Fourth Five-Year Review Report for the
Teledyne Wah Chang Superfund Site
Contract No. 68-57-03-04
Task Order No. (011)
U.S. Environmental Protection Agency
Region 10
December 28, 2012
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Fourth Five-Year Review Report for the
Teledyne Wah Chang Superfund Site
OSS' S
Prepared by
United States Environmental Protection Agency
Region 10
Approved In
Cami Grandinetti. Program Manager Date
Environmental Cleanup Division
US EPA Region 10
December 2S. 2012 | 415-2WIHP
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CITATION
U.S. Environmental Protection Agency. 2012. Fourth Five-Year Review
Report for Teledyne Wah Chang Superfund Site
City of Millersburg
Linn County, Oregon, December 28, 2012.
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Fourth Five-Year Review Report for Wah Chang Superfund Site
City ofMillersburg
Linn County, Oregon
U.S. Environmental Protection Agency
TABLE OF CONTENTS
EXECUTIVE SUMMARY ES-1
1 INTRODUCTION 1-1
2 SITE CHRONOLOGY 2-1
3 BACKGROUND 3-1
3.1 SITE LOCATION AND DESCRIPTION 3-1
3.1.1 Main Plant Area 3-1
3.1.2 Solids Area 3-2
3.1.3 Farm Ponds Area 3-2
3.1.4 Soil Amendment Area 3-2
3.2 PHYSICAL CHARACTERISTICS 3-2
3.2.1 Physical Setting and Topography 3-2
3.2.2 Site Geology and Hydrogeology 3-2
3.2.3 Groundwater Flow 3-4
3.2.4 Surface Water 3-4
3 .3 LAND AND RESOURCE USE 3-5
3.4 HISTORY 01 CONTAMINATION 3-6
3.4.1 Main Plant 3-6
3.4.2 Solids Area 3-7
3.4.3 Farm Ponds 3-8
3.5 INITIAL RESPONSE 3-8
3 .6 BASIS FOR TAKING ACTION 3-8
3.7 CONTAMINANTS OF CONCERN 3-9
3.7.2 0U1-Sludges 3-10
3.7.3 OU2 - Groundwater and Sediment 3-10
3.7.4 OU3 - Surface and Subsurface Soils 3-11
4 REMEDIAL ACTIONS 4-1
4.1 OU1 - SLUDGE PONDS 4-1
4.1.1 Remedy Selection 4-1
4.1.2 Remedy Implementation 4-1
4.2 OU2 - GROUNDWATER AND SEDIMENTS 4-1
4.2.1 Remedy Selection 4-1
4.2.2 Remedy Implementation 4-4
4.3 OU3 - SURFACE AND SUBSURFACE SOILS 4-7
4.3.1 Remedy Selection 4-7
4.3.2 Remedy Implementation 4-9
4.4 SITEWIDE ACTIONS 4-10
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Fourth Five-Year Review Report for Wah Chang Superfund Site
City ofMillersburg
Linn County, Oregon
U.S. Environmental Protection Agency
4.4.1 Institutional Controls 4-10
5 PROGRESS SINCE THE LAST FIVE-YEAR REVIEW 5-1
5.1 OU1 - SLUDGE PONDS 5-1
5 .2 OU2 - GROUNDWATER AND SEDIMENTS 5-1
5.3 OU3 - SURFACE AND SUB SURFACE SOIL 5-6
5.4 SITEWIDE 5-7
6 FIVE-YEAR REVIEW PROCESS 6-1
6.1 ADMINISTRATIVE COMPONENTS 6-1
6.2 COMMUNITY INVOLVEMENT 6-1
6.3 APPROPRIATE, RELEVANT, AND APPLICABLE REQUIREMENTS
REVIEW 6-1
6.3.1 OU1 6-1
6.3.2 OU2 6-1
6.3.3 OU3 6-3
6.4 INTERVIEWS 6-3
6.5 INSTITUTIONAL CONTROLS 6-4
6.5.1 Proprietary Controls 6-4
6.5.2 Government Controls 6-5
6.5.3 Informational Devices 6-5
6.6 SITE INSPECTION/TECHNOLOGY REVIEW 6-5
6.6.1 Management System Review 6-6
6.6.2 Technical Compliance Evaluation 6-6
6.6.3 Source Control 6-6
6.6.4 Groundwater Remediation 6-7
6.7 DATA REVIEW FOR OU1 6-7
6.8 DATA REVIEW FOR OU2 6-7
6.8.1 Main Plant: Groundwater Extraction and Treatment System (GETS) 6-7
6.8.2 Monitored Natural Attenuation 6-15
6.9 DATA REVIEW FOR OU3 6-17
6.10 RCRA INVESTIGATIONS 6-18
6.10.1 Drain SWMUs 6-18
6.10.2 Non-Drain SWMUs 6-19
7 TECHNICAL ASSESSMENT 7-1
7.1 TECHNICAL ASSESSMENT OF OU1 7-1
7.1.1 Question A: Is the remedy functioning as intended by the decision
documents? 7-1
7.1.2 Question B: Are the exposure assumptions, toxicity data, cleanup levels,
and RAOs used at the time of the remedy selection still valid? 7-1
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Fourth Five-Year Review Report for Wah Chang Superfund Site
City ofMillersburg
Linn County, Oregon
U.S. Environmental Protection Agency
7.1.3 Question C: Has any other information come to light that could call into
question the protectiveness of the remedy? 7-1
7.1.4 Technical Assessment Summary 7-1
7.2 TECHNICAL ASSESSMENT OF OU2 7-1
7.2.1 Question A: Is the remedy functioning as intended by the decision
documents? 7-1
7.2.2 Question B: Are the exposure assumptions, toxicity data, cleanup levels,
and RAOs used at the time of the remedy selection still valid? 7-5
7.2.3 Question C: Has any other information come to light that could call into
question the protectiveness of the remedy? 7-6
7.2.4 Technical Assessment Summary 7-6
7.3 TECHNICAL ASSESSMENT OF OU3 7-6
7.3.1 Question A: Is the remedy functioning as intended by the decision
documents? 7-7
7.3.2 Question B: Are the exposure assumptions, toxicity data, cleanup levels,
and RAOs used at the time of the remedy selection still valid? 7-7
7.3.3 Question C: Has any other information come to light that could call into
question the protectiveness of the remedy? 7-8
7.3.4 Technical Assessment Summary 7-8
8 ISSUES 8-1
8.1 OU1 - SLUDGE PONDS 8-1
8.2 OU2 - GROUNDWATER AND SEDIMENT 8-1
8.2.1 Additional Issues 8-2
8.3 OU3 - SURFACE AND SUBSURFACE SOIL 8-2
9 RECOMMENDATIONS AND FOLLOW-UP ACTIONS 9-1
9.1 OU1 - SLUDGE PONDS 9-1
9.2 OU2 - GROUNDWATER AND SEDIMENT 9-1
9.2.1 Additional Recommendations and Follow-Up Actions 9-3
9.3 OU3 - SURFACE AND SUBSURFACE SOIL 9-4
10 PROTECTIVENESS STATEMENTS 10-1
10.1 OU1-SLUDGE PONDS 10-1
10.2 OU2 - GROUNDWATER AND SEDIMENT 10-1
10.3 OU3 - SURFACE AND SUBSURFACE SOIL 10-2
10.4 SITEWIDE PROTECTIVENESS 10-3
11 NEXT REVIEW 11-1
12 REFERENCES 12-1
December 28, 2012 | 415-2328-007 iii
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Fourth Five-Year Review Report for Wah Chang Superfund Site
City ofMillersburg
Linn County, Oregon
U.S. Environmental Protection Agency
APPENDICES
A Public Notice
B Interviews
C Five-Year Review Site Inspection Report
LIST OF FIGURES
3-1 Site Location
3-2 Main Plant Site Areas
3-3 Spring 2010 Groundwater Elevation, Main Plant
3-4 Fall 2010 Groundwater Elevation, Main Plant
3-5 Fall 2010 Groundwater Elevation, Farm Ponds
6-1 Extraction Area
6-2 FMA pH Level in Groundwater
6-3 Concentration of Fluoride (F) in Groundwater in the FMA
6-4 Concentration of Fluoride (F) in Groundwater in the FMA
6-5 Concentration of Total Radium226 and Radium 228 in Groundwater in the FMA
6-6 Concentration of DCE in Non-Hot spot wells in SEA
6-7 Concentration of TCE in Non-Hot spot wells in SEA
6-8 Fabrication Area
6-9 VOC Concentrations for Former Crucible Cleaning Area Hot Spot Wells in the
Fabrication Area
6-10 VOC Concentrations for Acid Sump Area Hot Spot Wells in the Fabrication Area
6-11 VOC Concentrations for Ammonium Sulfate Area Hot Spot Wells in the Fabrication
Area
6-12 VOC Concentrations for Dump Master Area Hot Spot Wells in the Fabrication Area
6-13 VOC Concentrations for Material Recycle Area Hot Spot Wells in the Fabrication
Area
6-14 VOC Concentrations for Former Crucible Cleaning Area Non-Hot Spot Wells in the
Fabrication Area
6-15 VOC Concentrations for Acid Sump Area Non-Hot Spot Wells in the Fabrication
Area
6-16 6-17 VOC Concentrations for Dump Master Area Non-Hot Spot Wells in the
Fabrication Area
6-17 VOC Concentrations for Material Recycle Area Non-Hot Spot Wells in the
Fabrication Area
6-18 Concentration of DCE in Groundwater Perimeter Wells in the Fabrication Area
6-19 DCE Concentrations, Fall 2009, Fabrication Area
IV
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Fourth Five-Year Review Report for Wah Chang Superfund Site
City ofMillersburg
Linn County, Oregon
U.S. Environmental Protection Agency
6-20 TCE Concentrations, Fall 2009, Fabrication Area
6-21 VC Concentrations, Fall 2009, Fabrication Area
6-22 TCA Concentrations, Fall 2009, Fabrication Area
6-23 DCE Concentrations, Fall 2011, Fabrication Area
6-24 TCE Concentrations, Fall 2011, Fabrication Area
6-25 VC Concentrations, Fall 2011, Fabrication Area
6-26 TCA Concentrations, Fall 2011, Fabrication Area
6-27 DCE Concentrations Above ROD, Fall 2009 and 2011, Fabrication Area
6-28 TCE Concentrations Above ROD, Fall 2009 and 2011, Fabrication Area
6-29 VC Concentrations Above ROD, Fall 2009 and 2011, Fabrication Area
6-30 1,1,1-TCA Concentrations Above ROD, Fall 2009 and 2011, Fabrication Area
6-3 la Time-Series Charts Showing Chlorinated Ethene Reductive Dechlorination from the
ASA Source Area to Downgradient Wells
6-3 lb Time-Series Charts Showing Chlorinated Ethane Reductive Dechlorination from the
ASA Source Area to Downgradient Wells
6-32 Concentration of PCE, TCE, and VC (ug/L) in Well PW-40S
6-33 Concentration of PCE, TCE, and VC (ug/L) in Well SS
LIST OF TABLES
2-1 Chronology of Site Events
4-1 COCs in Groundwater Cleanup Levels from Table 10-1 of the ROD
5-1 Third Five-Year Review Issues, Recommendations and Follow-Up Actions for OU2
5-2 Third Five-Year Review Issues, Recommendations and Follow-Up Actions for OU3
5-3 Third Five-Year Review Sitewide Issues, Recommendations and Follow-Up Actions
6-1 FMA Summary of arsenic, radium 228, radium 226, fluoride, ammonia, ammonium,
cadmium, and nickel in groundwater
6-2 pH in Groundwater for Monitoring Wells in the FMA Extraction Area
6-3 FMA Extraction Well Summary of arsenic, radium 228, radium 226, fluoride,
ammonia, ammonium, cadmium, and nickel in groundwater
6-4 SEA Summary of VOCs in groundwater
6-5 Fabrication Area Summary of groundwater analytical results for TCA
6-6 Fabrication Area Summary of groundwater analytical results for DCA
6-7 Fabrication Area Summary of groundwater analytical results for DCE
6-8 Fabrication Area Summary of groundwater analytical results for cis-DCE
6-9 Fabrication Area Summary of groundwater analytical results for PCE
6-10 Fabrication Area Summary of groundwater analytical results for TCE
December 28, 2012 | 415-2328-007 v
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Fourth Five-Year Review Report for Wah Chang Superfund Site
City ofMillersburg
Linn County, Oregon
U.S. Environmental Protection Agency
6-11 Fabrication Area Summary of groundwater analytical results for VC
6-12 Fabrication Area Summary of groundwater analytical results for Fluoride
6-13 Fabrication Area Summary of groundwater analytical results for Nitrate
6-14 Summary of VOCs detected in Surface Water (Murder and Truax Creeks) from
November 2007 to September 2010
6-15 Summary of EISB Performance Monitoring in the ASA Source area
6-16 Summary of COCs detected in Solids area wells from November 2003 to
September 2011
6-17 Summary of VOCs detected in Farm Pond wells from June 2000 to September 2011
8-1 Issues for OU2
8-2 Issues for OU3
9-1 Issues, Follow-Up Actions, and Recommendations for OU2
9-2 Issues, Follow-Up Actions, and Recommendations for OU3
December 28, 2012 | 415-2328-007
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Fourth Five-Year Review Report for Wah Chang Superfund Site
City ofMillersburg
Linn County, Oregon
U.S. Environmental Protection Agency
ACRONYMS
Mg
microgram
(irem/hour
micro-roentgen equivalent man per hour
ARARs
Applicable or Relevant and Appropriate Requirements
ARS
Ammonium Recovery System
ATI
Allegheny Technologies, Inc.
AWQC
Ambient Water Quality Criteria
bgs
below ground surface
BNSF
Burlington Northern Santa Fe Railroad
CB
catch basin
CCA
Crucible Cleaning Area
CERCLA
Comprehensive Environmental Response, Compensation, and Liability Act
CFR
Code of Federal Regulations
cfs
cubic feet per second
CIC
Community Involvement Coordinator
cisDCE
cis 1,2 Dichloroethene
cm/sec
centimeters per second
coc
contaminant of concern
CoGen
Co-Generation
CRP
Chlorinated Residue Pile
CSM
conceptual site model
CT
cooling tower
CVOC
chlorinated volatile organic compound
CWD
Central Wastewater Drain
CWTS
Central Wastewater Treatment System
cy
cubic yards
DCA
dichloroethane
DCE
dichloroethene
ODEQ
Oregon Department of Environmental Quality
DNAPL
dense non-aqueous phase liquid
EISB
Enhanced In-Situ Bioaugmentation
EER
Environmental Evaluations Report
EFSC
Energy Facility Siting Council
ELCR
excess lifetime cancer risk
December 28, 2012 415-2328-007
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Fourth Five-Year Review Report for Wah Chang Superfund Site
City ofMillersburg
Linn County, Oregon
U.S. Environmental Protection Agency
EPA U.S. Environmental Protection Agency
ESD Explanation of Significant Differences
EW extraction wells
fpd feet per day
GAC granular activated carbon
GEM gamma-emitting material
GETS Groundwater Extraction and Treatment System
gpm gallons per minute
HI Hazard Index
1-5 Interstate 5
IDW investigation derived waste
LRSP Lower River Solids Pond
MCL maximum contaminant levels
MCLG maximum contaminant level goals
mg/kg milligram per kilogram
mg/kg/day milligram per kilogram per day
mg/L milligram per liter
mgd million gallons per day
MIBK methyl isobutyl ketone
Msl mean sea level
MNA monitored natural attenuation
MRRP Magnesium Resource Recovery Pile
NCP National Oil and Hazardous Substances Contingency Plan
NGVD National Geodetic Datum
NON Notice of Noncompliance
NORM naturally occurring radioactive materials
NPDES National Pollutant Discharge Elimination System
NPL National Priorities List
O&M operation and maintenance
OAR Oregon Administrative Rule
OPRD Oregon Parks and Recreation Department
OU operable unit
PAH polycyclic aromatic hydrocarbon
PCA tetrachloroethane
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Fourth Five-Year Review Report for Wah Chang Superfund Site
City ofMillersburg
Linn County, Oregon
U.S. Environmental Protection Agency
PCB polychlorinated biphenyl
PCE tetrachloroethene
pCi picoCuries
ppb parts per billion
PRG Preliminary Remediation Goal
PVC polyvinyl chloride
RA Remedial Action
RAO Remedial Action Objective
RCRA Resource Conservation and Recovery Act
RD/RA Remedial Design/Remedial Action
RFA RCRA Facility Assessment
RI Remedial Investigation
RI/FS Remedial Investigation/Feasibility Study
ROD Record of Decision
SAP Sampling and Analysis Plan
SDWA Safe Drinking Water Act
SEA South Extraction Area
SF slope factors
SOW Scope of Work
SVOC semi-volatile organic compound
SWMU Solid Waste Management Unit
TCA trichloroethane
TCE trichloroethene
TCLP toxicity characteristic leaching procedure
TDS total dissolved solids
TOPO Task Order Project Officer
TSCA Toxic Substance Control Act
TWC Teledyne Wah Chang
VC vinyl chloride
VOC volatile organic compound
WMP Willamette Memorial Park
December 28, 2012 | 415-2328-007
IX
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Fourth Five-Year Review Report for Wah Chang Superfund Site
City ofMillersburg
Linn County, Oregon
U.S. Environmental Protection Agency
Five-Year Review Summary Form
SITE IDENTIFICATION
Site Name: Teledyne Wah Chang
EPA ID: ORD050955848
Region: 10 State: OR City/County: Millersburg/Linn
1
SITE STATUS |
NPL Status: Final
Multiple OUs?
Has the site achieved construction completion?
YES
Yes
REVIEW STATUS
Lead agency: EPA
If "Other Federal Agency" was selected above, enter Agency name:
Author name (Federal or State Project Manager): Ravi Sanga
Author affiliation: US EPA Region 10
Review period: 1/28/2012 - 1/08/2013
Date of site inspection: 6/6/2012 - 6/8/2012
Type of review: Statutory
Review number: 4
Triggering action date: January 08, 2008
Due date (fiveyears after triggering action date): 1/08/2013
December 28, 2012 I 415-2328-007
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Fourth Five-Year Review Report for Wah Chang Superfund Site
City ofMillersburg
Linn County, Oregon
U.S. Environmental Protection Agency
1
Issues/Recommendations 1
()l (s) without IsMics/Kccommcndalions Idcnlil'ied in I lie l-"i\e-Year Re\ie\\:
()l 1
Issues iiiul Kccommendalions Identified in llie l-"i\e-Year Re\ie\\:
OU(s):2
Issue Category: Remedy Performance
Issue: Extraction Area -From Wah Chang's annual progress summaries and an
independent review of Wah Chang's data, EPA determined that although GETS has
reduced the concentrations of radium and other COCs in groundwater, low pH conditions
persist that are contributing to COCs above ROD cleanup levels. Therefore it is unlikely
that ROD cleanup levels will be achieved in the 15-year time frame without using a
different treatment technology.
Recommendation: Evaluate the use of basic solution (lime) groundwater flushing as a
new RA to raise groundwater pH and decrease the mobility of inorganic constituents. Wah
Chang has submitted a treatability study for the lime groundwater flushing and if EPA
determines that this technology is feasible, EPA expects to issue an ESD before the end of
2013 to implement the remedy.
Affect Current
Protectiveness
Affect Future Implementing Oversight Milestone Date
Protectiveness Party Party
No
Yes PRP EPA 12/31/2015
OU(s):2
Issue Category: Remedy Performance
Issue: Extraction Area - Although a source was never determined, Wah Chang
implemented EISB as a pilot project under EPA oversight and VOCs were not detected in
the SEA in 2011. Following EPA approval, Wah Chang shut down extraction wells in
April 2011. The groundwater data needs to be assessed for potential reestablishment of a
dissolved plume.
Recommendation: Wah Chang must continue to monitor groundwater biannually under
EPA oversight for 5 years following shutdown of extraction wells in the SEA in 2011 to
assess whether the dissolved plume is reestablishing itself.
Affect Current
Protectiveness
Affect Future Implementing Oversight Milestone Date
Protectiveness Party Party
No
Yes PRP EPA 12/31/2016
OU(s):2
Issue Category: Remedy Performance
Issue: Fabrication Area - Wah Chang implemented EISB in the CCA and EPA is
currently evaluating its effectiveness.
Recommendation: Wah Chang must continue additional performance monitoring to
determine if cleanup levels will be achieved by 2017, which is the time frame specified in
the ROD.
Affect Current
Protectiveness
Affect Future Implementing Oversight Milestone Date
Protectiveness Party Party
No
Yes PRP EPA 12/31/2017
December 28, 2012 415-2328-007
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Fourth Five-Year Review Report for Wah Chang Superfund Site
City ofMillersburg
Linn County, Oregon
U.S. Environmental Protection Agency
1
Issues/Recommendations (continued) |
OU(s):2
Issue Category: Remedy Performance
Issue: Fabrication Area - Wah Chang implemented EISB in the ASA in 2009 and EPA is
currently evaluating its effectiveness. However, Wah Chang's release of DNAPL and/or
high chemical concentrations in the ASA is an additional source area not encountered
during the RI/FS, and it is unlikely that ROD cleanup levels will be achieved in the 15-
year time frame without additional remedial actions.
Recommendation: Wah Chang must continue additional performance monitoring to
determine if ROD cleanup levels will be achieved. Treatment of the plume is successfully
reducing dissolved phase chlorinated solvents. However geochemical evidence in the form
of high dissolved concentrations in the source area indicate a DNAPL source remains that
will require removal or more aggressive treatment.
Affect Current
Protectiveness
Affect Future Implementing Oversight Milestone Date
Protectiveness Party Party
No
Yes PRP EPA 12/31/2015
OU(s):2
Issue Category: Remedy Performance
Issue: Farm Ponds Area - Based on Wah Chang's annual groundwater progress
summaries and an independent review of Wah Chang's data, EPA noted that VOCs
significantly and unexpectedly decreased to below ROD cleanup levels and was concerned
about possible plume migration. In 2012, Wah Chang removed potential source material
with EPA oversight since the drop in concentrations was unexplained.
Recommendation: Wah Chang excavated and removed the potentially contaminated
berms and collected groundwater samples to confirm groundwater conditions. EPA
expects to review these data in 2013 to determine whether the extent of the dissolved
plume requires additional assessment.
Affect Current
Protectiveness
Affect Future Implementing Oversight Milestone Date
Protectiveness Party Party
No
Yes PRP EPA 12/31/2014
OU(s):2
Issue Category: Monitoring
Issue: Wah Chang's method reporting limits for some VOCs (PCE and
VC) in surface water samples exceed the AWQC.
Recommendation: Wah Chang must reduce the method reporting limits for PCE and VC
in surface water samples to enable identification of COCs in surface water.
Affect Current
Protectiveness
Affect Future Implementing Oversight Milestone Date
Protectiveness Party Party
No
Yes PRP EPA 12/31/2014
December 28, 2012 I 415-2328-007
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Fourth Five-Year Review Report for Wah Chang Superfund Site
City ofMillersburg
Linn County, Oregon
U.S. Environmental Protection Agency
1
Issues/Recommendations (continued) |
OU(s):2
Issue Category: Monitoring
Issue: Ground-water monitoring constituents have been reduced over time since the
RI/FS. Contaminants may have migrated over this time period and monitoring points
should be reassessed.
Recommendation: Wah Chang must submit a work plan to EPA in 2013 and conduct a
round of Sitewide sampling for wells and parameters included in the original RI/FS using
current analytical technology.
Affect Current
Protectiveness
Affect Future Implementing Oversight Milestone Date
Protectiveness Party Party
No
Yes PRP EPA 12/31/2014
OU(s):2
Issue Category: Monitoring
Issue: During decommissioning of well SS in the Farm Ponds Area, Wah Chang
discovered the well was not properly constructed. The contractor that installed well SS,
Schoen Electric and Pump, also installed other Site wells.
Recommendation: Wah Chang must submit a report to EPA documenting whether any of
the wells being used for CERCLA Site investigations were installed by Schoen Electric
and Pump. If improperly constructed wells are being used, Wah Chang must prepare a
work plan for EPA approval and replace these wells with wells are compliant with well
construction regulations.
Affect Current
Protectiveness
Affect Future Implementing Oversight Milestone Date
Protectiveness Party Party
No
Yes PRP EPA 12/31/2013
OU(s):2
Issue Category: Institutional Controls
Issue: EPA has determined that Wah Chang needs to provide additional information on
the status of the Institutional Control instruments to verify that all institutional controls
required by EPA's decision documents are in place.
Recommendation: Wah Chang must verify the status of deed restrictions requiring that
land use at the Site remain industrial, and whether deed restrictions for groundwater use
and land use are in place for the properties Wah Chang recently purchased east of Old
Salem Road. Wah Chang must also provide EPA with their site maintenance plan
documenting areas of subsurface PCB and radionuclide contamination.
Affect Current
Protectiveness
Affect Future Implementing Oversight Milestone Date
Protectiveness Party Party
No
Yes PRP EPA 12/31/2013
OU(s):2
Issue Category: Monitoring
Issue: Surface Water - EPA noted from Wah Chang's annual progress summaries and an
independent review of Wah Chang's data that VOCs have been detected in surface water
at the site sporadically in past years. However, EPA believes that since the 2008 FYR,
elevated concentration of VOCs observed in PW-78A may indicate migration of
contaminated groundwater to Murder Creek.
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Fourth Five-Year Review Report for Wah Chang Superfund Site
City ofMillersburg
Linn County, Oregon
U.S. Environmental Protection Agency
1
Issues/Recommendations (continued) 1
Recommendation: Wah Chang must add surface water sample locations in the vicinity of
PW-78A in Murder Creek to evaluate the potential for contaminated groundwater to be
released to surface water.
Affect Current
Protectiveness
Affect Future Implementing Oversight Milestone Date
Protectiveness Party Party
No
Yes PRP EPA 12/31/2014
OU(s):2
Issue Category: Remedy Performance
Issue: Sediment - Additional information on PCB concentrations in sediment is needed to
determine if the RA for sediment is functioning as intended.
Recommendation: Wah Chang must resubmit an appropriate Work Plan to EPA for
approval and conduct sediment sampling and analysis in a manner consistent with the
approved Work Plan.
Affect Current
Protectiveness
Affect Future Implementing Oversight Milestone Date
Protectiveness Party Party
No
Yes PRP EPA 12/31/2014
OU(s):3
Issue Category: Operations and Maintenance
Issue: The SOW and Consent Decree do not incorporate requirements of the 2001 Soil ESD
regarding overall cleanup during decommissioning and other factors.
Recommendation: Prior to plant decommissioning, EPA and ODEQ will amend the SOW of the
1997 Consent Decree to incorporate applicable requirements of the 2001 Soil ESD for plant
decommissioning.
Affect Current
Protectiveness
Affect Future Implementing Oversight Milestone Date
Protectiveness Party Party
No
Yes PRP EPA 01/07/2018
OU(s):3
Issue Category: Operations and Maintenance
Issue: The Mayor of Millersburg indicated that tilling for agricultural purposes was being conducted
on the SAA. Although the RI/FS determined that agricultural practices did not pose a risk to human
health or the environment, EPA is revisiting the issue since it has been 17 years since the soil
radionuclide data were collected and the original evaluation did not address risks to agricultural
workers from soil resuspension due to tilling.
Recommendation: Wah Chang must collect and analyze soil samples for radium by the end of
calendar year 2013 so EPA can reevaluate, in 2014, the risk to human health and the environment
from the disturbance/resuspension of soil and remaining levels of radionuclides in soils. Given that
the earlier testing did not demonstrate human health risk, the City may continue to use the property
for agricultural activities although it is suggested by EPA that ground disturbing activities that may
resuspend soil should be limited. Following EPA's reassessment of the contaminated soils, should
there be an indication of human health risk to those exposed to these soils under current agricultural
practices, EPA will share those results with the City of Millersburg and discuss appropriate actions
for future use of the property.
Affect Current
Protectiveness
Affect Future Implementing Oversight Milestone Date
Protectiveness Party Party
Yes
Yes PRP EPA 12/31/2014
December 28, 2012 415-2328-007
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Fourth Five-Year Review Report for Wah Chang Superfund Site
City ofMillersburg
Linn County, Oregon
U.S. Environmental Protection Agency
1
Issues/Recommendations (continued) |
OU(s):3
Issue Category: Monitoring
Issue: There is uncertainty in the location of the CoGen Building with respect to the overall soil
radiation footprint left behind after Wah Chang's remedial actions in the Sand Unloading Area. EPA
Institutional Controls require that anyone constructing future buildings use radon-resistant
construction methods if those buildings are located on top of radioactive contamination.
Recommendation: Wah Chang, under EPA oversight, must retest indoor air for radon in the CoGen
Building by the end of calendar year 2013, and based on the results of radon concentrations, EPA
may require further testing or actions.
Affect Current
Protectiveness
Affect Future Implementing Oversight Milestone Date
Protectiveness Party Party
No
Yes PRP EPA 12/31/2014
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Fourth Five-Year Review Report for Wah Chang Superfund Site
City ofMillersburg
Linn County, Oregon
U.S. Environmental Protection Agency
Operable Unit:
Protectiveness Determination:
Protective
Addendum Due Date
(if applicable):
0U1
Protectiveness Statement:
The remedy for OU1 is protective of human health and the environment, and exposure pathways that could result
in unacceptable risks are being controlled.
Protectiveness Statement:
The remedy at OU2 is currently protective of human health and the environment in the short term.
Progress to meet the groundwater RAOs is being made through an operating GETS enhanced
with EISB. ICs are in place preventing exposure to contaminants of concern above cleanup
goals through on-site and off-site deed restrictions on groundwater use, zoning, and access
controls. In order for the remedy to be considered protective in the long term, Wah Chang must
obtain and provide to EPA further information on groundwater pH conditions and COC
concentrations, and verify that all ICs instruments required by EPA's decision documents are in
place. Long term protectiveness will be obtained when Wah Chang and EPA take the actions
described below:
Wah Chang must implement buffer solution treatment under EPA oversight to the
groundwater source area contamination in the FMA stemming from acidic pH conditions and
resulting in concentrations of COCs that remain above ROD cleanup levels. Groundwater
quality conditions in the FMA are unlikely to achieve RAOs within the estimated 15-year
time frame. EPA will evaluate the effectiveness of additional remedial actions in the FMA as
data become available. EPA expects this action to be completed and data available to assess
effectiveness in 2016.
Since Wah Chang's annual progress summaries and EPA's independent review of Wah
Chang's data indicate that no VOCs have been detected in groundwater in the SEA and that
ROD cleanup levels have been met, EPA considers the SEA protective in the short term.
EPA-required ICs are in place at the Site for use of groundwater, and the Site is still zoned for
General Industrial use by the City of Millersburg. Long term protectiveness will require Wah
Chang under EPA oversight to assess the mobilization of solvents from the source area after
oxygen has stopped the reductive dechlorination of dissolved chlorinated solvents. This
assessment will consist of long-term ground-water monitoring. EPA will reassess the
effectiveness of EISB in the SEA based on Wah Chang's groundwater monitoring data that
will be submitted annually through 2016.
EPA has determined that due to elevated concentrations of VOCs in the ASA and CCA, Wah
Chang must continue to monitor geochemical conditions to evaluate the effectiveness of EISB
and reductive dechlorination. In 2014, EPA will reassess the effectiveness of the EISB based
on the groundwater data collected by Wah Chang and will make a decision whether the
remedy will meet ROD cleanup levels in the 15-year time frame specified in the ROD or
whether additional treatment will be required. However, Wah Chang's release of DNAPL
and/or high concentrations of VOCs in the ASA is an additional source area not encountered
during the RI/FS that will likely require more aggressive remediation. Wah Chang must
assess the source of DNAPL in the ASA and provide data to EPA by 2014.
EPA has observed increased concentrations of VOCs in well PW-78A (close to Murder
Creek). The current downstream surface water sampling is located 200 feet from the
anticipated discharge point of groundwater in the vicinity of this well. Under EPA oversight,
Wah Chang must collect additional seepage and surface water samples in the vicinity of well
PW-78A so EPA can evaluate the potential for release of contaminated groundwater to the
creek. EPA expects to evaluate additional data by 2013.
December 28, 2012 I 415-2328-007 xvii
Operable Unit:
Protectiveness Determination:
Short-term Protective
Addendum Due Date
(if applicable):
OU2
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Fourth Five-Year Review Report for Wah Chang Superfund Site
City ofMillersburg
Linn County, Oregon
U.S. Environmental Protection Agency
Protectiveness Statement(s) (continued)
Since the 2008 FYR, Wah Chang's annual progress summaries and EPA's independent
review of Wah Chang's data showed increasing CVOC concentrations in groundwater in the
Farm Ponds Area indicating that ROD performance standards may not be met. However, EPA
noted recent unexplained declines in concentrations. In 2012 Wah Chang completed
excavation of the berm material that may have acted as a source of groundwater
contamination, and collected confirmation samples of groundwater. EPA will evaluate the
results of the completion report in 2013 to assess whether additional actions are required.
Wah Chang must conduct additional sampling and analysis of PCBs in sediments to ensure
that the remedy for sediments is protective. EPA will evaluate additional data in 2013.
Wah Chang must submit a report to EPA documenting whether any of the wells being used
for CERCLA Site investigations were installed by Schoen Electric and Pump. If improperly
constructed wells are being used, Wah Chang must prepare a work plan for EPA approval and
replace these wells with wells that are compliant with well construction regulations.
Wah Chang must verify the status of deed restrictions requiring that land use at the Site
remain industrial, and whether deed restrictions for groundwater use and land use are in place
for the properties Wah Chang recently purchased east of Old Salem Road. Wah Chang must
also provide EPA with their site maintenance plan documenting areas of subsurface PCB and
radionuclide contamination.
Operable Unit: Protectiveness Addendum Due Date
OU3 Determination: (if applicable):
Protectiveness Deferred 01/07/2018
Protectiveness Statement:
A protectiveness determination of the remedy at OU3 cannot be made at this time until further information is
obtained associated with exposure to radionuclides from resuspension due to tilling in the Soil Amendment Area.
Further information will be obtained by taking the following actions:
Under EPA oversight, Wah Chang must collect samples of SAA soil and test for radiological
contamination by the end of calendar year 2013 so EPA can reevaluate in 2014 the risk to
human health and the environment from the disturbance/resuspension of soil to evaluate
whether human health and the environment are protected under the existing remedy.
Excavation of contaminated soil was completed and ICs are in place in the form of deed restrictions that prevent
human exposure to remaining soils in the main plant of the site. Additionally, for the remedy to be protective in
the long term, EPA and Wah Chang need to take the following actions to ensure protectiveness:
Prior to plant decommissioning, EPA and ODEQ will amend the SOW of the 1996 Consent
Decree to incorporate applicable requirements of the 2001 Soil ESD for plant
decommissioning.
Under EPA oversight, Wah Chang must retest for radon in the CoGen Building by the end of
calendar year 2013 due to uncertainty in the location of the CoGen Building with respect to
the overall soil radiation footprint remaining after Wah Chang's remediation of the Sand
Unloading Area. Based on the results, EPA may require additional testing of radon in indoor
air or radon mitigation.
xviii
December 28, 2012 I 415-2328-007
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Fourth Five-Year Review Report for Wah Chang Superfund Site
City ofMillersburg
Linn County, Oregon
U.S. Environmental Protection Agency
For sites that have achieved construction completion, enter a sitewide protectiveness determination and
statement.
Protectiveness Statement:
EPA has determined that there is not enough information to evaluate protectiveness, primarily in the area of
the Site that has agricultural activities (SAA). Therefore, the Sitewide protectiveness determination is
deferred until the following additional information is evaluated. Wah Chang must collect and analyze soil
samples for radium so EPA can reevaluate the risk to human health from the disturbance/resuspension of
soil. Given that the earlier testing did not demonstrate human health risk, the City may continue to use the
property for agricultural activities including tilling the soil although it is suggested by EPA that ground
disturbing activities that may resuspend soil should be limited. Following EPA's reassessment of the
contaminated soils, should there be an indication of human health risk to those exposed to these soils under
current agricultural practices, EPA will share those results with the City of Millersburg and discuss
appropriate actions for future use of the property.
Progress to meet the groundwater RAOs is being made through an operating GETS enhanced with EISB. ICs
are in place preventing exposure to contaminants of concern above cleanup goals through zoning ordinances
and access controls and on-site and off-site deed restrictions on groundwater use. In order to ensure long
term protectiveness, Wah Chang must provide further information on pH conditions and groundwater COC
concentrations following remedy enhancements so that EPA can evaluate the ability of the OU2 remedy to
meet RAOs within the 15-year time frame specified in the ROD (2017). In addition, Wah Chang must
confirm that all IC instruments required by EPA's decision documents are in place for all parcels of property
that could be affected by contaminated groundwater. Wah Chang must verify the status of deed restrictions
requiring that land use at the Site remain industrial, and whether deed restrictions for groundwater use and
land use are in place for the properties Wah Chang purchased east of Old Salem Road. Wah Chang must also
provide EPA with their site maintenance plan documenting areas of subsurface PCB and radionuclide
contamination.
EPA Required Institutional Controls are in place requiring that anyone constructing future buildings on the
Teledyne Wah Chang Main Plant must conduct an assessment to determine whether radon levels could pose
an unacceptable risk to building occupants and implement radon resistant construction and controls and
radon testing if required. Since the CoGen building was not constructed using radon resistant construction
methods and is located in an area where residual radioactive contamination may exist, Wah Chang must
resample indoor air radon in this building to ensure long term protectiveness of human health, and depending
on the results, EPA may require additional sampling and radon mitigation.
December 28, 2012 I 415-2328-007 xix
Protectiveness Determination:
Protectiveness Deferred
Addendum Due Date (if applicable):
01/07/2018
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Fourth Five-Year Review Report for Wah Chang Superfund Site
City ofMillersburg
Linn County, Oregon
U.S. Environmental Protection Agency
EXECUTIVE SUMMARY
This report presents the findings of the Fourth Five-Year Review for the Teledyne Wah
Chang (Wah Chang) Superfund Site (Site) located in Millersburg, Oregon. The purpose of
this review is so EPA can confirm that the remedy continues to be protective of human health
and the environment. This Five-Year Review was conducted in accordance with the U.S.
Environmental Protection Agency's June 2001 Comprehensive Five-Year Review Guidance.
Wah Chang is an operating zirconium and other non-ferrous metals manufacturing plant; it
employs approximately 1,100 people. The Site is located in the industrial-based community
of Millersburg, Oregon, approximately 2 miles north of downtown Albany and approximately
20 miles due south of Salem, Oregon. The Site is adjacent to the Willamette River, with
portions of the property within the river's 100- and 500-year flood plains.
SITE FEATURES
Site features include:
The Main Plant, which is composed of:
> The Extraction Area: a 40-acre triangular-shaped parcel located south of
Truax Creek including the Feed Makeup Area (FMA) and South Extraction
Area (SEA).
> The Fabrication Area: a 50-acre parcel located north of Truax Creek and
south of Murder Creek including the Acid Sump Area (ASA) and Crucible
Cleaning Area (CCA).
The Farm Ponds Area: a 75- acre parcel north of the Main Plant. Four 2.5-acre
storage ponds at one time held the plant's wastewater treatment lime solids. The
farm ponds, historically used to hold wastewater treatment lime solids, are
located approximately 0.75-mile north of the main plant.
The Solids Area: a 20-acre parcel west of the Fabrication Area. It contains the
Lower River Solids Pond (LRSP), Schmidt Lake, Chlorinated Residue Pile
(CRP), and the Magnesium Resource Recovery Pile (MRRP). This area received
solids from Wah Chang's wastewater treatment system.
The Soil Amendment Area: an approximately 40-acre parcel of property
currently owned by the City of Millersburg, but part of the Site. In 1975 and
1976, Wah Chang applied lime solids from the LRSP in an ODEQ-permitted
action as a soil enhancement to the Soil Amendment Area. In the early 1990s the
property was exchanged with the City of Millersburg for a piece of property
contiguous with Wah Chang's Farm Ponds Area.
Site features are linked to Wah Chang's manufacturing process and support or have supported
zirconium and/or non-ferrous metal production. Wah Chang's zirconium manufacturing
process involves a number of physical, chemical and electrochemical steps that concentrate
zircon, hafnium, vanadium, niobium, titanium, and radioactive byproduct such as uranium
and thorium. Current and historic waste management programs include process wastewater
treatment, lime solid storage, solid waste management, hazardous waste management, and
radioactive waste management.
December 28, 2012 | 415-2328-007
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Fourth Five-Year Review Report for Wah Chang Superfund Site
City ofMillersburg
Linn County, Oregon
U.S. Environmental Protection Agency
BASIS FOR TAKING ACTION - SLUDGE PONDS OPERABLE UNIT (OU1)
The basis for EPA taking action was prompted by EPA's concerns that the unlined sludge
ponds were located in the Willamette River floodplain and that hazardous materials from the
Sludge Pond Operable Unit (OU1) would migrate to soil, surface water, and groundwater.
This led to EPA formally placing Wah Chang on the National Priorities List (NPL) in
October 1983. The Record of Decision (ROD) for OU1 was signed by EPA on December 28,
1989 (EPA 1989). Remedial actions have consisted of removal, solidification, and off-site
disposal of sludge material with the intent to effectively reduce risk to human health and the
environment, and to ensure that contaminants are not transported to groundwater, surface
water and/or air. On June 30, 1993, EPA issued a Certification of Completion for the Sludge
Ponds Operable Unit remedial action to Wah Chang.
GROUNDWATER AND SEDIMENT OPERABLE UNIT (OU2)
Remedial actions for OU2 identified in the ROD (EPA 1994) and subsequent ESDs consist of
a groundwater extraction and treatment system (GETS) with enhanced in-site
bioaugmentation (EISB) in the SEA, ASA and CCA; monitored natural attenuation (MNA):
treatment or removal of subsurface source material near the Feed Makeup Building: slope
erosion protection along the banks of Truax Creek: sediment removal: and Sitewide actions
including institutional controls.
The findings of the Fourth Five-Year Review indicate that the groundwater remedy has been
implemented and is currently being evaluated for its effectiveness. Data indicate that
estimated excess lifetime carcinogenic and non-carcinogenic risk to human health in
groundwater has been reduced in the Main Plant Area since the initiation of the GETS
system. However, opportunities for optimizing GETS are being conducted and/or discussed
between EPA and Wah Chang. Institutional controls are required to prevent on-site and off-
site use of contaminated groundwater and to ensure that site use remains industrial.
Institutional controls, required by EPA, still need to be verified.
The Fourth Five Year Review identified the following issues:
Groundwater
Groundwater monitoring constituents have been reduced since the RI/FS.
Contamination may have migrated over this period and monitoring points must
be reassessed.
During decommissioning of well SS in the Farm Ponds Area, Wah Chang
discovered that Well SS was not properly constructed, and the contractor that
installed well SS, Schoen Electric and Pump, also installed other wells at the Site
(Section 6.8.2.2). Wah Chang must verify all wells installed by Schoen Electric
and Pump under EPA oversight and if replacement wells are needed, Wah Chang
must install replacement wells under EPA approval.
EPA has determined that Wah Chang needs to provide additional information on
the status of the Institutional Control instruments to verify that all institutional
controls required by EPA's decision documents are in place (Section 7.2.1.4).
Extraction Area (Sections 6.8.1.2 and 7.2.1.1)
From Wah Chang's annual progress summaries and an independent review of
Wah Chang's data, EPA determined that although GETS has reduced the
concentrations of radium and other COCs in groundwater, low pH conditions
persist that are contributing to COCs above ROD cleanup levels. Therefore it is
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December 28, 2012 | 415-2328-007
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Fourth Five-Year Review Report for Wah Chang Superfund Site
City ofMillersburg
Linn County, Oregon
U.S. Environmental Protection Agency
unlikely that ROD cleanup levels will be achieved in the 15-year time frame
without using a different treatment technology (Section 6.8.1).
Wah Chang implemented EISB as a pilot project under EPA oversight and VOCs
were not detected in the SEA in 2011. Following EPA approval, Wah Chang shut
down extraction wells in April 2011, although a source was never determined.
The groundwater data needs to be assessed for potential reestablishment of a
dissolved plume.
Fabrication Area (Sections 6.8.1.3 and 7.2.1.1)
EISB has been implemented in the CCA and EPA is currently evaluating its
effectiveness (Section 6.8.1).
Wah Chang completed EISB in the ASA in 2009 and EPA is currently evaluating
its effectiveness. However, Wah Chang's release of DNAPL and/or high
chemical concentrations in the ASA is an additional source area not encountered
during the RI/FS, and it is unlikely that ROD cleanup levels will be achieved in
the 15-year time frame without additional remedial actions.
Farm Ponds Area (Sections 6.8.2.2 and 7.2.1.1)
Based on Wah Chang's annual progress summaries and an independent review of
Wah Chang's data, EPA noted VOCs significantly and unexpectedly decreased
to below ROD cleanup levels and EPA was concerned about possible plume
migration. In 2012, Wah Chang removed potential source material since the drop
in concentrations was unexplained.
Surface Water (Sections 6.8.1.3 and 7.2.1.2)
Wah Chang's laboratory method reporting limits for some VOCs (PCE and VC)
in surface water samples exceed the AWQC.
EPA noted from Wah Chang's annual progress summaries and an independent
review of Wah Chang's data that VOCs have been detected in surface water at
the Site sporadically in past years. However, EPA believes that since the 2008
FYR, elevated concentration of VOCs observed in PW-78A may indicate
migration of contaminated groundwater to Murder Creek.
Sediment (Section 7.2.1.5)
Additional information on PCB concentrations in sediment is needed from Wah
Chang so EPA can determine if the RA for sediment is functioning as intended.
OU3 - SURFACE AND SUBSURFACE SOIL
Remedial actions for OU3 identified in the ROD (EPA 1995) combined source removal with
institutional controls to reduce risk to human health and the environment posed by
contamination in surface and subsurface soils at the Site.
The Fourth Five Year Review identified the following issues:
The SOW and Consent Decree do not incorporate requirements of the 2001 Soil ESD
regarding overall cleanup during decommissioning and other factors.
The Mayor of Millersburg indicated that tilling for agricultural purposes was being
conducted on the SAA. Although the RI/FS determined that agricultural practices did not
pose a risk to human health or the environment, EPA is revisiting the issue since it has been
December 28, 2012 | 415-2328-007
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Fourth Five-Year Review Report for Wah Chang Superfund Site
City ofMillersburg
Linn County, Oregon
U.S. Environmental Protection Agency
17 years since the soil radionuclide data were collected and the original evaluation did not
assess risks to agricultural workers from soil resuspension due to tilling.
There is uncertainty in the location of the CoGen Building with respect to the overall soil
radiation footprint left behind after Wah Chang's remedial actions in the Sand Unloading
Area. EPA Institutional Controls require that anyone constructing future buildings use radon-
resistant construction methods if those buildings are located on top of radioactive
contamination.
PROTECTIVENESS STATEMENTS
OU1 - SLUDGE PONDS
The remedy for OU1 is protective of human health and the environment, and exposure
pathways that could result in unacceptable risks are being controlled.
OU2 - GROUNDWATER AND SEDIMENT
The remedy at OU2 is currently protective of human health and the environment in the short
term. Progress to meet the groundwater RAOs is being made through an operating GETS
enhanced with EISB. ICs are in place preventing exposure to contaminants of concern above
cleanup goals through on-site and off-site deed restrictions on groundwater use, zoning, and
access controls. In order for the remedy to be considered protective in the long term, Wah
Chang must obtain and provide to EPA further information on pH conditions and COC
concentrations, and verify that all IC instruments required by EPA's decision documents are
in place. Long term protectiveness will be obtained when Wah Chang and EPA take the
actions described below:
Wah Chang must implement buffer solution treatment under EPA oversight to the
groundwater source area contamination in the FMA stemming from acidic pH conditions and
resulting in concentrations of COCs that remain above ROD cleanup levels. Groundwater
quality conditions in the FMA are unlikely to achieve RAOs within the estimated 15-year
time frame specified in the ROD. EPA will evaluate the effectiveness of additional remedial
actions in the FMA as data become available. EPA expects this action to be completed and
data available to assess effectiveness in 2016.
Since Wah Chang's annual progress summaries and EPA's independent review of Wah
Chang's data indicate that no VOCs have been detected in groundwater in the SEA, and that
ROD cleanup levels have been met, EPA considers the SEA protective in the short term.
EPA-required ICs are in place at the Site that prevents human use of groundwater, and the
Site is still zoned for General Industrial use by the City of Millersburg. Long term
protectiveness will require Wah Chang under EPA oversight to assess the mobilization of
solvents from the source area after oxygen has stopped the reductive dechlorination of
dissolved chlorinated solvents. This assessment will consist of long-term ground-water
monitoring. EPA will reassess the effectiveness of EISB in the SEA based on Wah Chang's
groundwater monitoring data that will be submitted annually through 2016.
EPA has determined that due to elevated concentrations of VOCs in the ASA and CCA, Wah
Chang must continue to monitor geochemical conditions to evaluate the effectiveness of
EISB and reductive dechlorination. In 2014, EPA will reassess the effectiveness of the EISB
based on the groundwater data collected by Wah Chang and will make a decision whether the
remedy will meet ROD cleanup levels in the 15-year time frame specified in the ROD or
whether additional treatment will be required. However, Wah Chang's release of DNAPL
and/or high concentrations of VOCs in the ASA is an additional source area not encountered
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December 28, 2012 | 415-2328-007
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Fourth Five-Year Review Report for Wah Chang Superfund Site
City ofMillersburg
Linn County, Oregon
U.S. Environmental Protection Agency
during the RI/FS that will likely require more aggressive remediation. Wah Chang must
assess the source of DNAPL in the ASA and provide data to EPA by 2014.
EPA has observed increased concentrations of VOCs in well PW-78A (close to Murder
Creek). The current downstream surface water sampling is located 200 feet from the
anticipated discharge point of groundwater in the vicinity of this well. Under EPA oversight,
Wah Chang must collect additional seepage and surface water samples in the vicinity of well
PW-78A so EPA can evaluate the potential for release of contaminated groundwater to the
creek. EPA expects to evaluate additional data by 2013.
Since the 2008 FYR, Wah Chang's annual progress summaries and EPA's independent
review of Wah Chang's data showed increasing CVOC concentrations in groundwater in the
Farm Ponds Area indicating that ROD performance standards may not be met. However,
EPA noted recent unexplained declines in concentrations. In 2012 Wah Chang completed
excavation and removal of the berm material that may have acted as a source of groundwater
contamination, and collected confirmation samples of groundwater. EPA will evaluate the
results of the completion report in 2013 to assess whether additional actions will be are
required.
Wah Chang must conduct additional sampling and analysis of PCBs in sediments to ensure
that the remedy for sediments is protective. EPA expects to evaluate additional data in 2013.
Wah Chang must submit a report to EPA documenting whether any of the wells being used
for CERCLA Site investigations were installed by Schoen Electric and Pump. If improperly
constructed wells are being used, Wah Chang must prepare a work plan for EPA approval
and replace these wells with wells that are compliant with well construction regulations.
Wah Chang must verify the status of deed restrictions requiring that land use at the Site
remain industrial, and whether deed restrictions for groundwater use and land use are in place
for the properties Wah Chang recently purchased east of Old Salem Road. Wah Chang must
also provide EPA with their site maintenance plan documenting information on areas of
subsurface PCB and radionuclide contamination.
OU3 - SURFACE AND SUBSURFACE SOIL
A protectiveness determination of the remedy at OU3 cannot be made at this time until
further information is obtained associated with exposure to radionuclides from resuspension
due to tilling in the Soil Amendment Area. Further information will be obtained by taking the
following actions. Under EPA oversight, Wah Chang must collect samples of SAA soil and
test for radiological contamination by the end of calendar year 2013 so EPA can reevaluate in
2014 the risk to human health and the environment from the disturbance/resuspension of soil
in order to evaluate whether human health is protected under the existing remedy.
Excavation of contaminated soil was completed and ICs are in place in the form of deed
restrictions for the main plant that will prevent human exposure to remaining soils.
Additionally, for the remedy to be protective in the long term, EPA and Wah Chang need to
take the following actions to ensure protectiveness.
Prior to plant decommissioning, EPA and ODEQ will amend the SOW of the 1996 Consent
Decree to incorporate applicable requirements of the 2001 Soil ESD for plant
decommissioning.
Under EPA oversight, Wah Chang must retest for radon in the CoGen Building by the end of
calendar year 2013 due to uncertainty in the location of the CoGen Building with respect to
the overall soil radiation footprint remaining after remediation of the Sand Unloading Area.
December 28, 2012 | 415-2328-007
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Fourth Five-Year Review Report for Wah Chang Superfund Site
City ofMillersburg
Linn County, Oregon
U.S. Environmental Protection Agency
Based on the results, EPA may require additional testing of radon in indoor air or radon
mitigation.
SITEWIDE PROTECTIVENESS
EPA has determined that there is not enough information to evaluate protectiveness, primarily
in the area of the site that has agricultural activities (SAA). Therefore, protectiveness is
deferred until the following additional information is evaluated. Wah Chang must collect and
analyze soil samples for radium so EPA can reevaluate the risk to human health and the
environment from the disturbance/resuspension of soil. Given that the earlier testing did not
demonstrate human health risk, the City may continue to use the property for agricultural
activities including tilling the soil although it is suggested by EPA that ground disturbing
activities that may resuspend soil should be limited. Following EPA's reassessment of the
contaminated soils, should there be an indication of human health risk to those exposed to
these soils under current agricultural practices, EPA will share those results with the City of
Millersburg and discuss appropriate actions for future use of the property.
Progress to meet the groundwater RAOs is being made through an operating GETS enhanced
with EISB. ICs are in place preventing exposure to contaminants of concern above cleanup
goals through on-site and off-site deed restrictions on groundwater use, zoning, and access
controls. In order to ensure long term protectiveness, Wah Chang must provide further
information on pH conditions and groundwater COC concentrations following remedy
enhancements so that EPA can evaluate the ability of the OU2 remedy to meet RAOs within
the 15-year time frame specified in the ROD (2017). In addition, Wah Chang must confirm
that all IC instruments required by EPA's decision documents are in place for all parcels of
property that could be affected by contaminated groundwater. Wah Chang must verify the
status of deed restrictions requiring that land use at the Site remain industrial, and whether
deed restrictions for groundwater use and land use are in place for the properties Wah Chang
recently purchased east of Old Salem Road. Wah Chang must also provide EPA with their
site maintenance plan documenting areas of subsurface PCB and radionuclide contamination.
EPA required Institutional Controls are in place requiring that anyone constructing future
buildings on the Teledyne Wah Chang Main Plant must conduct an assessment to determine
whether radon levels could pose an unacceptable risk to building occupants and implement
radon resistant construction and controls and radon testing if required. Since the CoGen
building was not constructed using radon resistant construction methods and is located in an
area where residual radioactive contamination may exist, Wah Chang must resample indoor
air radon in this building to ensure long term protectiveness of human health, and depending
on the results, EPA may require additional sampling and radon mitigation.
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December 28, 2012 | 415-2328-007
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Fourth Five-Year Review Report for Wah Chang Superfund Site
City ofMillersburg
Linn County, Oregon
U.S. Environmental Protection Agency
1 INTRODUCTION
The U.S. Environmental Protection Agency (EPA) Region 10 prepared this Five-Year
Review (FYR) for remedial actions (RAs) at the Teledyne Wah Chang (Wah Chang)
Superfund Site (the Site) in Millersburg, Linn County, Oregon. This is a statutory review and
is the fourth FYR for the Site, covering the period of January 2008 through December 2012.
EPA, as lead agency for the Site, conducted this review in coordination with the Oregon
Department of Environmental Quality (ODEQ).
EPA conducted this FYR pursuant to the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) in Title 40 Code of Federal Regulations (CFR)
Subsection 121(c) (§121(c)), as amended by §300.430(f)(4)(ii) of the National Oil and
Hazardous Substances Contingency Plan (NCP).
CERCLA §121 states:
"If the President selects a remedial action that results in any hazardous substances, pollutants,
or contaminants remaining at the Site, the President shall review such remedial action no less
often than each five years after the initiation of such remedial action to assure that human
health and the environment are being protected by the remedial action being implemented. In
addition, if upon such review it is the judgment of the President that action is appropriate at
such site in accordance with section [104] or [106] of the NCP, the President shall take or
require such action. The President shall report to Congress a list of facilities for which such
review is required, the results of all such reviews, and any actions taken as a result of such
reviews."
The EPA further interpreted this requirement in NCP §300.430(f)(4)(ii), which states:
"If a remedial action is selected that results in hazardous substances, pollutants, or
contaminants remaining at the Site above levels that allow for unlimited use and unrestricted
exposure, the lead agency shall review such action no less often than every five years after
the initiation of the selected remedial action."
