Fourth Five-year Review Report for Jennison-wright Corporation Superfund Site Madison County Illinois


FOURTH FIVE-YEAR REVIEW REPORT FOR
JEMNISON-WRIGHT CORPORATION SUPERFUND SITE
MADISON COUNTY, ILLINOIS

Illinois Environmental Protection Agency
Springfield, Illinois

For

U.S. Environmental Protection Agency
Region 5
Chicago, Illinois

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Prepared by

9/26/2024

X Douglas Ballotti

Douglas Ballotti, Director

Super-fund & Emergency Management Division

Signed by: DOUGLAS BALLOTTI

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e of Contents

LIST OF ABBREVIATIONS & ACRONYMS	2

I.	INTRODUCTION	4

Site Background	4

FIVE-YEAR REVIEW SUMMARY FORM	5

II.	RESPONSE ACTION SUMMARY	6

Basis forTaking Action	6

Response Actions	8

Status of Implementation	12

Institutional Controls	17

Systems Operations/Operation & Maintenance	18

III.	PROGRESS SINCE THE LAST REVIEW	19

OTHER FINDINGS	24

IV.	FIVE-YEAR REVIEW PROCESS	26

Community Notification, Involvement & Site Interviews	26

Data Review	26

Site Inspection	30

V.	TECHNICAL ASSESSMENT	31

QUESTION A: Is the remedy functioning as intended by the decision documents?	31

QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action

objectives (RAOs) used at the time of the remedy selection still valid?	32

QUESTION C: Has any other information come to light that could call into question the
protectiveness of the remedy?	33

VI.	ISSUES/RECOMMENDATIONS	33

OTHER FINDINGS	37

VII.	PROTECTIVENESS STATEMENT	37

VIII.	NEXT REVIEW	38

APPENDICES

APPENDIX A - REFERENCE LIST

APPENDIX B - SITE LOCATION AND LAYOUT FIGURES

APPENDIX C - MUNICIPAL ORDINANCE

APPENDIX D - AERIAL PHOTOGRAPH SITE PARCELS

APPENDIX E - INSTITUTIONAL CONTROL AREAS FIGURE

APPENDIX F - PUBLIC NOTICE

APPENDIX G - MONITORING WELL LOCATION MAP

APPENDIX H - GROUNDWATER DATA

APPENDIX I - PCP PROCESS AREA FIGURE

APPENDIX J - SITE INSPECTION CHECKLIST AND PHOTOGRAPHS

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LIST OF ABBREVIATIONS & ACRONYMS

ACM	Asbestos Containing Material
Alpha-BHC Alpha-hexachlorocyclohexane

ARAR	Applicable or Relevant and Appropriate Requirement

AST	Aboveground Storage Tank

bgs	Below Ground Surface

CERCLA	Comprehensive Environmental Response, Compensation, and Liability Act

CFR	Code of Federal Regulations

COC	Contaminant of Concern

COPC	Contaminant of Potential Concern

CUO	Clean Up Objective

EE/CA	Engineering Evaluation/Cost Analysis

E&E	Ecology & Environment Engineering, Incorporated

EPA	United States Environmental Protection Agency

ERA	Environmental Risk Assessment

ESD	Explanation of Significant Differences

FYR	Five-Year Review

GAC	Granulated Activated Carbon

HRC	Hydrogen Releasing Compounds

ICIAP	Institutional Control Implementation and Assurance Plan

ICs	Institutional Controls

Illinois EPA Illinois Environmental Protection Agency

LTRA	Long-Term Remedial Action

LTS	Long-Term Stewardship

MCL	Maximum Contaminant Level

NAPL	Non-Aqueous Phase Liquid

NCP	National Oil and Hazardous Substances Pollution Contingency Plan

mg/kg	milligram per kilogram

ng/kg	nanogram per kilogram

NPL	National Priorities List

O&F	Operation and Functional

O&M	Operation and Maintenance

OU	Operable Unit

OWS	Oil-Water Separator

PAHs	Polyaromatic Hydrocarbons

PCOR	Preliminary Close Out Report

PCP	Pentachlorophenol

PPT	Parts Per Trillion

PRP	Potentially Responsible Party

Q	Quarter

RAO	Remedial Action Objectives

REACT	REACT Environmental

ROD	Record of Decision

RPM	Remedial Project Manager

Site	Jennison-Wright Corporation Superfund Site

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svoc

Semi-Volatile Organic Compound

UECA

Universal Environmental Covenant Act

Hg/L

microgram per liter

Hg/kg

microgram per kilogram

UST

Underground Storage Tank

UU/UE

Unlimited Use and Unrestricted Exposure

VOC

Volatile Organic Compound

WSP

WSP USA Environment & Infrastructure Incorporated

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I. INTRODUCTION

The purpose of a Five-Year Review (FYR) is to evaluate the implementation and performance of a
remedy in order to determine if the remedy is and will continue to be protective of human health and
the environment. The methods, findings, and conclusions of reviews are documented in FYR reports
such as this one. In addition, FYR reports identify issues found during the review, if any, and document
recommendations to address them.

The Illinois Environmental Protection Agency (Illinois EPA) prepared this FYR for the United States
Environmental Protection Agency (EPA) pursuant to the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) Section 121, consistent with the National Contingency Plan
(NCP)(40 CFR Section 300.430(f)(4)(ii)), and considering EPA policy.

This is the fourth FYR for the Jennison-Wright Corporation Superfund Site (Site). The triggering action
for this statutory review is the completion date of the previous FYR. The FYR has been prepared due to
the fact that hazardous substances, pollutants, or contaminants remain at the site above levels that
allow for unlimited use and unrestricted exposure (UU/UE).

The Site, as defined in the 1999 Record of Decision (ROD), consisted of five operable units (OUs),
however, the remedial action selected in the ROD was a Sitewide remedy (EPA, 1999). As a result, since
the first FYR report in 2009, EPA has described the Site as having all remedial actions taking place
under one OU. The entire Site is addressed in this FYR.

The Jennison-Wright Corporation Superfund Site FYR was led by Nicole Wilson, Remedial Project
Manager (RPM), Illinois EPA. Participants included Brooke Marcure, Illinois EPA; Tony Warren,
Corrective Action Contractor, REACT Environmental (REACT) (contractor to the Illinois EPA); and Nilia
Moberly Green, RPM, EPA. The review began on October 10, 2023.

Site Background

The Site is the location of a former wood-treating facility. The 20-acre property, consisting of
three parcels, is located at 900 West 22nd Street in Granite City, Madison County, Illinois,
approximately 6 miles northeast of downtown St. Louis, Missouri (see figures in Appendix B). The
area surrounding the Site is a mixed residential-industrial neighborhood. The Site is bisected by
22nd Street and is bordered on the south and east by Norfolk and Southern Railroad, on the north
by 23rd Street, and on the west by an unnamed alley running behind the houses of a residential
neighborhood. An Illinois-American Water Company waterworks facility is immediately north of
the Site. Currently, the Site is vacant except for the building that houses the groundwater
treatment system. It is anticipated that future use of the Site will be either commercial or
industrial use.

The former facility treated wooden railroad ties and wood blocks using creosote
pentachlorophenol (PCP), and zinc naphthenate. Jennite®, an asphalt sealant product composed
of coal tar pitch, clay and water, was also manufactured at the Site. The manufacturing process
areas were located on the southern portion of the Site, south of 22nd Street. The northern portion

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of the Site, north of 22nd Street, was used to store raw lumber and to dry and store treated
railroad ties and wood blocks. The southern portion of the Site contained both an aboveground
and buried railcarthat had been used to dispose of waste creosote and PCP. Several
contaminated soil stockpiles were located throughout the Site. An area in the northeast corner of
the Site, called Area H, the 22nd Street Lagoon, and the Jennite® Pit were all used as on-site
disposal areas where manufacturing wastes were placed. Other features in the southern part of
the Site included the transite building, the Jennite® building with two storage silos, the tank farm
(including the two railcars), the creosote process area (green building and concrete basin), the
PCP process area, sawmills, office, and other operations buildings. See Figure 2-2 in Appendix B
for historical Site features. Operations at the Site began prior to 1921 and continued until 1989.

EPA placed the Site on the National Priorities List (NPL) on June 17, 1996.

FIVE-YEAR REVIEW SUMMARY FORM

SITE IDENTIFICATION

Site Name: Jennison-Wright Corporation
EPA ID: ILD006282479

Region: 5

State:IL

City/County: Granite City/Madison

NPL Status: Final

Multiple OUs?

Yes

Has the site achieved construction completion?

Yes

Lead agency: State

Author name (Federal or State Project Manager): Nicole Wilson

Author affiliation: Illinois EPA

Review period: 10/10/2023 - 6/14/2024
Date of site inspection: 4/10/2024
Type of review: Statutory
Review number: 4
Triggering action date: 9/30/2019

Due date (five years after triggering action date): 9/30/2024

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II. RESPONSE ACTION SUMMARY

Basis for Taking Action

Past practices at the Site resulted in the release of chemicals to surface soils. In the case of the
Jennite® Pit and the 22nd Street Lagoon, waste was deposited directly into subsurface pits. Once
released, contamination migrated to subsurface soils and groundwater. In 1994, Illinois EPA
conducted an Engineering Evaluation and Cost Analysis (EE/CA) for a Non-Time-Critical Removal
Action and found (Ecology & Environment Engineering, Inc. [E&E], 1994):

•	Significant sources of contamination in drums and tanks;

•	Dioxins/furans and polyaromatic hydrocarbons (PAHs) in surface soils;

•	PCP in groundwater in the PCP Process Area;

•	PAHs, benzene, PCP, arsenic, 2,4-dimethylphenol and naphthalene in groundwater
under the 22nd Street Lagoon;

•	Benzene and naphthalene in subsurface soils;

•	Structurally unsound on-site buildings and silos; and

•	Four on-site buildings containing regulated asbestos containing material (ACM).

From July through September 1997, and in December 1997, Illinois EPA conducted sampling for a
second EE/CA (E&E, 1999), which became the basis for the ROD. Chemicals of potential concern
(COPCs) identified in soil included phenols, 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD; dioxin), and
semivolatile organic compounds (SVOCs), most of which are PAHs. Benzo(a)pyrene was detected in soil
samples at a maximum concentration of 2,800,000 micrograms per kilogram (i-ig/kg), and naphthalene
was detected at concentrations up to 4,200,000 |-ig/kg. PCP was detected in soil at concentrations up
to 670,000 |-ig/kg. Dioxins, which were associated with waste PCP material, were detected in soil at a
toxic equivalency quotient (TEQ) of up to 66 |-ig/kg.

Groundwater contained phenols and PAHs, as well as volatile organic compounds (VOCs) such as
benzene, xylenes, and toluene. The most significant areas of shallow groundwater contamination
identified were in the northeast corner of the south portion of the Site near the 22nd Street Lagoon and
in the former PCP Process Area. Phenol was detected in groundwater at concentrations up to 9,800
micrograms per liter (|_ig/L), PCP at concentrations up to 88,000 |ag/L, and naphthalene at
concentrations up to 21,000 |-ig/L. PCP concentrations was found to be significantly lower in
intermediate groundwater samples, suggesting limited downward migration of PCP in groundwater
occurred at the Site.

During the 1999 EE/CA, Illinois EPA collected 81 gridded surface soil samples, 15 biased surface soil
samples, 72 subsurface soil samples, four sediment samples, and 58 groundwater samples from three
different depths - shallow (20 feet bgs), intermediate (20-45 feet bgs), and deep (45-100 feet bgs).
Contamination was also found in groundwater in all three depth intervals, and a significant amount of
non-aqueous phase liquid (NAPL) source area was observed in the northeast corner of the southern
portion of the Site.

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A risk assessment was performed during the 1999 EE/CA to estimate the health or environmental
problems that could result from on-site contaminants. The determination of the human health risk
assessment was that the Site posed unacceptable risks to human health in both current- and future-
use scenarios. Therefore, remedial action was warranted. Factors causing the unacceptable risks to
humans included:

•	The presence of dioxins/dibenzofurans and PAHs in surface soil and potential exposures to
current site visitors and future site workers;

•	The presence of PAHs and PCP in groundwater, coupled with the possible future use of
groundwater as a drinking water source; and

•	The presence of benzene and naphthalene in subsurface soils and the potential future short-
term inhalation exposures of workers and nearby residents during periods of
excavation/construction on the site.

The ecological risk assessment (ERA), included in the 1999 EE/CA, was prepared based on information
collected by Illinois EPA during the Site characterization investigation from July through September
1997. Federal and state agencies were consulted for information on sensitive habitats and protected
species near the Site and relevant maps were reviewed to identify nearby sensitive habitats. In
addition, information was obtained from a local Illinois Department of Natural Resources
representative who visited the Site. A quantitative ecological risk evaluation was not performed
because the findings of the ERA indicated conditions were not likely to adversely impact wildlife. The
conclusions of the ERA were:

•	Habitat is of very low quality for wildlife;

•	The Site is in a mixed industrial/residential area. Only common wildlife, accustomed
to human activity and disturbance, are likely to utilize habitat on-site; and

•	The closest aquatic resource and ecologically sensitive areas to the Site are located
approximately one mile away and are not likely to be impacted by on-site
contamination.

No response actions to address ecological risks were initiated based on the conclusions above and
no adverse impacts to wildlife or sensitive habitats were expected to result from contamination at
the Site.

Table 1 shows contaminants of potential concern (COPCs), identified in the 1999 EE/CA and listed in
the ROD for each media - surface soil, subsurface soil, and groundwater.

TABLE 1: CONTAMINANTS OF POTENTIAL CONCERN BY MEDIA TYPE

Contaminant

Surface Soil

Subsurface Soil

Groundwater

Acenaphthene

X

X

X

Arsenic





X

Benzene



X

X

Benzo(a)anthracene

X



X

Benzo(a)pyrene

X

X



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Benzo(b)fluoranthene

X

X

X

Benzo(k)fluoranthene

X

X

X

Beryllium

X





Carbazole

X

X



Chloroform





X

Chromium

X





Chrysene

X

X

X

Di(2-ethylhexyl)phthalate





X

Dibenzo(a,h)anthracene

X

X



1,2-Dichloroethane





X

2,4-Dimethyl phenol



X

X

Ethylbenzene





X

alpha-Hexachlorocyclohexane

X



X

lndeno(l,2,3-cd)pyrene

X

X



Lead

X



X

Manganese

X



X

Methylene chloride





X

2-Methylphenol





X

Naphthalene

X

X

X

Pentachlorophenol

X

X

X

Phenol





X

2,3,7,8 TCDD Equivalents (dioxin)

X





Thallium





X

Toluene





X

Trichloroethene





X

Response Actions

Removal Actions

Illinois EPA conducted the first removal action at the Site in May 1992. Using bankruptcy trust funds,
Illinois EPA initiated a stabilization effort to prevent the spread of contamination. The contents of the
Jennite® Pit located at the east boundary of the south portion of the Site had become semi-liquid and
had begun to migrate off-site. To temporarily alleviate the problem, the overflowing material was
removed and placed in three cutoff tanks. A temporary clay cap was constructed using on-site
materials to shore up the sides of the Jennite® Pit. Approximately 175 drums of known and unknown
materials were found on the Site including 15 drums of creosote-contaminated asbestos insulation.
These drums were stored on-site in an existing structure.

Work accomplished during the removal included removal of 22 cubic yards of ACM, pumping of
1,300 gallons of creosote-contaminated water to an aboveground storage tank (AST), excavation
and temporary on-site storage of creosote, tar, and contaminated soil that had migrated off-site
from the Jennite® Pit.

