, and three City production wells, as shown on Figure 4-1) to address concerns about contaminant
concentrations within and outside of the approximated plume boundaries. Features and monitoring locations
specific to the Palermo neighborhood are shown on Figure 4-2. The current monitoring program is documented in
the Field Sampling Plan, Semiannual Groundwater Monitoring (GeoEngineers, 2013d) and consists of sampling at
a total of 30 groundwater monitoring wells, 15 piezometers, and 3 City production wells. Samples are also
collected from 4 groundwater seeps at the base of the bluff, 3 subdrain cleanouts, aeration lagoon influent and
4-4
ES051313073020SEA/SEA131330001
-------
4. REMEDIAL ACTION OBJECTIVES AND REMEDY SELECTION
effluent, air stripper tower effluent, and the Deschutes River. The long-term monitoring program will be modified
following completion of the supplemental RI/FS.
Changes in TCE and PCE concentrations over time have been plotted for wells located along the lengths of the TCE
and PCE plumes. Analytical results for wells and other monitoring locations associated with the former WSDOT
facility TCE plume, the current WSDOT facility TCE plume, and the Southgate Dry Cleaners PCE plume are shown
on Figures 4-3, 4-4, and 4-5, respectively. Maps depicting the extents of the PCE and TCE plumes in spring 2011,
fall 2011, and spring 2012 are provided on Figures 4-6 through 4-8. Note that these plume maps were prepared by
WSDOT's consultant (GeoEngineers) prior to development of the updated CSM and do not reflect the current
understanding of COC source areas (that is, two separate WSDOT TCE sources west of Interstate 5) or plume
extent (that is, the PCE plume extends to the subdrain surrounding the Palermo neighborhood). Analytical results
for the spring 2013 groundwater monitoring event are listed in Appendix A. Copies of the semi-annual
groundwater monitoring reports are maintained in the project file and are available on compact disc upon request
to EPA.
4.2.6 Monitoring of Subdrain and Treatment Lagoon Performance
Monitoring of subdrain and treatment lagoon performance was initiated in 2001. Annual monitoring reports are
generated detailing the results of the sampling. WSDOT is currently responsible for long-term groundwater
monitoring activities. The current performance monitoring program is described in Amendment, Operation and
Maintenance Manual, Subdrain System and Treatment Lagoon (GeoEngineers, 2013e) and consists of the
following:
• Semiannual sampling in March and September (to coincide with long-term groundwater monitoring)
• Depth to water and total depth measurements in 15 piezometers, 8 trunk drain cleanouts, and 3 catch basins
• Measuring flow rates and obtaining water samples from 3 drain cleanouts, 3 outfalls to the treatment lagoon,
and 3 surface water locations
• The treatment lagoon effluent samples will be compared to 2006 National Water Quality Criteria (0.69 ng/L
for PCE and 2.5 ng/L for TCE) in addition to the remediation goals presented in the ROD (0.8 ng/L for PCE and
2.7 ng/LforTCE).
• Effluent samples obtained at the discharge point to the Deschutes River will be analyzed only if
concentrations of PCE or TCE exceed ROD remediation goals in the effluent sample obtained from lagoon
discharge.
• Total depth measurements at 3 cross-sections in the treatment lagoon (annual in September).
PCE is regularly detected in several of the subdrain cleanout locations (Locations 357, 358, and 359 on the
western side of the subdrain, and Location 350 at the subdrain discharge near the aeration basin), but is generally
absent in the monitoring wells and piezometers within the Palermo neighborhood. This indicates that the
subdrain is effectively capturing the shallow PCE plume and conveying it to the aeration basin. TCE is also
detected in the western portion of the subdrain (Locations 358 and 359) and in the subdrain discharge (Location
350), but detections of TCE in several wells and piezometers in the neighborhood indicate that the TCE plume is
deeper than the subdrain and artesian conditions cause it to upwell into certain parts of the neighborhood. For
example, TCE concentrations in MW-ES-09, located east of the subdrain, are considerably higher than TCE
concentrations in nearby subdrain cleanouts. Plots illustrating TCE and PCE trends in the subdrain system are
included on Figures 4-9 and 4-10.
TCE and PCE are also regularly reported in the treatment lagoon outfall and are occasionally detected in the
receiving water outfall (to the Deschutes River) but concentrations remain below the ROD established
remediation goals for surface water. Plots of TCE and PCE in the outfalls are shown on Figures 4-9 and 4-10,
respectively. Analytical results for the spring 2013 subdrain monitoring event are listed in Appendix A. Copies of
the subdrain monitoring reports are maintained in the project file and are available on compact disc upon request
to EPA.
ES051313073020SEA/SEA131330001
4-5
-------
4. REMEDIAL ACTION OBJECTIVES AND REMEDY SELECTION
4.2.7 Public Notice of Contaminated Groundwater
EPA published a fact sheet in February 2001, which was sent to local well drillers and property owners. The fact
sheet included an alert concerning installation of new wells in the area of contaminated groundwater. A figure
was included to show the area of contamination. In addition to this public notice, the City requires that all
properties within the city limits be connected to the City water supply. This requirement is a disincentive to the
drilling of new private wells.
4.3 System Operation and Maintenance
This section describes the O&M requirements for the remedy components, summarizes the O&M activities that
have been conducted to date, and describes any problems that have been identified through O&M.
4.3.1 Wellhead Treatment Air Stripper Operations
O&M of the wellhead treatment air strippers includes weekly, monthly, semi-annual, and annual maintenance
including periodic change-outs of air filters, equipment lubrication and cleaning, and equipment repair or
replacement, as needed. O&M of the wellhead treatment air strippers is conducted by the City. Sampling of the
air stripper effluent is conducted by WSDOT as part of the current long-term groundwater monitoring program.
The wellhead treatment system captures and treats hundreds of millions of gallons of water per year. Based on
information provided by the City, it appears that production from Palermo System has been decreasing for the
past decade, with other groundwater sources (primarily the Bush Middle School Wellfield) making up a larger
portion of the total City water supply. The City is evaluating ways to increase the flow rate from Palermo,
including rehabilitation or replacement of wells. The average total production from the wellfield in 2010-2011 was
less than 400 gallons per minute (gpm) and the average in 2012 was 425 gpm.
The 1990 NCP [(300.68(a)(3)] provides that Federal, State and local permits are not required for remedial actions
taken under CERCLA, so a discharge permit from Olympic Regional Clean Air Agency is not required for the air
strippers located at the wellhead. Operation of this system, however, should be substantively equivalent with a
permitted air discharge. No operational difficulties have been reported by the City for this review period
In the fall of 2010, the City constructed a covered area to enclose the space under the air stripper area to relieve
re-occurring weather-related maintenance issues. Over the course of the construction and subsequent upgrades
to the treatment system, the City installed a new chlorination system. The new system does not allow for sample
collection from a port after aeration and before chlorination. The only location available for stripper tower
effluent sample collection after aeration and before chlorination was at the base of the stripper towers.
Therefore, the stripper tower effluent sample location was changed in the field from the port to the base of the
stripper towers in 2010. Additionally, the City typically runs the treatment system using only one stripper tower to
save on operation costs so only one of the two stripper towers (ST-1 or ST-2) has been sampled during the most
recent sampling events. Concentrations of TCE and PCE in air stripper tower effluent samples have been
consistently below laboratory detection limits of 1 ng/L over the five-year review period. .
Up to three wells (typically TW-4, TW-6, and TW-8) are currently used for production sources for the wellfield.
Wells TW-4, TW-5, and TW-8 are currently included in the long-term groundwater monitoring program. TW-2, the
well with the highest TCE concentrations, was sampled as part of the monitoring program through 2011.
However, the well was decommissioned in 2012. Additionally, the City no longer uses TW-5 as a source for
production, and the well is only run for routine maintenance and sampling. According to information in the 2011
Groundwater Long-term Monitoring Report (Parametrix, 2012b), the City planned to further evaluate wellfield
performance and possibly replace several more wells, including TW-5, in the future.
PCE concentrations in the production well samples have been below laboratory detection limits of 1 ng/L
throughout the review period. TCE concentrations in TW-2 from October 2008 through November 2011 (the last
sampling event before decommissioning) ranged from 6.3 to 12 ng/L, with all results exceeding the remediation
goal of 5 ng/L. TCE has been detected sporadically in the other production well, but all detections have been
below the remediation goal during the reporting period.
4-6
ES051313073020SEA/SEA131330001
-------
4. REMEDIAL ACTION OBJECTIVES AND REMEDY SELECTION
4.3.2 Subdrain and Treatment Lagoon Operations
O&M of the physical components of the subdrain system and treatment lagoon is performed in accordance with
procedures identified in the Operation and Maintenance Manual, Subdrain System and Treatment Lagoon (URS,
2002) and in the Amendment, Operation and Maintenance Manual, Subdrain System and Treatment Lagoon
(GeoEngineers, 2013e). The City of Tumwater operates and maintains the subdrain/aeration lagoon system.
Pursuant to the ASAOC, if the City fails to fulfill its obligations for the system. WSDOT will ensure that the system
operates consistent with the O&M Manual and its amendments. O&M conducted since completion of the
performance validation period in January 2002 has consisted of periodic inspections of the lagoon aerators, repair
and/or replacement of the lagoon aerators as needed, and maintenance of property easements. Sedimentation is
not causing problems in the lagoon or the aerators. Since 2008, the city has replaced two aerator pumps and
removes vegetation on a regular schedule. The city reports that the lagoon system continues to operate as it was
designed without any problems and treated water meets the remediation goals prior to discharge to the
Deschutes River.
The following O&M activities have taken place over the review period:
• The recent amendment to the O&M Manual (GeoEngineers, 2013e) now requires routine pruning and brush
removal to be performed as necessary. This is estimated to be a minimum of four times a year, to provide
access to measurement, monitoring, operation and maintenance locations. Pruning and brush removal also
provides access for personnel and equipment to areas surrounding the subdrain system, treatment lagoon
and piezometers located within vegetated areas.
• Previous sediment accumulation in the perforated drain pipe and cleanouts has necessitated that the system
should be closely monitored to ensure it continues to operate effectively.
• The project sign on the eastern side of the treatment lagoon was replaced but the EPA contact name needs to
be updated to the current Site Manager.
4.3.3 SVE System Operations and Maintenance
O&M of the SVE System at Southgate Dry Cleaners was performed under EPA's Response Action Contract program
before the system was decommissioned in 2000.
ES051313073020SEA/SEA131330001
4-7
-------
-------
5. Progress Since the Last Five-Year Review
The 2008 Five-Year Review identified six issues including:
1. Natural attenuation is not a significant process at the Site; the restoration timeframe in the ROD will not be
met with the selected remedy.
2. The deed restriction for Southgate Dry Cleaners and the transfer of personal property and easements for
monitoring has not been completed.
3. Warning signs are missing at the treatment lagoon.
4. The effectiveness of Palermo Wellfield operation at capturing and controlling contaminant migration requires
further evaluation.
5. The adequacy of the groundwater monitoring system requires further evaluation.
6. The remediation goal for groundwater to protect against inhalation risk is unsupportable based on indoor air
monitoring results.
In August, 2011 EPA conducted an Optimization Evaluation to consider the goals of the Site's remedy based on
available site data, its CSM, and remedy performance. The Optimization Evaluation identified the following issues
concerning the CSM and remedy performance:
1. The definition of the groundwater plume is incomplete.
2. Plume capture by the subdrain and wellfield is likely not complete.
3. Vapor intrusion remains a concern and additional information is needed.
4. There is insufficient information to determine if historic sources continue to be ongoing sources of
contamination.
The following work has been conducted to better characterize the site since the Optimization Evaluation:
1. The groundwater monitoring programs for 2012 and 2013 were expanded to include sampling at 30
monitoring wells, 15 piezometers, and 4 groundwater seeps at the base of the bluff. These additional data
points defined the northern and southern boundaries of the TCE plume and better characterized the
distribution of TCE and PCE relative to source areas and to the subdrain and wellfield capture zones.
2. The first of four rounds of indoor air testing was conducted in the Palermo neighborhood.
3. Piezometers were re-installed in the eastern portion of the Palermo neighborhood in order to get a better
understanding of the impact of the artesian conditions and groundwater flow in the very shallow portion of
the aquifer beneath the neighborhood. This information is being used to assess potential indoor air impacts
from contaminated groundwater.
4. Responsibility for Site monitoring and completion of the RI/FS was transferred to WSDOT.
The following sections describe the current status of each of the issues identified by the 2008 Five-Year Review
and the Optimization Evaluation.
5.1 Natural Attenuation
Degradation of chlorinated solvents in groundwater can occur as a result of naturally occurring and manmade
processes, through chemical or physical means. Under the right conditions, biologically driven degradation
(biodegradation) of chlorinated solvents can result in attenuation of COCs. One typical process for natural
biodegradation occurs through the process of dehalogenation, whereby chlorine atoms are removed and replaced
with hydrogen atoms. The process usually occurs in a sequential manner, with PCE (4 chlorine atoms) degrading
to TCE (3 chlorine atoms), which in turn degrades to DCE (2 chlorine atoms), which then goes to vinyl chloride. The
ES051313073020SEA/SEA131330001
5-1
-------
5. PROGRESS SINCE THE LAST FIVE-YEAR REVIEW
final step in dehalogenation is the conversion of vinyl chloride to ethane, which has no chlorine atoms. The
dehalogenation process occurs under, but is not limited to, anaerobic conditions, with dissolved oxygen
concentrations usually less than 1 milligrams per liter (mg/L). However, based on a review of groundwater
analytical results for the Site, natural attenuation is not a significant process at this Site because typical
degradation products of TCE and PCE, such as cis-l^-DCE1 and vinyl chloride, are mostly absent from
groundwater. In addition, the results of an isotope analysis of TCE and PCE in groundwater conducted as part of
the March 2006 long-term monitoring event confirmed that natural attenuation is not a significant mechanism for
reducing TCE and PCE concentrations in groundwater at the Site (Parametrix, 2007). As a result, EPA does not
expect this process will be a viable remedial measure for the future.
5.2 Dry Cleaner Site Deed Restriction
The deed restriction required in the 1999 ROD has not been processed or recorded for the Southgate Dry Cleaners
property. Results from the new source investigation that will be conducted in this area (see Section 5.7) will
determine if the Deed Restriction is still necessary.
5.3 Treatment Lagoon Signage
The project sign on the eastern side of the treatment lagoon was replaced but the EPA contact name needs to be
updated to the current Site Manager.
5.4 TCE Plume Capture Effectiveness
The ROD assumed, based mainly on numerical groundwater modeling performed during the Rl (URS, 1999a), that
groundwater extraction at the Palermo Wellfield would eventually capture the entire TCE plume as it was known
at the time. Hydrogeologic analysis conducted as part of the Optimization Evaluation found that plume capture
could not be confirmed with the available head and concentration data set. The required flow rate to capture the
TCE plume, based on simple calculations using aquifer properties and plume dimensions, was estimated at
720 gpm. The average flow rate from the Palermo Wellfield in the 1990s and early 2000s has typically been over
800 gpm. However, the Optimization Evaluation noted that average production in the wellfield during 2010 and
2011 was less than 400 gpm and that production appeared to be decreasing. The Optimization Evaluation
recommended that the wellhead capture zone be re-evaluated as part of the supplemental RI/FS being conducted
by WSDOT.
WSDOT recently evaluated capture zone effectiveness using a two-dimensional model (W/7AEM2000 [Kraemer et
al., 2007]) and more recent site data. The results of the evaluation were documented in the Draft Summary of
Existing Information Report (GeoEngineers, 2013a). In this model, the aquifer was assumed to be a confined,
homogenous, and isotropic aquifer, with thickness of 40 feet, porosity of 0.25, and transmissivity between 30,000
and 35,000 gallons per day per foot (gpd/ft), and a hydraulic conductivity of 100 to 117 feet per day (ft/day). In
order to delineate a capture zone for the Palermo Wellfield, a regional groundwater elevation was assumed by
setting the head at southwest corner of Trosper Lake as 170 feet, with a gradient of 0.008 toward northeast 65
degrees. The gradient was simplified as being uniformly distributed. Average pumping rates, based on 2006
through 2008 data, were used as the pumping rate in the model. For viewing the flow lines of groundwater
towards each well, 20 particles were set for each well in the model. The simulation period was set as 5 years and
time-of-travel ticks marked the location of the flow line for each year. Two scenarios were modeled to test the
sensitivity of aquifer transmissivity values on the extent of the capture zone. For Scenarios 1 and 2, transmissivity
was assumed to be 30,000 gpd/ft and 35,000 gpd/ft, respectively. The resulting capture zone for the wellfield
under each transmissivity scenario was then compared to the position of the TCE plume and hydrologic
boundaries, such as Trosper Lake. In both transmissivity scenarios the plume fell within the estimated capture
zone. However, there was insufficient information about the Site to evaluate the extent of the capture zone
^ Cis-1,2-DCE has been detected in nine wells (inclusive of monitoring wells, piezometers, and drinking water wells) between 2008 and 2013. These wells are
MW-111, MW-UI, MW-ES-05, MW-ES-09, MW-ES-10, PZ-721, PZ-724, PZ-728, and TW-2. Reported detections ranged from 0.02 to 2.7 ng/L.
5-2
ES051313073020SEA/SEA131330001
-------
5. PROGRESS SINCE THE LAST FIVE-YEAR REVIEW
relative to the vertical distribution of the plumes within the aquifer. Investigations are planned to collect
additional hydrogeologic and analytical data to support a three-dimensional capture zone analysis.
5.5 TCE Plume Delineation and Groundwater Monitoring
Adequacy
Expansion of the long-term groundwater monitoring program in 2012 and 2013 allowed for better delineation of
the down- and cross-gradient extents of the PCE and TCE plumes. Maps depicting the extents of the PCE and TCE
plumes in spring 2011, fall 2011, and spring 2012 are provided on Figures 4-6 through 4-8. However, these plume
maps were prepared prior to development of the updated CSM and do not reflect the current understanding of
COC source areas or plume extent. The extents of the plumes, based on spring 2012 monitoring data, are as
follows:
• The PCE plume originates near Southgate Dry Cleaners and extends beneath the bluff to emerge as shallow
groundwater that is captured by the western subdrain around the Palermo neighborhood. Concentrations of
PCE in wells and piezometers within the Palermo neighborhood are typically below detection limits and, when
detected, PCE concentrations are below the remediation goal of 5 ng/L. The highest concentrations of PCE (31
Hg/L) occur at MW-ES-04, just east of the source area at Southgate Dry Cleaners. The northern and southern
boundaries and the vertical extent of the PCE plume have not been established. These data gaps will be filled
by an investigation to be conducted by EPA (as lead agency for the Southgate Dry Cleaners portion of the Site)
in fall 2013.
• The southwestern lobe of the TCE plume originates from the former WSDOT testing laboratory located
southwest of Trosper Road and extends beneath the Chevron station. The plume is joined by another TCE
plume that originates at the current WSDOT materials testing laboratory located somewhere in the vicinity of
the western cloverleaf of Interstate 5 at Trosper Road. The two plumes coalesce into a single TCE plume that
extends to the Palermo neighborhood and the wellfield. The TCE plume appears to be deeper than the PCE
plume, and artesian conditions near the base of the bluff cause it to upwell within the southwestern portion
of the neighborhood just beyond the subdrain. The highest concentrations of TCE (150 ng/L in spring 2012)
occurred at MW-ES-09. The cross- and down-gradient boundaries of the TCE plume in the vicinity of the
neighborhood and wellfield appear to be delineated by the existing monitoring network, as shown on
Figure 4-8. However, additional wells are needed in the two WSDOT source areas and in the upland portion of
the Site near Interstate 5 to better understand hydrogeologic conditions and to characterize the lateral and
vertical distributions of TCE. These data gaps will be filled by an investigation to be conducted by WSDOT.
In accordance with the requirements of the ASAOC, WSDOT began implementation of an updated monitoring
program in the spring of 2013. The monitoring effort, documented in Field Sampling Plan, Semiannual
Groundwater Monitoring (GeoEngineers, 2013d), is designed to determine the following:
• Monitor concentrations of TCE, PCE and breakdown products in groundwater;
• Assess trends in TCE and PCE concentrations in groundwater beneath the Site;
• Monitor chemical and biochemical conditions in groundwater to assess whether natural degradation of TCE
and PCE is occurring;
• Monitor groundwater elevations and assess seasonal changes;
• Document the effectiveness of the remedy components, including an assessment of the capture zone of the
Palermo Wellfield and the air stripping system at the Palermo Wellfield.
These data, as well as information from the planned PCE and TCE investigations (see Section 5.7), will also be used
to determine the locations and screened intervals for new monitoring wells to delineate the contaminant plumes
and assess wellfield and subdrain effectiveness. Results from the spring 2013 groundwater monitoring event are
expected to be available at the end of February 2014.
ES051313073020SEA/SEA131330001
5-3
-------
5. PROGRESS SINCE THE LAST FIVE-YEAR REVIEW
5.6 Inhalation Risks from Groundwater Vapor Intrusion
EPA identified the water-to-indoor-air pathway for residences in the neighborhood as a potential exposure
pathway as a result of TCE and PCE concentrations in shallow groundwater. Previous Five-Year Reviews have
indicated that concentrations of TCE in residential indoor air may have exceeded the acceptable EPA cancer risk
range and/or that the RAO has not been met. These reviews deferred comments on the protectiveness of indoor
air until further evaluation could be conducted to assess this exposure pathway.