For the purpose of conducting RAs at the Teledyne Wah Chang Superfund Site, EPA
organized three Operable Units (OUs) as follows:
Operable Unit 1 (OU1); Sludge Ponds (EPA 1989)
The OU1 remedy includes removal, solidification, and off-site disposal of sludge in the
Lower River Solids Pond (LRSP) and Schmidt Lake. Wah Chang constructed a special
monocell at the Finley Buttes Landfill in Boardman, Oregon, for the radioactive sludge
removed from the LRSP and Schmidt Lake.
Operable Unit 2 (OU2); Groundwater and Sediment (EPA 1994)
The OU2 remedy includes groundwater extraction and treatment in the Main Plant Area
for areas with contaminants exceeding lxlO"4 risk; monitored natural attenuation in the
Main Plant for the remaining areas not exceeding lxlO"4 risk (but exceeding lxlO"6);
monitored natural attenuation for the Farm Ponds and Solids Areas formerly used to store
waste sludges; environmental investigations of uninvestigated areas to ensure that
CERCLA remedial action decisions remain effective; contaminated sediment removal
from Truax Creek and bank stabilization of material left behind; and institutional controls
for those areas where existing contamination does not allow unrestricted use. For
remedial actions in the Feed Make-up Area, the remedy includes removal of
contaminants in the subsurface source material via flushing of the source material with
water. EPA has further augmented the groundwater remedy with the application of
Enhanced In-situ bioaugmentation in the Fabrication Area.
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Operable Unit 3 (OU3); Surface and Subsurface Soil (EPA 1995)
The OU3 remedy includes excavation of contaminated soil from the Sand Unloading
Area, excavation from the front parking lot areas, and the implementation of institutional
controls. The contaminated media was transported to an off-site facility for disposal.
The EPA initiation of on-site construction activities for OU1 triggered action for the FYR
process in August 1991. Five-year reviews are required due to the presence of contaminants
remaining above levels that allow for unlimited land use and unrestricted exposure at the Site.
EPA conducted this fourth FYR pursuant to the Office of Solid Waste and Emergency
Response Directive 9355.7-03B-P. The EPA Site manager conducted the review with the
assistance of ODEQ between January and December 2012.
The purpose of this fourth FYR is to evaluate the implementation and performance of the
selected remedies in order to determine if the remedies are or will be protective of human
health and the environment.
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2 SITE CHRONOLOGY
The following table summarizes the chronology of events at the Site.
Table 2-1. Chronology of Site Events
Event Date
Production of zirconium begins 1957
Melting and fabrication facilities added 1959
Teledyne Industries, Inc. purchased Wah Chang 1967
Chlorinator residues disposed of at Teledyne Wah Chang (TWC) 1972-1978
Application of lime solids to Soil Amendment Area 1976
Confirmation of radioactive materials in unlined sludge ponds (OSHD) 1977
NORM license granted to TWC 3/1978
Use of V-2 Pond discontinued 1979
Farm Ponds constructed 1979
TWC facility proposed for inclusion on National Priorities List (NPL) 1982
TWC listed on NPL 10/1983
Magnesium Resource Recovery Pile (MRRP) project 1983-1988
All underground storage tanks removed 1987
V-2 pond emptied 1989
Record of Decision (ROD) for Sludge Ponds Unit is signed 12/28/1989
Schmidt Lake soil removal 6/19-11/6/1991
Removal action for Lower River Solids Pond (LRSP) and Schmidt Lake 1991-1993
TWC completed RI/FS 3/1993
Supplemental radioactive material removal action for Schmidt Lake 8/1992 1/1993
Polychlorinated biphenyl (PCB) soil removal in the Building 114 area 11/1992
Remedial Investigation and Feasibility Study (RI/FS) 3/1993
EPA issued certification of completion for the Sludge Ponds Unit 6/1993
Ownership of Soil Amendment Area transferred to the City of Millersburg 1994
Groundwater and Sediments ROD signed 6/10/1994
Surface and Subsurface Soil ROD signed 9/27/1995
Remedial actions for the OU2 and OU3 RODs implemented in accordance with Scope 9/19/1996
of Work (SOW)
Groundwater Explanation of Significant Differences (ESD) 10/8/1996
Consent Decree lodged with U.S. District Court and State of Oregon 1/31/1997
Sediment cleanup of Truax Creek complete 1997
Sand Unloading Area removal 10/1997
First Five-Year Review 1997
Access Agreement signed for Sapp property 9/18/1998
TWC becomes Allegheny Technologies Inc. (ATI) Wah Chang 1999
Front Parking Lot Certificate of Completion 8/1999
Operation of South Extraction Area Groundwater Extraction and Treatment System 10/2000
(GETS) begins
Soil and Subsurface Soil ESD 9/28/2001
Operation of Fabrication Area GETS begins 4/2001 8/2001
Operation of Feed Makeup Area GETS begins 4/2002
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Event Date
Second Five-Year Review 2003
Land Transfer of Solids Area to City of Albany 2004
Soil Amendment ICs implemented 2006
Proposed Consent Decree for the Soil Amendment ICs lodged with U.S. District 3/27/2006
Court: 3/27/06.
Three-Year Groundwater Remedy Evaluation Reports for the Fabrication, Extraction, 2/2007 -9/2007
Solids and Farm Ponds Areas submitted.
Discovery of DNAPL during drilling of FW-8 in the Acid Sump Area 9/2007
Third Five-Year Review 1/2008
In Situ Bioremediation Pilot project begins in the South Extraction Area 3/2008
In Situ Bioremediation begins in the Acid Sump Area 2009
In Situ Bioremediation begins in the Crucible Cleaning Area 2010
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3 BACKGROUND
The following section presents an overview of the Site's location, physical characteristics,
land and resource use, contamination history, initial agency response, and the basis for taking
action.
3.1 SITE LOCATION AND DESCRIPTION
Wah Chang is an operating zirconium and other non-ferrous metals manufacturing plant
located in Millersburg, approximately two miles north of downtown Albany and
approximately 20 miles due south of Salem, Oregon (Figure 3-1).1 The Wah Chang Site is
located within an area in Millersburg that is zoned for heavy industry. Approximately
85 percent of the property is occupied by 180 buildings situated on 110 acres of land that are
paved, gravel-covered, or vegetated.
The three main areas of the Site include the Main Plant Area, the Solids Area, and the Farm
Ponds and Soil Amendment Areas. The Farm Ponds, historically used to hold wastewater
treatment lime solids, are located approximately 0.75 mile north of the Main Plant.
The Site is within the Willamette River Valley along the east bank of the river. Portions of
the property are located within the Willamette River's 100- and 500-year flood plains.
Riparian areas along the Site's western boundary are densely vegetated. In addition, the Site
is bounded to the east by Old Salem Road and Interstate 5 (1-5).
3.1.1 Main Plant Area
The Main Plant portion of the Site consists of the Extraction Area and Fabrication Area
where the manufacturing process is centered. Site features are linked to the manufacturing
process and support or have supported zirconium or non-ferrous metal production. The
zirconium manufacturing process involves a number of physical, chemical and
electrochemical steps t concentrate zircon, hafnium, vanadium, niobium, titanium, and
radioactive byproducts such as uranium and thorium. Site areas are presented on Figure 3-2
and described below.
3.1.1.1 Extraction Area
The Extraction Area is a 40-acre triangular-shaped portion of the Site located south of Truax
Creek. Zircon sand concentrate raw material is processed into hafnium and zirconium. The
Extraction area includes the Feed Makeup Area (FMA) and the South Extraction Area (SEA).
3.1.1.2 Fabrication Area
The Fabrication Area is a 50-acre area located north of Truax Creek. Zirconium is
consolidated into ingots and then welded together and melted into ingots. The ingots are then
fabricated into numerous shapes and forms such as forgings, plate, sheet, foil, tubing, rod,
and wire. The Fabrication Area includes the Acid Sump, Ammonium Sulfate Storage,
Material Recycle, Dump Master, and former Crucible Cleaning Areas.
1 The Teledyne Wah Chang Albany plant name was changed in 1997 after a merger with Allegheny
Technologies, and the abbreviation is Wah Chang.
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3.1.2 Solids Area
The Solids Area is a 20-acre area located west of the Fabrication Area. Subareas include the
following: LRSP, Schmidt Lake, Chlorinated Residue Pile (CRP), and the Magnesium
Resource Recovery Pile (MRRP). This area received solids from Wah Chang's wastewater
treatment system.
3.1.3 Farm Ponds Area
The Farm Ponds Area is an approximately 115-acre parcel located 0.75 mile north of the
Main Plant. This area includes the former four 2.5-acre storage ponds that received the
plant's wastewater treatment lime solids. The Farm Ponds Area is adjacent to the Soil
Amendment Area.
3.1.4 Soil Amendment Area
The Soil Amendment Area is a 40-acre parcel currently owned by the City of Millersburg that
is located north of the Farm Ponds. This area received a one-time application of lime solids
from the LRSP in an ODEQ-permitted action. In accordance with the terms of the 2006
CERCLA Consent Decree, the City of Millersburg is required to comply with EPA
Institutional Controls for radon mitigation applicable to construction of future buildings on
the property.
3.2 PHYSICAL CHARACTERISTICS
The following section describes the Site's physical characteristics, including topography,
surface water drainage, geology, and the hydrogeologic strata underlying the Site.
3.2.1 Physical Setting and Topography
Wah Chang is located within the broad and relatively flat Willamette Valley, which lies
between the Coast Range Mountains to the west and the Cascade Mountains to the east. The
ground surface in the vicinity of the Site slopes westward toward the Willamette River, with a
gradient of approximately 11 feet per mile.
Elevations at the Main Plant range from approximately 212 feet above mean sea level (msl)
to 180 feet msl, with higher elevations found along the eastern portion of the Site. Elevations
at the Farm Ponds range from approximately 212 feet msl to 232 feet msl. The Fabrication
Area of the Main Plant is relatively flat from Old Salem Road to the Burlington Northern
Railroad where elevation varies less than approximately four feet. To the north of the
Fabrication Area, steeper slopes are present within the channel of Murder Creek. To the
south, steeper slopes are present in the channel of Truax Creek. The Extraction Area is south
of Truax Creek and the facility's wastewater treatment plant and ponds sit at a lower
elevation (approximately 200 to 202 feet msl) than the remaining Extraction Area (210 to 212
feet msl). The Extraction Area to the south of the wastewater treatment plant is at a slightly
higher elevation. Elevations in the Solids Area range from approximately 208 feet msl along
the western portion near the Burlington Northern Railroad line to 180 feet msl at the
Willamette River. The Solids Area exhibits more pronounced changes in topography across
the Site compared to the Main Plant Area.
3.2.2 Site Geology and Hydrogeology
Geologic deposits underlying Wah Chang are similar to those found in much of the central
Willamette Valley (Beaulieu J.D., et al. 1974; CH2M Hill 1993; Ma et al. 2009). The
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geologic units influence the groundwater flow characteristics of the water-bearing zones at
the Site.
Site stratigraphy of these units, from youngest to oldest, is as follows (additional details can
be obtained from the remedial investigation/feasibility study [RI/FS] report for the Site
[CH2M Hill, 1993] and the 2008 FYR Report [EPA 2008]):
Fill: A brown, poorly sorted subangular gravel with sand and silt. The fill may contain wood
and metal debris in some areas. Fill is primarily encountered in the Fabrication Area, with
irregular thickness between 1 and 23 feet, and along the banks of Truax and Murder Creeks.
The unit is a poor water-bearing unit with limited saturated thickness.
Recent Alluvium: Alluvial material is derived from present day streams and rivers, their
floodplains, and abandoned channels. The alluvium at the Site consists of silts and sands
with some possible reworked Linn Gravel. In areas of Truax and Murder Creeks the
alluvium has been observed to be up to approximately 15 feet thick. In the Solids Area,
alluvium ranges from 10 to 25 feet thick. The unit is generally a poor water-bearing zone
composed of an upper silt unit and a lower silty clay-clay unit under unconfined
conditions. Groundwater within this unit locally discharges to Truax Creek and the
Willamette River.
Willamette Silt: The Willamette Silt is a Pleistocene deposit associated with catastrophic
Missoula Floods (Waitt 1985). The unit consists of stiff, fine-grained silt, with varying
amounts of clay, and a gray clay is present at the base of the deposit. Thickness ranges
from 4 to 30 feet. The Willamette Silt is generally found at the ground surface of the Site.
Linn Gravel: The Linn Gravel is a Pleistocene outwash deposit from the Cascade
Mountains that consists of well-sorted sub-rounded gravel with occasional layers of sand,
silt, and clay. Unit thickness variations from 10 feet to over 40 feet appear to be related to
an erosional surface of the Spencer Formation. The Linn Gravel is the predominant
water-bearing zone at the Site and is under confined or semi-confined conditions.
Groundwater within this unit locally discharges to Murder and Truax Creeks, Second
Lake and the Willamette River.
Blue Clav: The Blue Clay is a lakebed or river overbank deposit that filled depressions in
the surfaces of the Spencer and Eugene Formations. The unit consists of a blue-gray to
brown, stiff, silty clay with fine sand lenses. The thickness of the Blue Clay is variable,
ranging from not encountered to over 145 feet thick. The unit serves as a confining layer
that is not laterally continuous throughout the Site.
Spencer Formation: The Spencer Formation consists of shallow marine indurated
siltstone to fine grain sandstone with some layers of volcanic tuff or flows and is the
shallowest bedrock formation in the Albany area. The Spencer Formation is estimated to
be approximately 1,500 feet thick. The unit is a poor water-bearing, indurated siltstone.
Yields may be dependent on fractures and jointing within the unit.
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3.2.3 Groundwater Flow
Groundwater flow on a regional scale is toward the Willamette River (CH2M Hill 2005).
Vertical groundwater flow is upward in the vicinity of the Willamette River. Localized
downward flow is associated with infiltration of precipitation and retention pond seepage
(CH2M Hill 1993). EPA determined the groundwater flow direction at the Site from
groundwater elevation measurements in wells located throughout the Site. Figure 3-3 shows
inferred groundwater elevation contours based on Wah Chang's May 2010 water level
measurements, and Figure 3-4 shows inferred groundwater elevation contours based on Wah
Chang's October 2012 water level measurements. The groundwater elevations are a typical
representation of the groundwater surface at the Site, and while the elevations may change
seasonally with precipitation, the general character of the groundwater surface and
groundwater flow directions remain relatively unchanged. Wah Chang collected groundwater
elevations for the Solids Area and Farm Ponds Area only for the October 2010 monitoring
event.
Wah Chang installed a pump-and-treat remediation system at the facility in 2001. The
groundwater extraction and treatment system (GETS) consists of seven extraction wells
(identified FW-1 though FW-7) at the Fabrication Area, and six extraction wells (identified
EW-1 through EW-6) at the Extraction Area. Based on groundwater level measurements from
the Fabrication Area, EPA identified an apparent groundwater divide that extends across the
northwest portion of the Fabrication Area (Figure 3-3 and Figure 3-4). North of the divide,
groundwater flows to Murder Creek, while south of the divide groundwater flows to Truax
Creek. In the southeastern portion of the Fabrication Area, seepage from a Cooling Water
Pond forms a localized groundwater mound that creates an east-to-southeast groundwater
flow direction from the pond area through the Dump Master area and discharges to Truax
Creek. Recharge from the Cooling Water Pond creates a groundwater flow divide between
extraction wells FW-1, FW-4 and FW-7 in the Arc-Melting subarea, and extraction wells
FW-2, FW-3 and FW-5 in the Acid Sump and Ammonia Sulfate Storage subareas. Extraction
wells appear to locally influence the direction of groundwater flow.
Groundwater flows west-southwest across the Extraction Area to Second Lake or north to
Truax Creek (Figure 3-3 and Figure 3-4). In the northern portion of the Extraction Area,
seepage from Ponds IB and 2 creates localized groundwater flow to the north and south of
the ponds. Surface water seepage from retention ponds is a source of groundwater recharge to
the Linn Gravels. Groundwater elevation data do not provide evidence that extraction wells
EW-1 through EW-3 provide localized hydraulic capture in the FMA.
Groundwater flow in the Solids Area is generally to the southwest towards Truax Creek and
the Willamette River (Figure 3-4). In the vicinity of Weyerhaeuser's primary settling ponds,
there is a localized groundwater mound.
Groundwater flow in the Farm Ponds Area is generally to the west-southwest towards Third
Lake and the Willamette River (Figure 3-5).
3.2.4 Surface Water
Surface water features at the Site include the Willamette River, Conser Slough, Truax and
Murder Creeks, and Second, Third and Fourth Lakes. Figure 3-1 displays surface water
features in and adjacent to Wah Chang. Also included are Wah Chang's four Site retention
ponds: Cooling Water Pond, Pond IB, Pond 2, and Schmidt Lake (Wah Chang has excavated
and lined Schmidt Lake and has designated it Pond 3; for the purpose of this report it will be
termed Schmidt Lake). The Weyerhaeuser settlement ponds and the Lower River Solids Pond
(LRSP) are not used for Site water retention. The Weyerhaeuser ponds receive water from the
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Weyerhaeuser facility. Wah Chang is not using the LRSP and it does not receive Site water.
Surface water is an important feature at the Site because of its influence on groundwater flow,
contaminant transport, and remedial actions.
The Willamette River borders the Site's western property boundary. Second, Third, and
Fourth Lakes are remnant features from the ancestral Willamette River. Surface water flows
into the Willamette River from Conser Slough, which in turn receives water from Second,
Third, and Fourth Lakes. Third Lake receives discharge from Murder and Truax Creeks.
The Murder Creek drainage forms a topographic and hydrologic boundary between Wah
Chang and the City ofMillersburg public and semi-public lands to the north. Discharge in the
creek is generally low during most of the year. Upstream of Wah Chang, the creek receives
recharge from forested and agricultural lands that originates from Knox Butte. Immediately
upstream of Wah Chang, the creek passes by a wood product and resin plant, and other light
industrial facilities.
The Truax Creek drainage forms a topographic and hydrologic boundary between the
Extraction and Fabrication Areas, flowing through the central portion of the Main Plant Area.
The creek originates southeast of the facility in a basin of approximately 9 square miles
consisting of residential, agricultural, and forested lands. During winter months (November-
May), creek flows have been measured from 0.5 to 15 cubic feet per second in the reach that
passes through the Wah Chang Site upstream of the Pond 2 weir. During the summer months
(June-October), there is no measurable flow in Truax Creek upstream of the Wah Chang
NPDES outfall. Sapp Ditch flows beneath Old Salem Road and into Truax Creek. In addition
to natural surface water run-off, Truax Creek receives approximately 3 million gallons per
day (mgd) of permitted discharge water from Pond 2, and approximately 150 gallons per
minute (gpm) of water from the Cooling Water Pond.
Wah Chang's Cooling Water Pond is approximately 1 acre in size and 5 feet deep and is
located in the southeast corner of the Fabrication Area (CH2M Hill 2005). Wah Chang pumps
surface water from the Willamette River, treats the water, and stores it in the pond for
industrial process use.
Wah Chang operates two wastewater ponds, Pond IB and Pond 2, under an NPDES permit.
The ponds are located south of Truax Creek at the north end of the Extraction Area. Water
from Pond IB, which originates from the wastewater treatment plant clarifier, is gravity-fed
to Pond 2, and from there is pumped to Schmidt Lake (now called Cell 3) and ultimately
pumped to an engineered wetlands along with treated effluent from the City of Albany prior
to discharge to the Willamette River. The ponds are maintained at a constant surface
elevation. By agreement with the City of Albany, additional water is pumped from the
Willamette River to maintain summer flows in Truax Creek.
LAND AND RESOURCE USE
Wah Chang, Weyerhaeuser, and Simpson Timber own the majority of land within the
Millersburg city limits. Wah Chang's Main Plant and surrounding properties are used
primarily for industrial purposes and zoned for General Industrial use, with some recreational
and residential use. The former residential area between 1-5 and Old Salem Road is zoned for
Limited Industrial Commercial use, and residential use is anticipated to be phased out with
the use of this area becoming more industrial.
A conservation easement in place west of the Site is intended to retain this property as natural
and scenic open space. Based on an interview with the mayor ofMillersburg, the EPA does
not anticipate re-zoning of surrounding properties which would require approval by the
Millersburg City Council and Planning Commission.
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Current groundwater use at Wah Chang includes base flow recharge to Murder and Truax
Creeks, Second Lake and the Willamette River. Two supply wellsone owned by Wah
Chang, the other owned by Georgia Pacificare used for fire suppression (CH2M Hill 2005).
Groundwater at the Wah Chang Site is a potential source of drinking water based on the EPA
classification scheme (EPA 1986). However, the EPA does not anticipate that domestic water
wells will be installed in the future on the Wah Chang Site or adjacent properties, given the
industrial zoning and the availability of potable water from the City of Albany. The City of
Albany requires that all new developments connect to municipal water lines if service is
available within 150 feet.
The Wah Chang Site and adjacent properties are subject to a declaration of restrictive
covenants that specifically prohibit the construction of water supply wells (Wah Chang
2012c). Therefore, future use of potable groundwater under the Wah Chang facility is not
anticipated and would be a violation of the Consent Decree without EPA approval. It is not
known whether restrictive covenants addressing groundwater use are in place for the
properties Wah Chang acquired in 2008 east of Old Salem Road.
3.4 HISTORY OF CONTAMINATION
Wah Chang began operating at the Site in 1956 when, under contract with the U.S. Atomic
Energy Commission, Wah Chang Corporation reopened the U.S. Bureau of Mines Zirconium
Metal Sponge Pilot Plant. Wah Chang began construction of new facilities at the location of
the existing plant in 1957. Wah Chang established these facilities primarily for the production
of zirconium and hafnium sponge; however, tantalum and niobium pilot facilities were also
included. Wah Chang's melting and fabrication operations were added in 1959. Historical
releases of hazardous chemicals to the environment at the Site were associated with the
manufacturing process of converting zircon sand into metal products.
3.4.1 Main Plant
This section presents general information on historical contamination in areas of the Main
Plant. Additional details can be found in the RI (CH2M Hill 1993).
3.4.1.1 Extraction Area
The Extraction Area of the facility is composed of the FMA and the SEA. The Extraction
Area contains the physical and chemical processes that isolate and extract target metals
(zirconium and hafnium) from the zircon sand concentrate.
Feed Makeup Area: Wah Chang reported during the RI that zirconium tetrachloride was
dissolved in water, resulting in a solution of very low pH that contained various other
metals. The solution was ultimately transferred to the Separations Building via
underground pipes. Leaks from the pipes and tanks containing the feed solution affected
soil and groundwater in the vicinity. Based on the results of the RI, the source of the
extremely low pH at well PW-28A was postulated to be buried pre-1978 feed solution
that was previously used in Wah Chang's ongoing processes. At the time of remedy
implementation, the groundwater pH was approximately 1 and contained inorganic
chemicals, most notably zirconium, thorium, and radium.
South Extraction Area: Wah Chang detected chlorinated solvents in groundwater
during the RI that may have been released from the maintenance shop area. Wah Chang
discontinued use of the cleaning solvents trichloroethene (TCE) and 1,1,1 trichloroethane
(TCA) in 1982 and 1988, respectively. Spills of the solvents have not been documented
in the area. However, a soil gas survey completed during the RI indicated the presence of
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TCE and TCA in soil gas beneath the asphalt pavement. Groundwater samples from
RI/FS wells documented the existence of a solvent plume composed of TCE and TCA.
Soils in the chemical unloading areas were found to be contaminated with semi-volatile
organic compounds (SVOCs), polychlorinated biphenyls (PCBs), polycyclic aromatic
hydrocarbons (PAHs), and radionuclides.
3.4.1.2 Fabrication Area
The Fabrication Area contained the manufacturing facilities that processed the finished
products, mainly the metal sponge produced during the extraction process. Contamination
generally resulted from historical use of chemicals in five subareas: the Acid Sump Area
(ASA), the Arc-Melting Building Area, Emergency Services Building, Truax Fill Area, and
the Ammonium Sulfate Storage Area.
Acid Sump Area: Solvents, caustics and acids were used for cleaning metals in the
manufacturing process. Releases from the ASA have occurred from historical leaks and
spills into soils and groundwater. Groundwater in the ASA contained the highest
concentrations of chlorinated VOCs during the RI. Important constituents in groundwater
include 1,1-dichloroethene (DCE), TCA, TCE and vinyl chloride (VC).
Arc-Melting Building Area: Incidental releases during solvent handling (TCE and
TCA) have been the source of contamination in soils and groundwater under and in the
vicinity of the Arc-Melting Building Area.
Emergency Services Building: A release of PCBs was encountered near the building
during the RI. PCB-containing oil was found floating on the water table in 1991. The
source of the PCB contamination was not discovered.
Truax Creek Fill: Fill material along Truax Creek's northern bank placed between 1958
and 1978 was found to be contaminated with radionuclides, PAHs, PCBs, and metals.
Ammonium Sulfate Storage Area: In 1978, a 400,000-gallon tank containing
ammonium sulfate in the Ammonium Sulfate Storage Area failed. This process liquid
also contained methyl isobutyl ketone (MIBK), chloride, sulfate, iron, uranium,
thiocyanate, and zirconium. In 1991 a spill of pickling acid (hydrofluoric and nitric acid)
was the primary source of fluoride and nitrate in the ASA.
3.4.2 Solids Area
The Solids Area received process waste material from facility operations. Waste material
primarily contained lime solid precipitate from industrial wastewater, magnesium chloride
from non-ferrous metal operations, and carbon from sand chlorination. The Solids Area
includes the Solids Ponds (LRSP and Schmidt Lake), the CRP, and the MRRP.
Wah Chang filled the Solids Ponds (LRSP and Schmidt Lake) with lime solids that resulted
as a byproduct from the manufacturing process of zirconium from 1967 to 1979. Seepage
from the ponds occurred from the carrier fluids to the shallow groundwater in the Solids
Area. RI activities conducted between 1989 and 1992 indicated the presence of chlorinated
volatile organic compounds (VOCs), SVOCs, trace metals, radium, ammonium, nitrate,
chloride, fluoride, and magnesium (CH2M Hill 2003).
Wah Chang placed solid material from the sand chlorination processes in the CRP located
north of Schmidt Lake between 1972 and 1977. The material contained 80 to 90 percent
carbon, a small amount of zircon sand, and low levels of radionuclide constituents, including
uranium, thorium, and their daughter products. Wah Chang removed approximately 5,000
cubic yards of material from the Solids Area in 1978.
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Wah Chang made process modifications 1978 that allowed for the separation of radioactive
compounds from wastewater treatment solids. The process modification directs the
radioactive materials into a separate solid waste stream, referred to as chlorinator residue. The
chlorinator residue is managed as low specific activity radioactive waste and is transported to
Hanford, Washington, for disposal. Implementation of this process modification allows the
remaining solids, referred to as lime solids, to be placed in the Farm Ponds Area.
Wah Chang stored approximately 44,000 cubic yards of magnesium chloride solids at the
northeast corner of the LRSP. Rainwater seepage through the material may have mobilized
water-soluble salts (CI, Na, S04, Mg). Wah Chang placed solids material produced in the
facility's non-ferrous metals operation in the MRRP until May 1983 and removed the
material under EPA oversight in 1988.
3.4.3 Farm Ponds
Wah Chang started piping lime solid slurry to the south end of the Farm Ponds for additional
settling and dewatering in October 1979. Solids-free return water was decanted from the
north end of the ponds and sent to the wastewater treatment plant. Removal and disposal of
the solids was regulated under an NPDES permit.
In 1994 Wah Chang stopped using the Farm Ponds and closed that portion of the Site.
Closure was conducted by draining and returning the free water to the wastewater treatment
system, excavating and drying the lime solids on an asphalt pad, and transporting the dried
solids to a Waste Management, Inc. Subtitle D disposal facility in Arlington, Oregon. Wah
Chang then re-graded the pond area to restore the natural topography. The closure work was
performed between 1995 and 2000. Currently, Wah Chang manages lime solids as solid
waste.
Although the material Wah Chang used to construct and dike the ponds was of relatively low
permeability, dissolved phase chemicals in the carrier fluid seeped into the underlying soil
and groundwater. Wah Chang conducted the RI investigation, that indicated the presence of
VOCs, SVOCs, trace metals, radium, ammonium, nitrate, chloride, fluoride, and magnesium
in groundwater in the vicinity of the Farm Ponds.
3.5 INITIAL RESPONSE
EPA and ODEQ were concerned that because the unlined sludge ponds in the Solids Area
were located in the Willamette River floodplain, hazardous materials from the sludge ponds
would migrate to soil, surface water, and groundwater. This led EPA to formally place Wah
Chang on the National Priorities List (NPL) in October 1983.
3.6 BASIS FOR TAKING ACTION
In response to releases or a substantial threat of a release of a hazardous substance at or from
the Site, Wah Chang commenced an RI/FS for the Site in 1987 under Consent Order (Docket
No. 1086-02-19-106).
The sludge ponds in the Solids Area were separated from the rest of the Site in 1988 shortly
after the commencement of the RI due to the likely source of groundwater contamination, the
area being located in the Willamette River floodplain, radioactive materials contained in the
sludge, and Wah Chang wanting to clean up the ponds before the full RI/FS was completed.
The EPA designated the Sludge Ponds as Operable Unit 1 (OU1) in a Record of Decision
(ROD) on December 28, 1989 (EPA 1989). The Farm Ponds were originally included in OU1
but were addressed under an investigation already underway for the rest of the Wah Chang
Site under oversight with ODEQ.
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On February 14, 1991, EPA issued a Unilateral Order to Wah Chang for design and
implementation of the selected remedy for the Sludge Ponds Operable Unit (OU1). In June
1991, in association with the response action, Wah Chang completed construction of the off-
site monocell at the Finley Buttes Landfill in Boardman, Oregon. Excavation and removal of
the sludges began in July 1991 and were completed in November 1991. Approximately
100,000 cubic yards of solids (including cement) were transported to the monocell at Finley
Buttes. Cover construction and grass seeding of the monocell were completed in April 1992.
On June 30, 1993, EPA issued a Certification of Completion to Wah Chang for the OU1
remedial action.
After publication of the RI/FS (CH2M Hill 1993) and proposed plan, EPA selected the
remedy for groundwater, sediments, and soils. EPA's decisions on remedial actions at Wah
Chang are embodied in two final ROD documents on which the State of Oregon gave its
concurrence:
The Groundwater and Sediments Operable Unit 2 (OU2), executed on June 10, 1994
(EPA 1994).
The Surface and Subsurface Soils Operable Unit 3 (OU3), executed on September 27,
1995 (EPA 1995).
The RODs included EPA's explanation for any significant differences between the final plans
and the proposed plans, as well as responsiveness summaries to public comments.
CONTAMINANTS OF CONCERN
EPA determined that contaminants of concern (COCs) at the Wah Chang Site were selected
based on the following criteria: (1) the concentration of the chemical exceeded naturally
occurring levels; (2) there were EPA-derived slope factors or reference doses available for the
respective chemical; or (3) the maximum detected concentration exceeded a conservative
health-based screening concentration. Chemicals in groundwater and soil were eliminated
from consideration if the maximum detected concentration was less than or equal to 10"6
excess lifetime cancer risk (ELCR) value, or less than or equal to 1 hazard index (HI) for
non-cancer effects.
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3.7.2 OU1 - Sludges
The ROD for OU1 identified the following COCs in the LRSP and Schmidt Lake sludge:
Bis(2-ethylhexyl)phthalate Antimony
Methylene Chloride Arsenic
1,1-Dichloroethane (1,1-DCA) . Barium
Hexachlorobenzene Beryllium
Tetrachloroethene (PCE) Cadmium
Trichloroethene (TCE) Chromium VI
1,1,1-trichloroethane (TCA) Copper
N-nitrosodi-N-propylamine Cyanide
Lead
Mercury
Nickel
Radium-226
Selenium
Thorium
Uranium
Zinc
Zirconium (metal)
3.7.3 OU2 - Groundwater and Sediment
The ROD for OU2 identified the following COCs for groundwater and sediments.
3.7.3.1 Groundwater
EPA identified the following COCs
in groundwater:
Acetone
Antimony
Benzene
Arsenic
Chloroform
Barium
1,1-Dichloroethane (1,1-DCA)
Beryllium
1,2-Dichloroethane (1,2-DCA)
Cadmium
1,1-Dichloroethene (1,1-DCE)
Copper
1,2-Dichloroethene (1,2-DCE)
Magnesium
Methyl isobutyl ketone (MIBK)
Manganese
1,1,2,2-Tetrachloroethane
Mercury
Tetrachloroethene (PCE)
Nickel
1,1,1 -Trichloroethane (1,1,1 -TCA)
Thallium
1,1,2-Trichloroethane (1,1,2-TCA)
Thorium
Trichloroethene (TCE)
Uranium
Vinyl Chloride (VC)
Zinc
Hexachlorobenzene
Zirconium
Bis(2-ethylhexyl)phthalate
Ammonia
Polychlorinated biphenyls (PCBs)
Fluoride
Radium-226
Nitrate
Radium-228
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3.7.3.2 Sediments
EPA identified the following COCs in sediments:
Total PCBs,
hexachlorobenzene, and
radionuclides.
3.7.4 OU3 - Surface and Subsurface Soils
The EPA identified the following COCs in surface and subsurface soils:
Benzo(a)anthracene
Benzo(a)pyrene
Total PCBs
Chromium
Thorium
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Chrysene
Zirconium
Radium-226
Radium-228
Dibenz(a,k)anthracene
Hexachlorobenzene
Indeno( 1,2,3 -cd)pyrene
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4 REMEDIAL ACTIONS
This section describes the remedial action objectives, selected remedy, and highlights of
remedy implementation for each of the three Operable Units of the Teledyne Wah Chang
Site. Those Operable Units are OU1 Sludge Ponds, OU2 Groundwater and Sediments, and
OU3 Surface and Subsurface Soils.
4.1 OU1 - SLUDGE PONDS
On December 28, 1989, EPA selected the Final Remedial Action for the Sludge Ponds
Operable Unit 1 (OU1), which is described in the ROD (EPA 1989). This section discusses
the RAOs and remedy selection, and remedy implementation for OU1.
4.1.1 Remedy Selection
The RAOs for OU 1 were to effectively reduce risk to human health and the environment and
to ensure that contaminants were not transported to groundwater, surface water, and/or air.
The remedy selected in the ROD for OU 1 consisted of:
Excavation and removal of approximately 110,000 cubic yards of solids from the ponds.
Partial solidification of the sludge using Portland cement.
Construction of a monocell at Finley Buttes Landfill, an off-site, permitted solid waste
facility.
Transportation of the solidified sludge to Finley Buttes Landfill and disposal in the
monocell.
Long-term operation and maintenance (O&M) of the off-site monocell.
4.1.2 Remedy Implementation
On February 14, 1991, EPA issued a Unilateral Order to Wah Chang for design and
implementation of the selected remedy for the Sludge Ponds. Based on this order, excavated
sludge was transported to the monocell at Finley Buttes Landfill in Boardman, Oregon. On
June 30, 1993, EPA issued a Certification of Completion for the Sludge Ponds OU1 RA to
Wah Chang (EPA 1993).
4.2 OU2-GROUNDWATER AND SEDIMENTS
On June 10, 1994, EPA selected the Final Remedial Action for Groundwater and Sediments
Operable Unit 2 (OU2), which is described in the ROD (EPA 1994). This section discusses
the RAOs and remedy selection, and remedy implementation for OU2.
4.2.1 Remedy Selection
4.2.1.1 Remedial Action Objectives
Based on the results of the Risk Assessment and the findings of the RI/FS, the following
RAOs were established for groundwater, surface water, and sediment in OU2.
Groundwater:
Prevent people from drinking groundwater containing contaminant levels above
federal or state drinking water standards.
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Prevent contaminated groundwater above federal or state drinking water standards
from leaving the TWC property boundary.
Reduce the concentrations of TWC-related organic, inorganic, or radionuclide
compounds in groundwater to concentrations below federal or state drinking water
standards or other risk based levels.
Prevent groundwater containing TWC-related organic, inorganic, or radionuclide
compounds above federal or state standards from discharging into nearby surface
water.
Surface Water:
Ensure that non-permitted discharges to surface water from the TWC facility do not
exceed federal or state water quality standards.
Sediments:
Reduce the concentrations of TWC-related organic, inorganic, or radionuclide
compounds in groundwater to concentrations below federal or state drinking water
standards or other risk based levels.
Prevent sediments containing TWC-related contaminants from leaving the Site.
Prevent aquatic organisms from coming into contact with contaminated sediments.
Reduce concentrations of TWC-related compounds in sediments where necessary, to
protect aquatic organisms.
4.2.1.2 Remedial Actions Identified in the ROD
The selected RAs for OU2 identified in the ROD consisted of groundwater extraction,
pretreatment of discharged extracted groundwater, monitored natural attenuation (MNA),
treatment or removal of subsurface source material near the Feed Makeup Area, slope erosion
protection along the banks of Truax Creek, sediment removal, and Sitewide actions. The
major components of the selected remedy are described below.
Groundwater Remedial Actions
Remediation by groundwater extraction where contaminant concentrations exceed
lifetime cancer risk levels of 10-4 and/or substantially exceed the non-cancer HI of 1
for worker exposure (hot-spot areas). Extraction shall continue until contaminant
concentrations in groundwater throughout the Site are reduced to below Safe
Drinking Water Act (SDWA) maximum contaminant levels (MCLs), non-zero
maximum contaminant level goals (MCLGs), or cancer risk levels of 10-6 and non-
cancer risk HI less than 1 for worker exposure, or until EPA in consultation with
ODEQ determines that continued groundwater extraction would not be expected to
result in additional cost-effective reduction in contaminant concentrations at the Site.
Contaminated groundwater in exceedance of SDWA MCLs, non-zero MCLGs, or
cancer risk levels of 10-6 and non-cancer risk HI greater than 1 for residential use
shall be prevented from migrating off the Plant Site or beyond the current boundary
of the groundwater contaminant plume at the Farm Ponds Area.
Discharge of extracted groundwater into Wah Chang's wastewater treatment plant.
Pretreatment of groundwater to comply with Clean Water Act (CWA) requirements
prior to discharge to the wastewater treatment plant.
Treatment or removal of subsurface source material near the Feed Makeup Building
on the Main Plant.
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Sediment Remedial Actions
Slope erosion protection consisting of a geotextile covered by riprap placed along the
banks of Truax Creek to prevent contaminated fill material from entering the creek.
Removal of 3,600 cubic yards of contaminated sediments from surface water bodies
adjacent to or flowing through the Site. Additional ecological characterization prior
to removal to determine potential impacts of sediment removal to local ecosystems
and to provide a mechanism to mitigate those potential impacts.
Sitewide Actions
Deed restrictions and institutional controls on land and groundwater use for both the
Main Plant and the Farm Ponds Area. The objective of this component of the remedy
is to ensure that the property and groundwater are used for purposes appropriate to
the cleanup levels achieved.
Environmental evaluations of currently uncharacterized potentially contaminated
source areas as needed to ensure achievement of groundwater remedial action
objectives (RAOs). The objective of this component of the remedy is to ensure that
contaminated source areas do not adversely impact the remedy.
Long-term on- and off-site groundwater, surface water, and sediment monitoring,
which shall include, at a minimum, the monitoring of on-site wells that are in
exceedance of MCLs and non-zero MCLGs, cancer risk levels of 10-6, and non-
cancer risk of HI greater than 1 for residential exposure.
Review of selected remedy at least once every 5 years to ensure protection of human
health and the environment.
4.2.1.3 ROD Amendments or Explanation of Significant Differences
During the preparation of the Scope of Work for implementation of the groundwater remedy,
the following changes were made to the selected RA and outlined in EPA issued ESDs on
October 8, 1996 (EPA 1996) and June 19, 2009 (EPA 2009).
Change 1 - Conditional Change to the Western and Northern Perimeter Containment
Requirements: EPA dropped the requirement for groundwater extraction at and outside the
plant boundaries on the northern and western perimeters. Dropping the perimeter
requirements was contingent on certain conditions described in the ESD (EPA 1996)
including placing deed restrictions on adjacent property on the western perimeter to preclude
groundwater use for drinking water. The EPA considered that contaminants in groundwater
would be reduced to below ROD cleanup levels at and outside compliance points, and the
public would be protected through restrictions on groundwater use.
Change 2 - Clarification in Requirements for the Farm Ponds Area: The EPA made the
remediation requirements for the Farm Ponds Area consistent with the rest of the Site. Within
the Farm Ponds Area, remediation will take place through removal of hot spots of
contaminated soil; however, the plume in the Farm Ponds must be kept from significantly
expanding. Wah Chang's compliance with this requirement will be demonstrated by existing
groundwater data; and by data collected pursuant to the RA indicating that contaminant levels
(and total excess cancer risk and/or HI) in wells in the Farm Ponds Area are not increasing, or
are declining; and/or other Site data or information indicating that natural attenuation is
effectively reducing contaminant levels. For consistency with the rest of the Site, EPA
changed the point of compliance to the property boundaries in the Farm Ponds Area through
this ESD.
Change 3 - Correction in Sediment Area Exceeding the Action Level: EPA reviewed the
RI/FS sediment data and identified that not all areas in the ROD exceeded action levels (1
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ppm). Areas not exceeding the 1 ppm total PCBs action level will not be remediated. These
include Conser Slough and Murder Creek. The areas that exceed sediment action levels,
including the confluence of Murder and Truax Creeks, the confluence of Truax Creek and
Second Lake overflow, and the reach of Truax Creek that passes along Truax Fill, were
planned to be remediated.
Change 4 - Implementation of the Enhanced In Situ Bioaugmentation: Wah Chang installed
GETS at the facility in 2001 that consists of seven extraction wells at the Fabrication Area,
and six extraction wells at the Extraction Area. One well (FW-6) planned for the ASA was
not implemented because the pump test revealed a sustainable yield of less than 0.1 gpm.
Before the 2008 Five Year Review, EPA was concerned that RAOs may not be met within
the ASA and required that an additional extraction well (FW-8) be installed. However, during
drilling Wah Chang encountered a sheen/solvent odor and testing indicated TCA was
detected at a concentration of 1,420 milligrams per liter (mg/L). The concentration of TCA
was indicative of dense non-aqueous phase liquid (DNAPL). EPA determined that GETS
alone would not achieve ROD performance standards. Therefore in addition to GETS, EPA
selected a secondary treatment technology consisting of Enhanced In Situ Bioaugmentation
(EISB) that was necessary to meet RAOs (EPA 2009).
4.2.2 Remedy Implementation
Implementation of the RAs for OU2 is described in the following sections.
4.2.2.1 Groundwater Extraction
Wah Chang implemented a GETS in the Extraction and Fabrication Areas as an element of
the remedy to achieve groundwater RAOs and cleanup levels.
Extraction Area
The GETS in the Extraction Area consists of two groups of three extraction wells: EW-1,
EW-2, and EW-3 in the FMA; and EW-4, EW-5, and EW-6 in the SEA (Figure 3-2). Startup
of GETS operation in the SEA was completed in October 2000. Startup of GETS operation in
the FMA was completed in April 2002.
Fabrication Area
The Fabrication Area well field consists of six extraction wells identified as FW-1, FW-2,
FW-3, FW-4, FW-5, and FW-7 (Figure 3-2). Startup of the GETS operation was completed
between April and August 2001. The Remedial Design of the Fabrication Area well field
originally called for seven extraction wells. FW-6 was not implemented because of a low
sustainable yield of less than 0.1 gpm. Operation at FW-7 was terminated in July 2009 per
EPA approval due to low CVOC concentrations and the Wah Chang's 2008 purchase of the
residential property on the east side of Old Salem Road (Wah Chang 2009). Well FW-7 was
installed in 2001 as a hydraulic barrier between the Wah Chang Site and the residential
property.
4.2.2.2 Attainment of Groundwater Cleanup Levels
The purpose of groundwater extraction is to expedite the attainment of Sitewide groundwater
ROD cleanup levels. Wah Chang will continue groundwater extraction until cleanup levels
are achieved at the point of compliance. EPA established the point of compliance at the Main
Plant property boundary and for the Farm Ponds Area, the edge of the Farm Ponds
themselves. ROD cleanup levels for groundwater are presented in Table 4-1.
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Table 4-1. COCs in Groundwater Cleanup Levels from Table 10-1 of the ROD
Chemical
Cleanup
COCs2
Classification
Level(jig/L)
Basis
Benzene
voc
5
MCL
1,2-Dichloroethane (DCA)
voc
5
MCL
1,1-Dichloroethene (DCE)
voc
7
MCL
Methylisobutylketone (MIBK)
voc
5,000
m=i
1,1,2,2-Tetrachloroethane
voc
0.175
10-6
Tetrachloroethene (PCE)
voc
5
MCL
1,1,1-Trichloroethane (TCA)
voc
200
MCL
1,1,2-Trichloroethane (1,1,2-TCA)
voc
3
Non-zero MCLG
Trichloroethene (TCE)
voc
5
MCL
Vinyl Chloride (VC)
voc
2
MCL
Hexachlorobenzene
svoc
1
MCL
Bis(2ethylhexyl)phthalate
svoc
0.2
MCL
Total PCBs
svoc
0.5
MCL
Beryllium
Metal
4
MCL
Copper
Metal
1,000
SMCL
Manganese
Metal
50
SMCL
Uranium
Metal
30
MCL
Radium-226
Radionuclide
5
MCL
Radium-228
Radionuclide
5
MCL
Ammonium
Inorganic
250,000
OAR 333-61-030
Fluoride
Inorganic
2,000
OAR 333-61-030
Nitrate
Inorganic
10,000
MCL
Notes:
COCs = Contaminants of Concern
MCL = Maximum Contaminant Limit
MCLG = Maximum Contaminant Limit Goal
HI = Hazard Index
OAR = Oregon Administrative Rule
SMCL = Secondary Maximum Contaminant Limit
The projected time frame for extraction is an estimated 15-year period beginning with the
implementation of GETS in 2002. Under this performance standard, cleanup levels at the Site
should be obtained in approximately 2017. To achieve this time frame, Wah Chang has
completed several EPA approved modifications to GETS to enhance groundwater extraction
and treatment. These include periodic well inspections, well rehabilitation to enhance
efficiency and minimize downtime during pump failures, and keeping replacement pumps,
flow meters, and other parts at the facility to expedite repairs. The GETS has also been
augmented by EISB.
4.2.2.3 Groundwater Extraction System Monitoring
Wah Chang conducts GETS monitoring through periodic sampling and analysis of
groundwater samples from extraction wells, selected monitoring wells, and treatment system
influent and effluent to confirm that the system performance objectives are being achieved.
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Wah Chang evaluates extraction well performance in bimonthly and annual progress reports,
and fulfills requirements pursuant of Section 10 of Wah Chang's Consent Decree. Extracted
groundwater is discharged to the facility's wastewater treatment plant. Treated wastewater
discharges to the City of Albany's wetland treatment program.
4.2.2.4 Solids Area Groundwater Monitoring
Wah Chang stored lime solids in the LRSP and Schmidt Lake which leached dissolved
organic and inorganic constituents into groundwater. Following the RA, Wah Chang
implemented a groundwater monitoring program in 2000 to confirm the effectiveness of the
sludge removal and to determine if groundwater quality cleanup levels could be achieved
within the 15-year time frame specified in the Groundwater and Sediments ROD.
Wah Chang performed semiannual groundwater monitoring between March 2000 and
September 2002. Beginning in fall 2003, sampling frequency was reduced to annual sampling
for 2 years, and then after 2005, to biannual sampling. In general, the monitoring results
showed that VOCs, trace metals, and radionuclides were below ROD cleanup standards in
2002.
4.2.2.5 Farm Ponds Groundwater Monitoring
The Farm Ponds Area formerly consisted of four 2.5-acre settling ponds. Wah Chang
discharged approximately 2.5 million gallons per day of wastewater, containing 2 to 5 percent
lime solids, between 1979 and 1993 from the facility's central wastewater treatment system.
The solids were retained in the ponds and the water pumped back to the central wastewater
treatment system. Wah Chang discontinued use of the Farm Ponds in 1993 when they were
replaced by an advanced solids handling system located in the Main Plant.
Dissolved-phase chemicals present in the wastewater eventually seeped into the underlying
groundwater. EPA evaluated groundwater data collected from the Farm Ponds area
monitoring wells and determined that PCE, TCE, and VC were the primary VOCs in the
groundwater at concentrations above the cleanup standards specified in the ROD. EPA
believed the source of VOCs to be the former ponds' soil bentonite liner which Wah Chang
eventually removed and disposed of at a solid waste landfill in 1999. Wah Chang leveled the
pond dikes and regraded the area in 2001. Wah Chang conducts annual groundwater
monitoring at selected Farm Ponds Area monitoring wells.
4.2.2.6 Long-Term Main Plant Groundwater and Surface Water Monitoring
Wah Chang conducts long-term monitoring consisting of sampling and analyzing
groundwater from the Extraction Area, Fabrication Area, Solids Area, and Farm Ponds Area;
and surface water from Truax and Murder Creeks. Procedures for groundwater and surface
water monitoring are presented in the Field Sampling Plan (CH2M Hill 1997). Long-term
monitoring was implemented as part of the RI and typically occurs in the spring and fall of
each year. Monitoring must continue for a period of 5 years after cleanup levels are achieved.
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4.2.2.7 Sediment Removal and Stabilization
In 1997, Wah Chang implemented sediment RAs that included removal of contaminated
sediments in Truax Creek, and applying geotextile to the creek bank to stabilize remaining
contaminated soil. Wah Chang removed approximately 3,600 cubic yards of contaminated
sediments from the surface water areas adjacent to or flowing through the Site. In 2007 Wah
Chang completed confirmation sediment sampling and testing to ensure that the sediment
remediation and bank stabilization was effective. Analytical results did not indicate any PCB
detections in Truax Creek sediment (CH2M Hill 2007a).
4.2.2.8 Environmental Evaluations of Uninvestigated Areas
Wah Chang conducts environmental evaluations of previously uninvestigated to ensure that
remaining soil contamination is not affecting the groundwater remedy and that RAOs for
groundwater are being achieved. Environmental evaluations of previously uninvestigated
areas occur whenever Wah Chang discontinues the use of, paves, or otherwise disturbs any
pond, plant area, or building on the Site (EPA 1994). Evaluations consist of analyses of
surface soil samples for chemical or radiological contamination. If analytical results or other
factors indicate potential elevated levels of contamination, additional soil and groundwater
sampling would be required for uncharacterized portions of the Site. Environmental
evaluation results are reported every 2 years until cleanup levels are achieved.
4.2.2.9 PCB Soil Removal in Fabrication Area to Protect Groundwater
Wah Chang encountered a floating non-aqueous oil layer containing 8 percent PCBs in
December 1991 during the installation of a soil boring adjacent to the Emergency Services
Building in the Fabrication Area of the Main Plant. Groundwater in the vicinity of this boring
contained up to 22,500 ppb PCBs. The highest detected concentrations in soil consisted of
440,000 ppb at 12.5 feet bgs, located due east of the Emergency Services Building.
Wah Chang conducted remedial activities for the PCB-contaminated soil with EPA oversight
on November 16-19, 1992 (CH2M Hill 2006). Remedial activities included the removal of
approximately 200 cubic yards of contaminated soil. Soil was screened for disposal options
using field test procedures. Of the 200 cubic yards of soil excavated, approximately 170 cubic
yards were disposed of at Waste Management's Arlington Landfill, and 30 cubic yards were
placed in the former V2 pond (CH2M Hill 2006). In November 1992 the excavation was
backfilled with approximately 280 tons of crushed rock and then covered with asphalt.
4.3 OU3 - SURFACE AND SUBSURFACE SOILS
On September 27, 1995, EPA selected the Final Remedial Action for the Surface and
Subsurface Soils Operable Unit 3 (OU3), which is described in the ROD (EPA 1995). This
section discusses RAOs and remedy selection, and implementation of RAs for OU3.
4.3.1 Remedy Selection
4.3.1.1 Remedial Action Objectives
Original Site RAOs for soil in OU3 are as follows:
Reduce the exposure to radon that would occur in future buildings constructed on the
Main Plant and the Soil Amendment Area. Reduce surface gamma radiation exposure to
acceptable levels (based on current risk assumptions, this level is 20 (irem/hour above
background.)
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Ensure that areas, where surface and subsurface chemical risks are acceptable based on
industrial or agricultural use, are not used for other purposes, and that proper handling
and disposal of soil occurs when it is disturbed.
Provide easily accessible information on the locations of the material for TWCA plant
workers, future Site purchasers, or regulatory agencies, where there are areas with
subsurface contamination. This includes the PCB contamination in the Fabrication Area,
and the residual radionuclide contamination in the Fabrication Area and Extraction Area.
4.3.1.2 Remedial Actions Identified in the ROD
The EPA-selected remedy combined source removal with institutional controls to reduce risk
to human health and the environment posed by contamination in surface and subsurface soils
at the Site.
Excavation of contaminated material exceeding the gamma radiation action level of 20
micro-roentgen ((.irem/hour) above background levels. Transportation of the excavated
material to an appropriate off-site facility for disposal.
For areas of the Site where modeling indicates that radon concentrations in future
buildings could exceed 4 pCi/liter, institutional controls requiring that future buildings be
constructed using radon resistant construction methods.
Requirement that information on areas of subsurface PCB and radionuclide
contamination which do not pose a risk if they are not disturbed, be incorporated into the
Wah Chang facilities maintenance plan and be made available to future Site purchasers or
regulatory agencies.
Because the determination that action is not required for certain areas of the Site is based
on scenarios which do not allow unrestricted use, should excavation occur as part of
future development of the Main Plant or the Soil Amendment Area, excavated material
must be properly handled and disposed of in accordance with federal and state laws.
Institutional controls requiring that land use remain consistent with current industrial
zoning.
4.3.1.3 ROD Amendments or Explanation of Significant Differences
Following soil cleanup, EPA amended the soil remedy with a September 28, 2001, ESD
(EPA 2001b), which includes:
Change 1: Wah Chang will conduct Final Site closure for radionuclides pursuant to Wah
Chang's Oregon Radioactive Materials License (Broad Scope Naturally Occurring
Radioactive Material License) and the Energy Facility Siting Council (EFSC)
Administrative Rules, Chapter 345, Division 50.
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Change 2: Wah Chang will control on-site surface gamma emissions through in-place
management of contamination. Prior to Site decommissioning under Oregon Health
Department (OHD) and EFSC, Wah Chang must keep surface gamma emissions below
cleanup levels through in-place management under an EPA- and ODEQ-approved
management plan, and additional excavation of contamination as part of on-going
excavation occurring during on-site construction.
Change 3: If the Site is not decommissioned under OHD and EFSC to EPA's cleanup
requirements, radiation management shall be a condition of property transfer to ensure
that these controls remain protective. Any partial or complete property transfer by Wah
Chang shall be conditioned on implementation and maintenance of an appropriate EPA-
and ODEQ-approved radiation management program.
Change 4: Excavation and either engineered berms or off-site disposal are acceptable
remedies for the Soil Amendment Area if institutional controls cannot be implemented.
4.3.2 Remedy Implementation
The selected remedy was implemented through the following RAs.
4.3.2.1 Schmidt Lake
EPA requested that Wah Chang conduct an electromagnetic survey of the Schmidt Lake area
to identify possible buried drums. The survey discovered several corroded metal drums
containing sands with elevated amounts of thorium and uranium, and an underground storage
tank containing liquid petroleum product.
Wah Chang conducted the Schmidt Lake Excavation Project in December 1992 to remove
2,016 cubic yards of materials containing zircon sands with elevated levels of thorium and
uranium from Schmidt Lake. Wah Chang transported the materials to the US Ecology low-
level radioactive waste site in Washington for disposal.
Wah Chang excavated between 12 and 15 cubic yards of soil from Schmidt Lake in August
1998. Wah Chang excavated all areas exceeding the Site action level of 20 (irem/hour above
background levels and transported the excavated material off-site for disposal at a permitted
low-level radioactive waste facility. The area was left as it was pending potential re-use of the
area. During the Site Inspection EPA observed that the area has returned to a functioning
wetland habitat adjacent to the Willamette River.