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Illinois EPA initiated a second removal response on November 8,1994, and completed it on
March 6,1995. This action implemented the recommendations in the 1994 EE/CA, which included:

•	Installation of a 6-foot-tall chain link fence around the area of stockpiled soil and drainage
area at the northeast corner of the Site;

•	Excavation and disposal of soils around the upright storage tanks and railroad tank cars;

•	Removal of aqueous waste from the various storage vessels, treatment by oil/water
separation, and off-site disposal at a water treatment plant;

•	Removal and disposal of creosote waste material from the storage vessels;

•	Decontamination/dismantling of the storage vessels;

•	Characterization of the material within the drums inside the transite-sided building
and proper disposal;

•	Installation of a protective geomembrane and clay cap over the Jennite® Pit; and

•	Removal of the contaminated soil in the three cutoff tanks in the south portion of
the Site and dismantling of the tanks.

As part of a third removal action in 2003, Illinois EPA demolished on-site buildings, removed
ASTs, underground storage tanks (USTs) and debris piles, and constructed a permanent
decontamination pad on the southern portion of the Site.

Remedial Decision Documents

EPA signed a ROD on September 29,1999. The ROD referred to five OUs: soils and wastes,

NAPL, groundwater, buildings, and miscellaneous items. The remedial action selected,
however, was a Sitewide remedy. The following general remedial action objectives (RAOs)
were developed for the Site:

•	Prevent current nearby residents and potential future workers from contacting,
ingesting, or inhaling on-site soil and waste materials containing COPCs that exceed the
calculated risk-based cleanup objectives;

•	Prevent the continued release of contaminants to groundwater;

•	Initiate long-term groundwater restoration to federal maximum contaminant levels (MCLs);

•	Abate regulated ACM present in the on-site buildings;

•	Remove listed hazardous waste from the Site for treatment and disposal at an
appropriately licensed facility;

•	To the extent practical, pump NAPL from the subsurface in the vicinity of the 22nd
Street Lagoon; and

•	Treat collected groundwater.

The main components of the remedy selected in the September 1999 ROD were:

•	Remove the drip track residue and the associated oils for off-site disposal as hazardous
waste;

•	For on-site impacted soils, construct a 'landfarm' in the northeast portion of the Site.

[Note that this component of the remedy was changed to excavation and off-site
disposal in the October 2005 Explanation of Significant Differences (ESD) (EPA, 2005)
discussed below.];

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•	For NAPL removal, hot water and steam flushing;

•	For the more highly contaminated groundwater plumes, enhanced in situ biological
treatment using oxygen releasing compound and air sparging;

•	Monitored natural attenuation was the selected alternative for the other areas of
the Site where groundwater contamination was at a much lower concentration;

•	The buildings and other structures on the Site would be razed and the ACM inside would
be abated; and,

•	Miscellaneous items, such as debris piles, storage tanks, abandoned steel trams, as
well as several sumps and pits (including their contents) were to be removed from the
Site for appropriate off-site disposal.

EPA signed the first ESD on October 27, 2005 which modified the soil remediation method from
landfarming treatment in an on-site treatment unit to excavation and off-site disposal of
contaminated soil. The excavated areas would then be backfilled with clean material and seeded.

A second ESD was signed by EPA on June 5, 2009 (EPA, 2009) which further modified the remedy
to include:

•	Institutional controls (ICs) for soil and groundwater

o Prior to the 2009 ESD, the only IC required was a zoning restriction to ensure the
property continued to be used for commercial and industrial purposes. The additional
ICs required by the 2009 ESD included requirements to prohibit excavation of soils
and/or restrict groundwater use in the following areas: to the west of the Site in the
alley, along the section of 22nd Street near the eastern border of Site, in the northeast
corner of the Site, and along the eastern border of Site between 22nd Street and
southern boundary of Site. The ESD required that groundwater use restrictions would
be needed on all on-site areas where groundwater cleanup objectives had not yet been
met.

•	Use of a different substrate to enhance in situ groundwater bioremediation,

•	Excavation of soils beneath 22nd Street,

•	Extraction and off-site disposal of NAPL from the Jennite® Pit, and identification of a
contingency remedy for potential additional NAPL and groundwater contamination in the
Jennite® Pit area.

o The 2009 ESD stated that if additional investigation showed that NAPL and

contaminated groundwater were located beneath the former Jennite® Pit area, hot
water injection wells and NAPL extraction wells would be installed in the area, and the
NAPL and contaminated groundwater would be treated in the existing groundwater
treatment plant.

Cleanup Objectives

Site-specific cleanup objectives (CUOs) were established in the ROD for soil and
groundwater. Site-specific CUOs for soil were based on future commercial or industrial
use of the Site and represented the 10"5 risk level for carcinogens or a hazard quotient of
1 for noncarcinogens. The groundwater CUOs selected in the ROD were based on future
drinking water or commercial use and represent the 10"6 level for carcinogens or a

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hazard quotient of 1 for noncarcinogens, or the MCL. The two exceptions to these rules
were the groundwater CUO for arsenic and the soil CUO for dioxin. The site-specific CUO
for arsenic in groundwater was set at 50 |-ig/L, which was the MCL at the time of the
ROD. For dioxin in soil, the 10~5 risk level was calculated to be 0.2 |-ig/kg. However, based
on a review of documentation from the Agency for Toxic Substances and Disease
Registry, a site-specific CUO of I M-g/kg was selected. This number is the same as 1 part
per billion (ppb) TEQ.

Tables 2 and 3 show the site-specific CUOs from in the 1999 ROD for soil and groundwater,
respectively.

Table 2: CUOs for Soil

Contaminant

CUO (ng/kg)

Benzene

3,000

Benzo(a)anthracene

14,000

Benzo(a)pyrene

2,000

Benzo(b)fluoranthene

22,000

Benzo(k)fluoranthene

32,000

Naphthalene

27,000

Carbazole

954,000

Dibenzo(a,h)anthracene

2,000

lndeno(l,2,3-cd)pyrene

11,000

PCP

51,000

TCDD

1

Table 3: CUOs for Groundwater

Contaminant

CUO (ng/L)

Arsenic

50

Benzene

10

Benzo(a)anthracene

0.13

Benzo(b)fluoranthene

0.18

Benzo(k)fluoranthene

0.4

Chrysene

4

PCP

1.0

Alpha-Hexachlorocyclohexane (Alpha-BHC)

0.03

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Manganese

200

Naphthalene

400

2,4-dimethylphenol

200

2-methylphenol

500

In January 2006, EPA lowered the arsenic MCL to 10 |-ig/L, which then prompted Illinois EPA to plan to
evaluate whether the 50 |ag/L groundwater cleanup objective for arsenic should be lowered to 10 |ag/L
as well.

From 2013-2014, Illinois EPA reviewed the 1999 EE/CA Report and in May 2014 it determined that the
arsenic MCL issue was no longer relevant. Illinois EPA found that only one soil sample in the EE/CA
slightly exceeded the calculated background level of 11.57 milligrams per kilogram (mg/kg). However,
the arsenic concentration in that soil sample was still within the range of naturally occurring or
background arsenic concentrations for soil in the area; also, the calculated upper confidence level of all
the samples collected at the Site, 7.7 mg/kg, was below the calculated background concentration.
Illinois EPA also reviewed the Site-use history and determined that arsenic was not used in any of the
manufacturing or wood treatment operations at the Site. Therefore, soil arsenic levels detected at the
Site are believed to represent background levels and not site-related contamination.

Although arsenic was listed on the potential COPC list for groundwater in the EE/CA report, it was
never a contaminant of concern (COC) in the soil. Since arsenic was not used at the site and it is not
present above soil background levels, Illinois EPA concluded that arsenic would not impact
groundwater at the site. Thus, arsenic is no longer a COC in groundwater and the change in arsenic
MCL is not relevant to the site cleanup effort.

Status of Implementation

Illinois EPA implemented the selected remedy over September 2004 through September 2009. Drip
track residues and oils were removed from the Site and disposed of appropriately. Soil from both
the northern and southern parcels was excavated in accordance with the October 2005 ESD.

Illinois EPA completed the excavations of the 22nd Street Lagoon, the Jennite® Pit and portions of
22nd Street. Groundwater remediation activities have included injections of hydrogen releasing
compound (HRC) in the PCP contaminant plume, along with the on-going hot water injection and
extraction of NAPL and contaminated groundwater in the vicinity of the 22nd Street Lagoon. For
this component of the remedy, which was referred to as "NAPL removal via hot water flushing" in
the 1999 ROD, groundwater extracted from the area near the 22nd Street Lagoon is treated using
an oil/water separator (OWS), clay adsorption, and granular activated carbon (GAC) before being
discharged to the Granite City wastewater treatment plant via the municipal sewer system.

Collected NAPL is shipped off-site for disposal.

Three rounds of HRC injections were completed in the PCP Process Area in 2009. The injections
were designed to span the horizontal and vertical extent of the PCP groundwater contaminant
plume to maximize the anaerobic treatment of PCP.

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The Site has been fenced and long-term groundwater monitoring has been conducted since
construction completion status was achieved in September 2009 (EPA, 2009b). Based on the
Preliminary Close Out Report (PCOR) signature date of September 28, 2009, and the final site
inspection in October 2010, the remedy at the Jennison-Wright site achieved Operation and
Functional (O&F) status on September 28, 2010 (EPA, 2011).

In 2017, Illinois EPA regraded the storm water retention basin area in the southern portion of the
Site. In 2018, Illinois EPA completed Site grading and construction of the new OWS system. The
groundwater restoration remedy is now in Operation and Maintenance (O&M).

Operation of the new OWS continued during this review period. During the development of the
last FYR, Illinois EPA reviewed site data and determined that the nature and extent of the
contamination at the Site was not fully defined and there were outstanding remedial actions. In
2021, Illinois EPA procured Woods Environmental & Infrastructure Solutions, Inc (now called WSP
USA Environment & Infrastructure Incorporated [WSP]) to review all the data available for the Site
and determine which remedies may be considered complete, which remedies still need to be
implemented, as well as identify all data gaps and areas that require further investigation. Illinois
EPA also procured WSP to conduct a Supplemental Remedial Investigation (Supplemental Rl)
based on the identified data gaps. The data evaluation and the results of the Supplemental Rl are
still underway and will not be available in time for this FYR review period.

Soil Data

Based on sampling conducted in 2008 (most recent sampling conducted prior to the pending
Supplemental Rl), high levels of COPCs remain in soil in the northeast corner of the Site (Area
H), along 22nd Street, and in the southern portion of the Site. The contaminated soil in the
southern portion is near the 22nd Street Lagoon, Jennite® Pit, and PCP Process Area. The four
sections below summarize sampling data collected by the Illinois EPA contractor in 2008,
along with their 2009 recommendations, related to Area H, 22nd Street, the PCP Process
Area, and the alley adjacent to the western Site boundary in the vicinity of the PCP Process
Area. The purpose of the 2008 sampling was to further define the extent of soil
contamination, compare the sampling results to CUOs, outline additional soil excavation that
may be needed, and define the areas where ICs would be required. The findings from these
investigations are summarized in two reports - Technical Memorandum: Soil Investigation
Report, E&E, January 27, 2009, and PCP Process Area Analytical Results and
Recommendations, E&E, January 22, 2009.

Soil Contamination - Area H

Nine soil samples were collected from 1 to 2 feet bgs from the drainage ditch in the Area H
during the December 2008 sampling event. Two of the nine soil samples (AH-1 and AH-2)
showed exceedances of site-specific CUOs for eight PAHs. The exceedances ranged from 62,000
l-ig/kg of dibenzo(a,h) anthracene at boring AH-2 to 81,000,000 M-g/kg of napthalene at boring
AH-1. The concentration of PCP in AH-2 was 12,000 M-g/kg, compared to the site-specific CUO
for PCP of 51,000 |-ig/kg. Because of the high concentrations of PAHs in sample AH-1, the
amount of PCP could not be quantified and was listed as "not detected" with a detection limit of
1,600,000 |ag/kg.

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Only one of the nine soil samples (AH-5) was analyzed for dioxin. A concentration of 73
nanograms per kilogram (ng/kg), also parts per trillion (ppt), dioxin was detected in boring AH-5.
This concentration is below the site-specific CUO of 1,000 ppt and above the current EPA
regional screening level of 22 ppt for commercial/industrial use. Although the other eight soil
samples were not analyzed for dioxin, because PCP, PAHs, and dioxin have historically been
found to be co-located at the Site, it can be instructive to compare PCP and PAH concentrations.
The concentration of PCP found in AH-5 was listed as "not detected" with a detection limit of
810 |ag/kg. The concentrations of PAHs detected at estimated levels in boring AH-5 ranged from
13 to 35 |ag/kg. In comparison, soil samples AH-1 and AH-2, which were not analyzed for dioxin,
contained PCP at concentrations of 12,000 M-g/kg (boring AH-1) and "non-detect" with a
detection limit of 1,600,000 M-g/kg (boring AH-2). The concentrations of PAHs in borings AH-1
and AH-2 ranged from 61,000 to 81,000,000 ng/kg. Considering the co-location of these
contaminants at the Site, it is likely that samples AH-1 and AH-2 contained dioxin at levels
significantly greater than the 73 ppt found in AH-5.

2009 Recommendation - Area H\ Based on these exceedances, the Illinois EPA contractor
recommended that the area around the two samples AH-1 and AH-2 be excavated to a
minimum depth of 2.5 feet to prevent further contamination throughout the ditch. The
excavation area was estimated to be approximately 100 feet in length by 20 feet in width, and a
total volume of 185 cubic yards of contaminated soil would be removed. This action has not
been completed. WSP's site-wide data evaluation and Supplemental Rl will include an
assessment of whether the 2009 recommendation is still necessary or if a data gap exists and
further investigation is warranted.

Soil Contamination - 22nd Street

Analysis of samples collected during the 2008 investigation showed a number of site-specific
CUO exceedances in nine of the 17 soil borings along 22nd Street. Sixteen of the boring
locations were based on former locations of four railroad spurs that crossed the street during
the time the Site was operating. Samples from two depths - 1 to 2 feet bgs and 3 to 4 feet
bgs - were collected at each of the borings along the street. An additional boring was made in
the area of the 22nd Street Lagoon for comparison purposes. Samples were collected from
four different depths at this boring.

In general, most contamination detected in the soil borings along 22nd Street was at the depth of
1 to 2 feet bgs. In the eight borings furthest to the west (SB1 through SB8), with the exception of
two slight exceedances of the CUO for benzo(a)pyrene at two shallow borings, no other CUO
exceedances were observed.

The remaining boring locations along 22nd Street, SB9 through SB16, and the boring in the
lagoon area, SB17, indicated exceedances of site-specific CUOs for multiple compounds.
Specifically, high concentrations of benzo(a)anthracene, benzo(b)fluoranthene,
benzo(a)pyrene, indeno(l,2,3-cd) pyrene, and dibenzo(a,h)anthracene were detected in
shallow soil samples (1 to 2 feet bgs) collected from borings SB9, SB11, SB12, SB13, and SB15.
The only CUO exceedance deeper than 2 feet along 22nd Street was an exceedance of the CUO
for benzo(a)pyrene at 3 to 4 feet bgs at SB16.

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The boring at the 22nd Street Lagoon, SB17, showed CUO exceedances at all four depth intervals
(1-2 feet bgs, 5-6 feet bgs, 9-10 feet bgs, and 15-16 feet bgs). The most significant exceedances
were at the deeper intervals, and contamination levels increased with depth. PCP was
identified at boring SB17. At the two shallow intervals, concentrations of PCP did not exceed
the site-specific CUO. For the two deeper intervals, PCP results were listed as non-detect based
on detection limits of 84,000 M-g/kg and 300,000 |-ig/kg.