In 2011 EPA's Office of Research and Development (ORD) completed its toxicological review of TCE. In the same
year EPA updated the toxicity information for TCE available in the Integrated Risk Information System (IRIS) (see
Section 7.2.2). The new IRIS information provides for oral and inhalation potency and noncancer toxicity values
that indicate that exposure to TCE before the age of 16 may result in increased risk of developing cancer later in
life. The ORD review shows that the noncancer toxicity values for TCE are based in part on fetal heart
malformations that may occur during an early, short window of exposure to the mother during gestation. As a
result, in December 2012, EPA Region 10's Office of Environmental Assessment recommended that risk
assessments in Region 10 use the values in IRIS for chronic TCE exposures, and recommended that the average
exposures over any 21-day period of time not exceed the concentration of 2.0 ng/m3.
The updated CSM presented in Section 3.1 and depicted on Figure 3-1 indicates that TCE impacted groundwater is
being transported along a vertical gradient to shallow groundwater in the Palermo neighborhood. The plume
apparently bypasses the subdrain and upwells within the southwestern portion of the neighborhood. As discussed
in Section 5.5 above, analytical results from the spring 2012 sampling event support this hypothesis, with the
primary TCE contamination plume in the Palermo neighborhood centered around two monitoring wells with
artesian flow, MW-ES-09 and MW-ES-10.
In accordance with the ASAOC SOW, WSDOT must evaluate exposure pathways associated with the potential for
vapor intrusion from the subsurface to indoor air in the Palermo neighborhood. In order to accomplish this,
WSDOT will conduct four rounds of indoor air monitoring. The current monitoring program documented in the Air
Monitoring QAPP (GeoEngineers, 2013b) consists of the following activities:
• Collection of air samples from designated homes and crawl spaces and from the ambient air in the Palermo
neighborhood to determine what additional investigations and actions, if any, are necessary to provide
adequate safety to Palermo residents.
• Collection of sub-slab soil vapor samples at homes in the Palermo neighborhood that do not have a crawl
space (i.e., are slab-on-grade construction).
• Analysis of vapor and air samples for PCE,TCE, vinyl chloride, 1,1-dichlorethene, cis-l,2-dichlorethene (cis-1,2-
DCE), trans-l,2-dichloroethene (trans-l,2-DCE), 1,1-dichloroethane, and 1,2-dichloroethane (1,2-DCA). PCE
and TCE are the primary COCs. With the exception of 1,2-DCA, the other VOCs are breakdown products of PCE
and TCE.
• Comparison of TCE results to Region 10's recommended protective concentration for short-term exposure to
indoor air (2.0 ng/m3) as well as the remediation goal for TCE (1.46 ng/m3) that is established in the ROD.
These sample results will be used to re-evaluate human health risks from vapor intrusion. Should indoor air
monitoring show concentrations that may pose an unacceptable risk to human health or the environment,
then immediate response actions will be taken.
In accordance with the 2013 Air Monitoring QAPP, the first of the four rounds of sampling was conducted in
March and April 2013. Thirty residences in the Palermo neighborhood were sampled and duplicate samples were
collected for quality assurance purposes at 10 percent of the residences. Residential samples were collected from
indoor air and from underlying crawl spaces or sub-slab soil gas, depending on home construction. Passive, long-
term exposure samplers (Radiellos) were used to evaluate conditions in all 30 homes and short-term exposure
samplers (Summa Canisters) were also deployed for 24 hours in 5 of the homes. To establish background
conditions for the residential results, Radiellos were also used to sample ambient air in the neighborhood and in
wellfield buildings.
5-4
ES051313073020SEA/SEA131330001
-------
5. PROGRESS SINCE THE LAST FIVE-YEAR REVIEW
Notification letters documenting the results of the 2013 residential sampling event were sent to the owners of
each sampled home in June 2013. All the letters indicated that the EPA and WDOH found no immediate health
concerns from TCE and PCE in the indoor air of the home. A Palermo neighborhood meeting was also conducted
on July 10, 2013, to discuss the air sampling conducted in the neighborhood, including results, health concerns,
and future sampling plans. A copy of the July meeting notice is included as Figure 5-1.
The overall residential indoor air results are summarized and compared to the indoor air remediation goals below,
and a listing of analytical results is provided in Appendix A:
• TCE was detected in 11 of 33 indoor air samples obtained using Radiellos. Reported concentrations ranged
from 0.053 to 0.25 ng/m3. None of the results exceeded the remediation goal for indoor air (1.46 ng/m3).
• TCE was detected in 2 of the 7 collocated Summa Canister samples. The detections were in the individual and
duplicate indoor air samples from the same home and both detections (0.2 ng/m3 for both) were below the
remediation goal for indoor air.
• PCE was detected in 25 of 33 indoor air samples obtained using Radiellos. The reported concentrations ranged
from 0.056 to 13 ng/m3. While three of these results exceeded the remediation goal for indoor air
(4.38 ng/m3), the PCE results for crawl space samples collected at two of these exceedance locations were
either non-detect or did not exceed the remediation goal. Crawl space or sub-slab soil vapor data were not
available for the third exceedance location, but the residents of the house reported using a product that may
have contained PCE at the time of sampling. For the three residences where PCE was detected above the
remediation goal, the groundwater near these residences did not have PCE detected above the remediation
goal. In notification letters sent to the homeowners, EPA reported that the source of the elevated PCE
readings was likely household products.
• PCE was detected in 2 of the 7 collocated Summa Canisters, with concentrations of 0.25 and 0.96 ng/m3.
Neither of these results exceeded the remediation goal for indoor air.
• A chemical not associated with the Site, 1,2-DCA, was detected in many of the residential indoor air samples
(33 Radiello samples and 3 Summa Canister samples). The reported concentrations ranged from 0.051 to
15 ng/m3. The ROD does not include a remediation goal for 1,2-DCA because it is not associated with the Site.
While the source of this chemical is unknown, several other vapor intrusion sites have shown a connection to
molded plastic goods and decorations (Kurtz et al, 2010 and Doucette et al, 2010).
5.7 Ongoing Sources of Contamination
Three historical sources of contamination have been identified at the Site: Southgate Dry Cleaners, the current
WSDOT materials testing laboratory, and the former WSDOT testing laboratory. At the time of the ROD, releases
from Southgate Dry Cleaners were assumed to be the primary source of contamination (TCE at the wellfield was
assumed to have resulted from degradation of PCE). Possible releases from the WSDOT sources were identified
during subsequent research and installation of additional monitoring wells upgradient of Southgate Dry Cleaners.
PCE and TCE are no longer stored or used at any of the source areas. However, residual soil contamination at the
original release locations may continue to act as ongoing sources of groundwater contamination.
A SVE system to remove PCE from the soil near Southgate Dry Cleaners was installed in 1998. The system
operated from March 1998 until June 2000 and an estimated 400 pounds of PCE were recovered during its
operation. The effectiveness of the historic SVE system at remediating soils in the Southgate Dry Cleaners portion
of the Site was revisited as part of the Optimization Evaluation. The Optimization Evaluation concluded that the
remaining soil contamination may be sufficient to cause vapor intrusion concerns or to act as a continuing source
of dissolved groundwater contamination. The EPA (as lead agency for the Southgate Dry Cleaners portion of the
Site) will conduct an investigation of the area in 2013. The overall objectives of the 2013 PCE investigation are to
characterize residual levels of PCE and other contaminants in soil and groundwater in the vicinity of Southgate Dry
Cleaners, evaluate risks to human health, and support development of potential remedial alternatives if additional
active remediation is required. Initially, only soil and groundwater samples will be collected; if concentrations in
ES051313073020SEA/SEA131330001
5-5
-------
5. PROGRESS SINCE THE LAST FIVE-YEAR REVIEW
those media are sufficiently high to suggest possible vapor intrusion concerns in nearby commercial buildings,
sub-slab soil vapor and/or indoor air samples may be collected.
The potential for residual soil contamination in the vicinity of the WSDOT source areas has not been evaluated.
Future investigations in support of the Supplemental RI/FS will likely include an evaluation of residual soil
contamination in these source areas.
5-6
ES051313073020SEA/SEA131330001
-------
6. Five-Year Review Process
This section provides a description of the 2013 five-year review process and findings.
6.1 Administrative Components
The following parties were identified as being potentially interested in the five-year review process:
• City of Turn water
• WSDOT
• Ecology
• Washington State Department of Health (WDOH)
The 2013 Palermo Wellfield Superfund Site Five-Year Review was led by Claire Hong of EPA, Remedial Project
Manager for the Site, and included support from the City of Tumwater, WSDOT, CH2M HILL (contractor to EPA),
and GeoEngineers (contractor to WSDOT). The review was initiated by a kickoff meeting held on April 24, 2013
before the Site Inspection. Key topics of that meeting included the a discussion on the effectiveness of the
groundwater extraction system at the Palermo Wellfield in capturing contaminated groundwater, the need to
reassess possible vapor intrusion of TCE into residential areas, and the potential lingering presence of PCE in soil
and groundwater near the Dry Cleaner Site.
Interview forms were distributed to personnel from the City, Ecology, WDOH, WSDOT, and GeoEngineers during
the week of April 29, 2008. Copies of the returned interview forms are provided in Appendix B.
The findings of this 2013 Five-Year Review process are discussed below.
In February 2013, EPA, and WSDOT conducted door-to-door visits to residents of the Palermo neighborhood to
share general information about the Superfund Site and to request access to properties in anticipation of
additional work that will occur as a result of the ASAOC (EPA and WSDOT, 2012). In addition, a Palermo
neighborhood meeting was conducted on July 10, 2013, to discuss the air sampling conducted in the
neighborhood, including results, health concerns, and future sampling plans. A copy of the July meeting notice is
included as Figure 5-1.
6.2 Summary of Community Involvement
6.3 Document Review
A list of the documents reviewed during the 2013 Five-Year Review is shown in Table 6-1.2
TABLE 6-1
Palermo Documents Reviewed During the 2013 Five-Year Review
Palermo Wellfield Superfund Site, Tumwater, Washington
Author
Document
Date
URS
Final Feasibility Study, Palermo Wellfield Superfund Site, Tumwater, Washington.
May 1999
Parametrix
URS
Final Remedial Investigation, Palermo Wellfield Superfund Site, Tumwater,
Washington.
Final Second Five-Year Review Report, Palermo Wellfield Superfund Site, Tumwater,
Washington.
June 1999
September 2008
URS Greiner, Inc. Remedial Action Construction Documentation, Subdrain System and Treatment
Lagoon.
March 2011
2
Guidance, EPA databases, and other reference documents used to complete the 2013 Five-Year Review are cited where relevant in the text.
ES051313073020SEA/SEA131330001
6-1
-------
6. FIVE-YEAR REVIEW PROCESS
TABLE 6-1
Palermo Documents Reviewed During the 2013 Five-Year Review
Palermo Wellfield Superfund Site, Tumwater, Washington
Author
Document
Date
EPA
Optimization Review, Palermo Wellfield Superfund Site, City of Tumwater, Thurston
County, Washington.
November 2011
EPA and WSDOT
Administrative Settlement Agreement and Order on Consent between U.S.
Environmental Protection Agency Region 10 and The Washington Department of
Transportation in the matter of Palermo Wellfield Superfund Site, Tumwater,
Washington. CERCLA Docket No. 10-2012-0149.
July 6, 2012
GeoEngineers
Draft Summary of Existing Information Report, Palermo Wellfield Superfund Site,
Tumwater, Washington.
January 2013
GeoEngineers
Sampling and Analysis Plan, Air Monitoring, Palermo Wellfield Superfund Site,
Tumwater, Washington
February 2013
GeoEngineers
Quality Assurance Project Plan, Air Monitoring, Palermo Wellfield Superfund Site,
Tumwater, Washington.
February 2013
GeoEngineers
Field Sampling Plan, Semiannual Groundwater Monitoring, Palermo Wellfield
Superfund Site, Tumwater, Washington.
February 2013
GeoEngineers
Amendment, Operation and Maintenance Manual, Subdrain System and Treatment
Lagoon, Palermo Wellfield Superfund Site, Tumwater, Washington.
February 2013
EPA = U.S. Environmental Protection Agency
WSDOT = Washington State Department of Transportation
6.4 Data Review
This section gives details about contaminant trends from all accessible data sources for the last five years.
From 2006 through 2012, Site monitoring typically consisted of collecting samples from 21 monitoring points. The
groundwater monitoring program was expanded in 2012 to include a total of 48 groundwater monitoring
locations (30 monitoring wells, 15 piezometers, and 3 City production wells) to address concerns about
contaminant concentrations within and outside of the approximated plume boundaries.
Periodic monitoring of the subdrain system and associated lagoon and outfalls was and continues to be part of the
long-term sampling program. In May 2012, groundwater seep samples were collected from four locations along
the base of the bluff at the western edge of the Palermo neighborhood.
The monitoring network, in its current configuration, indicates that PCE and TCE concentrations across the Site are
generally stable and, in most cases, decreasing slightly in overall concentration (see Figures 4-3, 4-4, and 4-5). The
exceptions are the continued high concentrations of TCE in the artesian wells within the Palermo neighborhood
(MW-ES-09 and MW-ES-10). Results for these wells suggest persistent contamination is present in the deeper
portion of the TCE plume. Additional wells screened in different portions of the aquifer are needed to better
assess conditions at depth within and upgradient of the neighborhood. Also, groundwater conditions in the
vicinity of the WSDOT source areas are generally unknown because existing wells in these areas do not appear to
be appropriately located or screened to intercept the plumes.
The key data trends for the Palermo Wellfield remedy include the following:
• PCE and TCE have not been detected in the groundwater seeps at the base of the bluff.
• PCE and TCE concentrations in municipal drinking water supplied from the Palermo Wellfield after treatment
continue to remain below laboratory reporting limits and the remediation goals established for these
constituents.
6-2
ES051313073020SEA/SEA131330001
-------
6. FIVE-YEAR REVIEW PROCESS
• Concentrations of TCE and PCE appear to be decreasing in groundwater at most sampling locations, but the
groundwater plume characterization at depth and in the vicinity of the WSDOT source areas is incomplete.
• PCE and TCE concentrations in water discharged from the treatment lagoon to the Deschutes River continue
to remain below their respective remediation goals.
• One round of air sampling to evaluate the vapor intrusion pathway for residents of the Palermo neighborhood
has been conducted. There are insufficient data to evaluate any trends.
6.5 2011 Optimization Evaluation Findings
As described previously, EPA Region 10 initiated an Optimization Evaluation composed of independent technical
experts to review the Palermo Site data including its CSM, cost effectiveness, closure strategies, and remedy
performance to date to help identify opportunities for improvements. The following represents the main findings
of the 2011 Optimization Evaluation (EPA, 2011b):
• Plume Understanding: The definition of the groundwater plume and plume capture by the subdrain and
wellfield is likely not complete.
• Vapor Intrusion Inhalation Risks: Vapor intrusion remains a concern and additional information is needed.
• Ongoing Sources of Contamination: There is insufficient information to determine if historic sources continue
to contribute to contamination.
• Groundwater Flow and Contaminant Distribution: The groundwater-flow pattern and contaminant
distribution are similar to those identified during the Rl. PCE concentrations remain above remediation goals
in MW-ES-04 and MW-ES-06, whereas TCE concentrations are more widely distributed and are significantly
higher.
• TCE Concentration Trends: Concentrations of TCE appear to be decreasing in groundwater at most sampling
locations, although TCE results at MW-UI and MW-ES-06 have shown both increasing and decreasing
concentrations since monitoring began in 2001.
• PCE Concentration Trends PCE concentrations are lower than those measured during the Rl and exhibit a
weak seasonality. PCE at MW-ES-06 has been steadily decreasing. Comparison of the long-term monitoring
data to the Rl data implies that the removal of residual PCE in soil by the SVE system, which operated from
March 1998 to June 2000, has resulted in decreased PCE concentrations in groundwater downgradient of
Southgate Dry Cleaners.
• Natural Biodegradation: There is little evidence for the occurrence of substantial biodegradation of PCE and
TCE during either the wet or dry season. Conditions remain generally unfavorable for substantial
biodegradation, as found during the Rl.
• Subdrain Contaminant Capture: Concentrations of TCE in piezometers located east of the subdrain exhibit
substantially higher concentrations on the order of two to three times those of the subdrain, indicating
subdrain capture of TCE may not be occurring.
• Long-term Monitoring Program: Further evaluation of the long-term monitoring program is needed to
determine the effectiveness of the selected remedy.
• Plume Configuration: Figures 4-6 and 4-7 show the TCE and PCE plume configurations, respectively, as
evaluated during the Optimization Evaluation. These plume maps do not reflect the current understanding of
COC source areas (that is, two separate WSDOT TCE sources west of Interstate 5) or plume extent (that is, the
PCE plume extends to the subdrain surrounding the Palermo neighborhood).
ES051313073020SEA/SEA131330001
6-3
-------
6. FIVE-YEAR REVIEW PROCESS
6.6 Summary of Site Inspection
The site inspection was conducted on April 24, 2013. Attendees included the following:
• Claire Hong, EPA Region 10
• Bernie Zavala, EPA Region 10
• Steve Craig, City of Tumwater
• Dan Smith, City of Tumwater
• Norm Payton, WSDOT
• Nick Rohrbach, GeoEngineers
• Marilyn Gauthier, CH2M HILL
• Patt O'Flaherty, CH2M HILL
The site inspection included visits to the wellhead treatment system, the subdrain system, the treatment lagoon
near the golf course, Southgate Dry Cleaners, and the area around the Palermo neighborhood. Key observations
made during the site inspection and discussions related to remedy operations are discussed in the following
sections. The site inspection checklist is included in Appendix C.
6.6.1 Wellhead Treatment System
A brief facility tour, historical review, and operations and maintenance discussion was led by Dan Smith, Water
Resources Program Manager and Steve Craig, Operations Manager for the City. The treatment system, well
construction, air stripper towers, and wet well were included in the discussions to better understand the entire
operation of the treatment system.
The treatment system appears to be in good working order and very well maintained. Because in the past, valves
in the stripper towers became frozen in the winter and were exposed to ambient air conditions, the City installed
a protective enclosure around the treatment system. The wellfield maintenance program consists of stripping
granular media with ascorbic acid to remove build up, cleaning the strippers, and testing for coliform bacteria.
6.6.2 Subdrain System and Treatment Lagoon
The City ensures maintenance is conducted on the treatment lagoon as specified by the O&M Plan. The Water
Resources Program Manager estimated that they have replaced two aerator pumps since the last Five-Year
Review and keep up with vegetation control. Overall he reported the lagoon system operates as designed. An
issue reported in the 2008 Five Year Review concerned the lack of a warning sign on the eastern side of the
treatment lagoon. Since then the sign has been replaced but it contains out-of-date EPA contact information.
6.6.3 Southgate Dry Cleaners
The land use at Southgate Dry Cleaners has not changed since the treatment system was decommissioned in
2000. Infiltration of precipitation to the area of residual soil contamination is still minimized by the presence of
buildings (Southgate Mall) and the paved parking lot. An investigation of the nature and extent of PCE in soil and
groundwater in the vicinity of Southgate Dry Cleaners is scheduled for the fall of 2013.
6.7 Summary of Interviews
Interview questionnaires were e-mailed to members of Ecology, WDOH, WSDOT, GeoEngineers, and City of
Tumwater the week of April 29. Completed interview questionnaires can be found in Appendix B. Persons
interviewed included:
• Steve Craig, City of Tumwater
• Dan Smith, City of Tumwater
• Guy Barrett, Ecology
• Barbara Trejo, WDOH
• Norm Payton, WSDOT
• Nick Rohrbach, GeoEngineers (Contractor to WSDOT)
6-4
ES051313073020SEA/SEA131330001
-------
6. FIVE-YEAR REVIEW PROCESS
6.7.1 City of Tumwater Personnel
City staff believes the groundwater treatment system at the Palermo Wellfield is working well based on the virtual
elimination of VOCs in the treated water distributed to the end users.
The City conducts weekly, monthly, semi-annual, annual, and bi-annual maintenance on the treatment system
according to the O&M manual. The City also conducts preventative maintenance based on historical experience.
Since the 2008 Five-Year Review, the City undertook a major system-wide retrofit to add 12.5% sodium
hypochlorite as a disinfectant. As part of this project, the air stripper towers and associated controls were
enclosed inside the treatment building, improving function, maintenance and security. Telemetry and control
standards have been upgraded to utilize current technologies. There have been no significant changes to O&M as
the routine maintenance has been optimized over the operation to date and is consistent and well understood by
maintenance staff. Some O&M difficulties that were identified are as follows:
• Access to the underdrain system for maintenance has become challenging, as the City does not own the
equipment necessary for maintenance. When access and/or maintenance is required, the City needs to rent
appropriate equipment. Emergency access/maintenance may be delayed.
• When maintaining the exhaust stacks, City staff have expressed concern that the vent doors open skyward. In
the event of rains, atmospheric settling or other "overhead" issues, could be a potential source of
contamination. City staff have recommended design revisions to include a vent opening horizontal to the
building to protect against potential overhead contamination.