4.3.2.2 Sand Unloading Area
The RI/FS identified an area where surface gamma radiation levels exceeded the cleanup
standard of 20 (j,rem/hour above background. Excavation of the area was conducted in 1997,
but was stopped when the northwestern edge of the material appeared to extend beneath a
concrete slab in front of the mobile maintenance shop, and under the shop itself, and when
the northernmost end of excavation would have interfered with on-site traffic with no
evidence that the limit of contamination had been reached. Wah Chang encountered gamma-
emitting material within 2 feet of the surface in the excavated areas. Wah Chang completed a
confirmation surface gamma survey that showed levels were below the cleanup standard of
20 (j,rem/hour above background. The amount Wah Chang excavated was 1,890 cubic yards,
twice the ROD estimate. Wah Chang disposed the material at a permitted low-level
radioactive waste facility. Most of the Sand Unloading Area is now overlain by Wah Chang's
Co-Generation (CoGen) Plant constructed in 2001, a natural gas-powered electricity-
generating plant. The plant is built on a 14-inch-thick concrete slab, which acts as an effective
gamma-blocking barrier.
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4.3.2.3 Front Parking Lot Area
Wah Chang removed low-level, radioactive rutile sand from the Front Parking Lot Area.
Samples of the sand indicated that radium-226 levels could cause radon concentrations in
future buildings to exceed the action level of 4 pCi/L thus requiring future buildings to be
constructed with radon-resistant construction methods.
4.3.2.4 Soil Amendment Area
Wah Chang obtained ODEQ solid waste permits in 1975 and 1976 for one-time applications
of solids from the primary wastewater treatment plant. These were experimental soil
amendments on the 40-acre Soil Amendment Area. The solids contained low levels of metals,
radionuclides, and organic compounds. Radium-226 and radium-228 concentrations in
surface soil averaged approximately 2.5 and 1.8 pCi/g, respectively. The RI/FS subsequently
indicated that the radionuclide contamination in the Soil Amendment Area could result in an
unacceptable risk from radon inhalation in any future buildings constructed on this area, and
that organic compounds are above levels that would allow unrestricted use of the property.
Between March 1989 and 1990, the Soil Amendment Area was transferred to the City of
Millersburg through a deed agreement between the Teledyne Wah Chang Company and the
City. The City acquired the 40-acre Soil Amendment Area, and Teledyne Wah Chang
acquired property contiguous to its Farm Ponds Area. Presently, institutional controls for the
Soil Amendment Area Operable Unit are enforced under a Consent Decree between the USA,
State of Oregon, and the City ofMillersburg (USA and Oregon 2006).
4.4 SITEWIDE ACTIONS
The following section summarizes the institutional controls and enforcement controls on the
Site that serve to reduce the risk for exposure to Site contaminants and minimize additional
releases.
4.4.1 Institutional Controls
The following institutional controls (ICs) are required at the Wah Chang Site:
4.4.1.1 Government Controls
The City of Millersburg zoning restrictions to maintain industrial land use at the Site and
adjacent properties (USA and State of Oregon 2006).
The City of Millersburg Land Use Development Code Section 7.500 Radon Impacted
Area Standards identifies the Soil Amendment Area as a Radon Impacted Area, prohibits
residential development in that area, and requires radon resistant construction methods
and testing.
The City of Albany has Development Code Restrictions (Public Improvements 12.410)
that require that all new development, including a single-family residence, must extend
and connect to the public water system when service is available within 150 feet. This
restriction prevents the use of groundwater for potable purposes. Note that the
development code does allow new single-family homes to use wells for water supply,
when service is not available, if approved by the City.
4.4.1.2 Proprietary Controls
The EPA required deed restrictions or restrictive covenants that require Wah Chang and
adjacent properties to restrict groundwater use as a drinking water supply. This includes
land owned by Linn County in the vicinity of Old Salem Road, and on the Burlington
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Northern Railroad right-of-way (Wah Chang 2001; Oremet-Wah Chang 1999a; Oremet-
Wah Chang 1999b; Oremet Wah Chang 1999c; Stoel Rives 1999).
Wah Chang has controls on the Main Plant and Farm Ponds Area to restrict access
through the use of fencing, signage (postings), and daily security patrols and manned
guard stations. The Farm Ponds Area has a fence only (Wah Chang 1997).
Wah Chang donated 12 acres of the Solids Area in November 2004, which excluded the
LRSP and Schmidt Lake, to the City of Albany. A fence was installed as part of an
institutional control to prevent access to the Wah Chang Site. The conservation easement
attached to the donation precludes future development of the donated parcel and requires
that it be maintained as part of the Willamette Greenway.
The EPA required a conservation easement to prevent land development, and to conserve
and protect property and natural resources in the Solids Area.
4.4.1.3 Enforcement Controls
The EPA required ICs on the Main Plant and Farm Ponds Area in the form of deed
restrictions and access restrictions, which will be implemented as long as Wah Chang
remains an active facility and/or until cleanup levels are achieved, as stipulated in the
ROD for OU2 (EPA 1994).
The EPA has provisions regarding transfer of property ownership (notice of obligations
to successor in title) as stipulated in Consent Decree (USA and State of Oregon 1997).
The EPA required ICs and deed restrictions on land and groundwater use for the Main
Plant and Farm Ponds Area to ensure that the property and groundwater use are
appropriate to cleanup levels achieved, as stipulated in the Consent Decree (USA and
State of Oregon 1997; Wah Chang 1997).
Wah Chang will provide access to the Site at all reasonable times to EPA and its
Contractors, as stipulated in the Consent Decree (USA and State of Oregon 1997).
Controls to ensure long-term protectiveness from materials contaminated with
radionuclides are to be incorporated by Wah Chang in the Broad Scope Radioactive
Materials License (#ORE-90001) for the facility. License conditions require that
operations be conducted in accordance with the State of Oregon "Standards for Protection
Against Radiation - OAR Division 333 Section 120 and Division 111" for the operating
facility. Decommissioning requirements under this license establish protectiveness
controls for any radioactive materials remaining in areas by requiring decontamination to
release the Site for unrestricted use upon permanently discontinuing manufacturing
activities.
Environmental evaluations of currently uncharacterized potential contaminant source
areas, as needed to ensure achievement of RAOs.
Long-term maintenance in areas known or suspected to contain gamma-emitting
materials (GEM) of pavement, capped material or structures, as stipulated in the ESD for
OU3 (EPA 2001b).
Long-term on-site and off-site groundwater, surface water, and sediment monitoring
which shall include, at a minimum, monitoring on-site wells which exceed MCLs and
non-zero MCLGs, cancer risk levels of 10"6, and non-cancer risk HI greater than 1 for
residential exposure (EPA 1994).
Areas of the Site where modeling indicates that radon concentrations in buildings exceed
4 pCi/L require that buildings be constructed using radon-resistant construction methods,
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as stipulated in the ESD for OU3 (EPA 2001b). Wah Chang has developed a Plant
Standard regarding radon control actions for future building sites located on the Plant Site
(Wah Chang 1997).
ICs for the Soil Amendment Area have been completed and are enforceable under the
Consent Decree (USA and State of Oregon 2006). These ICs require that the City of
Millersburg ensure that no buildings are erected in this area without testing indoor air for
Radon and if sampling results indicate Radon at levels are above EPAs regulatory criteria
then proper radon mitigation systems or remediation of the soil will be necessary.
4.4.1.4 Informational Devices
Wah Chang has provided information to occupational workers regarding risks from
contamination.
Wah Chang has incorporated information on PCBs and radionuclide contamination,
which do not pose a risk if they are not disturbed, into its maintenance plan and will make
this information available to future Site owners or regulatory agencies.
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5 PROGRESS SINCE THE LAST FIVE-YEAR REVIEW
This section cites the progress made since the last (third) FYR for the Wah Chang NPL Site,
signed in January 2008. This section includes protectiveness statements for the three OUs
(OU1 through OU3) cited in the 2008 FYR, and discusses the status of recommendations and
follow-up actions cited in the 2008 FYR.
5.1 OU1 - SLUDGE PONDS
Protectiveness Statement from the Last Review
The EPA determined that the remedy for OU1 is protective of human health and the
environment, and exposure pathways that could result in unacceptable risks are being
controlled.
Status of Recommendations and Follow-up Actions Since the Last Review
No recommendations were made in the 2008 FYR.
Status of Any Other Prior Issues
The EPA did not identify other issues in the 2008 FYR.
5.2 OU2-GROUNDWATER AND SEDIMENTS
Protectiveness Statement from the Last Review
In the Third Five Year Review, the EPA determined that progress to meet the groundwater
RAOs was being made through GETS and institutional controls (ICs) were in place to restrict
on-site and off-site beneficial use of groundwater. However, a protectiveness determination
for the remedy at OU2 could not be made until further information was obtained.
At the time of the 2008 FYR, EPA anticipated that these actions would be completed in the
end of fiscal year 2010 upon which a determination of protectiveness of OU2 could be made
through an addendum to the 2008 FYR. However Wah Chang generated the necessary data
that would have demonstrated progress with the remedy after 2010. In 2012, after review of
these data, EPA signed an Addendum to the 2008 FYR (EPA 2012a) that continued to defer
protectiveness for the Groundwater and Sediments OU2.
Status of Recommendations and Follow-Up Actions Since the Last Review
Table 5-1 provides a summary of issues and recommendations identified in the 2008 FYR
Report (EPA 2008). The table includes updates on actions taken and outcomes. A description
of each action taken and outcome, if any, are provided below the table.
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Table 5-1. Third Five-Year Review Issues, Recommendations and
Follow-Up Actions for OU2
Third Five-Year Review Issue
Follow-Up Action/
Recommendation
Action Taken and Outcome
GROUNDWATER
Extraction Area
GETS will not likely reduce COCs
concentrations in the FMA to
below ROD cleanup levels within
the 15-year time frame. COCs
include fluoride, manganese, and
radium, which are likely mobilized
by acidic conditions. Acidic
conditions are not effectively
addressed by GETS.
Evaluate the use of groundwater
flushing as a new remedial
action. Groundwater flushing
would use a weak basic solution
(lime) to raise groundwater pH
and decrease the mobility of
inorganic constituents.
Evaluation would include bench
scale testing and a pilot test
under an approved Work Plan.
Wah Chang has submitted a
weak base groundwater flushing
treatability study for EPA
review and approval.
GETS will not likely reduce VOCs
concentrations in the SEA and
Fabrication Area to below ROD
cleanup levels within the 15-year
time frame
Evaluate the use of enhanced
bioremediation as a new remedial
action in the SEA. Evaluation
would include a pilot test under
an approved Work Plan.
Wah Chang implemented an
EISB pilot in the SEA that was
effective at reducing
concentrations of VOCs to
below ROD cleanup levels.
The operation of GETS in the
SEA has been suspended due to
the implementation of
bioaugmentation in this area.
Monitoring for rebound will
continue for a 5-year evaluation
period.
A larger scale EISB effort was
implemented in the Fabrication
Area following EPA signing a
second ESD for the
groundwater remedy.
Fabrication Area
Apparent limited hydraulic control
Enhance GETS by installing new
Elevated VOCs discovered in
of the hot-spot area in the vicinity
extraction well FW-8 in the
groundwater and presence of
ofFW-3.
ASA.
DNAPT during drilling of well
Extraction well FW-6 is not
Optimize GETS by increasing
FW-8 made groundwater
functioning as intended.
groundwater pumping rates at
extraction not feasible for
Increasing and/or persistent
FW-3 due to change in VOC
remediation
concentrations of VOCs exist in
treatment from GAC to cooling
FW-3 has been shut down since
northern perimeter wells.
towers.
July 2009 as part of the EISB at
Continue semiannual
the ASA.
groundwater sampling and
Semiannual groundwater
analysis.
sampling continues.
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Linn County, Oregon
U.S. Environmental Protection Agency
Table 5-1. Third Five-Year Review Issues, Recommendations and
Follow-Up Actions for OU2 (continued)
Third Five-Year Review Issue
Follow-Up Action/
Recommendation
Action Taken and Outcome
Discovery of NAPL and/or high
concentration of VOCs in
groundwater during drilling of
proposed extraction well FW-8.
Contamination may stem from a
release from an unidentified source
and may affect the groundwater
remedy.
Determine the nature and extent
of VOCs in soil and groundwater
using reconnaissance borings.
Assess source of contamination
and release mechanism.
Prepare a feasibility study
evaluating appropriate remedial
options. Expedite a decision on
implementing a remedial action
if determined that a release has
occurred. Revise installation
location for FW-8.
4. Should additional response
action be needed regarding this
issue, a decision document will
be completed before end of fiscal
year 2009.
Following EPA's issuance of an
ESD in 2008, Wah Chang
implemented EISB in the ASA.
Initial results indicate that
reductive dechlorination is
occurring and concentrations of
VOCs are decreasing in the
dissolved phase groundwater
plume.
Wah Chang must continue
monitoring groundwater
concentrations in ASA wells to
evaluate progress of the EISB
remedy.
Wah Chang must evaluate
source removal options.
Apparent limited hydraulic control Optimize GETS by conducting the
of the hot-spot area in the vicinity following actions:
of FW-2 and FW-5. . increase pumping rates at FW-2
with a new electric submersible
pump.
Change VOC treatment from
GAC to cooling towers.
3. Conduct maintenance and
development on extraction well
screens.
System improvements and
modifications have allowed for
higher recovery rates at wells
FW-1, FW-2, and FW-5.
GETS may be limited in its ability
to achieve RAOs and ROD cleanup
levels in the projected 15-year time
frame as indicated by persistent
concentrations of DCE and TCE
above ROD cleanup levels in
groundwater.
Continued groundwater
monitoring on a semiannual
basis.
Semiannual groundwater
monitoring has occurred since
the 2008 FYR.
EISB enhancements are
expected to assist the GETS
system in achieving RAOs
Conditions for natural attenuation
may not be conducive for the full
dechlorination of TCE and DCE,
as observed by increasing
concentration of VC and cis 1,2-
DCE in groundwater from
perimeter and non-hot-spot wells,
and in surface water. The data set
used to evaluate MNA is limited.
Continue groundwater
monitoring semiannually. Sample
and analyze for applicable and
relevant water quality indicators
to evaluate MNA.
Wah Chang encountered
additional source materials in
the ASA that eliminate the
applicability of MNA in the
Fabrication Area.
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U.S. Environmental Protection Agency
Table 5-1. Third Five-Year Review Issues, Recommendations and
Follow-Up Actions for OU2 (continued)
Third Five-Year Review Issue
Follow-Up Action/
Recommendation
Action Taken and Outcome
Chemical-specific applicable or
relevant and appropriate
requirements (ARARs) for
Oregon's Ambient Water Quality
Criteria (AWQCs) for protection of
human health water and fish
ingestion have been updated from
Oregon Administrative Rules
(OAR) 340-41-445 to 340-041-
0033 (adopted by the
Environmental Quality
Commission on May 20, 2004 to
become effective February 15,
2005) (Section 10.2). Updated
AWQCs have not been recognized
by EPA; however, appear to be
consistent with 2006 CWA
AWQCs for human health,
consumption of water, and
organisms.
Compare criteria between OAR
340-41-445 and 340-041-0033.
Use criteria which are most
stringent to evaluate COCs in
groundwater and surface water.
EPA approved Oregon's
proposed water quality
standards for toxic pollutants on
October 17,2011. EPA is
comparing surface to the new
water quality standards.
Wah Chang is further investigating
the CCA SWMU in order to
further define the nature and extent
of TCA contamination in soils and
groundwater.
Work with ODEQ Resource
corrective action program to
ensure that SWMU closures are
consistent with the groundwater
remedy.
Since the 2008 FYR, Wah
Chang implemented EI SB in the
CCA. Further evaluation is
necessary to determine if the
remedy will prove to be
effective.
Wah Chang must continue
monitoring groundwater
concentrations in CCA wells so
EPA can evaluate progress of
the EISB remedy.
Ensure that contaminated
groundwater does not pose a risk to
building occupants through vapor
intrusion.
Continue to evaluate
groundwater VOC concentrations
in areas where potential
exposures could occur. Should
groundwater VOC concentrations
increase in these areas, vapor
intrusion pathway will be
assessed. Advise building
occupants of the results. Take
necessary actions to address
unacceptable exposure impacts.
VOC concentrations in
groundwater for the indoor air
evaluation wells (PW-12, PW-
42A, PW-71A, and PW-86A)
have been decreasing. No
additional action has been
necessary to address vapor
intrusion to indoor air. If
concentrations of VOC in these
wells increase, indoor air
sampling and evaluation will
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U.S. Environmental Protection Agency
Table 5-1. Third Five-Year Review Issues, Recommendations and
Follow-Up Actions for OU2 (continued)
Third Five-Year Review Issue
Follow-Up Action/
Recommendation
Action Taken and Outcome
Solids Area
Natural attenuation processes may
be limited in their ability to
achieve RAOs and ROD cleanup
levels as indicated by persistent
concentrations of manganese and
fluoride above the ROD cleanup
levels in groundwater from noted
monitoring.
Continued groundwater
monitoring on a semiannual
basis.
Wah Chang conducts
semiannual groundwater
monitoring that has occurred
since the 2008 FYR. Results
have been decreasing as seen
from the results of the latest
sampling effort.
Farm Ponds Area
Natural attenuation processes may
be limited in their ability to
achieve RAOs and ROD cleanup
levels as indicated by persistent
concentrations of PCE, TCE and
VC above the ROD cleanup levels
in groundwater from noted
monitoring.
Continued groundwater
monitoring on an annual basis
through 2010.
EPA will require that Wah Chang
analyze groundwater for chloride
and specific conductance from
identified wells (WS, PW-
43S/43A, PW-44S/44A) in future
sampling events. EPA believes
these results may help better
understand advective movement
of groundwater and the role of
natural attenuation for VOCs.
Wah Chang conducts annual
groundwater monitoring that
has occurred since the 2008
FYR.
Chloride and specific
conductance have been included
in groundwater analysis.
Concentrations of VOCs in
groundwater have been below
ROD performance standards
since September 2009. However
no explanation has been
provided and EPA is concerned
that the GW plume may have
migrated.
In 2012, Wah Chang removed
the contaminated berm that may
have been a source to GW. EPA
will evaluate the results of
confirmation sampling when
they are available.
SURFACE WATER
Surface water in Truax Creek has
exceeded ROD cleanup levels for
TCE and VC.
Conduct supplemental surface
water sampling at Truax Creek
and groundwater sampling from
applicable western perimeter
wells in March of 2008. Evaluate
risks of exposure to human health
and the environment via the
surface water pathway.
Surface water sampling in
Truax Creek has not detected
TCE or VC above ROD cleanup
levels since 2008.
Potential threat to human health
and the environment from
consumption of fish or organisms
in Second Lake.
Evaluate if exposure pathway is
complete by end of calendar year
2008.
A public health assessment
(Oregon Department of Human
Services 2009) indicated no
apparent public health hazard
from surface water exposure
and indeterminate public health
hazard from consumption of
fish. Also, tests for GW pH
have not indicated that acidic
conditions have migrated from
the FMA to Second Lake.
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Table 5-1. Third Five-Year Review Issues, Recommendations and
Follow-Up Actions for OU2 (continued)
Third Five-Year Review Issue
Follow-Up Action/
Recommendation
Action Taken and Outcome
SEDIMENT
Determine if the remedial action
for sediment is functioning as
intended.
Conduct sediment sampling and
analysis in a manner consistent
with approved work plan. Results
of sampling demonstrate that the
sediment remedy is protective.
Wah Chang is planning to
sample Truax Creek sediment
and EPA is currently reviewing
their work plan.
Historic impacts to soil from PCBs
in the vicinity of the Emergency
Services Building may affect the
protectiveness to the groundwater
remedy.
Work with Wah Chang to further
assess potential PCB impacts to
groundwater. Sample and
analyze groundwater from
monitoring wells PW-30A and
PW-46A for Total PCBs by the
applicable EPA method. Should
PCBs be detected in groundwater
from these wells, Wah Chang
may have to take further remedial
actions or conduct modifications
to GETS to meet RAOs and
ensure the protectiveness of the
groundwater remedy.
Groundwater samples collected
in June 2009 from wells PW-
30A still exceeded ROD
cleanup levels whereas PW-
46A did not exceed.
Groundwater monitoring for
total PCBs will continue.
5.3 OU3- SURFACE AND SUBSURFACE SOIL
Protectiveness Statement from the Last Review
The remedy for OU3 is protective of human health and the environment, and exposure
pathways that could result in unacceptable risks are being controlled.
Status of Recommendations and Follow-Up Actions Since the Last Review
Table 5-2 provides a summary of issues and recommendations identified in the 2008 FYR
Report (EPA 2008). The table includes updates on actions taken and outcomes. A description
of each action taken and outcome, if any, are provided below the table.
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U.S. Environmental Protection Agency
Table 5-2. Third Five-Year Review Issues, Recommendations and
Follow-Up Actions for OU3
Third Five-Year Review Issue
Follow-Up Action/
Recommendation
Action Taken and Outcome
The SOW and Consent Decree
do not incorporate
requirements of the 2001 Soil
ESD regarding overall cleanup
during decommissioning and
other factors.
Prior to plant decommissioning,
amend the SOW to incorporate
applicable requirements of the Soil
ESD for plant decommissioning by
calendar year 2009.
The SOW has not been updated.
Construction of the CoGen
Building may not comply with
institutional controls that
require that future buildings be
constructed using radon-
resistant construction methods.
It is uncertain however,
whether the CoGen building is
directly on the soil hotspot.
Radon testing will be conducted in
the CoGen Building by end of
calendar year 2008. All other
buildings constructed on areas of the
Main Plant where residual
radiological contamination would
lead to an increased risk of radon
exposure will require testing. Radon
testing will be conducted to evaluate
risk to human health and if
mitigation is necessary.
Wah Chang conducted radon
sampling in 2008 of indoor air
in two buildings (CoGen and
Mobile Shop). The highest
concentration of radon detected
during the sampling was 0.5
pCi/L, well below the 4.0 pCi/L
OU3 ROD cleanup level.
Wah Chang must retest for
radon in 2013 and depending on
the results, EPA may require
further monitoring or actions.
SITEWIDE
Table 5-3 provides a summary of issues and recommendations identified in the 2008 FYR
Report (EPA 2008).
Table 5-3. Third Five-Year Review Sitewide Issues, Recommendations and
Follow-Up Actions
Third Five-Year Follow-Up Action/
Review Issue Recommendation Action Taken and Outcome
Verify that all
institutional
controls (ICs)
are in place
Complete Title Search for
all parcels for entire Site
by end of calendar year
2008.
Wah Chang completed a title study in 2012 and the results
are presented in this Fourth FYR Report. EPA is requiring
Wah Chang to provide some additional information
missing from the title search on deed restrictions and
documentation on informational devices. Information
needed by EPA include the following 1) title search
information on properties purchased by Wah Chang in
2008 on the east side of Old Salem Road where
groundwater contamination is present, 2) information
showing that restrictive covenants prohibiting residential
and agricultural use are in place for the entire facility not
just the portion of Parcel 1 (Solids Area), 3) restrictive
covenants that prohibit construction, installation,
maintenance or use of any wells on the Soil Amendment
Area for the purposes of extracting water for human
drinking purposes or for the irrigation of food or feed
crops, 4) plant standards for radon control actions for
future buildings located on the Main Plant, and 5)
informational devices warning workers of occupational
risks from residual contamination on the Main Plant.
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6 FIVE-YEAR REVIEW PROCESS
6.1 ADMINISTRATIVE COMPONENTS
This fourth FYR followed EPA's Comprehensive Five-Year Guidance (EPA 2001a). EPA
Region 10 Remedial Project Manager, Mr. Ravi Sanga led the FYR effort. Mr. Sanga was
assisted by Ms. Debra Sherbina, the EPA Community Involvement Coordinator (CIC); Ms.
Joan Shirley, EPA Assistant Regional Counsel; Mr. Timothy Brincefield, EPA Policy
Advisor; Mr. Curt Black, EPA Risk Evaluation Unit Hydrogeologist; Mr. Geoff Brown,
ODEQ Project Manager; and Mr. Mike Marshall and Ms Lisa Gilbert, Parametrix Project
Manager/Hydrogeologists. The FYR was conducted from January 18, 2012, to December 30,
2012.
6.2 COMMUNITY INVOLVEMENT
A newspaper notice was placed in the Albany Herald on June 21, 2012, to announce the start
of the FYR (Appendix A). No public comments were received. Another newspaper notice
will be placed in the Albany Herald upon completion and availability of this review.
6.3 APPROPRIATE, RELEVANT, AND APPLICABLE REQUIREMENTS REVIEW
The remedies selected in the OU1, OU2, and OU3 RODs are intended to be protective of
human health and the environment and to comply with ARARs. The ARARs have been
reviewed to identify any new or updated state or federal regulatory standards that might affect
the protectiveness of the remedy if the RODs were written today.
6.3.1 OU1
ARARs for off-site disposal include Oregon Solid Waste Disposal Regulations. The Finley
Buttes landfill has state permits under these regulations. EPA determined that no additional
ARARs are considered under this OU.
6.3.2 OU2
EPA identified the following ARARs during the ROD. This section presents the ARARs and
provides any updates or changes to the standard that may impact protectiveness.
6.3.2.1 Chemical-Specific ARARs
Safe Water Drinking Act (SWDA) MCLs and non-zero MCLGs, 40 CFR Part 141
The SWDA has not been updated since the 2008 FYR.
Standards for degree of cleanup required, ORS 465.315; Cleanup rules, standards, OAR 340-
122-040
ODEQ adopted EPA's slope factors for TCE and PCE in 2012, resulting in RBCs
that are more consistent with EPA's Regional Screening Levels.
Oregon Water Quality Criteria for the Willamette Basin, OAR 340-41-445
OAR 340-041-0033 Ambient water quality criteria (AWQC) Effective October 17,
2011, ODEQ made changes to the AWQC and the concentrations of pollutants listed
in Table 40 were derived to protect humans from potential adverse health impacts
associated with long-term exposure to toxic substances associated with consumption
of fish, shellfish, and water. The "organism only" criteria are established to protect
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fish and shellfish consumption and apply to waters of the state designated for
fishing. The "water + organism" criteria are established to protect the consumption
of drinking water, fish, and shellfish, and apply where both fishing and domestic
water supply (public and private) are designated uses.
Human health criteria for arsenic (water+organism) were revised to 2.1 ug/L (ODEQ
2011; EPA 2011).
The Environmental Quality Commission (EQC) adopted revisions to Oregon's water
quality criteria for manganese by withdrawing the "water and fish ingestion" and
"fish consumption only" criteria as they apply to freshwaters (ODEQ 2010). EPA
approved these revisions on June 9, 2011.
Oregon Groundwater Quality Statute, ORS 468B.150 to 185
Risk-based numerical values, under the Oregon Environmental Cleanup Rules, have been
revised on several occasions, since the ROD for OU2 was issued, to incorporate changes in
toxicity studies.
6.3.2.2 Location-Specific ARARs
Executive Order 11988, statement of procedures on floodplain management and wetlands
protection Appendix A to 40 CFR Part 6
Oregon Statewide Planning Goals
Goal 5 - Open spaces, scenic and historic areas and natural resources
Goal 6 - Air, water, and land resource quality
Goal 7 - Areas subject to natural disaster and hazards
Goal 15 - Willamette River greenway
These goals have not been updated since the 2008 FYR.
Oregon removal-fill law, ORS 196.800-196.990
Modifications to this rule do not appear to significantly impact protectiveness
CWA Section 404(b)(1) Guidelines for Specification of Disposal Sites for Dredged or Fill
Material, 40 CFR Part 230; Section 404(c) Procedures 40 CFR Part 231
Fish and Wildlife Coordination Act (16 USC Part 661 et seq.) 40 CFR Part 6.302 and 50 CFR
Part 83
These have not been updated since the 2008 FYR.
6.3.2.3 Action-Specific ARARs
Toxic Substance Control Act (TSCA) PCB Disposal regulations, 40 CFR 761.60; Oregon
Hazardous Waste Management Rules for PCBs, OAR 340-110
These have not been updated since the 2008 FYR.
RCRA Land Disposal Treatment Standards, 40 CFR Part 268, Subpart D; RCRA
Transportation Regulations 40 CFR Part 263
40 CFR Part 263 was updated in 2010 since the 2008 FYR. Should future soil
removal actions occur at the Site, the new RCRA standards will be applicable.
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Oregon Waste Management Rules, OAR 340-100; Oregon Standards Applicable to
Generators of Hazardous Waste, Identification and Listing of Hazardous Wastes, OAR 340-
10, OAR 340-102;
These have not been updated since the 2008 FYR.
Oregon Standards for Owners and Operators of Hazardous Waste Treatment and Storage and
Disposal Facilities; OAR 340-104
These have not been updated since the 2008 FYR.
CWA NPDES industrial and/or Storm water Discharge Permits regulations, 40 CFR 122;
Ambient Water Quality Criteria, 40 CFR Part 131; Oregon Regulations Pertaining to NPDES
Permits, OAR 340-45
These have not been updated since the 2008 FYR.
CAA National Primary and Secondary Ambient Air Quality Standards, 40 CFR Part 50; CAA
National Emissions Standards for Hazardous Air Pollutants, 40 CFR Part 60; CAA New
Source Performance Standards, 40 CFR Part 61; RCRA Air Emission Standards for Process
Vents, 40 CFR Part 264, Subpart AA
These have not been updated since the 2008 FYR.
OSHA, 29 USC 651; Oregon OSHA OAR Chapter 437
These have not been updated since the 2008 FYR.
Amendment to NCP, Planning and Implementing Off-site Response Actions, 40 CFR 300-
400
These have not been updated since the 2008 FYR.
RCRA Closure and Post-Closure Regulations, 40 CFR Part 264
This has not been updated since the 2008 FYR.
6.3.3 OU3
The following regulations are applicable for Site soils: ORS 465; OAR 340-122, Sections 10
through 110. They require cleanup to background or the lowest feasible level.
These have not been updated since the 2008 FYR.
The following rules govern disposal of radioactive material in Oregon and are applicable to
the Site: Energy Conservation, ORS 469.375, 469.525, 469.556, 469.559; Radioactive Waste
Materials, OAR 345-050, Section 006 through 130.
These have not been updated since the 2008 FYR.
6.4 INTERVIEWS
EPA conducted interviews with a few key individuals to gain a greater understanding of the
Site background, state and local considerations for the project, and remediation activities.
Interviews were conducted with representatives of Wah Chang, ODEQ, the Oregon Health
Department, the Mayor of the City of Millersburg, and an expert in bioremediation
technology. Summaries of those interviews are provided in Appendix B.
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6.5 INSTITUTIONAL CONTROLS
EPA reviewed the status of institutional controls at the Site, including proprietary controls,
government controls, and informational devices.
6.5.1 Proprietary Controls
Wah Chang provided a title search in 2012 (Wah Chang 2012c) to document the current
status of proprietary controls at the Site. Based on a review of the title search, EPA found the
following deed restrictions to be in place:
6.5.1.1 Teledyne Wah Chang
Main Plant and Solids Area:
Restrictive Covenants (April 18, 1991): "There shall be no construction, installation,
maintenance or use of any wells on the above-described site for the purposes of
extracting water for human drinking purposes or for the irrigation of food or feed crops."
Solids Area (partial)
Restrictive Covenant (April 18, 1991): "Residential and agricultural uses are prohibited"
Burlington Northern Santa Fe Railway Company (November 25,1998), Union Pacific
Railroad Company (March 29, 2001), Linn County (April 10, 2001):
Equitable Servitude and Easement Agreements: "Grantor agrees it will not install,
construct, or use any groundwater supply wells (which does not include groundwater
monitoring wells) on the Property so long as this Equitable Servitude and Easement is in
effect."
6.5.1.2 Simpson Timber Company
Equitable Servitude and Easement Agreement (April 9, 1999): "Grantor agrees it will not
install, construct, or use any groundwater supply wells (which does not include
groundwater monitoring wells) on the Property so long as this Equitable Servitude and
Easement is in effect."
6.5.1.3 City of Millersburg:
Environmental Protection Easement and Equitable Servitude Agreement (re-recorded
December 14, 2007).
1) Use Restriction. No portion of the property shall be used for residential purposes,
2) Building Construction, including initial construction, testing after building is
constructed, radon monitoring, maintenance, notice to occupants.
3) Soil Management and Excavation Requirements,
4) Record Keeping and Reporting, and
5) Environmental Protection Easement.
Deed Restriction (May 8, 1990): "The rights of the public in and to that portion of the
herein described property lying within the limits of public roads, streets, or highways, and
portion of the property is designated as an EPA hazardous waste site."
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Restrictive Covenant (April 18, 1991): "There shall be no construction, installation,
maintenance or use of any wells for the purposes of extracting water for human drinking
purposes or for the irrigation of food or feed crops
Observations during the Site Inspection confirmed the Site is adequately fenced including
security cameras. The Farm Ponds Area was also observed to be fenced.
6.5.2 Government Controls
Interviews with ODEQ and Oregon Department of Health (Appendix B) indicated that the
ICs are functioning as intended and there have been no changes in land use or zoning.
EPA verified with the City of Millersburg that Wah Chang's Main Plant and surrounding
properties are still zoned for General Industrial use and the former residential area between I-
5 and Old Salem Road is zoned for Limited Industrial Commercial use. Based on an
interview with the mayor of Millersburg (Appendix B), the EPA does not anticipate rezoning
of surrounding properties which would require approval by the Millersburg City Council and
Planning Commission.
EPA verified with the City of Millersburg that the City of Millersburg Land Development
Code Section 7.500 is in place that identifies the Soil Amendment Area as a Radon Impacted
Area and provides restrictions on land use and requires radon resistant construction methods
and testing.
EPA verified that the City of Albany Development Code restrictions (Public Improvements
12.410) that require that all new developments, including a single-family residence, must
extend and connect to the public water system when service is available within 150 feet are
still in place.
6.5.3 Informational Devices
Wah Chang provided EPA with Plant Standards regarding radon control actions for future
building sites located on the Plant Site (Wah Chang 1997).
6.6 SITE INSPECTION/TECHNOLOGY REVIEW
EPA inspected the Wah Chang Site on June 6 through June 8, 2012. An environmental
scientist (hydrogeologist) from Region 10, Office of Environmental Assessment conducted
the inspection. Twenty-one inspection targets were identified prior to the Site visit for review
and assessment. Inspection activities focused on the active ground-water remedy for the Site.
Each source area and plume was evaluated as to adequacy of perimeter control. Each plume
was evaluated for trend data and potential to reach the 15 year time frame for cleanup
established in the ROD. Areas of past cleanup activities were evaluated as to the on-going
protectiveness of the remedy and adequacy of ground-water monitoring. 65 wells,
representing more than half of the wells in the monitoring well system, were visited and
evaluated. Noel Mak, NPL Program Coordinator was interviewed during the inspection. Mike
Cochran, an employee in charge of extraction well maintenance and system operation was
questioned about system maintenance. Randy Coots, a long-time security officer for the
facility was questioned as an assessment of Site security and access control. Geoff Brown,
Oregon Department of Environmental Quality participated in part of the inspection. Lisa
Gilbert, an employee of Parametrix participated as a contractor to the EPA assisting with the
Five Year Review. The inspection report is included as Appendix C.
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6.6.1 Management System Review
As part of the FYR for the Wah Chang Site, a Management System Review (MSR) has been
performed. This review identifies any issues that might affect the protectiveness of the
remedy. These issues are covered extensively in Section 7 of this document.
6.6.2 Technical Compliance Evaluation
The technical compliance evaluation is included to evaluate whether each element of the
remedy is being maintained and operated in accordance with its intended function.
Evaluation of Intended Function:
The exposure pathways and land use assumptions that were stated in the ROD
are still valid.
No zoning or land use changes have been made since the ROD.
Major removal actions of solid source materials have greatly reduced observed
residual ground-water contamination in areas such as the LRSP and Farm Ponds
Areas.
Site access is controlled by security constantly. The entire Site is fenced and
security cameras cover much of facility.
Areas of residual ground-water contamination are undergoing monitoring. The
SEA and CCA EISB remedies appear technically appropriate to deal with the
dissolved chlorinated solvent concentrations present. The plume in the northern
portion of the Fabrication Area requires additional assessment. The source area in
the acid sump area will require a different technical approach to deal with
DNAPL solvent.
Feed Makeup Area remedy modifications including the addition of buffered or
acid-neutralizing solutions are expected to address low-pH and metals mobility in
this area as this remedy modification is adopted.
Specific evaluations of each remedy component are addressed in detail in Section 7.
6.6.3 Source Control
Significant cleanup actions have been completed at the Wah Chang Site. Hundreds of
thousands of yards of material have been removed from the Site to address source control.
Completed projects include the Lower River Solids Ponds, Magnesium Resource Recovery
Pile, the Farm Ponds Area and others. Areas of ongoing issues with source control include the
Feed Makeup Area with the low pH ground water and the potential for mobilization of
constituents of concern from the feed material as well as the metals mobilized by the low pH.
The Acid Sump Area has been identified as an area of high concentrations of chlorinated
solvents that indicate the presence of DNAPL. The technology (EISB with sugars and edible
emulsified oils) is not likely to adequately address a DNAPL source. Wah Chang must
develop plans for additional excavation or an alternative treatment for this area. The
associated dissolved plume that is discharging to the north from the Acid Sump Area appears
to be potentially discharging at the northern plant boundary. As of this writing, the plume has
not yet dropped to concentrations that are near the ROD cleanup levels despite the EISB that
has changed ground-water chemistry to conditions to those suitable for solvent destruction.
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6.6.4 Groundwater Remediation
Groundwater Remediation continues in several parts of the plant. These include:
The EISB projects in the South Extraction Area;
The EISB project in the Fabrication Area - Acid Sump;
The EISB project in the Fabrication Area - Crucible Cleaning Area;
Ground-Water Extraction and Treatment in the Feed Makeup Area;
Ground-Water Extraction and Treatment in the Fabrication Area protecting Truax
Creek.
Detailed reviews of each of these systems and assessment of their operations and issues
requiring remedy modification are included in Section 7.
6.7 DATA REVIEW FOR OU1
EPA issued a Certification of Completion for OU1 RA to Wah Chang on June 30, 1993 (EPA
1993). The RA for OU1 is considered complete. SCS Engineers conducts semiannual
groundwater monitoring at the Finley Buttes Landfill monocell in Boardman, Oregon. Wells
MW-4 and MW-5 are used to monitoring upgradient and downgradient groundwater
conditions, respectively. The 2010 groundwater monitoring results (SCS Engineers 2011)
confirmed that trace metal results were not detected above the method reporting limits with
the exception of antimony, arsenic, and barium in MW-4 and barium and zinc in MW-5.
Manganese was detected one time over the past 5 years in MW-5 at 0.014 mg/L. All metals
detected were below the MCL and SMCL, and VOCs were not detected in groundwater
samples
6.8 DATA REVIEW FOR OU2
EPA obtained data through 2011 from Wah Chang and conducted an independent review of
the data as part of this FYR, including preparing summary tables, potentiometric surface
maps, time-series plots, and isoconcentration maps. EPA reviewed data beginning in October
2002 to evaluate groundwater concentration trends over time and to provide overlap with the
2008 FYR report.
This section presents a summary of EPA's findings for OU2. Remedial sectors include the
Main Plant Area, including Extraction and Fabrication Areas, the Solids Area, and the Farm
Ponds Area. Information obtained during the Site Inspection is described in this section.
6.8.1 Main Plant: Groundwater Extraction and Treatment System (GETS)
The remedy for groundwater in the Main Plant Area is GETS though granular activated
carbon (GAC) in the FMA and SEA and phase separation though air stripping in the cooling
towers in the Fabrication Area.
6.8.1.1 Operation and Maintenance
Wah Chang is responsible for the operation and maintenance of the groundwater extraction
system. System operation includes recording system pumping rates, influent concentrations,
extraction well downtime, and routine and non-routine maintenance activities.
Wah Chang employs one full-time staff personnel to satisfy operation requirements in
accordance with the operation and maintenance plan. This person conducts weekly
inspections of the conditions at each extraction well, identifies potential issues, maintains
parts on hand, and repairs equipment as needed. Several other personnel assist with
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maintenance and sampling. Wah Chang has responded to unscheduled, non-routine
maintenance activities in a timely manner. Wah Chang stores groundwater extraction pumps
on-site and replaces pumps in the FMA approximately every 3 months due to the low pH
corrosion of the equipment.
During the Site Inspection, extraction wells were observed operating as expected. Treatment
systems appeared well maintained and spare parts were observed. Totalizers were functioning
and metered treatment equipment was observed treating water prior to pumping for additional
treatment. Inspection logs were observed. Site access control was observed. Maintenance
issues were noted with several of the flush-completed wells in the monitoring well system,
specifically, the sealing of flush-completed wells in areas of high traffic. Wells were observed
where, due to heavy traffic, threads on vaults or the bolts to seal the vaults were stripped,
vaults were cracked, gaskets were missing, locks were found to be inoperable due to
corrosion and the seals on wells were compromised due to wear on seals. At least one well
was observed that should be reconstructed with a new vault. Overall, a new approach to
sealing wells should be established in high traffic areas to protect the integrity of the
monitoring well program. Nearly all wells with above ground completions were found to be
labeled, locked, capped and protected with yellow-painted barrier posts. Inside the protective
casing nearly all wells were found to have marked measurement points. See Appendix C for
specific observations.
Wah Chang submitted a Work Plan (Wah Chang 2012d) to conduct a pumping test at
extraction well FW-4 and monitoring well PW-30A to assess the capability of well FW-4 to
hydraulically capture groundwater in the portion of the Site previously captured by extraction
well FW-7 where pumping was discontinued in 2009, and to evaluate possible capture zone
improvements gained by augmenting well FW-4 pumping. EPA expects to review the pump
test work plan by 2013.
6.8.1.2 Extraction Area
Extraction well and monitoring well locations for the Extraction Area are presented on
Figure 6-1. Groundwater contamination in the FMA is characterized by the presence of
metals, radionuclides, and low (acidic) pH levels. Groundwater contamination in the SEA is
characterized by the presence of chlorinated solvents. The groundwater monitoring network
in the Extraction Area is composed of 18 monitoring wells.
Feed Makeup Area
Mass Removal
Wah Chang reported that 3.92 pounds of fluoride, 149.02 pounds of ammonia, 1.32xlO"10
pounds of radium-226, and 1.32xl0"8 pounds of radium-228 were removed by GETS in the
FMA during 2009 (Wah Chang 2010c). Wah Chang reported that 6.9 pounds of fluoride,
112.43 pounds of ammonia, 8.9xl0"9 pounds of radium-226, and 1.24xl0"6 pounds of radium-
228 were removed by GETS in the FMA Area during 2010 (Wah Chang 201 le). Wah Chang
reported that 6.33 pounds of fluoride, 82.12 pounds of ammonia, 3.2xlO"10 pounds of radium-
226, and 2.56xl0"6 pounds of radium-228 were removed by GETS in the FMA Area during
2011 (Wah Chang 2012f). The mass recovery volumes reported above are derived from Wah
Chang's annual reports. EPA compared the reported mass removal to analytical data and
extraction rates obtained from Wah Chang. The results of this comparison indicated that the
values were similar and were within approximately 25% of Wah Chang reported values and
EPA calculated values. This difference in values is likely due to assumptions made during
calculations; however, the values agree in general.
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Mass Removal (pounds) in the FMA Reported by Wah Chang
2008
2009
2010
2011
Fluoride
NA
3.92
6.9
6.33
Ammonia
NA
149.02
112.43
82.12
Radium 226
NA
1.3xl0"10
8.9xl0"9
3.2xlO"10
Radium 228
NA
1.32xl0"8
1.24xl0"6
2.56xl0"6
TDS
20509
15663
13989
10295
Groundwater Monitoring
Nine monitoring wells are located in the FMA (Figure 6-1). Additional information about the
wells follows:
Five wells were installed in the area where groundwater concentrations were
above the 10-4 risk and are considered hot-spot wells: PW-28A, PW-28B, PW-
5OA, PW-51A, and PW-52A.
One well was installed in the area where groundwater concentrations were below
the 10-4 risk and is considered anon-hot-spot well: PW-27A.
Four wells were installed adjacent to Second Lake and are considered perimeter
wells: PW-21A, PW-22A, PW-23A, and PW-24A.
Table 6-1 presents a summary of arsenic, radium-228, radium-226, fluoride, ammonium,
cadmium, and nickel concentrations in groundwater beginning in October 2002. pH levels are
summarized in Table 6-2. Data for FMA extraction wells is presented in Table 6-3. During
the December 2011 groundwater monitoring event (approximately 9 years after the GETS
startup):
Two perimeter wells exceeded the ROD cleanup level of 2 mg/L for fluoride
(PW-22A at 2.4 mg/L and PW-23A at 11 mg/L).
One hot-spot well exceeded the ROD cleanup level of 0.05 mg/L for arsenic
(PW-28A at 0.09 mg/L).
No radium was detected above ROD cleanup levels during either 2001
monitoring event.
Groundwater pH ranged from 2.5 to 6.7 (Table 6-2). With the exception of
perimeter well PW-22A(6.67), all wells in the FMA did not meet the pH level
required by the ROD.
Figure 6-2 presents pH trends in FMA wells beginning in October 2002. Although in the
majority of wells, pH has slightly increased since the 2008 FYR by approximately 1 pH unit,
pH remains below the ROD cleanup-up range. The lowest pH values were observed in wells
PW-28A, PW-52A, and PW-50A.
The number of detections and concentrations of metals and radionuclides in the FMA have
decreased. However, monitoring data in the FMA currently show that concentrations of
COCs are above ROD cleanup levels and the concentrations over time have been highly
variable (Figure 6-3 through Figure 6-5).
Second Lake pH sampling EPA requested that Wah Chang perform an additional Site
characterization in 2011 (Wah Chang 2011f)to select a location for a new downgradient
monitoring well in the FMA to evaluate migration of a low pH groundwater plume extending
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from the FMA to Second Lake. The Site characterization included a groundwater sampling
transect downgradient of the FMA and oriented perpendicular to the direction of groundwater
flow.
Wah Chang measured groundwater discharge into Second Lake and indicated that the pH of
groundwater entering Second Lake ranged between 5.52 and 7.47. Based on the results of the
investigation, EPA determined that the low pH groundwater plume did not appear to
discharge into Second Lake.
South Extraction Area (SEA)
The 2008 FYR report concluded that based on water quality data, GETS was not effective in
reducing DCE and TCE concentrations and would not likely achieve ROD performance
standards within the time frame. Wah Chang completed an EISB pilot test in June 2008 in the
SEA to reduce the concentration of VOCs in the area (Wah Chang 2011b). Wah Chang
installed two new monitoring wells to support the evaluation of VOC concentrations in
groundwater. A drilling contractor completed temporary injection wells for Wah Chang to
inject amendment water, substrate, and the SiREM KB-1 Plus microbe culture. Temporary
injection points were distributed around the SEA where there were elevated VOC
concentrations. A groundwater amendment included the injection of deoxygenated water used
to alter the groundwater environment to be suitable for bacterial growth. Wah Chang added
approximately 125 ppm of food-grade 60 percent sodium lactate and Newman Zone
vegetable oil to stimulate biotic and oxygen-consuming activity. Wah Chang monitored
chemical parameters consisting of dissolved oxygen (DO), pH, and oxidation-reduction
potential (ORP) to determine if additional lactate and amendment water were required to
complete the deoxygenating process.
Nine monitoring wells are in the SEA (Figure 6-1). Additional information about the wells
follows:
Three wells were installed in the area where groundwater concentrations were
below the 10-4 risk and are considered non-hot-spot wells: PW-47A, PW-48A,
and PW-96A.
Six wells were installed adjacent to Second Lake and are considered perimeter
wells: PW-25A, PW-26A, PW-29A, PW-49A, PW-57A, and PW-97A.
Table 6-4 presents a summary of VOC concentrations in groundwater in the SEA. As a result
of EISB treatment, with the exceptions of PW-96A, VOCs in the SEA have not been detected
above their respective method reporting limit since the April 2010 monitoring event. Figure
6-6 presents concentrations of DCE and Figure 6-7 presents concentrations of TCE in
groundwater wells in the SEA. No VOCs were detected during the April and December 2011
groundwater monitoring events. EPA has determined that groundwater field parameter data
indicated current conditions were conducive to survival and function of dechlorination
microbes, which are necessary to break down VOCs. These parameters include anoxic and
negative oxidation potentials of less than -70 mV.
Based on analytical data that indicated that no VOCs were detected in the SEA above the
method reporting limits, EPA approved suspending operation of extraction wells EW-1, -2,
and -3. However, given the lack of identification of the source area of the VOC
concentrations, Wah Chang will monitor wells biannually in the SEA for VOCs for a period
of at least 5 years from the shutdown of extraction wells (operation was suspended in April
2011) to determine if rebound occurs. If rebound occurs and additional action is necessary,
Wah Chang and EPA will consider remedial action options to reduce VOCs in the SEA.
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6.8.1.3 Fabrication Area
Groundwater contamination in the Fabrication Area is characterized by the presence of
chlorinated solvents, primarily DCE, TCA, TCE, PCE, and VC. The Fabrication Area GETS
includes extraction wells FW-1 through FW-5 and FW-7. Well FW-7 was taken out of
operation in 2009. Extraction and monitoring well locations are presented on Figure 6-8. The
main objectives of GETS in the Fabrication Area are to remove VOC mass and reduce VOCs
concentrations to below ROD cleanup levels.
Wah Chang performed additional response actions in the Fabrication Area to reduce
concentrations of COCs in groundwater in two areas, the ASA and the CCA. Specific
response actions included EI SB that the EPA had not considered at the time of the ROD. The
EPA signed an ESD in June 2009 to use EISB as a new RA in the Fabrication Area.
Mass Removal
In 2008, Wah Chang extracted approximately 20 million gallons of water from the
Fabrication Area and removed 130 pounds of VOCs (Wah Chang 2009b). In 2009, Wah
Chang extracted approximately 19.5 million gallons of water and removed 94 pounds of
VOCs (Wah Chang 2010b). In 2010, Wah Chang extracted approximately 16.1 million
gallons of water and removed 101.8 pounds of VOCs (Wah Chang 201 Id). In 2011, Wah
Chang extracted approximately 13.2 million gallons of water and removed 35.1 pounds of
VOCs (Wah Chang 2012i).
Mass Removal in the Fabrication Area
2008
2009
2010
2011
Water Extracted (million gallons)
20
19.5
16.1
13.2
VOCs removed (pounds)
130
94
101.8
35.1
Acid Sump Area
In September 2009, Wah Chang completed EISB in the ASA. Approximately 12 months
following EISB, monitoring results from Wah Chang's sampling indicated groundwater field
parameter conditions conducive to dechlorination microbes, which are necessary to reduce
VOCs, had improved from the baseline conditions prior to injection (Wah Chang 201 lc). As
noted above, EPA determined that COC concentrations in some wells still remain above
ROD cleanup levels (Table 6-15). However, groundwater analytical data for VOCs indicate
that the proportions of TCA and TCE concentrations have been reduced, and in general
daughter compounds increased as a result of EISB (Figure 6-3la and Figure 6-3lb).
Reductive dechlorination of chlorinated ethenes appears to be more pronounced in TMW-5
and PW-98A. A DNAPL source is indicated by the initial concentrations of several
chlorinated solvents in the ASA. This source will require additional assessment and an
additional remediation technology to address the indicated DNAPL.
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Crucible Cleaning Area
In September 2010, Wah Chang completed EISB in the CCA, and installed two additional
monitoring wells to support performance monitoring. Wah Chang's initial groundwater
analytical results show that VOC concentrations have been reduced (Wah Chang 201 Id).
Additional performance monitoring results are anticipated from Wah Chang in 2012. The
EISB Technology applied here appears capable of addressing the dissolved chlorinated
solvents present.
Groundwater Monitoring
The groundwater monitoring network in the Fabrication Area is composed of 51 monitoring
wells and 7 extraction wells (Figure 6-8).
Hot-Spot Area Wells
Of the wells in the Fabrication area, 24 are installed in an area where groundwater
concentrations were above the 10"4 risk and are considered hot-spot wells. These include the
following monitoring wells:
PW-11, PW-12, PW-13, and PW-99A located near the ASA.
PW-01A, PW-03A, and PW-83A located near the Ammonium Sulfate Storage
Building.
PW-42, PW-85A, and PW-86A located near the Material Recycle Building.
PW-45A, PW-68A, PW-69A, PW-71A, PW-93A, PW-94A, PW-95A, PW-100A,
MW-01A, MW-02A, MW-03A, and MW-04A located near the former CCA.
PW-30A and PW-73B located near the Dump Master Building.
Table 6-5 through Table 6-11 present a summary of VOC concentrations in groundwater
from hot-spot wells in the Fabrication Area. The tables indicate that DCE, TCA, TCE, PCE
and VC exceeded their respective ROD cleanup levels in two or more hot-spot wells since the
spring 2008 groundwater monitoring event.
Figure 6-9 through Figure 6-13 display DCE, TCA, TCE, PCE and VC concentrations in
groundwater, respectively, over time for hot-spot wells that exceeded ROD cleanup levels for
one or more of these compounds in the past 5 years. In general, the figures indicate that
contaminant concentrations have decreased in a majority of hot-spot wells since the
implementation of GETS. In November 2011, TCA, DCE, and VC concentrations remained
above their respective ROD cleanup levels in 14 hot-spot wells. Most noteworthy are the
following hot-spot wells:
PW-12, PW-13, and PW-99A (ASA).
PW-42 A and PW-85A (Material Recycle).
PW-69A, PW-93A, PW-94A, PW-95A, PW-100A, MW-02A, and MW-04A
(CCA).
PW-30A and PW-73B (Dump Master).
Table 6-12 and Table 6-13 present a summary of fluoride and nitrate in hot-spot wells. No
hot-spot wells exceeded the ROD cleanup level for ammonium in the last 5 years. Table 6-12
indicates that four wells (PW-11, PW-12, PW-13, and PW-99A) exceeded ROD performance
levels for fluoride and nitrate in the last 5 years. Only two hot-spot wells (PW-13 and PW-
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99A) exceeded the ROD cleanup level for fluoride and one well (PW-13) for nitrate in
November 2011.
Non-Hot-Spot Area Wells
There are 22 wells installed in areas where groundwater concentrations were below the 10"4
risk and are considered non-hot-spot wells:
PW-10, PW-14, PW-16A, PW-19A, PW-80A, PW-81A, PW-82A, and PW-98A
located near the ASA.
PW-20A, PW-89A, and PW-92A, located near the Ammonia Sulfate Storage
Building.
PW-84A, PW-87A, and PW-88A, located near the Material Recycle Building.
PW-70A, PW-72A, and PW-101A located near the CCA.
PW-46A, PW-74B, and PW-75A and PW-91A near the Dump Master area.
PW-31A, located in the northeast corner of the Site (hydraulically upgradient).
Table 6-5 through Table 6-11 present a summary of VOC concentrations in non-hot-spot
wells. The table indicates that DCE, TCA, and TCE exceeded their respective ROD cleanup
levels in one or more non-hot-spot wells since the spring 2008 groundwater monitoring event.
Figure 6-14 through Figure 6-17 display DCE, TCA, PCE, TCE, and VC concentrations over
time for non-hot-spot wells that exceeded ROD cleanup levels for one or more of these
compounds in the past 5 years. In general, the figures indicate that contaminant
concentrations have decreased in non-hot-spot wells since the implementation of GETS. In
November 2011, TCE, DCE, and VC concentrations above their respective ROD cleanup
levels persisted in 2 non-hot-spot wells:
PW-98A (ASA)
PW-101A (CCA) (below ROD cleanup level for TCE)
Table 6-12 and Table 6-13 present a summary of fluoride and nitrate in non-hot-spot wells.
Three wells (PW-10, PW-89A, and PW-98A) exceeded the ROD cleanup level for fluoride
and one well (PW-89A) exceeded the ROD cleanup level for nitrate in the last 5 years,
although concentration of fluoride and nitrate have decreased in these wells over the past 5
years. No non-hot-spot wells exceeded the ROD cleanup level for ammonium in the last 5
years.
Northern Perimeter Wells - Murder Creek
Five wells are installed in the area adjacent to Murder Creek and are considered perimeter
wells:
PW-15AR (inactive), PW-76A, PW-77A, PW-78A, and PW-79 (ASA)
Table 6-5 through Table 6-11 present a summary of VOC concentrations in northern
perimeter wells. DCE concentrations exceeded the ROD cleanup level in three of the five
northern perimeter wells since the spring 2008 groundwater monitoring event. No other
VOCs were detected above ROD cleanup levels in northern perimeter wells.
Figure 6-18 displays DCE concentrations over time for the three northern perimeter wells that
exceeded ROD cleanup levels for DCE in the past 5 years. While DCE concentrations still
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exceed ROD cleanup levels, DCE concentrations have decreased or remained consistent in
northern perimeter wells since the implementation of GETS.
Table 6-12 and Table 6-13 present a summary of fluoride and nitrate in northern perimeter
wells. Fluoride concentrations in one well (PW-79A) exceeded the ROD cleanup level in the
last 5 years. Fluoride concentrations in well PW-79A have not exceeded the ROD cleanup
level of 2 mg/L since June 2009. No concentrations of ammonium or nitrate exceeded the
ROD cleanup level in northern perimeter wells in the last 5 years.