2009 Recommendation - 22nd Street. Based on the analytical results, the Illinois EPA
contractor recommended excavation of shallow soil along the railroad spurs at 22nd Street.
The estimated excavation area along the westernmost spur would be approximately 60 feet
long by 20 feet wide. An additional 60-foot by 30-foot area along the central railroad spur in
the vicinity of borings SB9 through SB12 would also be excavated. The total volume of
contaminated soil to be removed was estimated to be approximately 220 cubic yards. This
action has not been completed. For the high levels of contamination found in borings SB13,
SB15, and SB17, the Illinois EPA contractor indicated that this area had been excavated to the
degree that was physically possible. In addition, further digging would be obstructed by
subgrade and overhead utilities. For this area, the Illinois EPA contractor recommended the
implementation of ICs to prohibit excavation. This action has not been completed. WSP's
site-wide data evaluation and Supplemental Rl will include an assessment of whether the
2009 recommendation is still necessary or if a data gap exists and further investigation is
warranted.

Soil Contamination - PCP Process Area

The investigative sampling of the PCP Process Area conducted in 2008 consisted of three test pits
located approximately 50-, 75-, and 110-feet south of the previous excavation boundary. Soil
samples were collected from each test pit at intervals of 8-feet and 15-feet bgs.

Exceedances of the site-specific CUO for PCP (51,000 M-g/kg) were identified in the test pits 50
feet and 75 feet away from the previous excavation. PCP was detected at 8 feet bgs at 500,000
l-ig/kg and at 15 feet bgs at 110,000 |-ig/kg. No CUO exceedances of the PAHs were seen in any
of the test pits.

Dioxin was detected in all six soil samples, but the site-specific CUO for dioxin was only
exceeded in two of the samples. Both exceedances were in samples collected 15 feet bgs and
were in the test pits 50 and 75 feet away from the previous excavation. The two concentrations
in exceedance of the CUO were 1,300 ppt and 4,100 ppt. Other results for dioxin ranged from
320 ppt to 1,000 ppt, with the result of 1,000 ppt being the only one exceeding the EPA
screening level for dioxin for commercial/industrial use.

2009 Recommendation - PCP Process Area: Based on these findings, the Illinois EPA
contractor recommended that an area 47 feet by 100 feet be excavated down to the water
table (approximately 18 feet bgs). The estimated volume of PCP-contaminated soil that
would need to be excavated was 520 cubic yards. The estimated volume of dioxin-
contaminated soil that would be excavated was 1,740 cubic yards. This action has not been
completed. WSP's site-wide data evaluation and Supplemental Rl will include an assessment

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of whether the 2009 recommendation is still necessary or if a data gap exists and further
investigation is warranted.

Soil Contamination - Alley

During the December 2008 sampling, four soil borings were completed in the alley between
the western boundary of the Site and the adjacent residential area, and two soil borings were
completed along 21st Street, which is perpendicular to the alley. All borings were outside of
the Site fence. Samples were collected from four depth intervals: 1-2 feet bgs, 5-6 feet bgs, 9-
10 feet bgs, and 12-14 feet bgs. All samples were analyzed for PCP and eight PAHs. Samples
from one boring, SB18, were analyzed for dioxin.

Analytical results from the samples collected at the six borings showed no exceedances of
the site- specific CUOs for PCP or the eight PAHs that were analyzed. In general, low
concentrations of contamination were found in the shallow samples, collected at 1 to 2 feet
bgs. The highest PAH concentration was 1,000 M-g/kg g of benzo(b)fluoranthene at 1 to 2
feet bgs at SB21. PCP was not detected in any of the samples based on detection limits that
ranged from 710 to 910 |-ig/kg.

In the soil boring that was tested for dioxin, SB18, dioxin was present at all four depth
intervals. The levels ranged from 580 ppt at 9-10 feet bgs to 740 ppt at 13 to 14 feet bgs. The
shallow sample collected from 1 to 2 feet bgs contained dioxin at a concentration of 680 ppt.
None of the sample results exceeded the site-specific CUO for dioxin of 1,000 ppt.

2009 Recommendation -Alley. Because contaminant concentrations in samples collected
along the alley near the PCP process area did not exceed site-specific CUOs, the Illinois EPA
contractor recommended no soil excavation in this area. However, that recommendation was
based on a comparison to the site-specific CUO for commercial/industrial use. Additional
sampling may be required to define the extent of dioxin-contaminated soil. WSP's site-wide
data evaluation, risk evaluation, and Supplemental Rl will include an assessment of whether
the 2009 recommendation is still necessary or if a data gap exists and further investigation is
warranted.

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Institutional Controls

Table 5: Summary of Planned and/or Implemented ICs

Media, engineered
controls, and areas
that do not support
UU/UE based on
current conditions

ICs
Needed

ICs Called
for in the
Decision
Documents

Impacted
Parcel(s)

IC

Objective

Title of IC Instrument
Implemented and Date
(or planned)

Entire Site

Yes

Yes

North and
south
parcels

Limit future Site
use to
commercial/
industrial.

Environmental
Covenant under the
Illinois Uniform
Environmental
Covenants Act (UECA)
(planned)

Area east of the
eastern Site border
extending from 22nd
Street to southern
boundary-all media

Yes

Yes

South
parcel

Prohibit
excavation of soil

and prohibit
groundwater use.

Environmental
Covenant under Illinois

UECA (planned);
Granite City Drinking
Water Ordinance
#7529 (7/17/2001; See
Appendix C)

Former drip track
area in the vicinity of
22nd Street along the
eastern boundary-
surface soil and
subsurface soil

Yes

Yes

North
parcel

Prohibit
excavation of soil
in the area.

Environmental
Covenant under Illinois
UECA (planned)

Area H (northeast
corner of the Site) -
surface soil

Yes

Yes

North
parcel

Prohibit
excavation of soil
in Area H.

Environmental
Covenant under Illinois
UECA (planned)

Groundwater on-site
and off property (the
alley on the western
border and the areas
east of the eastern
border - groundwater

Yes

Yes

North and
south
parcels

Prohibit well
drilling, use of
groundwater as
drinking water,
and exposure to
groundwater with
contaminant
levels above

cleanup
objectives.

Granite City Drinking
Water Ordinance
#7529 (7/17/2001;
See
Appendix C)

Alley adjacent to the
western boundary of
southern portion -

surface soil,
subsurface soil, and
groundwater

Yes

Yes

South
parcel

Prohibit
groundwater use
and land use
(prohibit
excavation and
disturbance of
cover).

Environmental
Covenant under Illinois

UECA (planned);
Granite City Drinking
Water Ordinance
#7529 (7/17/2001; See
Appendix C)

17

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The identification and location of the three site parcels are shown on an aerial photograph in Appendix
D. A map showing the area in which the institutional controls (ICs) apply is included in Appendix E. Note
that the map shows soil and groundwater "management zones." These zones represent the most
highly contaminated soil and groundwater areas. To be protective, ICs will put into place for these
highly-contaminated zones along with contaminated areas outside the zones. The map does not show
all the areas for which ICs are in place or the areas outside of those zones. Preparation of a map
showing all areas is a follow-up action of this FYR.

Status of Access Restrictions and ICs

No indications of trespassing or of any uses of the Site that would be inconsistent with the planned ICs
were observed during the April 10, 2024 Site inspection. Staff that operate the groundwater treatment
system are at the Site five days a week and have reported no misuse of the Site property. There are no
known uses of groundwater as a source of drinking water in the vicinity of the Site. The groundwater
ordinance status was checked as part of this review and was found to still be valid. An Illinois EPA
website, https://epa.illinois.gov/topics/cleanup-programs/bol-database/groundwater-ordinance-
status.html . which provides the status of groundwater ordinances used as environmental ICs, states:
"Ordinance approved. No MOU required. The Agency's [Illinois EPA's] survey of approved groundwater
ordinances confirms that this ordinance remains valid for use as an environmental institutional control
pursuant to 35 III. Adm. Code 742 as of April 2010."

IC Follow up Actions

An Institutional Control Implementation and Assurance Plan (ICIAP) should be prepared. This will include a
map showing all areas that require ICs should be prepared, and ICs pursuant to the Illinois UECA should
be implemented at the Site in order to ensure no exposures to contaminated soil or groundwater occur
and to ensure that the remedy is not negatively impacted. A Long-Term Stewardship (LTS) plan, with
appropriate IC monitoring actions, will be included in the ICIAP to ensure that ICs remain in place and
are regularly monitored. As illustrated in Table 5, the planned ICs include Environmental Covenant under
the Illinois UECA include the following:

• Limit future Site use to commercial/industrial - entire Site;

• Prohibit excavation of soil and prohibit groundwater use in the area east of the eastern Site
border extending from 22nd Street to southern boundary - all media;

• Prohibit excavation of soil in the area of the former drip track area in the vicinity of 22nd Street
along the eastern boundary - surface soil and subsurface soil;

• Prohibit excavation of soil in Area H (Area H [northeast corner of the Site] -surface soil; and,

• Prohibit groundwater use and land use (prohibit excavation and disturbance of cover) in the
alley adjacent to the western boundary of southern portion - surface soil, subsurface soil, and
groundwater.

Systems Operations/Operation & Maintenance

A draft O&M Plan completed in 2010 outlines the requirements related to maintenance of the

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groundwater treatment system. The O&M tasks needed to operate the groundwater treatment
system include:

• Operation of groundwater treatment system with a Certified Industrial Wastewater Treatment
Works Operator;

• Inspections of the groundwater treatment system and completion of weekly logs;

• Influent and effluent sampling;

• Recording of temperature, flow rates, pressures, cycles, water levels and gallons discharged;

• Maintenance activities to ensure continued operation of the groundwater
treatment system, such as extraction well cleaning, movement of pumps and
packers in extraction and injection wells, and electrical and mechanical servicing
of equipment;

• Submittal of quarterly reports; and,

• Submittal of documents as directed by Illinois EPA.

An updated O&M Plan was completed in April 2020 to reflect the requirements of the newly-
upgraded groundwater treatment system (E&E, 2020).

Since 2019, Illinois EPA has completed routine groundwater monitoring. Monitoring wells that
are sampled quarterly since 2019 include MW5S, MW5D, MW6M, MW6D, MW8S, MW8M,
MW17S, MW18S, MW20, MW21, MW22, and MW23. Monitoring wells MW3S, MW3D, and MW4S
were added to the quarterly sampling in 2020. Additional wells, including MW2S, MW8D,
MW10S, MW11S, MW11M, MW12S, MW13S, MW14S, MW15S, MW16S, MW19S, have been
sampled generally once per year since 2019. Groundwater samples are typically analyzed for 20
SVOCs and PCP.

Additional tasks to improve overall remedy operation and Site security were conducted between
2019 and 2024 are:

• Routine grounds maintenance now includes fence-line trash and debris removal, vegetation
weeding, trimming, and mowing, as well as repairs to fencing, as needed.

• Installed insulation on outer wall of boiler room to protect boiler from freezing.

III. PROGRESS SINCE THE LAST REVIEW

This section includes the protectiveness determinations and statements from the last FYR as well as
the recommendations from the last FYR and the current status of those recommendations.

Table 6: Protectiveness Determinations/Statements from the 2019 FYR

ou#

Protectiveness
Determination

Protectiveness Statement

OUl/Sitewide

Short-term Protective

The remedy is currently protective of human health
and the environment because there are no complete
exposure pathways at the Site and remedial
components are in place and operating. However, in
order for the remedy to be protective of human

-------
health and the environment in the long-term, the
following actions need to be taken to ensure
protect iveness:

ICs: Implement an environmental covenant under the
Illinois UECA and develop and implement an LTS Plan.

Vapor Intrusion: Conduct a review to determine if
there is a potential for vapor intrusion and if
collection of soil vapor samples is required.

Soil: Conduct a risk evaluation to determine if long-
term protectiveness is compromised due to the
change in the non-cancer toxicity factor for dioxin;
conduct additional sampling to define the extent of
dioxin-contaminated soil in the alley; determine if
EPA screening level for residential use or
commercial/industrial use should be applied to the
results of sampling in the alley; determine if soil
excavation is required in the alley; review
recommendations for additional soil excavation
made by Illinois EPA contractor and determine if
additional excavation is necessary; if additional soil
excavation is necessary, prepare an ESD and/or ROD
Amendment to document the change in remedy; and
implement additional soil excavation if required by
an ESD and/or ROD Amendment.

Groundwater: Define off-site migration of contaminated
groundwater to the west; evaluate groundwater data to
determine if any additional remedial actions should be
taken to increase the rate of cleanup; if it is determined
that additional remedial actions should be taken to
increase the rate of groundwater cleanup and/or to
address off-site migration of contaminated
groundwater, prepare an ESD and/or ROD Amendment

to document the change in remedy; and implement
additional groundwater remedial action if required by an
ESD and/or ROD Amendment.

20

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Table 7: Status of

Recommendations from the 2019 FYP

¦

OU#

Issue

Recommendations

Current
Status

Current
Implementation
Status Description

Completion

Date (if
applicable)

OUl/Sitewide

ICs are needed on the
Site to prevent the use
of groundwater until
the cleanup levels are
met, prevent the
disturbance of
contaminated soil
remaining in place,
maintain the integrity
of the remedial and
monitoring systems,

and prohibit the
future residential use
of the property.

Implement
environmental
covenants under the
Illinois UECA.

Ongoing

A Supplemental Rl is

expected to be
completed in March
2025 which may
identify additional
areas requiring ICs.
As a result, ICs will
be implemented
following its
completion. A single
UECA environmental
covenant will be
developed for all
parcels requiring ICs.

NA

OUl/Sitewide

LTS procedures are
needed to ensure that
effective ICs are

monitored,
maintained and
enforced.

Develop and
implement an LTS Plan
to include procedures
for monitoring and
tracking compliance

with existing ICs,
communicating with
EPA, and providing an
annual certification to
EPA that the ICs
remain in place and
are effective.

Addressed in
Next FYR

LTS procedures will
be developed once
the ICs are in place.

NA

OUl/Sitewide

Vapor intrusion
pathway was not
considered when the
ROD was signed in
1999.

Conduct a review to
determine if there is a
potential for vapor
intrusion and if
collection of soil vapor
samples is required.

Ongoing

WSP (Illinois EPA's

contractor) is
conducting a site-
wide data
evaluation,
including a vapor

intrusion
assessment, and a
Supplemental Rl.
This report will not

be completed in
time for this review.

NA

21

-------
OUl/Sitewide

Extent of off-site

Define off-site

Addressed in

WSP (Illinois EPA's

NA



migration of

migration of

Next FYR

contractor) is





contaminated

contaminated



conducting a site-





groundwater to the

groundwater to the



wide data





west has not been

west.



evaluation,





defined.





including defining
extent of off-site
contamination, and
a Supplemental Rl.
This report will not

be completed in
time for this review.



OUl/Sitewide

Groundwater

Evaluate groundwater

Addressed in

WSP (Illinois EPA's

NA



contamination is

data to determine if

Next FYR

contractor) is





persistent and, in

any additional



conducting a site-





some cases, has

remedial actions



wide data





increased since HRC

should be taken to



evaluation,





injections were

increase the rate of



including evaluating





completed in 2009

groundwater cleanup



the need for





and extent of off-site

and/or to address off-



additional remedial





migration of

site migration of



actions, and a





contaminated

contaminated



Supplemental Rl.





groundwater to the

groundwater.



This report will not





west has not been





be completed in





defined.





time for this review.



OUl/Sitewide

Groundwater

If it is determined that

Considered

EPA Remedial

9/13/2024



contamination is

additional remedial

But Not

Response Program





persistent and, in

actions should be

Implemented

decided that





some cases, has

taken to increase the



decision document





increased since HRC

rate of groundwater



will be completed





injections were

cleanup and/or to



should it be





completed in 2009

address off-site



determined that





and extent of off-site

migration of



additional remedial





migration of

contaminated



actions need to be





contaminated

groundwater, prepare



taken.





groundwater to the

an ESD and/or ROD









west has not been

Amendment to









defined.

document the change
in remedy.