6.7.1.1 Functionality of the Wellfield Treatment System
City staff believes the groundwater treatment system at the Palermo Wellfield is working well based on the virtual
elimination of VOCs in the treated water distributed to the end users.
The City conducts weekly, monthly, semi-annual, annual, and bi-annual maintenance on the treatment system
according to the O&M manual. The City also conducts preventative maintenance based on historical experience.
6.7.1.2 Groundwater Use
Both the City's Wellhead Protection Ordinance and the Aquifer Protection Overlay are enforced. These protect
groundwater and municipal water supply through prohibiting certain land uses within wellhead protection areas
and within city limits. Installation and operation of water supply wells is regulated by WDOH per Washington
Administrative Code (WAC) 246-290; water rights and well construction is regulated by Ecology per WAC 173-152
and WAC 173-160, respectively. When the City is informed a new well is being considered for installation, they
provide comments relative to well location. Well installation is coordinated through the City of Tumwater Public
Works - Water Resources Department. The City is also considering a prohibition of new well drilling city-wide.
Staff believes the prohibition could benefit the Site.
6.7.1.3 Complaints or Comments from the Public
The City occasionally receives questions from the general Palermo Valley community regarding operations at the
wellfield and water quality.
6.7.1.4 Other Comments and Concerns
The City would like to see the maintenance approach evaluated for more efficient routine maintenance of
underdrain system and safety improvements considered for routine maintenance of exhaust stacks on the air
stripper towers.
6.7.2 Washington State Department of Ecology
Consistent with the NCP, Ecology, in their role as a support agency, provides document reviews and other
assistance as requested by EPA on the Palermo Wellfield Superfund Site. Ecology has indicated that they will not
be providing comment for this Five-Year Review.
ES051313073020SEA/SEA131330001
6-5
-------
6. FIVE-YEAR REVIEW PROCESS
6.7.3 Washington State Department of Health
The WDOH has had a limited role in the project. In the past, by EPA's request, WDOH has been involved in the
vapor intrusion evaluation and has published its evaluation in health consultation reports. WDOH has also
summarized results of the evaluations in fact sheets and letters distributed to residences which participated in air
monitoring events. WDOH believes that overall the EPA is taking good steps to further characterize the site and
assess the potential health threat and has not received any complaints, violations, or other incidents requiring
their response.
6.7.3.1 Complaints or Comments from the Public
WDOH has received no comments, requests, or complaints regarding the remedy.
6.7.3.2 Other Comments and Concerns
WDOH has no additional comments, suggestions, or recommendations.
6.7.4 Washington State Department of Transportation
GeoEngineers prepared the interview responses provided in this section on behalf of WSDOT. Beginning in 2013,
GeoEngineers, on behalf of WSDOT, began performing the Semi-Annual Groundwater Monitoring and the
Subdrain and Treatment Lagoon O&M sampling for the Site. This work was previously performed by EPA with
assistance on vegetation management by the City of Tumwater. Their overall impression of the remedy is that the
treatment lagoon and wellfield air strippers appear to be meeting their intended remedial goals. However, the
subdrain system does not appear to be functioning as designed and its overall function will be further
investigated. GeoEngineers understands that a warning sign has been posted at the treatment lagoon facility and
a restrictive covenant for the Site was initiated (but not completed) since the previous Five-Year Review. The only
O&M difficulty they are aware of is the issues with flow rates in the subdrain system that will be further
investigated.
6.7.4.1 Complaints or Comments from the Public
WSDOT and GeoEngineers received feedback from the homeowners during the spring 2013 air sampling activities.
Some were unaware they lived within a Superfund site and others expressed anger that their health and property
values might be negatively impacted by contaminated groundwater. Most were happy that remedies were
currently in place and being actively monitored.
6.7.4.2 Other Comments and Concerns
WSDOT and GeoEngineers note that vegetation at the lagoon is particularly heavy and makes it extremely difficult
to locate the brass markers used to identify the transect locations. Currently, the markers are located by wooden
stakes that are easily removed. They would suggest re-establishing the brass markers with an extension or
permanent post that can be seen better about the ground surface. Otherwise they have no additional comments,
suggestions, or recommendations.
6-6
ES051313073020SEA/SEA131330001
-------
7. Technical Assessment
The Five-Year Review should determine whether the remedy at the Site is (or will be, when complete) protective
of human health and the environment. This technical assessment responds to three questions provided in the
Comprehensive Five-Year Review Guidance (EPA, 2001a) to assess the protectiveness of the remedy including:
• Question A - Is the remedy functioning as intended by the decision documents?
• Question B - Are the exposure assumptions, toxicity data, cleanup levels, and RAOs used at the time of the
remedy selection still valid?
• Question C - Has any other information come to light that could call into question the protectiveness of the
remedy?
The protectiveness of the different components of the Site remedy based on these three questions is discussed in
the following sections.
7.1 Is the Remedy Functioning as Intended by the Decision
Documents?
A review of documents, risk and exposure assumptions, ARARs, and the results of the Site inspection were used to
complete the Technical Assessment and answer Question A.
Although there has been no noteworthy change in the physical condition of the Site or foreseeable land use, there
is other information that calls into question remedy protectiveness. Previous five-year reviews, the ASAOC, recent
IRIS reassessments on TCE and PCE toxicity and health effects, the findings of the Optimization Evaluation, and the
more recent assessments of Site conditions relative to the CSM indicate the remedy is not fully functioning as
intended by the ROD. The following are major issues related to the limitations of the remedy as implemented to
date:
• There is insufficient information to determine if historic sources continue to be ongoing sources of
contamination. This is because residual soil contamination in the Southgate Dry Cleaners area may be acting
as an ongoing source of PCE contamination and because residual soil and groundwater contamination in the
WSDOT source areas have not been characterized.
• The cross-gradient and vertical extents of the PCE plume have not been defined.
• The vertical distribution of TCE in groundwater has not been characterized sufficiently to understand plume
migration under the influence of artesian conditions and pumping at the wellfield. Accordingly, plume capture
by the subdrain and wellfield may not be complete.
• Vapor intrusion remains a concern and additional information is needed.
The effectiveness of each remedy component as assessed by this evaluation is briefly noted below.
7.1.1 Wellhead Treatment System
The groundwater treatment component of the remedy (air stripping) is effective for the groundwater it extracts.
Treated water does not exceed the MCLs for TCE and PCE but concentrations of these COCs within the
groundwater plume continue to exceed them and are expected to for many decades.
7.1.2 Wellfield Capture Zone
Although it was assumed in the ROD that the existing wellfield was adequate to capture the entire TCE plume,
available pumping rate and concentration data may not support this assumption. In addition, the wellfield
operator is not under any contractual obligation to operate the wellfield to ensure complete plume capture into
the future.
ES051313073020SEA/SEA131330001
7-1
-------
7. TECHNICAL ASSESSMENT
The wellfield capture zone will be re-evaluated using additional data collected as part of the supplemental RI/FS
being conducted by WSDOT.
7.1.3 Plume Delineation and Long-Term Monitoring Adequacy
Previous Five-Year Review reviews and the Optimization Evaluation indicated that uncertainties exist as to
whether the existing monitoring network is adequate for plume characterization and delineation. The current
groundwater monitoring program being conducted by WSDOT has resulted in better delineation and
characterization of the contaminant plumes. Data from this program will be used to determine the appropriate
locations and screened intervals for new monitoring wells to better characterize the TCE plumes. Updated plume
dimensions and characteristics will be incorporated into the supplemental RI/FS and into an updated long-term
groundwater monitoring program. In addition, the PCE investigation at the Southgate Dry Cleaners portion of the
Site will provide better delineation of the PCE plume and better understanding of its interaction with the TCE
plume in this area.
7.1.4 Subdrain System and Treatment Lagoon
Based on recent subdrain and treatment lagoon status reports (URS Greiner, 2011; Parametrix, 2012a,b), the
subdrain system has been successful in achieving performance criteria required by the ROD in the central portion
of Rainier Avenue but not at its south end or, occasionally, at the north end of the street due to artesian
conditions. As a result, groundwater shallower than the required three feet occurs beneath some homes. This
increases the risk of exposure to vapor intrusion that may exceed the indoor air goals established by the ROD
(1.46 ng/m3 TCE and 4.38 ng/m3 PCE). The subdrain is also not effective in eliminating the surface seeps along the
base of the bluff as anticipated. There may also be other instances of water in crawl spaces.
The treatment lagoon has been meeting performance criteria in reducing TCE and PCE concentrations. TCE and
PCE are occasionally detected in the receiving water outfall but do not exceed the ROD-established water quality
limit.
7.1.5 Soil Vapor Extraction System at Southgate Dry Cleaners
An SVE system was operated from 1998 to 2000 at the Southgate Dry Cleaners location to reduce the levels of
PCE. The SVE system functioned in accordance with the ROD but did not fully achieve the remediation goal for PCE
in soil. As a result, a deed restriction was required to ensure the asphalt parking lot functioned as a barrier. The
results of a 2008 title search indicated that a deed restriction was not in place at that time. Recent (March 2013)
discussions with the Thurston County Auditor's office indicate the deed restriction has still not been recorded.
7.1.6 Notification of Contaminated Groundwater
The public notification of contaminated groundwater was completed in accordance with the ROD. A fact sheet
specifically discussing the contaminated groundwater was mailed directly to well drillers and property owners in
the area. In February 2013, EPA visited residents of the Palermo neighborhood to obtain permission to enter
properties to conduct new investigations. Although not required by the ROD, WSDOT has sent fact sheets to
Palermo neighborhood residents concerning the 2013 air monitoring investigation required by the ASAOC (EPA
and WSDOT, 2012).
7.2 Are the Exposure Assumptions, Toxicity Data, Cleanup
Levels, and RAOs Used at the Time of Remedy Selection
Still Valid?
An evaluation of the effects of significant changes in exposure assumptions, toxicity data, cleanup levels, and
RAOs used in the ROD was conducted in the 2013 Five-Year Review. Some of changes described below that have
occurred since the last Five-Year Review may impact the protectiveness of the remedy. These changes need to be
evaluated in concert with the results of ongoing air and groundwater investigations. If the monitoring results
determine there is no meaningful change to RAOS, routes of exposure, and/or are within the CERCLA acceptable
risk range, the remedy may continue to be effective and protective. Alternatively, if monitoring findings suggest
7-2
ES051313073020SEA/SEA131330001
-------
7. TECHNICAL ASSESSMENT
the remedy is not protective of human health and/or the environment, new or modified requirements may need
to be considered in a ROD Amendment or Explanation of Significant Difference (ESD).
Changes since the 2008 Five-Year Review to each category of Question B are discussed below.
7.2.1 Exposure Assumptions
The pathways and routes of exposure that were identified in the ROD and evaluated in the original Risk
Assessment have not changed. Supplemental RI/FS results will be used to assess if the ROD-established remedies
can achieve RAOs or if changes to the remedy action may be required. For example, updated monitoring of
residential crawl space and indoor air conditions is being conducted concurrent with the preparation of this 2013
Five-Year Review. The monitoring results will be used to assess if potential vapor intrusion of TCE or PCE from
groundwater and crawl spaces into residences exceed the ROD-established cleanup goals for indoor air. If vapor
intrusion exceedances are detected, then a reassessment of human health risk may be necessary.
7.2.2 Toxicity Data
The groundwater cleanup levels selected in the ROD for TCE and PCE were the Federal Drinking Water Standards
MCL of 5.0 ng/L, respectively. In addition to MCLs, Model Toxics Control Act (MTCA) Method B groundwater
cleanup standards (WAC 173-340-720) were identified as ARARs in the ROD. Based on MTCA Method B and the
oral cancer slope factor of 0.011 per mg/kg-day in use at the time, the risk at the MCL for TCE equated to an
excess cancer risk of 1.26 x 10-6, which was consistent with the MTCA range (WAC 173-340-720 (7)(b)).
Consequently, the federal MCL was deemed to be protective and was selected as the groundwater cleanup
standard for the wellfield. The ROD-specified remediation goals for TCE and PCE in surface water and shallow
groundwater to protect against vapor intrusion of indoor air were calculated in the FS (URS, 1999b) using the
Johnson and Ettinger model assuming an acceptable indoor air inhalation risk level (10-6). The calculated
groundwater remediation goals for protection of indoor air using the Johnson and Ettinger model were 0.27 ng/L
and 0.05 ng/L for TCE and PCE, respectively. As stated in the ROD:
Because of the conservative nature of the modeling conducted to estimate indoor air concentrations of
TCE and PCE, and because the resulting remediation goals for crawlspace water are two orders of
magnitude below drinking water standards, EPA will review the appropriateness of these remediation
goals and the methodology to assess compliance with the indoor air cleanup levels during the Five-Year
Review.
Since the 2008 Five-Year Review, EPA has published updated toxicity information in Final Health Assessments for
TCE (EPA, 2011c) and PCE (EPA, 2012c). TCE is now considered a more potent carcinogen and PCE is now
considered slightly less toxic from a carcinogenic perspective, but more toxic for non-carcinogenic effects. Each
reassessment is discussed in more detail below.
7.2.2.1 TCE Final Health Assessment Summary and Region 10 Recommendations
Updated toxicological information for TCE was released in support of EPA's Integrated Risk Information System
(IRIS) on September 28, 2011 (EPA, 2011c). EPA concluded that "based on the available human epidemiologic data
and experimental and mechanistic studies, TCE poses a potential human health hazard for noncancer toxicity to
the CNS, the kidney, the liver, the immune system, the male reproductive system, and the developing fetus." TCE
was also determined to be "carcinogenic to humans based on convincing evidence of a causal association
between TCE exposure in humans and kidney cancer." EPA now classifies TCE as carcinogenic to humans through
all routes of exposure. Early life exposures may pose increased risks. Since TCE is considered carcinogenic via a
mutagenic mode of action for kidney cancer (one of the three cancer outcomes that the updated oral and
inhalation potency values are based on), IRIS provides for the use of age-dependent adjustment factors when
early-life exposure is known or a possibility. For noncancer effects, one particular concern is possible fetal cardiac
malformations that may occur during early fetal development.
The assessment established the following health benchmarks for noncancer effects by the oral and inhalation
routes of exposure:
• Reference Dose for Chronic Oral Exposure ("RfD") = 5 x 10"4 mg/kg/day
ES051313073020SEA/SEA131330001
7-3
-------
7. TECHNICAL ASSESSMENT
• Reference Concentration for Chronic Inhalation Exposure ("RfC") = 0.002 mg/m3 (2 ng/m3)
• Quantitative Estimate of Carcinogenic Risk from Oral Exposure Oral Slope Factor = 5 x 10"2 per mg/kg-day
• Quantitative Estimate of Carcinogenic Risk from Inhalation Exposure Inhalation Unit Risk = 4.1 xlO"6
per ng/m3.
EPA may use the revised toxicity assessments to establish new cleanup standards and improve cleanup methods
at contaminated waste sites. As a result of the updated TCE toxicological assessment, EPA Region 10 distributed a
memorandum providing recommendations to regional staff involved with investigation or cleanup of Resource
Conservation and Recovery Act or CERCLA sites (EPA, 2012d). Region 10 recommends that the values now
available on IRIS for chronic TCE exposures be utilized for risk assessments in Region 10. The Agency also stresses
that media concentrations of TCE based on chronic exposures, noncancer endpoints and hazard quotients (HQs)
of 1 be given special attention, as the HQ may be exceeded at media concentrations that are calculated to
represent individual excess lifetime cancer risks of 1 x 10~4 and 1 x 10~5.
Region 10 recommends a health protective TCE concentration for residential indoor air settings that will yield a
noncancer limit of 2.1 ng/m3 to achieve a HQ of 1. For short term average exposure concerns to protect against
fetal cardiac malformation Region 10 adjusted the exposure frequency to derive a calculated concentration of 2.0
Hg/m3 represents an average concentration over a 21-day period of time.3
7.2.2.2 PCE Final Health Assessment
EPA also posted the Final Health Assessment for PCE to the IRIS Database in February 2012 (EPA, 2012c). The
assessment replaces the 1988 IRIS assessment for PCE and, for the first time, includes a hazard characterization
for cancer effects. EPA has calculated a chronic inhalation reference concentration (RfC; the estimate of a daily
human exposure that is likely to be without an appreciable risk of deleterious non-cancer effects during a lifetime)
of 40 ng/m3 based on the neurotoxicological effects seen in exposed workers. The Agency has also developed a
chronic oral reference dose (RfD) of 6 ng/kg bw/day, which involved extrapolation from the human inhalation
data. The final assessment characterizes PCE as "likely to be carcinogenic to humans" by all routes of exposure.
As a result of the Final Health Assessment for PCE, EPA may use the revised toxicity assessments to establish new
cleanup standards and improve cleanup methods at contaminated waste sites.
7.2.3 Are There Changes in Standards to Be Considered?
ARARs identified in the 1999 ROD were reviewed for changes that could affect the assessment of whether the
remedy remains protective. Table 7-1 identifies the current status of key ARARs listed in the ROD, including those
that have changed or are currently being updated since the 2008 Five-Year Review (Parametrix, 2008). Of these
ARARs, the most significant change appears to be updated MTCA media cleanup levels for TCE and PCE. In 2012,
Ecology updated its Cleanup Levels and Risk Calculation (CLARC) on-line database formula values to reflect the
new IRIS toxicity information for TCE and PCE. These calculations serve to revise MTCA Method B cleanup values
for groundwater, surface water, air, and soil (including soil to groundwater leaching pathway) based on the recent
changes in IRIS.
It is important to note that whenever a change to the cleanup standard occurs, such as the recent MTCA update
to TCE and PCE cleanup levels, it is necessary to consider the change in context with the protectiveness of the
remedy. In the preamble to the final NCP, EPA states in its policy that it will not reopen remedy selection decisions
contained in RODs (i.e., ARARs are normally frozen at the time of ROD signature) unless a new or modified
requirement calls into question the protectiveness of the selected remedy (55 Federal Register 8757 ). If the
change in the standard is more stringent, it may be prudent to evaluate and compare the old and new standards
and associated risks given current site conditions. The results of investigations to be conducted by WSDOT and
EPA over the next 4 years will be evaluated to identify potential changes in media concentrations, increased
3 Note that the ROD established a remedial goal of 1.46 ^g/m3, which, if achieved, is compliant with Region 10's recent recommendations.
7-4
ES051313073020SEA/SEA131330001
-------
7. TECHNICAL ASSESSMENT
exposure pathways, or higher inhalation risks, all of which may affect the protectiveness of the ROD-established
remedy. If it is concluded that the current remedy is not protective of human health and/or the environment,
then EPA can decide to alter the remedy by either a ROD Amendment or an ESD.
TABLE 7-1
Key Applicable or Relevant and Appropriate Requirements Status
Palermo Wellfield Superfund Site, Tumwater, Washington
Regulation
Change
Explanation
Washington State primary MCLs for
groundwater
Unchanged
The MCLs for VOCs remain the same as the Federal MCLs (40 CFR 141.61(a)).
MTCA cleanup standards in WAC 173-
340-720 for groundwater
Changed
Washington State (Ecology) updated pre-calculated Method B media cleanup
levels to reflect new EPA IRIS toxicity values for TCE and PCE.
MTCA cleanup standards in WAC 173-
340-740 for soil
Changed
Washington State (Ecology) updated pre-calculated Method B media cleanup
levels to reflect new EPA IRIS toxicity values for TCE and PCE.
MTCA cleanup standards in WAC 173-
340-747 protective of potable
groundwater for soil leaching pathway
Changed
Washington State (Ecology) updated pre-calculated Method B media cleanup
levels to reflect new EPA IRIS toxicity values for TCE and PCE.
MTCA cleanup standards in WAC 173-
340-750 for air
Changed
Washington State (Ecology) updated pre-calculated Method B media cleanup
levels to reflect new EPA IRIS toxicity values for TCE and PCE.
MTCA cleanup standards in WAC 173-
340-730 for surface water
Changed
Washington State (Ecology) updated pre-calculated Method B media cleanup
levels to reflect new EPA IRIS toxicity values for TCE and PCE.
National Toxics Rule water quality
standards for surface water
Unchanged
Human health-based water quality criteria used by Washington State are those
contained in 40 CFR 131.36 (known as the National Toxics Rule). However in
September 2012, Ecology began formal rule-making activities to adopt new
human health-based water quality standards for toxics.
Washington Clean Air Act and
Implementing regulations (WAC 173-
460-150)
Changed
Revised in 2008, but changes do not affect the remedy unless new or modified
emission units are installed; then only substantive requirements of these
regulations would apply to emission units.