Isoconcentrations
EPA prepared isoconcentration maps (Figures 6-19 through 6-26) of persistent VOCs (DCE,
TCE, TCA, and VC) in the Fabrication Area to evaluate changes in spatial distribution in
COCs during the fall sampling events of 2009 and 2011. These isoconcentrations include data
from wells installed in the ASA (TMW-1, TMW-3, TMW-4, and TMW-5, shown in Table 6-
15) as a result of the discovery of DNAPL in this area. Three areas of elevated concentrations
of VOCs are present in the Fabrication Area. A comparison of groundwater DCE
concentrations above the ROD cleanup level in 2009 to those in 2011 (Figure 6-27) indicates
that the areal extent of DCE in groundwater has not been significantly reduced over this 2-
year period. However, TCE (Figure 6-28) does appear to have reduced in areal extent. VC
(Figure 6-29) appears only to have slightly been reduced in one area as a result of the
concentration of VC in PW-42A). TCA (Figure 6-30) appears to have been significantly
reduced in areal extent.
Surface Water Monitoring
Wah Chang collects surface water samples in Murder and Truax Creeks to monitor discharge
of contaminated groundwater from the Fabrication Area to the creeks. Samples are collected
upstream and downstream of the facility (Figure 6-8). Table 6-14 displays a summary of
COC concentrations in surface water samples collected adjacent to perimeter wells along
Murder Creek (MC) and Truax Creek (TC) during the past 5 years. In addition, the table
displays ROD cleanup criteria based on AWQCs for human health, water and fish
consumption that ODEQ finalized in October 2011.
Murder Creek
Wah Chang collected surface water samples from upstream (MC-U) and downstream (MC-
D) of the facility in Murder Creek from locations adjacent to the northern perimeter wells
PW-79A, PW-78A, PW-77A, and PW-76A.
Following the 2008 FYR report and as presented in Table 6-14, VOCs were not detected in
downstream surface water above the AWQC. However, the method reporting limit is higher
than the AWQC for PCE and VC.
Truax Creek
Wah Chang collected surface water samples from upstream (TC-U) and downstream (TC-D)
of the facility in Truax Creek from locations adjacent to western perimeter wells PW-89A,
PW-88A, and PW-75A.
Following the 2008 FYR report and as presented in Table 6-14, VOCs were not detected in
downstream surface water above the AWQC. However, the method reporting limit is higher
than the AWQC for PCE and VC.
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6.8.2 Monitored Natural Attenuation
Monitored natural attenuation (MNA) is a technique used to monitor or test the progress of
natural processes that can degrade contaminants in soil and groundwater. The data
interpretation focuses on detection of spatial and temporal changes and assessment of their
impacts on the achievement of Site-specific goals. The following section summarizes the
MNA progress in the Solids and Farm Ponds Areas.
6.8.2.1 Solids Area
The primary groundwater contaminant source in the Solids Area was lime solids stored in the
LRSP and Schmidt Lake. In September 2010, Wah Chang used high density polyethylene
(HDPE) material to line the pond formerly known as Schmidt Lake and now designated Pond
3. This was completed as part of a joint project with the Cities of Albany and Millersburg to
divert Wah Chang's wastewater discharge from Truax Creek to the City of Albany's new
wetland treatment system. When the new system is operational, water will be pumped from
Pond 2 to Pond 3 for additional cooling and discharged to the wetland treatment system and
no longer discharged to Truax Creek. Additional water will be pumped from the Willamette
River to the Cooling Pond for release to Truax Creek to maintain flows through the summer
months.
Groundwater flow in the Solids Area is from the east to the west as indicated on Figure 3-
5.The groundwater monitoring network in the Solids Area is composed of 17 monitoring
wells (see Figure 3-5).
Eight wells are screened in Willamette Silt (WS): PW-07A, PW-09A, PWA-1,
PWB-1, PWC-1, PWF-1, PW-17B, and PW-18B.
Four wells are screened in the Linn Gravels (LS): PWA-2, PWB-2, PWD-1, and
PWE-1.
Five wells are screened in the Blue Clay (BC): PWB-3, PWC-2, PWD-2, PWE-2,
and PWF-2.
Based on analytical results, the only COC detected above ROD cleanup levels since June
2007 was fluoride (Table 6-16). Out of the 17 wells, concentrations of fluoride in six wells
were above the ROD cleanup level of 2 mg/L. During the fall of 2011, the concentration of
fluoride in only one out of the 17 wells was above the ROD cleanup level. The November
2011 concentration of fluoride was 2.1 (ig/L in PWE-1, and fluoride was detected in PWB-1
at a concentration of 2 j^ig/L and PWB-3 at a concentration of 1.7 j^ig/L.
6.8.2.2 Farm Ponds
The groundwater monitoring network in the Farm Ponds Area is composed of 19 monitoring
wells (see Figure 3-5). Of these 19, three wells screened in Willamette Silt are sampled
regularly: PW-40S, SS, and PW-65S. Groundwater flow in the Farm Ponds Area is from the
east-northeast to the west-southwest as indicated on Figure 3-5.
Table 6-17 displays a summary of VOC concentrations in groundwater from monitoring
wells in the Farm Ponds Area. Groundwater monitoring data from PW-40S indicates that
removal of lime solids from the Farm Ponds Area in 1999 reduced groundwater VOC
concentrations (Figure 6-32). However, increasing concentrations of PCE and TCE were
observed in well SS following the regrading of the Farm Pond dikes and were a concern to
EPA as potential indicators that source material may still be present (EPA 2012b). As shown
on Figure 6-33, PCE and TCE in well SS steadily increased from 2002 to peak in September
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2008. Following the fall 2008 event, PCE and TCE concentrations decreased abruptly to
below the ROD cleanup levels.
Analytical results from 2009, 2010, and 2011 indicate that TCE was detected in well SS
below the method reporting limit in 2009 and 2010, but was not detected in 2011. PCE was
detected at concentrations of 2.52 (ig/L, 2.13 (ig/L, and 1.45 (ig/L in 2009, 2010, and 2011,
respectively. No other VOCs were detected above ROD cleanup levels in the Farm Ponds
monitoring wells in 2011.
The increasing concentrations of PCE and TCE in well SS from 2002 to 2008 prompted Wah
Chang to consider removing the remaining dike material surrounding the well. Wah Chang
completed this work under an approved EPA work plan (Wah Chang 2012e; EPA 2012b) in
the summer of 2012. The work included decommissioning well SS with excavation and
disposal of the remaining dike followed by confirmation soil sampling. Wah Chang collected
groundwater samples and EPA will assess the results to determine whether additional actions
will be required. Wah Chang discovered during decommissioning that well SS, installed by
Schoen Electric and Pump, had not been constructed in accordance with the regulations, and
the depths and construction were not as shown on the well construction log. ODEQ checked
Oregon's database for registered wells and found that Schoen Electric and Pump installed at
least 14 other wells for Wah Chang between 1978 and 1982. Wah Chang must submit a
report to EPA documenting whether any of the wells being used for CERCLA Site
investigations were installed by Schoen Electric and Pump. If improperly constructed wells
are being used, Wah Chang must prepare a work plan for EPA approval and replace these
wells with wells that are compliant with well construction regulations.
6.8.2.3 Environmental Evaluations of Uninvestigated Areas
The ROD requires evaluation of areas not investigated during the RI/FS to ensure RAOs for
groundwater at the Site are being achieved. Wah Chang field-screened excavated soil for
potential contamination, and samples with positive detections were analyzed for toxicity
characteristic leaching potential (TCLP) metals, VOCs, and SVOCs.
The 2008 to 2009 Biennial Environmental Evaluation Report (Wah Chang 2010a) disclosed
that 167 excavations were conducted in previously uninvestigated areas from January 2008 to
December 2009. The 2008 to 2009 biennial report indicated the following:
Samples from 21 excavations where field pH or soil conductivity exceeded
screening levels were analyzed for TCLP metals. Results indicated metals were
not detected above Site background levels.
One excavation was analyzed for VOCs and detected TCA at a concentration of
0.167 mg/kg which was below the risk-based screening level of 2 mg/kg.
In all excavations surface gamma radiation was less than the 30.5 (irem/hr
screening level.
Contaminated soil was not in contact with the water table.
The 2010 to 2011 Biennial Report (Wah Chang 2012h) disclosed that 155 excavations were
conducted in previously uninvestigated areas between January 2010 and December 2011. Of
these, 68 excavations contained soils requiring environmental evaluation and 155.25 cu yards
of soils were removed. The report indicated the following:
Samples from seven excavations where field pH or soil conductivity exceeded
screening levels were analyzed for TCLP metals. Results indicated metals were
not detected above Site background levels.
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Eleven excavations were analyzed for VOCs and none of the soils exceeded
screening levels.
All excavation base samples had surface gamma radiation less than the 30.5
(irem/hr screening level. Surface gamma radiation was above than the 30.5
(irem/hr screening level in the disposal piles at four locations in areas already
known to have soils containing radium.
Contaminated soil was not in contact with the water table.
6.8.2.4 PCBs
The 2008-2009 Biennial Evaluation Report (Wah Chang 2010a) indicated that PCB
concentrations in excavated soil exceeded the 50 mg/kg TSCA disposal requirement in five
excavations and in the bottom of two of these excavations.
PCBs detected in soil (85.9 mg/kg) and left in place (28.3 mg/kg) in the vicinity of the
Emergency Services Building Area were consistent with historical observations in this area.
Groundwater samples collected from PW-30A downgradient of the excavation confirmed
PCB levels had not increased since the RI/FS.
Wah Chang completed excavations near Building 1, Building 53, and Building 54. Previous
excavations in this area indicated elevated PCB levels in shallow soil. PCBs were left in place
at concentrations of 35.7 mg/kg and 2.78 mg/kg in two of the excavations at approximately 4
feet bgs. Wah Chang completed one excavation near the mobile shop, Building 73, where
excavated soil exceeded 50 mg/kg. Confirmation sampling at the bottom of the excavation
indicated that PCBs was not detected at 4 feet bgs.
The 2010 to 2011 biennial report (Wah Chang 2012h) indicated that samples from one
excavation west of Building 1 encountered PCBs left in place at a concentration of 212 mg/kg
at a depth of 2 ft below ground surface exceeding the 50 mg/kg TSCA requirement.
Mobilization of PCBs to groundwater at this location is believed to be unlikely because the
sample was collected inside a covered building under a 12-inch thick concrete slab.
6.9 DATA REVIEW FOR OU3
Wah Chang constructed the CoGen Building on top of the former Sand Unloading Area with
no excavating or sampling prior to construction. The unoccupied CoGen Building is capable
of producing the electricity needed to operate the plant. Wah Chang performed gamma
surveys to meet the ROD gamma radiation cleanup criteria; however, the ROD also required
demonstration that construction over residual contamination will not result in radon
concentrations in indoor air above 4 pCi/L. Wah Chang conducted radon sampling of indoor
air in two buildings (CoGen and Mobile Shop) from June 3, 2008 to December 3, 2008 (Wah
Chang 2008). The highest concentration of radon detected during the sampling was 0.5
pCi/L, well below the 4.0 pCi/L OU3 ROD performance standard. Wah Chang submitted a
work plan (Wah Chang 2012a) for additional radon sampling in these buildings, which EPA
is currently reviewing. Results from this analysis are expected in 2013.
EPA interviewed the Mayor of Millersburg regarding the status of the SAA. Based on this
interview, the Mayor indicated tilling agricultural activity was taking place on the SAA. The
EPA determined that there is presently no current radiological data for the soil on the SAA.
The EPA is requiring that Wah Chang sample soil in the SAA to determine the current status
of Site soils and crop residues grown in this area to determine whether a risk to human health
exists.
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6.10 RCRA INVESTIGATIONS
6.10.1 Drain SWMUs
In a 1997 RCRA Facility Assessment (RFA) of the Site (PRC Environmental Management
1997), SWMUs were identified as "Any discernible unit at which solid wastes have been
placed at any time, irrespective of whether the unit was intended for the management of solid
or hazardous waste. Such units include any area at a facility at which solid wastes have been
routinely and systematically released." On this basis all catch basins, sumps, and drain
systems at the Site were identified as SWMUs.
The RFA identified three categories of SWMUs:
Low Release Potential SWMUs are those that have little or no potential of releasing
hazardous constituents to the environment. The RFA stipulates that no further action
is required on low priority SWMUs.
Moderate Release Potential SWMUs are those that have some potential to release
hazardous wastes or constituents to the environment, based on the materials it
contains, its proximity to risk-contoured areas, and its integrity. Further investigation
was required for all Moderate Release Potential SWMUs. All catch basins and
pumped sumps in the south drainage systems were included in this category.
High Release Potential SWMUs are those that meet the criteria of the Moderate
Release Potential SWMUs and have either a documented release or a very likely
release. Among the South Drain System, the connecting drain systems are included in
this category. High Release Potential SWMUs required further investigation.
For Moderate and High Release Potential SWMUs the RFA required the additional
investigation including:
Verification of drainage system features such as piping, sumps, catch basins, etc.
Evaluating the materials that are or have been conveyed in the drainage systems.
Evaluate the integrity of the drainage system
Characterization of releases to soil and groundwater
The RFA identified all SWMUs as Moderate or High release potential SWMUs.
In 2007, Wah Chang submitted a report evaluating all of the drainage related SWMUs south
of Truax creek (CH2M Hill 2007b). These SWMUs consisted of 202 catch basins, 21 sumps,
and four drain systems totaling 19,142 feet of drain piping.
Most of these SWMUs did not have documented releases to soil or groundwater. Rather they
were identified as potential locations where a release could occur based on the presence of
underground or above ground plumbing that conveyed wastewater that may have contained
hazardous waste.
The report detailed engineering inspections and reports for each catch basin and sump,
camera inspections of all underground lines, relining of underground lines in poor conditions,
and results of limited soil and groundwater sampling.
Based on a review of the document, ODEQ concluded that all catch basins and sumps except
10 met the requirements of low release potential SWMUs. The remaining SWMUs require
additional evaluation in order to reclassify. ODEQ also reclassified two of the drain systems
as low release potential.
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6.10.2 Non-Drain SWMUs
During the 2008-2012 period, ODEQ assisted EPA in evaluating the Former Crucible
Cleaning Area, which was identified as a potential source for groundwater contamination in
an earlier ODEQ evaluation of non-drain SWMUs.
ODEQ is also working with EPA to evaluate potential petroleum impact to groundwater and
possibly surface water near the former Deep Hole Boring Machine SWMU. Wah Chang
recently completed an evaluation of the area downgradient of an underground storage tank in
the area but has not yet submitted the results.
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7 TECHNICAL ASSESSMENT
7.1 TECHNICAL ASSESSMENT OF OU1
The following section presents the technical assessment of OU1.
7.1.1 Question A: Is the remedy functioning as intended by the decision
documents?
The review of documents and the results of the Site Inspection indicate that the remedy is
functioning as intended by the ROD. EPA issued a Certification of Completion for the OU1
RA cleanup of contaminated material in the LRSP and Schmidt Lake on June 30, 1993.
Wah Chang lined Schmidt Lake (Pond 3). The Wah Chang facility wastewater will be
pumped from Pond 2 to Pond 3 for additional cooling and discharged to the wetland
treatment system and no longer discharged to Truax Creek.
Institutional Controls in the form of a conservation easement preclude further development
on 12 acres of the Solids Area that is part of the LRSP.
7.1.2 Question B: Are the exposure assumptions, toxicity data, cleanup levels,
and RAOs used at the time of the remedy selection still valid?
There are no changes in the exposure assumptions or RAOs used in making the remedy
decisions in OU1.
7.1.3 Question C: Has any other information come to light that could call into
question the protectiveness of the remedy?
No information calling into question the protectiveness of the remedy was identified during
this FYR.
7.1.4 Technical Assessment Summary
The remedy for OU 1 is functioning as intended and there are no changes that would affect
protectiveness of human health and the environment.
7.2 TECHNICAL ASSESSMENT OF OU2
The following section presents the technical assessment of OU2.
7.2.1 Question A: Is the remedy functioning as intended by the decision
documents?
EPA has determined that the remedy in OU2 is not functioning as intended by the decision
documents in that the cleanup levels may not be met in the time frame of 15 years from the
time of completion of GETS as specified in the Groundwater and Sediments ROD.
7.2.1.1 Groundwater
Extraction Area
The number of detections and concentrations of metals and radionuclides in the FMA have
decreased, according to data reports Wah Chang submitted to EPA. However, annual
monitoring data in the FMA currently show that COC concentrations are above ROD cleanup
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levels and the concentrations over time have been highly variable (Figure 6-3 through Figure
6-5). EPA has concluded that this could be due to acidic conditions in groundwater that
mobilize metals from soil into the groundwater aquifer. The GETS system was not designed
to address the acidic groundwater condition in the FMA that is potentially mobilizing COCs
into groundwater. Therefore, in accordance with the ROD, implementation of in situ soil
flushing is necessary. Since the 2008 FYR, discussions between EPA and Wah Chang
resulted in the EPA's decision not to implement the original in situ soil flushing with solely
water as specified in the ROD. The large amounts of water that are needed would overwhelm
the utility trenches at the Site. Wah Chang submitted to EPA a focused feasibility study and
treatability study work plan (Wah Chang 2012b) to evaluate the option of neutralizing the
chemistry of the FMA acid plume by direct injection of base or buffer solutions instead of
unbuffered water. EPA and Wah Chang are currently discussing the appropriate buffer
technology. EPA expects to issue an ESD to the 1994 ROD by the end of 2013 in order to
implement the unanticipated change of soil flushing with a buffer solution to raise pH in
groundwater so RAOs can be met.
Since the 2008 FYR, Wah Chang performed source characterization to define the extent of
soil flushing needed in the FMA. Wah Chang's source characterization included sampling a
groundwater transect in September 2011 to determine if low pH groundwater was reaching
Second Lake. Based on the results of the study, EPA determined that low pH groundwater
was not detected in groundwater entering Second Lake (Wah Chang 201 la).
EPA determined from low extraction volumes in the extraction wells in the SEA and elevated
concentrations of VOCs in groundwater that GETS was ineffective in this area. EPA further
concluded that groundwater VOC concentrations in the SEA were not declining at a rate that
would achieve RAOs within the timeframe called for in the ROD. Response actions that Wah
Chang took to address this issue included EISB that EPA did not consider at the time of the
ROD. Wah Chang and EPA evaluated the use of EISB as a new RA in the SEA through a
March 2008 pilot test under an approved EPA work plan. Approximately 30 months (Fall
2010) following the implementation of EISB through the SEA pilot, EPA concurred with
Wah Chang that all wells in the SEA met cleanup standards set forth in the ROD for OU2.
Concentrations of VOC daughter products indicated that breakdown of parent compounds
was occurring suggesting that reductive dechlorination was active and progressing.
Groundwater field parameter data indicated geochemical conditions in the SEA were
conducive to survival and function of dechlorination microbes, which are necessary to reduce
VOCs (Wah Chang 201 lb). Based on the low concentrations in the SEA, EPA approved Wah
Chang's proposal for suspending operation of area extraction wells. .Given the lack of source
area identification for the VOC concentrations, Wah Chang must monitor wells biannually in
the SEA for VOCs for a period of at least 5 years from the shutdown of extraction wells
(operation was suspended in April 2011) so EPA can determine if rebound is occurring. EPA
will evaluate whether rebound occurs after the area returns to an oxygenated chemistry. If
rebound occurs and additional action is necessary, Wah Chang and EPA will consider RA
options to reduce VOCs in the SEA.
Fabrication Area
Following issuance of the second ESD for the groundwater ROD in 2009, Wah Chang
performed EISB in the Fabrication Area to reduce COC concentrations in groundwater in two
areas, the ASA and the CCA. In September 2009, Wah Chang, under EPA oversight,
completed EISB in the ASA. Approximately 12 months following EISB, Wah Chang
sampled groundwater and monitoring results indicated groundwater field parameter
conditions conducive to dechlorination microbes, which are necessary to reduce COCs, had
improved from the baseline conditions prior to injection (Wah Chang 2011c). Based on
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review of the ASA data summary, EPA determined that some wells still remain above action
levels. However, Wah Chang's groundwater analytical data for VOCs indicate that TCA and
TCE concentrations have been reduced and daughter compounds increased as a result of
EISB. Wah Chang must continue monitoring to assess the continued effectiveness of parent
compound dechlorination and to monitor changes in concentrations indicative of rebound
conditions. The results of 18- and 24-month long-term monitoring following EISB
implementation are expected in 2012 and should reveal to EPA how the remedy is
progressing and if follow-up actions are needed.
After review of annual monitoring reports and ASA data summaries, EPA noted the presence
of DNAPL solvent as a source. EPA is requiring Wah Chang to perform additional source
characterization and removal or treatment in the ASA due to EPA's determination following
review of ASA data summaries that the EISB has limited effect in the treatment of DNAPL
sources.
In September 2010, Wah Chang completed EISB in the CCA and two additional monitoring
wells were installed to support performance monitoring. Wah Chang's initial groundwater
analytical results show that VOC concentrations have been reduced (Wah Chang 201 Id).
Additional performance monitoring results are anticipated from Wah Chang in 2012.
Farm Ponds
Analytical data from groundwater in the Farm Ponds Area indicated that concentrations of
VOCs abruptly and unexpectedly decreased to below ROD cleanup levels after the 2008
monitoring event in the most contaminated well. However, since Wah Chang could not
explain the decrease in VOC concentrations, the presence of chlorinated source material
remains, and the possibility of rebound is likely. Wah Chang conducted additional actions in
2012 at the Farm Ponds to eliminate the suspected source of contaminants (Wah Chang
2012e) including removing the source material and excavating beyond the contaminated
depth of the remaining pond's berms, with confirmation sampling. Wah Chang sampled
groundwater downgradient of the former berms and EPA expects to evaluate the data in 2013
to assess the extent of dissolved solvents.
7.2.1.2 Surface Water
Wah Chang conducted supplemental surface water sampling on a biannual basis at Truax
Creek and groundwater sampling from applicable western perimeter wells so the EPA could
evaluate the potential for exposure to human health and the environment via the surface water
pathway. Based on the results from surface water sampling, EPA has determined that VOCs
have not been detected in surface water since the fall of 2008. However, EPA observed
increased concentrations of VOCs in well PW-78A (close to Murder Creek) (Wah Chang
201 Id) since the 2008 FYR until following the fall 2009 monitoring event when
concentrations began to decrease in this well. The concentration of DCE in PW-78A again
increased in November 2011. Isoconcentration maps also indicate the proximity of the DCE
plume to Murder Creek. Wah Chang must collect additional surface water samples in the
vicinity of this well to evaluate the potential for release of contaminated groundwater to the
creek.
In order to evaluate risk to human health and the environment from the consumption of fish
and/or organisms at Second Lake, Wah Chang recently sampled (August 2011) a transect that
was discussed in the FMA section above. Since low pH groundwater was not detected in
groundwater entering Second Lake, EPA concluded that constituents that would have been
mobilized by the extremely acidic conditions would not be present in the lake as well. EPA
also determined that contaminants are not reaching surface water and therefore not adversely
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impacting potential risk to human health from the consumption of fish and/or organisms. The
implementation of the FMA acidic groundwater treatability study will likely increase the pH
in groundwater and reduce the potential for COCs to be released from the underlying soils,
transported by groundwater and reach surface water. Wah Chang will continue to monitor
perimeter wells and EPA will evaluate the results.
7.2.1.3 PCBs
Wah Chang conducted a soil excavation in the early 1990s to remove PCBs in soil in the
vicinity of the Emergency Services Building. Groundwater is being monitored in PW-30 and
PW-46 to assess future impacts to groundwater that might come from sources in the soil of
PCB contamination. In general, available information shows that PCB contamination does
not pose a concern to human health and the environment because direct exposure to
contaminated soil is limited by a protective cap (concrete or asphalt). Based on Wah Chang's
data for ongoing environmental evaluations of uninvestigated areas, the groundwater remedy
is not likely to be adversely affected by PCB contamination because PCB concentrations
greater than 50 mg/kg have not been found to be in contact with groundwater.
7.2.1.4 Institutional Controls
ICs are required to prevent on- and off-site use of contaminated groundwater and to ensure
that Site use remains industrial. ICs have been implemented on the Site in the form of
restrictions on land use, groundwater use for drinking water, access, and construction; and
Equitable Servitude and Easement Agreements on adjacent properties preventing use of
groundwater for drinking water. The City of Albany requirements provide additional control
that all new developments connect to municipal water lines if service is available within 150
feet.
Interviews with ODEQ and Oregon Department of Health (Appendix B) indicated that the
ICs are functioning as intended and there have been no changes in land use or zoning.
Observations during the Site Inspection confirmed the Site is adequately fenced including
security cameras. The Farm Ponds Area was observed to be fenced.
The Consent Decree requires deed restrictions on the Main Plant and Farm Ponds Areas to
ensure groundwater will not be used for human consumption until remediation is complete,
and to ensure that Site use remains industrial. Based on Wah Chang's title search (Wah
Chang 1212c), EPA verified that deed restrictions on groundwater use are in place for the
Main Plant and Farm Ponds Area. EPA verified that the Site is zoned for General Industrial
use by the City of Millersburg, and ODEQ and Oregon Department of Health (Appendix B)
do not anticipate future changes in zoning. Deed restrictions prohibiting residential use are in
place for the Solids and Soil Amendment Areas, but not for the Main Plant and Farm Ponds
Areas (Wah Chang 1212c).
The 1996 ESD requires "deed restrictions or other institutional controls acceptable to EPA
and ODEQ for all off-site properties where groundwater containing contaminants above
cleanup levels is present. These deed restrictions or other institutional controls shall notify
future potential buyers of Site conditions, prevent the installation of water supply wells
(and/or require proper abandonment of existing wells), and shall run with the land until
groundwater contaminated above cleanup levels does not leave the Site boundary, and off-site
cleanup levels are achieved." Based on Wah Chang's title search (Wah Chang 1212c), EPA
confirmed that Equitable Servitude and Easement Agreements restricting groundwater use are
in place on adjacent properties. However, EPA could not determine whether any deed
restrictions are in place for the properties Wah Chang purchased in 2008 on the east side of
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Old Salem Road where groundwater contamination has been confirmed, although EPA
verified with the City of Millersburg that these properties are zoned for Limited Industrial
Commercial use. EPA will further work with Wah Chang to verify that deed restrictions for
properties on the east side of Old Salem Road are still indeed in place.
The ROD for OU2 required that "information on areas of subsurface PCB and radionuclide
contamination which do not pose a risk if they are not disturbed be incorporated into the
TWCA facilities maintenance plan, and be made available to future Site purchasers or
regulatory agencies." EPA is requiring that Wah Chang provide a copy of this section of their
site maintenance plan.
7.2.1.5 Sediment
Wah Chang implemented bank stabilization in 2000 that is currently functioning as intended.
EPA does not plan additional RA for sediments. Wah Chang is planning to conduct an
additional round of sediment sampling and analysis for PCBs in Truax Creek to assess the
protectiveness of the remedy (Wah Chang 2012g). Results of this analysis are expected in
2013.
7.2.2 Question B: Are the exposure assumptions, toxicity data, cleanup levels,
and RAOs used at the time of the remedy selection still valid?
The State of Oregon has revised the Risk Based concentrations for some COCs. The exposure
concentrations for PCE, TCE, and VC under Oregon's Risk Based Concentrations have been
increased and are now consistent with EPA's RBCs. There have been no changes to toxicity
factors to these chemicals in IRIS.
Chemical-specific ARARs for Oregon's AWQCs protection of human health water and fish
ingestion have been updated from OAR 340-41-445 to 340-041-0033 (adopted by the
Environmental Quality Commission and became effective February 15, 2005). EPA
recognized the updated AWQCs in October 2011. EPA is unable to determine the impact
from the updated AWQC values because method reporting limits of the surface water
samples are higher than the AWQC values. The manganese human health water quality
criterion has been removed, and the arsenic human health water quality criterion has been
revised to 2.1 ug/L.
The Environmental Health Assessment Program (EHAP), part of Oregon Public Health
Division (OPHD), developed a Public Health Assessment (OPHD 2009) to evaluate the
public health risk of exposure to contaminants in and around the Site. EHAP evaluated the
public health impact of exposure to surface water in Second Lake and the consumption of fish
caught from Second Lake, and determined that exposure to surface water from Second Lake
poses no apparent public health hazard to adults or children who use the lake recreationally or
as transients. To protect public health, EHAP recommended that Wah Chang continue to
maintain perimeter fencing and security measures that prevent public access to areas within
the Wah Chang plant, and notify EHAP if Wah Chang operations are altered such that parts
of the plant, Truax Creek, or Murder Creek become accessible to the general public. EHAP
also recommended that people not drink the water from Second Lake, because the water is
not treated and may contain non-Site related bacteria or algae that could cause disease.
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7.2.3 Question C: Has any other information come to light that could call into
question the protectiveness of the remedy?
In 2007, as a result of implementing an EPA-required additional extraction well, Wah Chang
released a source of TCA in the subsurface of the ASA. Following Wah Chang's groundwater
investigation under EPA oversight, EPA concluded that a TCA concentration of 1,420,000
|jg/L existed that was above the 10 percent solubility limit of the compound suggesting that
DNAPL product is present in this area (CH2M Hill 2008). Due to the potential presence of
DNAPL and/or the high concentrations of dissolved phase chlorinated organics in
groundwater, EPA determined that modification to the groundwater remedy in the
Fabrication Area was necessary to achieve RAOs in the estimated 15-year time frame for
cleanup. In 2009, EPA issued the second groundwater ESD so Wah Chang could implement
EISB under EPA oversight as a cleanup enhancement. Pending Wah Chang's submission of
the results of additional groundwater monitoring data in 2013, additional remedial action in
this area is required to address the source material that is unlikely to be successfully treated
by EISB.
Wah Chang discovered during decommissioning that well SS, installed by Schoen Electric
and Pump, had not been constructed in accordance with the regulations, and the depths and
construction were not as shown on the well construction log. ODEQ checked Oregon's
database for registered wells and found that Schoen Electric and Pump installed at least 14
other wells for Wah Chang between 1978 and 1982. Wah Chang must determine whether any
of these wells are part of the routine monitoring program, and replace them if they are being
used.
7.2.4 Technical Assessment Summary
EPA is evaluating the effectiveness of GETS and EISB and its ability to achieve cleanup
goals in a reasonable time frame through review of ongoing groundwater monitoring data.
Concentrations of COCs in groundwater remain above cleanup levels in the Fabrication Area
and a DNAPL source discovered in the ASA will likely require additional treatment efforts.
In the FMA of the Extraction Area of the Main Plant, low groundwater pH is persistent.
Although decreases in concentrations of some COCs have been observed since the 2008
FYR, modifications to the remedy in the FMA are required to achieve RAOs and the
estimated 15-year time frame for cleanup. Wah Chang and EPA are evaluating the feasibility
of groundwater infiltration using a basic solution to neutralize acidic groundwater and
precipitate metals. EPA will evaluate Wah Chang's groundwater data collected following the
2012 source material removal at the Farm Ponds Area to confirm that concentrations of
COCs are below cleanup levels.
The Site is zoned for General Industrial use and changes in zoning are not expected. Fencing
is in place at the Main Plant and Farm Ponds Areas. Deed restrictions or Equitable Servitude
and Easement Agreements restricting groundwater use are in place for the Main Plant, Farm
Ponds Area, and adjacent properties. Wah Chang must verify the status of deed restrictions
requiring that land use at the Site remain industrial, and determine whether deed restrictions
for groundwater use and land use are in place for the properties Wah Chang recently
purchased east of Old Salem Road.
7.3 TECHNICAL ASSESSMENT OF OU3
The following section presents the technical assessment of OU3.
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7.3.1 Question A: Is the remedy functioning as intended by the decision
documents?
The remedy is functioning as intended by the decision documents. Final Site closure for
radionuclides will be conducted pursuant to Wah Chang's Oregon Radioactive Materials
License and the Energy Facility Siting Council Administrative Rules. This work will be
conducted under the oversight of the OHD and in consultation with ODEQ and EPA.
Currently, Site safety is in place through Wah Chang's radiation management programs.
The Sitewide controls required in the September 2001 Soil ESD need to be incorporated into
the Scope of Work for long-term protectiveness. At the time of decommissioning, Site
controls will be added to the Consent Degree and SOW. Short-term protectiveness is in place
through the Broad Scope Materials Radioactive License and is being implemented as part of
the Wah Chang ongoing safety program.
The Soil Amendment Area is currently being used for agriculture and institutional controls
are in place for radon mitigation with future buildings constructed on the property. Since it
has been 17 years since the data were collected, EPA is requiring additional evaluation for
radionuclides to ensure that tilling of soils or consumption of crops does not present risk to
human health or the environment. There is uncertainty as to whether the current use of tilling
the soil for agricultural purposes and the resulting soil resuspension were evaluated in the
1995 Radiological Survey Addendum. Wah Chang will be collecting soil samples and
reevaluating the exposure and risk under EPA oversight.
Where radon concentrations in buildings could exceed 4 pico Curies per liter (pCi/L), the
Consent Decree required institutional controls such that future buildings will be constructed
using radon-resistant construction methods. These institutional controls include plant
institutional controls, plant building codes, deed restrictions, or deed notices placed on the
identified Main Plant Areas. Wah Chang has developed a Plant Standard providing
requirements for radon control actions (Wah Chang 1997).
The Consent Decree and ROD also require institutional controls requiring that land use
remain consistent with current industrial zoning. The Site is currently zoned for General
Industrial use and zoning changes are not anticipated. Deed restrictions prohibiting residential
use are in place for the Solids and Soil Amendment Areas, but not for the Main Plant and
Farm Ponds Areas (Wah Chang 2012c).
7.3.2 Question B: Are the exposure assumptions, toxicity data, cleanup levels,
and RAOs used at the time of the remedy selection still valid?
There have been no changes to the exposure assumptions, toxicity data, cleanup levels, and
RAOs that would affect the remedy for the soils OU.
The Environmental Health Assessment Program (EHAP), part of Oregon Public Health
Division (OPHD), developed a Public Health Assessment (OPHD 2009) to evaluate the
public health risk of exposure to contaminants in and around the Site. EHAP evaluated the
risk of the Soil Amendment Area, and determined that touching or swallowing soil from the
Soil Amendment Area north of the Wah Chang plant is not expected to harm people's health,
and recommended that the City of Millersburg ensure that no buildings are erected in this
area without proper radon mitigation systems or remediation of the soil. EPA still has
concerns regarding the agricultural process of tilling the soil and will be evaluating the
current risks from farm worker exposure to resuspended soils.
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7.3.3 Question C: Has any other information come to light that could call into
question the protectiveness of the remedy?
Wah Chang has constructed the CoGen facility on an area of the Site where residual
radioactive contamination potentially remains in place. This building was not constructed
using radon resistant construction methods and does not include radon controls. Under EPA
oversight, Wah Chang sampled indoor air in 2008 for radon and Wah Chang's results showed
no radon detected above the action level and therefore no risks were present at the time of
sampling.
Wah Chang's compliance with the ROD requirements for future operations will continue to
be monitored and enforced. Site contamination not previously addressed is subject to
investigation and corrective action under RCRA and may be addressed under either RCRA or
CERCLA.
7.3.4 Technical Assessment Summary
EPA has determined that the remedy is functioning as intended by the ROD and as modified
by the 2001 ESD based on review of Wah Chang's data. Although Wah Chang has completed
the soil remediation in accordance with the 2001 ESD, Wah Chang is required to cleanup
additional soils under the Wah Chang NORM License in order to comply with EPA's
decommissioning rules at plant closure.
Anyone constructing future buildings on the Teledyne Wah Chang Main Plant must comply
with EPA's decisions set forth in the ROD and ESD, and must conduct an assessment to
determine whether radon levels could pose an unacceptable risk to building occupants and
implement radon resistant construction and controls and radon testing if required. Since the
CoGen building was not constructed using radon resistant construction methods and is
located in an area where residual radioactive contamination may exist, Wah Chang must
re sample indoor air radon in this building to ensure protection of human health, and
depending on the results, EPA may require additional sampling and radon mitigation.
EPA required institutional controls for radon mitigation in future buildings for the Soil
Amendment Area and the City of Millersburg has such ICs in place. Since the City is
conducting agricultural activities and tilling on the SAA, the existing soil radionuclide data
were collected 17 years ago, EPA is requiring Wah Chang to collect and analyze soil samples
in the SAA to reassess remaining levels of radionuclides and determine the risk to human
health and the environment from the disturbance of soil.
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8 ISSUES
This section discusses issues identified during the technical assessment and FYR activities,
and provides a determination of whether each issue affects current or future protectiveness.
8.1 OU1 - SLUDGE PONDS
There are no issues regarding OU1.
8.2 OU2-GROUNDWATER AND SEDIMENT
Table 8-1. Issues for OU2
Issue
Affects
Protectiveness
Current/Future
GROUNDWATER
Groundwater monitoring constituents have been reduced since the RI/FS. Contamination may have
migrated over this period and monitoring points must be reassessed.
NO/YES
During decommissioning of well SS in the Farm Ponds Area, Wah Chang discovered that Well SS was
not properly constructed, and the contractor that installed well SS, Schoen Pump and Electric, also
installed other wells at the Site.
NO/YES
EPA has determined that Wah Chang needs to provide additional information on the status of the
Institutional Control Instruments to verify that all institutional controls required by EPA's decision
documents are in place.
NO/YES
Extraction Area
From Wah Chang's annual progress summaries and an independent review of Wah Chang's data, EPA
determined that although GETS has reduced the concentrations of radium and other COCs in
groundwater, low pH conditions persist that are contributing to COCs above ROD cleanup levels.
Therefore it is unlikely that ROD cleanup levels will be achieved in the 15-year time frame without
using a different treatment technology.
NO/YES
Wah Chang implemented EISB as a pilot project under EPA oversight and VOCs were not detected in
the SEA in 2011. Following EPA approval, Wah Chang shut down extraction wells in April 2011,
although a source was never determined. The groundwater data needs to be assessed for potential
reestablishment of a dissolved plume.
NO/YES
Fabrication Area
EISB has been implemented in the CCA and EPA is currently evaluating its effectiveness.
NO/YES
Wah Chang completed EISB in the ASA in 2009 and EPA is currently evaluating its effectiveness.
However, Wah Chang's release of DNAPL and/or high chemical concentrations in the ASA is an
additional source area not encountered during the RI/FS, and it is unlikely that ROD cleanup levels will
be achieved in 15-year time frame without additional remedial actions.
NO/YES
Farm Ponds Area
Based on Wah Chang's annual progress summaries and an independent review of Wah Chang's data,
EPA noted that VOCs significantly and unexpectedly decreased to below ROD cleanup levels and was
concerned about possible plume migration. In 2012, Wah Chang excavated potential source material,
with EPA oversight, since the drop in concentrations was unexplained.
NO/YES
SURFACE WATER
Wah Chang's method reporting limits for some VOCs (PCE and VC) in surface water samples exceed
the AWQC.
NO/YES
EPA noted from Wah Chang's annual progress summaries and an independent review of Wah Chang's
data that VOCs have been detected in surface water at the Site sporadically in past years. However, EPA
believes that since the 2008 FYR, elevated concentration of VOCs observed in PW-78A may indicate
migration of contaminated groundwater to Murder Creek.
NO/YES
SEDIMENT
Additional information on PCB concentrations in sediment is needed from Wah Chang so EPA can
determine if the RA for sediment is functioning as intended.
NO/YES
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8.2.1 Additional Issues
The FYR Site Inspection has identified maintenance issues in some of the flush completed
monitoring wells and extraction wells.
8.3 OU3- SURFACE AND SUBSURFACE SOIL
Table 8-2. Issues for OU3
Affects Protectiveness
Issue
Current/Future
The SOW and Consent Decree do not incorporate requirements of the 2001 Soil
NO/YES
ESD regarding overall cleanup during decommissioning and other factors (see
recommendations in Table 9.3).
The Mayor ofMillersburg indicated that tilling for agricultural purposes was being YES/YES
conducted on the SAA. Although the RI/FS determined that agricultural practices
did not pose a risk to human health or the environment, EPA is revisiting the issue
since it has been 17 years since the soil radionuclide data were collected and the
original evaluation did not assess risks to agricultural workers from soil
resuspension due to tilling, (see recommendations in Table 9.3).
There is uncertainty in the location of the CoGen Building with respect to the NO/YES
overall soil radiation footprint left behind after Wah Chang's remedial actions in
the Sand Unloading Area. EPA Institutional Controls require that anyone
constructing future buildings use radon-resistant construction methods if those
buildings are located on top of radioactive contamination (see recommendations in
Table 9.3).
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9 RECOMMENDATIONS AND FOLLOW-UP ACTIONS
This section discusses required and/or suggested improvements to current Site operations,
remedies, or conditions.
9.1 OU1 - SLUDGE PONDS
There are no issues regarding OU1.
9.2 OU2-GROUNDWATER AND SEDIMENT
Table 9-1. Issues, Follow-Up Actions, and Recommendations for OU2
Issue
Follow-Up Action/
Recommendation
Affects
Protectiveness
Current/Future
Responsible
Party
Milestone
Date
GROUNDWATER
Groundwater monitoring
constituents have been reduced
since the RI/FS. Contamination
may have migrated over this
period and monitoring points
should be reassessed.
Wah Chang must submit a work
plan to EPA and conduct a round
of Sitewide monitoring for wells
and parameters included in the
original RI/FS using current
analytical methodology.
NO/YES
Wah Chang
with EPA
oversight
12/31/2014
During decommissioning of
well SS in the Farm Ponds
Area, Wah Chang discovered
that well SS was not properly
constructed, and the contractor
that installed well SS, Schoen
Pump and Electric, also
installed other wells at the site.
Wah Chang must submit a report
to EPA documenting whether any
of the wells being used for
CERCLA Site investigations were
installed by Schoen Electric and
Pump. If improperly constructed
wells are being used, Wah Chang
must prepare a work plan for EPA
approval and replace these wells
with wells that are compliant with
well construction regulations.
NO/YES
Wah Chang
with EPA
oversight
12/31/2013
EPA has determined that Wah
Chang needs to provide
additional information on the
status of Institutional Control
instruments to verify that all
institutional controls required
Wah Chang must verify the status
of deed restrictions requiring that
land use at the Site remain
industrial, and whether deed
restrictions for groundwater use
and land use are in place for the
NO/YES
Wah Chang
with EPA
oversight
12/31/2013
by EPA's decision documents properties Wah Chang recently
are in place. purchased east of Old Salem
Road. Wah Chang must also
provide EPA with their site
maintenance plan documenting
areas of subsurface PCB and
radionuclide contamination.
Extraction Area
From Wah Chang's annual
progress summaries and an
independent review of Wah
Chang's data, EPA determined
that although GETS has reduced
the concentrations of radium
and other COCs in
groundwater, low pH conditions
persist that are contributing to
COCs above ROD cleanup
levels. Therefore it is unlikely
Evaluate the use of basic solution NO/YES
(lime) groundwater flushing as a
new RA to raise groundwater pH
and decrease the mobility of
inorganic constituents. Wah
Chang has submitted a treatability
study and if EPA determines that
this technology is feasible, EPA
expects to issue an ESD before
the end of 2013 to implement the
remedy.
Wah Chang
with EPA
oversight
12/31/2015
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Table 9-1. Issues, Follow-Up Actions, and Recommendations for OU2 (continued)
Affects
Follow-Up Action/
Protectiveness Responsible Milestone
Issue
Recommendation
Current/Future Party Date
that ROD cleanup levels will be
achieved in the 15-year time
frame without using a different
treatment technology.
Wah Chang implemented EI SB
as a pilot project under EPA
oversight and VOCs were not
detected in the SEA in 2011.
Following EPA approval, Wah
Chang shut down extraction
wells in April 2011, although a
source was never determined.
The groundwater data needs to
be assessed for potential
reestablishment of dissolved
plume.
Wah Chang must continue to
monitor groundwater conditions
biannually under EPA oversight
for 5 years following shutdown of
extraction wells to assess whether
the dissolved plume is
reestablishing itself.
NO/YES
Wah Chang
with EPA
oversight
12/31/2016
Fabrication Area
EISB has been implemented in
the CCA and EPA is currently
evaluating its effectiveness.
Wah Chang must continue
additional performance
monitoring to determine if ROD
cleanup levels will be achieved by
2017 which is the time frame
specified in the ROD.
NO/YES
Wah Chang
with EPA
oversight
12/31/2017
Wah Chang completed EISB in
the ASA in 2009 and EPA is
currently evaluating its
effectiveness. However, a
release of DNAPL and/or high
chemical concentrations in the
ASA indicate an additional
source area not encountered
during the RI/FS, and it is
unlikely that ROD cleanup
levels will be achieved in thel 5-
year time frame without
additional remedial actions.
Wah Chang must continue
additional performance
monitoring to determine if ROD
cleanup levels will be achieved.
Treatment of the plume is
successfully reducing dissolved
phase chlorinated solvents,
however geochemical evidence in
the form of high dissolved
concentrations in the source area
indicate a DNAPL source remains
that will require more aggressive
remediation.
NO/YES
Wah Chang
with EPA
oversight
12/31/2015
Farm Ponds Area
Based on Wah Chang's annual
progress summaries and an
independent review of Wah
Chang's data, EPA noted that
VOCs unexpectedly decreased
to below ROD cleanup levels
and was concerned about
potential plume migration. In
2012, Wah Chang excavated
potential source material since
the drop in concentrations was
unexplained.
Wah Chang excavated the
potentially contaminated pond's
berms, and collected groundwater
samples to confirm groundwater
conditions. EPA will evaluate the
data to determine whether the
extent of the dissolved solvent
plume requires additional
assessment.
NO/YES
Wah Chang
with EPA
oversight
12/31/2014
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Table 9-1. Issues, Follow-Up Actions, and Recommendations for OU2 (continued)
Issue
Follow-Up Action/
Recommendation
Affects
Protectiveness
Current/Future
Responsible
Party
Milestone
Date
SURFACE WATER
Wah Chang's method reporting
limits for some VOCs (PCE and
VC) in surface water samples
exceed the AWQC.
Wah Chang must reduce the
method reporting limits for PCE
and VC in surface water samples
to enable identification of COCs
in surface water.
NO/YES
Wah Chang
with EPA
oversight
12/31/2014
EPA noted from Wah Chang's
annual progress summaries and
an independent review of Wah
Chang's data that VOCs have
been detected in surface water
at the Site sporadically in past
Wah Chang must add surface
water sample locations in the
vicinity of PW-78A in Murder
Creek to evaluate potential for
contaminated groundwater to be
released to surface water.
NO/YES
Wah Chang
with EPA
oversight
12/31/2014
years. However, EPA believes
that since the 2008 FYR,
elevated concentration of VOCs
observed in PW-78A may
indicate migration of
contaminated groundwater to
Murder Creek.
SEDIMENT
Additional information on PCB
Wah Chang must submit an NO/YES
Wah Chang
12/31/2014
concentrations in sediment is
appropriate work plan to EPA for
with EPA
needed from Wah Chang so that
approval and conduct sediment
oversight
EPA can determine if the RA
sampling and analysis in a
for sediment is functioning as
manner consistent with the
intended.
approved Work Plan.
9.2.1 Additional Recommendations and Follow-Up Actions
The FYR Site Inspection has identified maintenance issues in some of the flush completed
monitoring wells and extraction wells. Wah Chang will conduct minor maintenance on some
of those monitoring wells and contract with a driller to conduct rehabilitation of some of
those extraction wells.
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9.3 OU3- SURFACE AND SUBSURFACE SOIL
Table 9-2. Issues, Follow-Up Actions, and Recommendations for OU3
Issue
Follow-Up Action
Affects
Protectiveness
Current/Future
Responsible
Party
Milestone
Date
The SOW and Consent Decree
do not incorporate requirements
of the 2001 Soil ESD regarding
overall cleanup during
decommissioning and other
factors.
Prior to plant
decommissioning, EPA
and ODEQ will amend the
SOW of the 1996 Consent
Decree to incorporate
applicable requirements of
the 2001 Soil ESD for
plant decommissioning.
NO/YES
Wah Chang and
USA and State
of Oregon
01/07/2018
The Mayor ofMillersburg
Wah Chang must collect YES/YES EPA and the 12/31/2014
indicated that tilling for
and analyze soil samples City of
agricultural purposes was being
for radium so EPA can Millersburg
conducted on the SAA.
reevaluate the risk to
Although the RI/FS determined
human health and the
that agricultural practices did
environment from the
not pose a risk to human health
disturbance/resuspension
or the environment, EPA is
of soil and remaining
revisiting the issue since it has
levels of radionuclides in
been 17 years since the soil
soil. Given that the earlier
radionuclide data were collected
testing did not demonstrate
and the original evaluation did
human health risk, the City
not assess exposures to
may continue to use the
agricultural workers from soil
property for agricultural
resuspension due to tilling.
activities including tilling
the soil although it is
suggested by EPA that
ground disturbing activities
that may resuspend soil
should be limited.
Following EPA's
reassessment of the
contaminated soils, should
there be an indication of
human health risk to those
exposed to these soils
under current agricultural
practices, EPA will share
those results with the City
ofMillersburg and discuss
appropriate actions for
future use of the property.
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City ofMillersburg
Linn County, Oregon
U.S. Environmental Protection Agency
Table 9-2. Issues, Follow-Up Actions, and Recommendations for OU3 (continued)
Issue
Follow-Up Action
Affects
Protectiveness
Current/Future
Responsible
Party
Milestone
Date
There is uncertainty in the
location of the CoGen Building
with respect to the overall soil
radiation footprint left behind
after Wah Chang's remedial
actions in the Sand Unloading
Area. EPA Institutional
Controls require that anyone
constructing future buildings
use radon-resistant construction
methods if those buildings are
located on top of radioactive
contamination.
Wah Chang, under EPA
oversight, must retest
indoor air for radon in the
CoGen Building by end of
calendar year 2013, and
based on the results of
radon concentrations, EPA
may require further testing
or actions.
NO/YES
Wah Chang
with EPA
oversight
12/31/2014
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U.S. Environmental Protection Agency
10 PROTECTIVENESS STATEMENTS
This section presents protectiveness statements for OU1 through OU3.
10.1 OU1-SLUDGE PONDS
The remedy for OU1 is protective of human health and the environment, and exposure
pathways that could result in unacceptable risks are being controlled.
10.2 OU2-GROUNDWATER AND SEDIMENT
The remedy at OU2 is currently protective of human health and the environment in the short
term. Progress to meet the groundwater RAOs is being made through an operating GETS
enhanced with EISB. ICs are in place preventing exposure to contaminants of concern above
cleanup goals through on-site and off-site deed restrictions on groundwater use, zoning, and
access controls. In order for the remedy to be considered protective in the long term, Wah
Chang must obtain and provide to EPA further information on pH conditions and COC
concentrations and verify that all IC instruments required by EPA's decision documents are
in place. Long term protectiveness will be obtained when Wah Chang and EPA take the
actions described below:
Wah Chang must implement buffer solution treatment under EPA oversight to the
groundwater source area contamination in the FMA stemming from acidic pH conditions and
resulting in concentrations of COCs that remain above ROD cleanup levels. Groundwater
quality conditions in the FMA are unlikely to achieve RAOs within the estimated 15-year
time frame specified in the ROD. EPA will evaluate the effectiveness of additional remedial
actions in the FMA as data become available. EPA expects this action to be completed and
data available to assess effectiveness in 2016.
Since Wah Chang's annual progress summaries indicate that no VOCs have been detected in
groundwater in the SEA, and that ROD cleanup levels have been met, EPA considers the
SEA protective in the short term. EPA-required ICs are in place at the Site that prevent
human use of groundwater, and the Site is still zoned for General Industrial use by the City of
Millersburg. Long term protectiveness will require Wah Chang under EPA oversight to assess
the mobilization of solvents from the source area after oxygen has stopped the reductive
dechlorination of dissolved chlorinated solvents. This assessment will consist of long-term
ground-water monitoring. EPA will reassess the effectiveness of EISB in the SEA based on
Wah Chang's groundwater monitoring data that will be submitted annually through 2016.
EPA has determined that due to elevated concentrations of VOCs in the ASA and CCA, Wah
Chang must continue to monitor geochemical conditions to evaluate the effectiveness of
EISB and reductive dechlorination. In 2014, EPA will reassess the effectiveness of the EISB
based on the groundwater data collected by Wah Chang and will make a decision whether the
remedy will meet ROD cleanup levels in the 15-year time frame specified in the ROD or
whether additional treatment will be required. However, Wah Chang's release of DNAPL
and/or high concentrations of VOCs in the ASA is an additional source area not encountered
during the RI/FS that will likely require more aggressive remediation. Wah Chang must
assess the source of DNAPL in the ASA and provide data to EPA by 2014.
EPA has observed increased concentrations of VOCs in well PW-78A (close to Murder
Creek). The current downstream surface water sampling is located 200 feet from the
anticipated discharge point of groundwater in the vicinity of this well. Under EPA oversight,
Wah Chang must collect additional seepage and surface water samples in the vicinity of well
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PW-78A so EPA can evaluate the potential for release of contaminated groundwater to the
creek. EPA expects to evaluate additional data by 2013.
Since the 2008 FYR, Wah Chang's annual progress summaries and EPA's independent
review of Wah Chang's data showed increasing CVOC concentrations in groundwater in the
Farm Ponds Area indicating that ROD performance standards may not be met. However,
EPA noted recent unexplained declines in concentrations. In 2012 Wah Chang completed
excavation of the berm material that may have acted as a source of groundwater
contamination, and collected confirmation samples of groundwater. EPA will evaluate the
results of the completion report in 2013 to assess whether additional actions will be are
required.
Wah Chang must conduct additional sampling and analysis of PCBs in sediments to ensure
that the remedy for sediments is protective. EPA expects to evaluate additional data in 2013.
Wah Chang must submit a report to EPA documenting whether any of the wells being used
for CERCLA Site investigations were installed by Schoen Electric and Pump. If improperly
constructed wells are being used, Wah Chang must prepare a work plan for EPA approval
and replace these wells with wells that are compliant with well construction regulations.
Wah Chang must verify the status of deed restrictions requiring that land use at the Site
remain industrial, and whether deed restrictions for groundwater use and land use are in place
for the properties Wah Chang recently purchased east of Old Salem Road. Wah Chang must
also provide EPA with their site maintenance plan documenting areas of subsurface PCB and
radionuclide contamination.
10.3 OU3 - SURFACE AND SUBSURFACE SOIL
A protectiveness determination of the remedy at OU3 cannot be made at this time until
further information is obtained associated with exposure to radionuclides from resuspension
due to tilling in the Soil Amendment Area. Further information will be obtained by taking the
following actions. Under EPA oversight, Wah Chang must collect samples of SAA soil and
test for radiological contamination by the end of calendar year 2013 so EPA can reevaluate in
2014 the risk to human health and the environment from the disturbance/resuspension of soil
to evaluate whether human health and the environment are protected under the existing
remedy.
Excavation of contaminated soil at the main facility was completed and ICs, in the form of
deed restrictions, are in place for remaining contaminated soil so human exposure will not
occur. Additionally, for the remedy to be protective in the long term, EPA and Wah Chang
need to take the following actions to ensure protectiveness:
Prior to plant decommissioning, EPA and ODEQ will amend the SOW of the 1996 Consent
Decree to incorporate applicable requirements of the 2001 Soil ESD for plant
decommissioning.
Under EPA oversight, Wah Chang must retest for radon in the CoGen Building by the end of
calendar year 2013 due to uncertainty in the location of the CoGen Building with respect to
the overall soil radiation footprint remaining after remediation of the Sand Unloading Area.
Based on the results, EPA may require additional testing of radon in indoor air or radon
mitigation.
10-2
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Fourth Five-Year Review Report for Wah Chang Superfund Site
City ofMillersburg
Linn County, Oregon
U.S. Environmental Protection Agency
10.4 SITEWIDE PROTECTIVENESS
EPA has determined that there is not enough information to evaluate protectiveness, primarily
in the area of the Site that has agricultural activities (SAA). Therefore, the Sitewide
protectiveness is deferred until the following additional information is evaluated. Wah Chang
must collect and analyze soil samples for radium so EPA can reevaluate the risk to human
health and the environment from the disturbance/re suspension of soil. Given that the earlier
testing did not demonstrate human health risk, the City may continue to use the property for
agricultural activities including tilling the soil although it is suggested by EPA that ground
disturbing activities that may resuspend soil should be limited. Following EPA's
reassessment of the contaminated soils, should there be an indication of human health risk to
those exposed to these soils under current agricultural practices, EPA will share those results
with the City of Millersburg and discuss appropriate actions for future use of the property.