22

-------
OUl/Sitewide

Groundwater
contamination is
persistent and, in
some cases, has
increased since HRC

injections were
completed in 2009
and extent of off-site
migration of
contaminated
groundwater to the
west has not been
defined.

Implement additional
groundwater remedial
action if required by
an ESD and/or ROD
Amendment.

Considered

But Not
Implemented

EPA Remedial
Response Program
decided that if a
decision document
is completed, the
selected remedy

will be
implemented at
that time.

09/13/2024

OUl/Sitewide

The dioxin non-cancer
toxicity factor was
revised.

Conduct a risk
evaluation to
determine if long-term

protectiveness is
compromised due to
the change in the
dioxin non-cancer
toxicity factor.

Addressed in
Next FYR

EPA screening
values have been
updated since this
FYR

recommendation
was made. The
cancer screening
values are more
conservative than
the non-cancer
values, including the
2012 re-evaluation.

It has been
determined that a
risk evaluation to
determine if long-
term protectiveness
is compromised due
to the change in the
dioxin cancer
toxicity factor is
needed.A new
issue and
recommendation
have been included.

NA

OUl/Sitewide

Exceedances of EPA
screening levels for
dioxin for
commercial/industrial
use and for residential
use were observed in
soil borings collected
from the alley to the
west of the Site
adjacent to the
residential area.

Conduct additional
sampling to define the

extent of dioxin-
contaminated soil in
the alley.

Considered

But Not
Implemented

EPA Remedial
Response Program
decided that if the

risk evaluation
determines that the
current dioxin value
is not protective
due to changes in
the toxicity factor,
additional dioxin
sampling will be
conducted.

9/13/2024

23

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OUl/Sitewide

Exceedances of EPA
screening levels for
dioxin for
commercial/industrial
use and for residential
use were observed in
soil borings collected
from the alley to the
west of the Site
adjacent to the
residential area.

Determine if the EPA
screening level for
residential use or
commercial/industrial
use should be applied
to the results of soil
sampling in the alley
and if soil excavation
is required in this
area.

Considered

But Not
Implemented

If the risk evaluation
determines that the
current dioxin value
is not protective
due to changes in
the toxicity factor
then a new site-
specific dioxin CUO
will be developed
and evaluation of
necessary remedial
actions will be
conducted.

NA

OUl/Sitewide

Site-specific CUOs for
soil are exceeded in
several areas of the
Site.

Review
recommendations for

additional soil
excavation made by
Illinois EPA contractor

and determine if
additional excavation
is necessary.

Considered

But Not
Implemented

EPA Remedial
Response Program
decided that the
Supplemental Rl,
expected in March
2025, will identify
areas that are
recommended to be
addressed to ensure
protectiveness.

9/13/2024

OUl/Sitewide

Site-specific CUOs for
soil are exceeded in
several areas of the
Site.

If additional soil
excavation is
necessary, prepare an
ESD and/or ROD
Amendment to
document the change
in remedy.

Considered

But Not
Implemented

EPA Remedial
Response Program
decided the need

for a decision
document will be
made once it has
been determined
that additional
action such as
excavation is
necessary.

9/13/2024

OUl/Sitewide

Site-specific CUOs for
soil are exceeded in
several areas of the
Site.

Implement additional
soil excavation if
required by an ESD
and/or ROD
Amendment.

Considered

But Not
Implemented

EPA Remedial
Response Program
decided any future
soil excavation, if
needed, will be
identified in a
future decision
document.

9/13/2024

OTHER FINDINGS

In addition, the following are recommendations were identified during the FYR, but do not
affect current nor future protectiveness:

Recommendation: Prepare a map showing all areas where ICs are needed.

24

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Current Status: This map has not been drafted but will be included in the planned ICIAP. WSP is
conducting a site-wide data evaluation and Supplemental Rl. This report, which will evaluate the need
for ICs, will not be completed in time for this review.

Recommendation: Prepare an updated O&M Plan to specify routine maintenance
activities for the upgraded groundwater treatment system and to include information
about long-term groundwater monitoring.

Current Status: The updated O&M Plan was developed in April 2020.

Recommendation: Review list of groundwater COPCs identified in the ROD and list of CO PCs
currently monitored, add COPCs identified in ROD to lab analyses or document why the
contaminant(s) are not being analyzed, and remove contaminants from lab analyses if not
needed.

Current Status: This review has not been completed but will be included in WSP's site-wide
data evaluation and Supplemental Rl. This report will not be completed in time for this review.

Prepare concentration vs time graphs for the main COPCs in groundwater and perform statistical
trend analyses for those COPCs and monitoring wells where the type of trend is not clear.

Current Status: These graphs have not been completed but will be included in WSP's site-wide
data evaluation and Supplemental Rl. This report will not be completed in time for this review.

Conduct an evaluation of the monitoring well network to see if any additional wells are required.
Current Status: This evaluation has not been conducted but will be included in WSP's is
conducting a site-wide data evaluation and Supplemental Rl. This report will not be completed
in time for this review. This has been added as an Issue/Recommendation of this FYR.

Collect samples from MW9S, MW9M, and MW9D to monitor concentrations of contaminants in
groundwater near the Jennite® Pit.

Current Status: WSP indicates that these monitoring wells were abandoned during remedial
action. We are not sure why this was included as an Other Finding in the prior FYR. Illinois EPA
contractor is conducting a site-wide data evaluation and Supplemental Rl. This report will not
be completed in time for this review.

Evaluate condition of MW3S, MW3D, and MW4S, which are adjacent to the western fence line,
and collect samples if the wells are in good condition and if data would be helpful in defining the
western extent of groundwater contamination in these areas.

Current Status: These wells were inspected and added to the quarterly sampling list in 2020.

Illinois EPA contractor is conducting a site-wide data evaluation, including data from these
wells, and a Supplemental Rl. This report will not be completed in time for this review.

Continue to adjust hot water injection system, groundwater extraction, and groundwater
treatment system to optimize performance.

Current Status: Ongoing. Operational conditions of the groundwater treatment system
vary along with NAPL volume based on water table fluctuations.

Continue to complete minor regrading of low areas as they are identified after heavy rains.

-------
Current Status: The contractor continues to monitor the Site and addresses low areas as
needed.

IV. FIVE-YEAR REVIEW PROCESS

Community Notification. Involvement & Site Interviews

Illinois EPA published a notice announcing the start of the fourth FYR in the Edwardsville
Intelligencer on Friday, December 1, 2023 (Appendix F). The public was invited to submit
comments or concerns to either Illinois EPA or EPA. The notice also informed the citizens that the
results of the review and the report will be made available at the information repository located at
the Granite City Public Library, 2001 Delmar Avenue, Granite City, Illinois 62040, and on the site
profile page at https://www.epa.gov/superfund/iennison-wright. No requests for information
were received prior to publication of this FYR.

Data Review

Illinois EPA and EPA reviewed NAPL removal, soil contamination, and O&M groundwater
monitoring data. WSP is conducting a site-wide data evaluation and Supplemental Rl. This report
will not be completed in time for this review. No soil remedial activities occurred during this FYR
period.

NAPL Removal

NAPL is removed from the Site through a system of six hot-water injection wells placed along
the NAPL plume boundary and two groundwater/NAPL extraction wells centered within the
injection well network. The extraction wells pump contaminated groundwater and recovered
NAPL to the treatment system that consists of a phase separation step (an OWS) where the
NAPL is separated from the water by specific gravity. Recovered NAPL is stored for off-site
disposal. Separated groundwater is then treated by clay adsorption and GAC to remove
dissolved metals and organic compounds. Most of the treated water is then sent to the hot-
water generation system to be injected into the NAPL plume and the remainder is discharged to
the Granite City wastewater treatment plant under a permit.

The total amounts of NAPL removed each year between the end of 2019 and first quarter 2024 are
shown below.

• 2019 (Q4): 4,968.25 pounds

• 2020: 22,045.8 pounds

• 2021: 30,668 pounds

• 2022:18,388 pounds (although Q1 total was not available so this quantity is actually higher)

• 2023: 33,480 pounds

• 2024 (Ql): 6,255 pounds

System performance is effective in terms of the hot water injection being able to mobilize
NAPL for recovery. Prior to 2018 the OWS was undersized and could not fully separate the

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NAPL from contaminated groundwater. Given the 2018 annual NAPL removal total was only
12,379 lbs, the installation of a larger OWS has resulted in a significant increase in NAPL
recovery. Illinois EPA continues to adjust the system to find optimum operating conditions and
maximize NAPL removal, but the larger OWS system has caused other issues with the rest the
treatment train.

The rest of the treatment system was not designed to handle the increase in NAPL volume.
NAPL bleed through after the OWS is occurring at an increasing rate. The amount of treatment
system repairs and/or part replacements has also grown. The GAC tanks are old, and the
internal components are breaking; a confined space entry event was necessary in 2023 to
repair internal damage. When the GAC tanks need to be serviced the whole system must be
shut down. The GAC tanks are not large enough to handle the volume of NAPL that is escaping
the OWS. The inline filter bags are being overwhelmed too quickly, resulting in increases in
time, material, and disposal costs and poses additional risk to the other downstream
treatment components should too much NAPL get past the filters.

The OWS is a skimmer system that collects the NAPL off the surface of the water, however,
50+ gallons of pure coal tar are being removed from the bottom of the OWS weekly.

The spent activated carbon can no longer be recharged(recycled). The vendor no longer offers
those services, which has led to an increase in disposal costs and having purchase new carbon
instead of reactivated carbon.

The increase in the NAPL type and volume is also putting stress on the extraction pumps, both
of which had to be replaced during this review cycle (2020 and 2021).

The pumps for the biocide injections are regularly failing requiring repair and/or replacement
multiple times during this review cycle.

The extraction wells are only operating at a single depth, which means the pump is only
skimming off the top layer of NAPL, so even if the system was run for the next 50 years, it
would have little to no impact on the deeper NAPL that is present. Injection of hot water could
have mobilized deeper NAPL. Contamination below the extraction well intake is not being
recovered. The overall remedy performance needs to be evaluated.

Groundwater Monitoring

To date, concentrations of PCP and other COPCs still exceed their cleanup levels. ICs will be
needed to minimize potential exposure until the cleanup levels are met. The extent of off-site
migration of PCP-contaminated groundwater to the west has not been fully defined. Illinois
EPA's contractor is still in the process of collecting and evaluating data, and the results will not
be ready in time for this FYR.

Quarterly groundwater monitoring was conducted at the Site from late 2019 to 2024. During
each year, samples were collected from 15 monitoring wells during three of the quarters and
from 23 monitoring wells in one of the quarters. The samples were analyzed for 20 SVOCs
and PCP. During some quarters, analyses of other phenols, such as 2,4-dichlorophenol and
2,4-dimethylphenol, were also included. See Appendix G for monitoring well locations and

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Appendix H for the most recent results from 4th quarter 2023 and first quarter 2024. WSP is
conducting a site-wide data evaluation and Supplemental Rl, which includes samples these
monitoring wells.

Table 13 shows COPCs with and without CUOs and contaminants currently monitored.

Eleven contaminants that are currently monitored but which are not identified as
groundwater COPCs in the ROD include: 2-methylnaphthalene, acenaphthylene,
dibenzofuran, fluorene, phenanthrene, 2,4-dichlorophenol, carbazole, analine, anthracene,
fluoranthene, and pyrene. A different set of 12 compounds identified in the 1999 ROD as
groundwater COPCs are not currently monitored, as shown in Table 12.

Because there are 11 compounds that are monitored that are not designated as groundwater
COPCs and 12 groundwater COPCs that are not monitored, one follow-up action
recommended in the last FYR was to review the current list of groundwater analytes, remove
contaminants from the list if they are not needed, and either begin monitoring the 12 COPCs
that have not been included or document why they do not need to be monitored. This review
is ongoing, and the determinations will not be available during this review cycle. The
recommendation will be carried forward for this FYR.

Table 12: Contaminants Identified as Groundwater COPCs (with and without CUOs) and Contaminants
Currently Monitored in Groundwater

Contaminant

COPC
without a
CUO

COPC
with a CUO

Currently
Monitored

Acenaphthene

X



X

Arsenic



X



Benzene



X

X

Benzo(a)anthracene



X

X

Benzo(b)fluoranthene



X

X

Benzo(k)fluoranthene



X

X

Chloroform

X





Chrysene



X

X

Di(2-ethylhexyl)phthalate

X



X

1,2-Dichloroethane

X





2,4-Dimethylphenol



X

X

Ethylbenzene

X





alpha-hexachlorocyclohexane



X

X

Lead

X





Manganese



X

X

Methylene chloride

X





2-Methylphenol



X

X

Naphthalene



X

X

Pentachlorophenol



X

X

28

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Phenol

Thallium

Toluene

Trichloroethene

Historically the levels of contaminants in groundwater are below CUOs throughout much of the
Site. However, during this review it was noticed that contamination has started to migrate into
areas that were previously below CUOs. The contaminant plume is no longer under control.

In the northern portion of the Site, groundwater contamination remains above CUOs near Area
H (monitoring well MW2S), which is in the northeast corner. Monitoring well MW2S was
sampled annually from 2020 to 2023. The PCP concentration fluctuates from non-detect to
slightly exceed the CUO at this well. The presence of manganese exceeding the CUO at
monitoring well MW2S also fluctuated between non-detect and above the CUO. The other four
wells in the northern portion of the Site (monitoring wells MW12, MW13, MW14, and MW15)
have also been sampled annually since 2020 and the concentrations detected for PCP fluctuate
between non-detect (however the method detection limits were above the CUO) and above the
CUO.

In the southern portion of the Site, the area historically has shown no groundwater
contamination is the southernmost point (monitoring wells MW10, MW11, MW19) since 2015.
However, the annual sampling starting in 2020 has found PCP concentrations above CUOs in all
these monitoring wells. The maximum concentration (859 |ag/L) of PCP was found in MW10S in
2020. A variety of PAH and manganese concentrations also fluctuated between non-detect and
above the CUO in this area. This area is downgradient of the PCP Process Area. It is possible
that the incomplete in-situ treatment that occurred in the PCP Process Area has allowed the
contamination to continue migrating.

The main areas of groundwater contamination are near the 22nd Street Lagoon (monitoring
wells MW5S, MW20, MW21, MW22, and MW23), the PCP Process Area (monitoring wells
MW8S, MW8M and MW8D), and the area in between the lagoon and the PCP Process Area
(monitoring wells MW17S and MW18S). Another well near the PCP Process Area, MW16S,
contains contamination but the levels are not as high as in monitoring wells MW17S and
MW18S. Appendix I shows the general areas of the PCP groundwater plume.

In the last groundwater sampling event in 2024, the maximum concentrations of PCP
(533,000 |-ig/L) and naphthalene (298,000 |ag/L) were detected at monitoring well
MW21, which is near the 22nd Street Lagoon. The CUO for PCP is 1 |-ig/L. The CUO for
naphthalene is 400 |-ig/L. Table 14 shows concentrations exceeding the CUO for
naphthalene during the 2024 sampling event. The highest concentration of naphthalene
in the monitoring well adjacent to the western alley, monitoring well MW8, was 82.9
Hg/L in 2024.

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Table 13. Concentrations of Naphthalene in Groundwater Exceeding CUO (First Quarter 2024)

Monitoring

400

10,300

17S

400

7,160

18S

400

5,220

400

298,000

400

1,380

400

1,670

After HRC injections were done in 2009, the concentration of PCP in monitoring well MW8S, near
the PCP Process Area, decreased from 720,000 |ag/L to 75,000 |ag/L. Data were not collected to
determine if this decrease was due to biodegradation or physical displacement of the
contaminants by the HRC agent. Since that time, PCP concentrations have not decreased
significantly and in some cases have increased. Monitoring wells downgradient have seen an
increase in PCP concentrations. Further active measures will likely be needed to achieve
groundwater CUOs, Illinois EPA's full data evaluation and Supplemental Rl will hopefully provide
more detailed determination for the next FYR.