CFR = Code of Federal Regulations
Ecology = Washington State Department of Ecology
EPA = U.S. Environmental Protection Agency
IRIS = Integrated Risk Information System
MCL = maximum contaminant level
MTCA = Model Toxics Control Act
PCE = tetrachloroethylene
TCE = trichloroethylene
VOC = volatile organic compound
WAC = Washington Administrative Code
The 1999 ROD determined that MTCA Method B cleanup levels for air, groundwater, surface water, and soil are
ARARs for the Palermo Wellfield Site. The new CLARC calculations reflect early life susceptibility for kidney cancer
only and apply age-dependent adjustment factors when calculating the associated Method B formula cleanup
values. MTCA also applies formula-based cleanup level values for the three types of cancer that are calculated
separately. It is important to note that Washington State's formula calculations differ from EPA's methods. The
harmonic mean of the three values is calculated to derive the final cleanup level. For noncancer adverse health
effects, MTCA uses the new IRIS values to calculate cleanup level values using the MTCA equations. The new
MTCA Method B cleanup levels calculated in CLARC for TCE are summarized and compared to the 1999 ROD-
established cleanup levels in Table 7-2. Table 7-3 presents the 2012 EPA Region 10 recommended media limits for
TCE for comparison to updated MTCA cleanup levels.
ES051313073020SEA/SEA131330001
7-5
-------
7. TECHNICAL ASSESSMENT
TABLE 7-2
TCE Cleanup Level Comparison
Palermo Wellfield Superfund Site, Tumwater, Washington
Medium
2012 MTCA
Method Ba'b
1999 ROD
Cleanup Level
1999 ROD Cleanup Level Basis
Drinking Water (potable groundwater)
4 pg/L
5.0 pg/L
Federal MCL and WAC 173-340-720
Soil (Ingestion)
11 mg/kg
NA
ROD selected soil cleanup level based on protection of
groundwater, therefore ingestion was not considered.
Soil (Leaching)
0.03 mg/kg
0.398 mg/kg
WAC 173-340-740
Air
0.37 |ig/mB
1.46 pg/m3
WAC 173-340-750
Surface Water
2.5 or 30 |ig/Lc
2.7 pg/L
National Toxics Rule, WAC 173-340-730
a Ecology (2012).
b Updated MTCA cleanup level concentrations are not applicable to the Site unless the current ROD-selected remedy is determined to
be not protective. If it is concluded that the current remedy is not protective of human health and/or the environment, then EPA can
decide if the remedy (including ARAR revisions) needs to be altered by either a ROD Amendment or an ESD.
c If drinking the surface water is identified as a beneficial use under WAC 173-340-201A, then use 2.5 pg/L as the cleanup level.
Otherwise, use 30 pg/L.
Hg/L = micrograms per liter
Hg/m3 = micrograms per cubic meter
ARAR = applicable or Relevant and Appropriate Requirement
ESD = Explanation of Significant Difference
MCL = maximum contaminant level
mg/kg = milligrams per kilogram
MTCA = Model Toxics Control Act
NA = not applicable
ROD = Record of Decision
WAC = Washington Administrative Code
TABLE 7-3
EPA Region 10 Recommended Residential Media Concentrations of TCE
Palermo Wellfield Superfund Site, Tumwater, Washington
Medium
Cancer Risk
Chronic Non-cancer
Risk
Short-term Non-cancer
Risk
Drinking Water
0.44 |jg/L
0.26 |J.g/L
3.4 Mg/L
Soil
0.91 mg/kg
0.44 mg/kg
4.7 mg/kg
Air
0.43 Mg/m3
0.21 |ag/m3
2.0 Mg/m3
Source: EPA (2012c).
Hg/L = micrograms per liter
Hg/m3 = micrograms per cubic meter
mg/kg = milligrams per kilogram
TCE = trichloroethylene
In response to the new toxicity values provided in IRIS for PCE, Ecology has also calculated new MTCA Method B
cleanup levels for groundwater, surface water, soil (including the soil leaching pathway), and air. Because the
current MCL (5 ng/L (ppb) does not exceed a HQ of 1 or a cancer risk of 1 x 10-5, it continues to be used for the
groundwater cleanup level. Updated (2012) MTCA Method B cleanup levels for PCE are presented and compared
to the 1999 ROD-established cleanup levels in Table 7-4.
7-6
ES051313073020SEA/SEA131330001
-------
7. TECHNICAL ASSESSMENT
TABLE 7-4
PCE Cleanup Level Comparison
Palermo Wellfield Superfund Site, Tumwater, Washington
Medium
2012 MTCA
Method Ba,b
1999 ROD
Cleanup Level
1999 ROD Cleanup Level Basis
Drinking Water (potable
groundwater)
5 Hg/L
Federal MCL and WAC 173-340-720
Soil (Ingestion)
480 mg/kg
NA
ROD selected soil cleanup level based on protection of
groundwater, therefore ingestion was not considered.
Soil (Leaching)
0.05 mg/kg
0.0858 mg/kg
WAC 173-340-740
Air
9.6 pg/m3
4.38 Mg/m3
WAC 173-340-750
Surface Water
0.69 or 3.3 |ig/Lc
0.8 |jg/L
National Toxics Rule, WAC 173-340-730
a Ecology (2012).
b Updated MTCA cleanup level concentrations are not applicable to the Site unless the current ROD-selected remedy is
determined to be not protective. If it is concluded that the current remedy is not protective of human health and/or the
environment, then EPA can decide if the remedy (including ARAR revisions) needs to be altered by either a ROD Amendment
or an ESD.
c If drinking the surface water is identified as a beneficial use under WAC 173-340-201A, then use 0.69 pg/L as the cleanup
level. Otherwise, use 3.3 pg/L.
Hg/L = micrograms per liter
Hg/m3 = micrograms per cubic meter
ARAR = applicable or Relevant and Appropriate Requirement
ESD = Explanation of Significant Difference
MCL = maximum contaminant level
mg/kg = milligrams per kilogram
MTCA = Model Toxics Control Act
NA = not applicable
ROD = Record of Decision
WAC = Washington Administrative Code
The 2013 Five-Year Review establishes several recommendations to better characterize contaminant transport
and potential exposure pathways at the Site. Additionally, cleanup levels should be evaluated to determine if they
are protective based on the new toxicity information for PCE and TCE. If an exposure pathway is complete, then
more stringent cleanup standards may be warranted.
7.2.4 RAOs and Progress of Remedy
RAOs have not changed, but the remedy is not progressing as expected. The ROD predicted that drinking water
standards would be achieved within 5 to 30 years. In contrast, the Optimization Evaluation anticipates several
decades or more may be required. Predicting treatment time is made worse because the definition of the TCE
groundwater plume is incomplete and because plume capture by the subdrain and wellfield is likely not complete.
The potential for vapor intrusion remains a concern, and additional information is needed about potential
exposure risks. Finally, natural attenuation remains an unlikely treatment for significantly reducing TCE and PCE
concentrations in groundwater, as anticipated in the ROD.
7.2.5 Validity of Assumptions for Remedy Components
This section discusses the validity of the ROD assumptions related to exposure, toxicity data, cleanup levels, and
RAOs for each of the remedy components.
7.2.5.1 Wellhead Treatment System
With the exception of TCE and PCE toxicity factors, ROD exposure assumptions, cleanup levels, and RAOs related
to this remedy component are still valid. However, operation of the Palermo Wellfield may not be completely
capturing contaminated groundwater as assumed by the ROD. Thus exposure assumptions related to this remedy
component may need to be revised based on the results of the supplemental RI/FS.
ES051313073020SEA/SEA131330001
7-7
-------
7. TECHNICAL ASSESSMENT
7.2.5.2 Subdrain System and Treatment Lagoon
With exception of the TCE and PCE toxicity factors, the ROD exposure assumptions, cleanup levels, and RAOs
related to this remedy component are still valid. Plume capture by the subdrain (and wellfield) is likely not
complete.
7.2.5.3 Soil Vapor Extraction System at Southgate Dry Cleaners
The ROD exposure assumptions, cleanup levels, and RAOs applicable to this remedy component are still valid.
Toxicity information has been revised as discussed above. Exposure assumptions related to this remedy
component may need to be revised based on the results of the site investigation.
7.2.5.4 Long-Term Groundwater Monitoring
The ROD exposure assumptions, cleanup levels, and RAOs applicable to this remedy component are still valid.
Toxicity information has been revised as discussed above. Exposure assumptions related to this remedy
component may need to be revised based on the results of the supplemental RI/FS.
7.2.5.5 Institutional Control Assessment
An assessment of institutional controls was conducted in accordance with draft Supplement to the
Comprehensive Five-Year Review Guidance: Evaluation of Institutional Controls (EPA, 2011e). The results of the
2013 Five-Year Review show that the restriction required by the ROD has yet to be recorded.
7.3 Has Any Other Information Come to Light That Could Call
into Question the Protectiveness of the Remedy
Aside from the conclusions of the 2008 Five-Year Review (Parametrix, 2008), the recommendations of the
Optimization Evaluation, and the findings of the ASAOC, there is no other information known of that has come to
light since the last Five-Year Review that could call into question the protectiveness of the remedy.
7.4 Technical Assessment Summary
According to the data reviewed, the site inspection, and the interviews, the remedy is not completely functioning
as intended.
7.4.1 Wellhead Treatment System
The wellhead treatment system is functioning as intended by the ROD. But plume capture by the configuration of
the existing wellfield may be inadequate.
7.4.2 Subdrain System and Treatment Lagoon
The subdrain system and treatment lagoon are only partly functioning as envisioned by the ROD. Treated water
discharges to the Deschutes River meet the ROD-established cleanup level. But reduction of groundwater
elevations to 3 feet bgs has not been met for all residences. TCE-impacted groundwater appears to not be
captured by the subdrain and is upwelling within the neighborhood because of artesian conditions at the base of
the bluff.
An evaluation of additional air and groundwater sampling results is needed to conclude that this remedy is
protective of human health and the environment.
7.4.3 Soil Vapor Extraction System at Southgate Dry Cleaners
The SVE system at Southgate Dry Cleaners functioned in accordance with the ROD. Confirmation soil samples
indicated that some PCE remains in soil at concentrations exceeding the remediation goal. Because of this, the
ROD requires a deed restriction. In addition, continued detections of PCE in groundwater suggest that the residual
PCE in soil may act as a continuing source of groundwater contamination and as a potential source of vapor
intrusion into nearby commercial buildings. The residual contamination is currently under investigation by EPA.
7-8
ES051313073020SEA/SEA131330001
-------
7. TECHNICAL ASSESSMENT
7.4.4 Long-Term Groundwater Monitoring
Long-term groundwater monitoring is functioning as intended by the ROD, and in the short term, is protective.
However, the existing groundwater monitoring system may be inadequate because it may not be optimized for
actual hydrogeologic conditions. There is the potential that gaps in the monitoring well network may result in
contaminated groundwater not being captured by the Palermo Wellfield nor being detected in downgradient
wells. An evaluation of additional groundwater monitoring data is needed to conclude that this remedy is
protective of human health and the environment.
Natural attenuation is not a significant process at the Site as assumed in the ROD. Therefore, the restoration of
groundwater will not occur within five to thirty years as predicted by the ROD.
7.4.5 Public Notification of Contaminated Groundwater
The public notification of contaminated groundwater was completed in accordance with the ROD. In February
2013, EPA and WSDOT conducted door-to-door visits with residents of the Palermo neighborhood to request
access to their properties for continuing investigative work.
Although not required by the ROD, the 2013 investigation of residential indoor air and crawl spaces in the
Palermo neighborhood was explained in notices provided and distributed by WSDOT.
ES051313073020SEA/SEA131330001
7-9
-------
-------
8. Issues
The following issues were identified during the 2013 Five-Year Review that appear to have the potential to impact
the protectiveness of the remedy, as shown in Table 8-1.
TABLE 8-1
Issues Identified During 2013 Five-Year Review
Palermo Wellfield Superfund site, Tumwater, Washington
Affects Protectiveness?
Issue # Issue Current Future
1
The potential risks from vapor intrusion in the Palermo neighborhood remain a concern.
Yes
Yes
2
The effectiveness of the Palermo Wellfield System at capturing and controlling contaminant
migration requires further evaluation.
Yes
Yes
3
TCE and PCE groundwater plumes need better definition; characterization of the soil and
groundwater is not complete at the three source areas, and plume capture by the subdrain
and wellfield is likely not complete.
No
Yes
4
TCE in soil at the former and current WSDOT facilities and PCE in soil at Southgate Dry
Cleaners may continue to be sources of contamination to groundwater because it is unknown
if significant masses remain in vadose zone soil or in shallow groundwater. Institutional
controls, such as a deed restriction for the Southgate Dry Cleaners property, may be needed if
investigations determine that residual contamination is present and poses a potential human
health risk.
No
Yes
5
The long-term groundwater monitoring system requires further evaluation.
Yes
Yes
6
New toxicity information on TCE and PCE exists that may affect the protectiveness of the
remedy.
No
Yes
PCE = tetrachloroethylene
TCE = trichloroethylene
WSDOT = Washington State Department of Transportation
ES051313073020SEA/SEA131330001
-------
-------
9. Recommendations and Follow-Up Actions
Table 9-1 lists the recommendations and follow-up actions for each of the issues listed in Table 8-1, together with
other recommendations that do not necessarily affect the protectiveness of the remedy.
TABLE 9-1
Recommendations and Follow-up Actions
Palermo Wellfield Superfund Site, Tumwater, Washington
Affects Protectiveness
Responsible Milestone
# Recommendation/Follow-up Action Party Date Current Future
1
Complete evaluation of groundwater-to-indoor-air
pathway and conduct sufficient air monitoring to
determine whether TCE and PCE vapor concentrations in
indoor air remain below the remediation goals of
1.46 |ag/m3 and 4.38 |ig/m3, respectively.
WSDOT
7/31/15
Yes
Yes
2
Conduct a three-dimensional capture zone analysis to
assess whether the contaminant plumes are being fully
captured by the operation of the Palermo Wellfield.
WSDOT
12/1/15
Yes
Yes
3
Evaluate the lateral and vertical distribution of
contaminants within the aquifer.
EPA/
WSDOT
12/1/16
No
Yes
4
Complete investigations at known and potential source
areas and determine if institutional controls, such as a
deed restriction for the Southgate Dry Cleaners property,
are needed.
EPA/
WSDOT
10/3/17
No
Yes
5
Based on Actions 2 through 4, determine whether the
current groundwater monitoring well network is adequate
to monitor plume migration and gauge effectiveness of
remediation. Install additional monitoring wells, if
necessary.
WSDOT
8/31/17
Yes
Yes
6
Determine whether cleanup levels need to be modified
based on new toxicity information on TCE and PCE.
EPA
3/30/16
No
Yes
iag/m3 = micrograms per cubic meter
EPA = U.S. Environmental Protection Agency
PCE = tetrachloroethylene
TCE = trichloroethylene
WSDOT = Washington State Department of Transportation
If Actions 1 through 5 indicate that the remedy selected by the 1999 ROD is not protective, then, based on EPA's
judgment, the remedy will be modified through an ESD or as an Amendment to the ROD. This decision is
anticipated by November 30, 2019.
ES051313073020SEA/SEA131330001
9-1
-------
-------
10. Protectiveness Statement
At this time, a protectiveness determination of the remedy at Palermo Wellfield Superfund Site cannot be made
until further information is obtained. The actions necessary to make the protectiveness determination are listed,
with anticipated completion dates, in Table 9-1. It is expected that these actions will take approximately 4 years to
complete.
Other Comments
Human Exposure Environmental Indicator Status for the Site remains "Insufficient Data to Make a
Determination" until ongoing site investigations are complete.
Groundwater Migration Environmental Indicator Status for the Site remains "Insufficient Data to Make a
Determination" until ongoing site investigations are complete.
ES051313073020SEA/SEA131330001
10-1
-------
-------
11. Next Review
The next Five-Year Review for the Palermo Wellfield Superfund Site is scheduled to be completed 5 years from the
date of this review, September 30, 2018.
ES051313073020SEA/SEA131330001
-------
-------
12. References
Doucette, W.J., A.J. Hall, and K.A. Gorder. 2010. "Emissions of 1,2-Dichloroethane from Holiday Decorations as a
Source of Indoor Air Contamination." Ground Water Monitoring & Remediation 30, No. 1/Winter 2010.
GeoEngineers. 2013a. Draft Summary of Existing Information Report, Palermo Wellfield Superfund Site, Tumwater,
Washington. January.
GeoEngineers. 2013b. Sampling and Analysis Plan, Air Monitoring, Palermo Wellfield Superfund Site, Tumwater,
Washington. February.
GeoEngineers. 2013c. Quality Assurance Project Plan, Air Monitoring, Palermo Wellfield Superfund Site,
Tumwater, Washington. February.
GeoEngineers. 2013d. Field Sampling Plan, Semiannual Groundwater Monitoring, Palermo Wellfield Superfund
Site, Tumwater, Washington. February.
GeoEngineers. 2013e. Amendment, Operation and Maintenance Manual, Subdrain System and Treatment Lagoon,
Palermo Wellfield Superfund Site, Tumwater, Washington. February.
Kraemer S.R., Haitjema H.M., Kelson V.A. 2007. Working with WhAEM2000: Capture Zone Delineation for a City
Wellfield in a Valley Fill Glacial Outwash Aquifer Supporting Wellhead Protection. Office of Research and
Development, U.S. Environmental Protection Agency, Washington, DC.
Kurtz, P., E.M. Wolfe, A.K. Woodland, and S.J. Foster. 2010. "Evidence for Increasing Indoor Sources of
1,2-Dichloroethane Since 2004 at Two Colorado Residential Vapor Intrusion Sites." Ground Water Monitoring &
Remediation 30, No. 3/Summer 2010.
Parametrix. 2007. Draft Groundwater Long Term Monitoring 2006 Annual Report, Palermo Wellfield Superfund
Site, Tumwater, Washington. Prepared for U.S. Environmental Protection Agency, Region 10, Seattle, Washington.
Parametrix. 2008. Final Second Five-Year Review Report, Palermo Wellfield Superfund Site, Tumwater,
Washington. Prepared by Parametrix, Bremerton, Washington. September.
Parametrix. 2012a. Groundwater Long-term Monitoring Report. Prepared for U.S. Environmental Protection
Agency, Region 10, Seattle, Washington.
Parametrix. 2012b. Final Late Spring 2012 Groundwater Long-term Monitoring Report. Prepared for U.S.
Environmental Protection Agency, Region 10, Seattle, Washington.
U.S. Environmental Protection Agency (EPA). 1999. Final Record of Decision, Palermo Wellfield, City of Tumwater,
Thurston County, Washington. EPA/ROD/R10-00/049. Region 10, Seattle, Washington. October.
U.S. Environmental Protection Agency (EPA). 2001a. Comprehensive Five-Year Review Guidance. Office of Solid
Waste and Emergency Response (OSWER) No. 9355.7-03B-P; EPA 540-R-01-007. Available at
http://www.epa.gov/superfund/accomp/5year/guidance.pdf. Accessed May 2013. June.
U.S. Environmental Protection Agency (EPA). 2001b. Preliminary Closeout Report, Palermo Wellfield Superfund
Site, Tumwater, Washington. Prepared by EPA Region 10 and signed by Michael Gearhead, Director, Office of
Environmental Cleanup, Region 10, Seattle, Washington. February 22.
U.S. Environmental Protection Agency (EPA). 2011a. Five-Year Review Summary Form. Available at
http://www.epa.gov/superfund/cleanup/postconstruction/5vr reviewform.htm. Accessed May 2012.
U.S. Environmental Protection Agency (EPA). 2011b. Optimization Evaluation, Palermo Wellfield Superfund Site,
City of Tumwater, Thurston County, Washington. Office of Solid Waste and Emergency Response. November.
ES051313073020SEA/SEA131330001
12-1
-------
12. REFERENCES
U.S. Environmental Protection Agency (EPA). 2011c. Toxicological Review ofTrichloroethylene (CAS No. 79-01-6) In
Support of Summary Information on the Integrated Risk Information System (IRIS). EPA/635/R-09/011F.
September.
U.S. Environmental Protection Agency (EPA). 2011d. Fact Sheet: Basic Questions and Answers for the Drinking
Water Strategy Contaminant Groups Effort. EPA Number 815F11002. Available at
http://vosemite.epa.gov/water/owrccatalog.nsf/epanumber/443afa68fcl4bdcc5852578300058a47f7opendocume
nt. Accessed April 2013.
U.S. Environmental Protection Agency (EPA). 2011e. Recommended Evaluation of Institutional Controls:
Supplement to the Comprehensive Five-Year Review Guidance. OSWER Directive 9355.7-18. Available at
http://www.epa.gov/superfund/policy/ic/guide/641333.pdf. Accessed April 2012.
U.S. Environmental Protection Agency (EPA). 2012a. Assessing Protectiveness at Sites for Vapor Intrusion.
Available at http://www.epa.gov/superfund/fiveyearreview/. Accessed June 2012. November.
U.S. Environmental Protection Agency (EPA). 2012b. Clarifying the Use of Protectiveness Determinations for
CERCLA Five-Year-Reviews. Office of Solid Waste and Emergency Response (OSWER) 9200.2-84. Available at
http://www.epa.gov/superfund/fivevearreview/. Accessed June 2012. September.
U.S. Environmental Protection Agency (EPA). 2012c. Toxicological Review of Tetrachloroethylene
(Perchloroethylene) (CAS No. 127-18-4) In Support of Summary Information on the Integrated Risk Information
System (IRIS). EPA/635/R-09/011F. February.