Progress to meet the groundwater RAOs is being made through an operating GETS enhanced
with EISB. ICs are in place preventing exposure to contaminants of concern above cleanup
goals through on-site and off-site deed restrictions on groundwater use, zoning, and access
controls. In order to ensure long term protectiveness, Wah Chang must provide further
information on pH conditions and groundwater COC concentrations following remedy
enhancements so that EPA can evaluate the ability of the OU2 remedy to meet RAOs within
the 15-year time frame specified in the ROD (2017). In addition, Wah Chang must confirm
that all IC instruments required by EPA's decision documents are in place for all parcels of
property that could be affected by contaminated groundwater. Wah Chang must verify the
status of deed restrictions requiring that land use at the Site remain industrial, and whether
deed restrictions for groundwater use and land use are in place for the properties Wah Chang
recently purchased east of Old Salem Road. Wah Chang must also provide EPA with their
site maintenance plan documenting areas of subsurface PCB and radionuclide contamination.
EPA required Institutional Controls are in place requiring that anyone constructing future
buildings on the Teledyne Wah Chang Main Plant must conduct an assessment to determine
whether radon levels could pose an unacceptable risk to building occupants and implement
radon resistant construction and controls and radon testing if required. Since the CoGen
building was not constructed using radon resistant construction methods and is located in an
area where residual radioactive contamination may exist, Wah Chang must resample indoor
air radon in this building to ensure long term protectiveness of human health, and depending
on the results, EPA may require additional sampling and radon mitigation.
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U.S. Environmental Protection Agency
11 NEXT REVIEW
The next statutory review will be in 2018, 5 years after the signature date of this review.
Based on the ROD performance standards, concentrations of Site contaminants must be
below cleanup levels by the time of the next FYR. However, if hazardous substances remain
above levels that allow for unlimited use and unrestricted exposure at the Site, five-year
reviews will continue and the remedy may need to be revisited.
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Linn County, Oregon
U.S. Environmental Protection Agency
12 REFERENCES
Beaulieu, J.D., Hughes, P.W. and Mathoit, R.K., 1974, Environmental geology of western
Linn County: Oregon Department of Geology and Mineral Industries, Bulletin 84, scale
1:62500.
CH2M Hill, 1993. Revised Draft TCWA Remedial Investigation Report and Feasibility
Study, Teledyne Wah Chang Albany, Albany, Oregon. Volumes I through IV. Prepared
by CH2M Hill, Corvallis, Oregon. March 1993.
CH2M Hill, 1997. Sampling and Analysis Plan, Wah Chang, Albany, Oregon. Prepared by
CH2M Hill, April 1997.CH2M Hill, 2005. Wah Chang Fabrication Area Groundwater
Remedy 3-Year Evaluation, Albany, Oregon. Prepared by CH2M Hill, Corvallis, Oregon.
July 2005.
CH2M Hill, 2006. Addendum to Wah Chang Fabrication Area Groundwater Remedy 3-Year
Evaluation, Wah Chang, Albany, Oregon. Prepared by CH2M Hill, Corvallis, Oregon.
August 2006.
CH2M Hill, 2007a. Fabrication Area Groundwater 2006 Remedial Action Progress Report,
Wah Chang, Albany, Oregon. Prepared by CH2M Hill, Corvallis, Oregon. February
2007.
CH2M Hill. 2007b. RCRA Facility Investigation Administrative Action Closure Report for
the Wah Chang South Drain System.
CH2M Hill, 2008. Acid Sump Area Subsurface Soil and Groundwater Investigation Results.
Prepared by CH2M Hill, Corvallis, Oregon. February 21, 2008.
Department of Environmental Quality (ODEQ). 2010. Water Quality Standards Review and
Recommendations: Iron and Manganese. November 16, 2010.
Department of Environmental Quality (ODEQ). 2011. Water Quality Standards Review and
Recommendations: Arsenic. Draft Report. February 1, 2011.
EPA, 1986. Guidelines for Groundwater Classification under the EPA Groundwater
Protection Strategy.
EPA, 1989. Record of Decision, Decision Summary and Responsiveness Summary for
Interim Response Action, Teledyne Wah Chang Albany Superfund Site, Operable Unit
#1 Sludge Pond Units, Albany, Oregon. Prepared by the United States Environmental
Protection Agency. June 10, 1994.
EPA, 1993, Certificate of Completion for Operable Unit 1.
EPA, 1994. Record of Decision, Declaration, Decision Summary and Responsiveness
Summary for Final Remedial Action of Groundwater and Sediments Operable Unit,
Teledyne Wah Chang Albany Superfund Site, Millersburg, Oregon. Prepared by the
United States Environmental Protection Agency. June 10, 1994.
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U.S. Environmental Protection Agency
EPA, 1995. Record of Decision for Surface and Subsurface Soil Operable Unit, Teledyne
Wah Chang Albany Superfund Site, Millersburg, Oregon. Prepared by the United States
Environmental Protection Agency. September 27, 1995.
EPA, 1996. Explanation of Significant Differences from the June 10, 1994 ROD for Final
Remedial Action of Groundwater and Sediment Operable Unit. Prepared by the United
States Environmental Protection Agency. October 8, 1996.EPA, 2001a. Comprehensive
Five-Year Review Guidance. EPA 540-R-01-007. Prepared by United States
Environmental Protection Agency, Office of Emergency and Remedial Response. June,
2001.
EPA, 2001b. Explanation of Significant Differences to the September 27, 1995 Record of
Decision for Surface and Subsurface Soil Operable Unit, Teledyne Wah Chang Albany
Superfund Site, Millersburg, Oregon. Prepared by the United States Environmental
Protection Agency. September 28, 2001.
EPA, 2008, Third Five Year Review Report for the Teledyne Wah Chang Superfund Site.
Prepared by the U.S. EPA. Region 10. January 8, 2008.
EPA, 2009, Explanation of Significant Differences to the June 10, 1994 Record of Decision
for Final Remedial Action of Groundwater and Sediments Operable Unit, Teledyne Wah
Chang Albany Superfund Site, Millersburg, Albany. Prepared by the United States
Environmental Protection Agency. June 19, 2009.
EPA, 2011. EPA's Approval of New and Revised Human Health Water Quality Criteria for
Toxics and Implementation Provisions in Oregon's Water Quality Standards Submitted
on July 12 and 21, 2011. October 17, 2011.
EPA, 2012a, Addendum - Third Five Year Review Report, Teledyne Wah Chang Superfund
Site. Prepared by the U.S. EPA. Region 10. March 28, 2012.
EPA 2012b. US EPA Approval Final Work Plan Well SS Removal and downgradient
assessment of CVOC Contamination at the Farm Ponds Area, Teledyne Wah Chang
Superfund Site, Albany Oregon. August 24, 2012.
Ma, Lina, Ian P. Madin, Keith V. Olson, Rudie J. Watzig, Ray E. Wells, Alan R. Niem, and
George R. Priest. 2009. Oregon Geologic Data Compilation (OGDC) - Release 5
Oregon Department of Human Services (OPHS), 2009. Public Health Assessment, ATI Wah
Chang, Millersburg, Oregon, EPA FACILITY ID: ORD050955848, December 2, 2009.
Oremet-Wah Chang, 1999a. Letter from James H. Denham to Joan Shirley regarding BNSF
Equitable Servitude, March 29, 1999.
Oremet-Wah Chang, 1999b. Letter from James H. Denham to Joan Shirley regarding the
Simpson Equitable Servitude, April 9, 1999.
Oremet-Wah Chang, 1999c. Letter from James H. Denham to Joan Shirley regarding the
Simpson Equitable Servitude, April 23, 1999.
12-2
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Linn County, Oregon
U.S. Environmental Protection Agency
PRC Environmental Management. 1997. Resource Conservation and Recovery Act Facility
Assessment, August 1, 1997.
SCS Engineers, 2011, 2010 Annual Environmental Monitoring Report. Finley Buttes
Regional Landfill. Boardman, Oregon. March 30, 2011.
Stoel Rives, 1999, Letter from J. Mark Morford to Joan Shirley regarding Wah Chang;
Second Lake Shoreline Property, March 4, 1999.
United States of America (USA) and State of Oregon, 1997. Order Entering Consent Decree
CV-97-169-RE. Teledyne Wah Chang Albany. January 31, 1997.
United States of America (USA) and State of Oregon, 2006. Order Entering Consent Decree
CV-06089-TC. City ofMillersburg. June 19, 2006.
Wah Chang, 1997. Letter from Charles R. Knoll to Kevin Rochlin regarding Statement of
Work Requirement 5.2.6.1 Institutional Controls/Deed Restrictions.
Wah Chang, 2008. Results of Buildings 73 and 198 Radon Testing. December 17, 2008.
Wah Chang, 2009a. Extraction Area Groundwater Year 2008 Remedial Action Progress
Summary. March 13, 2009.
Wah Chang, 2009b. Fabrication Area Groundwater Year 2008 Remedial Action Progress
Summary. March 30, 2009.Wah Chang, 2010a, Wah Chang Facility Biennnial Report of
Environmental Evaluations: January 2008 - December 2009. September 2010.
Wah Chang, 2010b. Fabrication Area Groundwater Year 2009 Remedial Action Progress
Report. Prepared by GSI. April 5, 2010.
Wah Chang, 2010c. Extraction Area Groundwater Year 2009 Remedial Action Progress
Report. April 5, 2010.
Wah Chang, 2011a. Re: Feed Makeup Area - Second Lake Groundwater pH Sampling
Transect Results. Letter from Noel Mak of Wah Chang to Ravi Sanga of EPA. October
26, 2011.
Wah Chang. 2011b, EISB Pilot Test Summary, South Extraction Area, Technical
Memorandum. ATI Wah Chang Facility, Albany, Oregon August 15, 2011.
Wah Chang, 2011c. Acid Sump Source Area Enhanced InSitu Bioremediation Project and
Performance Summary, Fabrication Area, ATI Wah Chang Facility, Albany, Oregon.
Prepared by GSI. September 9, 2011.
Wah Chang, 201 Id. Fabrication Area Groundwater Year 2010 Remedial Action Progress
Report. Prepared by GSI. August 22, 2011.
Wah Chang, 201 le. Revised Extraction Area Groundwater Year 2010 Remedial Action
Progress Summary. August 15, 2011.
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Wah Chang, 201 If. Feed Makeup Area - Second Lake Groundwater pH Sampling Transect
Results. Prepared by GSI. October 26, 2011.
Wah Chang, 2012a. Work Plan for 2012 Radon Monitoring. March 1, 2012.
Wah Chang, 2012b. FMA Groundwater Focused Feasibility Study and Treatability Study
Work Plan - Draft. May 1, 2012.
Wah Chang, 2012c. EPA Request for Information of Teledyne Wah Chang Superfund Site.
Letter to EPA with attachment prepared by Stoel Rives, LLP, re: Linn County, OR Deed
Restrictions. July 6, 2012.
Wah Chang, 2012d. Extraction Well FW-4 Aquifer Test Work Plan. August 16, 2012.
Wah Chang, 2012e. ATI Wah Chang Farm Ponds Area - Revised Well SS Removal Work
Plan. August 23, 2012.
Wah Chang, 2012f. Extraction Area Groundwater Year 2011 Remedial Action Progress
Summary. September 5, 2012.
Wah Chang, 2012g. Truax Creek Sediment Sampling and Analysis Plan. September 14, 2012.
Wah Chang, 2012h. Wah Chang Facility Biennial Report of Environmental Investigations:
January 2012 - December 2011. September 28, 2012.
Wah Chang, 2012i, Fabrication Area Groundwater Year 2011 Remedial Action Progress
Summary. November 30, 2012.
Waitt, R.B. 1985. Case for periodic, colossal jokulhlaups from Pleistocene glacial Lake
Missoula. Geological Society of America. Bulletin Vol. 96, No. 10.
12 4
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APPENDIX A
Public Notice
-------
Teledyne Wah Chang
United States Superfund Site Cleanup
Environmental Protoctior _ w _
Agency 5-Year Review
Public Comments Invited Through July 31, 2012
The U.S. Environmental Protection Agency (EPA) is preparing the fourth 5-Year
Review of the Teledyne Wah Chang Superfund Site in Millersburg, Oregon. EPA
is required to review the cleanup decision for Superfund sites every five years.
The review evaluates whether the cleanup continues to protect people and the
environment. Cleanup at Teledyne Wah Chang combined soil excavation with a
system to extract and treat contaminated groundwater; it also included land
use restrictions.
Teledyne Wah Chang continues to monitor chemical concentrations in the
groundwater. EPA regularly reviews the data to ensure that the cleanup is
progressing as planned. EPA welcomes the public's participation in this review.
Anyone who has information that may help the review, or concerns about the
site should contact EPA Project Manager Ravi Sanga at 206-553-4092, or toll
free at 1-800-424-4372, extension 4092. You can send email to:
sanga.ravi@epa.gov. TDD users may call the Federal Relay Service at
1-800-877-8339 and give the operator Ravi Sanga's phone number.
The Teledyne Wah Chang site is on EPA's National Priorities List of the nation's
most contaminated hazardous waste sites. The site was contaminated by
wastes from a metals production plant. Pollutants include radionuclides and
volatile organic compounds, which impacted site groundwater, sediments, and
soils. Cleanups took place during the mid- and late-1990s and in early 2000.
To learn more, visit www.epa.gov/rl0earth/. click on Index A-Z, then click on T
and select Teledyne Wah Chang.
&EPA
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APPENDIX B
Interviews
-------
INTERVIEW RECORD
Site Name: Wah Chang
EPA ID No.: ORD050955848
Subject: Five Year Review Report Interview
Time: 1300
Date: 3-12-12
Type: ~ Telephone
Location of Visit:
~ Visit
~ Other
~ Incoming ~ Outgoing
Contact Made By:
Name: Ravi Sanga
Title: TOPO
Organization: EPA
Name: Mike Marshall
Title: Geologist
Organization: Parametrix
Individual Contacted:
Name: Clayton Wood
Title: Mayor
Organization: City of Millersberg
Telephone No: 541-928-4523
E-Mail Address: bcastillo@cityofmillersburg.org
Street Address: 422 NE Old Salem Road
City, State, Zip: Albany, Or 97321
Summary Of Conversation
1. How long have you been mayor?
a. Since January 2, 1976
2. Are you aware of the soil amendment area (SAA)? What is your knowledge about the
parcel of property that was received from Teledyne ?
a. The status of the property has not change from farmland. The property is used for
the production of grass seed. The City of Millersburg is aware of the radionuclide
contamination on the property.
3. Do you recall the transfer of the soil amendment area? Do you recall the circumstances that
lead to the transfer off the SAA to the City of Millersburg ?
a. The transfer was a part of a land swap deal between Wah Chang and the City of
Millersburg. The land was traded for land closer to Wah Chang the City owned for
the SAA that was connected to land on owned by the City on each side of the SAA
4. Has anything to your knowledge changed in the area? What is the current use of the
property ? Has anything changed regarding the land use of the property in the past 5 years ?
10 years ?
a. No land use has changed within the last 10 or 5 years
b. Current use includes agricultural activities which till and farm for the production of
grass seed. The land is plowed and the grass seed added. The recent use of direct
seed planting occurred last year. This process does not use tilling. The grass seed is
planted by drilling a small hole and the seed placed inside. The tilling process
usually impacts the top 7 or 6 inches of soil.
5. Are land use and zoning laws unchanged in this area?
a. Zoning laws are unchanged
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6. Do you have the deed and title documents for this property?
a. These documents should have land use restrictions in them.
7. Have there been any complaints on the site or trespassing?
a. No complains or trespassing activity has been reported
b. No buildings have been constructed on the property
c. There has been no interest in building on the property. Development in the area has
been very dead in the last 5 years.
8. Can EPA have a copy of the deed to ensure the appropriate restrictions are placed on the
property?
a. yes we can have copy
b. Barbara Castillo will provide a copy
9. Do you feel informed about the Teledyne site's activities and progress? By activities we
mean progress with the GW cleanup, monitoring for Radon in buildings etc.
a. There is not much contact with the site related to cleanup or contamination
b. The only communication is when there is a link with the city and Jim Dennum with
Wah Chang is requesting building permits
10. Do you have any additional questions or comments regarding the 5 year review process or
the Teledyne Wah Chang Superfund site and the SAA ?
c. No additional questions
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INTERVIEW RECORD
Site Name: Wah Chang
EPA ID No.: ORD050955848
Subject: Five Year Review Report Interview
Time: 1530
Date: 8-09-12
Type: IE Telephone
Location of Visit:
~ Visit
~ Other
~ Incoming
Outgoing
Contact Made By:
Name: Ravi Sanga
Title: TOPO
Organization: EPA
Name: Lisa Gilbert
Title: Hydrogeologist
Organization: Parametrix
Individual Contacted:
Name: David Farrer
Title: Public Health Toxicologist,
Environmental Health Assessment
Program
Organization: Oregon Health
Authority Public Health
Telephone No: 971-673-0971
E-Mail Address: david.g.farrer@state.or.us
Street Address: Research and Education Services
800 NE Oregon Street, Suite 640
City, State, Zip: Portland, OR 97232
Summary Of Conversation
1. What is your overall impression of the Teledyne Wah Chang Superfund Site? Are there any human
health or Ecological concerns that you may have resulting from the contamination? Do you think the
health of the surrounding communities are being affected by the site?
Their agency deals with public health, not worker health. The remaining risks are contained on
the site property and barriers including ICs bar access to the general public. There are no
residual risks for the general public. Second Lake (recreation and fishing) and the Soils
Amendment Area were found to have a low risk to the general public. There may be risks in
the future to the public if the site were to shut down and become accessible to the public.
2. Have there been routine communications or activities (site visits, inspections, reporting activities,
etc.) conducted by your office with Teledyne Wah Chang regarding any human health or ecological
issues that you have been concerned about ? If so, please give purpose and results.
Prepared the Public Health Assessment in May 2008 and released it in December 2009. David
hasn't been to the site since then. The conclusion of the Public Health Assessment was no
substantial health risk, even in Second Lake, although the water should not be a drinking source
because it is generally untreated. Wah Chang is maintaining ICs and physical barriers.
3. Have there been any concerns from your constituents, violations, or other incidents related to the
contamination at Teledyne Wah Chang that require a response by your office? If so, please give details
of the events and results of the responses.
No there has been little contact from the general public.
4. Do you feel well informed about the cleanup at the site?
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Yes but haven't kept up on all the information.
5. Do you have any comments, suggestions, or recommendations regarding the contamination still
present at Teledyne Wah Chang? Are there any concerns you have regarding the current
manufacturing/production operation of Teledyne that you believe is still resulting in contamination to
the environment?
No.
6. Are there any changes in State laws or regulations that may impact protectiveness?
No.
7. Has the site been in compliance with permitting or reporting requirements from the programs you
enforce or manage? If not what has been going on and what are your concerns?
This question is Not Applicable since Public Health does not have authority.
8. Do you have any additional questions or comments regarding the 5 year review process or the
Teledyne Wah Chang Superfund site and the SAA ?
No.
Page 2 of 2
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INTERVIEW RECORD
Site Name: Wah Chang
EPA ID No.: ORD050955848
Subject: Five Year Review Report Interview
Time: 1430
Date: 8-09-12
Type: IE Telephone
Location of Visit:
~ Visit
~ Other
~ Incoming
Outgoing
Contact Made By:
Name: Ravi Sanga
Title: TOPO
Organization: EPA
Name: Lisa Gilbert
Title: Hydrogeologist
Organization: Parametrix
Individual Contacted:
Name: Geoff Brown
Title: Hydrogeologist
Organization: Oregon Department
of Environmental Quality
Telephone No: 541-686-7819
E-Mail Address: brown.geoff@deq. state.or.us
Street Address:
City, State, Zip:
165 East 7th Avenue, Suite 100
Eugene, OR 97401
Summary Of Conversation
1. What is your overall impression of the Teledyne Wah Chang Superfund Site?
Wah Chang is working hard and spending a lot of money to remedy past practices.
Are there any human health or Ecological concerns that you may have resulting from the
contamination?
No concerns that are not being addressed by the remedy.
Do you think the health of the surrounding communities are being affected by the site?
No. Soil and groundwater are in control, we have a good sense of the beneficial uses, and we
know where the soil amendment was spread.
2. Have there been routine communications or activities (site visits, inspections, reporting activities,
etc.) conducted by your office with Teledyne Wah Chang regarding any human health or ecological
issues that you have been concerned about ? If so, please give purpose and results.
None related to the Superfund cleanup, but DEQs Hazardous Waste Department has had
interactions with the operation side. There was an issue not too long ago with an unrelated
facility.
3. Have there been any concerns from your constituents, violations, or other incidents related to the
contamination at Teledyne Wah Chang that require a response by your office? If so, please give details
of the events and results of the responses.
No violations or incidents have occurred during the last 5 years, but it DEQ may have
responded to some spill incidents. Geoff will search Spills Program database. There have been
sporadic inquiries about the Soil Amendment Area for potential development. Also there was
an inquiry about the Main Plant regarding influence on a nearby organic farm, but this site was
upgradient, and a question about a site as to whether soil amendment had been applied
Page 1 of 2
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(negative).
4. Do you feel well informed about the cleanup at the site?
Yes and No. Overall Yes. But there are nagging issues regarding documents not being
received by DEQ, and DEQ would like to receive communication in a more consistent fashion.
5. Do you have any comments, suggestions, or recommendations regarding the contamination still
present at Teledyne Wah Chang? Are there any concerns you have regarding the current
manufacturing/production operation of Teledyne that you believe is still resulting in contamination to
the environment?
Nothing concrete. No concerns regarding the complex manufacturing process. However, there
are a lot of pipes at the site and DEQ has had past concerns regarding the soil screening criteria.
It is possible that contaminants were missed because of field-based tests. Additional testing is
not required but would present an opportunity to identify source soils.
6. Are there any changes in State laws or regulations that may impact protectiveness?
No the site is governed by EPA. However, DEQ just revised its TEQs for TCE and PCE to be
less stringent by a factor of 20, and the resulting drinking water RBCs went way up.
7. Has the site been in compliance with permitting or reporting requirements from the programs you
enforce or manage? If not what has been going on and what are your concerns?
Yes Wah Chang rarely pushes back.
8. Do you have any additional questions or comments regarding the 5 year review process or the
Teledyne Wah Chang Superfund site and the SAA ?
The SWMU evaluation of the south drainage system (south of Truax Creek, including catch
basins, sumps, and pipes) was completed in 2008 and looked at SWMUs identified in the 1997
RCRA Facility Investigation with low, moderate or high release potential. Some pipe systems
where potential leaks were identified were sealed with epoxy, but the majority of the SWMUs
were recharacterized as low potential risk. DEQ is currently tallying the remaining issues.
The only discovery was near the CCA SWMU and this is being addressed by EISB.
The Deep Hole Boring UST is on a path toward closure. There are no seeps to the creek but
some possible contamination in groundwater. DEQ has recently sent modifications to the Work
Plan to Wah Chang, and the investigation is moving forward.
Page 2 of 2
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INTERVIEW RECORD
Site Name: Wah Chang
EPA ID No.: ORD050955848
Subject: Five Year Review Report Interview
Time: 1100
Date: 3-12-12
Type: IE Telephone
Location of Visit:
~ Visit
~ Other
~ Incoming
Outgoing
Contact Made By:
Name: Ravi Sanga
Title: TOPO
Organization: EPA
Name: Mike Marshall
Title: Geologist
Organization: Parametrix
Individual Contacted:
Name: Jeff Roberts
Title: Laboratory Manager
Organization: SiREM Labs
Telephone No: l-866-251-1747ext.228
E-Mail Address: jroberts@siremlab.com
Street Address: 130 Research Lane Suite 2
City, State, Zip: Guelph, Ontario, Canada, N1G5G3
Summary Of Conversation
1. What is your technical background and role with SiREM?
Bachelor of Science Degree from Waterloo University for environmental science. Graduated in 2003,
and was hired by SiREM. Attended the master degree program at the University of Waterloo, Ontario,
Canada for Earth Science. Currently the Lab manager, after working through the ranks. Mr. Roberts
oversees the bioremediation activities at hundreds of sites across the country. Oversees a lot of culture
growth and maintenance in the lab as well as treatability studies.
2. How long have you been with the company?
a. Since about 2002 as a co-op student.
3. What is your experience with the Wah Chang site?
a. First exposed with GIS in about 2007 for the first pilot test
i. GSI provided site data and Mr. Roberts worked with that to recommended appropriate
volume ofkb-1 and KB-1 plus
b. Data needed for recommendations, contaminated concentrations, redox, pH, DO Sulfate and
nitrate, other electron acceptors, proposed number of injection points, electron donor, and size of
treatment area.
c. Standard dosing based on volume of groundwater trying to treat and can be adjusted form other
factors, like high concentrations may require increased volume of KB-1.
d. What is your opinion of progress?
i. Great success data received showed TCA and TCE concentration decreased to ROD
limits within several months.
ii. The site is well suited to this treatment and the way implemented was done well.
iii. Adding the electron donor, ensuring the groundwater was reduced, culture was added
under the appropriate conditions was key.
iv. And the process was conducted effectively.
v. SiREM provided insight and data review for GSI.
4. Have you had much coordination with Wah Chang following the implementation of the remedy?
a. Coordinate with GSI for size, volumes, geochemistry
5. Can you briefly describe the dechlorination process?
a. Ethenes (PCE) parent compounds is dechlorinated by removal of a chlorine atom and is
replacement by hydrogen. And it becomes a less chlorinated compound. The dehalococcoides is
respiring the compound using is it as an electron acceptor and hydrogen as an electron donor.
6. How do you think the progress is going across the site in the other areas (ASA and CCA)
Page 1 of 2
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a.
Believe that based on conversations with GSI the results are positive.
7.
At what point would you recommend amendment to the treatment in progress?
a.
Most cases KB1 does not need to be reapplied
i. Once established the bacteria are hardy. But Adding deoxygenated water with some
lactate could be enough to reinvigorate bugs
b.
Certain criteria to suggest need for additional treatment see a dechlorination trend stall, electron
donor level depletion
c.
Rule of thumb to reamendment is necessary when 100 mg/L of TOC present
d.
ORP in negative range -70 to -100 mV is ideal
8.
What other compounds in groundwater could limit the effectiveness of treatment?
a.
Iron and mag compete for electron donor so if present they need to be reduced first before the
chlorinated compound will be reduced.
b.
Chloroform and 1,1,1 -TCA can inhibit ethene pathway so the KB-1 was used due to halobacter
bacteria.
9.
Do you have any other recommendations to enhance treatment effectiveness?
a.
Monitor and keep an eye on indicators; dechlorination, low ORP and enough electron donor
presents. And if something begins to change additional electron donor could be added.
10.
Are you
aware of the effect of oil substrate on water level measurements?
a.
Oil present in the water can coat ORP membrane and distort ORP measurements. This needs to
be regularly cleaned off.
b.
Some sites bio fowling may occur at some sites from lactate additives. Screen intervals could be
influencing water levels in the wells.
11.
Will the
bacteria consume NAPL?
a.
The bacteria will only consume VOCs in the dissolved phase, they won't degrade pure NAPL.
The bacteria can only access what is in aqueous phase. However, they enhance the dissolution of
the DNAPL as the concentration becomes low at the product water interface, the bacteria can
increase the dissolution rate from the pure phase to the dissolved phase. The dehalococcoides
will die off when chlorinated compounds are gone.
Page 2 of 2
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INTERVIEW RECORD
Site Name: Wah Chang
EPA ID No.: ORD050955848
Subject: Five Year Review Report Interview
Time: 1500
Date: 2-16-12
Type: ~ Telephone
Location of Visit:
Visit
~ Other
~ Incoming ~ Outgoing
Contact Made By:
Name: Mike Marshall
Title: Geologist
Organization: Parametrix
Individual Contacted:
Name: Noel Mak
Title: Resource Conservation
Specialist
Organization: Wah Chang
Telephone No:
E-Mail Address:
Street Address:
City, State, Zip:
Summary Of Conversation
The EPA interviewed Ms. Noel Mak of Wah Chang on February 16, 2012. Ms. Mak is Wah Chang's Resource
Conservation Specialist.
Her overall impression of the clean-up activities at the site were things were going well and that she expected
ROD standards to be achieved within the required time frame. Ms. Mak indicated that monitoring data collected at
the site currently showed that progress was being achieved in all areas, and contaminant concentrations were
decreasing. Ms. Mak indicated that the clean-up activities for OU1 were complete, cleanup for OU2 was ongoing,
and the cleanup for OU3 was ongoing until OU2 cleanup was completed. She indicated that gamma radiation left
in place at the Sand Unloading Area and the front parking lot will remain until appropriately transferred under the
facilities naturally occurring radioactive materials (NORM) license.
She mentioned that the facility had a full-time employee that was responsible for operation and maintenance of the
GETS. Mr. Mike Cochran is the facilities dump master and repairs, monitors, and directs replacement of the
treatment system components as necessary. If repairs are beyond his abilities, he pursues assistance from pump
specialists, electricians, and outside contractors as necessary to maintain operation of the groundwater treatment
system. To maintain operation, Wah Chang replaces pumps in the FMA extraction wells approximately every 3
months due to the corrosive nature of groundwater in the area. Several parts and replacement pumps are stored at
the Wah Chang facility to minimize downtime associated with malfunctioning equipment. Broken parts can be
quickly replaced with parts on hand at the site. Ms. Mak stated that the Operation and Maintenance Plans
associated with the GETS were up to date and reviewed annually.
Ms. Mak mentioned that the facility no longer discharges site wastewater to Truax Creek. The facility's
wastewater is piped to a recently completed joint project with the City of Albany. The project constructed a
wetland wastewater treatment facility south of the Wah Chang facility, and site wastewater was redirected to the
wetland treatment system in October 2011. She stated that the facility was compliant with all of the required
permits (NPDES, POTW, Title 5, NORM, DOT, RCRA, and Department of Homeland Security). The facility has
not received complaints from the public regarding foul odors or releases to the Willamette River to the best of her
knowledge.
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APPENDIX C
Five-Year Review Site Inspection Checklist
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Appendix C
Wah Chang, Albany, Oregon
th
4 Five Year Review Inspection Report
Inspection Dates: June 6-8, 2012
Inspector: Curt Black, Environmental Scientist (Hydrogeologist), EPA, Region 10, Seattle, 206 553-1262 Geoff Brown,
Oregon Department of Environmental Quality participated in part of the inspection. Lisa Gilbert, an employee of
Parametrix participated as a contractor to the EPA assisting with the Five Year Review.
Remedy Includes: Access controls, Institutional controls, Groundwater pump and treat system, Groundwater
containment, Ground-water monitoring in areas of past removal actions
Interviews: Noel Mak, NPL Program Coordinator was interviewed during the inspection. Mike Cochran, an employee in
charge of extraction well maintenance and system operation was questioned about system maintenance. Randy Coots,
a long-time security officer for the facility was questioned as an assessment of site security and access control.
Brief Site Overview: Operations since 1957, 1982 NPL Listing, ROD OU1 1989, RIFS, 1993, First 5-year review 1997,
Ground-water treatment and extraction system October 2000, Soil and Subsurface Soil ESD September 2001.
Site Inspection Targets / Areas of Interest;
Emergency Services Area - well PW-46A - PCB source issue;
Fabrication Area - Plume Containment near PW-78 - DCE trends and fate;
Temporary Monitoring wells in Acid Sump -TMW-4 388,000ug/l TCA - Source Control Options;
Source Area Review for each source including: Plume maps, well pattern, transport and adequacy of
monitoring, location selection criteria, address preferential pathways and bypassing of monitoring;
Review all trend data for 15 year ROD target for cleanup;
Monitoring program instrumentation issues with OPR and DO data;
MEMTEK Facility - solids deposition and liquids handling;
Past Cleanup Areas - LRSP/Schmidt Lake - wastes handled vs current analyte list;
Farm Ponds - Examine Well-SS and review excavation process, confirmation sampling and future groundwater
assessment of CVOC fate;
Soil Amendment Area - Current activity, assessment of current levels and fate of radionuclides in soil and
plant/crop residues;
Ammonium Sulfate Storage Area - 1978 400,000 gallon process liquid loss, NH4-S04, MIKB, CI-, U, thiocyanate,
zirconium - fate, progress and adequacy of monitoring;
Dump-Master Area - Ground-water monitoring and waste handling evaluation
Truax Creek - Remedy modification - assessment of preferential pathways and current monitoring program.
Need for and options for additional assessment;
Arc-Melting Sub Area (Crucible Cleaning Area) EISB remedy evaluation
Acid Sump Area - EISB remedy evaluation;
Extraction Area EW-1 - 6 inspect wells, labeling, locks, condition;
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South Extraction Area - EISB remedy evaluation;
Fabrication Area - Evaluation of FW-1 - FW-7
Cooling Water Pond - Historic use, liner, effect on hydrology
Deep Hole Boring Machine UST- SWMU - steps for closeout
Murder Creek - sampling locations vs. plume discharge location
Sixty-five of the wells in the monitoring program were evaluated for condition, security, integrity of each location
(prevention of tampering and ingress of water and protection from damage). Specifically, inspector examined the
presence and condition of labels, locks, protection including barrier posts and covers, seals for the well, marked
measurement points and signs of ongoing maintenance. Various plumes were evaluated for establishment of
containment, locations of wells with respect to plume extent, potential for offsite transport of COCs and trend data for
achievement of ROD 15 year timeframe to cleanup. Groundwater treatment and extraction system was evaluated for
condition of pipes, valves, pumps, totalizers, treatment steps, electrical conditions, safety, security and the availability of
spare parts for operation. Tanks were evaluated for the presence of secondary containment, signage on contents and
appropriate response in event of release. Discharge structures were examined - the weir to Truax creek has been
replaced with a pump system which discharges to Schmidt Lake (now Cell 3) for cooling and polishing followed by
discharge to a new constructed wetland where the water is commingled with City of Albany water prior to return to the
Willamette River.
Overall assessment;
Plant is a large, complex chemical and fabrication facility with many waste generating processes and past practice issues.
Many of the earlier sources have been removed. Issues are noted on the following:
Incomplete perimeter containment of CVOC plume on the north boundary,
Source control issue in Acid Sump for NAPL solvent in absence of remedy suitable for NAPL
Current fate of dissolved CVOCs from Well-SS remains unassessed
Time to cleanup in Feed Make-up Area will require remedy modification
Soil Amendment Area requires assessment of current radionuclide concentrations and the fate of radionuclides
in plant/crop materials derived from site.
Many wells were noted to be damaged by heavy traffic and high traffic. Flush well completions were frequently
found to be in a condition which precluded securing the vault from inflow of water from the pavement. Many
vaults were found to be filed or partially filled with water. Locks were frequently inoperable due to corrosion,
well seals were in several cases in a condition which could allow intrusion of water from the vault to the well.
Most above ground well completions were found to be locked, with barrier posts in place and the well inside the
protective casing was found sealed with the exception of several wells with cracked caps from the continued
presence of bailers suspended from the caps. Nearly all wells were visibly labeled with the well ID and had a
visible measurement point. See site visit chronology for specific findings.
Opportunities for Optimization;
As the several EISB remedies continue, there should be the opportunity the reduce the number of wells in the CVOC
plume areas. Once the dissolved constituents are lowered below action levels, the active pumping system could be
expected to be removed from service. At the present time, no wells are suggested for removal from the monitoring
program due to their use in monitoring the progress of cleanup. Additional well coverage at the north boundary of
the site in the area of PW-78 is recommended to assess CVOCs potentially discharging to Murder Creek. Once the
CVOC plume concentrations are lowered below action levels, it should be possible to reduce monitoring in the
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surface waters of Truax and Murder Creeks. Given the questions about plume trajectory on the north boundary, an
additional surface water monitoring point in Murder Creek is recommended.
Site Inspection Chronology:
June 6, 2012 - Arrived at 1150. Checked in and showed ID, watched a mandatory safety video, met Noel Mak and
set out inspection targets for the next 3 days. Discussed inspection process and started.
Conditions: Clear, Sunny, 70 Degrees F, Wind SW 5 mph.
1245 - Started in the South Extraction Area - viewed Plant Well, PW-96A. This well had just been sampled. Lock was
open and corroded. New lock was reported to be on order.
1305 - PHOTO - 293 -South Extraction Area Treatment System control panel inside locked treatment shed
PHOTO - 294 -Treatment pressure monitoring system
PHOTO - 295 -Treatment system totalizers
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PHOTO - 296 -Treatment system carbon canisters - 2 parallel systems
1310 - View Well 57A and PW-26A - sampled previous week - well protected yellow barrier posts, steel casing, lock, cap
and measurement point all present
1314 PHOTO - 297 -View north from EW-4 across PW-26A to PW96A
1317 PHOTO - 298 -View of Well 49A - Well locked, still with old bailer inside from old sampling program. Label found
welded onto casing, barrier posts present, yellow paint, measurement point present
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1328 PHOTO - 299 -View of well PW-47A - Well found locked, but with welded ring loose (requires maintenance),
steel casing intact, cap present, measurement point visible, barrier posts present.
1340 - PHOTO - 300 - View of PW-24A - West toward railroad tracks and Second Lake - good steel casing present,
locked well, measurement point present
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1344 - PHOTO - 301 - View of PW-27A - example of a problematic flush completion where damage has occurred to the
vault so the cover does not seal. The well is labeled however the cap is cracked and water could easily enter to the risk
of the integrity of the monitoring program.
1347 - Visit well PW-23A - well found locked, barrier posts present, cap in place and intact, measurement point present
1352 - PHOTO - 302 - View of Solvent storage tank with environmental codes and disposal information - secondary
containment present as well as fire control system
1402 - PHOTO - 303 - View from EW-3 toward EW-2 and EW-1 - Extraction Area Separations Feed Makeup Area
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1411 - Viewed PW28B and discussed release in FMA - 40K gallons of feed lost 1970s - during investigation, found piping
that was compromised and abandoned.
1415 - PHOTO - 304 - EW-1,2 & 3, Extraction System control panel - Maintenance log viewed in shed. Equipment in
shed for the continuous logging of pH and totalizers - containment system present with alarms
1418 - PHOTO 305 - View North across feed deck from control shed
1424 - PHOTO 306 - View North across Pond 2 to new 3-pump system to covey water to Cell 3 (Formerly Schmidt Lake)
-------
1428 - PHOTO 307 - View north across the former (1979-1989) V-2 solids settling pond location - 3 tanks are the
treatment that replaces the V-2 pond. V-2 waste stream is pickling solution including hydrofluoric acid - now solids are
filter pressed with liquids to acid sludge treatment - this area is now contractor parking.
Photo embargoed by Wah Chang - due to process info inadvertantly captured - replacement photo not yet received
from Wah Chang
1436 - Visit PW-22A- Observed barrier posts present and locked well. Found cracked (16lh inch) cap and measurement
point visible
1444 - Visit PW-21A - Observed barrier posts and lock present, found piping in the well for the 1-month duration
radium sampling which is ongoing.
1448 - PHOTO 308 - View south from Zz distance from PW-21A to PW-20A. Across V-2 Tanks to separations stacks in
background
1452 - Visit PW-20A - Well found locked, label present, with barrier posts present - well cap cracked
1455 - Visit PW-19A - Well found locked, label present, barrier posts present, cap intact
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1459 - PHOTO 309 - View to the SW on the W side of the railroad tracks. View is of the Truax Creek sample point
showing the volume of water flowing.
1520- PHOTO ,310-View of PW-84A - 2-inch well, barrier posts present and well locked. Intact cap, monitor point
present.
1524- PHOTO 311 - View west at ammonium storage - 2 400K gallon wood stave tanks (48% ammonium)
1526 Viewed PW-85A - 2-inch well, locked, barrier posts present, cap present and measurement point present
1536 - Viewed PW-01A -barrier posts present, steel casing, locked and labeled, cap and measurement point present
1532 - PHOTO 312 - View South across PW-01A to Pond 2 west end and 3 new wetland pumps
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1536 - Visit PW-83A - Found flush-mounted and not able to open with tools available
1540 - Visit PW-82A - 2-inch flush mounted, locked with sealing cap - not opened
1545 - Visit PZ-1 -Barrier posts found, well locked, steel casing, vent hole in cap (old practice) with bailer still present in
well. Recommended removing bailers since they are no longer used and the weight and eye-hook hole in caps appears
to be leading to damage by cracking.
1543 - PHOTO 313 - View of calcium chloride tank showing secondary containment
Visit PW-3A -Barrier posts present, well locked, steel casing, labeled, sealing cap, measurement point present
1550 - PHOTO 314 -View East From PW-3A to Truax Creek and Pond 2
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1555 - PHOTO 315 - View of treatment shed (locked) at FW-5 - totalizer and secondary containment present.
Discharges into ammonium recovery system.
1610 - Conversation with Mike Cochran - talked about the historic LRSP Cleanup and Cleanup of Magnesium Recovery
Pile, Schmidt Lake Cleanup and well maintenance procedures and observations.
1624 - Visit well PW-89A -found barrier posts present, steel casing, label, well not locked, cap good - well needs new
lock due to corrosion.
1626 - PHOTO 316 - View across PW-89A to South East across Truax Creek to the now unused weir on Pond 2
1635 - PHOTO 317 - Cooling water pond - receives Willamette River water from pump station on river for use
throughout the plant. About to increase the pumping by % to allow replacing Pond 2 outfall flow into Truax Creek that
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it is diverted to Cell 3. Discharge is arranged with City of Albany to maintain summer flow in Truax. This pond is unlined
and significantly alters the ground-water contours in this area.
1637 - Visit PW-74A and PW-74B - wells with flush completions - unable to open with tools available.
1640 - Visit PW-46A - Flush completion - bolts stripped, lock inoperable, sealed cap in place in casing
1648 - Visit PW-73A and PW-73B- wells with flush completions - unable to open with tools available.
1650 PHOTO 318 - View south east into Dump Master Area from Emergency Services Building where PCB spill occurred
-Well PW-46A is highest in system for PCBs
1710 - Interview with Randy Coots - Security Officer for Wah Chang. Examined logs (electronic) of entry control system.
Viewed extensive security system with demonstrations of camera system and intruder alert features.
1718 Offsite to hotel - Holiday Inn Express, Albany
Thursday, June 7, 2012 - 0700 Records review and target selection - Onsite 0755 - 50 degrees F, steady rain, wind
lOmph Southwest.
0815 - Meet Noel Mak, Continue site visit
0820 - Visit Murder Creek up-stream surface-water sample site at north property line
0830 PHOTO 319 - View north at up-stream sample location - stream is nearly obscured by blackberry and reed-canary
grass (Phalaris)
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0832 Visit PW-34A - Adjacent to small parts disposal on flake-board property. Piles of small parts like these have
previously been associated with solvent disposal to the surface - this is not on Wah Chang property
0835 - Visit PW-15AR (replacement) - well found locked, with barrier posts in good condition, with label and visible
measurement point
0836 - PHOTO 320 - View across PW-15AR toward Creek
0837 - PHOTO 321 - View north of Murder Creek in Reed-canary grass and blackberries from PW-15AR
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0841 - Visit PW-76A -Barrier posts found, steei casing, well found locked.
0846 Visit PW-77A- Flush mount completion, no bolts present, opened lid and found lock in place, sealing cap in place,
measurement point visible
0849 PHOTO 322 - View of Deep Hole Boring Machine UST area - located under pad on N. end of Building 71. View
south at pad location
0850 PHOTO 323 - View North toward murder creek from DHBM UST former location. Zirconium stock to be fabricated
into tubing on pallets
0853 - Visit Outfall 2 discharge into Murder Creek north of PW-78A
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0855 - PHOTO 324 - View north through outfall control equipment to Murder Creek - outfall flowing due to ongoing
rainfall event. Blackberries were later removed by a contractor for our investigation in the creek
0902 - Visit PW-78A -Used tools to open this flush completion well. All bolts present, Location is just west of building
100
0908 - PHOTO - 325 - Pw-78A - View downward showing measurement point, showing label on bottom of protective
cover. Compromised gasket allows parking lot water to accumulate - cup it to bail water down below top of casing prior
to cap removal
0912 - Visit FW-6 - Well under manhole - not removed. This well is not used as extraction. Used for chemistry to
monitor EISB progress.
0914 - Photo 326 - PW-10 - View downward showing bent protective casing, no pad on well, no barrier posts, label
present inside, well found locked, good cover. Need rehabilitation - new well pad, barrier posts, recommend redrilling
due to bent casing. Also, well is partially completing (old well).
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0922 - Visit PW-79A - Flush completion. Found good bolts, good gasket, no water, locked well, labeled with visible
measurement point.
0926 - Visit PW-16A - Found Barrier posts present, casing present, locked, labeled and measurement point visible. Old
style vent hole in cap, well needs new pad - surface completion.
0935 PHOTO 327 - View to South East across LRSP - all solids removed in closure process - water present year round,
found good habitat feature. Still groundwater contamination and still monitoring ongoing. Manganese exceedances -
area will be included in August sampling
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0936 PHOTO 328 - View south across Truax Creek to end of Second Lake from south-west corner of old dike protecting
LRSP from 500 year events.
0943 - PHOTO 329 - View west from same dike as photo 328 viewing confluence of Truax Creek and discharge from
Second Lake just above confluence with Murder Creek
0945 - Visit PW-09 - Well entombed beneath "drivable" cover and could not be opened for inspection.
0950- Searched for PW-E and PW-B unsuccessfully in heavy undergrowth
0955 - Return to visitor center to pick up Lisa Gilbert
10:22 - Visit PWA-1 and PWA-2 in single protective steel casing - multiple completion
10:23 - PHOTO 330 - View downward at casing including the nested PWA-1 and PWA-2 in single protective pipe. Well
found locked, labeled - next to be sampled in August with expanded 5-year review analyte list
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1040 - Searched unsuccessfully for well 17B
1044- PHOTO 331 - View to southeast toward the plant from PWC-1 and PWC-2 - Schmidt Lake Excavation Project Pad
and current soil staging area from all excavations while testing is completed. Also cooling area for slag and cement in
drums before shipment to Columbia Ridge LF.
1048 - Visit PW-C - well found locked with steel casing and cap. Barrier posts not painted and found damaged
1051 - Visit PW-07 - Unorthodox design of well completion found - sanitary seal being used for well cap - no locks
present, well labeled. Well should be recompleted - no barrier posts, no pad, no measurement point
1057 - Visit to 90 day accumulation area. Contractor actively inspecting and testing wastes as they arrived. Random
sample of labels on drums found all within 90 days - oldest observed was March 19, 2012.
1100 - PHOTO - 332 and 333 - Views of 90 day accumulation area showing acceptance process for flammable drums -
photos embargoed by Wah Chang.
1103 - PHOTO 334 View southwest across new Cell 3 - previously Schmidt Lake - completed 1 year ago to allow
additional cooling and polishing prior to discharge to new constructed wetland to the south with City of Albany.
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1110-PHOTO 335-View northeast across former Magnesium Resource Recovery Pile toward well PW-07. Photo
embargoed by Wah Chang.
1130 - Mobe to Soil Amendment Area - North on Old Salem Highway then east on Conser Road, 0.25 miles.
1134- PHOTO 336 - View southeast across the soil amendment area
1140 - Break for lunch
1238 PHOTO - 337 - View north across constructed wetlands which receives effluent from Wah Chang Cell 3 and City of
Albany for polishing prior to discharge to the Willamette River -wetlands are wildlife filled public attraction named
"Talking Water Gardens"
1251- Mobe to area between 1-5 and Old Salem Road - Visit MW-01A-found yellow barrier posts, steel casing, well
was locked, straight well with slight twist to the north, water visible in bottom.
-------
1255 PHOTO 338 - Well FW-7 Extraction treatment shed showing GAC control panel - not currently in use - was to
protect specific neighbor prior to property acquisition from plant groundwater. Treatment was GAC through 2005, then
discharge was plumbed directly across Old Salem Highway into main plant for treatment. Shed and GAC have secondary
containment and leak detection equipment still visible.
1300 PHOTO - 339 - View west from FW-7 to plant showing treatment shed and security fencing.
1305 - Visit MW-10A - Found yellow barrier posts, well locked, steel casing cap, visible measurement point
1306 - Visit MW-05A - Yellow barrier posts present, locked well, steel protective casing, sealing well cap in place,
cement pad present
1320 - Mobe back into main plant site - Visit PW-35A - Flush completion - found no bolts, compromised cover, no lock
and no marking
1323 - Visit FW-4 - well has sealing cap installed - Treatment building found to have control equipment and observed
equalization tanks.
1324 - Visit PW-30A - found yellow barrier posts, above grade completion, well found locked, 4-inch PVC - marked
measurement point.
-------
1326 - PHOTO 340 - Interior of treatment building for FW-4 with metering injection equipment and equalization tanks
visible
1327 - PHOTO - 341 - Treatment building for FW-4 - view to south across PW-30A to treatment building and dump
master area
1332 - PHOTO -342 - View of PW-91A- Flush completion - labeled on inside lid, found holding water, found locked cap
inside, but improvements to sealing should be made to preclude ingress of water.
-------
1340 - Visit PW-75 - No label visible at first - found label on cap after removing mud - flooded flush completion found,,
without bolts, sealing cap found locked on casing - however lock not usable - corroded - cap slips off for access. Well
requires repair to protect integrity of monitoring program
1345 - PHOTO 343 - View to south of Truax Creek in Dump Master Area flowing west - showing confluence from
multiple conduits under Old Salem Road
1347 - PHOTO 344 - View northwest across emergency services parking lot across PW-73A and PW-73B toward process
water Cooling pond - Building 122 - cobalt 60 source storage building in background. This parking lot was the site of
PCB removal
1352 - PHOTO - 345 - View across FW-1 to well shed for FW-1. Observed totalizer, equalizations tanks, filtration.
Discharge is routed to cooling tower, spare filters are stored. Shed is equipped with secondary containment.
-------
1358 - PHOTO 346 - Current Crucible Cleaning Area - view to southwest showing crucible storage from PW-95A
1401 - Visit to PW-95A - well labeled with spray paint on the pavement-flush completion found water present in vault
just below the level of the sealing cap - cap present and locked. Lock is rusted but still usable. Water ingress is a
concern.
1405 - Visit PW-69A - Man hole covered - not removed for inspection - Noel reported a 5 gallon bucket us used to
remove standing water prior to unsealing the well for sampling.
1415 - stopped to pick up Geoff Brown, ODEQfrom visitor center,
1428 - Visit PW-101A - Newest well in system - installed for EISB monitoring - bolts found to be in good condition, flush
completion, white cover present, well opened, lock open on bottom and corroded. Sealing cp present on 2-inch PVC
casing. No label seen - gasket good and apparently functioning.
1436 - Visit PW93A - In-house manufactured cover to attempt to find a design which can withstand heavy equipment
traffic. Good strong design, but not water proof. Vault found full of water, locked sealing cap in place and functioning.
PW-100 in vicinity also visited, but under pallets and not opened.
1437 - PHOTO 347 - View to southwest from PW-93A and in direction of calculated groundwater flow with presumed
Crucible Cleaning Area Source to the right and injection points array for the EISB project east and west of this
-------
1440 - PHOTO 348 - View across Crucible Cleaning Plaza to east along 2nd line of injection point and across well PW-93A
1500-mobe to north end of plant for assessment of former Deep Hole Boring Machine UST site with QDEQ
1530 PHOTO 350-Testing for nature of stream bed prior to deciding if mini-wells or other techniques would be suitable
for assessing discharge of the northern Fabrication Area plume into Murder Creek. Also part of the Deep Hole Boring
Machine assessment for close-out of that SWMU with ODEQ. Streambed found to be largely very soft materials
recently deposited at the waning stages of the severe flooding which occurred last winter.
1549 - mobe to Farm Ponds Area - north on Old Salem Road, west on Arnold Lane
1606 - Visit well SS and discuss remediation of this solvent source area, approaches to confirmation sampling,
discrepancies in the analytical data including an unexplained drop in concentrations the last several rounds and
approaches for assessing impacts to groundwater from the ongoing source. Well found with no barrier posts, well in
steel casing, found locked, active paper wasp nest inside cover.
-------
1620 - PHOTO - 351 - Farm Ponds Area
and waste storage pad.
- view to north across remediated pond system showing non-hazardous soii
1621 - PHOTO 352 - View west from southeast corner of former Farm Ponds Area toward berm remnant. Photo is
facing wells PW-40A and PW-40S with yellow barrier posts visible
/V .
. . . ;
1625 - Demobe to Main Plant
1630 - Visit Acid Sump Area with Geoff Brown, ODEQ to discuss remediation issues such as NAPL recalcitrance to EISB
remediation. Visit PW-13 - well requires recompletion. No bolts are present, threads stripped, unsealed vault, well cap
fits into casing exactly - no vault space - suggest rehabilitation with appropriate sized vault to provide protection from
ingress of surface water.
1639 - PHOTO 353 - View of Acid Sump courtyard across TMW-1 toward acid tanks and II and toward PW-11
-------
1641 - PHOTO 354 View from PW-13 to the northeast to the northeast corner of the Acid Sump Courtyard
1645 - PHOTO 356 (Photo 355 deleted on site to better capture intended well pattern in courtyard) View southeast
from area of PW-13 to show injection well in foreground toward the more distant TMW-4 and 1-1 - the center of the
apparent NAPL solvent source material which wili require excavation or another remedial approach to achieve a
protective remedy in this area
-------
1652 PHOTO #57 - View to the northeast from the southeast corner of the Acid Sump Courtyard with acid tanks and
piping and loading facilities visible - underground piping is also present in this area
1700 - Deadline to be out of operating plant site achieved. Returned to Administration Building - off site 1730, June 7,
2012
End of Site Inspection Chronology
June 8, 2012 - On site at Wah Chang
0730 - Meet Noel Mak for review of outstanding issues and questions, review of records and discussion of observations
Outstanding Issues and Resolution
V-2 Pond - Ground-water monitoring wells - PW-21A and PW-22A appear well located to monitor perimeter
concentrations - concentrations appear to be decreasing with time. No recent exceedances
MEMTEK Process - Question on disposition of waste streams - awaiting diagram of process from facility.
Examined the diagram on site.
Well SS - Monitoring results discrepancy - possible analytical or sampling change to explain significant drop in
observed VOC concentrations - no explanation. Well is about to be removed along with the source material.
The area will undergo confirmation sampling followed by an assessment of any potential dissolved plume which
may remain.
LRSP/Schmidt Lake - Question on the adequacy of analyte list and well pattern. Suggest revisiting the RIFS
analyte list for one round for this 5-year review to address potential for unmonitored COCs to have migrated
into or across the area.
Records of Soils Excavation tracking system and evidence of ongoing testing. Examined records which appear to
be congruent with the wording of the remedy.
Progress on ICs- Deferred until conversation with Ravi, Wah Chang PM.
Functionality of the Groundwater Extraction and Treatment System (GETS) - on hold awaiting the outcome of
the EISB remedial action. Results for all plumes are on track to achieve remedial goals with the exception of
Acid Sump Area plume discharging to the north across the Fabrication Area.
FMA Remedy - Remedy modification in this area appears to be an adequate approach for reaching the pH
targets and reduced mobility of metals called for in the ROD.
-------
Acid Sump Remedy - evaluation of the well pattern, trend data and data from wells in the source area indicate
that this remedy component is unlikely to achieve cleanup goals in the ROD timeframe. Additional actions are
expected to be necessary in the Acid Sump Area source to remove the NAPL source as well as additional action
to address solvent discharge across the northern boundary into Murder Creek. Recommend adding an
additional monitoring point along the northern boundary between PW-77A and PW-78A to assess
concentrations at mid plume.
PCB source at the Emergency Services Building and distributed PCBs across site: Ongoing testing as each
excavation is advanced appears to be functioning as defined by the ROD
EISB in Crucible Cleaning Area - EISB appears to be removing dissolved CVOCs at a rate which would achieve
cleanup in the timeframe developed in the ROD.
Requested O&M costs for remediation and ground-water treatment for the period of the 5-year review. Costs
not yet received. However, this item is usually included in the review to provide an early notice of issues with
the remedy. We have already determined that the ROD timeframe is unlikely to be met without the specific
modifications noted for the Feed Makeup Area and Acid Sump Area. This data-gap is therefore not considered
significant.
Exit Interview
Discussed with Noel Mak the perimeter control to Murder Creek and potential new well in this area to address
uncertainty with discharge. Discussed maintenance issues with monitoring wells (particularly the challenges with flush
completions in areas of high traffic), specifically the integrity of covers, seals labels and locks and the importance of
these items to the representativeness of the samples obtained in the groundwater monitoring program.