Table 15 shows the concentrations of PCP in the fourth quarter of 2019 and in the first quarter of 2024.

Table 14. Concentrations of PCP in Groundwater in Q4/2019 and Ql/2024

1,180

678

51,100

60,900

17S

118

51,100

60,900

6,700,000

533,000

Site Inspection

The inspection of the Site was conducted on 4/10/2024. In attendance were Nicole Wilson, Illinois EPA;
Nilia Green, EPA; Brooke Marcure, Illinois EPA; and Tony Warren, Corrective Action Contractor, REACT
Environmental (REACT) (contractor to the Illinois EPA). The purpose of the inspection was to assess the
protectiveness of the remedy.

The inspection did not identify any major condition issues. Site plans and permits were up-to-date

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and readily available. Site fencing had no breaches, and no signs of trespassing were observed.
Groundwater monitoring and extraction wells, electric panels, and treatment system pipelines
were in good condition. One electric panel in the treatment building will be upgraded so that it is
rated for wet conditions. The Illinois EPA contractor noted their concern about the treatment
system being able to ever meet the RAOs and that the pipelines between the extraction wells and
treatment building are constructed of black iron and will require ongoing periodic maintenance.
The FYR Site Inspection Checklist is included as Appendix J and documents the inspection findings.

V. TECHNICAL ASSESSMENT

QUESTION A: Is the remedy functioning as intended by the decision documents?

Question A Summary:

No. While the treatment system is technically functioning as intended by removing NAPL from the
ground, there are other issues that have arisen during this FYR that indicate the overall remedy is not
functioning as intended in the ROD.

The NAPL remedy is currently operating. After the remedy was declared operational and functional in
2010, a review of the operating data showed that the OWS did not have sufficient capacity to treat the
volume of NAPL-contaminated groundwater that was being extracted. A larger-scale OWS was installed
in 2018. The extraction and treatment system is now removing more NAPL than the previous system.
However, the upgrade was limited to just the OWS. The rest of the treatment train was not
designed/upgraded to handle the volume increase and is also starting to show its age. This has caused
a new set of operational issues that should be addressed if all the NAPL is going to be removed in a
reasonable timeframe. The ROD called out the use of steam and hot water injection, however, as part
of the optimization of the new OWS, the use of steam causes operational issues that leads to extended
down time of the system. So, the NAPL remedy is not currently operating as intended in the ROD. An
ESD or Memorandum to File will be needed to remove the requirement or add an as necessary clause
to the remedy to be functioning as intended.

The HRC injections completed in 2009 led to the decrease in the concentration of PCP in
groundwater near the PCP Process Area from 720,000 |ag/L to 75,000 |ag/L. Since that time,
however, PCP concentrations have not decreased further and in some cases have increased.
The groundwater treatment was not enough to address the contamination which has started
to migrate to the south. The contaminant plume is no longer under control, as monitoring
wells near this PCP area that previously did not have PCP contamination are now showing PCP
concentrations exceeding the CUOs. This portion of the groundwater remedy is not functioning
as intended. The ROD identified another component to the groundwater remedy. An air sparge
system was supposed to be designed and installed in the area of monitoring well MW5. This
system was never installed, and Illinois EPA was not able to find an ESD or ROD Amendment to
remove it from the remedy. Additional injections and design/installation of an air sparge
system will be needed for the remedy to be operating as intended. Otherwise, a decision
document will be needed to remove and/or revise the remedy requirements.

In addition, the extent of off-site migration of PCP-contaminated groundwater to the west has
not been fully defined and PCP concentrations that historically have been below CUOs in the

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southern portion of the Site are now above CUOs (maximum PCP concentration 859 |-ig/L). A
variety of PAH and manganese concentrations have also fluctuated between non-detect and
above the CUO in this area during this FYR period. There are no water supply wells in the
immediate vicinity of the site and there is an existing public water supply system that serves
the area (E&E, 1999). Granite City Ordinance # 7529 prohibits the use of groundwater as a
potable water supply by the installation or use of potable water supply wells or any other
method within the corporate city limits. Thus, ultimately the protectiveness may be impacted
and WSP's pending evaluation and Supplemental Rl will provide additional evaluations once
completed.

Exceedances of site-specific CUOs for other COPCs were identified in soil in Area H, along 22nd
Street, and in the PCP Process Area by E&E's, indicates that soil contamination remains on-site
above CUOs therefore the remedy did not perform as intended. WSP's site-wide data evaluation
and Supplemental Rl will include an assessment of whether the 2009 recommendation is still
necessary or if a data gap exists and further investigation is warranted. The site is currently
fenced so the remedy is short-term protective; however, long-term protectiveness may be
impacted pending WSP's evaluation and Supplemental Rl.

Except for in the PCP Process Area, concentrations of dioxin in soil meet the site-specific CUO
established in the ROD.

ICs are required at the Site to limit future use to commercial/industrial uses and to prohibit
excavation of soil and groundwater use. The Site is currently vacant and there is no use of
groundwater for drinking in the vicinity of the Site. Implementing the necessary ICs will
ensure that the remedy remains protective in the long-term. In addition, an ICIAP should be
prepared. An LTS plan, with appropriate IC monitoring actions, will be included in the ICIAP to
ensure that ICs remain in place and are regularly monitored. The LTS Plan will include
procedures for monitoring and tracking compliance with existing ICs, communicating with
EPA, and providing an annual certification to EPA that the ICs remain in place and are
effective.

QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action
objectives (RAOs) used at the time of the remedy selection still valid?

Question B Summary:

No. As stated above, Illinois EPA reviewed site data and determined that the nature and extent of
the contamination at the Site was not fully defined. Due to insufficient remedial investigation,
exposure assumptions and RAOs made at the time of the ROD may not be entirely valid.

The cancer screening values are more conservative than the non-cancer values, including the
2012 re-evaluation noted in the 2019 FYR.

Based on the risk assessment and ARARs, CUOs were established in the 1999 ROD. There have
been advances in science since 1999 resulting in a change to the toxicity value for dioxin. The
toxicity value for dioxin has changed since the ROD, the site-specific CUO of 1,000 ppt is less

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stringent than EPA's current soil regional screening level of 22 ppt for commercial/industrial use.
Sampling data show that results exceed this screening level in the one sample collected in the
alley. Currently, no indications of any uses of the Site that would be inconsistent with ICs and no
disturbances to surface soils have been observed in this area. It has been determined that a risk
evaluation due to the change in the dioxin screening values is necessary to assess the
protectiveness of the remedy. Current toxicity values will be considered in Illinois EPA's
Supplemental Rl.

Vapor intrusion can occur when VOCs volatilize out of groundwater into structures and buildings.
At the Site, SVOCs, rather than VOCs, are the primary contaminants in groundwater and the
SVOC concentrations near the residential area are low. The fact that the contaminants in Site
groundwater are semi-volatile significantly reduces the potential for vapor intrusion so Site
conditions should be protective. The 2019 FYR indicated that because the contaminants in Site
GW are semi-volatile it significantly reduces the potential for vapor intrusion. Napthalene,
however, is relatively volatile with a VISL screening level in the near surface aquifer for
residential exposure with a screening level of 200 ug/L. In October 2018, naphthalene in the
monitoring well adjacent to the western alley, MW8, was below that at 110 ug/L. The closest
residences are approximately 200 feet from this monitoring well. The potential for risk
associated with the vapor intrusion pathway, which was not considered at the time the ROD was
completed, will be evaluated. Illinois EPA has a contractor doing this evaluation, but the report
will not be completed in time for this FYR.

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

No. According to the data reviewed and the FYR site inspection, there is no new information that
would call into question the protectiveness of the selected remedies. There have been no newly
discovered risks or significant impacts to the Site from natural disasters or climate change.

VI. ISSUES/RECOMMENDATIONS

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): OU1/

Issue Category: Institutional Controls

Sitewide

Issue: ICs are needed on the Site to prevent the use of groundwater until the
cleanup levels are met, prevent the disturbance of contaminated soil remaining
in place, maintain the integrity of the remedial and monitoring systems, and

-------


prohibit the future residential use of the property.

Recommendation: Implement environmental covenants under the Illinois UECA.

Affect Current
Protectiveness

Affect Future
Protectiveness

Party Responsible

Oversight Party

Milestone Date

No

Yes

EPA/State

EPA

3/31/2026

OU(s): OU1/
Sitewide

Issue Category: Institutional Controls

Issue: LTS procedures are needed to ensure that effective ICs are monitored,
maintained and enforced.

Recommendation: Develop an ICIAP which includes LTS procedures for
monitoring and tracking compliance with existing ICs, communicating with EPA,
and providing an annual certification to EPA that the ICs remain in place and are
effective.

Affect Current
Protectiveness

Affect Future
Protectiveness

Party Responsible

Oversight Party

Milestone Date

No

Yes

EPA/State

EPA

12/30/2026

OU(s): OU1/
Sitewide

Issue Category: Other

Issue: Vapor intrusion pathway was not considered when the ROD was signed in
1999.

Recommendation: Conduct a review to determine if there is a potential for vapor
intrusion and if collection of soil vapor samples is required.

Affect Current
Protectiveness

Affect Future
Protectiveness

Party Responsible

Oversight Party

Milestone Date

No

Yes

EPA/State

EPA

6/30/2025

OU(s): OU1/
Sitewide

Issue Category: Remedy Performance

Issue: Extent of off-site migration of contaminated groundwater to the west has
not been defined.

Recommendation: Define off-site migration of contaminated groundwater to the
west by installing additional monitoring wells.

Affect Current
Protectiveness

Affect Future
Protectiveness

Party Responsible

Oversight Party

Milestone Date

No

Yes

State

EPA

12/31/2025

34

-------
OU(s): 0U1/

Issue Category: Remedy Performance

Sitewide

Issue: Groundwater contamination is persistent or increasing, for example COPC
concentrations have increased within and south of the area where HRC injections
were completed in 2009. Contamination has begun to migrate south into areas
that historically had been below CUOs. The extent of off-site migration of
contaminated groundwater to the west has not been defined; however, there
are no water supply wells in the vicinity of the site.



Recommendation: Conduct an evaluation of the monitoring well network to see
if additional wells are required and evaluate groundwater data to determine if
any additional remedial actions should be taken to increase the rate of
groundwater cleanup and/or to address off-site migration of contaminated
groundwater.

Affect Current
Protectiveness

Affect Future
Protectiveness

Party Responsible

Oversight Party

Milestone Date

No

Yes

State

EPA

12/31/2025

OU(s): OU1/
Sitewide

Issue Category: Other

Issue: The dioxin toxicity factor was revised.

Recommendation: Conduct a risk evaluation to determine if protectiveness is
affected due to the change in the dioxin toxicity factor.

Affect Current
Protectiveness

Affect Future
Protectiveness

Party Responsible

Oversight Party

Milestone Date

No

Yes

EPA/State

EPA

12/21/2025

OU(s): OU1/
Sitewide

Issue Category: Remedy Performance

Issue: Site-specific CUOs for soil are exceeded in several areas of the Site.

Recommendation: Review 2009 recommendations for additional soil excavations
made by Illinois EPA contractor and determine if additional excavation is
necessary of if a data gap still exists and further investigation is warranted.

Affect Current
Protectiveness

Affect Future
Protectiveness

Party Responsible

Oversight Party

Milestone Date

No

Yes

EPA/State

EPA

12/31/2025

35

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OU(s): 0U1/
Sitewide

Issue Category: Remedy Performance

Issue: The 1999 ROD specifically identifies the use of an air sparge system
around MW5. However, to date, no such system has been implemented.

Recommendation: Review site information and develop a decision document to
discuss the lack of remedy implementation for the air sparge system.

Affect Current
Protectiveness

Affect Future
Protectiveness

Party Responsible

Oversight Party

Milestone Date

No

Yes

EPA

EPA

12/31/2027

OU(s): OU1/
Sitewide

Issue Category: Remedy Performance

Issue: The groundwater treatment system is supposed to use hot water and
steam injection. Currently the system is only injecting hot water due to issues
injecting steam causes.

Recommendation: Develop a decision document explaining the change to not
using steam injection.

Affect Current
Protectiveness

Affect Future
Protectiveness

Party Responsible

Oversight Party

Milestone Date

No

Yes

EPA/State

EPA

12/31/2027

OU(s): OU1/

Issue Category: Remedy Performance

Sitewide

Issue: The 1999 ROD said the NAPL removal would only take 3-4 years to
complete. The treatment system has now been operational for more than 13
years and free product is still being removed. Only a portion of the treatment
system was upgraded and the older portion is not able to handle the increase
and is starting to show its age. Injection of hot water could have mobilized
deeper contamination. Contamination below the extraction well intake is not
being recovered.



Recommendation: Re-evaluate overall remedy performance, not just upgrading
a component of the treatment train, to see if there is a more effective and
efficient way to remove the NAPL.

Affect Current
Protectiveness

Affect Future
Protectiveness

Party Responsible

Oversight Party

Milestone Date

No

Yes

EPA/State

EPA

12/31/2028

36

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OU(s): OU1/
Sitewide

Issue Category: Other

Issue: The risk calculation methods for site specific groundwater CUOs have been
revised since the 1999 ROD and are scheduled to change again during the next
FYR cycle.

Recommendation: Review the groundwater CUOs and develop a decision
document to bring the CUOs up to date with the current groundwater standards
and MCLs.

Affect Current
Protectiveness

Affect Future
Protectiveness

Party Responsible

Oversight Party

Milestone Date

No

Yes

EPA/State

EPA

12/31/2027

OTHER FINDINGS

In addition, the following are recommendations that were identified during the FYR and (may improve
performance of the remedy, reduce costs, improve management of O&M, accelerate site close out,
conserve energy, promote sustainability, etc.), but do not affect current nor future protectiveness:

•	Review list of groundwater COPCs identified in the ROD and list of COPCs currently
monitored, add COPCs identified in ROD to lab analyses or document why the
contaminant(s) are not being analyzed, and remove contaminants from lab analyses if
not needed.

•	Prepare concentration vs time graphs for the main COPCs in groundwater and perform
statistical trend analyses for those COPCs and monitoring wells where the type of trend is
not clear.

•	Continue to complete minor regrading of low areas as they are identified after heavy rains.

•	For the next FYR consider breaking the review out into the OUs. Even though the ROD describes
an overall remedy, it does refer to OUs and each OU does have its own alternative described. The
various OUs have different degrees of effectiveness and completeness which makes the overall
protectiveness discussions skewed towards the areas that are still having issues.

VII. PROTECTIVENESS STATEMENT

Protectiveness Statement(s)

Operable Unit:	Protectiveness Determination:

OUl/Sitewide	Short-term Protective

Protectiveness Statement: The remedy at the Jennison-Wright Corporation Superfund Site
currently protects human health and the environment because there are no known complete
exposure pathways at the Site and remedial components are in place and operating. However, in
order for the remedy to be protective in the long-term, the following actions need to be taken to
ensure protectiveness:

• Implement environmental covenants under the Illinois UECA.

37

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• Develop an ICIAP which includes LTS procedures for monitoring and tracking compliance
with existing ICs, communicating with EPA, and providing an annual certification to EPA
that the ICs remain in place and are effective.

• Conduct a review to determine if there is a potential for vapor intrusion and if collection
of soil vapor samples is required.

• Define off-site migration of contaminated groundwater to the west by installing additional
monitoring wells.