U.S. Environmental Protection Agency (EPA). 2012d. OEA Recommendations Regarding Trichloroethylene Toxicity
in Human Health Risk Assessments. Memorandum from J. Kelly, Director, Office of Environmental Assessment, to
R. Albright, Director, Office of Environmental Cleanup. EPA Region 10, Seattle, Washington. December 13.
U.S. Environmental Protection Agency and Washington State Department of Transportation (EPA and WSDOT).
2012. Administrative Settlement Agreement and Order of Consent between U.S. Environmental Protection Agency
Region 10 and The Washington Department of Transportation in the matter of Palermo Wellfield Superfund Site,
Tumwater, Washington. CERCLA Docket No. 10-2012-0149. EPA Region 10, Seattle, Washington. July 6.
URS. 1999a. Final Remedial Investigation, Palermo Wellfield Superfund Site, Tumwater, Washington. Prepared for
EPA Region 10 under ARC No. 68-W9-0054. June.
URS. 1999b. Final Feasibility Study, Palermo Wellfield Superfund Site, Tumwater, Washington. Prepared for EPA
Region 10 under ARC No. 68-W9-0054. May.
URS. 2002. Operation and Maintenance Manual, Subdrain System and Treatment Lagoon, Palermo Wellfield
Superfund Site, Tumwater, Washington. Prepared for EPA Region 10 under Remedial Action Contract No. 68-W-
98-228. August 30.
URS. 2003. First Five-Year Review Report: Palermo Wellfield Superfund Site, Tumwater, Washington. Prepared for
EPA Region 10 under Remedial Action Contract No. 68-W98-228. September.
URS Greiner, Inc. 2011. Remedial Action Construction Documentation, Subdrain System and Treatment Lagoon.
March.
Washington State Department of Ecology (Ecology). 2012. Cleanup Levels and Risk Calculations (CLARC), History of
Changes - Tetrachloroethylene. Available at https://fortress.wa.gov/ecy/clarc/CLARCHome.aspx. Date of Change:
9/26/2012.
12-2
ES051313073020SEA/SEA131330001
-------
Figures
-------
-------
Miller
Brewery
Wells -
Capitol
5000 Bldg
BARNES LAKE
Former Binger's
Gull Station
City of Tumwater
Municipal Golf
Course
Brewery City
Pizza —i
Southgate Dry
Cleaners —.
/ TW-3
Palermo c OtwJ
Neighborhood \ tw-6
Palermo
Wellfield
Southgate Mall
Chevron Station
Texaco Station
Trosper Road
Palermo
Valley Bluff
Road
Poage's Towing
and Auto Repair
Linda St.
Former WDOT Faciliti
SCALE IN FEET
p WDOT District
Maintenance Facility
VICINITY MAP
EVERETT
SEATTLE
TACOMA
PALERMO NEIGHBORHOOD BOUNDARY
APPROXIMATE AREA OF PALERMO WELLFIELD SUPERFUND SITE
Figure 1-1
Site Location Map
oEPA
REGION 10
108-FR-FE-104K
Palermo Wellfield Superfund Site
FIVE-YEAR REVIEW
VANCOUVER
ISLAND
BELUNGHAM
OLYMPIA
-TUMWATER
©
DRAWING NOT TO SCALE
-------
-------
WEST
FORMER
WSDOT
MTL
200-
WSDOT
MTL
(NORTH OF
SECTION)
POSSIBLE
VAPOR
INTRUSION
SOUTHGATE
SHOPPING
CENTER
Q
>
EAST
150 —
PALERMO
BLUFF
GROUNDWATER
SEEPS
VASHON
RECESSIONAL
OUTWASH
PALERMO
oo
oo
Q
>
O
£
LU
100 —
50 —
POSSIBLE
VAPOR
INTRUSION
VASHON
TILL
0 —
-50—1
TERTIARY
BEDROCK
~i r
~i r
r^~
Ti
r^—r
TCE PLUME
MAY
EXTEND
EASTWARD
ALLUVIUM
N \
—i—O-. — *
I N _ - ("
i i r
~i r
ill
KITSAP
FORMATION
I . I
n- 200
_ 150
— 100
— 50
oo
oo
Q
>
O
£
LU
50
NOTE: ELEVATIONS ARE APPROXIMATE. NOT TO SCALE.
Figure 3-1
Cross Section Illustration of
Site Conceptual Model
wEPA
REGION 10
Palermo Wellfield Superfund Site
FIVE-YEAR REVIEW
WSi m ba\p rojMJ s Env irom ental Prote\468186_Pa le rm o_F YR\Fi gu res
-------
-------
Feet
Notes:
1. The locations of all features shown are approximate.
2. This drawing is for information purposes. It is intended to assist in
showing features discussed in an attached document.
GeoEnglneers, Inc. cannot guarantee the accuracy and content
of electronic files. The master file is stored by GeoEngineers, Inc.
and will serve as the official record of this communication.
Reference: Drawing provided by Parametrix. Quality assurance project
plan sampling and analysis for Operation and Maintenance of subdrain
system (URS, 2000).
Roads/Highway
!=~ Buildings
Palermo Neighborhood Boundary
MW-19 Monitoring Well
TW-2® Drinking Water Well
SEEP #1 & Seep Sample
Source: GeoEngineers (2013)
Figure 4-1
Project Location and Groundwater
Monitoring Locations
oEPA
RESIGN 1©
Palermo Wellfield -Superfund Site
FIVE-YEAR REVIEW
-------
-------
-------
-------
Figure 4-3
Concentration Trends for TCE
at the Former WSDOT Facility
oEPA
REGION 10
Palermo Wellfield Superfund Site
FIVE-YEAR REVIEW
Sampling Date
-TCE TCE Trendline I
MW-ES-03
TCE Concentration Time-Trend Plot
Sampling Date
-TCE TCE Trendline I
MW-ES-10
TCE Concentration Time-Trend Plot
Sampling Date
TCE TCE Trendline I
MW-109
TCE Concentration Time-Trend Plot
Sampling Date
MW-ES-05
TCE Concentration Time-Trend Plot
Sampling Date
MW-UI
TCE Concentration Time-Trend Plot
Sampling Date
-TCE TCE Trendline I
55
50
j 45
O)
•2- 40
c
0
= 35
1 30
I-
O 20
H
15
10
5
0
MW-ES-02
TCE Concentration Time-Trend Plot
Sampling Date
MW-ES-07
TCE Concentration Time-Trend Plot
Sampling Date
-TCE TCE Trendline I
PZ-728
TCE Concentration Time-Trend Plot
-------
-------
TCE Concentration Time-Trend Plot
Sampling Date
| —B—TCE TCE Trendline |
PZ-721
TCE Concentration Time-Trend Plot
V
\
V
A
v
1
i i
c
1
i i
O M
i i
i i
c
«<:
1
i i
£ i
c
1
£ i
£ i
1
1
° l
8 |
1
§ l
§ I
1
§ i
§ |
2
§
§
§
o
Sampling Date
| —TCE TCE Trendline |
WSi m ba\p rojMJ s Env irom e ntal Prote\468186_Pal erm o_F YR\Fi gu res
MW-ES-09
TCE Concentration Time-Trend Plot
TCE Concentration Time-Trend Plot
¦
January-06
April-06
July-06
October-06
January-07
>
i
<:
o
October-07
January-08
April-08
i
<:
D
October-08
January-09
April-09
c
¦<:
o
October-09
January-10
>
' July-10
October-10
I January-11
Sampling Date
-¦-TCE TCE Trendline
Figure 4-4
Concentration Trends for TCE
at the WSDOT Testing Laboratory
®EPA
REGION 10
Palermo Wellfield Superfund Site
FIVE-YEAR REVIEW
-------
-------
MW-ES-04
PCE Concentration Time-Trend Plot
PCE Concentration Time-Trend Plot
Sampling Date
-¦-PCE PCE Trendline |
WSi m ba\p roj\U s Env irom ental Prote\468186_Pa le rm o_F YR\Fi gu res
MW-ES-06
PCE Concentration Time-Trend Plot
180
160
Figure 4-5
Concentration Trends for PCE
at the Southgate Mall
wEPA
REGION 10
Palermo Wellfield Superfund Site
FIVE-YEAR REVIEW
-------
-------
Palermo
Neighborhood
Brewery City Pizza
TW-2 J
0.5 U (PGE)
® 8.3 (ICE)
0.5 U (PCE)
0.5 U (TCE)
WSDOT Testing Lab
Southgate Cleaners
(former location
of SVE Systems)
MW-UI
0.5 U (PCE)®
11 (TCE)
Trosper Road
Former WSDOT
Testing Lab
Area of Mixed Commercial and
Potential Residential Receptors
Area of Residential Receptors
Palermo Wellfield
(location of wellhead
treatment air strippers)
Aeration Lagoon
Projection: NAD 1983 StatePlane Washington South FIPS 4602 Feet
Notes:
1. The locations of all features shown are approximate.
2. This drawing is for information purposes. It is intended
to assist in showing features discussed in an attached document.
GeoEngineers, Inc. cannot guarantee the accuracy and content
of electronic files. The master file is stored by GeoEngineers, Inc.
and will serve as the official record of this communication.
mw-ui yetrach|orethene (PCE) /Trichloroethene (TCE)
U.O U (rwt)
9.3(tce) Concentrations [micrograms per liter (ug/L)];
Bold value used for contours
Trichlorethene isoconcentration contour (Spring 2011) ®
Trichlorethene isoconcentration contour (inferred)
|/ Extent of Tetrachlorethene (10 ug/L) (Spring 2011)
Monitoring well and identifier
Piezometer and identifier
City Production well and identifier
Source: GeoEngineers (2013)
a epa
RESI!€lii 10
Palermo Wellfield Superfund Site
FIVE-YEAR REVIEW
Figure 4-6
PCE and TCE Concentrations in Groundwater
Spring 2011
Barnes
Lake
Area of Mixed Commercial and
Potential Residential Receptors
-------
-------
Barnes
Lake
Area of Mixed Commercial and
Potential Residential Receptors
Brewery City Pizza
\ TJW-2
0.5 V] (PCE)
® 12* (TCE)
®TW-4
0.5 U (PCE)
0,5 U (TCE)
WSDOT Testing Lab
Southgate Cleaners
(former location
of SVE Systems)
MW-UI
0.5 U (PCE)a
11 (TCE)
Trosper Road
Former WSDOT
Testing Lab
Area of Mixed Commercial and
Potential Residential Receptors
Area of Residential Receptors
Palermo Wellfield
(location of wellhead
treatment air strippers)
Aeration Lagoon
Projection: NAD 1983 StatePlane Washington South FIPS 4602 Feet
Notes:
1. The locations of all features shown are approximate.
2. This drawing is for information purposes. It is intended
to assist in showing features discussed in an attached document.
GeoEngineers, Inc. cannot guarantee the accuracy and content
of electronic files. The master file is stored by GeoEngineers, Inc.
and will serve as the official record of this communication.
mw-ui Tetraehlorethene (PCE) /Trichloroethene (TCE)
U.O U (rwt)
9.3(tce) Concentrations [micrograms per liter (ug/L)];
Bold value used for contours
Trichlorethene isoconcentration contour (Fall 2011)
Trichlorethene isoconcentration contour (inferred)
1/ Extent of Tetraehlorethene (10 ug/L) (Fall 2011)
® Monitoring well and identifier
IE Piezometer and identifier
® City Production well and identifier
Source: GeoEngineers (2013)
©EPA
REGION 10
Palermo Wellfield Superfund Site
FIVE-YEAR REVIEW
Figure 4-7
PCE and TCE Concentrations in Groundwater
Fall 2011
-------
-------
Area of Residential Receptors
Barnes
Lake
Aeration Lagoon
Area of Mixed Commercial and
Potential Residential Receptors
Palermo
Neighborhood
Brewery City Pizza
MW-4B
0.5 U (PCE);
0.5 U (TCE)
MW-4A'
WSDOT Testing Lab
® TW-4
0.5 U (PCE)
0.71 J (TCE)
Palermo Wellfield
(location of wellhead
treatment air strippers)
Southgate Cleaners
(former location
of SVE Systems)
Trosper Road
Former WSDOT
Testing Lab
Area of Mixed Commercial and
Potential Residential Receptors
Projection: NAD 1983 StatePlane Washington South FIPS 4602 Feet
Notes:
1. The locations of all features shown are approximate.
2. This drawing is for information purposes. It is intended
to assist in showing features discussed in an attached document.
GeoEngineers, Inc. cannot guarantee the accuracy and content
of electronic files. The master file is stored by GeoEngineers, Inc.
and will serve as the official record of this communication.
Mw-ui Jetrachlorethene (PCE) /Trichloroethene (TCE)
U.O U (rwt)
9.3(tce) Concentrations [micrograms per liter (ug/L)];
Bold value used for contours
Trichlorethene isoconcentration contour (Spring 2012) ®
Trichlorethene isoconcentration contour (inferred)
1/ Extent of Tetrachlorethene (10 ug/L) (Spring 2012)
Monitoring well and identifier
Piezometer and identifier
City Production well and identifier
Source: GeoEngineers (2013)
300
300
Feet
Figure 4-8
PCE and TCE Concentrations in Groundwater
Spring 2012
SEPA
REGION 10
Palermo Wellfield Superfund Site
FIVE-YEAR REVIEW
-------
-------
70.0
60.0
50.0
? 40.0
C
o
1
«
£ 30.0
«
o
c
0
V>
o
~
HI „ „
]
o 20.0
l—
1
10.0
0.0
Validation
Monitoring
Subdrain System
Ecology Monitoring
EPA
Monitoring
«{• 0s J§1' si1, 5? s? d? $ J0 C? ^ sj S? s? # # # ,C? jP J? \Q \N ft" ^ !?
Jjr ,!^r ^ ^ ^ ^|T ^ ^ <& $ $ & $§> C? C? »S* \N nn & .fi
¥ / ^ jp sf / y / y o°v # ^ # / # # / / / # / of ¦? /
Source: Parametrix (2012)
Figure 4-9
Subdrain System TCE Concentrations (ug/L)
February 2001 through March 2013
oEPA
REGION 10
Palermo Wellfield Superfund Site
FIVE-YEAR REVIEW
\\S i m b a\proj\U s Envi rom ental Prote\468186_Pal erm o_ FYR\Fig ures
-------
-------
Subdrain System
70
60
50
5 40
o 30
O
20
10
Validation j
Monitoring
Ecology Monitoring
EPA
Monitoring
TCE Remediation Goal - 2 7ppb
\
J? J? .S? .S>v ,S^ J? J- J? S? J* .>
^ Vs # / # ^ ^ sf» \& £
-------
-------
Palermo Neighborhood, You're Invited - Join
us to discuss the recent Air Sampling in your
Neighborhood.
July 10, 2013
Stop by between 4:00 - 7:00 PM
Formal presentations will be given at 4:30 and 6.
EPA, Washington State Department of Transportation,
Department of Health, and Health professionals will be
available to:
• Answer questions about your results
• Talk about plans for future sampling
• Discuss your health concerns related to the results
Open house starts at 4:00
Presentations at 4:30 & 6:00
Location: River's Edge
4611 Tumwater Valley Dr.
Olympia, WA 98501
For More information,
contact:
• Caryn Sengupta:
206-553-1275 or
1-800-424-4372 x31275,
sengupta.caryn@epa.gov
• Erin Kochaniewicz:
360-236-3358,
erin.kochaniewicz@doh.wa.g
ov
Figure 5-1
Notice of Palermo Neighborhood Meeting -
July 10, 2013
Palermo Wellfield Superfund Site
FIVE-YEAR REVIEW
oEPA
REGION 10
\\S im b a\proj\U s Envi rom ental Prote\468186_Pal erm o_ FYR\Fig ures
-------
-------
Appendix A
2013 Air, Groundwater, and Subdrain
Analytical Results
-------
-------
Table A-1
March/April 2013 Air and Soil Vapor Sample Results
Palermo Wellfield Superfund Site, Tumwater, Washington
1,1 -Dichloroethane
1,1 -Dichloroethene
1,2-Dichloroethane
cis-1,2-Dichloroethene
Tetrachloroethene
T rans-1,2-Dichloroethene
Trichloroethene
Sample Location
Sample ID
Date
Type
Collection
Method
Sample Point
(ug/m3)
(ug/m3)
(ug/m3)
(ug/m3)
(ug/m3)
(ug/m3)
(ug/m3)
Ambient Samples
East end N Street
ARAD-EN_20130403
4/3/2013
N
Radello
Ambient
0.050 U
0.17 U
0.046
0.051 U
0.055
0.10 U
0.046 U
North end Palermo
ARAD-NP 20130403
4/3/2013
N
Radello
Ambient
0.050 U
0.17 U
0.041 U
0.051 U
0.054 U
0.10 U
0.046 U
North end Rainier SE
ARAD-NR 20130403
4/3/2013
N
Radello
Ambient
0.050 U
0.17 U
0.046
0.051 U
0.056
0.10 U
0.046 U
South end Palermo
ARAD-SP1 20130403
4/3/2013
N
Radello
Ambient
0.050 U
0.17 U
0.044
0.051 U
0.054 U
0.11 U
0.046 U
South end Palermo
ARAD-SP2 20130403
4/3/2013
FD
Radello
Ambient
0.050 U
0.17 U
0.041
0.051 U
0.054 U
0.11 U
0.046 U
South end Rainier SE
ARAD SR_20130403
4/3/2013
N
Radello
Ambient
0.050 U
0.17 U
0.041
0.051 U
0.054 U
0.10 U
0.046 U
In-Home Samples*
H-01
4/1/2013
N
Radello
Crawlspace
0.052 U
0.17 U
0.043 U
0.053 U
0.056 U
0.11 U
0.24
4/1/2013
N
Radello
Indoor
0.052 U
0.17 U
0.26
0.053 U
0.65
0.11 U
0.15
3/12/2013
N
Summa
Indoor
0.27 U
0.13 U
0.48
0.26 U
0.96
1.3 U
0.35 U
H-02
4/3/2013
N
Radello
Crawlspace
0.052 U
0.17 U
0.043 U
0.053 U
0.056
0.11 U
0.048 U
4/3/2013
N
Radello
Indoor
0.052 U
0.17 U
0.42
0.053 U
0.14
0.11 U
0.048 U
H-03
4/5/2013
N
Radello
Crawlspace
0.052 U
0.17 U
0.043 U
0.053 U
0.056 U
0.11 U
0.048 U
4/5/2013
FD
Radello
Crawlspace
0.052 U
0.17 U
0.043 U
0.053 U
0.056 U
0.11 U
0.048 U
4/5/2013
N
Radello
Indoor
0.052 U
0.17 U
0.29
0.053 U
0.056 U
0.11 U
0.22
4/5/2013
FD
Radello
Indoor
0.052 U
0.17 U
0.38
0.053 U
0.056 U
0.11 u
0.25
H-04
4/3/2013
N
Radello
Indoor
0.050 U
0.17 U
0.55
0.051 U
0.21
0.10 u
0.046 U
3/21/2013
N
Summa
Sub Slab
0.43 UJ
0.21 UJ
0.43 UJ
0.42 UJ
550 J
2.1 UJ
0.57 UJ
H-05
4/3/2013
N
Radello
Crawlspace
0.052 U
0.17 U
0.043 U
0.053 U
0.056 U
0.11 U
0.048 U
4/3/2013
N
Radello
Indoor
0.052 U
0.17 U
0.054
0.053 U
13
0.11 u
0.048 U
H-06
4/3/2013
N
Radello
Crawlspace
0.049 U
0.16 U
0.040 U
0.049 U
0.052 U
0.10 u
0.044 U
4/3/2013
N
Radello
Indoor
0.049 U
0.16 U
0.5
0.049 U
0.064
0.10 u
0.044 U
4/11/2013
N
Radello
Crawlspace
0.050 U
0.16 U
0.041 U
0.050 U
0.053 U
0.10 u
0.049
4/11/2013
N
Radello
Indoor
0.050 U
0.16 U
2.2
0.050 U
2
0.10 u
0.053
H-07
4/5/2013
N
Radello
Crawlspace
0.053 U
0.18 U
0.12
0.054 U
0.057 U
0.11 u
0.048 U
4/5/2013
N
Radello
Indoor
0.053 U
0.18 U
5.3
0.054 U
0.32
0.11 u
0.048 U
H-08
4/4/2013
N
Radello
Crawlspace
0.052 U
0.17 U
0.043 U
0.053 U
0.056 U
0.11 u
0.048 U
4/4/2013
FD
Radello
Crawlspace
0.052 U
0.17 U
0.043 U
0.053 U
0.056 U
0.11 u
0.048 U
4/4/2013
N
Radello
Indoor
0.052 U
0.17 U
0.078
0.052 U
0.055 U
0.11 u
0.047 U
4/4/2013
FD
Radello
Indoor
0.052 U
0.17 U
0.08
0.053 U
0.056 U
0.11 u
0.048 U
H-09
4/4/2013
N
Radello
Crawlspace
0.052 U
0.17 U
0.042 U
0.053 U
0.055 U
0.11 u
0.047 U
4/4/2013
N
Radello
Indoor
0.052 U
0.17 U
0.33
0.053 U
0.073
0.11 u
0.047 U
H-10
4/3/2013
N
Radello
Crawlspace
0.052 U
0.17 U
0.043 U
0.053 U
0.056 U
0.11 u
0.048 U
4/3/2013
N
Radello
Indoor
0.052 U
0.17 U
0.094
0.053 U
0.056 U
0.11 u
0.048 U
H-11
4/8/2013
N
Radello
Crawlspace
0.052 U
0.17 U
0.043 U
0.053 U
0.056 U
0.11 u
0.048 U
4/8/2013
N
Radello
Indoor
0.052 U
0.17 U
3.8
0.053 U
0.056 U
0.11 u
0.048 U
H-12
4/3/2013
N
Radello
Crawlspace
0.050 U
0.17 U
0.057
0.051 U
0.054 U
0.10 u
0.046 U
4/3/2013
N
Radello
Indoor
0.050 U
0.17 U
15
0.051 U
0.078
0.10 u
0.046 U
H-13
4/4/2013
N
Radello
Crawlspace
0.052 U
0.17 U
0.14
0.052 U
0.055 U
0.11 u
0.047 U
4/4/2013
N
Radello
Indoor
0.052 U
0.17 U
1.9
0.052 U
0.055 U
0.11 u
0.047 U
H-14
4/5/2013
N
Radello
Crawlspace
0.052 U
0.17 U
0.046
0.053 U
0.082
0.11 u
0.048 U
4/5/2013
N
Radello
Indoor
0.083
0.17 U
0.17
0.053 U
6.2
0.11 u
0.048 U
H-15
4/8/2013
N
Radello
Indoor
0.052 U
0.17 U
0.078
0.053 U
0.061
0.11 u
0.048 U
H-16
4/3/2013
N
Radello
Crawlspace
0.052 U
0.17 U
0.045
0.053 U
0.06
0.11 u
0.048 U
4/3/2013
N
Radello
Indoor
0.052 U
0.17 U
0.075
0.053 U
0.94
0.11 u
0.048 U
H-17
4/3/2013
N
Radello
Crawlspace
0.050 U
0.17 U
0.043
0.051 U
0.054 U
0.10 u
0.046 U
4/3/2013
N
Radello
Indoor
0.050 U
0.17 U
0.87
0.050 U
0.34
0.10 u
0.077
H-18
4/5/2013
N
Radello
Crawlspace
0.053 U
0.17 U
0.043 U
0.053 U
0.056 U
0.11 u
0.048 U
4/5/2013
N
Radello
Indoor
0.053 U
0.17 U
0.96
0.053 U
0.079
0.11 u
0.08
H-19
4/8/2013
N
Radello
Crawlspace
0.052 U
0.17 U
0.043 U
0.053 U
0.056 U
0.11 u
0.048 U
4/8/2013
N
Radello
Indoor
0.052 U
0.17 U
0.06
0.053 U
0.071
0.11 u
0.16
H-20
4/8/2013
N
Radello
Crawlspace
0.052 U
0.17 U
0.045
0.053 U
0.057
0.11 u
0.048 U
4/8/2013
N
Radello
Indoor
0.052 U
0.17 U
0.25
0.053 U
0.056
0.11 u
0.048 U
H-21
4/11/2013
N
Radello
Indoor
0.050 U
0.17 U
0.19
0.050 U
0.92
0.10 u
0.046 U
H-22
4/3/2013
N
Radello
Crawlspace
0.052 U
0.17 U
0.1
0.053 U
0.089
0.11 u
0.048 U
4/3/2013
N
Radello
Indoor
0.052 U
0.17 U
0.43
0.053 U
0.29
0.11 u
0.048 U
H-23
4/4/2013
N
Radello
Crawlspace
0.052 U
0.17 U
0.043 U
0.053 U
0.056 U
0.11 u
0.048 U
4/4/2013
N
Radello
Indoor
0.052 U
0.17 U
0.061
0.053 U
0.056 U
0.11 u
0.048 U
H-24
4/1/2013
N
Radello
Crawlspace
0.052 U
0.17 U
0.043 U
0.053 U
0.073
0.11 u
0.13
4/1/2013
N
Radello
Indoor
0.052 U
0.17 U
0.2
0.053 U
0.093
0.11 u
0.056
3/12/2013
N
Summa
Crawlspace
0.11 U
0.056 U
0.11 u
0.11 U
0.23
0.56 U
0.15 U
3/12/2013
N
Summa
Indoor
0.13 U
0.066 U
0.4
0.13 U
0.22 U
0.66 U
0.18 U
PAGE 1 OF 2
-------
Table A-1
March/April 2013 Air and Soil Vapor Sample Results
Palermo Wellfield Superfund Site, Tumwater, Washington
1,1 -Dichloroethane
1,1 -Dichloroethene
1,2-Dichloroethane
cis-1,2-Dichloroethene
Tetrachloroethene
T rans-1,2-Dichloroethene
Trichloroethene
Sample Location
Sample ID
Date
Type
Collection
Method
Sample Point
(ug/m3)
(ug/m3)
(ug/m3)
(ug/m3)
(ug/m3)
(ug/m3)
(ug/m3)
H-25
4/1/2013
N
Radello
Crawlspace
0.052 U
0.17 U
0.046
0.053 U
0.14
0.11 U
0.048 U
4/1/2013
N
Radello
Indoor
0.052 U
0.17 U
1.4
0.053 U
0.23
0.11 U
0.048 U
3/12/2013
N
Summa
Crawlspace
0.12 U
0.058 U
0.12 U
0.12 U
0.20 U
0.58 U
0.16 U
3/12/2013
N
Summa
Indoor
0.12 U
0.060 U
3.1
0.12 U
0.35
0.60 U
0.16 U
H-26
4/3/2013
N
Radello
Crawlspace
0.051 U
0.17 U
0.05
0.051 U
0.055
0.11 U
0.14
4/3/2013
FD
Radello
Crawlspace
0.051 U
0.17 U
0.042
0.051 U
0.054 U
0.11 U
0.12
4/3/2013
N
Radello
Indoor
0.051 U
0.17 U
0.075
0.051 U
0.06
0.11 U
0.13
4/3/2013
FD
Radello
Indoor
0.051 U
0.17 U
0.064
0.051 U
0.066
0.11 U
0.13
H-26 (additional)
3/21/2013
N
Summa
Crawlspace
0.12 U
0.060 U
0.12 U
0.12 U
0.21 U
0.60 U
0.16 U
3/21/2013
FD
Summa
Crawlspace
0.13 U
0.063 U
0.13 U
0.13 U
0.22 U
0.63 U
0.17 U
3/14/2013
N
Summa
Crawlspace
0.14 U
0.068 U
0.14 U
0.14 U
0.23 U
0.68 U
0.18 U
3/14/2013
FD
Summa
Crawlspace
0.14 U
0.066 U
0.14 U
0.13 U
0.23 U
0.66 U
0.18 U
H-27
3/21/2013
N
Summa
Indoor
0.14 U
0.070 U
0.14 U
0.14 U
0.24 U
0.70 U
0.2
3/21/2013
FD
Summa
Indoor
0.13 U
0.063 U
0.13 U
0.13 U
0.22 U
0.63 U
0.2
3/14/2013
N
Summa
Indoor
0.13 U
0.064 U
0.13 U
0.13 U
0.22 U
0.64 U
0.17 U
3/14/2013
FD
Summa
Indoor
0.13 U
0.063 U
0.13 U
0.13 U
0.22 U
0.63 U
0.17 U
H-28
4/4/2013
N
Radello
Indoor
0.052 U
0.17 U
1.6
0.053 U
7.7
0.11 U
0.054
H-29
4/1/2013
N
Radello
Crawlspace
0.053 U
0.17 U
0.043 U
0.053 U
0.056 U
0.11 U
0.048 U
4/1/2013
N
Radello
Indoor
0.053 U
0.17 U
0.16
0.053 U
0.077
0.11 U
0.048 U
H-30
4/5/2013
N
Radello
Indoor
0.052 U
0.17 U
0.051
0.053 U
0.066
0.11 U
0.048 U
Wellfield Samples
Treatment Bldg (North)
RRAD-TB1 20130411
4/11/2013
N
Radello
Indoor
0.052 U
0.17 U
0.052
0.053 U
0.056 U
0.11 U
0.048 U
Treatment Bldg (South)
RRAD-TB2 20130411
4/11/2013
N
Radello
Indoor
0.052 U
0.17 U
0.046
0.053 U
0.056 U
0.11 U
0.048 U
T reatment Warehouse
RRAD-WH 20130411
4/11/2013
N
Radello
Indoor
0.052 U
0.17 U
0.043 U
0.053 U
0.056 U
0.11 U
0.048 U
Production Well "TW-4"
RRAD-TW4 20130411
4/11/2013
N
Radello
Indoor
0.052 U
0.17 U
0.045
0.053 U
0.056 U
0.11 U
0.048 U
Production Well "TW-5"
RRAD-TW5_20130411
4/11/2013
N
Radello
Indoor
0.052 U
0.17 U
0.046
0.053 U
0.056 U
0.11 U
0.048 U
Notes: N = normal (primary) environmental sample; FD = field duplicate; ug/m3= micrograms per cubic meter; U = not detected at or above the reported detection
limit; R = rejected result; J = estimated result detected below the reporting detection limit and above the method detection limit; BOLD = detected result above the
method detection limit.
* Sample location and identification numbers have been removed for confidentiality
PAGE 2 OF 2
-------
Table A-2
March 2013 Groundwater Sample Results Palermo
Wellfield Superfund Site, Tumwater, Washington
1,1,1,2-Tetrachloroethane
1,1,1-Trichloroethane
1,1,2,2-Tetrachloroethane
1,1,2-Trichloro-1,2,2-trifluoroethane
(CFC-113)
1,1,2-Trichloroethane
1,1-Dichloroethane
1,1-Dichloroethene
1,1 -Dichloropropene
1,2,3-Trichlorobenzene
1,2,3-Trichloropropane
1,2,4-Trichlorobenzene
1,2,4-Tri methyl benzene
1,2-Dibromo-3-Chloropropane
1,2-dibromoethane (EDB)
1,2-Dichlorobenzene (o-Dichlorobenzene)
1,2-Dichloroethane (EDC)
1,2-Dichloropropane
1,3,5-Tri methyl benzene
1,3-Dichlorobenzene (m-Dichlorobenzene)
1,3-Dichloropropane
1,4-Dichlorobenzene (p-Dichlorobenzene)
2,2-Dichloropropane
2-Butanone (MEK)
2-Chloroethyl vinyl ether
2-Chlorotoluene
4-Chlorotoluene
4-Methyl-2-Pentanone (Methyl isobutyl keton
Acetone
Acrolein
Acrylonitrile
Benzene
Location
Sample ID
Date
Type
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
MW-100
MW-100 130305
03/05/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
2.5 U
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
10 u
50 U
1.0 u
1.0 u
10 u
50 U
50 U
10 u
1.0 u
MW-101A
MW-101A 130306
03/06/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
2.5 U
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
10 u
50 U
1.0 u
1.0 u
10 u
50 U
50 U
10 u
1.0 u
MW-101B
MW-101B 130305 26.5 FT
03/05/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
2.5 U
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
10 u
50 U
1.0 u
1.0 u
10 u
50 U
50 U
10 u
1.0 u
MW-102
MW-102 130305 20 FT
03/05/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
2.5 U
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
10 u
50 U
1.0 u
1.0 u
10 u
50 U
50 U
10 u
1.0 u
MW-103
MW-103 130306
03/06/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
2.5 U
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
10 u
50 U
1.0 u
1.0 u
10 u
50 U
50 U
10 u
1.0 u
MW-104A
MW-104A 130307
03/07/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
2.5 U
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
10 u
50 U
1.0 u
1.0 u
10 u
50 U
50 U
10 u
1.0 u
MW-104B
MW-104B 130311
03/11/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
2.5 U
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
10 u
50 U
1.0 u
1.0 u
10 u
50 U
50 U
10 u
1.0 u
MW-107
MW-107 130306
03/06/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
2.5 U
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
10 u
50 U
1.0 u
1.0 u
10 u
50 U
50 U
10 u
1.0 u
MW-109
MW-109 130305
03/05/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
2.5 U
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
10 u
50 U
1.0 u
1.0 u
10 u
50 U
50 U
10 u
1.0 u
MW-110
DUP-1 130306
03/06/2013
Duplicate
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
2.5 U
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
10 u
50 U
1.0 u
1.0 u
10 u
50 U
50 U
10 u
1.0 u
MW-110
MW-110 130306
03/06/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
2.5 U
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
10 u
50 U
1.0 u
1.0 u
10 u
50 U
50 U
10 u
1.0 u
MW-111
MW-111 130307
03/07/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
2.5 U
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
10 u
50 U
1.0 u
1.0 u
10 u
50 U
50 U
10 u
1.0 u
MW-4A
MW-4A 130312
03/12/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
2.5 U
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
10 u
50 U
1.0 u
1.0 u
10 u
50 U
50 U
10 u
1.0 u
MW-4B
MW-4B 130312
03/12/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
2.5 U
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
10 u
50 U
1.0 u
1.0 u
10 u
50 U
50 U
10 u
1.0 u
MW-93-02
MW-93-02 130312
03/12/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
2.5 U
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
10 u
50 U
1.0 u
1.0 u
10 u
50 U
50 U
10 u
1.0 u
MW-96-15
MW-96-15 130307
03/07/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
2.5 U
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
10 u
50 R
1.0 u
1.0 u
10 u
50 U
50 U
10 u
1.0 u
MW-96-16
MW-96-16 130306
03/06/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
2.5 U
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
10 u
50 U
1.0 u
1.0 u
10 u
50 U
50 U
10 u
1.0 u
MW-96-17
MW-96-17 130306
03/06/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
2.5 U
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
10 u
50 U
1.0 u
1.0 u
10 u
50 U
50 U
10 u
1.0 u
MW-ES-02
MW-ES-02 130307
03/07/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
2.5 U
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
10 u
50 U
1.0 u
1.0 u
10 u
50 U
50 U
10 u
1.0 u
MW-ES-03
DUP-2 130307
03/07/2013
Duplicate
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
2.5 U
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
10 u
50 U
1.0 u
1.0 u
10 u
50 U
50 U
10 u
1.0 u
MW-ES-03
MW-ES-03 130307
03/07/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
2.5 U
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
10 u
50 U
1.0 u
1.0 u
10 u
50 U
50 U
10 u
1.0 u
MW-ES-04
MW-ES-04 130308
03/08/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
2.5 U
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
10 u
50 U
1.0 u
1.0 u
10 u
50 U
50 U
10 u
1.0 u
MW-ES-05
MW-ES-05 130308
03/08/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
2.5 U
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
10 u
50 U
1.0 u
1.0 u
10 u
50 U
50 U
10 u
1.0 u
MW-ES-06
MW-ES-06 130308
03/08/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
2.5 U
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
10 u
50 U
1.0 u
1.0 u
10 u
50 U
50 U
10 u
1.0 u
MW-ES-07
MW-ES-07 130305 30 FT
03/05/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
2.5 U
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
10 u
50 R
1.0 u
1.0 u
10 u
50 U
50 U
10 u
1.0 u
MW-ES-08
MW-ES-08 130305
03/05/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
2.5 U
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
10 u
50 U
1.0 u
1.0 u
10 u
50 U
50 U
10 u
1.0 u
MW-ES-09
MW-ES-09 130311
03/11/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
2.5 U
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
10 u
50 U
1.0 u
1.0 u
10 u
50 U
50 U
10 u
1.0 u
MW-ES-10
MW-ES-10 130311
03/11/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
2.5 U
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
10 u
50 U
1.0 u
1.0 u
10 u
50 U
50 U
10 u
1.0 u
MW-ES-11
MW-ES-11 130306
03/06/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
2.5 U
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
10 u
50 U
1.0 u
1.0 u
10 u
50 U
50 U
10 u
1.0 u
MW-UI
MW-UI 130305
03/05/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
2.5 U
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
10 u
50 U
1.0 u
1.0 u
10 u
50 U
50 U
10 u
1.0 u
PZ-704
PZ-704 130313
03/13/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
2.5 U
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
10 u
50 U
1.0 u
1.0 u
10 u
50 U
50 U
10 u
1.0 u
PZ-709
PZ-709 130313
03/13/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
2.5 U
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
0.38 J
1.0 u
1.0 u
1.0 u
10 u
50 U
1.0 u
1.0 u
10 u
11 U
50 U
10 u
1.0 u
PZ-715
PZ-715 130313
03/13/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
2.5 U
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
0.65 J
1.0 u
1.0 u
1.0 u
10 u
50 U
1.0 u
1.0 u
10 u
50 U
50 U
10 u
1.0 u
PZ-719
DUP-4 130314
03/14/2013
Duplicate
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
2.5 U
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
10 u
50 U
1.0 u
1.0 u
10 u
50 U
50 U
10 u
1.0 u
PZ-719
PZ-719 130314
03/14/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
2.5 U
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
10 u
50 U
1.0 u
1.0 u
10 u
50 U
50 U
10 u
1.0 u
PZ-720
PZ-720 130314
03/14/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
2.5 U
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
10 u
50 U
1.0 u
1.0 u
10 u
50 U
50 U
10 u
1.0 u
PZ-721
PZ-721 130314
03/14/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
2.5 U
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
10 u
50 U
1.0 u
1.0 u
10 u
50 U
50 U
10 u
1.0 u
PZ-722
PZ-722 130314
03/14/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
2.5 U
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
10 u
50 U
1.0 u
1.0 u
10 u
50 U
50 U
10 u
1.0 u
PZ-723
PZ-723 130314
03/14/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
2.5 U
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
10 u
50 U
1.0 u
1.0 u
10 u
50 U
50 U
10 u
1.0 u
PZ-724
PZ-724 130314
03/14/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
2.5 U
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
10 u
50 U
1.0 u
1.0 u
10 u
50 U
50 U
10 u
1.0 u
PZ-725
PZ-725 130314
03/14/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
2.5 U
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
10 u
50 U
1.0 u
1.0 u
10 u
50 U
50 U
10 u
1.0 u
PZ-726
PZ-726 130312
03/12/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
2.5 U
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
10 u
50 U
1.0 u
1.0 u
10 u
50 U
50 U
10 u
1.0 u
PZ-728
PZ-728 130307
03/07/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
2.5 U
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
10 u
50 U
1.0 u
1.0 u
10 u
50 U
50 U
10 u
1.0 u
RPZ-730
RPZ-730 130313
03/13/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
2.5 U
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
10 u
50 U
1.0 u
1.0 u
10 u
50 U
50 U
10 u
1.0 u
RPZ-731
RPZ-731 130313
03/13/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
2.5 U
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
10 u
50 U
1.0 u
1.0 u
10 u
50 U
50 U
10 u
1.0 u
RPZ-732
RPZ-732 130312
03/12/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
2.5 U
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
10 u
50 U
1.0 u
1.0 u
10 u
50 U
50 U
10 u
1.0 u
WDOT-MW-1
WDOT-MW-1 130307
03/07/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
2.5 U
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
10 u
50 U
1.0 u
1.0 u
10 u
50 U
50 U
10 u
1.0 u
WDOT-MW-2
WDOT-MW-2 130306
03/06/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
2.5 U
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
10 u
50 U
1.0 u
1.0 u
10 u
50 U
50 U
10 u
1.0 u
PAGE 1 OF 3
-------
Table A-2
March 2013 Groundwater Sample Results Palermo
Wellfield Superfund Site, Tumwater, Washington
Benzene, 1,2,3-Trimethyl-
Bromobenzene
Bromodichloromethane
Bromoform (Tribromomethane)
Bromomethane
Carbon Tetrachloride
Chlorobenzene
Chloroethane
Chloroform
Chloromethane
cis-1,2-Dichloroethene
Cis-1,3-Dichloropropene
Dibromochloromethane
Di bromomethane
Dichlorodifluoromethane (CFC-12)
Diisopropyl Ether (Dot)
Ethyl benzene
Hexachlorobutadiene
Isopropylbenzene (Cumene)
Methyl t-butyl ether
Methylene Chloride
Naphthalene
n-Butyl benzene
n-Propylbenzene
p-lsopropyltoluene
Sec-Butyl benzene
Styrene
Tert-Butylbenzene
Tetrachloroethene
Toluene
Total Xylenes
Location
Sample ID
Date
Type
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
MW-100
MW-100 130305
03/05/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
5.0 U
5.0 U
2.5 U
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
3.0 U
MW-101A
MW-101A 130306
03/06/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
5.0 U
5.0 U
2.5 U
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
3.0 U
MW-101B
MW-101B 130305 26.5 FT
03/05/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
5.0 U
5.0 U
2.5 U
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
3.0 U
MW-102
MW-102 130305 20 FT
03/05/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
5.0 U
5.0 U
2.5 U
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
3.0 U
MW-103
MW-103 130306
03/06/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
5.0 U
5.0 U
2.5 U
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
3.0 U
MW-104A
MW-104A 130307
03/07/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
5.0 U
5.0 U
2.5 U
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
3.0 U
MW-104B
MW-104B 130311
03/11/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
5.0 U
5.0 U
2.5 U
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.7 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.4
5.0 U
3.0 U
MW-107
MW-107 130306
03/06/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
5.0 U
5.0 U
2.5 U
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
3.0 U
MW-109
MW-109 130305
03/05/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
5.0 U
5.0 U
2.5 U
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
3.0 U
MW-110
DUP-1 130306
03/06/2013
Duplicate
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
5.0 U
5.0 U
2.5 U
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
3.0 U
MW-110
MW-110 130306
03/06/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
5.0 U
5.0 U
2.5 U
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