End of Report - Curt Black
June 21, 2012
-------
FIGURES
-------
CONSER RD
Soil Amendment Area
Farm Pond Area
~o
03
O
DC
E
0)
nj
if)
MURDER
CREEK DR
/
/
V
I
'v
\
xM
qy^
,o
>-5
Fabrication Area
V x
\
w
<Ł-
7>
&
'I
McMinnv$6t
Tigard
Portland
ťSalem
N^ivpo it
Wa ypuft
cjCalto
Site Location
M,li CUy
_Eugene
G>4kndgŤ
VQnfdl j
-Solids Area
\
s§->.
Extraction Area-
Front Parking
DATE: May, 2012 FILE: P:\GIS\Projects\415_WahChang\MXD\FiveYearReview\F_3-1_site.mxd
1,000
Figure 3-1
Site Location
Five Year Review Report
Wah Chang, Albany, Oregon
Scale in Feet
-------
'Acid Sump
Material Recycle
CoGen
'Facility
Ammonia
'Sulfate Area
Former
Crucible
Cleaning
Area
SaPP Oee,
Dump
Master
Feed
Makeup
Area
South
'Extraction
Area
-f^Cree.k
N
500
Scale in Feet
Figure 3-2
Main Plant Site Areas
Wah Chang Five Year Review
Albany, Oregon
-------
DATE: March, 2012 FILE: P:\GIS\Projects\415_WahChang\MXD\FiveYearReview\F_3-3_Spring_2010_GWE.mxd
Scale in Feet
Monitoring Wells and Spring 2010 Groundwater Elevation (feet msl)
Spring 2010 Groundwater Elevation Contour (feet msl)
Figure 3-3
Spring 2010 Groundwater Elevation
Main Plant
Wah Chang
Albany, Oregon
PW-17B
](NM)
PWA
/(NM)
PW-18B
/( NM)
PWD
/(NM)
PWB
/(NM)
PWC
/(NM)
PWE
/(NM)
PW-09
/(NM)
PW-07
/(NM)
PWF
/(NM)
-------
PW-33A
(202.6 8)
,f?Vtf-98A
(200.48)
PW-07
(190W)
pw-8-m
<5*199.48?
PW-704R
(200.21 p-
, PWB-2
(175.59)
PWE-1
(167.43)
PW-68A
(199>5).
PW^OA
J190.8$f
PWF-1
(185.42)
llfW-87A
M 96.26)
(,186r0i
MW-06A
^ MW-1 OA (195.3)
(194.41) Ž )
/ PW-28A
t / (192.92)
* EW-1
(=^193,65)
MW-09A
(194.39)
PW-52A
(194.1)
PW-29A
(195.49)
PW-47A
(186.'7.8)
DATE: March, 2012 FILE: P:\GIS\Projects\415_WahChang\MXD\FiveYearReview\F_3-4_Fail_2010_GWE.mxd
Ž Monitoring Well with groundwater elevation in feet msl
Fall 2010 Groundwater Elevation (feet msl)
Scale in Feet
Figure 3-4
Fall 2010 Groundwater Elevation
Main Plant
Wah Chang
Albany, Oregon
-------
PW-43A
'(199)02)
PW-43^
(202.63)
PW-40A/ ,PW-40S
(199.89) (203.5)
PW-44A \
(203.28) NT;
PW-44S*
(200.66)
DATE: March, 2012 FILE: P:\GIS\Projects\415_WahChang\MXD\FiveYearReview\F_3-5_Fall_2010_GWE_Farm.mxd
Former Farm
Ponds Location
N
Scale in Feet
Ž Monitoring Well with groundwater elevation (feet msl)
Groundwater Elevation (feet msl)
Ground Elevation Contour (5 feet contour)
500
Figure 3-5
Fall 2010 Groundwater Elevation
Farm Ponds
Wah Chang
Albany, Oregon
-------
HvV-b/A
PW-86A
FW-2
PW-89A
PW-88A
PW-21A
PW-73A
PW-74A
PW-74B
PW-22A
EW-3
PW-50A
^PW-28B
^PW-28A
! EW-1
PW-91A
EW-2
PW-23A
PW-52A
PW-51A
PW-27A
PW-24A
PW-25A
PW-93A
PW-96A
PW-97A
PW-47A
PW-57A
EW-5
PW-26A
EW-4
PW-48A
PW-49A
Date: March, 2012 P:\GIS\Projects\415_WahChang\MXD\FiveYearReview\F_7-1_ExtArea.mxd
N
Scale in Feet
250
5
a Extraction Well
Monitoring Well
Figure 6-1
Extraction Area
Wah Chang Five Year Review
Albany, Oregon
-------
9
8
7
6
5
4
3
2
1
0
8.5 pH
6.5 pH
PW-22A
PW-23A
PW-24A
PW-27A
PW-28A
PW-50A
* PW-51A
PW-52A
^^6.5 pH
average
i i i i i i i i
02 Jan-03 Jan-04 Jan-05 Jan-06 Jan-07 Jan-08 Jan-09 Jan-10
Figure 6-2. FMA pH Level
in Groundwater
-------
25
Ś EW-01 EW-02 EW-03 Figure 6-3. Concentration of Fluoride (F)
in Groundwater in the FMA
X -PW-22A PW-23A ROD
-------
Jan-02
Jan-03
Jan-04
Jan-05
Ś PW-27A "O" PW-28A PW-28A
PW-50A PW-52A ROD
0
Jan-08
Jan-09
Jan-10
Jan-11
Figure 6-4. Concentration of Fluoride (F) in
Groundwater in the FMA
-------
Jan-02 Jan-03
PW-28A
Jan-05 Jan
PW-51A
A PW-52A
ŚROD
Figure 6-5. Concentration of Total Radium 226 and
Radium 228 in Groundwater in the FMA
-------
40
So
X
\/
A'
Śtsr
\ /
~
. A
Jan-02
Jan-03 Jan-04 Jan-05 Jan-06 Jan-07 Jan-08 Jan-09 Jan-10
Jan-11
PW-47A
PW-97A
A PW-57A
ŚROD
PW-96A
Figure 6-6. Concentration of DCE in Non-
Hot spot wells in SEA
-------
90
80
70
60
50
40
30
20
10
0
PW-47A
PW-97A
-A PW-57A
ŚROD
PW-96A
Figure 6-7. Concentration of TCE in Non-
Hot spot wells in SEA
-------
PW-15AR
Former
Crucible
'Cleaning
Area
PW-70AR
Material
Recycle
PW-71AŠ
ŚPW-42A
AmmoriiurR"
fw-5 Sulfate Storage
Fw-2,r
>PW-89A
iMW-03A
PW-45A
MW-02A-Ž
.SW-02 MW-05A
MW-04A
PW-46A
MW-06A
FW-4
Dump
Master
MW-09A
Dal
N
Scale in Feet
250
A Extraction Well
Ž Monitoring Well
Figure 6-8
Fabrication Area
Wah Chang Five Year Review
Albany, Oregon
-------
DCE
10000
SŁ
1000
100
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MW-02A >X MW-04A
Ś PW-100A <> PW-45A A" PW-69A
Ś PW-93A
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ROD
PCE
100
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10
"'t **"*A
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-"k." PW-69A
. PW-93A
ROD
TCA
100000
1
~
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m
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m
m
LD
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to
to
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C 3
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C 3
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A" PW-69A ~ PW-93A PW-94A PW-95A ROD
Figure 6-9. VOC Concentrations for Former Crucible Cleaning
Area Hot Spot Wells in the Fabrication Area
-------
TCE
1000
100
S 10 A...
Ť. .
A.
* * A-.>* ;>7
/ ,1 A
V / * * / \
^^^
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~ PW-69A
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vc
1000
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1
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C 3
C 3
O
C 3
C 3
o
C 3
o
C 3
C 3
C 3
o
C 3
C 3
C 3
o
C 3
O
C 3
C 3
C 3
C 3
C 3
C 3
C 3
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
ti
ti
ti
ti
ti
tI
ti
ti
ti
tI
tI
tI
ti
tI
tI
ti
ti
ti
ti
ti
ti
T1
T1
T1
T1
T1
T1
T1
T1
tI
tI
ti
ti
ti
ti
ti
ti
O
ti
r*>
o
tI
Śvf
r*>
o
tI
r*>
o
tI
r*>
o
ti
r*>
o
T1
r*>
o
T1
r*>
o
tI
r*>
O
ti
Śvf
r*>
O
tl
T1
T1
T1
T1
T1
T1
T1
tl
tl
MW-02A
-X-
MW-04A -
- PW-100A
<>
PW-45A
1
A"
PW-69A
PW-93A
PW-94A
-A-
PW-95A -
-ROD
Figure 6-9. VOC Concentrations for Former Crucible Cleaning
Area Hot Spot Wells in the Fabrication Area
-------
DCE
rvj
m
m
m
m
lO
lO
LD
lO
tO
tO
tO
tO
r*>
r*>
r*>
r*>
00
00
00
00
CD
CD
CD
CD
O
O
O
O
ti
ti
ti
ti
O
o
o
o
o
o
O
O
O
o
o
O
O
O
o
O
O
o
o
o
o
o
o
o
o
O
O
o
o
tI
tl
tl
tl
ti
ti
ti
ti
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
r\]
r\j
r\j
r\j
rvj
r\]
r\]
r\]
r\]
rvj
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\j
r\j
rvj
r\j
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
rvj
r\]
r\]
r\]
rvj
rvj
r\]
r\]
ti
ti
ti
ti
ti
ti
ti
ti
ti
tI
tI
ti
tI
ti
ti
ti
ti
ti
ti
ti
ti
ti
ti
ti
ti
T1
T1
T1
T1
ti
ti
ti
ti
ti
ti
ti
ti
o 1 r-> o *-I'vtr^o*i^r^o*-i^r^o
PW-ll Ś PW-12 -A- PW-13 -ŤX- PW-99A ROD
PCE
100
TCA
10000
rvj
m
m
m
m
LD
LO
LD
LD
tO
tO
to
to
r*>
r*>
r*>
r*>
00
00
00
00
CD
CD
CD
CD
o
o
o
o
T1
T1
T1
T1
O
o
o
o
o
o
O
O
O
O
O
O
O
o
o
o
o
O
o
o
o
o
o
o
o
o
o
o
o
T1
T1
T1
T1
T1
T1
T1
T1
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
ti
ti
ti
ti
ti
ti
ti
ti
ti
T1
T1
T1
T1
T1
T1
T1
T1
ti
ti
ti
ti
T1
T1
T1
T1
T1
T1
T1
T1
T1
T1
T1
T1
T1
T1
T1
T1
o *--i o *~~i o *~~i o *~~ii^"f>*>o*ii^"f>*>o*i^"f>->o*i^"f>*>o*i o *~~i o
PW-12 PW-13 ROD
Figure 6-10. VOC Concentrations for Acid Sump Area
Hot Spot Wells in the Fabrication Area
-------
TCE
Figure 6-10. VOC Concentrations for Acid Sump Area
Hot Spot Wells in the Fabrication Area
-------
DCE
1000
rvj
m
m
m
m
lO
lO
LD
lO
tO
tO
tO
tO
r*>
r*>
r*>
r*>
00
00
00
00
CD
CD
CD
CD
O
O
O
O
ti
ti
ti
ti
O
o
o
o
o
o
O
O
O
o
o
O
O
O
O
O
O
o
o
o
o
o
o
o
o
O
O
o
o
tI
tl
tl
tl
ti
ti
ti
ti
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
r\]
r\j
r\j
r\j
r\j
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\j
r\j
r\j
r\j
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
ti
ti
ti
ti
ti
ti
ti
ti
ti
tI
tI
ti
tI
ti
ti
ti
ti
ti
ti
ti
ti
ti
ti
ti
ti
T1
T1
T1
T1
ti
ti
ti
ti
ti
ti
ti
ti
o I'vtr^o*-i^r^o*I'vtr^o*i^r^o*-i^r^o
PW-01A ROD
TCE
100
vc
100
Figure 6-11. VOC Concentrations for Ammonium Sulfate Area
Hot Spot Wells in the Fabrication Area
-------
DCE
1000
100
10
rvj
m
m
m
m
LD
lO
LD
lO
tO
tO
tO
tO
p^
P^
P^
P^
00
00
00
00
CD
CD
CD
CD
O
O
O
O
tl
ti
ti
ti
O
o
o
o
o
o
O
O
O
O
O
O
O
O
o
O
O
o
O
O
O
o
o
o
o
O
O
O
o
tI
tl
tl
tl
tl
ti
ti
ti
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
O
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
r\]
r\j
rvj
r\j
r\j
r\]
r\]
rvj
r\]
r\]
r\]
r\]
r\j
r\]
r\]
r\]
r\j
r\]
r\]
rvj
r\j
r\]
r\]
r\]
r\]
r\]
r\]
rvj
r\]
r\]
r\]
rvj
r\]
rvj
r\]
rvj
rvj
i
i
i
i
i
tI
tI
ti
ti
tI
tI
ti
tI
ti
ti
ti
tI
tI
ti
ti
ti
tI
ti
ti
ti
tI
T1
T1
T1
ti
ti
ti
ti
ti
ti
ti
ti
O
i
Śvf
o
tI
O
tI
O
ti
Śvf
O
tI
Śvf
P^
O
tI
Śvf
P^
o
tI
p^
o
ti
Śvf
P^
O
ti
Śvf
P*>
O
l
T1
tl
tl
tl
tl
T1
T1
tl
tl
~ PW-30A
-Ś-PW-73B
ROD
TCA
10000
1000
DO 100
10
rvj
m
m
m
m
LD
lO
LD
LD
tO
tO
tO
tO
P^
P^
P^
P^
00
00
00
00
CD
CD
CD
CD
O
O
O
O
tI
tI
ti
ti
O
o
o
o
o
o
O
O
O
O
o
O
O
O
O
O
O
O
O
O
O
o
o
o
o
O
O
O
O
tl
tl
tl
tl
tI
tI
ti
ti
O
o
o
o
o
o
o
o
o
O
o
O
O
O
O
O
O
o
o
o
o
o
o
o
o
O
O
O
O
o
o
o
o
O
O
O
O
rsj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
tI
ti
ti
ti
ti
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
ti
ti
ti
PW-30A
Ś ROD
TCE
100
10
bjo
rvj
m
m
m
m
lO
lO
lO
lO
tO
to
to
p*>
P^
P^
P^
00
00
00
00
CD
CD
CD
CD
o
o
o
o
T1
T1
T1
T1
O
o
o
o
o
o
O
O
O
o
o
o
o
O
O
O
o
O
O
O
O
o
o
o
o
o
o
o
o
T1
T1
T1
T1
T1
T1
T1
T1
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
ti
ti
ti
ti
ti
ti
ti
ti
ti
tI
tI
tI
tI
T1
T1
T1
T1
ti
ti
ti
ti
T1
T1
T1
T1
T1
T1
T1
T1
T1
T1
T1
T1
T1
T1
T1
T1
ŚPW-73B
ŚROD
Figure 6-12. VOC Concentrations for Dump Master Area
Hot Spot Wells in the Fabrication Area
-------
vc
100
rvj
m
m
m
m
lO
lO
lO
lO
tO
tO
tO
tO
r*>
r*>
r*>
r*>
00
00
00
00
CD
CD
CD
CD
O
O
O
O
tI
tI
ti
ti
O
o
o
o
o
o
O
O
O
o
o
o
o
O
O
O
O
o
o
o
o
o
o
o
o
O
O
O
O
tl
tl
tl
tl
tI
tI
ti
ti
O
o
o
o
o
o
o
o
o
o
o
o
o
O
O
O
O
o
o
o
o
o
o
o
o
O
O
O
O
o
o
o
o
O
O
O
O
rsj
r\j
r\j
r\j
r\j
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\j
r\j
r\j
r\j
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
ti
ti
ti
ti
ti
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
ti
ti
ti
ti
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
ti
ti
ti
o I'vtr^o*-i^r^o*I'vtr^o*i^r^o*-i^r^o
PW-30A ^HPW-73B ROD
Figure 6-12. VOC Concentrations for Dump Master Area
Hot Spot Wells in the Fabrication Area
-------
TCE
10000
rvj
m
m
m
m
LD
lO
LD
LD
tO
tO
tO
tO
r*>
r*>
r*>
r*>
00
00
00
00
CD
CD
CD
CD
O
O
O
O
tI
tI
ti
ti
O
o
o
o
o
o
O
O
O
O
o
O
O
O
O
O
O
o
o
o
o
o
o
o
o
O
O
O
O
tl
tl
tl
tl
tI
tI
ti
ti
O
o
o
o
o
o
o
o
o
O
o
O
O
O
O
O
O
o
o
o
o
o
o
o
o
O
O
O
O
o
o
o
o
O
O
O
O
rsj
r\j
r\j
r\j
r\j
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\j
r\j
r\j
r\j
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
ti
ti
ti
ti
ti
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
ti
ti
ti
ti
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
ti
ti
ti
o I'vtr^o*-i^r^o*I'vtr^o*i^r^o*-i^r^o
PW-42A ^HPW-85A -^PW-86A ROD
vc
100
rvj
m
m
m
m
lO
lO
lO
lO
tO
to
to
to
r*>
r*>
r*>
r*>
00
00
00
00
CD
CD
CD
CD
o
o
o
o
T1
T1
T1
T1
O
o
o
o
o
o
O
O
O
o
o
o
o
O
O
O
o
O
o
o
o
o
o
o
o
o
o
o
o
T1
T1
T1
T1
T1
T1
T1
T1
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
ti
ti
ti
ti
ti
ti
ti
ti
ti
tI
tI
tI
tI
T1
T1
T1
T1
ti
ti
ti
ti
T1
T1
T1
T1
T1
T1
T1
T1
T1
T1
T1
T1
T1
T1
T1
T1
o *--i o *~~i o *~~i^r^o*ii^"f>*>o*ii^"f>*>o*i^"f>*>o*i^"f>*>o*i o *~~i o
PW-42A -&- PW-86A ROD
Figure 6-13. VOC Concentrations for Material Recycle Area
Hot Spot Wells in the Fabrication Area
-------
DCE
1000
100
10
rvj
m
m
m
m
lO
lO
LD
lO
tO
tO
tO
tO
r*>
00
00
00
00
CD
CD
CD
CD
O
O
O
O
ti
ti
ti
ti
O
o
o
o
o
o
O
O
O
o
o
O
O
O
O
o
O
O
O
O
o
o
o
o
o
O
O
o
o
tI
tl
tl
tl
ti
ti
ti
ti
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
r\]
r\j
r\j
r\j
r\j
rvj
r\]
r\]
r\]
r\]
rvj
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
rvj
rvj
r\]
r\]
r\]
r\]
r\]
r\]
r\]
rvj
rvj
r\]
r\]
r\]
rvj
rvj
r\]
i
i
i
i
i
i
i
i
ti
tI
tI
ti
tI
ti
ti
ti
ti
ti
ti
ti
ti
ti
ti
ti
ti
T1
T1
T1
T1
ti
ti
ti
ti
ti
ti
ti
ti
PW-101A
ŚROD
PCE
10
bjo
rvj
m
m
m
m
lO
lO
lO
lO
tO
tO
tO
tO
P^
P^
P^
00
00
00
00
CD
CD
CD
CD
O
O
O
O
tI
tI
ti
ti
O
o
o
o
o
o
O
O
O
o
o
o
o
O
O
O
O
O
O
O
O
o
o
o
o
O
O
O
O
tl
tl
tl
tl
tI
tI
ti
ti
O
o
o
o
o
o
o
o
o
o
o
o
o
O
O
O
O
o
o
o
o
o
o
o
o
O
O
O
O
o
o
o
o
O
O
O
O
rsj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
ti
ti
ti
ti
ti
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
ti
ti
ti
PW-101A
ROD
vc
100
10
bjo
rvj
m
m
m
m
lO
lO
lO
lO
to
tO
to
to
P*>
P^
P^
P^
00
00
00
00
CD
CD
CD
CD
o
o
o
o
T1
T1
T1
T1
O
o
o
o
o
o
O
O
O
o
o
o
o
o
o
o
o
O
O
O
O
o
o
o
o
o
o
o
o
T1
T1
T1
T1
T1
T1
T1
T1
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
ti
ti
ti
ti
ti
ti
ti
ti
ti
tI
tI
tI
tI
ti
ti
ti
ti
ti
ti
ti
ti
T1
T1
T1
T1
T1
T1
T1
T1
T1
T1
T1
T1
T1
T1
T1
T1
PW-101A
'ROD
Figure 6-14. VOC Concentrations for Former Crucible Cleaning
Area Non-Hot Spot Wells in the Fabrication Area
-------
DCE
10000
1000
100
rvj
m
m
m
m
LD
lO
LD
LD
tO
tO
tO
tO
r*>
00
00
00
00
CD
CD
CD
CD
o
O
O
O
ti
ti
ti
ti
O
o
o
o
o
o
O
O
O
O
O
O
O
O
O
O
O
o
O
O
O
o
o
o
o
O
O
O
o
T1
tl
tl
tl
ti
ti
ti
ti
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
r\]
r\j
rvj
r\j
r\j
r\]
r\]
rvj
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
rvj
rvj
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
rvj
r\]
r\]
r\]
rvj
rvj
r\]
r\]
r\]
rvj
ti
ti
ti
ti
ti
ti
ti
ti
ti
ti
tI
ti
T1
ti
ti
ti
ti
ti
ti
ti
ti
ti
ti
ti
ti
ti
T1
T1
T1
ti
ti
ti
ti
ti
ti
ti
ti
o*i^r^o*-i^r^o
PW-10 ^HPW-80A Ł PW-98A ROD
PCE
100
rvj
m
m
m
m
lO
lO
lO
lO
tO
tO
to
to
r*>
P^
P*>
00
00
00
00
CD
CD
CD
CD
O
O
O
O
tI
tI
ti
ti
O
o
o
o
o
O
O
O
O
o
o
o
o
o
o
o
o
o
O
O
O
o
o
o
o
O
O
O
O
tl
tl
tl
tl
tI
tI
ti
ti
O
o
o
o
o
o
o
o
o
o
o
o
o
o
o
o
o
o
o
o
o
o
o
o
o
O
O
O
O
o
o
o
o
O
O
O
O
rsj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
ti
ti
tI
ti
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
ti
ti
ti
o*I'vtr^o*-i^r^o*-i^r^o*-i^r^o*I'vtr^o*i^r^o*-i^r^o*-i^r^o
PW-98A ROD
TCA
1000
100
10
rvj
m
m
m
m
lO
lO
LD
LO
to
to
to
to
p*>
p^
P^
P*>
00
00
00
00
CD
CD
CD
CD
o
o
o
o
T1
T1
T1
T1
O
o
o
o
o
o
O
O
O
o
o
O
O
o
o
o
o
O
O
O
O
o
o
o
o
o
o
o
o
T1
T1
T1
T1
T1
T1
T1
T1
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
ti
ti
ti
ti
ti
ti
ti
ti
ti
tI
tI
T1
T1
T1
T1
T1
T1
T1
ti
ti
ti
T1
T1
T1
T1
T1
T1
T1
T1
T1
T1
T1
T1
T1
T1
T1
T1
o *--i o *~~i o *~~i^r^o*ii^"f>*>o*ii^"f>*>o*i^"f>*>o*i^"f>*>o*i^r^o^H^r^o
-6- PW-98A ROD
Figure 6-15. VOC Concentrations for Acid Sump Area
Non-Hot Spot Wells in the Fabrication Area
-------
TCE
1000
100
bjo
i
10
vc
1000
rvj
m
m
m
m
lO
lO
LD
lO
to
tO
tO
tO
r*>
00
00
00
00
CD
CD
CD
CD
O
O
O
O
ti
ti
ti
ti
O
o
o
o
o
o
O
O
O
o
o
O
O
o
O
O
O
O
o
O
O
o
o
o
o
O
O
o
o
tI
tl
tl
tl
ti
ti
ti
ti
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
r\]
r\]
r\j
r\]
r\j
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
ti
ti
ti
ti
ti
ti
ti
ti
ti
tI
tI
ti
tI
ti
ti
ti
ti
ti
ti
ti
ti
ti
ti
ti
ti
T1
T1
T1
T1
ti
ti
ti
ti
ti
ti
ti
ti
o*i^r^o*-i^r^o
-6- PW-98A ROD
Figure 6-15. VOC Concentrations for Acid Sump Area
Non-Hot Spot Wells in the Fabrication Area
-------
DCE
10000
PCE
100
rvj
m
m
m
m
lO
lO
lO
lO
tO
tO
tO
tO
00
00
00
00
CD
CD
CD
CD
O
O
O
O
tI
tI
ti
ti
O
o
o
o
o
o
O
O
O
o
o
o
o
O
O
O
O
O
O
O
O
o
o
o
o
O
O
O
O
tl
tl
tl
tl
tI
tI
ti
ti
O
o
o
o
o
o
o
o
o
o
o
o
o
O
O
O
O
o
o
o
o
o
o
o
o
O
O
O
O
o
o
o
o
O
O
O
O
rsj
r\j
r\j
r\j
r\j
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
ti
ti
ti
ti
ti
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
ti
ti
ti
o*i^r^o*-i^r^o
-X- PW-91A ROD
TCA
100000
v
10000
i\
^ mn X'---Xť
m 100 ť*ť
1000 1t
^^ tr
v^AŤ4 /V
/
* / *
10
/
">C7
' >.
/ ~ X.
17 ^Ťx-x
X
\ -x ;
X-'" X
rvj
m
m
m
m
LD
LD
LD
LD
tO
tO
to
to
p*>
P^
P^
P^
00
00
00
00
CD
CD
CD
CD
o
o
o
o
T1
T1
T1
T1
O
o
o
o
o
o
O
O
O
O
O
O
O
o
o
o
o
O
O
O
O
o
o
o
o
o
o
o
o
T1
T1
T1
T1
T1
T1
T1
T1
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
ti
ti
ti
ti
ti
ti
ti
ti
ti
T1
T1
T1
T1
T1
T1
T1
T1
ti
ti
ti
ti
T1
T1
T1
T1
T1
T1
T1
T1
T1
T1
T1
T1
T1
T1
T1
T1
o r-v o
>X- PW-91A ROD
Figure 6-16. VOC Concentrations for Dump Master Area
Non-Hot Spot Wells in the Fabrication Area
-------
TCE
100
10
bjo
i
x' ^xXX-X
rvj
m
m
m
m
lO
lO
lO
lO
tO
tO
tO
tO
r*>
r*>
r*>
r*>
00
00
00
00
CD
CD
CD
CD
O
O
O
O
tI
tI
ti
ti
O
o
o
o
o
o
O
O
O
o
o
o
o
O
O
O
O
o
o
o
o
o
o
o
o
O
O
O
O
tl
tl
tl
tl
tI
tI
ti
ti
O
o
o
o
o
o
o
o
o
o
o
o
o
O
O
O
O
o
o
o
o
o
o
o
o
O
O
O
O
o
o
o
o
O
O
O
O
rsj
r\j
r\j
r\j
r\j
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\j
r\j
r\j
r\j
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
ti
ti
ti
ti
ti
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
ti
ti
ti
ti
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
ti
ti
ti
PW-46A
ŚX- PW-91A
ROD
vc
100
rvj
m
m
m
m
lO
lO
lO
lO
tO
to
to
to
r*>
r*>
r*>
r*>
00
00
00
00
CD
CD
CD
CD
o
o
o
o
T1
T1
T1
T1
O
o
o
o
o
o
O
O
O
o
o
o
o
O
O
O
O
o
o
o
o
o
o
o
o
o
o
o
o
T1
T1
T1
T1
T1
T1
T1
T1
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
ti
ti
ti
ti
ti
ti
ti
ti
ti
tI
tI
tI
tI
T1
T1
T1
T1
ti
ti
ti
ti
T1
T1
T1
T1
T1
T1
T1
T1
T1
T1
T1
T1
T1
T1
T1
T1
o i^r^o
PW-46A --X- PW-91A ROD
Figure 6-16. VOC Concentrations for Dump Master Area
Non-Hot Spot Wells in the Fabrication Area
-------
DCE
100
rvj
m
m
m
m
lO
lO
lO
lO
tO
tO
to
tO
r*>
r*>
r*>
r*>
00
00
00
00
CD
CD
CD
CD
O
O
O
O
ti
ti
ti
ti
O
o
o
o
o
o
O
O
O
o
o
o
o
O
O
o
O
o
o
o
o
o
o
o
o
O
O
o
o
tI
tl
tl
tl
ti
ti
ti
ti
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
C 3
r\]
r\j
r\j
r\j
r\j
rvj
r\]
r\]
r\]
r\]
rvj
r\]
r\]
r\]
r\]
r\]
r\]
r\j
r\j
r\j
rvj
r\]
r\]
r\]
r\]
r\]
r\]
r\]
r\]
rvj
rvj
r\]
r\]
r\]
rvj
rvj
r\]
ti
ti
ti
ti
ti
ti
ti
ti
ti
tI
tI
tI
tI
ti
ti
ti
ti
ti
ti
ti
ti
ti
ti
ti
ti
T1
T1
T1
T1
ti
ti
ti
ti
ti
ti
ti
ti
o I'vtr^o*-i^r^o*I'vtr^o*i^r^o*-i^r^o
PW-84A ROD
TCE
100
rvj
m
m
m
m
lO
lO
lO
lO
tO
tO
tO
tO
r*>
r*>
r*>
r*>
00
00
00
00
CD
CD
CD
CD
O
O
O
O
tI
tI
ti
ti
O
o
o
o
o
o
O
O
O
o
o
o
o
O
O
O
O
o
o
o
o
o
o
o
o
O
O
O
O
tl
tl
tl
tl
tI
tI
ti
ti
O
o
o
o
o
o
o
o
o
o
o
o
o
O
O
O
O
o
o
o
o
o
o
o
o
O
O
O
O
o
o
o
o
O
O
O
O
rsj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
rvj
ti
ti
ti
ti
ti
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
ti
ti
ti
ti
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
tI
ti
ti
ti
o I'vtr^o*-I'vtr^o*-I'vtr^o*-1 r-> o *-I'vtr^o*i^r^o*-i^r^o
PW-84A ^^PW-88A ROD
Figure 6-17. VOC Concentrations for Material Recycle Area
Non-Hot Spot Wells in the Fabrication Area
-------
90
80
70
60
50
40
30
20
10
0
PW-77A PW-78A A ťPW-79A ROD Figure 6-18. Concentration of DCE in Groundwater Perimeter
Wells in the Fabrication area
-------
90
80
70
60
50
40
30
20
10
0
^PW-77A <> PW-78A A -PW-79A ROD
Figure 6-19. Concentration of DCE in Groundwater Perimeter
wells in the Fabrication area
-------
TMW-4
40600
TMW-3
18000
DATE: May, 2012 FILE: P:\GIS\Projects\415_WahChang\MXD\FiveYearReview\F_6-20_Fab_DCE_2009.mxd
m§o
N
Scale in Feet
Monitoring Well with Concentration in pig/L
DCE Isoconcentration Line
ROD (7 jig/L)
Figure 6-19
DCE Concentrations, Fall 2009
Fabrication Area
Teledyne Wah Chang
Albany, Oregon
-------
DATE: May, 2012 FILE: P:\GIS\Projects\415_WahChang\MXD\FiveYearReview\F_6-21_Fab_TCE_2009.mxd
tffo
N
Scale in Feet
Monitoring Well with Concentration in |jg/L
TCE Isoconcentration Line
ROD (5 (jg/L)
Figure 6-20
TCE Concentrations, Fall 2009
Fabrication Area
Teledyne Wah Chang
Albany, Oregon
-------
71A
u
PW-100A
NS
PW-93A
14.7
DATE: May, 2012 FILE: PAGIS\Projects\415_WahChang\MXD\FiveYearReview\F_6-22_Fab_VC_2009.mxd
Scale in Feet
Fab_VC_2009
VC Isoconcentration Line
ROD (2 |ag/L)
Figure 6-21
VC Concentrations, Fall 2009
Fabrication Area
Teledyne Wah Chang
Albany, Oregon
-------
TMW-3 .
105000
Material Recycle
PW-03A
0.5 U Ammonium Sulfate Storage
Dump Master
DATE: May, 2012 FILE: PAGIS\Projects\415_WahChang\MXD\FiveYearReview\F_6-23_Fab_TCA_2009.mxd
Scale in Feet
Ž Monitoring Well with Concentration in jjg/L
TCA Isoconcentration Line
ROD (200 ng/L)
Figure 6-22
1,1,1 TCA Concentrations, Fall 2009
Fabrication Area
Teledyne Wah Chang
Albany, Oregon
-------
PW-76A
0.5 U
PW-77A
nr?-"
*aŁUI
PW-78A
46.2 P W-10
y, I 1.38
PW-S8A
245
PW-14
TMW-5
68.5
PW-79A
0.76
PW-13]
135
TMW-1
1853>
PW-16A
0.5 U
TMW-4
14700
TMW-3
12300
PW-80A
0.5 U
PW-99A
,143
PW-11
0.73
PW-12
175
PW-31A
0.5 U
PW-92A
0.5 U
PW-19A
0.5 LJ
PW-82A
o:5\y 1
PW-100A
81.4
PW-93A
-315
PW-71A
0.5 U
PW-83A
0.21 J
PW-84A
0;54
PW-101A
64.8
PW-42A
13.5/
PW-01A \wj
o 51 PW-85A
>8*39
PW-68A
0.5 U
l=W-95A
512 3,
PW-94A
8.12
MW-03A
0.5 U
PW-86A
0.5 U
PW-69A
28.6
PW-03A
0.5 U
PW-87A
0.5 LJ
PW-89A
0.5 U
PW-72A
PW-45A
0.5 U .
/A
PW-88A
0.5 U
MW-02A
35.6
MW-04A
12.4
PW-73B
1.28
PW-74B
0.63
PW-46A
3.48 a
MW-01A
0.12 J
PW-30A
8.4
PW-91A
0.33 J
PW-75A
3.67
DATE: May, 2012 FILE: P:\GIS\Projects\415_WahChang\MXD\FiveYearReview\F_6-24_Fab_DCE_2011 .mxd
Ś00
N
Scale in Feet
Monitoring We!! with Concentration in jjg/L
DCE Isoconcentration Line
ROD (7 |ig/L)
Figure 6-23
DCE Concentrations, Fall 2011
Fabrication Area
Teledyne Wah Chang
Albany, Oregon
-------
DATE: May, 2012 FILE: P:\GIS\Projects\415_WahChang\MXD\FiveYearReview\F_6-25_Fab_TCE_2011 .mxd
Śfo
N
Scale in Feet
Monitoring well with concentration in |_ig/L
TCE Isoconcentration Line
ROD (5 ug/L)
Figure 6-24
TCE Concentrations, Fall 2011
Fabrication Area
Teledyne Wah Chang
Albany, Oregon
-------
DATE: May, 2012 FILE: P:\GIS\Projects\415_WahChang\MXD\FiveYearReview\F_6-26_Fab_VC_2011 .mxd
Ś00
N
Scale in Feet
Monitoring Well with Concentration in ng/L
VC Isoconcentration Line
ROD (2 ng/L)
Figure 6-25
VC Concentrations, Fall 2011
Fabrication Area
Teledyne Wah Chang
Albany, Oregon
-------
TMW-4
168000
TMW-3
43000
DATE: May, 2012 FILE: P:\GIS\Projects\415_WahChang\MXD\FiveYearReview\F_6-27_Fab_TCA_2011 mxd
Śto
N
Note: Due to steep concentration gradient, TMW-1 is not used for contouring on this figure.
Monitoring Well with Concentration in jig/L
Scale in Feet
TCA Isonconcentration Line
ROD (200 jig/L)
Figure 6-26
TCA Concentrations, Fall 2011
Fabrication Area
Teledyne Wah Chang
Albany, Oregon
-------
TMW-4
14700
DATE: May, 2012 FILE: P:\GIS\Projects\415_WahChang\MXD\FiveYearReview\F_6-28_Fab_DCE.mxd
Ś00
N
Scale in Feet
Monitoring Well with 2011 DCE Concentration (|ig/L)
2011 ROD (7 ng/L)
~~ ~ 2009 ROD (7 [ig/L)
Figure 6-27
DCE Concentrations, Above ROD
Fall 2009 and 2011
Fabrication Area
Teledyne Wah Chang
Albany, Oregon
-------
| TM W-5
I1! L TMW-3
A-"""' 500 U
, PW-99A
y 0.5 u
TMW-4
1000 u
TMW-1
25 U
DATE: May, 2012 FILE: P:\GIS\Projects\415_WahChang\MXD\FiveYearReview\F_6-29_Fab_TCE.mxd
Śjf!)
N
Scale in Feet
Monitoring well with 2011 concentration in ng/L
2011 ROD (5 (jg/L)
_ " 2009 ROD (5 ng/L)
Figure 6-28
TCE Concentrations, Above ROD
Fall 2009 and 2011
Fabrication Area
Teledyne Wah Chang
Albany, Oregon
-------
Scale in Feet
Monitoring well with 2011 VC concentration (jig/L)
2011 ROD (2 |ig/L)
2009 ROD (2 |ig/L)
VC Concentrations Above ROD
Fall 2009 and 2011
Fabrication Area
Teledyne Wah Chang
Albany, Oregon
-------
TMVV-4
168000
TMVv-3
4300^.
DATE: May, 2012 FILE: P:\GIS\Projects\415_WahChang\MXD\FiveYearReview\F_6-31_Fab_TCA.mxd
Figure 6-30
TCA Concentrations Above ROD
* Monitoring Well with 2011 TCA concentration (ng/L) Fall 2009 and 2011
*f° 2011 ROD (200 |ig/L)
Fabrication Area
Scale in Feet Teledyne Wah Chang
2009 ROD (200 [ig/L) Albany, Oregon
-------
PW-99A
TMW-1
TMW-5
PW-13
PW-98A
PW-78A
o
E
E
O
'5
re
01
u
O
u
_ro
o
o
(0
01
u
o
u
_ns
o
01
u
01
a.
3.0
2.5
2.0
1.5
1.0
0.5
0.0
100%
90% --
80% --
70% --
60% --
50% --
40% --
30% --
20% --
10% -I-
0% -
160
120 --
80 --
40 --
160
120 --
80 --
40 --
_B B_
10.0
8.0
6.0
4.0
2.0
0.0
10.0
8.0 --
6.0 --
4.0 --
2.0 --
0.0
1.0
0.8
0.6
0.4
0.2
0.0
i i"i r
i1
July Dec May Dec May Nov
200920092010201020112011
July Dec May Dec May Nov
200920092010201020112011
July Dec May Dec May Nov
2009 2009 2010 2010 2011 2011
July Dec May Dec May Nov
2009 2009 2010 2010 2011 2011
July Dec May Dec May Nov
2009 2009 2010 2010 2011 2011
i1 i i t1Śr
July Dec May Dec May Nov
2009 2009 2010 2010 2011 2011
~ TCE ~ 1,1-DCE nVC mEthene
Figure 6-31 a. Time Series Charts Showing Chlorinated Ethene
Reductive Dechlorination from the ASA Source Area to
Down Gradient Wells
Wah Chang Five Year Review Report
-------
Source area ~ Groundwater flow
Direction
Figure 6-31 a. Time Series Charts Showing Chlorinated Ethene
Reductive Dechlorination from the ASA Source Area to
Down Gradient Wells
Wah Chang Five Year Review Report
-------
PW-99A
TMW-1
TMW-5
PW-13
PW-98A
PW-78A
o
E
3
c
o
4-J
re
ai
u
o
u
_re
o
1.2
1.0
0.8
0.6
0.4
0.2
0.0 J
400
300 --
200 --
100 --
400
300
200
100
40.0
30.0
20.0
10.0
10.00 n
8.00
6.00
4.00 --
2.00 --
0.00
2.0 n
1.6
1.2
0.8
0.4
0.0
o
re
a>
u
o
u
_re
o
a>
u
a>
a.
100%
90% +-
80%
70%
60%
50%
40%
30%
20%
10% -J-
0%
July Dec May Dec May Nov
200920092010201020112011
July Dec May Dec May Nov
200920092010201020112011
July Dec May Dec May Nov
200920092010201020112011
July Dec May Dec May Nov
200920092010201020112011
July Dec May Dec May Nov
200920092010201020112011
r-1 i i r
July Dec May Dec May Nov
2009 2009 2010 2010 2011 2011
~ 1,1,1-TCA n1,1-DCA DChloroethane ~ Ethane
Figure 6-31 b. Time Series Charts Showing Chlorinated Ethane
Reductive Dechlorination from the ASA Source Area to
Down Gradient Wells
Wah Chang Five Year Review Report
-------
Groundwater flow
Source area
Direction
Figure 6-31 b. Time Series Charts Showing Chlorinated Ethane
Reductive Dechlorination from the ASA Source Area to
Down Gradient Wells
Wah Chang Five Year Review Report
-------
Jan-00 Jan-01 Jan-02 Jan-03 Jan-04 Jan-05 Jan-06 Jan-07 Jan-08 Jan-09 Jan-10 Jan-11
PW-40S (PCE) O PW-40S (TCE) PW-40S (VC) Figure 6-32. Concentration of PCE, TCE and VC (ng/L)
in Well PW-40S
ROD for PCE & TCE ROD for VC
-------
ROD for PCE&TCE ROD for VC
-------
TABLES
-------
Table 6-1. FMA Summary of arsenic, radium 228, radium 226, fluoride, ammonia, ammonium, cadmium, and nickel in groundwater
Wah Chang Five Year Review Report
a
1
Q
(N
0
0
0
g
1
=
O
ts
ts
g.
in
Q.
S"
Q.