• Conduct an evaluation of the monitoring well network to see if additional wells are
required and evaluate groundwater data to determine if any additional remedial actions
should be taken to increase the rate of groundwater cleanup and/or to address off-site
migration of contaminated groundwater.

• Conduct a risk evaluation to determine if protectiveness is affected due to the change in
the dioxin toxicity factor.

• Review 2009 recommendations for additional soil excavations made by Illinois EPA
contractor and determine if additional excavation is necessary of if a data gap still exists
and further investigation is warranted.

• Review site information and develop a decision document to discuss the lack of remedy
implementation for the air sparge system.

• Develop a decision document explaining the change to not using steam injection.

• Re-evaluate overall remedy performance, not just upgrading a component of the
treatment train, to see if there is a more effective and efficient way to remove the NAPL.

• Review the groundwater CUOs and develop a decision document to bring the CUOs up to
date with the current groundwater standards and MCLs.

VIII. NEXT REVIEW

The next FYR report for the Jennison-Wright Corporation Superfund Site is required five years from the
completion date of this review.

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APPENDIX A

REFERENCE LIST

Ecology & Environment Engineering, Inc. (E&E), 1994. Jennison-Wright Site Engineering Evaluation/Cost
Analysis, Non-Time Critical Removal Action, January 1994. SEMS ID # 150249

E&E, 1999. Jennison-W right Site Engineering Evaluation/Cost Analysis, July 1999. SEMS ID # 577312
(Volume 1 text) and # 969693 (Volume 2 appendices)

EPA, 1999. Record of Decision, Jennison-Wright Corporation Superfund Site, September 29, 1999. SEMS
ID #205538.

EPA, 2005. Explanation of Significant Differences, Jennison Wright National Priorities List Site, October
27, 2005. SEMS ID #259576.

EPA, 2009a. Explanation of Significant Differences, Jennison-Wright Superfund Site, Granite City, IL,

June 5, 2009. SEMS ID # 349653.

EPA, 2009b. Preliminary Close Out Report, Jennison-Wright Superfund Site, Granite City, Madison
County, Illinois. September 28, 2009. SEMS ID # 341578.

E&E, 2008. Remedial Action Design, Jennison-Wright Superfund Granite City, Illinois. December 19,
2008. SEMS ID #s 2006152 (text) & 2006143 (drawings)

E&E, 2009. Technical Memorandum: Soil Investigation Report, Jennison-Wright Superfund
Site. January 27, 2009. SEMS ID # 951047.

E&E, 2009. PCP Process Area Analytical Results and Recommendations, Jennison-Wright Superfund Site.
January 22, 2009, SEMS ID # 951050.

Bodine Environmental Services, Inc., 2010. Operation and Maintenance Quality Assurance Project Plan,
Jennison-Wright Corporation Superfund site, Remedial Action treatment System. May 25, 2010. SEMS
ID #542938.

EPA, 2011. Achievement of Operational and Functional (O&F) Status, Jennison-Wright Corporation
Superfund Site, Granite City, Illinois. July 7, 2011. SEMS ID # 951062.

EPA, 2019. Third Five-Year Review Report for Jennison-Wright Corporation Superfund Site. September
30, 2019. SEMS ID #950942.

Illinois EPA, 2019, 2020, 2021, 2022, 2023 and 2024. Groundwater Monitoring Data. SEMS ID # 2006155.
E&E, 2020. (Draft) O&M Plan Jennison-Wright Superfund Granite City, Illinois. March 1, 2020. Revised

-------
by REACT Environmental April 7, 2020. SEMS ID # 2006154.

Illinois EPA Groundwater Ordinance Status website.

https://epa.ill inois.gov/topics/cleanup-programs/bol-data base/ground water-
ordinance-status, html

-------
APPENDIX B - SITE LOCATION AND LAYOUT FIGURES

-------
SCALE 1:24-000

1/2	0	1 MILE

1 KILOMETER

|

ecology and environment, inc.	

FIGURE 2-1 - SITE LOCATION MAP
JENNISON-WRIGHT SITE
GRANITE CITY, ILLINOIS

-------
AREA H

SCALE IN FEET
120	240

360
I

NOTE: THE FOLLOWING FEATURES WERE FORMERLY
LOCATED ON SITE BUT HAVE SINCE BEEN
REMOVED:

22nd STREET LAGOON (DRY)
(AREA G)

AREA B - CREOSOTE TREATMENT CYLINDERS
AREA I - TWO 160,000—GALLON TANKS
ABOVEGROUND RAILCAR
BURIED RAILCAR
CUTOFF TANKS
JENNITE BUILDING.

AREA J
AREA K
AREA L
AREA M

TRANSITE
BUILDING
(AREA N)

JENNITE PIT (AREA E)

DEBRIS PILE

SOURCE: REVISED FROM WOODWARD-CLYDE CONSULTANTS, 1988

FIGURE 2-2
SITE LAYOUT MAP

JENNISON-WRIGHT SITE
GRANITE CITY, MADISON COUNTY,
ILLINOIS	

r = ioo-

02/2011

Features-DWG

-------
APPENDIX C - MUNICIPAL ORDINANCE

-------
STATE OF ILLINOIS ¦ )
COUNTY OF MADISON )
CITY OF GRANITE CITY )

SS

CERTIFICATION

I, jxjdY J. WHITAKER, City Clerk of. the City of Granite
City, Madison County, Illinois, do hereby certify that the foregoing pages,
constitute a- true Ordinance No.	of said City, passed and approved on this

approved by the Mayor of said City on the 	/^	of

¦ ¦

I DO FURTHER CERTIFY that said Ordinance has been
spread at length upon the permanent records of said City, where it now
appears and remains in effect.	¦	'

IN WITNESS WHEREOF, I have hereunto set my hand and
affixed the seal of said City this	_day of

'Mi.

(SEAL)

-------
ORDINANCE NO. nssj

AND ORDINANCE PROHIBITING THE USE OF GROUNDWATER AS A POTABLE
WATER SUPPLY BY THE INSTALLATION OR USE OF POTABLE WATER SUPPLY
		¦ WELLS OR BY ANY OTHER METHOD '	

WHEREAS, certain properties in the City of Granite City, Illinois, have been used over a
period of time for commercial/industrial purposes; and

WHEREAS, because of said use, concentrations of certain chemical constituents in the
groundwater beneath the City may exceed Class I groundwater quality standards for potable
resource groundwater as set forth in 35 Illinois Administrative Code 620 or Tier 1 residential
remediation objectives as set forth in 35 Illinois Administrative Code 742; and

WHEREAS, the city of Granite City desires to limit potential threats to human health '
from groundwater contamination while facilitating the redevelopment and productive use of
properties that are the source of said chemical constituents.

" NOW, THEREFORE, BE IT ORDAINED BY THE CITY COUNCIL OF THE CITY OF
GRANITE CITY AS FOLLOWS:

Section 1. Use of Groundwater as potable water supply prohibited. Except for such
uses or methods in existence before the effective date of this ordinance, the use or attempt to use
as a potable water supply groundwater from within the corporate limits of the City of Granite
City by the installation or drilling of wells or by any other method is hereby prohibited, including
at points of withdrawal by the City of Granite City.

Section 2. Penalties. Any person violating the provisions of this ordinance shall be ¦
subject to a fine of up to $750.00 for each violation, except that the City itself shall not be liable
under any circumstances.

Page 1 of 2

-------
Section 3. Definitions. "Person" is any individual, partnership, co-partnership, firm,
company, limited liability company, corporation, association, joint stock company, trust, estate,
political subdivision, or any other legal entity, or their legal representatives, agents or assigns.

"Potable Water" is any water used for human or domestic consumption, including, but
not limited to, water used for drinking, bathing, swimming, washing dishes, or preparing foods.

Section 4. Memorandum of Understanding. As this Ordinance applies to the City of
Granite aCity, no Memorandum of Understanding is required.

Section 5. Repealer. All ordinances or parts of ordinances in conflict with this
ordinance are hereby repealed insofar as they are in conflict with this ordinance.

Section 6. Severability. If any provision of this ordinance or its application to any
person or under any circumstances is adjudged invalid, such adjudication shall not affect the
validity of the ordinance as a whole or of any portion not adjudged invalid.

Section 7. Effective Date. This ordinance shall be in full force and effect from an after

pass?*"**	onrl nnKli/*atinrt ic* ronnirprl Kv 1 o

approve:

j 2001.

// day of

APPROVED by the Mayor of the City of Granite City, Illinois, this

j 2001.

MAYOR

ATTEST:

Page 2 of 2

-------
APPENDIX D - AERIAL PHOTOGRAPH SITE PARCELS

-------
Jennison-Wright Site Parcels

Addresses:

•	899 West 22nd Street, Granite City, Madison County, Illinois 62040 (North Parcel)

o 22-1-19-13-16-401-001

•	900 West 22nd Street, Granite City, Madison County, Illinois 62040 (South Parcel)

o 22-1-19-13-16-401-002
o 22-1-19-13-20-401-001

-------
APPENDIX E - INSTITUTION CONTROL AREAS FIGURE

-------


HMZ and SMZ Coordinates

Point

X Coord

Y Coord

A

2301466,5353

744569.3014

B

230129.6210

744203.9093

C

2301211.3561

744246.7229

D

2301381.9315

744609.3111

E

2301427.3325

744587,8407

T

2301298.0772

744321.2225

G

2301256.7026

74434,1150

H

2300987.8207

743683.5931

I

2300835.4162

743399,1860

J

2300602.6875

743400,4330

K

2300603.7621

743687.7108

L

2300702.3140

743153,7311

M

2300660.65 48

743077.2511

N

2300559,2253

743123.7519

~

2300599.8949

743202.2372

P

2300411.7944

743332.5771

Q

2300411,7944

742941.7725

R

2300270.39 85

742941,7725

S

2300269.9555

743332.9923

T

2300957.2606

743676.6432

U

2300929,4974

743621.2300

V

2300864.8000

743660.7783

w

2300893.4030

743716.9527

X

2301116.8068

743990.0468

Y

2300943.3106

743596.1651

z

2300427.1791

742648.6242

AA

2300387.9228

742670.6893

BB

2300553.5625

742975.6513

CC

2300578.5870

742963,4535

22ND STREET LAGOON (AREA G)

~

+

SCALE IN FEET:

375

LEGEND

GROUNDWATER
MANAGEMENT ZONE

SOIL MANAGEMENT
ZONE

MONITORING WELL

ABANDONED
MONITORING WELL

JENNITE PIT

MW-1S

ALLEY

FIGURE 1-1



Institutional Control

Areas

JENNISON-WRIGHT

SITE

GRANITE CITY, MADISON

COUNTY,

ILLINOIS



SEE ABOVE

01/2010

caa. n£ Ha

ICIP_120909.DWG

www WOl

1

-------
APPENDIX F - PUBLIC NOTICE

-------
A2 FRIDAY, DECEMBER 1, 2023

TTHEINTELLIGENCER.COM

Illinois EPA Begins Review
of the Jennisen-Wright Sup«rfund Site
Granite City, Illinois

The Illinois Environmental Protection Agency and the United
States Environmental Protection Agency {U.S. EPA) are con-
ducting the required Five-Year Review of the Jertmson-Wright
Superfund Site located at 900 West 22nd Street, Granite City,
Illinois, "he Comprehensive Environmental Response, Com-
pensation, and Liability Act of 1980 (CERCLA) requires regular
checkups of sites (at least every five years) where cleanup is
underway, with waste managed on-site, to ensure the cleanup
continues to be protective ot human health and the environ-
ment, This is trie fourth five-year review o* this site following the

start of remedial action in 2004.

In 1992, Illinois EPA took actions to aleviate the spread of con-
tamination and to stabilize the site. In 1994, a removal action
was conducted, which included removing and properly dispos-
ing of approximately 175 drums of chemicals, removal of waste
materials from on-site storage vessels, constructor! ot a pro-
tective cap over a portion of the site, and excavation of some
contaminated soils. The Jennison-Wright Site underwent fur-
ther cleanup to address residual soil contam ination and waste
disposal pits. The groundwater treatment system was com-
pleted in 2009, was enhanced in 2018, and continues to cper

ate as designed
More information is available for public review at the Granite
City Public Library, 2001 Oeimar Avenue, Granite City, Illinois

62040. The next Five-Year Review w II be due in 2029.
"tie Five-Year Review is an opportunity for you to tell Illinois
EPA about site conditions and any concerns you may have.
Please contact Sabrina Bailey, Illinois EPA Office of Com-
munity Relations at P.O. Box 19276, Springfield, Illinois 62734,
or by telephone at 847-294-4394 or e-mail at
sabrina. bailey® iHinois,gov.

23-2049! 12/1

-------
APPENDIX G - MONITORING WELL LOCATION MAP

-------
Well Location Map

900 West 22nd'Street



100 ft

Notes

• Monitoring Well

• Extraction Well

-------
APPENDIX H - GROUNDWATER DATA

(4th Quarter 2023 and 1st Quarter 2024)

-------
REACT Project #8460.03.24

TABLE - Jennison Wright Superfund Site
Fourth Quarter 2023 Groundwater Analysis vs Site CUO and Taco Tier I Objectives

Jennison Wright

Sample Date

11/29/2023|

111/29/2023|

111/29/2023|

111/29/2023|

111/29/2023|

111/29/2023|

12/7/2023|

12/7/2023

12/7/2023|

112/7/2023

12/7/2023|

112/7/2023









18S

17S

6D

6M

8M

8S

23D

5S

22D

20D

5D

21D

Proposed
CUO

IEPA
TACO
Tier I

Analyte

Unit

Result

Result

Result

Result

Result

Result

Result

Result

Result

Result

Result

Result

ng/L

ng/L

VOCs - 5030, 8260B































Benzene | ng/L



2.8





92.1





0.5



<

0.1

M

<

0.1

M



2.5





0.2



367





35.8





0.3



<

0.1

M

<

1000

M



10

5

SVOCs - 3510C, 8270C Sims, 8270C













































































Naphthalene

Hg/L



7.5





7330





74.6





8.9





2.06





116





1940



12900





1960





26.9





1.2





22000





400

25

Chrysene

Hg/L



1.24



<

0.4

M

<

0.04

M

<

0.04

M

<

0.04

M

<

0.04

M

<

1

M

2.75



<

1

M

<

0.4

M

<

0.40

M



2570





4

1.5

Benzo(a)anthracene

Hg/L



1.42



<

0.6

M

<

0.06

M

<

0.06

M

<

0.06

M

<

0.06

M

<

1.5

M

3.75



<

1.5

M

<

0.60

M

<

0.60

M



2980





0.13

0.13

Benzo(b)fluoranthene

Hg/L



1.08



<

0.4

M

<

0.04

M

<

0.04

M

<

0.04

M



0.05



<

1

M

4





1



<

0.4

M

<

0.4

M



2020





0.18

0.18

Benzo(k)fluoranthene

Hg/L



0.46



<

0.4

M

<

0.04

M

<

0.04

M

<

0.04

M

<

0.04

M

<

1

M

4

M

<

1

M

<

0.40

M

<

0.4

M



825





0.4

0.17

Pentachlorophenol

Hg/L



106



<

70

M



45





21



<

7

M



36300



<

175

M

400



<

175

M

<

70

M

<

70

M

<

3500

M



1

1

2,4-Dimethylphenol

Hg/L

<

4

M



32



<

2

M

<

2

M

<

2

M

<

2

M

<

50

M

240



<

50

M

<

20

M

<

20

M

<

1000

M



200

140

2-Methylphenol (o-cresol)