3.0 U
MW-111
MW-111 130307
03/07/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
5.0 U
5.0 U
2.5 U
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
3.0 U
MW-4A
MW-4A 130312
03/12/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
5.0 U
5.0 U
2.5 U
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.7 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
3.0 U
MW-4B
MW-4B 130312
03/12/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
5.0 U
5.0 U
2.5 U
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.6 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
3.0 U
MW-93-02
MW-93-02 130312
03/12/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
5.0 U
5.0 U
2.5 U
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.6 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
3.0 U
MW-96-15
MW-96-15 130307
03/07/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
5.0 U
5.0 U
2.5 U
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
3.0 U
MW-96-16
MW-96-16 130306
03/06/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
5.0 U
5.0 U
2.5 U
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
3.0 U
MW-96-17
MW-96-17 130306
03/06/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
5.0 U
5.0 U
2.5 U
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
3.0 U
MW-ES-02
MW-ES-02 130307
03/07/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
5.0 U
5.0 U
2.5 U
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
3.0 U
MW-ES-03
DUP-2 130307
03/07/2013
Duplicate
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
5.0 U
5.0 U
2.5 U
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.8 J
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
3.0 U
MW-ES-03
MW-ES-03 130307
03/07/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
5.0 U
5.0 U
2.5 U
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
3.0 U
MW-ES-04
MW-ES-04 130308
03/08/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
5.0 U
5.0 U
2.5 U
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.8 J
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
44
5.0 U
3.0 U
MW-ES-05
MW-ES-05 130308
03/08/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
5.0 U
5.0 U
2.5 U
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
3.0 U
MW-ES-06
MW-ES-06 130308
03/08/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
5.0 U
5.0 U
2.5 U
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
23
5.0 U
3.0 U
MW-ES-07
MW-ES-07 130305 30 FT
03/05/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
5.0 U
5.0 U
2.5 U
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
3.0 U
MW-ES-08
MW-ES-08 130305
03/05/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
5.0 U
5.0 U
2.5 U
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
3.0 U
MW-ES-09
MW-ES-09 130311
03/11/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
5.0 U
5.0 U
2.5 U
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.7 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
3.0 U
MW-ES-10
MW-ES-10 130311
03/11/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
5.0 U
5.0 U
2.5 U
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.7 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
3.0 U
MW-ES-11
MW-ES-11 130306
03/06/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
5.0 U
5.0 U
2.5 U
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
3.0 U
MW-UI
MW-UI 130305
03/05/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
5.0 U
5.0 U
2.5 U
0.34 J
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
3.0 U
PZ-704
PZ-704 130313
03/13/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
5.0 U
5.0 U
2.5 U
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
3.0 U
PZ-709
PZ-709 130313
03/13/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
5.0 U
5.0 U
2.5 U
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
3.0 U
PZ-715
PZ-715 130313
03/13/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
5.0 U
5.0 U
2.5 U
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
3.0 U
PZ-719
DUP-4 130314
03/14/2013
Duplicate
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
5.0 U
5.0 U
2.5 U
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
3.0 U
PZ-719
PZ-719 130314
03/14/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
5.0 U
5.0 U
2.5 U
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
3.0 U
PZ-720
PZ-720 130314
03/14/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
5.0 U
5.0 U
2.5 U
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
0.38 J
5.0 U
3.0 U
PZ-721
PZ-721 130314
03/14/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
5.0 U
5.0 U
2.5 U
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
3.0 U
PZ-722
PZ-722 130314
03/14/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
5.0 U
5.0 U
2.5 U
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
3.0 U
PZ-723
PZ-723 130314
03/14/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
5.0 U
5.0 U
2.5 U
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
3.0 U
PZ-724
PZ-724 130314
03/14/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
5.0 U
5.0 U
2.5 U
1.2
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
3.0 U
PZ-725
PZ-725 130314
03/14/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
5.0 U
5.0 U
2.5 U
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
3.0 U
PZ-726
PZ-726 130312
03/12/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
5.0 U
5.0 U
2.5 U
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.6 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
3.0 U
PZ-728
PZ-728 130307
03/07/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
5.0 U
5.0 U
2.5 U
0.31 J
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
0.39 J
1.0 u
1.0 u
1.0 u
5.0 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
0.84 J
3.0 U
RPZ-730
RPZ-730 130313
03/13/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
5.0 U
5.0 U
2.5 U
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
3.0 U
RPZ-731
RPZ-731 130313
03/13/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
5.0 U
5.0 U
2.5 U
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
3.0 U
RPZ-732
RPZ-732 130312
03/12/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
5.0 U
5.0 U
2.5 U
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.7 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
3.0 U
WDOT-MW-1
WDOT-MW-1 130307
03/07/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
5.0 U
5.0 U
2.5 U
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
3.0 U
WDOT-MW-2
WDOT-MW-2 130306
03/06/2013
Primary
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
5.0 U
5.0 U
2.5 U
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
3.0 U
PAGE 2 OF 3
-------
Table A-2
March 2013 Groundwater Sample Results
Palermo Wellfield Superfund Site, Tumwater, Washington
Trans-1,2-Dichloroethene
Trans-1,3-Dichloropropene
Trichloroethene (TCE)
Trichlorofluoromethane (CFC-11)
Vinyl Chloride
Location
Sample ID
Date
Type
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
MW-100
MW-100 130305
03/05/2013
Primary
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
MW-101A
MW-101A 130306
03/06/2013
Primary
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
MW-101B
MW-101B 130305 26.5 FT
03/05/2013
Primary
1.0 u
1.0 u
3.0
5.0 U
1.0 u
MW-102
MW-102 130305 20 FT
03/05/2013
Primary
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
MW-103
MW-103 130306
03/06/2013
Primary
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
MW-104A
MW-104A 130307
03/07/2013
Primary
1.0 u
1.0 u
8.0
5.0 U
1.0 u
MW-104B
MW-104B 130311
03/11/2013
Primary
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
MW-107
MW-107 130306
03/06/2013
Primary
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
MW-109
MW-109 130305
03/05/2013
Primary
1.0 u
1.0 u
15
5.0 U
1.0 u
MW-110
DUP-1 130306
03/06/2013
Duplicate
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
MW-110
MW-110 130306
03/06/2013
Primary
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
MW-111
MW-111 130307
03/07/2013
Primary
1.0 u
1.0 u
9.1
5.0 U
1.0 u
MW-4A
MW-4A 130312
03/12/2013
Primary
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
MW-4B
MW-4B 130312
03/12/2013
Primary
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
MW-93-02
MW-93-02 130312
03/12/2013
Primary
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
MW-96-15
MW-96-15 130307
03/07/2013
Primary
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
MW-96-16
MW-96-16 130306
03/06/2013
Primary
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
MW-96-17
MW-96-17 130306
03/06/2013
Primary
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
MW-ES-02
MW-ES-02 130307
03/07/2013
Primary
1.0 u
1.0 u
38
5.0 U
1.0 u
MW-ES-03
DUP-2 130307
03/07/2013
Duplicate
1.0 u
1.0 u
20
5.0 U
1.0 u
MW-ES-03
MW-ES-03 130307
03/07/2013
Primary
1.0 u
1.0 u
17
5.0 U
1.0 u
MW-ES-04
MW-ES-04 130308
03/08/2013
Primary
1.0 u
1.0 u
0.56 J
5.0 U
1.0 u
MW-ES-05
MW-ES-05 130308
03/08/2013
Primary
1.0 u
1.0 u
27
5.0 U
1.0 u
MW-ES-06
MW-ES-06 130308
03/08/2013
Primary
1.0 u
1.0 u
0.97 J
5.0 U
1.0 u
MW-ES-07
MW-ES-07 130305 30 FT
03/05/2013
Primary
1.0 u
1.0 u
3.9
5.0 U
1.0 u
MW-ES-08
MW-ES-08 130305
03/05/2013
Primary
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
MW-ES-09
MW-ES-09 130311
03/11/2013
Primary
1.0 u
1.0 u
120
5.0 U
1.0 u
MW-ES-10
MW-ES-10 130311
03/11/2013
Primary
1.0 u
1.0 u
37
5.0 U
1.0 u
MW-ES-11
MW-ES-11 130306
03/06/2013
Primary
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
MW-UI
MW-UI 130305
03/05/2013
Primary
1.0 u
1.0 u
8.1
5.0 U
1.0 u
PZ-704
PZ-704 130313
03/13/2013
Primary
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
PZ-709
PZ-709 130313
03/13/2013
Primary
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
PZ-715
PZ-715 130313
03/13/2013
Primary
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
PZ-719
DUP-4 130314
03/14/2013
Duplicate
1.0 u
1.0 u
1.5
5.0 U
1.0 u
PZ-719
PZ-719 130314
03/14/2013
Primary
1.0 u
1.0 u
1.6
5.0 U
1.0 u
PZ-720
PZ-720 130314
03/14/2013
Primary
1.0 u
1.0 u
5.0
5.0 U
1.0 u
PZ-721
PZ-721 130314
03/14/2013
Primary
1.0 u
1.0 u
30
5.0 U
1.0 u
PZ-722
PZ-722 130314
03/14/2013
Primary
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
PZ-723
PZ-723 130314
03/14/2013
Primary
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
PZ-724
PZ-724 130314
03/14/2013
Primary
1.0 u
1.0 u
32
5.0 U
1.0 u
PZ-725
PZ-725 130314
03/14/2013
Primary
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
PZ-726
PZ-726 130312
03/12/2013
Primary
1.0 u
1.0 u
2.7
5.0 U
1.0 u
PZ-728
PZ-728 130307
03/07/2013
Primary
1.0 u
1.0 u
4.7
5.0 U
1.0 u
RPZ-730
RPZ-730 130313
03/13/2013
Primary
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
RPZ-731
RPZ-731 130313
03/13/2013
Primary
1.0 u
1.0 u
0.60 J
5.0 U
1.0 u
RPZ-732
RPZ-732 130312
03/12/2013
Primary
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
WDOT-MW-1
WDOT-MW-1 130307
03/07/2013
Primary
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
WDOT-MW-2
WDOT-MW-2 130306
03/06/2013
Primary
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
Notes: ug/L = micrograms per liter; U = not detected at or above the reported detection limit; R = rejected result; J = estimated
result detected below the reporting detection limit and above the method detection limit;
BOLD = detected result above the method detection limit.
PAGE 3 OF 3
-------
-------
Table A-3
March 2013 Subdrain Sample Results
Palermo Wellfield Superfund Site, Tumwater,
Washington
1,1,1,2-Tetrachloroethane
1,1,1-Trichloroethane
1,1,2,2-Tetrachloroethane
1,1,2-Trichloro-1,2,2-trifluoroethane (CFC-113)
1,1,2-Trichloroethane
1,1-Dichloroethane
1,1-Dichloroethene
1,1 -Dichloropropene
1,2,3-Trichlorobenzene
1,2,3-Trichloropropane
1,2,4-Trichlorobenzene
1,2,4-Tri methyl benzene
1,2-Dibromo-3-Chloropropane
1,2-dibromoethane (EDB)
1,2-Dichlorobenzene (o-Dichlorobenzene)
1,2-Dichloroethane (EDC)
1,2-Dichloropropane
1,3,5-Tri methyl benzene
1,3-Dichlorobenzene (m-Dichlorobenzene)
1,3-Dichloropropane
1,4-Dichlorobenzene (p-Dichlorobenzene)
2,2-Dichloropropane
2-Butanone (MEK)
2-Chloroethyl vinyl ether
2-Chlorotoluene
4-Chlorotoluene
4-Methyl-2-Pentanone (Methyl isobutyl ketone)
Acetone
Acrolein
Acrylonitrile
Benzene
Benzene, 1,2,3-Trimethyl-
Bromobenzene
Bromodichloromethane
Bromoform (Tribromomethane)
Bromomethane
Carbon Tetrachloride
Chlorobenzene
Chloroethane
Chloroform
Chloromethane
cis-1,2-Dichloroethene
Cis-1,3-Dichloropropene
Dibromochloromethane
Location 1 Sample ID 1 Date 1 Tvoe
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
Sub-Drain System
357
357 130308
03/08/2013
N
1.0 U
1.0 u
1.0 u
1.0 UJ
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
2.5 U
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
10 u
50 U
1.0 u
1.0 u
10 u
50 U
50 U
10 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
5.0 U
5.0 U
2.5 U
1.0 u
1.0 u
1.0 u
357
DUP-3 130308
03/08/2013
FD
1.0 U
1.0 u
1.0 u
1.0 UJ
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
2.5 U
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
10 u
50 U
1.0 u
1.0 u
10 u
50 U
50 U
10 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
5.0 U
5.0 U
2.5 U
1.0 u
1.0 u
1.0 u
358
358 130308
03/08/2013
N
1.0 U
1.0 u
1.0 u
1.0 UJ
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
2.5 U
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
10 u
50 U
1.0 u
1.0 u
10 u
50 U
50 U
10 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
5.0 U
5.0 U
2.5 U
1.0 u
1.0 u
1.0 u
359
359 130308
03/08/2013
N
1.0 U
1.0 u
1.0 u
1.0 UJ
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
2.5 U
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
10 u
50 U
1.0 u
1.0 u
10 u
50 U
50 U
10 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
5.0 U
5.0 U
2.5 U
1.0 u
1.0 u
1.0 u
360
360 130308
03/08/2013
N
1.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
2.5 U
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
10 u
50 U
1.0 u
1.0 u
10 u
50 U
50 U
10 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
5.0 U
5.0 U
2.5 U
1.0 u
1.0 u
1.0 u
350
350 130308
03/08/2013
N
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
2.5 U
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
10 u
50 U
1.0 u
1.0 u
10 u
50 U
50 U
10 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
5.0 U
5.0 U
2.5 U
1.0 u
1.0 u
1.0 u
356
356 130308
03/08/2013
N
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
2.5 U
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
10 u
50 U
1.0 u
1.0 u
10 u
50 U
50 U
10 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
5.0 U
5.0 U
2.5 U
1.0 u
1.0 u
1.0 u
361
361 130308
03/08/2013
N
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
2.5 U
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
10 u
50 U
1.0 u
1.0 u
10 u
50 U
50 U
10 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
5.0 U
5.0 U
2.5 U
1.0 u
1.0 u
1.0 u
364
364 130308
03/08/2013
N
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
2.5 U
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
10 u
50 U
1.0 u
1.0 u
10 u
50 U
50 U
10 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
5.0 U
5.0 U
2.5 U
1.0 u
1.0 u
1.0 u
Seeps
Seep 1
SEEP-1
03/19/2013
N
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 UJ
2.5 U
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
10 u
50 U
1.0 u
1.0 u
10 u
50 U
50 U
10 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
5.0 U
5.0 U
2.5 U
1.0 u
1.0 u
1.0 u
Seep 2
SEEP-2
03/19/2013
N
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 UJ
2.5 U
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
10 u
50 U
1.0 u
1.0 u
10 u
50 U
50 U
10 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
5.0 U
5.0 U
2.5 U
1.0 u
1.0 u
1.0 u
Seep 3
SEEP-3
03/19/2013
N
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 UJ
2.5 U
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
10 u
50 U
1.0 u
1.0 u
10 u
50 U
50 U
10 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
5.0 U
5.0 U
2.5 U
1.0 u
1.0 u
1.0 u
Seep 5
DUP-5 130319
03/19/2013
FD
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 UJ
2.5 U
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
10 u
50 U
1.0 u
1.0 u
10 u
50 U
50 U
10 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
5.0 U
5.0 U
2.5 U
1.0 u
1.0 u
1.0 u
Seep 5
SEEP-5
03/19/2013
N
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 UJ
2.5 U
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
10 u
50 U
1.0 u
1.0 u
10 u
50 U
50 U
10 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
5.0 U
5.0 U
2.5 U
1.0 u
1.0 u
1.0 u
Wellfield Samples
ST-2
ST-2 130307
03/07/2013
N
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
2.5 U
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
10 u
50 U
1.0 u
1.0 u
10 u
50 U
50 U
10 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
5.0 U
5.0 U
2.5 U
1.0 u
1.0 u
1.0 u
TW-4
TW-4 130307
03/07/2013
N
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
2.5 U
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
10 u
50 U
1.0 u
1.0 u
10 u
50 U
50 U
10 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
5.0 U
5.0 U
2.5 U
1.0 u
1.0 u
1.0 u
TW-5
TW-5 130307
03/07/2013
N
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
2.5 U
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
10 u
50 U
1.0 u
1.0 u
10 u
50 U
50 U
10 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
5.0 U
5.0 U
2.5 U
1.0 u
1.0 u
1.0 u
TW-8
TW-8 130307
03/07/2013
N
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
2.5 U
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
10 u
50 U
1.0 u
1.0 u
10 u
50 U
50 U
10 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
1.0 u
5.0 U
5.0 U
2.5 U
1.0 u
1.0 u
1.0 u
PAGE 1 OF 2
-------
Table A-3
March 2013 Subdrain Sample Results
Palermo Wellfield Superfund Site, Tumwater,
Washington
Dibromo methane
Dichlorodifluoromethane (CFC-12)
Diisopropyl Ether (Dot)
Ethyl benzene
Hexachlorobutadiene
Isopropylbenzene (Cumene)
Methyl t-butyl ether
Methylene Chloride
Naphthalene
n-Butyl benzene
n-Propylbenzene
p-lsopropyltoluene
Sec-Butyl benzene
Styrene
Tert-Butylbenzene
Tetrachloroethene
Toluene
Total Xylenes
Trans-1,2-Dichloroethene
Trans-1,3-Dichloropropene
Trichloroethene (TCE)
Trichlorofluoromethane (CFC-11)
Vinyl Chloride
Location I Sample ID I Date I Tvoe
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
Sub-Drain System
357
357 130308
03/08/2013
N
1.0 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
7.5
5.0 U
3.0 U
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
357
DUP-3 130308
03/08/2013
FD
1.0 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
7.3
5.0 U
3.0 U
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
358
358 130308
03/08/2013
N
1.0 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
10
5.0 U
3.0 U
1.0 u
1.0 u
16
5.0 U
1.0 u
359
359 130308
03/08/2013
N
1.0 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
6.5
5.0 U
3.0 U
1.0 u
1.0 u
13
5.0 U
1.0 u
360
360 130308
03/08/2013
N
1.0 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.3
5.0 U
3.0 U
1.0 u
1.0 u
11
5.0 U
1.0 u
350
350 130308
03/08/2013
N
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
3.0 U
1.0 u
1.0 u
1.1
5.0 U
1.0 u
356
356 130308
03/08/2013
N
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
3.0 U
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
361
361 130308
03/08/2013
N
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
3.0 U
1.0 u
1.0 u
0.83 3
5.0 U
1.0 u
364
364 130308
03/08/2013
N
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
3.0 U
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
Seeps
Seep 1
SEEP-1
03/19/2013
N
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
3.0 U
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
Seep 2
SEEP-2
03/19/2013
N
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
3.0 U
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
Seep 3
SEEP-3
03/19/2013
N
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
15
3.0 U
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
Seep 5
DUP-5 130319
03/19/2013
FD
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
3.0 U
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
Seep 5
SEEP-5
03/19/2013
N
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
3.0 U
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
Wellfield Samples
ST-2
ST-2 130307
03/07/2013
N
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
3.0 U
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
TW-4
TW-4 130307
03/07/2013
N
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
3.0 U
1.0 u
1.0 u
1.7
5.0 U
1.0 u
TW-5
TW-5 130307
03/07/2013
N
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
3.0 U
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
TW-8
TW-8 130307
03/07/2013
N
1.0 u
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
5.0 U
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
1.0 u
5.0 U
3.0 U
1.0 u
1.0 u
1.0 u
5.0 U
1.0 u
Notes:
uq/L = micrograms per liter
U = not detected at or above the reported
detection limit
R = rejected result
J = estimated result detected below the
reportinq detection limit and above
the method detection limit
BOLD = detected result above the method
detection limit.
PAGE 2 OF 2
-------
Appendix B
2013 Five-Year Review Interviews
-------
-------
Palermo Wellfield Superfund Site 3r,i five-Year Review
Site Inspection Sign-In
April 24,2013
W&C '¦! f'-O ; |;A
EMAIL/PHONE
;tl 1 >b '/
*A~>A L,\ f» C. ^ n, eVn • < i:
;
|S5«?, j #• # ••» n 0 4 »5+". ^' v*Jj
(
](k#t. S^t#i
" i,....,„»,.
S?k.V....: ...... I V>..^
: i \
j-''
iJii»;?£lS-
' ¦ ; ¦. -¦' . / ' ;' . , i j
! I'Ti ^
. - .. . % .. . -A . ¦
1 t - 1 W--v.uj»c4rJit< (Lu^^y'.;
i „ „r
]iC&SfMirki?Cf*,HiirniA&£€S* ufK, •
. -
-------
-------
PALERMO WELLFIELD SUPERFUND SITE
THRID FIVE-YEAR REVIEW
INTERVIEW QUESTIONNAIRE
Name: Steve Craig Title: Operations Manager
Organization: City of Tumwater Date: June 3, 2013
Telephone/Email: 360-754-4150 / scraig@ci.tumwater. wa.us
1. What is your overall impression of the functioning of the remedy (subdrain and treatment
lagoon, wellfield air stripper)
Good - facility operates as designed and remedies have proven to be reliable.