S"
ts
in
ts
e
s>
s
s>
I
Ł
o
<
O
<
s
2
2
O
s
O
a
<
z
<
a
PW-21A
P
AMMONIA
mg/L
19.4
50.5
25
73
22
20
21
15
PW-22A
P
AMMONIA
mg/L
196
200.7
91.06
156
102
217
212
222
240
236
212
215
189
PW-23A
P
AMMONIA
mg/L
104
92.7
89.23
86.4
34.7
68.2
65.6
64.1
34
62
31
28
28
23
PW-24A
P
AMMONIA
mg/L
171
72
172.3
146
45.5
27.2
139
186
152
53
148
132
132
118
PW-27A
NHS
AMMONIA
mg/L
21.3
21.4
27.03
40.3
26.8
24.3
26.7
20.5
20
5
18
12
16
12
PW-28A
HS
AMMONIA
mg/L
362
294
331.34
236
106
118
122
164
230
145
123
133
116
PW-50A
HS
AMMONIA
mg/L
92.6
100
114.5
25.9
18.5
22.2
32.8
38
33
27
0.28
0.12
0.26
0.11
PW-51A
HS
AMMONIA
mg/L
92.6
90.1
69.65
55
49.1
61.5
50.5
50.5
48
43
33
38
22
PW-52A
HS
AMMONIA
mg/L
316
254
239.81
215
179
84.5
166
154
154
130
125
105
125
PW-21A
P
AMMONIUM
mg/L
250
31.0
93.0
33.0
28.0
31.0
18.0
PW-22A
P
AMMONIUM
mg/L
250
240.0
200.0
180.0
180.0
278.0
310.0
255.0
234.0
265.0
236.0
PW-23A
P
AMMONIUM
mg/L
250
120.0
87.0
70.0
58.0
43.0
79.0
42.0
36.0
35.0
29.0
PW-24A
P
AMMONIUM
mg/L
250
140.0
89.0
160.0
160.0
190.0
68.0
180.0
156.0
165.0
148.0
PW-27A
NHS
AMMONIUM
mg/L
250
24.0
7.0
24.0
26.0
25.0
6.0
22.0
18.0
20.0
18.0
PW-28A
HS
AMMONIUM
mg/L
250
350.0
230.0
250.0
205.0
290.0
190.0
157.0
167.0
145.0
PW-50A
HS
AMMONIUM
mg/L
250
76.0
80.0
40.0
20.0
20.0
41.0
35.0
0.3
0.2
0.3
0.1
PW-51A
HS
AMMONIUM
mg/L
250
72.0
83.0
43.0
50.0
45.0
60.0
55.0
44.0
48.0
28.0
PW-52A
HS
AMMONIUM
mg/L
250
220.0
220.0
160.0
150.0
93.0
193.0
185.0
175.0
131.0
175.0
PW-21A
P
ARSENIC
mg/L
0.05
0.001 u
0.001 u
0.02 U
0.02 U
0.02 U
0.02 U
0.02 U
0.02 U
PW-22A
P
ARSENIC
mg/L
0.05
0.005 U
0.0148
0.0087
0.02 U
0.02 U
0.015 U
0.02 U
0.02 U
0.01 U
0.0057
0.01 u
0.02 U
0.02 U
0.02 U
0.02 U
0.02 U
0.02 U
PW-23A
P
ARSENIC
mg/L
0.05
0.0107
0.01 U
0.0112
0.02 U
0.02 U
0.015 U
0.02 U
0.02 U
0.025 U
0.01 U
0.108
0.0118
0.02 U
0.02 U
0.02 U
0.02 U
0.02 U
0.02 U
PW-24A
P
ARSENIC
mg/L
0.05
0.005 U
0.01 U
0.005 U
0.02 U
0.02 U
0.015 U
0.02 U
0.02 U
0.025 U
0.01 U
0.01 U
0.01 u
0.02 U
0.02 U
0.02 U
0.02 U
0.02 U
0.02 U
PW-27A
NHS
ARSENIC
mg/L
0.05
0.005 U
0.01 U
0.005 U
0.02 U
0.02 U
0.015 U
0.02 U
0.02 U
0.025 U
0.01 U
0.001 U
0.002 U
0.02 U
0.02 U
0.02 U
0.02 U
0.02 U
0.02 U
PW-28A
HS
ARSENIC
mg/L
0.05
0.05 U
1.05 U
10 U
g|
0.02 U
1.5 U
0.02 U
0.02 U
2.5 U
1 u
0.106
0.14
0.14
0.12
0.11
Ś68091
0.09
PW-50A
HS
ARSENIC
mg/L
0.05
0.05 U
0.0322
0.0162
0.02 U
0.02 U
0.075 U
0.02 U
0.02 U
0.02 U
0.05 U
0.05 U
0.05 U
0.05 U
0.02 U
0.02 U
0.02 U
0.02 U
0.02 U
0.02 U
PW-51A
HS
ARSENIC
mg/L
0.05
0.005 U
0.014
0.02 U
0.02 U
0.02 U
0.015 U
0.02 U
0.02 U
0.02 U
0.025 U
0.05 U
0.05 U
0.05 U
0.02 U
0.02 U
0.02 U
0.02 U
0.02 U
PW-52A
HS
ARSENIC
mg/L
0.05
0.005 U
0.105 U
0.0671
0.03
0.02 U
0.0307
0.02 U
0.02 U
0.02 U
0.05 U
0.2 U
0.05 U
0.2 U
0.02 U
0.02 U
0.02 U
0.02 U
0.02 U
PW-21A
P
CADMIUM
mg/L
0.005
0.0056
0.0005 U
0.01 U
0.01 U
0.01 U
0.01 U
0.01 U
0.01 U
PW-22A
P
CADMIUM
mg/L
0.005
0.001 U
0.005 U
0.001 u
0.01 U
0.01 U
0.005 U
0.01 U
0.01 U
0.005 U
0.0025 U
0.005 U
0.01 U
0.01 U
0.01 U
0.01 U
0.01 U
0.01 U
PW-23A
P
CADMIUM
mg/L
0.005
0.001 U
0.005 U
0.001 u
0.01 U
0.01 U
0.005 U
0.01 U
0.01 U
0.005 U
0.005 U
0.005 U
0.005 U
0.01 U
0.01 U
0.01 U
0.01 U
0.01 U
0.01 U
PW-24A
P
CADMIUM
mg/L
0.005
0.001 U
0.005 U
0.001 u
0.01 U
0.01 U
0.005 U
0.01 U
0.01 U
0.005 U
0.005 U
0.0079
0.005 U
0.01 U
0.01 U
0.01 U
0.01 U
0.01 U
0.01 U
PW-27A
NHS
CADMIUM
mg/L
0.005
0.001 u
0.005 U
0.001 u
0.01 U
0.01 U
0.005 U
0.01 U
0.01 U
0.005 U
0.005 U
0.0102
0.001 U
0.01 U
0.01 U
0.01 u
0.01 u
0.01 U
0.01 u
PW-28A
HS
CADMIUM
mg/L
0.005
0.01 u
0.526 U
5 U
0.04
0.05
0.5 U
MB
HI
0.5 U
0.5 U
0.5 U
0.1 u
0.1 U
0.1 u
0.1 u
0.1 u
PW-50A
HS
CADMIUM
mg/L
0.005
0.01 u
0.0219
0.0121
0.01
0.01
0.025 U
0.01 u
0.01 u
0.01 u
0.01 U
0.025 U
0.05 U
0.01 u
0.01 u
0.01 u
0.01 u
0.01 u
0.01 u
PW-51A
HS
CADMIUM
mg/L
0.005
0.003
0.0076
0.0119
0.01 U
0.01 U
0.0052
0.01 u
0.01 u
0.01 u
0.005 U
0.025 U
0.025 U
0.025 U
0.01 u
0.01 u
0.01 u
0.01 u
0.01 u
PW-52A
HS
CADMIUM
mg/L
0.005
0.0024
0.0524 U
0.0177
0.03
0.0066
0.02 u
WeM
WeM
0.01 U
0.1 U
0.025 U
0.1 U
0.01 u
0.01 u
0.01 u
0.01 u
0.01 u
PW-21A
P
FLUORIDE
mg/L
2
0.73
1.92
1.1
1
1.1
1.1
PW-22A
P
FLUORIDE
mg/L
2
0.39
2Al\
1.75
3
3
2.7i
3
5
3
3.8
13.1
3.1
2
2.5
2.4
PW-23A
P
FLUORIDE
mg/L
2
14.6
12.1
15
12
10.4
10
15
17.8
EB
19.9
0.98
17
21
14
12
12
11
PW-24A
P
FLUORIDE
mg/L
2
0.32
0.29
0.35
1 U
1 U
0.1 U
1 u
1
0.68
0.7
0.92
9.7(9
1 U
1 U
1 u
1 U
1 u
1 u
PW-27A
NHS
FLUORIDE
mg/L
2
1.87
2 U
0.1 U
1 U
1 U
0.5 U
1 u
1 U
0.1 U
0.1 u
0.1 U
3.17
1 U
1 U
1 u
1 U
1 u
1 u
PW-28A
HS
FLUORIDE
mg/L
2
6.88
25 U
4.98
8
9
1 u
8
9
0.1 U
0.1 u
0.1 U
1 U
12
1 u
1 U
1 u
1 u
PW-50A
HS
FLUORIDE
mg/L
2
5.62
35.8
25.87
8
26
0.5 U
8
6
5
1.9
1.1
0.13
0.17
1.1
2
1 u
1 u
1 u
1 u
PW-51A
HS
FLUORIDE
mg/L
2
4.77
13
10.09
11
9
mm
6
6
5
2.7
2.8
3.3
0.4
1.5
1.4
1.2
1.2
1.1
PW-52A
HS
FLUORIDE
mg/L
2
5.7
35.2
22.99
34
25
1.86
25
22
17
0.28
0.26
0.24
0.19
0.21
0.18
0.16
0.16
0.15
PW-21A
P
NICKEL
mg/L
2
0.0047
0.0129
0.02 U
0.02 U
0.02 U
0.02 U
0.02 U
0.02 U
PW-22A
P
NICKEL
mg/L
2
0.01 u
0.02 U
0.01 u
0.02 U
0.02 U
0.02 u
0.02 U
0.02 U
0.02 U
0.01 U
0.02 U
0.02 U
0.02 U
0.02 U
0.02 U
0.02 U
0.02 U
PW-23A
P
NICKEL
mg/L
2
0.01 u
0.02 U
0.01 u
0.02 U
0.02 U
0.02 U
0.02 U
0.02
0.02 U
0.02 U
0.02 U
0.02 U
0.02 U
0.02 U
0.02 U
0.02 U
0.02 U
0.02 U
PW-24A
P
NICKEL
mg/L
2
0.01 u
0.02 U
0.01 u
0.02 U
0.02 U
0.02 U
0.02 U
0.02
0.02 U
0.02 U
0.02 U
0.02 U
0.02 U
0.02 U
0.02 U
0.02 U
0.02 U
0.02 U
PW-27A
NHS
NICKEL
mg/L
2
0.01 u
0.02 U
0.01 u
0.02 U
0.02 U
0.02 U
0.02 U
0.02
0.02 U
0.02 U
0.0059
0.0258
0.02 U
0.02 U
0.02 U
0.02 U
0.02 U
0.02 U
PW-28A
HS
NICKEL
mg/L
2
6.13
3.79
20 U
2.7
4.1
mn
3
2 U
EB
mm
1.8
Ś 3.4
1.5
1.25
1.4
1.16
PW-50A
HS
NICKEL
mg/L
2
1.75
1.87
1.74
0.55
1
0.536
0.56
0.38
0.33
0.326
0.342
0.618
0.565
0.25
0.13
0.23
0.15
0.21
0.12
PW-51A
HS
NICKEL
mg/L
2
0.472
1.08
1.07
0.69
0.65
0.523
0.45
0.41
0.36
0.297
0.343
0.311
0.367
0.3
0.25
0.22
0.19
0.22
PW-52A
HS
NICKEL
mg/L
2
0.38
3.46
3.42
2.3
1.9
2.23
1.8
1.7
1.4
2.25
1.92
1.56
1.85
1.6
1.3
1.1
1.1
1.1
PW-21A
P
RADIUM 226
pCi/L
5
0.65
3.2
40 U
1.5
1.4
0.21 J
0.18 J
PW-21A
P
RADIUM 228
pCi/L
5
3.5
2.9
2.1
40 U
0.92 J
0.84 J
0.11 J
0.07 J
PW-22A
P
RADIUM 226
pCi/L
5
0.4
0.2 U
0.4
10 U
10 U
0.2 U
10 U
10 U
0.2 U
0.37
0.49
40 U
0.83
0.75
0.12 J
0.11 J
PW-22A
P
RADIUM 228
pCi/L
5
3.6
5.1
1 U
10 u
10 u
1 U
10 u
10 U
2.9
3.7
2.9
2.4
40 U
0 J
0.1 J
0.11 J
0.11 J
PW-23A
P
RADIUM 226
pCi/L
5
0.2 U
0.2 U
0.2 U
10 u
10 u
0.2 U
10 u
10 U
0.2 U
0.77
1
1.4
40 U
0.12 J
0.1 J
0.01 J
0.01 J
PW-23A
P
RADIUM 228
pCi/L
5
1 U
1 U
1 u
10 u
10 u
1 u
10 u
10 U
1 U
2
1.6
1.6
40 U
0 J
0.05 J
0.01 J
0.01 J
PW-24A
P
RADIUM 226
pCi/L
5
0.2 U
0.2 U
0.2 U
10 u
10 u
0.2 U
10 u
10 U
0.2 U
0.22
1.6
40 U
0.1 J
0.2 J
0.12 J
0.06 J
PW-24A
P
RADIUM 228
pCi/L
5
1 u
1 u
4
10 u
10 u
1 u
10 u
10 U
1 u
3.5
2.2
3.1
40 U
0.29 J
0.2 J
0.11 J
0.05 J
PW-27A
NHS
RADIUM 226
pCi/L
5
0.2 U
0.2 U
0.2 U
10 u
10 u
0.2
10 u
10 U
0.2 U
0.79
0.68
2.4
40 U
0.15 J
0.12 J
0.02 J
0.01 J
PW-27A
NHS
RADIUM 228
pCi/L
5
1 u
1 u
1 U
10 u
10 u
1 u
10 u
10 U
1.5 U
2.2
2.9
2.1
40 U
1.5
1.3
0.05 J
0.04 J
PW-28A
HS
RADIUM 226
pCi/L
5
168
91.3
139
11
10 u
75.6
10 u
10 U
3.6
44
25
40 U
1.1 J
1.13 J
PW-28A
HS
RADIUM 228
pCi/L
5
352
25.1
56
25
10 u
60.8
10 u
10 U
67
53
12
54
11
5
1.12 J
1.4 J
PW-50A
HS
RADIUM 226
pCi/L
5
28.3
21
15.4
10 u
10 u
5.7
10 u
10 U
10 U
2.6
10
6.5
40 U
0.75
0.67
0.04 J
0.03 J
PW-50A
HS
RADIUM 228
pCi/L
5
44.7
25.6
19
10 u
10 u
10.8
10 u
10 u
10 U
5.1
8.8
13
5.3
40 U
1.9
1.7
0.02 J
0.02 J
PW-51A
HS
RADIUM 226
pCi/L
5
0.7
1
0.5 U
10 u
10 u
0.2 U
10 u
10 u
10 u
0.2 U
0.37
2.1
0.39 J
0.31 J
0.21 J
0.18 J
PW-51A
HS
RADIUM 228
pCi/L
5
2.8
1 U
1 U
10 u
10 u
1 U
10 u
10 u
10 u
2.4
2.5
2.4
2.6
0.59 J
0.49 J
0.11 J
0.1 J
PW-52A
HS
RADIUM 226
pCi/L
5
8.7]
Ś 6.3
10 u
10 u
2
10 u
10 u
10 u
0.2 U
3.3
3.1
2.1
0.06 J
0.05 J
PW-52A
HS
RADIUM 228
pCi/L
5
7.3
3.7
1 U
10 u
10 u
1.8
10 u
10 u
10 u
2.1
2.9
^Ś113
1.8
2.7
2.7
0.11 J
0.08 J
U = not detected above reporting limit shown
Blank cells indicate no analysis performed
Shading indicates that ROD concentration was exceeded
-------
Table 6-2. pH in groundwater for monitoring wells in the FMA Extraction Area
Wah Chang Five Year Review Report
Station
Well
Type
Oct-02
Apr-03
Oct-03
Apr-04
Sep-04
May-05
Sep-05
Oct-05
May-06
Sep-06
May-07
Oct-07
May-08
Jun-08
Jun-09
Dec-10
Apr-10
Nov-10
PW-21A
P
5.79
6.09
6.14
6.87
6.32
PW-22A
P
6.50
6.73
6.76
6.81
6.65
6.51
6.30
6.63
6.55
6.53
6.82
6.77
6.14
6.67
PW-23A
P
6.77
6.99
6.97
7.03
6.85
6.67
6.60
6.77
6.46
6.92
6.79
6.70
6.03
5.99
7.02
6.01
PW-24A
P
6.24
6.33
6.60
6.49
6.44
6.31
6.14
6.30
6.17
6.45
6.45
6.35
5.11
5.16
6.42
5.78
PW-27A
NHS
6.23
5.61
6.08
6.01
6.28
6.05
5.68
5.97
5.73
6.01
5.98
5.87
5.72
5.78
4.02
5.98
PW-28A
HS
1.44
1.40
1.89
2.30
2.15
1.91
1.92
2.30
1.68
1.92
1.62
1.75
1.97
2.46
2.42
2.52
PW-28B
HS
PW-50A
HS
2.44
2.40
2.89
3.62
3.53
3.08
1.97
3.45
3.00
3.74
3.50
2.56
4.13
4.45
4.50
4.32
PW-51A
HS
3.48
3.37
4.00
4.03
4.36
4.30
3.16
4.17
3.85
4.40
4.33
4.04
4.45
5.60
5.51
PW-52A
HS
2.97
3.02
3.39
3.54
3.68
3.64
2.33
3.64
3.20
3.69
3.66
3.38
3.72
3.43
3.59
Blank cells indicate no analysis performed or data is missing
Shading indicates that ROD Cleanup level was exceeded
P = Perimeter well
NHS = Non hot spot well
HS = Hot spot well
-------
Table 6-3. FMA Extraction Well Summary of arsenic, radium 228, radium 226, fluoride, ammonia, ammonium, cadmium, and nickel in groundwater
Wah Chang Five Year Review Report
Well
Parameter
Unit
ROD
Oct-02
Apr-03
Oct-03
Apr-04
Sep-04
May-05
Sep-05
May-06
Sep-06
May-07
Oct-07
00
Š
>
ro
2
Oct-08
Jun-09
Dec-09
Apr-10
Nov-10
Apr-11
Dec-11
EW-01
AMMONIA
mg/L
-
41.2
8
44.7
33.8
25
62
20
15
15
13
EW-02
AMMONIA
mg/L
-
159
80
82.5
59.5
51
46
45
30
42
20
EW-03
AMMONIA
mg/L
-
24.47
18.8
19.3
24.1
20.1
20
22
22
18
18
17
EW-01
AMMONIUM
mg/L
250
57.0
45.0
40.0
31.0
79.0
34.0
20.0
19.0
16.0
EW-02
AMMONIUM
mg/L
250
150.0
150.0
120.0
100.0
64.0
59.0
60.0
40.0
53.0
25.0
EW-03
AMMONIUM
mg/L
250
19.0
20.0
25.0
40.0
25.0
28.0
24.0
24.0
23.0
22.0
EW-01
ARSENIC
mg/L
0.05
0.02 U
0.02 U
0.075
U
0.02 U
0.02
U
0.25 U
0.1 U
0.1 U
0.02 U
0.02
U
0.02
U
0.02 U
0.02 U
0.02 U
EW-02
ARSENIC
mg/L
0.05
0.02 U
0.02 U
1.5
U
0.02 U
0.04
0.02
U
2.5 U
1 U
0.1 U
0.05
0.05
0.05
0.05
0.05
0.04
EW-03
ARSENIC
mg/L
0.05
0.005 U
0.02 U
0.02 U
0.015
U
0.02 U
0.02 U
0.02
U
0.025 U
0.02 U
0.05 U
0.02
U
0.02
U
0.02
U
0.02 U
0.02 U
0.02 U
EW-01
CADMIUM
mg/L
0.005
0.02
0.02
0.025
U
0.02
0.02
0.05 U
0.05 U
0.05 U
0.01 U
0.01
U
0.01
u
0.01 U
0.01 U
0.01 U
EW-02
CADMIUM
mg/L
0.005
0.02
0.03
0.05
U
0.02
0.02
0.02
0.5 U
0.5 U
0.5 U
0.1 U
0.1
U
0.1
u
0.1 U
0.1 U
0.1 U
EW-03
CADMIUM
mg/L
0.005
0.0061
0.01 U
0.01 U
0.005
U
0.01 U
0.01 U
0.01 U
0.005 U
0.0121
0.05 U
0.01 U
0.01
U
0.01
u
0.01 U
0.01 U
0.01 U
EW-01
FLUORIDE
mg/L
2
14
14
7.3
23
18
0.25
0.33
0.32
1.2
24
1.1
1
1.2
1.2
EW-02
FLUORIDE
mg/L
2
8
8
1.51
7
9
10
0.1 U
0.1 U
0.1 U
0.1 U
6
0.1
u
0.1 u
0.1 U
0.1 U
EW-03
FLUORIDE
mg/L
2
11.4
10
11
2.25
8
8
7
5
4.6
4.2
5.1
7
4.2
3.8
3.8
3.3
EW-01
NICKEL
mg/L
2
0.98
1
1.1
1.3
1
0.2 U
1.13
1
0.95
0.82
0.77
0.75
0.69
0.66
EW-02
NICKEL
mg/L
2
1.6
1.8
2.01
2.1
1.6
1.3
2 U
2.36
1.87
1.7
1.8
1.6
1.5
1.5
1.4
EW-03
NICKEL
mg/L
2
0.492
0.31
0.32
0.269
0.3
0.24
0.18
0.18
0.183
0.223
0.23
0.24
0.22
0.21
0.18
0.18
EW-01
RADIUM 226
pCi/L
5
18.2
29
10 U
10
U
4.8
10 U
10 U
10
U
1.4
4.6
3.5
40
U
1.6
1.5
0.01 J
0.01 J
EW-01
RADIUM 228
pCi/L
5
60
17
10 U
10
U
8.4
10 U
10 U
10
U
3.2
6.2
5.9
40
U
3.1
3.2
0.01 J
0.01 J
EW-02
RADIUM 226
pCi/L
5
65
20
10 U
10
U
36.1
10 U
10 U
10
U
4.9
37
35
40
U
18
12
0.11 J
0.12 J
EW-02
RADIUM 228
pCi/L
5
198
59
22
10
U
1.7
10
12
10
u
83.2
23
21
55
U
14
16
0.56 J
0.47 J
EW-03
RADIUM 226
pCi/L
5
10 U
0.5 U
10 U
10
U
0.2 U
10 U
10 U
10
u
0.2 U
3.6
2.5
40
U
3.3
2.3
0.22 J
0.23 J
EW-03
RADIUM 228
pCi/L
5
10 U
1 U
10 U
10
U
1 U
10 U
10 U
10
u
1 U
4.2
3.6
40
U
4.1
3.3
0.18 J
0.17 J
Notes:
U = not detected above reporting limit shown
D = Dilution
J = estimated value
Blank cells indicate no analysis performed or data is missing
Shading indicates that ROD performance standard was exceeded
-------
Table 6-4. SEA Summary of VOCs in groundwater
Wah Chang Five Year Review Report
Well ID
Parameter
Well Type
Units
ROD
Oct-02
Apr-03
Oct-03
Apr-04
Sep-04
May-05
Sep-05
May-06
Aug-06
May-07
Oct-07
Jun-08
Oct-08
Jun-09
Dec-09
Apr-10
Nov-10
Apr-11
Dec-11
EW-04
TCA
R
M-S/L
200
1.10
163.00
2.56
193.37 D
18.10
0.67
1.4
2.00
0.78
150 D
66.4
2.37
3.27
0.76
1.02
0.5 U
0.5 U
0.5 U
EW-05
TCA
R
M-S/L
200
100
96.08
30.10
176.15 D
13.70
10.00
38.9
30.30
55.30
35.10
62.8
14.80
0.85
0.75
0.32 J
0.5 U
0.5 U
0.5 U
EW-06
TCA
R
l^g/L
200
248
35.75
170 D
149 D
180 D
179 D
125 D
142 D
190 D
169 D
34.90
0.5 U
1.67
0.29 J
0.5 U
0.5 U
0.5 U
PW-25A
TCA
P
M-S/L
200
2.90
1 U
1.17
1.79
1.00
0.59
1.90
1.3
2.00
1.20
0.75
1.1
0.44 J
0.63
0.42 J
0.5 U
0.5 U
0.5 U
0.5 U
PW-26A
TCA
P
l^g/L
200
1.90
1 U
2.54
0.64
1.45
0.5 U
0.5 U
0.5 U
0.34 J
0.62
0.49 J
0.6
1.93
2.64
0.20 J
0.31 J
0.5 U
0.5 U
0.5 U
PW-29A
TCA
P
M-S/L
200
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.16 J
0.5 U
0.14 J
0.5 U
0.50 U
0.5 U
0.50 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-47A
TCA
NHS
Hg/L
200
54.90
95.77
75.68
134 D
117.81 D
86.50
49.90
99.3
130 D
116 D
95
32.3
29.10
3.84
0.08 J
0.08 J
0.5 U
0.5 U
0.5 U
PW-48A
TCA
NHS
M-S/L
200
1 U
0.5 U
0.5 U
0.5 U
0.50 U
0.5 U
0.50 U
0.5 U
0.50 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-49A
TCA
P
M-S/L
200
1 U
1 U
1 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.50 U
0.2 J
0.50 U
0.5 U
0.50 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-57A
TCA
P
M-S/L
200
76.60
9.10
73.48
48.65
61.93
52.10
60.70
41.1
45.00
42.6
69.10
43
19.60
0.09 J
0.50 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-96A
TCA
NHS
Hg/L
200
1 U
132 D
12.40
0.13 J
0.29 J
2.23 J
0.5 U
0.5 U
0.5 U
PW-97A
TCA
P
M-S/L
200
1.83
81.4
61.80
12.80
4.61
2.54
0.5 U
0.5 U
0.5 U
EW-04
DCA
R
M-S/L
1.10
34.00
1.46
127.44 D
11.50
0.61
0.75
1.10
0.45 J
75.40
19.8 J
1.42
2.78
1.00
1.13
0.5 U
0.5 U
0.5 U
EW-05
DCA
R
M-S/L
71.40
1 U
12.94
115.23 D
8.00
5.40
14.7
11.00
19.10
12.70
23.7
9.11
4.53
4.58
11.40
0.5 U
0.5 U
0.5 U
EW-06
DCA
R
M-S/L
161
164.00
111 D
75.55
114 D
110 D
87.1
86.30
91.00
76.00
26.20
1.33
1.48
0.78
0.5 U
0.5 U
0.5 U
PW-25A
DCA
P
M-S/L
6.00
1 U
2.86
3.92
3.03
1.40
5.20
3.7
6.00
2.70
1.70
2.5
3.31
2.53
1.74
0.5 U
0.5 U
0.5 U
0.5 U
PW-26A
DCA
P
M-S/L
1.80
1 U
2.07
0.5 U
0.98
0.5 U
0.5 U
0.5 U
0.11J
0.18 J
0.50 U
0.15 J
1.88
3.25
0.40 J
0.35 J
0.5 U
0.5 U
0.5 U
PW-29A
DCA
P
M-S/L
1.39
2.01
0.93
0.57
0.51
0.75
0.58
0.64
0.64
0.86
0.59
0.50 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-47A
DCA
NHS
M-S/L
24.30
26.57
28.90
45.50
41.00
26.80
18.70
34.7
46.40
44.90
31.40
15.7
36.40
35.90
2.04
1.33
0.5 U
0.5 U
0.5 U
PW-48A
DCA
NHS
M-S/L
1 U
0.5 U
0.5 U
0.5 U
0.50 U
0.5 U
0.50 U
0.5 U
0.50 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-49A
DCA
P
M-S/L
1 U
1 U
1 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.50 U
0.5 U
0.50 U
0.5 U
0.50 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-57A
DCA
P
M-S/L
40.00
9.10
37.06
26.58
33.89
25.60
30.10
22.2
22.60
20.8
29.30
20.5
26.90
2.76
0.16 J
0.5 U
0.5 U
0.5 U
0.5 U
PW-96A
DCA
NHS
M-S/L
1 U
42.4
16.00
3.41
18.40
40.30
10.20
0.5 U
0.5 U
PW-97A
DCA
P
M-S/L
1 U
61.5
67.00
59.30
30.20
20.90
2.35
0.5 U
0.5 U
EW-04
DCE
R
ms/l
7
1 U
1 U
0.5 U
32.84
3.30
0.5 U
0.5 U
0.26 J
0.16 J
23.40
4.2 J
0.39 J
0.36 J
0.21 J
0.17 J
0.5 U
0.5 U
0.5 U
EW-05
DCE
R
Hg/L
7
21.10
1 U
2.91
30.22
2.40
1.80
3
2.20
4.20
3.50
3.9
0.50 U
0.1J
2.54
1.16
0.5 U
0.5 U
0.5 U
EW-06
DCE
R
ms/l
7
50.20
1 U
32.52
19.92
31.00
30.00
27.4
26.10
29.00
22.20
9.48
1.44
0.31 J
0.58
0.5 U
0.5 U
0.5 U
PW-25A
DCE
P
M-S/L
7
1.50
1 U
1 U
1.22
0.82
0.5 U
1.30
1.1
1.80
0.71
0.49 J
0.5
0.69
0.51
0.36 J
0.5 U
0.5 U
0.5 U
0.5 U
PW-26A
DCE
P
M-S/L
7
1 U
1 U
1 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.50 U
0.5 U
0.84
0.31 J
0.50 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-29A
DCE
P
M-S/L
7
0.53
0.75
0.5 U
0.5 U
0.5 U
0.12 J
0.19 J
0.18 J
0.27 J
0.34 J
0.22 J
0.50 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-47A
DCE
NHS
M-S/L
7
2.60
6.00
2.78
7.73
5.42
6.40
2.90
7.4
10.80
11.30
5.50
1.9
2.82
0.94
0.39 J
0.5 U
0.5 U
0.5 U
0.5 U
PW-48A
DCE
NHS
M-S/L
7
1 U
0.5 U
0.5 U
0.5 U
0.50 U
0.5 U
0.50 U
0.5 U
0.50 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-49A
DCE
P
M-S/L
7
1 U
1 U
1 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.50 U
0.5 U
0.50 U
0.5 U
0.50 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-57A
DCE
P
M-S/L
7
10.10
9.10
8.30
6.32
8.45
7.00
8.30
6.1
5.80
5.6
8.50
5.5
3.46
0.11J
0.50 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-96A
DCE
NHS
M-S/L
7
1 U
7.1
1.89 J
0.42 J
1.13
0.88
0.5 U
0.5 U
0.5 U
PW-97A
DCE
P
M-S/L
7
34.4
28.60
6.80
3.55
3.02
0.5 U
0.5 U
0.5 U
EW-04
cis-l,2-DCE
R
ms/l
70
6.60
1.24
22.52
4.50
2.40
1.8
1.50
1.10
20.70
7.8 J
2.42
1.65
1.06
0.86
0.5 U
0.5 U
0.5 U
EW-05
cis-l,2-DCE
R
ms/l
70
8.90
3.90
20.58
2.10
1.50
6.1
4.50
7.40
4.60
8.9
3.26
0.90
2.44
2.59
0.5 U
0.5 U
0.5 U
EW-06
cis-l,2-DCE
R
ms/l
70
16.20
17.45
14.90
21.70
22.60
21
20.80
29.30
20.80
80.80
6.53
1.57
0.95
0.5 U
0.5 U
0.5 U
PW-25A
cis-l,2-DCE
P
M-S/L
70
1.90
1 U
1.05
0.94
0.78
0.5 U
2.30
0.73
0.95
0.51
0.21 J
0.75
0.88
0.60
0.27 J
0.5 U
0.5 U
0.5 U
0.5 U
PW-26A
cis-l,2-DCE
P
Hg/L
70
2.40
1 U
1.96
0.5 U
0.73
0.5 U
0.5 U
0.5 U
0.5 U
0.1 J
0.50 U
0.08 J
1.26
1.32
0.54
0.1 J
0.5 U
0.5 U
0.5 U
PW-29A
cis-l,2-DCE
P
M-S/L
70
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.50 U
0.5 U
0.50 U
0.5 U
0.50 U
0.5 U
0.5 U
0.5 U
0.5 U
-------
Well ID
Parameter
Well Type
Units
ROD
Oct-02
Apr-03
Oct-03
Apr-04
Sep-04
May-05
Sep-05
May-06
Aug-06
May-07
Oct-07
Jun-08
Oct-08
Jun-09
Dec-09
Apr-10
Nov-10
Apr-11
Dec-11
PW-47A
cis-l,2-DCE
NHS
M-S/L
70
3.50
5.17
4.68
9.04
8.16
7.30
4.00
12.1
13.70
13.50
11.20
5.4
16.30
9.70
2.25
1.06
0.5 U
0.5 U
0.5 U
PW-48A
cis-l,2-DCE
NHS
M-S/L
70
1 U
0.5 U
0.5 U
0.5 U
0.50
U
0.5 U
0.50 U
0.5 U
0.50 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-49A
cis-l,2-DCE
P
Mg/L
70
1 U
1 U
1 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.50
0.5 U
0.50
U
0.5 U
0.07 J
0.5 U
0.50 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-57A
cis-l,2-DCE
P
M-S/L
70
6.00
9.10
6.78
4.62
6.32
5.20
6.10
5.3
5.90
5.2
8.10
5
18.40
1.06
0.66
0.46 J
0.5 U
0.5 U
0.5 U
PW-96A
cis-l,2-DCE
NHS
Mg/L
70
1 U
19.6
34.50
2.12
3.80
10.90
0.98
0.5 U
0.5 U
PW-97A
cis-l,2-DCE
P
M-S/L
70
50.55
19.9
28.70
13.20
5.59
3.89
0.5 U
0.5 U
0.5 U
EW-04
PCE
R
Mg/L
5
1 U
1 U
0.5 U
3.29
0.54
0.5 U
0.5 U
0.21
0.14 J
3.20
25 U
0.27 J
0.29
0.17 J
0.29 J
0.5 U
0.5 U
0.5 U
EW-05
PCE
R
M-S/L
5
3.10
1.94
3.14
1.60
1.40
1.8
1.50
2.30
2.30
1.8
0.68
0.18
0.44 J
0.5 U
0.5 U
0.5 U
0.5 U
EW-06
PCE
R
Mg/L
5
4.10
3.57
2.11
3.30
3.10
2.9
2.70
3.30
2.90
0.90
0.5
0.32 J
0.12 J
0.5 U
0.5 U
0.5 U
PW-25A
PCE
P
M-g/L
5
2.80
1 U
1.47
1.38
1.19
0.59
2.30
1.1
1.50
0.85
0.53
0.49 J
0.24 J
0.51
0.29 J
0.5 U
0.5 U
0.5 U
0.5 U
PW-26A
PCE
P
Hg/L
5
1 U
1 U
1 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.07
0.13 J
0.09 J
0.5 U
0.20 J
0.27
0.50 U
0.27 J
0.5 U
0.5 U
0.5 U
PW-29A
PCE
P
M-g/L
5
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.10
0.5 U
0.50 U
0.5 U
0.09 J
0.5 U
0.50 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-47A
PCE
NHS
M-g/L
5
3.20
3.40
3.13
4.81
3.71
2.80
1.60
3.1
3.80
4.10
3.30
1.4
0.37 J
0.42 J
0.16 J
0.5 U
0.5 U
0.5 U
0.5 U
PW-48A
PCE
NHS
M-g/L
5
1 U
0.5 U
0.5 U
0.5 U
0.50 U
0.5 U
0.50 U
0.5
0.50 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-49A
PCE
P
Mg/L
5
1 U
1 U
1 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.50
0.5 U
0.50 U
0.5 U
0.50 U
0.5 U
0.50 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-57A
PCE
P
Mg/L
5
4.30
9.10
4.84
3.93
3.73
2.90
3.50
3
2.70
2.4
3.60
2.1
0.26 J
0.5 U
0.50 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-96A
PCE
NHS
Mg/L
5
1 U
1.2
2.50 U
0.5 U
0.50 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-97A
PCE
P
Mg/L
5
1 U
1.9
1.22
0.26 J
0.17 J
0.14 J
0.5 U
0.5 U
0.5 U
EW-04
TCE
R
Mg/L
5
30.40
1 U
4.67
137.23 D
21.80
9.80
6.5
8.90
4.40
90.20
46.8
11.60
9.46
6.05
6.32
0.58
0.5 U
0.5 U
EW-05
TCE
R
Mg/L
5
78.50
1.12
31.95
127.64 D
16.70
11.80
37.1
30.30
44.20
31.70
45.4
16.40
0.53
4.32
1.24
0.5 U
0.5 U
0.5 U
EW-06
TCE
R
Mg/L
5
129.00
1 U
125 D
85.99
130 D
124 D
114 D
118.00
119 D
87.30
15.90
6.00
7.40
1.01
0.5 U
0.5 U
0.5 U
PW-25A
TCE
P
Mg/L
5
5.60
1 U
3.13
3.50
2.53
1.30
4.70
2.4
3.80
1.80
0.98
1.3
1.52
1.22
0.61
0.5 U
0.5 U
0.5 U
0.5 U
PW-26A
TCE
P
Mg/L
5
12.30
9.10
6.46
2.39
3.70
1.90
1.10
1.5
1.30
1.70
1.50
1.1
3.73
3.66
0.63
0.57
0.5 U
0.5 U
0.5 U
PW-29A
TCE
P
Mg/L
5
0.5 U
0.58
0.5 U
0.5 U
0.5 U
0.16
0.18 J
0.18 J
0.21 J
0.29 J
0.2 J
0.50 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-47A
TCE
NHS
Mg/L
5
34.60
50.55
48.18
72.77
68.47
52.30
34.50
69.6
78.90
63.30
53.90
21.8
12.90
1.94
1.18
0.76
0.5 U
0.5 U
0.5 U
PW-48A
TCE
NHS
Mg/L
5
1 U
0.5 U
0.5 U
0.5 U
0.50 U
0.5 U
0.50 U
0.5 U
0.50 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-49A
TCE
P
Mg/L
5
6.10
1 U
1.21
5.18
0.5 U
1.40
4.20
2.5
1.10
2.20
0.60
2.2
1.49
0.70
0.13 J
0.25 J
0.5 U
0.5 U
0.5 U
PW-57A
TCE
P
Mg/L
5
46.70
9.10
50.41
34.56
44.22
35.10
42.30
39.9
41.60
30.7
43.80
25.6
2.58
0.23 J
0.33 J
0.31 J
0.5 U
0.5 U
0.5 U
PW-96A
TCE
NHS
Mg/L
5
1 U
62
0.57 J
0.66
1.08
1.90
0.5 U
0.5 U
0.5 U
PW-97A
TCE
P
Mg/L
5
67.3
43.20
9.98
4.73
4.58
0.5 U
0.5 U
0.5 U
EW-04
VC
R
Mg/L
2
1 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.50
0.5 U
0.50
U
25 U
0.50 U
0.5 U
0.50 U
0.5 U
0.5 U
0.5 U
0.5 U
EW-05
VC
R
Mg/L
2
1 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.50
0.5 U
0.50
U
0.5 U
0.50 U
2.51
0.48 J
1.49
0.5 U
0.5 U
0.5 U
EW-06
VC
R
Mg/L
2
1 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.13
0.31 J
0.50
U
1.55
3.11
0.25 J
0.58
0.5 U
0.5 U
0.5 U
PW-25A
VC
P
Mg/L
2
1 U
1 U
1 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.50
0.5 U
0.50
U
0.5 U
0.50 U
0.5 U
0.50 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-26A
VC
P
Mg/L
2
1 U
1 U
1 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.50
0.5 U
0.50
U
0.5 U
0.50 U
0.5 U
0.50 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-29A
VC
P
Mg/L
2
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.50
0.5 U
0.50
U
0.5 U
0.50 U
0.5 U
0.50 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-47A
VC
NHS
Mg/L
2
1 U
1 U
1 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.50
0.5 U
0.50
U
0.5 U
1.25
1.25
0.58
0.5 U
0.5 U
0.5 U
0.5 U
PW-48A
VC
NHS
Mg/L
2
1 U
0.5 U
0.5 U
0.5 U
0.50
U
0.5 U
0.50 U
0.5 U
0.50 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-49A
VC
P
Mg/L
2
1 U
1 U
1 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.50
0.5 U
0.50
U
0.5 U
0.50 U
0.5 U
0.50 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-57A
VC
P
Mg/L
2
1 U
9.10
1 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.50
0.5 U
0.50
U
0.5 U
0.84
0.59
0.17 J
0.5 U
0.5 U
0.5 U
0.5 U
PW-96A
VC
NHS
Mg/L
2
1 U
0.5 U
1.27 J
1.10
2.93
7.25
0.28
0.5 U
0.5 U
PW-97A
VC
P
Mg/L
2
0.56
1.43
3.02
1.70
0.93
0.5 U
0.5 U
0.5 U
Notes: U = not detected above reporting limit shown; D = Dilution;
R = Recovery well, P = Perimeter well, NHS = Non hot spot well
J = estimated value; Blank cells indicate no analysis performed or missing data; Shading indicates that ROD Performance level was exceeded
-------
Table 6-5. Fabrication Area Summary of groundwater analytical results forTCA
Wah Chang Five Year Review Report
Station
Well Type
ROD
Oct-2002
Apr-2003
Oct-2003
May-June-
July2004
Sept-Oct 2004
May-june 2005
Oct-Nov-2005
May-2006
Oct-Nov-2006
May-June 2007
Oct-Nov-2007
May-2008
Oct-2008
June-July 2009
Dec-2009
April May 2010
Nov-Dec-2010
May-2011
Nov-2011
MW-01A
HS
200
2.2
1 U
79.84
0.5 U
9.99
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.12 J
0.5 U
0.14 J
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
MW-02A
HS
200
22
10.56
11.14
6.24
4.84
0.51
0.5 U
0.5 U
0.5 U
0.5 U
0.12 J
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
MW-03A
HS
200
1U
1 U
1U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.15 J
0.5 U
0.45 J
0.5 U
0.5 U
0.5 U
0.5 U
MW-04A
HS
200
1U
1 u
1U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.13 J
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-01A
HS
200
1.2
0.99
0.6
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.12 J
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-03A
HS
200
10.5
3.88
4.72
2.76
1.62
1.1
0.52
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.17 J
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-10
NHS
200
136.6 D
82.55
104 D
70.83
73.58
55.9
62.6
58.9
69.2
78.7
68.9
65.8
56.1
16.1
16.6
1.23
0.13 J
0.68
0.5 U
PW-100A
HS
200
0.99
113
84.5
PW-101A
NHS
200
0.08 J
8.93
5.67
PW-11
HS
200
122 D
47.35
227 D
256 D
323 D
37.3
280 D
26.1
83
7.1
12.1
3.7
41.4
16.5
21.1
15.2
4.61
3.1
1.65
PW-12
HS
200
1330 D
207.55
423 D
536 D
583 D
1140 D
2960 D
621 D
738 D
1260 D
663 D
1640 D
1910 D
2490
1190
823
389
364
65
PW-13
HS
200
655 D
280.57
213 D
289.26
144.55
227
239
173
135
49.8
146
340 D
168
417
175
152
15.6
56
8.77
PW-14
NHS
200
2.3
PW-16A
NHS
200
5.4
1.71
3.98
3.23
5.75
5.1
4.1
10.7
4.3
4.1
2.4
3.85
4.51
4.33
3.78
1.89
1.2
0.53
PW-19A
NHS
200
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
1.64
0.5 U
0.5 U
0.5 U
0.5 U
PW-30A
HS
200
185 E
449.87
1510 D
1660 D
799 D
1250 D
662 D
959 D
1640 D
938 D
952 D
960 D
1480 D
833
452
431
415
286
264
PW-31A
NHS
200
0.5 U
0.5 U
0.5 U
0.5 U
0.1 J
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-42A
HS
200
1U
0.5 U
1.29
0.68
0.5 U
0.5 U
3.3
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-45A
HS
200
2.5
2.38
4.12
9.9
13
3.2
9.3
1.2
0.5 U
1.9
0.91
0.85
0.36 J
0.11 J
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-46A
NHS
200
1.5
0.85 J
1U
0.95
0.5 U
0.57
0.32 J
0.5 U
0.56
0.18 J
0.25 J
0.13 J
0.18 J
0.15 J
0.5 U
0.5 U
0.5 U
0.5 U
PW-68A
HS
200
202 D
0.62
4.17
8.36
1.77
0.87
3.4
0.88
0.54
0.95
0.48 J
0.77
2.61
2.51
0.16 J
0.5 U
0.5 U
0.5 U
0.5 U
PW-69A
HS
200
5810 D
3570
2620
2570 D
1390 D
2100 D
1780 D
885 D
392
482
295 D
473 D
349
386
451
368
28.8
245
13.4
PW-70A
NHS
200
0.5 U
0.5 U
PW-71A
HS
200
66.9
53.28
33.94
34.77
20.22
63.6
0.5 U
0.5 U
0.5 U
0.5 U
1.5
0.14 J
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-72A
NHS
200
1U
0.5 U
1U
0.5 U
0.5 U
0.5 U
PW-73B
HS
200
1U
1 U
1U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.14 J
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-74B
NHS
200
1U
0.5 U
1U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.1 J
0.5 U
0.1 J
0.22 J
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-75A
NHS
200
38.6
134
37.92
313 D
88.85
85.5
14.1
46.9
14.3
44.2
10.2
45.3
17.4
64.2
42.6
39.6
27.5
21.3
11.6
PW-76A
P
200
2.18
0.5 U
75.57
80.55
1.57
1.8
7.3
0.5 U
0.5 U
2.1
0.2 J
1.1
0.11 J
1.14
1.77
0.5 U
0.5 U
0.5 U
0.5 U
PW-77A
NHS
200
2.22
1.28
0.56
5.51
16.35
28.9
26.8
17.7
13.1
14.6
16.2
17.9
11.7
3.57
4.97
2.15
1.08
1.26
0.53
PW-78A
P
200
13.9
10.63
13.35
13.9
7.86
7.5
8.8
8.4
12.1
16.7
5.7
11.7
10.1
1.79
10.5
9.55
2.18
4.38
0.67
PW-79A
P
200
28
81.02
151.95 D
69.12
26.48
48.4
72.6
71.4
67
70.5
188 D
83.3
28.1
0.08 J
8.63
4.19
1.33
4.34
0.69
PW-80A
NHS
200
71.9
48.85
45.57
55.44
16.4
6.9
3.2
6.3
3.8
7.2
8.7
8.4
1.93
0.19
3.36
2.09
0.49 J
1.25
0.5 U
PW-82A
NHS
200
4.8
0.5 U
1.9
1.26
1.14
0.63
0.29 J
0.5 U
0.22 J
0.16 J
0.18 J
0.12 J
0.5 U
1.53
1.22
0.77
0.59
0.23 J
PW-83A
HS
200
9.9
0.5 U
3.97
3.9
2.57
1.9
0.83
0.76
0.5 U
0.46 J
0.5 U
0.26 J
0.12 J
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-84A
NHS
200
1U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.25 J
0.65
0.32 J
0.26 J
6.43
5.25
2.33
2.81
1.42
PW-85A
HS
200
3.2
5.64
3.39
2.04
1.19
2.6
1.5
1.6
18.4
2.1
0.43 J
1.7
1.24
3.28
11.2
8.95
6.18
6.34
2.34
PW-86A
HS
200
2
0.5 U
2.48
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.83
3.7
0.69
0.13 J
2.19
0.27 J
1.04
0.98
0.33 J
0.54
0.5 U
PW-87A
NHS
200
1U
0.5 U
1U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.1 J
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-88A
NHS
200
2.6
0.68
1.48
1.31
0.96
1.1
0.73
0.72
0.5
0.49 J
0.39 J
0.47 J
0.26 J
0.19 J
0.17 J
0.5 U
0.5 U
0.5 U
0.5 U
PW-89A
NHS
200
1U
0.5 U
1U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-91A
NHS
200
160 D
143.28
63.55
97.9 D
6.84
52.5
8.7
43.9
0.16 J
0.5 U
0.14 J
16500 D
0.36 J
8.57
2.74
1.79
1.31
0.54
0.64
PW-92A
NHS
200
1U
0.5 U
1U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-93A
HS
200
11800 D
15300 D
24900 D
13300
9980
11100
1120
5970
845
PW-94A
HS
200
1U
220 D
421 D
302 D
43.5
183
39
197
12
156
PW-95A
HS
200
229 D
759 D
224 D
1820
205
348
90.4
234
45.2
PW-98A
NHS
200
504
406
507
183
123
128
PW-99A
HS
200
27.5
54.6
22.1
7.15
8.94
5.18
Notes:
U = not detected above reporting limit shown
D = Dilution
J = estimated value
Blank cells indicate no analysis performed
Shading indicates that ROD concentration was exceeded
P=Perimeter well, =NHS = Non hot spot well, HS = Hot spot well
(1) Initial GW samples were collected in September 2007 for PW-93A(B-07-12), PW-94A(B07-09), and PW-95A(B07-07) during the intial soil and groundwater investigation at the former CCA area.
(2) Initial GW samples were collected in July 2009 for PW-98A and PW-99A.
(3) Initial GW samples were collected in August 2010 for PW-100A and PW-101A.
(4) Initial GW samples were collected in May 2010 for E-ll.
(5) Initial GW samples were collected in April 2010 for FW-6.
-------
Table 6-6. Fabrication Area Summary of groundwater analytical results for DCA
Wah Chang Five Year Review Report
Station
Well Type
ROD
Oct-2002
Apr-2003
Oct-2003
May-June-
July2004
Sept-Oct 2004
May-June 2005
Oct-Nov-2005
May-2006
Oct-Nov-2006
May-June 2007
Oct-Nov-2007
May-2008
Oct-2008
June-July 2009
Dec-2009
April-May 2010
Nov-Dec-2010
May-2011
Nov-2011
MW-01A
HS
0.5 U
0.5 U
MW-02A
HS
3.81
1.25
MW-03A
HS
0.5 U
0.5 U
MW-04A
HS
2.84
2.11
PW-01A
HS
64.5
47.09
47.87
58.4
58.84
64.8
54.4
52.6
56.1
50.8
48.5
39
32
27.2
1.07
1.02
0.98
0.88
0.55
PW-03A
HS
18.3
5.62
6.66
5.33
6.44
4.8
2.5
1.9
1.6
0.77
0.29 J
0.1 J
0.4 J
0.49 J
0.51
0.5 U
0.5 U
0.5 U
0.5 U
PW-10
NHS
328.85 D
161.25
193 D
111 D
129.35 D
69.5
171 D
81.2
114 D
131 D
99.9
63.2
60.2
58.8
31.8
28.6
35.1
23.9
22.2
PW-100A
HS
5.5
2250
1850
PW-101A
NHS
1.56
671
513
PW-11
HS
29.9
12.38
27.99
32.28
51.52
6.9
47.3
5.6
18.5
1.6
3.4
1.3
6.49
3.77
3.79
4.12
8.15
2.68
3.12
PW-12
HS
162 D
99.17
71.51
82.26
114.25
139
242 D
78.5
55
125
68.5
159
140
321
255
414
312
189
289
PW-13
HS
1730 D
1260
865 D
1370 D
842 D
1430 D
1440 D
1210 D
545 D
285 D
767 D
977 D
551 D
3310
1710
1310
1524
789
1125
PW-14
NHS
0.64
PW-16A
NHS
1.8
1.1
1.34
1.05
1.51
1.4
1.5
2.3
1
1.5
0.92
1.13
1.12
0.69
0.5 U
0.5 U
0.5 U
0.5 U
PW-19A
NHS
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.79
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-30A
HS
39.3
12.9
39.57
32.96
25.25
25.6
18.8
24.8
32.5
17
17.4
13.9
19.9
20.2
10.2
11.1
5.6
4.5
3.9
PW-31A
NHS
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-42A
HS
7.3
10.14
6.04
6.91
5.25
3.1
4.2
2.6
5.8
8.4
8.2
8
5.87
5.52
4.72
3.82
3.37
2.01
0.84
PW-45A
HS
47.7
71.51
56.7
72.79
91.96
42.5
54.7
27.7
1.6
21.1
13.7
13
8.66
2.06
0.22 J
0.5 U
0.5 U
0.5 U
0.5 U
PW-46A
NHS
15
9.33
8.73
15.63
4.38
6.8
5.7
0.27 J
5.4
3.1
3.7
2.07
4.31
4.27
3.89
2.86
2.64
1.34
PW-68A
HS
76.2
0.5 U
2
7.68
1.09
0.5 U
2.5
0.65
0.32 J
0.78
0.22 J
0.15 J
2.08
4.95
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-69A
HS
2110 D
1540
1390
949 D
736
677
525
748 D
280
205
148 D
196
208
234
299
246
141
189
135
PW-70A
NHS
0.16 J
0.5 U
PW-71A
HS
8.7
9.88
8.62
10.21
4.78
8.5
10.9
1.9
1.5
0.5 U
1.7
0.98
1.72
0.12 J
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-72A
NHS
1 U
0.5 U
1 U
0.5 U
0.5 U
0.5 U
PW-73B
HS
43.9
30.14
31.15
23.75
21.99
19
16.9
12.1
10.8
11.8
10.5
9.6
8.38
2.83
4.51
4.23
3.54
1.18
1.65
PW-74B
NHS
10.8
5.7
7.35
5.76
5.96
6.7
8.7
10.5
8.2
7.2
9.5
7.8
10.7
0.5 U
2.86
1.96
0.83
1.15
0.49 J
PW-75A
NHS
24
14.3
22.64
30.14
23.54
17.3
10.8
12
10.2
5.5
4.7
8.5
4.81
8.62
8.13
7.15
9.68
2.33
6.47
PW-76A
P
1.71
3.01
1.96
2.5
4.83
5.4
0.65
0.5 U
0.5 U
0.28 J
0.25 J
0.18 J
0.38 J
0.34 J
2.04
0.5 U
0.5 U
0.5 U
0.5 U
PW-77A
NHS
163.05 D
118.8
127.44 D
341 D
449 D
478 D
483 D
526 D
477 D
515 D
703 D
641 D
462 D
212
227
216
186
143
142
PW-78A
P
95.2 D
143.52
123.09 D
143 D
99.08
130 D
124 D
144 D
99.4
123 D
96.6
87.9
88.7
141
114
91.1
87.2
73.4
25.8
PW-79A
P
18.6
27.93
52.72
30.91
20.49
22.5
34.1
26.8
36.4
26.9
79.5
35.1
15.5
1.88
5.52
2.08
1.64
1.26
1.16
PW-80A
NHS
11.6
9.02
6.97
8.84
4.08
1.8
1.2
1.9
1.3
1.8
2.5
2
0.49 J
0.5 U
1.57
0.65
0.23 J
0.54
0.5 U
PW-82A
NHS
1.6
0.94
0.84
0.61
0.72
0.5 U
0.32 J
0.5 U
0.27 J
0.29 J
0.18 J
0.19 J
0.5 U
0.13 J
0.5 U
0.5 U
0.5 U
0.5 U
PW-83A
HS
4.1
2.87
3.23
3.12
3.12
2.5
2.7
1.6
1.9
1.2
0.48 J
0.75
0.48 J
2
0.57
0.44 J
0.5 U
0.5 U
0.5 U
PW-84A
NHS
1.4
0.94
0.75
0.59
0.62
0.74
0.7
0.86
1.2
2.2
2.75
1.35
3.65
3.15
2.49
2.18
1.98
PW-85A
HS
7.1
13.4
12.53
6.28
5.87
9.3
7.9
5.2
6.7
6.2
4.9
6.5
3.06
6.06
11.2
9.61
8.26
4.18
5.54
PW-86A
HS
198 D
143.65
35.8
73.91
80.89
48.2
39.2
22.8
18.2
2.3
5.7
9.8
0.9
3.97
0.52
0.44 J
0.5 U
0.11 J
0.5 U
PW-87A
NHS
1 U
0.84
1 U
0.77
0.5 U
0.8
0.77
0.5 U
0.62
0.66
0.63
0.54
0.59
0.62
0.52
0.23 J
0.5 U
0.5 U
PW-88A
NHS
1 U
0.5 U
1 U
2.67
6.96
6.2
2.9
4.3
0.28 J
0.57
0.72
1.6
0.21 J
0.5 U
0.2 J
0.5 U
0.5 U
0.5 U
0.5 U
PW-89A
NHS
3.4
0.5 U
1 u
2.86
2.99
2.4
1.9
1.6
0.67
1.4
1.1
1.9
1.47
0.58
0.39 J
0.5 U
0.5 U
0.5 U
0.5 U
PW-91A
NHS
29
11.77
16.72
19.21
6.23
13.1
5.3
10.6
0.23 J
0.5 U
0.41 J
2250
0.56
4.31
1.3
1.21
1.52
0.89
0.84
PW-92A
NHS
1 U
0.5 U
1 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.08 J
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-93A
HS
2410
2290
2630
2670
1130
2370
9770
3380
6218
PW-94A
HS
1 U
196 D
269 D
128 D
24.3
88.3
25.7
125
8.96
81
PW-95A
HS
103 D
209 D
123 D
335
108
152
60.6
3.16
45.1
PW-98A
NHS
170
253
458
503
268
384
PW-99A
HS
28.5
60.6
58.3
23.9
41.5
14.8
Notes:
U = not detected above reporting limit shown
D = Dilution
J = estimated value
Blank cells indicate no analysis performed or missing data
Shading indicates that ROD concentration was exceeded
P=Perimeter well, =NHS = Non hot spot well, HS = Hot spot well
(1) Initial GW samples were collected in September 2007 for PW-93A(B-07-12), PW-94A(B07-09), and PW-95A(B07-07) during the intial soil and groundwater investigation at the former CCA area
(2) Initial GW samples were collected in July 2009 for PW-98A and PW-99A.
(3) Initial GW samples were collected in August 2010 for PW-100A and PW-101A.
(4) Initial GW samples were collected in May 2010 for E-ll.
(5) Initial GW samples were collected in April 2010 for FW-6.
-------
Table 6-7. Fabrication Area Summary of groundwater analytical results for DCE
Wah Chang Five Year Review Report
Station
Well Type
ROD
Oct-2002
Apr-2003
Oct-2003
May-June-
July2004
Sept-Oct 2004
May-june
2005
Oct-Nov-2005
May-2006
Oct-Nov-2006
May-June
2007
Oct-Nov-2007
May-2008
Oct-2008
MW-01A
HS
7
3.3
2.45
8.83
4.1
3.89
1.4
0.66
0.25 J
0.5 U
0.5
0.09 J
0.62
0.3 J
MW-02A
HS
7
375 D
237.22
253.93
219 D
188.7 D
177 D
185 D
151 D
108 D
96.7
77.8
85.9
95.5
MW-03A
HS
7
1.9
1 U
1U
0.5 U
0.74
0.5 U
0.1 J
0.19 J
0.5 U
0.21 J
0.5 U
1.58
MW-04A
HS
7
166 D
59.37
101 D
32.4
98.41
34.9
48
27.4
58.4
23.3
23
22.7
40.5
PW-01A
HS
7
99.4
69.33
85.76
106 D
99 D
148 D
89.6
81.1
108 D
94.9
96.6
77.7
50.7
PW-03A
HS
7
71.2
18.31
23.71
17.32
19.21
16.5
9
6.9
5.4
2.3
0.76
0.34 J
1.6
PW-10
NHS
7
18.59
9.89
14.04
oo
oo
9.67
6.6
10.9
7.7
7.1
9.5
7.4
8.2
4.03
PW-100A
HS
7
PW-101A
NHS
7
PW-11
HS
7
79.2
18.37
100 D
143 D
216 D
9.6
198 D
12.9
54
3.3
oo
oo
1.3
27.5
PW-12
HS
7
964 D
372
291 D
275 D
333 D
410
922 D
276 D
207
324
267 D
427
420
PW-13
HS
7
825 D
476.21
403 D
547 D
414
462
554 D
493 D
308 D
175 D
392 D
412 D
267 D
PW-14
NHS
7
0.19 J
PW-16A
NHS
7
3.5
1.16
2.33
1.95
3.95
3.5
3.7
7.3
2.8
3.6
2
2.73
PW-19A
NHS
7
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-30A
HS
7
113 D
28.15
109.49 D
96.01
56.96
92.3
37.7
85.9
75.3
76.5
78.7
79.1
86.7
PW-31A
NHS
7
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-42A
HS
7
31.6
19.11
30.05
23.07
19.83
10.9
21.5
6.5
12.2
17.3
20.1
35.8
23.5
PW-45A
HS
7
95.5
105.61
147.53 D
149 D
178 D
124 D
182 D
118 D
11.5
164 D
143 D
128 D
121 D
PW-46A
NHS
7
14.3
9.48
9.4
18.15
5.24
00
00
9.7
0.18 J
9.6
6.1
7.1
3.81
PW-68A
HS
7
154 D
1 U
3.26
6.08
1.38
0.5 U
3.2
0.84
0.37 J
0.88
0.35 J
0.3 J
3.96
PW-69A
HS
7
212 D
159
160.51
127 D
90.14
152
79.8
102
25
48.4
24.9
41.3
35.3
PW-70A
NHS
7
PW-71A
HS
7
97.5 D
84.9
75.16
73.92
52.07
94.2
10.5
3.8
1.6
0.5 U
0.95
3.1
0.82
PW-72A
NHS
7
1U
1 U
1U
0.5 U
0.5 U
0.5 U
PW-73B
HS
7
55.4
33.25
36.42
30.78
28.39
25.6
25.5
18.8
18.5
20.3
18.9
17
15.2
PW-74B
NHS
7
9.4
3.86
4.99
4.48
4.33
5
6.7
8.1
6.4
5.9
8.1
6.6
9.15
PW-75A
NHS
7
27.9
10.92
18.13
21.81
15.34
14.6
10.8
8.2
13.7
5.7
5.6
oo
oo
6.99
PW-76A
P
7
0.7
1 U
29.38
29.27
0.61
0.86
4
0.5 U
0.5 U
0.79
0.5 U
0.38 J
0.06 J
PW-77A
P
7
16.45
22.89
40.54
45.09
62.12
68.3
85
31.1
51.7
27.5
46.4 D
36.8
33.5
PW-78A
P
7
84.2
72.25
66.72
65.59
51.04
64.1
62.4
69.6
60.2
58.1
51.1
67.4
78.9
PW-79A
P
7
12.8
25.13
41.25
18.29
11.25
18.9
29.4
30.7
24.3
20.8
94.9
27.4
10.5
PW-80A
NHS
7
57.4
37.71
30.6
38.02
14.73
6
3.5
5.8
2.9
5.6
8.7
7.2
1.64
PW-82A
NHS
7
5.3
1 U
2.88
2.8
2.35
1.5
1
1.9
1
0.83
0.67
1.06
PW-83A
HS
7
31.2
1 U
22.47
18.25
16.76
11.1
14.2
6.4
9.2
4.7
1.6
2.4
1.78
PW-84A
NHS
7
1U
1 u
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
1.2
1.9
10.1
14.4
PW-85A
HS
7
13.7
30.74
23.72
11.16
11.68
14.4
14
7.1
4.4
4.9
5.4
10.5
4.45
PW-86A
HS
7
97.7
67.32
18.82
49.91
50.42
36.3
37
28.7
17.5
1.1
7.2
12.4
0.62
PW-87A
NHS
7
1.2
1 U
1U
0.94
0.5 U
1
0.94
0.5 U
0.7
0.69
0.72
0.5
PW-88A
NHS
7
1U
1 u
1U
1.28
3.01
2.9
1.3
2
0.14 J
0.32 J
0.38 J
0.95
0.14 J
PW-89A
NHS
7
1U
3.14
1U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.21 J
0.22 J
0.67
0.56
PW-91A
NHS
7
29.3
10.43
11.48
10.76
5.67
9
7.7
9.3
0.23 J
0.1 J
0.45 J
1030
1.22
PW-92A
NHS
7
1U
1 U
1U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-93A
HS
7
1460
1080
1600
PW-94A
HS
7
1U
15
31.2
13.8
PW-95A
HS
7
25.2
98.1
29.3
PW-98A
NHS
7
PW-99A
HS
7
Notes:
U = not detected above reporting limit shown
D = Dilution
J = estimated value
Blank cells indicate no analysis performed or data missing
Shading indicates that ROD concentration was exceeded
P=Perimeter well, =NHS = Non hot spot well, HS = Hot spot well
(1) Initial GW samples were collected in September 2007 for PW-93A(B-07-12), PW-94A(B07-09), and PW-95A(B07-07) during the intial soil and groundwater investigation at the former CCA area.
(2) Initial GW samples were collected in July 2009 for PW-98A and PW-99A.
(3) Initial GW samples were collected in August 2010 for PW-100A and PW-101A.
(4) Initial GW samples were collected in May 2010 for E-ll.
(5) Initial GW samples were collected in April 2010 for FW-6.
0.12 J
71
0.12 J
44.8
68.4
1.33
1.91
11.5
512
3.04
0.5 U
42.5
0.5 U
24.3
29.3
7.22
1.45
29.2
0.5 U
4.77
0.5 U
7.08
0.18 J
30.8
71.3
2.05
0.2
0.5 U
6.76
5.19
7.31
7.96
0.49 J
0.5 U
0.5 U
2.54
0.5 U
918
2.11
296
1080
87.8
1.4
62.1
0.12 J
38.6
1.71
1.53
1.17
1.05
522
432
1.75
0.5 U
21.9
0.5 U
32.5
3.45
7.47
0.5 U
35.4
0.5 U
7.86
2.22
6.36
0.2 J
34.4
83.8
5.47
2.21
0.15 J
2.21
4.23
22.1
0.17 J
0.52
0.14 J
0.5 U
1.15
0.5 U
638
5.45
13.7
1070
245
1.31
58.2
0.5 U
35.4
1.22
1.25
2.55
6.09
0.16 J
2.11
611
352
0.61
0.5 U
18.8
0.5 U
30.9
2.22
6.94
0.5 U
31.2
0.5 U
6.98
1.82
5.78
0.54
33.8
68.7
3.09
0.99
0.5 U
1.89
3.98
18.2
0.5 U
0.5 U
0.5 U
0.5 U
0.88
0.5 U
905
1.9
15.2
495
232
0.56
52.8
0.5 U
28.6
1.13
0.72
3.51
103
286
1.15
489
263
0.5 U
0.5 U
12.2
0.5 U
27.6
0.5 U
5.69
0.5 U
44.3
0.5 U
0.5 U
4.18
1.25
5.18
0.5 U
26.5
57.6
2.64
0.25 J
0.5 U
1.26
2.56
11.8
0.5 U
0.5 U
0.5 U
0.5 U
0.69
0.5 U
512
11.1
15.5
427
186
0.89
41.3
0.5 U
22.2
0.89
0.98
1.45
1.64
235
189
0.5 U
0.5 U
7.5
0.5 U
18.1
0.5 U
3.14
0.5 U
28.4
0.5 U
5.11
0.76
3.16
0.26 J
26.4
42.3
1.56
0.88
0.5 U
1.11
2.58
10.2
0.5 U
0.5 U
0.5 U
0.5 U
0.76
0.5 U
785
0.23 J
8.18
125
155
0.12 J
35.6
0.5 U
12.4
0.51
0.5 U
1.38
81.4
64.8
0.73
175
135
0.5 U
0.5 U
8.4
0.5 U
13.5
0.5 U
3.48
0.5 U
28.6
0.5 U
0.5 U
1.28
0.63
3.67
0.5 U
18.4
46.2
0.76
0.5 U
0.5 U
0.21 J
0.54
8.49
0.5 U
0.5 U
0.5 U
0.5 U
0.33 J
0.5 U
315
8.12
12.3
245
143
-------
Table 6-8. Fabrication Area Summary of groundwater analytical results for cis-DCE
Wah Chang Five Year Review Report
Station
Well Type
ROD
Oct-2002
Apr-2003
Oct-2003
May-June-
July2004
Sept-Oct 2004
May-june 2005
Oct-Nov-2005
May-2006
Oct-Nov-2006
May-June 2007
Oct-Nov-2007
May-2008
Oct-2008
June-July 2009
Dec-2009
April-May 2010
Nov-Dec-2010
May-2011
Nov-2011
MW-01A
HS
70
1 U
1 U
1.12
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
MW-02A
HS
70
3.4
2.02
1.86
1.72
1.47
1.3
1.2
1.1
0.97
0.83
0.77
0.71
0.73
0.58
0.49 J
0.41 J
0.5 U
0.5 U
0.5 U
MW-03A
HS
70
1 U
1 U
1 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
MW-04A
HS
70
4.5
1.71
3.14
1.06
2.94
1.3
1.3
0.85
1.7
0.84
0.76
0.87
1.38
1.74
1.29
0.98
0.67
0.71
0.5 U
PW-01A
HS
70
42.5
23.11
34.6
36.44
36.65
39.3
36
32.8
35.4
30
29.2
24.8
20.8
26.3
1.28
0.88
0.68
0.62
0.36 J
PW-03A
HS
70
1.3
1 U
0.53
0.5001
0.83
0.81
0.5 U
0.5 U
0.5 U
0.16 J
0.5 U
0.5 U
0.1 J
0.14 J
0.17 J
0.5 U
0.5 U
0.5 U
0.5 U
PW-10
NHS
70
5.63
1.93
3.4
2.07
1.88
1.5
2.3
1.5
2.3
2.6
2.4
2.1
2.23
1.68
1.67
1.52
0.75
1.1
0.66
PW-100A
HS
70
83.4
57.2
43.4
PW-101A
NHS
70
0.19 J
25.4
15.7
PW-11
HS
70
5.9
3.5
18.7
30.83
49.54
2.2
52.2
4.3
19.5
0.95
2.8
0.46 J
10.2
4.91
0.28 J
0.5 U
0.5 U
0.5 U
0.5 U
PW-12
HS
70
3.4
1.59
1.72
1.6
1.95
2.5
2.6
1.9
2.3
2.5
2.1
2.8
2.36 J
1.84 J
1.14 J
2.52
0.14 J
1.38
2.5 U
PW-13
HS
70
4.1
1 U
1 U
2.5 U
2.5 U
2.5 U
2.5 U
2.5 U
1.1 U
0.5 U
1.1 U
1.1 U
1.1 U
5 U
2.5 U
2.5 U
2.5 U
2.5 U
2.5 U
PW-14
NHS
70
0.5 U
PW-16A
NHS
70
1 U
1 U
1 U
0.5 U
0.89
0.86
0.98
2.1
0.96
1.2
0.67
1.01
1.25
0.72
0.5 U
0.5 U
0.5 U
0.5 U
PW-19A
NHS
70
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-30A
HS
70
2.4
1 U
1.86
2.5 U
2.5 U
2.5 U
1.1 U
0.9 J
1.2
1.4
0.81 J
1.1
1.1 J
1.08 J
0.57 J
1.1 U
1.1 U
1.1 U
1.1 U
PW-31A
NHS
70
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-42A
HS
70
22.4
41.07
19.84
47.65
39.7
54.3
160 D
35.4
35.9
38.4
35.2
40.3
30.3
34.1
21.4
19.2
16.7
6.54
5.6
PW-45A
HS
70
5
3.78
3.62
3.73
2.84
2.8
2.1
2.3
0.12 J
2.2
1.9
2
1.86
0.39 J
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-46A
NHS
70
5.7
4.13
4.07
8.52
2.32
4.4
4.6
0.08 J
4.8
2.7
3.7
1.96
4.14
4.54
4.12
3.59
3.55
2.81
PW-68A
HS
70
1 U
1 U
1 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-69A
HS
70
9.2
2.54
10 u
2.28
5 U
5 U
5 U
4.5
1.2 J
2.2 J
1.5
3.2
3.74 J
4.86 J
2.71 J
5.2 J
16.6
5.2
12.2
PW-70A
NHS
70
0.5 U
0.5 U
PW-71A
HS
70
3.4
1.97
2.06
1.59
2.59
2.1
2
1.5
0.38 J
0.5 U
0.35 J
0.49 J
0.43 J
0.09 J
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-72A
NHS
70
1 U
1 U
1 U
0.5 U
0.5 U
0.5 U
PW-73B
HS
70
44.1
32.52
37.77
30.61
29.75
27.8
25.8
18.9
17.5
19.5
18.1
16.3
14.5
4.68
7.58
7.18
5.86
3.64
2.69
PW-74B
NHS
70
3
1.34
1.81
1.65
1.41
1.8
2.1
2.7
1.9
2
2.6
2.2
3.05
0.5 U
0.76
0.59
0.5 U
0.44 J
0.5 U
PW-75A
NHS
70
2.5
1 U
1.54
0.5 U
0.5 U
0.56
0.5 U
0.16 J
2.5
0.46 J
0.73
0.5 U
0.28 J
0.37 J
0.24 J
0.5 U
0.5 U
0.5 U
0.5 U
PW-76A
P
70
0.5 U
1 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
1.89
1.23
0.56
0.22 J
PW-77A
NHS
70
0.5 U
1.57
5.4
6.5
8.78
9.9
10
2.3
6.3
1.5
3.1
0.5 U
1.69
1.74
1.85
1.79
1.37
1.39
0.84
PW-78A
P
70
1 U
1 U
1 U
0.75
0.68
0.84
0.71
0.87
0.78
0.9
0.66
1
1.05
0.56
1.34
1.33
0.76
1.21
0.39 J
PW-79A
P
70
1 u
1 U
1.69
0.92
0.92
1.8
2.1
2.5
2.1
1.5
2.1
1.2
0.81
0.15 J
0.51
0.5 U
0.5 U
0.5 U
0.5 U
PW-80A
NHS
70
4.8
4.87
4.28
6.32
2.48
1.1
0.58
1.5
0.88
1.9
2.8
2.7
0.63
0.1
1.13
0.5 U
0.5 U
0.5 U
0.5 U
PW-82A
NHS
70
0.5 U
1 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-83A
HS
70
0.5 U
1 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.1 J
0.5 U
0.5 U
0.5 U
0.22 J
0.09 J
0.5 U
0.5 U
0.5 U
0.5 U
PW-84A
NHS
70
1.8
2.55
2.46
2.07
2.3
1.4
1.2
3.7
3.9
9.3
13.3
6.69
5.17
4.98
3.16
3.48
2.37
PW-85A
HS
70
1.5
1.71
1.44
1.27
1.34
1.4
1.7
1.3
1.9
1.7
2.1
3.4
3.04
4.4
2.81
2.43
2.28
1.56
1.34
PW-86A
HS
70
77.7
96.4
29.52
124 D
153 D
193 D
197 D
192 D
124 D
1.7
105 D
223 D
4.59
156
0.5
0.32 J
0.5 U
0.5 U
0.5 U
PW-87A
NHS
70
1 U
1 U
1 U
0.5 U
0.5 U
0.5
0.5 U
0.5 U
0.37 J
0.37 J
0.36 J
0.31 J
0.31 J
0.33 J
0.5 U
0.5 U
0.5 U
0.5 U
PW-88A
NHS
70
1 U
1 U
1.93
10.36
29.28
26.5
12.3
22.2
0.74
1.6
1.4
9.1
0.54
0.5 U
0.48 J
0.32 J
0.5 U
0.5 U
0.5 U
PW-89A
NHS
70
4.1
2.8
1 U
2.61
2.88
2.8
1.4
1.8
1
1.6
1.2
2.2
2.39
0.38 J
0.46 J
0.22 J
0.5 U
0.5 U
0.5 U
PW-91A
NHS
70
1.2
1 U
1 U
0.57
0.6
0.5 U
0.65
0.47 J
0.5 U
0.5 U
0.2 J
193
0.33 J
0.37 J
0.31 J
0.12 J
0.08 J
0.33 J
0.5 U
PW-92A
NHS
70
1 U
1 U
1 u
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-93A
HS
70
124
190
141
276
299
31.9
70.7
26.2
34.4
PW-94A
HS
70
1.49
0.5 U
1.4
0.7
1.31
0.86
1.2
0.83
0.76
0.54
PW-95A
HS
70
1.6
1.7
1.66
5.8
3.01
4.2
0.43 J
2.74
0.5 U
PW-98A
NHS
70
32.9
77.5
25.9
18.2
12.1
14.5
PW-99A
HS
70
0.19 J
0.36 J
0.5 U
0.5 U
0.5 U
0.5 U
Notes:
U = not detected above reporting limit shown
D = Dilution
J = estimated value
Blank cells indicate no analysis performed or data missing
Shading indicates that ROD concentration was exceeded
P=Perimeter well, =NHS = Non hot spot well, HS = Hot spot well
(1) Initial GW samples were collected in September 2007 for PW-93A(B-07-12), PW-94A(B07-09), and PW-95A(B07-07) during the intial soil and groundwater investigation at the former CCA area
(2) Initial GW samples were collected in July 2009 for PW-98A and PW-99A.