Hg/L

<

4

M



21



<

2

M

<

2

M

<

2

M

<

2

M

<

50

M

50

M

<

50

M

<

20

M

<

20

M

<

1000

M



500

350

2-Methylnathalene

Hg/L

<

6

M



272





5



<

3

M

<

3

M



164





75



339





75



<

30

M

<

30

M



21600







NA

Acenapthene

Hg/L



52





236





5.87





1.3





85.3





6.96





278



294





247





39.2





58.1





8960







420

Dibenzofuran

Hg/L



10





113





3



<

2

M

<

2

M



5





140



140





120



<

20

M

<

20

M



5380







NA

Flourene

Hg/L



10.3





116





3.35





0.95





18.2





7.7





119



139





112





20.2





14.8





7730







280

Phenanthrene

Hg/L



7.64





53.2





2.38





1.01





0.39





6.38





118



116





101





4.9



<

1.6

M



25200







NA

2,4-Dichlorophenol

Hg/L

<

2

M



26



<

1

M

<

1

M

<

1

M



3



<

25

M

25

M



25



<

10

M

<

10

M

<

500

M





21

Carbazole

Hg/L



88





629





13



<

0.03

M

<

3

M



6





190



420





170



<

30

M

<

30

M

<

1500

M





NA

Acenaphthylene

Hg/L



0.4





8.3





0.19





0.04





0.17





1.11





1.2



29





5.25





0.5





1.2





685







NA

Anthracene

Hg/L



0.86



<

0.4

M



0.06





0.04





0.2





0.52





6.5



8.75





8.75





1





0.9





3280







2100

Fluoranthene

Hg/L



3.56



<

0.7

M



0.17





0.13





0.42



<

0.07

M



14



23.2





17.2





5.8





5.5





12700







280

Pyrene

Hg/L



2.82



<

0.6

M



0.11





0.08





0.17





6.38





8



15





9.25





3.5





3.4





9670







210

Phenol

Hg/L

<

4

M

<

20

M

<

2

M

<

2

M

<

2

M

<

2

M

<

50

M

50

M

<

50

M

<

20

M

<

20

M

<

1000

M





100

Pesticides 3510C, 8180B





























alpha-BHC Hg/L

<| 0.091 M

< | 0.041 M

< | 0.04| M

< 1 0.02| M

< 1 0.04| M

| 0.08|

<| 0.02| M

0.041 M

<| 0.02| M

<| 0.021 M

<| 0.02| M

<| 91.71 M

0.03

0.03

Metals (ICP) - 3005A, 6010B





























Manganese | ng/L

o

LO
(N

CD
CO
CM

o
(N
CM

1 271|

| 411|

| 2730|

CO
-vj

29801

00
00

o

CO
CM

CO
LO

I 180| |

200



Red shaded cells indicate an exceedence of proposed clean up objectives
Bold values indicate an exceedence of IEPA TACO Tier I objectives

R - Result is less than the reporting limit.

M-Results is less than the MDL

C:\Users\nicole.wilson\Desktop\JW\JW data reports\Copy of JW Groundwater Table QTR4-23 with dates.xls

-------
REACT Project #8460.03.23

TABLE - Jennison Wright Superfund Site
First Quarter 2024 Groundwater Analysis vs Site CUO and Taco Tier I Objectives

Jennison Wright

Sample Date

3/6/2024

| 3/6/2024

3/12/2024|

3/12/2024|

| 3/6/2024

3/6/20241

| 3/12/2024

3/14/2024|

| 3/14/2024

3/14/2024|

| 3/12/2024

3/14/2024|









18S

17S

6D

6M

8M

8S

23D

5S

22D

20D

5D

21D

Proposed
CUO

IEPA
TACO
Tier I

Analyte

Unit

Result

Result

Result

Result

Result

Result

Result

Result

Result

Result

Result

Result

ng/L

ng/L

VOCs - 5030, 8260B































Benzene | ng/L



34.2





60.3



<

0.1

M

<

0.1

M

<

0.1

M



1.9



<

0.1

M

270





23



<

0.1

M

<

0.1

M

<

1000

M



10

5

SVOCs - 3510C, 8270C Sims, 8270C













































































Naphthalene

W?/L



145





7160





1.72





1.64





1.16





82.9





1670



10300





1380





119.0





10.7





180000





400

25

Chrysene

W?/L

<

0.08

M

<

0.8

M

<

0.08

M

<

0.08

M

<

0.16



<

0.08

M



0.14



4.3





0.52





0.14



<

0.08

M

<

51700

M



4

1.5

Benzo(a)anthracene

W?/L

<

0.1

M

<

1

M

<

0.1

M

<

0.10

M

<

0.20

M

<

0.1

M



0.16



6





0.84





0.26



<

0.10

M

<

41400

M



0.13

0.13

Benzo(b)fluoranthene

W?/L

<

0.14

M

<

1.4

M

<

0.14

M

<

0.14

M

<

0.28

M

<

0.14

M



0.14



4.8





0.54



<

0.14

M

<

0.14

M

<

25900

M



0.18

0.18

Benzo(k)fluoranthene

W?/L

<

0.14

M

<

1.4

M

<

0.14

M

<

0.14

M

<

0.28

M

<

0.14

M

<

0.14

M

1.7





0.18



<

0.14

M

<

0.14

M

<

56900

M



0.4

0.17

Pentachlorophenol

W?/L



134



<

90

M



9



<

9

M

<

18

M



60900



<

9

M

678



<

9

M

<

9

M

<

9

M

<

533000

M



1

1

2,4-Dimethylphenol

kig/L



5



<

30

M

<

2

M

<

2

M

<

4

M

<

2

M

<

2

M

246



<

2

M

<

2

M

<

2

M

<

388000

M



200

140

2-Methylphenol (o-cresol)

kig/L

<

2

M

<

20

M

<

2

M

<

2

M

<

4

M

<

200

M

<

2

M

10

M

<

2

M

<

2

M

<

2

M

<

253000

M



500

350

2-Methylnaphthalene

kig/L

<

8

M



318



<

8

M

<

8

M

<

16

M



139





19



260





19



<

8

M

<

8

M

<

378000

M





NA

Acenapthene

kig/L



49.6





183





0.28





0.4





99.5





5.1





240



255





221





40.5





2.46





91000







420

Dibenzofuran

kig/L



9





84



<

3

M

<

3

M

<

6

M

<

4

M



106



115





123





14



<

3

M

<

398000

M





NA

Flourene

kig/L



8.1





89





0.16





0.38





14.2





5.38





103



109





108





20.7





2.12





78000







280

Phenanthrene

Hg/L



5.48





42





0.3





0.72





0.8



<

10

M



90.6



91.9





83.3





8.16





2.54





240000







NA

2,4-Dichlorophenol

kig/L

<

3

M

<

30

M

<

3

M

<

3

M

<

6

M

<

3

M

<

3

M

15

M



11



<

3

M

<

3

M

<

259000

M





21

Carbazole

kig/L



72





689



<

2

M

<

2

M

<

4

M

<

200

M



181



630





141





11



<

2

M

<

279000

M





NA

Acenaphthylene

kig/L



0.42





5.4



<

0.08

M

<

0.08

M

<

0.16

M



1.08





0.76



24.8





5.16





0.82



<

0.08

M

<

36200

M





NA

Anthracene

kig/L



0.22



<

1

M

<

0.1

M

<

0.1

M



0.32



<

10

M



4.42



7





4.94





1.22





0.18



<

51700

M





2100

Fluoranthene

Hg/L



0.28



<

1

M



0.18





0.36





0.8



<

10

M



8.58



33.3





14.7





6.1





0.54





120000







280

Pyrene

kig/L



0.18



<

1

M



0.12





0.16





0.4



<

10

M



4.8



23





7.62





3.58





0.28





97000







210

Phenol

kig/L

<

3

M

<

30

M

<

3

M

<

3

M

<

6.00

M

<

300

M

<

3

M

15

M

<

3

M

<

3

M

<

3

M

<

264000

M





100

Pesticides 3510C, 8180B





























alpha-BHC \x%/l

<| 0.041 M

< | 0.041 M

< | 0.021 m

< | 0.021 M

< | 0.02| M

I 0.12|

< | 0.02| M

0.041 M

<| 0.041 M

<| 0.041 M

<| 0.02| M

<| 1000|M

0.03

0.03

Metals (ICP) - 3005A, 6010B





























Manganese | ng/L

| 1170|

| 2221

CM
CM

1 776|

CO
CD
O

| 2150|

CD
O

28701

I 413|

CO
CD
O

CM
CO

1 150| |

200



Red shaded cells indicate an exceedence of proposed clean up objectives
Bold values indicate an exceedence of IEPA TACO Tier I objectives

R - Result is less than the reporting limit.

M-Results is less than the MDL

-------
APPENDIX I - PCP PROCESS AREA FIGURE

-------
MW-14S ,

4-

LEGEND

® - MONITORING WELL SAMPLED

- MONITORING WELL NOT SAMPLED
(g) - GEOPROBE LOCATION SAMPLED
® - GEOPROBE LOCATION NOT SAMPLED
-HRC BARRIER TRENCH

Appendix H

Jennison-Wright Site, Granite City, Illinois

r ecology and environment engineering, inc.

f International Speciuhsts iii the Environment

FIGURE 5-3
PCP Process area
Pentachlorophenol Concentrations
in Groundwater (December, 2009)

MW-12S

©

GP44

(AREA G)

MW-:

PCP
ug/L

^ 25,000

—	10,000

—	1000

	 100 MW-1S

—	10

-------
APPENDIX J - SITE INSPECTION CHECKLIST AND PHOTOGRAPHS

-------
Site Inspection Checklist

1. SITE INFORMATION

Site name:

Jennison-Wright Superfund Site

Date of inspection:
4/10/2024

Location and Region:
Granite City, IL Region 5

EPA ID:
ILD006282479

Agency, office, or company leading the FYR:

Illinois EPA

Weather/temperature:

56 °F, overcast and rainy

Remedy Includes: (Check all that apply)

~ Landfill cover/containment

~ Monitored natural attenuation

M Access controls

~ Groundwater containment

IEI Institutional controls

IEI Groundwater pump and treatment

~ Surface water collection and treatment

~	Vertical barrier walls

~	Other: Click or tap here? to enter text.

Attachments:

~ Inspection team roster attached

~ Site map attached

1

-------
Site Inspection Checklist

II. INTERVIEWS (Check all that apply)

Operations	.

1.	O&M Site Manager	Tony Warren,	Manager	4/10/2024

Interviewed: Kl at site ~ at office ~ by phone Phone Number: Click here to enter text,

Problems, suggestions:	~ Report attached

Provided a drive with site data/reports. Gave general impressions about the Site and/or
remedy. Identified some major limitations of the existing groundwater treatment system,
which should be further looked into.	

,	Click or tap to

2.	O&M Staff	Name ,	Title ,

611161 d UcR6.

Interviewed: ~ at site ~ at office ~ by phone Phone Number: Click here to enter text,
Problems, suggestions: ~ Report attached
	NA	

3.	Local regulatory authorities and response agencies (i.e., State and Tribal offices, emergency
response office, police department, office of public health or environmental health, zoning office,
recorder of deeds, or other city and county offices, etc.) Fill in all that apply.

Agency: NA

Contact: Name /Title , Click or tap to enter a date,, P: Phone Number
Problems, suggestions: Provided a drive with	~ Report attached

Click or tap here to enter text,

Agency: Click or tap here to enter text,

Contact: Name , Title , Click or tap to enter a date,, P: Phone Number
Problems, suggestions:	~ Report attached

Click or tap here to enter text,

Agency: Click or tap here to enter text,

Contact: Name , Title , Click or tap to enter a date,, P: Phone Number
Problems, suggestions:	~ Report attached

Click or tap here to enter text,

Agency: Click or tap here to enter text,

Contact: Name , Title , Click or tap to enter a date,, P: Phone Number

Problems, suggestions:

Click or tap here to enter text,

4.	Other Interviews (optional):	~ Report attached

-------
Site Inspection Checklist

Click or tap here to enter text,



III. ON-SITE DOCUMENTS & RECORDS VERIFIED (Check all that apply)

1.

O&M Documents









IEI O&M manual

M Readily available

SI Up to date

~ N/A



IEI As-built drawings

M Readily available

M Up to date

~ N/A



ISI Maintenance logs

M Readily available

SI Up to date

~ N/A



Remarks: Click or tap here to enter text,





2.

Site-Specific Health and Safety Plan



M Readily available





ISI Contingency Plan/Emergency Response Plan

M Readily available





Remarks: Click or tap







3.

O&M and OSHA Training Records











M Readily available

SI Up to date

~ N/A



Remarks: Click or tap







4.

Permits and Service Agreements









~ Air discharge permit

~ Readily available

~ Up to date

~ N/A



~ Effluent discharge

~ Readily available

~ Up to date

~ N/A



ISI Waste disposal, POTW

M Readily available

~ Up to date

~ N/A



SI Other permits: Landfill Disposal









Remarks: Click or tap







5.

Gas Generation Records











~ Readily available

~ Up to date

SI N/A



Remarks: Click or tap





6.

Settlement Monument Records











~ Readily available

~ Up to date

SI N/A



Remarks: Click or tap







7.

Groundwater Monitoring Records











M Readily available

~ Up to date

~ N/A



Remarks: Provided on thumb drive at site inspection





8.

Leachate Extraction Records











M Readily available

SI Up to date

~ N/A

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Site Inspection Checklist

Remarks: Click or tap here to enter text.

9.

Discharge Compliance Records







~ Air ~ Readily available

~ Up to date IEI

N/A



~Water (effluent) ~ Readily available

~ Up to date ^

N/A



Remarks: Click or tap here to enter text,





10.

Daily Access/Security Logs







~ Readily available

~ Up to date ^

N/A



Remarks: Click or tap here to enter text,





IV. O&M COSTS

1.

O&M Organization







~ State in-house M Contractor for State





~ PRP in-house ~ Contractor for PRP





~ Federal Facility in-house ~ Contractor for Federal Facility





Remarks: Click or tap here to enter text,





2.

O&M Cost Records





4

-------
Site Inspection Checklist

KlReadily available

ISI Up to date

ISI Funding mechanism/agreement in place

Original O&M cost estimate Click or tap here to enter text,

~ Breakdown attached

Total annual cost by year for review period if available

From

To

Total cost



Click or tap to enter a

Click or tap to

Click or tap here to

~ Breakdown attached

date.

enter a date,

enter text,



From

To

Total cost



Click or tap to enter a

Click or tap to

Click or tap here to

~ Breakdown attached

date.

enter a date,

enter text,



From

To

Total cost



Click or tap to enter a

Click or tap to

Click or tap here to

~ Breakdown attached

date.

enter a date,

enter text,



From

To

Total cost



Click or tap to enter a

Click or tap to

Click or tap here to

~ Breakdown attached

date.

enter a date,

enter text,



From

To

Total cost



Click or tap to enter a

Click or tap to

Click or tap here to

~ Breakdown attached

date.

enter a date,

enter text,



3. Unanticipated or Unusually High O&M Costs During Review Period

Describe costs and reasons:

Click or tap here to enter text,

V. ACCESS AND INSTITUTIONAL CONTROLS



M Applicable

~ N/A



1.

Fencing Damaged ~ Location shown on site map

ISI Gates secured

~ N/A



Remarks: Fence repairs are an ongoing maintenance activity due to trespass attempts.



2.

Other Access Restrictions ~ Location shown on site map
Remarks: Signage on fencing

~ Gates secured



3.

Institutional Controls (ICs)







A. Implementation and Enforcement







Site conditions imply ICs not properly implemented

~ Yes SI No

~ N/A



Site conditions imply ICs not being fully enforced

~ Yes SI No

~ N/A



Type of monitoring (e.g., self-reporting, drive by)

5

Click or tap here to enter text,

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Site Inspection Checklist

Frequency	Click or tap

Responsible party/agency	Click or tap

Contact: Name /Title , Click or tap to enter a date,, P: Phone Number

Reporting is up-to-date

~

Yes

~

No

~

N/A

Reports are verified by the lead agency

~

Yes

~

No

~

N/A

Specific requirements in deed or decision documents have been
met

~

Yes

Kl

No

~

N/A

Violations have been reported

~

Yes

~

No

~

N/A

Other problems or suggestions:

ICs needed. Discussed in five-year review report.