2. Can you describe updates or planned changes to either remedy component since the last Five
Year Review?
• Extended treatment building to close exposed piping.
• Added chlorination injection to process.
• Upgraded telemetry & control systems to current standards.
3. Have there been any significant changes in the O&M requirements, maintenance schedules, or
sampling routines since start-up or in the last five years? If so, do they affect the protectiveness
or effectiveness of the remedy? Please describe changes and impacts.
No significant changes.
4. Have there been unexpected O&M difficulties or costs at the site since start-up or in the last
five years? If so, please give details.
None.
5. Have there been opportunities to optimize O&M, or sampling efforts? Please describe
changes and resultant or desired cost savings or improved efficiency.
WA Department of Health compliance testing has reduced frequency of VOC monitoring
requirements, as the facilities have proven to be effectively removing TCE.
6. Do you have any comments, suggestions, or recommendations regarding the project?
Improve safe access to tower exhaust vents for routine inspection and maintenance.
7. Are you aware of any concerns from the local community regarding the Site and the 0& M of
the remedy?
-------
No.
8. Has the city of Tumwater responded to any complaints, violations, or other incidents related
to the remedy?
No.
9. Do you have any additional comments, suggestions or recommendations regarding remedy
operation?
• Improve maintenance procedures for accessing and cleaning underdrain system
behind houses on Rainier St.
-------
PALERMO WELLFIELD SUPERFUND SITE
THRID FIVE-YEAR REVIEW
INTERVIEW QUESTIONNAIRE
Name: Dan Smith Title: Water Resources Program Manager
Organization: City of Tumwater Date: June 3, 2013
Telephone/Email: 360-754-4140 / desmith@ci. tumwater. wa.us
1. What is your overall impression of the functioning of the remedy (subdrain and treatment
lagoon, wellfield air stripper)
Overall, my impression is that the remedies continue to work well. From a potable water
distribution perspective, we see the air strippers work well, with zero detections of VOC
compounds leaving the wellfield into our distribution system. Maintenance of all
components is relatively simple and our crews are kept informed of EPA/WSDOT/ECY
needs for access and procedure changes.
2. Can you describe updates or planned changes to either remedy component since the last Five
Year Review?
Since the last review, the City undertook a major system-wide retrofit to add 12.5%
sodium hypochlorite as a disinfectant. As part of this project, the air stripper towers and
associated controls were enclosed inside the treatment building, improving function,
maintenance and security. Telemetry and control standards have been upgraded to utilize
current technologies.
3. Have there been any significant changes in the O&M requirements, maintenance schedules, or
sampling routines since start-up or in the last five years? If so, do they affect the protectiveness
or effectiveness of the remedy? Please describe changes and impacts.
No. The City continues to follow O&M schedules and standards and maintain water
quality sampling requirements as required annually by WA Department of Health.
4. Have there been unexpected O&M difficulties or costs at the site since start-up or in the last
five years? If so, please give details.
A couple of items have been raised, including:
• Access to the underdrain system for maintenance has become challenging, as the
City does not own the equipment necessary for maintenance. When access and/or
maintenance is required, the City needs to rent appropriate equipment. Emergency
access/maintenance may be delayed.
• When maintaining the exhaust stacks, staff have expressed concern that the vent
doors open skyward. In the event of rains, atmospheric settling or other "overhead"
-------
issues, could be a potential source of contamination. Staff have recommended
design revisions to include a vent opening horizontal to the building to protect against
potential overhead contamination.
5. Have there been opportunities to optimize O&M, or sampling efforts? Please describe
changes and resultant or desired cost savings or improved efficiency.
No, the routine maintenance has been optimized over the operation to date and is
consistent and well understood by maintenance staff. Enclosing the air stripper towers
has helped with parts freezing experienced during winter months.
6. Do you have any comments, suggestions, or recommendations regarding the project?
A comment re: employee safety would be to improve accessibility to the exhaust collar
for routine maintenance.
7. Are you aware of any concerns from the local community regarding the Site and the 0& M of
the remedy?
We occasionally receive questions from the general Palermo Valley community re:
operations at the wellfield and water quality. No major concern has been raised, to my
knowledge.
8. Has the city of Tumwater responded to any complaints, violations, or other incidents related
to the remedy?
None.
9. Do you have any additional comments, suggestions or recommendations regarding remedy
operation?
• Evaluate maintenance approach for routine maintenance of underdrain system, and
provide recommendations for more efficient operation.
• Consider safety improvements for routine maintenance of exhaust stacks on the air
stripper towers.
-------
PALERMO WKLLFIELI) SUPEUFl'ND SITE
THRU) FIVE-YEAR REVIEW
INTERVIEW QUESTIONNAIRE
>amc: Nick Kohrhach Title: Project Manager
Organization: __ GeoEngintcrs. inc. Date: 05-02-1J
Telephone/fc'.mnil: {2531 383-4940'nrohrbach a geoenginrer.s.cum
1, What Is your overall impression of the functioning of the remedy (subdrain and treatment
lagoon, wcllficld air stripper I?
Our overall impression of the remedy is as follows:
1 > The subdrain system does not seem to he functioning as designed {based on recent
groundwater elevation information teg groundwater elevations appear to not be
lowered'drawn down around the southern portion of the subdrain system) and previous
EPA observations (e.g. it portion of the subdrain system has been observed to have
differing flow rates between drainage structures)) and requires an assessment of it's
overall function. It is anticipated that the subdrain system will he investigated daring the
Data Gaps Investigation field work to troableshoot the subdrain issues.
~) The treatment lagoon appears to be functioning and generally meeting it s intended
remedial goals bused on the most recent water sampling results collected in March 3d}3,
Furthermore, the City ofTumwater has indicated the treatment lagoon equipment is
currently in proper running order.
3) The well field air strippers appear to be maintained and operated in accordunce with the
remedial action goals for the site based on a review of previous performance data (water
sampling results) ami observations made during the site inspection activities of the
facility on 04/24,13 This portion of the remedy appears to be achieving it's intended
goal for protecting the City ofTumwater ',y drinking water.
2. Can you describe updates or plamied changes to cither remedy component since the last Five
Year Review?
Geo Engineer v understands that a warning sign was posted at the treatment lagaonjacility^ g
property title search was completed and a restrictive covenant for the Superfimd site was
initiated (but not completed) since the last Five Year Review.
3.1 lave there been any significant changes in tlie O&M requirements, maintenance schedules, or
sampling routines since start-up or in the last five years? If so, do they affect the proteciiveness
or effectiveness of the remedy? Please describe changes and impacts.
Significant changes,
-------
1 JhL$wyn£ in 2013, iieoLngitieers (on behalf of IVSDOT) began performing the Se/m-
Annua! Groundwater Monitoring and the Suhdraiti and Treatment Lagoon O&M
sampling for the site.
*"' ik'oEngineers understands that EPA performed the monitoring and sampling associated
with the suhdrain and treatment lagoon between 2009 and 2012 and that during that
timeframe, vegetation management along the bluff ami at the treatment lagoon were
performed by the City ofTumwater on an annuaI basis at the request of EPA. Vegetation
management will continue to he requested annually or on an as needed basis by
Neither of these changes affect the proteetiveness or the effectiveness of the remedy.
4. Have there been unexpected O&M difficulties or costs at the site since start-up or in the last
five years? If so, please give details.
At this time, EPA has indicated an issue with flow rates between drainage structures within
suhdrain system (along the northern boundary of the Palermo neighborhood). JVe understand
that this (low rate issue requires additional investigation to trouhleshoot potential suhdrain
system maintenance or repair work.
No other O&M difficulties are known at this time,
5. Have there been opportunities to optimi/e O&M. or sampling efforts? Piease describe
changes and resultant or desired cost savings or improved efficiency.
GeoEngineers is utilizing a rental home within the Palermo neighborhood to streamline field
work activities and provide a field office when performing (MM and sampling efforts. This
rental home provides efficiencies for field staff and storage of equipment and supplies instead of
driving equipment'supplies/samples on a daily basis. The rental home has also provided a venue
for collecting 'control' air samples during the recent March 20IS air sampling activities.
6. Do you have any comments, suggestions, or recommendations regarding the project?
Vegetation, particularly at the lagoon, is heavy and makes it extremely difficult to locate (he
brass markers used to identify the transect locations Presently the transect markers are located
by wooden stakes that are easily removed. GeoEngineers suggests re-establishing the brass
markers by adding an extension or other permanent post that can be seen from at least 12 inches
or more above ground surface,
7. Are you aware of any concerns from the local community regarding the Site and the 0& M of
the remedy?
GeoEngineers representatives recently completed air sampling activities (March 2013 - Ajvij
2013} in 30 homes. Some homeowners or tenants were unaware thai they lived within a
Superfund site. Other homeowners or tenants expressed their anger that their health problems
or property values may be negatively impacted by the contaminated groundwater. Most
-------
were happy that remedies were currently in-nlure and hrinv nnhvh-
monitored
8. Has the city ol 1 um water responded to any complaints, violations, or other incidents related
to the remedy?
City ofTumwaier responses to any complaints, violations, or other
incidents related to the remedy,
9, Do you have any additional comments, suggestions or recommendations regarding remedy
operation?
Geo Engineers does not have any additional comments, suggestions or recommendations
regarding the remedy operation at this time.
-------
-------
PALERMO WELLFIELD SUPERFUND SITE
THIRD FIVE-YEAR REVIEW
INTERVIEW QUESTIONNAIRE
Name: _Barbara Trejo Title: _Health Assessor/Hydrogeologist
Organization: _Washington Department of Health Date: _May 6, 2013.
Telephone/Email: _360-236-3373
1.What is your overall impression of the project?
Overall, EPA is taking good steps to further characterize the site and assess the potential health
threat.
2. Have there been routine communications or activities (site visits, inspections, reporting
activities, etc.) conducted by your office regarding the site? If so, please provide
results.
The Washington Department of Health has not conducted any routine communications or
activities regarding this site.
3. Have there been any complaints, violations, or other incidents related to the site requiring a
response by your office? If so, please give details of the events and results of the responses.
The Washington Department of Health has not received any complaints, violations, or other
incidents requiring our response.
4. Do you feel well informed about the site's activities and progress?
Yes - EPA's project manager keeps DOH well informed.
5. Do you have any comments, suggestions, or recommendations regarding the site's
management or operation?
None
-------
-------
Appendix C
2013 Five-Year Review Site Inspection Checklist
-------
-------
Site Inspection Checklist
1. SITE INFORMATION
Site name: Palermo Wellfield Superfund Site
Date of inspection: April 24, 2013
Location and Region: Tumwater, WA
EPA ID: WAD0000026534
Agency, office, or company leading the five-year review:
Weather/temperature: Sunny, 60°F
EPA Region 10
Remedy Includes: (Check all that apply)
15^1 Soil Vapor Extraction System at Southgate Dry Cleaners-Dismantled
^ Wellhead Treatment System at Palermo Wellfield
^ French Drain and Aeration Lagoon
^ Public Notice of Groundwater Contamination
1^1 Long-term Groundwater Monitoring
1^1 Deed Restriction at Southgate Dry Cleaners-Not recorded to date
Attachments: Inspection team roster attached Q Site map attached
II. INTERVIEWS (Check all that apply)
City of Tumwater
1. Citv O&M site manager: Steve Craig
Ooerations Manager Mav2013
Name
Title
Date
Interviewed £3 at site O at office
1 1 by phone
Phone no.
15^1 by email
Problems, suggestions; O Report attached
See Five-Year Review Report
2. City O&M staff:
Name
Title
Date
Interviewed O at site O at office
1 1 by phone
Phone no.
1 1 by email
Problems, suggestions; Q Report attached
3. Other Citv staff: Dan Smith
Water Resources Program Manager May 2013
Name
Title
Date
Interviewed at site O at office
1 1 by phone
Phone no.
1^1 by email
Problems, suggestions; O Report attached
See Five-Year Review Report
Washington State Department of Ecology-Not present at site inspection
4. Ecology Project Manager: Guv Barrett
Site Manager
May 2013
Name
Title
Date
Interviewed O at site O at office
1 1 by phone
Phone no.
15^1 by email
Problems, suggestions; O Report attached
See Five-Year Review Report
Washington State Department of Transportation
5. WSDOT Staff: Norm Pavton
Site Manager
May 2013
Name
Title
Date
Interviewed at site O at office
1 1 by phone
Phone no.
1^1 by email
Problems, suggestions; O Report attached
See Five-Year Review Reoort
GeoEngineers
6. GeoEngineers Staff: Norm Rohrbach
Proiect Manager
May 2013
Name
Title
Date
Interviewed Kl at site O at office
1 1 by phone
Phone no.
1^1 by email
Problems, suggestions; O Report attached
See Five-Year Review Report
-------
Washington Department of Health-Not present at site inspection
7. DOH Staff: BarbaraTrejo Health Assessor/Hydrogeologist Mav2013
Name Title
Date
Interviewed O at site O at office O by phone
Phone no. ^ by email
Problems, suggestions; O Report attached
See Five-Year Review Report
III. ON-SITE DOCUMENTS & RECORDS VERIFIED (Check all that apply)
1. O&M Documents for Air Stripper (City of Tumwater)
1X1 O&M manual
Rl Readily available
IXI Up to date
~ N/A
Rl As-built drawings
Rl Readily available
Rl Up to date
~ N/A
1X1 Maintenance logs
1X1 Readily available
1X1 Up to date
~ N/A
Remarks: O&M documents are computerized and kept at the City office in Tumwater.
2. Permits for Air Stripper
I | Air discharge permit
I | Readily available
I | Up to date
E3 N/A
I | Effluent discharge
I | Readily available
I | Up to date
E3 N/A
1 1 Waste disposal, POTW
1 1 Readily available
1 1 Up to date
^ N/A
1 1 Other permits
1 1 Readily available
1 1 Up to date
^ N/A
Remarks: No permits are reauired.
3. Discharge Compliance Records for Air Strippers
~ Air
1 1 Readily available
I | Up to date
E3 N/A
^ Water (effluent)
1X1 Readily available
^ Up to date
~ N/A
Remarks: No air discharge sampling reauired. Water sampling data is maintained at the City office.
4. O&M Documents for French Drain and Lagoon (Ecology)
IXI O&M manual
1X1 Readily available
IXI Up to date
~ N/A
1X1 As-built drawings
1X1 Readily available
IXI Up to date
~ N/A
1X1 Monitoring/status reports
1X1 Readily available
1X1 Up to date
~ N/A
Remarks: These documents are available at the City office in Tumwater and at WSDOT.
IV. INSTITUTIONAL CONTROLS
1. Implementation and enforcement (Southgate Dry Cleaners)
Site conditions imply ICs not properly implemented
~ Yes ^ No ~ N/A
Site conditions imply ICs not being fully enforced
~ Yes ^ No ~ N/A
Type of monitoring (e.g., self-reporting, drive by)
Not reauired.
Reporting is up-to-date
~ Yes ~ No £3 N/A
Reports are verified by the lead agency
~ Yes ~ No N/A
Specific requirements in deed or decision documents have been met
~ Yes ^ No ~ N/A
Violations have been reported
~ Yes ~ No ^ N/A
Other problems or suggestions: O Report attached
The deed restriction is not recorded. An additional investigation is being conducted that
mav determine if the deed restriction is necessarv.
2. Implementation-public notice of contaminated groundwater
Notification performed?
^ Yes ~ No ~ N/A
Documentation of notification available?
^ Yes ~ No ~ N/A
Type of monitoring (e.g., self-reporting, drive by)
Not reauired.
Reporting is up-to-date
~ Yes ~ No ^ N/A
Reports are verified by the lead agency
~ Yes ~ No ^ N/A
Other problems or suggestions: ~ Report attached
~ Yes ~ No ~ N/A
EPA issued a factsheet to area well drillers in 1999. In 2013 EPA conducted door-to-door
visits with Palermo residents to gain property access for supplemental RI/FS activities.
-------
3. Adequacy ICs are adequate ~ ICs are inadequate ~ N/A
Remarks: Currently, no deed restriction is recorded for the Southgate Dry Cleaners. However, land use has not changed since the ROD.
4. Land use changes on site Q Changes observed ^ No changes observed
Remarks: Land use has not changed since the ROD. At the dry cleaners site, asphalt pavement remains intact.
V. SOIL VAPOR EXTRACTION SYSTEM AT SOUTHGATE DRY CLEANERS
1. Implementation
15^1 Installed and operated per ROD
15^1 Documentation of results available
2. Current Status
1^1 Status is: Decommissioned
1^1 Record of current status available
Remarks:
3. Results (summarize results of SVE system)
Approximately 425 lbs of PCE removed by SVE system. Confirmation sampling detected residual PCE concentrations in soil above
cleanup limits. A new investigation is being conducted in 2013 to investigate potential PCE sources in vadose zone and/or groundewater.
VI. WELLHEAD TREATMENT SYSTEM
1. Treatment Train (Check components that apply)
~ Metals removal ~ Oil/water separation
15^1 Air stripping ~ Carbon adsorbers
15^1 Filters Air used by air strippers is filtered
1^1 Additive (e.g., chelation agent, flocculent) Disinfection
1^1 Others Asorbic acid used to strip build-up (chlorite, etc.) from media in the strippers.
Rl Good condition ~ Needs Maintenance
Rl Sampling ports properly marked and functional
1^1 Sampling/maintenance log displayed and up to date
1^1 Equipment properly identified
1^1 Quantity of groundwater treated annually
~ Quantity of surface water treated annually
Remarks: Housing constructed around stripper towers to enclose piping and valves.
2. Electrical Enclosures and Panels (properly rated and functional)
~ N/A Good condition ~ Needs Maintenance
Remarks:
3. Air Stripper and Appurtenances
~ N/A ^ Good condition ~ Proper secondary containment ~ Needs Maintenance
Remarks: Maintenance was being conducted on day of site inspection.
4. Discharge Structure and Appurtenances
~ N/A Good condition ~ Needs Maintenance
Remarks:
5. Treatment Building(s)
~ N/A Good condition ~ Needs Repair
15^1 Chemicals and equipment properly stored
Remarks:
6. Current Status
Transfer from EPA to City complete?
~ Yes Date of transfer:
No Expected date of transfer: Not reported.
Remarks:
7. Results (summarize monitoring data for Wellhead Treatment System)
Remarks: System is performing as designed. Neither PCE nor TCE has been detected in treated effluent.
-------
VII. SUBDRAIN AND TREATMENT LAGOON
1. Inlet to Lagoon Pipe Inspected ^ Functioning ~ N/A
Remarks:
2. Inlet Pipe Riprap Rock Inspected Functioning ~ N/A
Remarks:
3. Siltation Areal extent Depth _ ~ N/A Siltation not evident
Remarks:
4. Erosion Areal extent Depth _ ~ N/A Erosion not evident
Remarks:
5. Outlet Weir ^Functioning I I N/A
Remarks:
6. Aerators 1^1 All three functioning ~ Less than three functioning ~ None Functioning
Remarks: Only 2 of the 3 aerators are operated at a time.
7. Plantings 1^1 Growing and healthy 1^1 Effectively reducing erosion
Rl Meeting aesthetic goals ^ Invasive weeds controlled
Remarks:
8. Fencing Intact, gates locked ~ Damaged or unlocked
Remarks: Warning sign on fence displays wrong EPA contact.
9. Real Property and Easements
Transfer from EPA to City complete?
~ Yes Date of transfer:
No Expected date of transfer: Not reported.
Remarks:
10. Results (summarize monitoring data for Subdrain and Lagoon)
The system is not completely functioning as intended. The 3-foot compliance level is not met at two homes at the south end of Rainier
Avenue. A new investigation of indoor air is currently being conducted by WSDOT. Results from the first round of sampling should be
available by late summer/early fall 2013.
VIII. LONG-TERM MONITORING
1. Monitoring Wells
^ Properly secured/locked ^Functioning ^ Routinely sampled Rl Good condition
1^1 All required wells located Needs Maintenance ~ N/A
Remarks: Some wells require minor maintenance, but overall in good condition.
2. Long-term monitoring data
Rl Is routinely submitted on time ^ Is of acceptable quality
3. Long-term monitoring data suggests:
~ Groundwater plume is effectively contained Containment concentrations are declining ~ Biodegradation is occurring
Remarks: There is little evidence that biodegradation is occurring. Insufficient data to assess if the groundwater plume is effectively
contained. A supplemental RI/FS is being conducted by WSDOT to evaluate the effectiveness of plume containment.
IX. OVERALL OBSERVATIONS
A. Implementation of the Remedy
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.).
See Five-Year Review Report.
B. Adequacy of O&M
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.).
See Five-Year Review Report.
-------
C. Early Indicators of Potential Remedy Problems
Describe issues and observations such as unexpected changes in the cost or scope of O&M or a high frequency of unscheduled repairs,
which suggest that the protectiveness of the remedy may be compromised in the future.
See Five-Year Review Report.
D. Opportunities for Optimization
Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy.
See Five-Year Review Report.
-------
------- |