B. Adequacy	~ ICs are adequate	M ICs are inadequate	~ N/A

Remarks: See notes in Item 1 above.

4. General

A.	Vandalism/Trespassing ~ Location shown on site map IEI No vandalism evident
Remarks: Contractor states trespass attempts are frequent and causes frequent fence repairs

B.	Land use changes on site	M N/A

Remarks: Click or tap here to enter text,

C.	Land use changes off site	M N/A

Remarks: Click or tap here to enter text,

VI. GENERAL SITE CONDITIONS
1. Roads	M Applicable	~ N/A

A.	Roads damaged	~ Location shown on site map	IEI Roads adequate ~ N/A
Remarks: Click or tap here to enter text,

B.	Other Site Conditions

f	¦	r tap hen	xt.

VII. LANDFILL COVERS
1. Landfill Surface	~ Applicable	M N/A

A. Settlement (Low Spots) ~ Location Shown on Site Map	~ Settlement Not Evident

Area I Extent: Click or tap here to enter text,	Depth: Click or tap here to enter text,

6

-------
Site Inspection Checklist

Remarks: Click or tap here to enter text.

B.

Cracks

~ Location Shown on Site Map



~ Cracking Not Evident



Lengths: Click or tat
to enter text.

) here

Widths: Click or tap here to ent

er text,

Depths: Click or tap here to
enter text,



Remarks: Click or ta

p here to enter text,





C.

Erosion

~ Location Shown on Site Map



~ Erosion Not Evident



Areal Extent: Click c

sr tap here to enter text,

Depth: C

ick or tap here to enter text,



Remarks: Click or ta

p here to enter text,





D.

Holes

~ Location Shown on Site Map



~ Holes Not Evident



Areal Extent: Click c

sr tap here to enter text,

Depth: C

ick or tap here to enter text,



Remarks: Click or ta

p here to enter text,





E.

Vegetative Cover

~ Grass



~ Cover Properly Established



~ Tress/Shrubs (indicate size and locations on a diagram



~ No Signs of Stress



Remarks: Click or ta

p here to enter text,





F.

Alternative Cover (armored rock, concrete, etc.)

Remarks: Click or tap here to enter text,



~ N/A

G.

Bulges

~ Location Shown on Site Map



~ Bulges Not Evident



Areal Extent: Click c

sr tap here to enter text,

Height: C

lick or tap here to enter text,



Remarks: Click or tap here to enter text,





H.

Wet Areas/Water Damage ~ Wet Areas/Water Damage Not Evident



~ Wet Areas

~ Location Shown on Site Map

Areal Extent: Click or tap here to enter
text.



~ Ponding

~ Location Shown on Site Map

Areal Extent: Click or tap here to enter
text.



~ Seeps

~ Location Shown on Site Map

Areal Extent: Click or tap here to enter
text.



~ Soft Subgrade

~ Location Shown on Site Map

Areal Extent: Click or tap here to enter
text.



Remarks: Click or tap here to enter text,





1.

Slope Instability

~	Location Shown on Site Map

~	Slides

~ Slope Instability Not Evident

Areal Extent: Click or tap here to enter
text.

7

-------
Site Inspection Checklist

Remarks: Click or tap here to enter text,

2.	Benches	~ Applicable	~ N/A

(Horizontally constructed mounds of earth placed across a steep landfill side slope to interrupt the slope
in order to slow down the velocity of surface runoff and intercept and convey the runoff to a lined
channel.)

A.	Flows Bypass Bench ~ Location Shown on Site Map ~ N/A or Okay
Remarks: Click or tap here to enter text,

B.	Bench Breached ~ Location Shown on Site Map	~ N/A or Okay
Remarks: Click or tap here to enter text,

C.	Bench Overtopped ~ Location Shown on Site Map ~ N/A or Okay
Remarks: Click or tap here to enter text,

3.	Letdown Channels	~ Applicable	~ N/A

(Channel lined with erosion control mats, riprap, grout bags, or gabions that descend down the steep side
slope of the cover and will allow the runoff water collected by the benches to move off of the landfill
cover without creating erosion gullies.)

A.	Settlement	~ Location Shown on Site Map ~ Settlement Not Evident

Area I Extent: Click or tap here to enter text,	Depth: Click or tap here to enter text,

Remarks: Click or tap here to enter text,

B.	Material Degradation ~ Location Shown on Site Map	~ Degradation Not Evident

. 1T	.	.	Areal Extent: Click or tap here to enter

Material Type: Click or tap here to enter text.

f	text.

Remarks: Click or tap here to enter text,

C.	Erosion	~ Location Shown on Site Map	~ Erosion Not Evident
Areal Extent: Click or tap here to enter text, Depth: Click or tap here to enter text,
Remarks: Click or tap here to enter text,

D.	Undercutting	~ Location Shown on Site Map	~ Undercutting Not Evident
Areal Extent: Click or tap here to enter text, Depth: Click or tap here to enter text,
Remarks: Click or tap here to enter text,

E.	Obstructions	~ Location Shown on Site Map	~ Undercutting Not Evident
Type: Click or tap here to enter text,

-------
Site Inspection Checklist

Area I Extent: Click or tap here to enter text,
Remarks: Click or tap here to enter text,

Size: Click or tap here to enter text,

F. Excessive Vegetative Growth ~ Location Shown on Site Map ~ Excessive Growth Not Evident
Area I Extent: Click or tap here to enter text,

Remarks: Click or tap here to enter text,

~ Vegetation in channels does not obstruct
flow

4. Cover Penetrations

~ Applicable

~ N/A

A. Gas Vents

~	Properly secured/locked

~	Good condition

~	Needs Maintenance

~ Active	~ Passive

~	Functioning ~ Routinely sampled

~	Evidence of leakage at penetration

~	N/A

Remarks: Click or tap here to enter text,

B. Gas Monitoring Probes

~	Properly secured/locked

~	Good condition

~	Needs Maintenance

Remarks: Click or tap here to enter text,

~	Functioning ~ Routinely sampled

~	Evidence of leakage at penetration

~	N/A

C. Monitoring Wells

~	Properly secured/locked

~	Good condition

~	Needs Maintenance

Remarks: Click or tap here to enter text,

~	Functioning ~ Routinely sampled

~	Evidence of leakage at penetration

~	N/A

D. Leachate Extraction Wells

~	Properly secured/locked

~	Good condition

~	Needs Maintenance

Remarks: Click or tap here to enter text,

~	Functioning ~ Routinely sampled

~	Evidence of leakage at penetration

~	N/A

9

-------
Site Inspection Checklist

E. Settlement Monuments ~ Located ~ Routinely Surveyed ~ N/A
Remarks: Click or tap here to enter text.

5.

Gas Collection and Treatment

~ Applicable

~ N/A



A. Gas Treatment Facilities

~	Flaring

~	Good condition
Remarks: Click or tap here

~	Thermal Destruction

~	Needs Maintenance

to enter text,

~ Collection for Reuse



B. Gas Collection Wells, Manifolds, and Piping

~ Good condition ~ Needs Maintenance
Remarks: Click or tap here to enter text,

~ N/A

C. Gas Monitoring Facilities (e.g. gas monitoring of adjacent homes or buildings)

~ Good condition ~ Needs Maintenance ~ N/A
Remarks: Click or tap here to enter text.

6.

Cover Drainage Layer

~ Applicable

~ N/A



A. Outlet Pipes Inspected

Remarks: Click or tap here

~ Functioning

to enter text,

~ N/A



B. Outlet Rock Inspected ~ Functioning

Remarks: Click or tap here to enter text,

~ N/A

7.

Detention/Sediment Ponds

~ Applicable

~ N/A



A. Siltation

Areal Extent: Click or tap h
Remarks: Click or tap here

~ Siltation Not Evident

are to enter text, Depth: Clicl
to enter text,

~ N/A

or tap here to enter text,



B. Erosion

Areal Extent: Click or tap h
Remarks: Click or tap here

~ Erosion Not Evident

are to enter text, Depth: Clicl
to enter text,

or tap here to enter text,



C. Outlet Works ~ Functioning

Remarks: Click or tap here to enter text,

~ N/A



D. Dam ~ Functioning
Remarks: Click or tap here to enter text,

~ N/A

10

-------
Site Inspection Checklist

8. Retaining Walls

~ Applicable

~ N/A

A. Deformations	~ Location Shown on Site Map

Horizontal Displacement: Click or tap here? to enter text.

Vertical Displacement: Click or tap here to enter text.

Rotational Displacement: Click or	to enter text.

Remarks: Click or tap here to enter text,

~ Deformation Not Evident

B. Degradation	~ Location Shown on Site Map

Remarks: Click or tap here to enter text,

~ Deformation Not Evident

9. Perimeter Ditches/Off-Site Discharge

~ Applicable

~ N/A

A. Siltation	~ Location Shown on Site Map ~ Siltation Not Evident

Area I Extent: Click or tap here to enter text,	Depth: Click or tap here to enter text,

Remarks: Click or tap here to enter text,

B.	Vegetative Growth	~ Location Shown on Site Map ~ N/A
~ Vegetation Does Not Impede Flow

Area I Extent: Click or tap here to enter text,	Type: Click or tap here to enter text,

Remarks: Click or tap here to enter text,

C.	Erosion	~ Location Shown on Site Map ~ Erosion Not Evident
Area I Extent: Click or tap here to enter text,	Depth: Click or tap here to enter text,
Remarks: Click or tap here to enter text,

D.	Discharge Structure	~ Functioning	~ N/A
Remarks: Click or tap here to enter text,

VIII. VERTICAL BARRIER WALLS

~ Applicable

Kl N/A

1.	Settlement	~ Location Shown on Site Map	~ Settlement Not Evident
Areal Extent: Click or tap here to enter text, Depth: Click or tap here to enter text,
Remarks: Click or tap here to enter text,

2.	Performance Monitoring Type of Monitoring: Click or tap here to enter text,

11

-------
Site Inspection Checklist

~ Performance Not Monitored
Frequency: Click or tap here? to enter text.
Remark:-

~ Evidence of Breaching

Head Differential: Click or tap here to enter text,

IX. GROUNDWATER/SURFACE WATER REMEDIES

M Applicable

~ N/A

1. Groundwater Extraction Wells, Pumps, and Pipelines

Applicable

~ N/A

A.	Pumps, Wellhead Plumbing, and Electrical	~ N/A

IEI Good Condition	~ All Required Wells Properly Operating ~ Needs Maintenance

Remarks: Good condition with regular maintenance

B.	Extraction System Pipelines, Valves, Valve Boxes, and Other Appurtenances

IEI Good Condition	~ Needs Maintenance

Remarks: Click or tap here to enter text,

C. Spare Parts and Equipment

M Readily Available	~ Good Condition

Remarks: Click or tap here to enter text,

~	Needs to be Provided

~	Requires Upgrade

2. Surface Water Collection Structures, Pumps, and Pipelines

~ Applicable

Kl N/A

A. Collection Structures, Pumps, and Electrical

~ Good Condition	~ Needs Maintenance

Remarks: Click or tap here to enter text,

B. Surface Water Collection System Pipelines, Valves, Valve Boxes, and Other Appurtenances

~ Good Condition	~ Needs Maintenance

Remarks: Click or tap here to enter text,

C. Spare Parts and Equipment

~ Readily Available	~ Good Condition

Remarks: Click or tap here to enter text,

~	Needs to be Provided

~	Requires Upgrade

3. Treatment System

Applicable

~ N/A

A. Treatment Train (Check components that apply)

~	Metals removal	IEI Oil/Water Separation

~	Air Stripping	IEI Carbon Absorbers

IEI Filters oil filter-organo clay, activated carbon

12

~ Bioremediation

-------
Site Inspection Checklist

IEI Additive (e.g. chelation agent, flocculent) biocide/AN400/AN3104

~	Others Click or tap here to enter text,

IEI Good Condition	~ Needs Maintenance

IEI Sampling ports properly marked and functional

IEI Sampling/maintenance log displayed and up to date

IEI Equipment properly identified

IEI Quantity of groundwater treated annually On thumb drive provided at site visit

~	Quantity of surface water treated annually Click or tap here to enter text.

Remarks: Click or tap here to enter text,

B.	Electrical Enclosures and Panels (properly rated and functional)

~	N/A	IEI Good Condition	~ Needs Maintenance
Remarks: Click or tap here to enter text,

C.	Tanks, Vaults, Storage Vessels	~ N/A

~	Proper Secondary Containment IEI Good Condition	~ Needs Maintenance

Remarks: Click or tap here to enter text,

D. Discharge Structure and Appurtenances



~ N/A EE

3 Good Condition ~ Needs Maintenance

Remarks: Click or tap here to enter text,



E. Treatment Building(s)



~ N/A

IEI Good condition (esp. roof and doorways)

~ Needs repair

ISI Chemicals and equipment properly stored

Remarks Click or tap here to enter text,



F. Monitoring Wells (Pump and Treatment Remedy) ~ N/A

IEI Properly secured/locked

M Functioning

M Routinely sampled

ISI All required wells located

M Good condition

~ Needs Maintenance

Remarks Click or tap here to enter text,



4. Monitoring Data

A. Monitoring Data:



ISI Is Routinely Submitted on Time

SI Is of Acceptable Quality

13

-------
Site Inspection Checklist

B. Monitoring Data Suggests:

~ Groundwater plume is effectively contained ~ Contaminant concentrations are declining
5. Monitored Natural Attenuation

A. Monitoring Wells (natural attenuation remedy)

~ Properly secured/locked ~ Functioning

~ All required wells located ~ Needs Maintenance
Remarks: Click or tap here to enter text,

X. OTHER REMEDIES

If there are remedies applied at the site which are not covered above, attach an inspection sheet
describing the physical nature and condition of any facility associated with the remedy. An example
would be soil vapor extraction.

XI. OVERALL OBSERVATIONS

1. 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.).

The remedy is intended to contain the plume(s) and remove contamination.

After the new system was installed, it was determined that steam injection operating 100% of the time
was no longer feasible. The system became overwhelmed and caused more downtime due to
maintenance. Instead, the contractor injects water at 102°F for half the time. The recovery was better
and less maintenance was required.

The treatment system is not able to access the deeper free product still present at the site. There is still
about 50' below the bottom of the extraction wells to bedrock.

While the new larger system is able to remove more contamination, an oil-water separator is intended to
catch residual scale contamination, not free product. Combined with the limited reach of the extraction
wells, the treatment system will never reach the intended goal of the remedy.

The treatment system extraction well network covers only about 1/3 of the facility. There is groundwater
contamination across the entire facility that is not being addressed.

|Xl N/A

~ Routinely sampled

~ Good condition

-------
Site Inspection Checklist

2.	Adequacy of O&M

Describe issues and observations related to the implementation and scope of O&M procedures. In
particular, discuss their relationship to the current and long-term protectiveness of the remedy.
See #1 above. With 2/3 of the groundwater contamination not being addressed and the treatment
systems ultimate inability to ever achieve closure, the current and long-term protectiveness of remedy
are in jeopardy.

3.	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 that suggest that the protectiveness of the remedy may be
compromised in the future.

See #1 above.

4.	Opportunities for Optimization

Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy.
Large scale improvements to the size, depth, and coverage area of the treatment system will be needed.

15

-------
Site Inspection Pictures

Skimmer Box on top of OWS

OWS unit

-------
GAC Units and discharge storage tank

-------
Looking South from treatment building area

Well field for treatment system

-------
Example of a monitoring well in the well field.

-------