(3) Initial GW samples were collected in August 2010 for PW-100A and PW-101A.
(4) Initial GW samples were collected in May 2010 for E-ll.
(5) Initial GW samples were collected in April 2010 for FW-6.
-------
Table 6-9. Fabrication Area Summary of groundwater analytical results for PCE
Wah Chang Five Year Review Report
Station
Well Type
ROD
Oct-2002
Apr-2003
Oct-2003
M ay-J u n e-J u Iy2004
Sept-Oct 2004
May-june 2005
Oct-Nov-2005
May-2006
Oct-Nov-2006
May-June 2007
Oct-Nov-2007
May-2008
Oct-2008
June-July 2009
Dec-2009
April-May 2010
Nov-Dec-2010
May-2011
Nov-2011
MW-01A
HS
5
1U
1 U
1U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
MW-02A
HS
5
1U
1 u
1U
0.5 U
0.5 U
0.5 U
0.5 U
0.1 J
0.5 U
0.5 U
0.5 U
0.07 J
0.06 J
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
MW-03A
HS
5
1U
1 u
1U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
MW-04A
HS
5
1U
1 u
1U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-01A
HS
5
1U
1 u
0.51
0.5 U
0.52
0.5 U
0.5 U
0.18 J
0.2 J
0.15 J
0.5 U
0.12 J
0.12 J
0.5 U
0.33 J
0.5 U
0.5 U
0.5 U
0.5 U
PW-03A
HS
5
1U
1 u
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.12 J
0.5 U
0.07 J
0.1 J
0.1 J
0.1 J
0.5 U
0.5 U
0.5 U
0.5 U
PW-10
NHS
5
3.33
2.69
2.62
2.39
2.8
1.9
2.1
1.9
2
3
1.3
2.3
1.21
0.52
0.6
0.5 U
0.5 U
0.5 U
0.5 U
PW-100A
HS
5
7.23
2.99
1.45
PW-101A
NHS
5
0.5 U
5.28
4.18
PW-11
HS
5
4
1.85
8.87
11.56
19.32
2.4
16.2
1.9
7.6
1.1
1.1
0.4 J
1.96
0.96
0.33 J
0.5 U
0.5 U
0.5 U
0.5 U
PW-12
HS
5
5.7
1.97
2.14
2.72
3.5
7.7
10.5
3.2
3.2
7.3
3.2
6.4
7.42
9.21
3.94
2.5 U
2.5 U
2.5 U
2.5 U
PW-13
HS
5
3.4
1.54
1.39
2.5 U
2.5 U
5.1
2.5 U
2.5 U
1.5
0.62
0.96 J
1.7
1.3
3.5 J
1.35 J
2.1 J
2.5 U
2.5 U
2.5 U
PW-14
NHS
5
0.28 J
PW-16A
NHS
5
1U
1 U
1U
0.5 U
0.5 U
0.5 U
0.32 J
0.8
0.45 J
0.35 J
0.23 J
0.29 J
0.29 J
0.21 J
0.5 U
0.5 U
0.5 U
0.5 U
PW-19A
NHS
5
0.11 J
0.5 U
0.21 J
0.5 U
0.12 J
0.11 J
0.09 J
0.1 J
0.5 U
0.5 U
0.5 U
0.5 U
PW-30A
HS
5
1.2
1 U
1U
2.5 U
2.5 U
2.5 U
1.1 U
0.75 J
1
0.77
2.5 U
0.63 J
1.14 J
0.68 J
0.32 J
1.1 U
1.1 U
1.1 U
1.1 U
PW-31A
NHS
5
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-42A
HS
5
2.4
1.33
1.62
0.63
0.56
1.5
40.7
0.5 U
0.39 J
3.8
2.6
3.5
4.36
0.08 J
0.41 J
0.5 U
0.5 U
0.5 U
0.5 U
PW-45A
HS
5
1U
1 U
1U
0.5 U
0.5 U
0.5 U
0.5 U
0.13 J
0.5 U
0.2 J
0.5 U
0.15 J
0.11 J
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-46A
NHS
5
1U
1 U
1U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-68A
HS
5
1U
1 u
1U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-69A
HS
5
15.5
11.41
10.27
13.04
8.98
14.3
12
13.4
7.6
11.7
3.9
11.8
8.27
15.5
10.5
8.21
6.69
7.12
4.26
PW-70A
NHS
5
0.5 U
0.5 U
PW-71A
HS
5
8.5
8.54
10.06
4.91
13.39
11.3
0.75
0.5 U
0.09 J
0.5 U
0.2 J
0.16 J
0.09 J
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-72A
NHS
5
1U
1 U
1U
0.5 U
0.5 U
0.5 U
PW-73B
HS
5
1U
1 U
1U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-74B
NHS
5
1U
1 U
1U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-75A
NHS
5
1U
1 U
1U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-76A
P
5
0.5 U
1 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-77A
NHS
5
0.5 U
1 U
0.5 U
0.5 U
0.5 U
0.5 U
1.1 U
0.36 J
0.37 J
0.53 J
1.1 U
0.48 J
1.1 U
0.47 J
0.42 J
0.5 U
0.5 U
0.5 U
0.5 U
PW-78A
P
5
1U
1 U
1U
0.61
0.5 U
0.6
0.5 U
0.5
0.54
0.66
0.23 J
0.65
0.57
0.68
0.6
0.72
0.5 U
0.44 J
0.5 U
PW-79A
P
5
1U
1 U
1U
0.5 U
0.5 U
0.5 U
0.5 U
0.59
0.5 U
0.76
0.63
0.63
0.23 J
0.5 U
0.15 J
0.5 U
0.5 U
0.5 U
0.5 U
PW-80A
NHS
5
1.9
2.25
1.5
2.56
1.13
0.5 U
0.5 U
0.55
0.5 U
0.59
0.54
0.46 J
0.12 J
0.5 U
0.14 J
0.5 U
0.5 U
0.5 U
0.5 U
PW-82A
NHS
5
0.5 U
1 U
0.5 U
0.5 U
0.5 U
0.5 U
0.13 J
0.5 U
0.13 J
0.11 J
0.1 J
0.14 J
0.15 J
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-83A
HS
5
0.5 U
1 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.1 J
0.5 U
0.5 U
0.5 U
0.5 U
0.09 J
0.5 U
0.5 U
0.5 U
0.5 U
PW-84A
NHS
5
1U
1 u
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.11 J
0.15 J
0.15 J
0.1 J
0.31 J
0.11 J
0.5 U
0.5 U
0.5 U
PW-85A
HS
5
1U
1 u
1U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.17 J
0.26 J
0.21 J
0.2 J
0.25 J
0.18 J
0.26 J
0.5 U
0.5 U
0.5 U
0.5 U
PW-86A
HS
5
5.8
1 u
9.1
4.41
2.62
3.6
3.1
2.1
2.1
0.82
1.7
1.2
0.44 J
3.21
0.41 J
0.5 U
0.5 U
0.5 U
0.5 U
PW-87A
NHS
5
1U
1 u
1U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-88A
NHS
5
1U
1 u
1U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.14 J
0.14 J
0.22 J
0.12 J
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-89A
NHS
5
1U
1 u
1U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.36 J
0.26 J
0.26 J
0.26 J
0.31 J
0.16 J
0.5 U
0.5 U
0.5 U
0.5 U
PW-91A
NHS
5
1U
1 u
1U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
35
0.5 U
0.08 J
0.4 J
0.5 U
0.5 U
0.5 U
0.5 U
PW-92A
NHS
5
1U
1 u
1U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-93A
HS
5
36.8
34.1
40.8 J
40
79
31.5
5.26 J
14.3
1.18 J
PW-94A
HS
5
1U
0.39 J
1.2
0.25 J
0.12 J
0.19 J
0.5 U
0.1 J
0.5 U
0.5 U
PW-95A
HS
5
1.7
2.7
2.21
4.28
1.72
1.51
1.12
0.65
0.78
PW-98A
NHS
5
16.3
8.46
6.84
3.59
3.11
1.57
PW-99A
HS
5
0.21 J
0.37 J
0.5 U
0.5 U
0.5 U
0.5 U
Notes:
U = not detected above reporting limit shown
D = Dilution
J = estimated value
Blank cells indicate no analysis performed or missing data
Shading indicates that ROD concentration was exceeded or data missing
P=Perimeter well, =NHS = Non hot spot well, HS = Hot spot well
(1) Initial GW samples were collected in September 2007 for PW-93A(B-07-12), PW-94A(B07-09), and PW-95A(B07-07) during the intial soil and groundwater investigation at the former CCA area.
(2) Initial GW samples were collected in July 2009 for PW-98A and PW-99A.
(3) Initial GW samples were collected in August 2010 for PW-100A and PW-101A.
(4) Initial GW samples were collected in May 2010 for E-ll.
(5) Initial GW samples were collected in April 2010 for FW-6.
-------
Table 6-10. Fabrication Area Summary of groundwater analytical results for TCE
Wah Chang Five Year Review Report
Station
Well Type
ROD
Oct-2002
Apr-2003
Oct-2003
May-June-
July2004
Sept-Oct 2004
May-june 2005
Oct-Nov-2005
May-2006
Oct-Nov-2006
May-June 2007
Oct-Nov-2007
May-2008
Oct-2008
June-July 2009
Dec-2009
April-May 2010
Nov-Dec-2010
May-2011
Nov-2011
MW-01A
HS
5
1 U
1U
1 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
MW-02A
HS
5
2.1
1.55
1.32
1.41
1.11
1
0.87
0.89
0.83
0.66
0.64
0.57
0.56
0.54
0.35 J
0.2 J
0.5 U
0.5 U
0.5 U
MW-03A
HS
5
1 U
1U
1 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.1 J
0.5 U
0.5 U
0.5 U
0.11 J
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
MW-04A
HS
5
1 U
1U
1 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.09 J
0.5 U
0.12 J
0.24 J
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-01A
HS
5
10.1
9.01
8.51
10.79
9.77
13.3
9.6
10.9
10
10.4
6.7
7.2
5.29
5.23
1.38
0.56
0.5 U
0.33 J
0.5 U
PW-03A
HS
5
2.4
0.87
0.92
0.84
1.13
0.97
0.56
0.5 U
0.5 U
0.21 J
0.5 U
0.5 U
0.17 J
0.16 J
0.15 J
0.5 U
0.5 U
0.5 U
0.5 U
PW-10
NHS
5
9.15
3.73
4.65
3.63
3.67
2.9
3.7
2.5
3.4
3.4
2.3
2.3
2.39
2.07
1
0.5 U
0.5 U
0.5 U
0.5 U
PW-100A
HS
5
43
5.37
4.81
PW-101A
NHS
5
0.12 J
4.02
1.84
PW-11
HS
5
13.4
6.3
31.35
43.99
70.72
4
65
5.5
27.6
1.9
2.8
0.64
7.19
3.86
0.23 J
0.5 U
0.5 U
0.5 U
0.5 U
PW-12
HS
5
20.9
9.85
7.99
8.55
10.75
14.3
24.8
8.7
7.7
15.4
7.1
13.7
15.1
18.3
8.12
5.52
1.02 J
2.5 U
2.5 U
PW-13
HS
5
15.1
10.13
7.88
10.48
7.69
11
11
10.5
5.6
3.7
5
7.8
5.12
19.5
7.27
10.1
2.5 U
1.2 J
2.5 U
PW-14
NHS
5
0.5 U
PW-16A
NHS
5
1.3
0.51 J
1 U
0.68
1.38
1.2
1.4
3
1.4
1.1
0.76
1.08
1.2
0.57
0.5 U
0.5 U
0.5 U
0.5 U
PW-19A
NHS
5
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-30A
HS
5
4.6
1.14
3.75
3.55
2.6
4
1.9
3.1
3.9
2.4
1.8 J
2.1
3.08
2.17
0.85 J
1.1 u
1.1 U
1.1 U
1.1 U
PW-31A
NHS
5
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.1 J
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-42A
HS
5
84
54.49
105.24 D
66.36
92.99
82
1100 D
20.4
39.4
77.3
52.2
59.5
83.6
6.76
12.8
8.7
6.2
5.7
3.7
PW-45A
HS
5
2.5
2.14
2.04
2.04
1.82
1.7
1.6
1.4
0.12 J
1.8
0.98
1.3
1.16
0.37 J
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-46A
NHS
5
7.4
6.25
5.61
11.41
3.24
5.8
5.7
0.5 U
5.4
2.6
3.8
2.07
4.18
3.68
3.33
2.11
1.86
1.89
PW-68A
HS
5
1 U
0.5 U
1 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-69A
HS
5
8.4
8.51
10 U
8.65
5 U
8.8
6
5.9
2.5 J
3.2 J
1.1
3.3
2.99 J
5.48
2.32 J
5.3
4.23
3.96
1.96
PW-70A
NHS
5
0.17 J
0.5 U
PW-71A
HS
5
324 D
221.1
249.1 D
88.71
330 D
244 D
21.5
2
0.55
0.5 U
0.3 J
0.8
0.47 J
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-72A
NHS
5
1 U
0.5 U
1 U
0.5 U
0.5 U
0.5 U
PW-73B
HS
5
24
19.14
18.51
14.58
14.46
14.5
13.1
9.7
8.1
10.8
10.7
8.9
8
2.15
3.46
2.52
1.29
0.89
0.26 J
PW-74B
NHS
5
4.9
2.91
3.19
2.67
2.27
2.7
3.7
3.8
2.8
3
2.8
2.8
4
0.5 U
0.82
0.67
0.5 U
0.33 J
0.5 U
PW-75A
NHS
5
3.5
1U
2.24
0.91
0.65
0.9
0.5 U
0.31 J
4
0.58
1.3
0.29 J
0.37 J
0.49 J
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-76A
P
5
0.53
0.79
0.5 U
0.5 U
0.84
1.4
0.5 U
0.5 U
0.5 U
0.12 J
0.16 J
0.08 J
0.2 J
0.16 J
0.42 J
0.5 U
0.5 U
0.5 U
0.5 U
PW-77A
NHS
5
2.89
2.41
3.04
2.74
4
4.1
4.2
3.4
3.7
3.8
2.9
3.2
3.27
3.09
2.44
1.98
1.72
1.45
0.69
PW-78A
P
5
1 U
1.9
1.51
1.5
1.28
1.8
1.3
1.7
1.5
1.9
0.78
1.9
1.8
2.05
1.73
1.94
0.75
0.63
0.55
PW-79A
P
5
1 U
2.24
3.21
1.96
1.44
2.4
2.5
3.2
2.6
2.8
3.3
2.5
1.11
0.5 U
0.58
0.5 U
0.5 U
0.5 U
0.5 U
PW-80A
NHS
5
11.1
11.88
8.64
11.25
4.69
2
1
2
1.3
2.3
1.9
2.1
0.55
0.09
0.48 J
0.5 U
0.5 U
0.5 U
0.5 U
PW-82A
NHS
5
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-83A
HS
5
0.8
0.5 U
0.58
0.51
0.50001
0.5 U
0.5 U
0.5 U
0.5 U
0.24 J
0.5 U
0.1 J
0.17 J
0.34 J
0.11 J
0.5 U
0.5 U
0.5 U
0.5 U
PW-84A
NHS
5
1 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
1.9
14.5
38.7
36.1
10.4
3.93
3.34
1.69
1.48
0.67
PW-85A
HS
5
1 u
1.37
1.05
0.62
0.57
0.77
0.76
0.55
1.1
4.3
4.6
8.3
7.62
6.11
2.09
1.89
0.68
0.81
0.23 J
PW-86A
HS
5
289 D
215.4
359.61 D
281 D
272 D
275 D
258 D
205 D
137 D
11.2
116 D
124 D
8.01
164
3.97
3.56
0.74
2.41
0.47 J
PW-87A
NHS
5
1 U
0.5 U
1 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.08 J
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-88A
NHS
5
1 u
0.5 U
1.52
7.68
21.79
22.4
10.3
17
0.63
1.3
0.84
6.8
0.6
0.5 U
0.39 J
0.5 U
0.5 U
0.5 U
0.5 U
PW-89A
NHS
5
8.6
3.02
2.56
3.39
3.56
3.4
2.6
2.7
1.8
3
1.6
3.1
3.01
0.9
0.86
0.77
0.62
0.26 J
0.5 U
PW-91A
NHS
5
2.2
0.97
1.01
0.86
0.5 U
0.59
0.5 U
0.49 J
0.5 U
0.5 U
0.11 J
69
0.13 J
0.33 J
0.2 J
0.5 U
0.5 U
0.5 U
0.5 U
PW-92A
NHS
5
1 U
0.5 U
1 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-93A
HS
5
57.1
71.8
87.9
60.3
157
16.7 J
29.4
2.13 J
17.4
PW-94A
HS
5
1 u
0.25 J
0.81 J
0.29 J
0.32 J
0.21 J
0.31 J
0.23 J
0.5 U
0.5 U
PW-95A
HS
5
0.73
1.3
0.8
9.94
1.41
2.3
0.68
1.9
0.23 J
PW-98A
NHS
5
336
150
108
26.3
46.1
18.4
PW-99A
HS
5
0.77
1.04
0.23 J
0.5 U
0.5 U
0.5 U
Notes:
U = not detected above reporting limit shown
D = Dilution
J = estimated value
Blank cells indicate no analysis performed or data missing
Shading indicates that ROD concentration was exceeded
P=Perimeter well, =NHS = Non hot spot well, HS = Hot spot well
(1) Initial GW samples were collected in September 2007 for PW-93A(B-07-12), PW-94A(B07-09), and PW-95A(B07-07) during the intial soil and groundwater investigation at the former CCA area.
(2) Initial GW samples were collected in July 2009 for PW-98A and PW-99A.
(3) Initial GW samples were collected in August 2010 for PW-100A and PW-101A.
(4) Initial GW samples were collected in May 2010 for E-ll.
(5) Initial GW samples were collected in April 2010 for FW-6.
-------
Table 6-11. Fabrication Area Summary of groundwater analytical results for VC
Wah Chang Five Year Review Report
Station
Well Type
ROD
Oct-2002
Apr-2003
Oct-2003
May-June-
July2004
Sept-Oct 2004
May-june 2005
Oct-Nov-2005
May-2006
Oct-Nov-2006
May-June 2007
Oct-Nov-2007
May-2008
Oct-2008
June-July 2009
Dec-2009
April-May 2010
Nov-Dec-2010
May-2011
Nov-2011
MW-01A
HS
2
1.2
0.69 J
1U
2.14
0.5 U
0.74
0.5 U
0.5 U
0.5 U
0.17 J
0.5 U
0.5 U
0.5 U
0.5 U
0.9
0.99
0.82
0.62
0.61
MW-02A
HS
2
161 D
143.6
172 D
160 D
141 D
100
136 D
125 D
128 D
123 D
87.3
83.6
85.7
68.2
109
52.7
36.5
42.1
16.4
MW-03A
HS
2
1U
1 U
1U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.39 J
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
MW-04A
HS
2
22.4
12.91
19.21
7.75
14.27
6.9
7.2
6.4
10.2
4.6
4.4
4.6
8.27
9.23
10.2
8.51
7.93
6.21
5.41
PW-01A
HS
2
28.2
22.42
24.71
34.07
31.83
29.1
23.7
18
34.5
28.6
50
22.4
21.6
23.4
0.77
0.61
0.51
0.43 J
0.42 J
PW-03A
HS
2
1.7
0.5 U
0.79
0.77
0.69
0.78
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.17 J
0.5 U
0.5 U
0.5 U
0.5 U
PW-10
NHS
2
1.18
1 U
1U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.25 J
0.5 U
0.5 U
0.21 J
0.13 J
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-100A
HS
2
5.18
19.9
7.64
PW-101A
NHS
2
0.5 U
36.5
26.4
PW-11
HS
2
1U
0.65 J
1.9
0.53
0.93
0.5 U
2.9
0.5 U
0.84
0.5 U
0.5 U
0.5 U
1.07
0.43 J
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-12
HS
2
11.2
9.81
9.41
9.68
10.91
11.2
12.3
12.1
8
18.7
27.6
34.6
15.8
15.1
12
10.1
8.1
4.3
6.3
PW-13
HS
2
10
10.5
9.96
13.58
7.64
7.7
7.1
7.7
4.8
3.4
10.4
4.9
4.93
4.62 J
2.73
2.43 J
2.13 J
2.5 U
1.11 J
PW-14
NHS
2
0.5 U
PW-16A
NHS
2
1U
1 U
1U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-19A
NHS
2
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-30A
HS
2
1U
0.5 U
1U
2.5 U
2.5 U
2.5 U
1.1 U
2.5 U
0.5 U
0.14 J
2.5 U
1.1 U
2.5 U
0.24 J
1.1 U
1.1 U
1.1 U
1.1 U
1.1 U
PW-31A
NHS
2
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-42A
HS
2
2
6.63
1.53
6.98
2.84
3
1.4
2.6
3.7
2.5
4.7
3.6
2.04
5.14
2.99
2.59
2.11
2.11
0.84
PW-45A
HS
2
25.6
21.33
15.25
27.64
11.81
14.1
6.6
23.1
0.57
24.8
47.3
30.4
34
0.33 J
0.15 J
0.5 U
0.5 U
0.5 U
0.5 U
PW-46A
NHS
2
1U
0.98 J
1U
2.35
0.63
1
1.4
0.5 U
1.4
1.5
0.97
0.67
1.65
2.28
2.03
1.99
1.89
1.32
PW-68A
HS
2
1U
0.5 U
1U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-69A
HS
2
17.6
2.32
10 u
3.29
5 U
5 U
5 U
4.1
5 U
1.4 J
0.96
1.4
5 U
3.18 J
4.76 J
4.8 J
1.06
3.8 J
0.43 J
PW-70A
NHS
2
0.5 U
0.5 U
PW-71A
HS
2
1U
0.5 U
1U
0.5 U
0.5 U
0.5 U
4.2
0.5 U
0.5 U
0.5 U
0.7
0.5 U
0.47 J
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-72A
NHS
2
1U
0.5 U
1U
0.5 U
0.5 U
0.5 U
PW-73B
HS
2
10.4
11.47
11.94
16.36
13.84
12.4
12.2
12.9
12.1
13.4
12.1
11.3
12
5.14
9.36
7.62
6.85
6.58
3.48
PW-74B
NHS
2
1U
0.5 U
1U
0.5 U
0.5 U
0.5 U
0.52
0.7
0.61
0.58
1.5
0.73
1.42
0.5 U
0.53
0.49 J
0.5 U
0.5 U
0.5 U
PW-75A
NHS
2
1U
1 U
1U
0.51
0.5 U
0.5 U
0.5 U
0.5 U
0.62
0.5 U
0.5 U
0.5 U
0.22 J
0.5 U
0.13 J
0.5 U
0.12 J
0.5 U
0.5 U
PW-76A
P
2
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-77A
NHS
2
0.5 U
3.18
9.55
14.8
19.4
12.5
11.5
3.7
5.5
2.7
6.4
1.7
3.14
0.49 J
3.61
3.15
2.86
1.89
1.13
PW-78A
P
2
1U
0.5 U
1U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.21 J
0.2 J
0.5 U
0.18 J
0.27 J
0.14 J
0.36 J
0.5 U
0.5 U
0.5 U
0.5 U
PW-79A
P
2
1U
0.5 U
1U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-80A
NHS
2
1U
0.95
1U
0.82
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.23 J
0.5 U
0.5 U
0.5 U
0.5 U
PW-82A
NHS
2
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-83A
HS
2
3.1
0.5 U
2.5
2.4
1.86
1.5
2.8
1.2
2.3
0.84
0.57
0.5 U
0.38 J
1.65
0.82
0.67
0.43 J
0.33 J
0.11 J
PW-84A
NHS
2
1U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-85A
HS
2
1U
0.5 U
1U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-86A
HS
2
20.3
22.74
2.97
26.69
21.69
16.1
14.3
15.8
7.9
0.17 J
10
11.1
0.3 J
7.62
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-87A
NHS
2
1U
0.78
1U
1.22
0.5 U
1.2
1.4
0.5 U
1
1.9
1.3
0.85
0.93
1.35
1.12
0.98
0.89
0.34 J
PW-88A
NHS
2
1U
0.5 U
1U
0.5 U
1.1
0.95
0.5 U
0.98
0.5 U
0.5 U
0.5 U
0.31 J
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-89A
NHS
2
1U
0.73
1U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.51
0.54
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-91A
NHS
2
1U
0.5 U
1U
0.5 U
0.99
0.5 U
0.77
0.53
0.5 U
0.5 U
0.4 J
39.9
0.49 J
0.35 J
0.24 J
0.5 U
0.5 U
0.5 U
0.5 U
PW-92A
NHS
2
1U
0.5 U
1U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
PW-93A
HS
2
40.6
40.2
34.9 J
31.3
14.7
13.5 J
10 U
25 U
10 U
PW-94A
HS
2
1U
2.5
3.6
1.71
1.63
1.54
1.7
1.39
0.68
0.81
PW-95A
HS
2
7.1
1.9
3.75
1.98
5.75
3.8
0.24 J
2.1
0.5 U
PW-98A
NHS
2
8.86
131
95.2
78.2
25.3
34.4
PW-99A
HS
2
0.32 J
1.53
4.23
5.33
2.48
2.84
Notes:
Bold values are MRL above the ROD performance standard
U = not detected above reporting limit shown
D = Dilution
J = estimated value
Blank cells indicate no analysis performed or data missing
Shading indicates that ROD concentration was exceeded
P=Perimeter well, =NHS = Non hot spot well, HS = Hot spot well
(1) Initial GW samples were collected in September 2007 for PW-93A(B-07-12), PW-94A(B07-09), and PW-95A(B07-07) during the intial soil and groundwater investigation at the former CCA area.
(2) Initial GW samples were collected in July 2009 for PW-98A and PW-99A.
(3) Initial GW samples were collected in August 2010 for PW-100A and PW-101A.
(4) Initial GW samples were collected in May 2010 for E-ll.
(5) Initial GW samples were collected in April 2010 for FW-6.
-------
Table 6-12. Fabrication Area Summary of groundwater analytical results for Fluoride
Wah Chang Five Year Review Report
Station
Well Type
ROD
9
§
Apr-03
9
§
May-Juno-
July2004
Sopt-Oct 2004
May-juno 2005
Oct-Nov-2005
M.iy-06
Oct-Nov-2006
May-Juno
2007
1
1
§
May-08
Oct-08
Juno-July 2009
1
April May
2010
Nov-Doc-2010
May-11
Nov-11
PW-01A
HS
2
0.92
1.01
0.68
0.17
0.55
0.67
PW-03A
HS
2
1.39
1.02
1.57
0.89
1.54
0.86
PW-10
NHS
2
53.5
39.9
38.5
23.3
32.5
25.4
25
24.2
27.7
23.3
26.2
16.1
24
25
20
18
15
14
PW-11
HS
2
2.08
1.9
2.3
1.68
1.67
1.59
1.7
2.8
0.36
2.1
2.1
1.56
2
2
2 U
2 U
2 U
2 U
PW-12
HS
2
0.95
0.98
1.3
1.17
1.02
0.62
0.7
1.5
1.7
2.1
2.4
2.1
3.27
2
1 U
1 U
1 U
1 U
1 U
PW-13
HS
2
9.67
14.7
12.8
19.6
10.6
10.5
11.8
14.5
18.4
10
9.4
17.6
10.8
69
31
27
24
21
PW-14
NHS
2
1.8
PW-16A
NHS
2
0.12 J
0.11
0.1 u
0.1 U
0.1 U
0.1 U
1 U
1 U
1 U
1 u
1 U
PW-19A
NHS
2
0.11
0.31 J
0.21
0.16
0.14
0.16
1 U
PW-30A
HS
2
0.25
PW-31A
NHS
2
0.1
0.1 U
0.1 U
PW-76A
P
2
0.95
0.3
0.46
0.2
0.31
0.16
0.17
0.48 J
0.52
0.45
0.46
0.41
0.47
1 u
1 U
1 U
1 U
1 u
1 U
PW-77A
NHS
2
1.01
0.19
0.32
0.2
1 U
0.1 U
0.1 U
0.3 J
0.35
0.28
0.29
0.29
0.32
1 u
1 U
1 u
1 U
1 u
1 U
PW-78A
P
2
0.89
0.12
0.2
0.1
0.17
0.1 U
0.1 U
0.28 J
0.36
0.29
0.29
0.3
0.34
1 u
1 U
1 u
1 U
1 u
1 U
PW-79A
P
2
1.32
0.63
0.94
1.12
1.53
1.36
1.2
2.4
3.1
2.8
2.9
3.1
1.74
1 u
1 U
1 u
1 U
1 u
1 U
PW-80A
NHS
2
0.51
0.14
0.2
0.1
0.1 U
0.1 U
0.1 U
0.17 J
0.23
0.18
0.16
0.16
0.16
1 u
1 U
1 u
1 U
1 u
1 U
PW-82A
NHS
2
1.12
0.25
0.49
0.23
0.32
0.23
0.46 J
0.53
0.52
0.48
0.58
0.62
1 u
1 U
1 u
1 U
1 u
1 U
PW-83A
HS
2
0.89
0.13
0.25
0.1 U
0.12
0.1 U
PW-84A
NHS
2
PW-89A
NHS
2
15.4
16.8
17
16.6
17.3
18.8
27
10
8.2
7.5
7.8
6.4
PW-91A
NHS
2
0.44
0.35
PW-92A
NHS
2
1.25
0.31
0.17
PW-98A
NHS
2
19
PW-99A
HS
2
10
9.8
7.3
9.4
3.4
Notes:
U = not detected above reporting limit shown
D = Dilution
J = estimated value
Blank cells indicate no analysis performed
Shading indicates that ROD concentration was exceeded
P=Perimeter well, =NHS = Non hot spot well, HS = Hot spot well
(1) Initial GW samples were collected in September 2007 for PW-93A(B-07-12), PW-94A(B07-09), and PW-95A(B07-07) during the intial soil and groundwater investigation at the former CCA area
(2) Initial GW samples were collected in July 2009 for PW-98A and PW-99A.
(3) Initial GW samples were collected in August 2010 for PW-100A and PW-101A.
(4) Initial GW samples were collected in May 2010 for E-ll.
(5) Initial GW samples were collected in April 2010 for FW-6.
-------
Table 6-13. Fabrication Area Summary of groundwater analytical results for Nitrate
Wah Chang Five Year Review Report
Station
Well Type
ROD
Oct-2002
Apr-2003
Oct-2003
May-June-
July2004
Sept-Oct 2004
May-june 2005
Oct-Nov-2005
May-2006
Oct-Nov-2006
May-June
2007
Oct-Nov-2007
May-2008
Oct-2008
June-July 2009
Dec-2009
April-May
2010
Nov-Dec-2010
May-2011
Nov-2011
PW-01A
HS
10
0.1 u
6.02
0.02
PW-03A
HS
10
21.9
29.1
14.6
PW-10
NHS
10
0.75
0.4
0.5224
0.14
0.1 U
0.28
0.34
0.51
0.54
5 U
5 U
5 U
5 U
5 U
5 U
PW-11
HS
10
8.5
6.3
12.4
9.13
18.6
12.1
34.5
9.2
8.6
7.2
15.4
7
6
5.5
5.2
4.8
5 U
PW-12
HS
10
1
1.71
0.3194
0.75
0.446
0.37
0.51
0.4
0.82
1.9
0.35
0.85
0.42
5 U
5 U
5 U
5 U
5 U
5 U
PW-13
HS
10
9.74
47.6
14.5
58.5
26.7
45.2
39.5
26.5
10.1
2.2
30.1
25.1
160
33
29
27
22
22
PW-14
NHS
10
0.84
PW-16A
NHS
10
3.8
2.5
2.6
1.4
2.8
3.42
5 U
5 U
5 U
5 U
5 U
PW-19A
NHS
10
5.86
3.2
1.5
2.2
1.3
1.82
5 U
5 U
5 U
5 U
5 U
5 U
PW-30A
HS
10
0.5
0.86
2.431
PW-31A
NHS
10
7.03
11.9
13.4
11.6
PW-42A
HS
10
0.01 U
PW-45A
HS
10
0.048
PW-46A
NHS
10
0.1 U
0.18
PW-68A
HS
10
2.42
2.43
PW-69A
HS
10
0.01 U
PW-71A
HS
10
0.01 U
PW-75A
NHS
10
0.01 U
PW-76A
P
10
0.98
0.25
0.01 U
0.1
0.5
0.24
0.45
0.36
0.33
0.41
0.17
0.39
5 U
5 U
5 U
5 U
5 U
5 U
PW-77A
NHS
10
0.92
0.13
0.01 U
0.1
0.17
0.1 U
0.1 U
0.01 U
0.01 U
0.75
0.39
0.4
0.51
5 U
5 U
5 U
5 U
5 U
5 U
PW-78A
P
10
1.08
0.37
0.64
0.61
0.45
0.25
0.21
0.13
0.24
0.15
0.28
0.28
5 U
5 U
5 U
5 U
5 U
5 U
PW-79A
P
10
4.64
9.93
18.1
20.4
5.79
6.27
6.1
9.7
0.85
0.16
6.1
5.75
5 U
5 U
5 U
5 U
5 U
5 U
PW-80A
NHS
10
3.86
4.83
2.13
2.63
1.679
1.78
1.6
1.5
2.6
1.9
2.3
1.6
5 U
5 U
5 U
5 U
5 U
5 U
PW-82A
NHS
10
13.6
25.2
16.4
16.3
12.665
12.7
9
10.6
1.4
8.6
6.5
7.04
9
7
6
5
6
5
PW-83A
HS
10
4
23.6
6.24
11.4
7.98
4.7
PW-84A
NHS
10
0.38
PW-86A
HS
10
1.4
PW-88A
NHS
10
0.49
PW-89A
NHS
10
191
26.6
91
78.9
173
0.01 U
158
290
45
38
28
23
22
PW-92A
NHS
10
1.17
0.98
2.72
PW-98A
NHS
10
8.76
5 U
7.5
6.9
2.4
2.4
PW-99A
HS
10
2.31
5 U
5 U
5 U
5 U
5 U
Notes:
U = not detected above reporting limit shown
D = Dilution
J = estimated value
Blank cells indicate no analysis performed or data is missing
Shading indicates that ROD concentration was exceeded
P=Perimeter well, =NHS = Non hot spot well, HS = Hot spot well
(1) Initial GW samples were collected in September 2007 for PW-93A(B-07-12), PW-94A(B07-09), and PW-95A(B07-07) during the intial soil and groundwater investigation at the former CCA area.
(2) Initial GW samples were collected in July 2009 for PW-98A and PW-99A.
(3) Initial GW samples were collected in August 2010 for PW-100A and PW-101A.
(4) Initial GW samples were collected in May 2010 for E-ll.
(5) Initial GW samples were collected in April 2010 for FW-6.
-------
Table 6-14. Summary of VOCs detected in Surface Water (Murder and Truax Creeks) from November 2007 to
September 2010
Wan Chang Five Year Review
Oregon AWQC
Station
Parameter
units
Water and
Organism
Organism
Only
Nov-07
00
o
1
>
ro
2
00
o
1
ŚM
U
o
01
o
1
>
ro
2
Dec-09
Apr-10
Nov-10
MC-D
TCA
Hg/L
-
-
1.9
0.73
1.2
0.36 J
0.1 J
0.5 U
0.5 U
MC-D
DCA
Hg/L
-
-
0.79
0.29 J
0.52
0.13 J
0.5 U
0.5 U
0.5 U
MC-D
DCE
Hg/L
230
710
0.71
0.31 J
0.48 J
0.1 J
0.5 U
0.5 U
0.5 U
MC-D
cis-DCE
Hg/L
-
-
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
MC-D
PCE
Hg/L
0.24
0.33
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
CL)
MC-D
TCE
Hg/L
1.4
3
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
CL)
u
MC-D
VC
Hg/L
0.023
0.24
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
CL)
T3
3
MC-U
TCA
Hg/L
-
-
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
5
MC-U
DCA
Hg/L
-
-
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
MC-U
DCE
Hg/L
230
710
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
MC-U
cis-DCE
Hg/L
-
-
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
MC-U
PCE
Hg/L
0.24
0.33
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
MC-U
TCE
Hg/L
1.4
3
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
MC-U
VC
Hg/L
0.023
0.24
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
TC-D
TCA
Hg/L
-
-
0.14 J
0.1 J
0.5 U
0.09 J
0.5 U
0.5 U
0.5 U
TC-D
DCA
Hg/L
-
-
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.07 J
TC-D
DCE
Hg/L
230
710
0.14 J
0.11 J
0.07 J
0.5 U
0.5 U
0.5 U
0.5 U
TC-D
cis-DCE
Hg/L
-
-
0.22 J
0.17 J
0.14 J
0.5 U
0.5 U
0.5 U
0.5 U
TC-D
PCE
Hg/L
0.24
0.33
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
J*.
CL)
CL)
U
TC-D
TCE
Hg/L
1.4
3
0.11 J
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
TC-D
VC
Hg/L
0.023
0.24
0.15 J
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
X
CD
Z5
TC-U
TCA
Hg/L
-
-
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
H
TC-U
DCA
Hg/L
-
-
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
TC-U
DCE
Hg/L
230
710
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
TC-U
cis-DCE
Hg/L
-
-
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
TC-U
PCE
Hg/L
0.24
0.33
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
TC-U
TCE
Hg/L
1.4
3
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
TC-U
VC
Hg/L
0.023
0.24
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
Notes:
* Surface water data was not provided for 2006 or 2011
* Bold value indicates that method reporting limit is higher that the AWQC
AWQC = ambient water quality criteria
TCA = 1,1,1-trichloroethane
DCA = 1,1-dichloroethane
cis-DCE = cis-l,2-dichloroethene
PCE = tetrachloroethene
TCE = trichloroethene
VC = vinyl chloride
Hg/L = microgram per liter
U = Parameter not detected above the method reporting limit
J = Estimated value below reporting limit
-------
Table 6-15. Summary of EISB Performance Monitoring in the ASA Source area
Wah Chang Five Year Review Report
TMW-1
TMW-4
TMW-5
Well
Dnn
_ ..
TMW-1
TMW-1
TMW-1
TMW-1
TMW-1
TMW-4
TMW-4
TMW-4
TMW-4
TMW-4
Baseline
TMW-5
TMW-5
TMW-5
TMW-5
TMW-5
Date
KUL)
Baseline
(6/30/09)
(12/18/09)
(5/1/10)
1(12/20/10)
(5/18/11)
(11/16/11)
Baseline
(6/30/09)
(12/29/09)
(5/7/10)
(12/20/10)
(5/18/11)
(11/16/11)
(6/30/09)
(12/18/09)
(5/7/10)
(12/20/10)
(5/18/11)
(11/16/11)
CVOCs (ng/L)
Source Area Wells
Injection Area Well
1,1,1-TCA
200
48,200
11,400
1,720
52.3
1,120
26.9
1,170,000
721,000
583,000
583,000
343,000
168,000
47,300
47.9
25.1
1.34
11.1
1.1 U
1,1 -DCA
1,280
1,350
4,790
10,000
8,575
9,800
5,486
43,600
32,000
35,000
35,000
16,800
26,500
2,120
1,050
980
525
540
213
1,2-DCA
5
100
U
25
U
9.35
J
25
U
11.3 J
25
U
1,000
U
1,000
U
1,000
U
1,000
U
1,000
U
1,000
U
100
U
1.32
1.1
U
1.1
U
1.1
U
1.1 U
Chloroethane
-
43.6
J
5,490
9,150
8,150
7,432
6,487
1,000
U
1,000
U
1,000
U
1,000
U
1,000
U
1,000
U
100
U
158
211
318
189
245
TCE
5
382
92.4
95.1
12.3
J
54.5
25
U
6,210
1,980
720
J
720
J
120
J
1,000
U
334
3.71
1.02
1.1
U
0.89
J
1.1 U
cis-1,2-DCE
70
100
U
25
U
25
U
25
U
25 U
25
U
1,000
U
1,000
U
1,000
U
1,000
U
1,000
U
1,000
U
100
U
1.1 U
1.1
U
1.1
U
1.1
U
1.1 U
trans-1,2-DCE
100
100
U
25
U
25
U
25
U
25 U
25
U
1,000
U
1,000
U
1,000
U
1,000
U
1,000
U
1,000
U
100
U
1.1 U
1.1
U
1.1
U
1.1
U
1.1 U
1,1 -DCE
7
14,400
6,230
3,410
2,810
2,641
1853
128,000
40,600
42,500
42,500
38,200
14,700
15,100
132
141
98.3
54
68.5
Vinyl Chloride
2
100
U
98.7
123
78
89.9
45.7
1,000
U
1,000
U
1,000
U
1,000
U
1,000
U
1,000
U
100
U
88.2
92.1
68.1
68.3
45.4
Tetrachloroethylene
5
83
J
18.9
J
31.4
25
U
16.1
25
U
1,000
U
1,000
U
1,000
U
1,000
U
1,000
U
1,000
U
44.4
J
0.76 J
1.1
U
1.1
U
1.1
U
1.1 U
DHG (ng/L)
Methane
-
1.52
3.18
11.7
25.2
13
18.3
1.17
U
3.29
U
33.1
33.1
18.1
113
52.1
389
285
187
243
124
Ethane
-
1.13
3.26
1.08
2.08
1.09
2.15
1.05
U
16.1
U
15.2
15.2
13.1
15.8
1.11
2.31
2.81
1.65
2.18
1.73
Ethene
-
1.14
1.6
2.68
2.34
2.15
2.43
1.06
U
14.9
U
8.1
8.1
8.2
4.4
0.87
4.27
3.78
2.91
2.68
2.54
General Chemistry (mg/L)
Chloride
-
35
50
50
41
38
420
550
580
580
480
435
18
25
23
21
21
18
Nitrate-N
-
21
5
U
18
5
U
17
5
U
51
34
28
28
22
14
69
5 U
5
U
5
U
5
U
5 U
Sulfate
-
10
U
10
U
10
U
10
U
10
U
115
110
118
118
108
134
10
U
10 U
10
U
10
U
10
U
10 U
Alkalinity
-
569
923
847
782
467
127
134
128
128
113
142
3.4
3.2
1.8
1.6
1.6
1.2
TOC (mg/L)
-
-
5
U
320
800
312
284
7.8
180
175
175
151
164
1.4
2.2
2.1
2
1.8
2
Metals (mg/L)
Iron
-
31
66
63
55
46
43
46
42
42
38
26
27
37
35
26
34
21
Parameters
ORP (mV)
-
-18.2
-35.2
-79
-55.4
-94
-46.4
180.6
88.7
-11.2
-11.2
-11.2
-12.4
10.3
-43.6
-21.3
-75.8
-19.3
-96.8
Dissolved Oxygen (mg/L)
-
0.89
0.63
0.36
0.48
0.36
0.11
0.64
0.32
0.23
0.23
0.2
0.27
0.89
0.74
0.21
0.55
0.17
0.44
PH
-
6.13
6.98
6.28
6.78
6.23
6.83
5.78
6.53
6.02
6.02
6.12
6.89
6.31
6.78
6.14
6.68
6.13
6.66
Specific Conductance (us/cm)
-
732
840
2,418
813
2,433
885
1,281
1,991
1,168
1,168
1,248
1,767
4,538
5,984
4,681
5,318
4,714
5,341
Temperature (Celcius)
-
15.33
14.84
15.29
14.81
15.28
14.59
15.13
14.46
14.89
14.89
15.45
14.85
15.32
12.78
14.87
14.48
14.96
14.14
Notes:
Shaded indicates concentration exceeds ROD cleanup level
U= not detected above reporting limit shown.
J = Estimated value below reporting limit.
CVOC= Chlorinated volatile organic compound
DHG= Dissolved hydrocarbon gas
DCE= Dichloroethene
TCE= Trichloroethylene
DCA= 1,1- Dichloroethane
T CA= 1,1,1 - T richloroethane
ORP = Oxidation reduction potential
Hg/L = micrograms per liter
mg/L = milligrams per liter
mV= millivolts
uS/cm = microSiemens per centimeter
NS = Not sampled.
-------
Table 6-15. Summary of EISB Performance Monitoring in the ASA Source area
Wah Chang Five Year Review Report
Well
Date
ROD
E-11
Baseline
(5/1/09)
E-11
(12/29/09)
E-11
(5/1/10)
E-11
(12/20/10)
E-11
(5/17/11)
E-11
(11/15/11)
PW-13
Baseline
(6/30/09)
PW-13
(12/17/09)
PW-13
(5/1/10)
PW-13
(12/16/10)
PW-13
(5/31/11)
PW-13
(11/29/11)
FW-6
Baseline
(5/1/09)
FW-6
(12/29/09)
FW-6
(5/1/10)
FW-6
(11/16/10)
FW-6
(5/17/11)
FW-6
(11/9/11)
CVOCs (ng/L)
Injection Area Well
Perimeter Well
1,1,1-TCA
200
0.5
U
0.5
U
0.5
U
0.5
U
0.5
U
0.5
U
417
175
152
15.6
56
8.77
16.9
11.2
8.17
3.18
6.25
1.11
1,1 -DCA
1,280
0.5
U
0.24
J
0.5
U
0.5
U
0.5
U
0.5
U
3,310
1,710
1,310
1,524
789
1,125
4.26
4.59
4.82
6.13
3.1
4.18
1,2-DCA
5
0.5
U
0.5
U
0.5
U
0.5
U
0.5
U
0.5
U
1.95
J
0.8
J
0.77
J
2.5
U
2.5
U
2.5
U
0.5
U
0.5
U
0.5
U
0.5
U
0.5
U
0.5 U
Chloroethane
-
2.93
4.77
6.81
7.21
6.91
2.18
5.72
3.25
18.1
56.4
9.8
49.3
0.97
2.67
3.12
4.21
2.89
2.31
TCE
5
0.5
U
0.5
U
0.5
U
0.5
U
0.5
U
0.5
U
19.5
7.27
10.1
2.5
U
1.2
J
2.5
U
0.6
0.5
0.5
U
0.5
U
0.5
U
0.5 U
cis-1,2-DCE
70
0.5
U
0.5
U
0.5
U
0.5
U
0.5
U
0.5
U
5
U
2.5
U
2.5
U
2.5
U
2.5
U
2.5
U
0.5
U
0.5
U
0.5
U
0.5
U
0.5
U
0.5 U
trans-1,2-DCE
100
0.5
U
0.5
U
0.5
U
0.5
U
0.5
U
0.5
U
5
U
2.5
U
2.5
U
2.5
U
2.5
U
2.5
U
0.5
U
0.5
U
0.5
U
0.5
U
0.5
U
0.5 U
1,1 -DCE
7
0.5
U
0.23
J
0.44
J
0.52
0.5
U
0.5
U
849
432
352
263
189
135
0.5
U
0.12
J
0.22
J
0.5
U
0.18
J
0.5 U
Vinyl Chloride
2
0.11
J
0.38
J
0.5
U
0.5
U
0.5
U
0.5
U
4.62
J
2.73
2.43
J
2.13
J
2.5
U
1.11
J
0.5
U
0.5
U
0.5
U
0.5
U
0.5
U
0.5 U
Tetrachloroethylene
5
0.5
U
0.5
U
0.5
U
0.5
U
0.5
U
0.5
U
3.5
J
1.35
J
2.1
J
2.5
U
2.5
U
2.5
U
1.01
0.97
0.44
J
0.5
U
0.5
U
0.5 U
DHG (ng/L)
Methane
-
1,580
5,780
4,120
3,815
3,890
2,754
0.73
1.15
8.77
150
9.12
143
5.13
U
14.4
U
14.4
U
0.73
U
14.4
U
0.73 U
Ethane
-
1.07
U
1.09
U
0.55
J
0.43
J
0.53
J
0.68
J
1.16
U
1.17
U
0.65
J
0.87
J
0.71
J
0.66
J
1.21
U
1.38
U
1.38
U
1.38
U
1.25
U
1.38 U
Ethene
-
1.05
U
1.08
U
1.08
U
1.08
U
1.08
U
1.08
U
1.14
U
1.15
U
0.1
J
0.31
J
0.13
J
0.23
J
1.18
U
1.35
U
1.35
U
1.35
U
1.23
U
1.35 U
General Chemistry (mg/L)
Chloride
-
9.8
15
14
13
13
12
60
62
58
63
51
58
15
20
18
17
19
16
Nitrate-N
-
5
U
5
U
5
U
5
U
5
U
5
U
160
33
29
27
22
22
5
5
U
5
U
5
U
5
U
5 U
Sulfate
-
10
U
10
U
10
U
10
U
10
U
10
U
49
50
42
35
38
31
10
U
10
9
10
8.7
9
Alkalinity
-
567
878
652
632
632
532
65
101
98
78
73
67
276
436
402
390
401
278
TOC (mg/L)
-
-
1.6
85
79
77
72
55
5
U
5
U
5.8
5.7
4.1
4.3
3.2
11
10
9.5
9
7.8
Metals (mg/L)
Iron
-
19
23
21
18
20
15
0.23
0.18
0.22
0.21
0.17
0.15
0.14
0.16
0.15
0.16
0.14
0.13
Parameters
ORP (mV)
-
-18.2
-121.2
-21.3
-135
-18.3
-175
123.8
185.6
22.1
135.5
21.1
123.5
40.2
36
23.5
22.1
22.5
18.1
Dissolved Oxygen (mg/L)
-
0.42
0.25
0.34
0.22
0.33
0.21
0.38
0.31
0.11
0.27
0.09
0.25
0.78
3.54
0.35
2.15
0.32
1.33
PH
-
6.89
6.75
6.21
6.66
6.19
6.56
6.64
6.32
6.72
6.53
6.68
6.62
7.00
7.01
6.59
6.99
6.62
7.05
Specific Conductance (us/cm)
-
843
1,777
1,421
1,682
1,407
1,702
213
877
181
813
108
770
342
823
251
813
180
852
Temperature (Celcius)
-
14.78
13.69
14.56
14.23
14.61
14.3
14.57
15.2
13.98
14.81
13.67
14.75
15.12
15.96
14.84
15.46
14.95
16.03
Notes:
Shaded indicates concentration exceeds ROD cleanup lev
U= not detected above reporting limit shown.
J = Estimated value below reporting limit.
CVOC= Chlorinated volatile organic compound
DHG= Dissolved hydrocarbon gas
DCE= Dichloroethene
TCE= Trichloroethylene
DCA= 1,1- Dichloroethane
T CA= 1,1,1 - T richloroethane
ORP = Oxidation reduction potential
Hg/L = micrograms per liter
mg/L = milligrams per liter
mV= millivolts
uS/cm = microSiemens per centimeter
NS = Not sampled.
-------
Table 6-15. Summary of EISB Performance Monitoring in the ASA Source area
Wah Chang Five Year Review Report
Well
Date
ROD
PW-10
Baseline
(6/29/09)
PW-10
(12/17/09)
PW-10
(5/1/10)
PW-10
(11/16/10)
PW-10
(5/17/11)
PW-10
(11/9/11)
PW-11
Baseline
(6/30/09)
PW-11
4-Month
(12/17/09)
PW-11
8-Month
(5/1/10)
PW-11
12-Month
(10/1/10)
PW-77A
Baseline
(6/29/09)
PW-77A
(12/17/09)
PW-77A
(5/1/10)
PW-77A
(12/16/10)
PW-77A
(5/10/11)
PW-77A
(11/9/11)
PW-78A
Baseline
(6/29/09)
PW-78A
(12/17/09)
CVOCs (ng/L)
Perimeter Well
1,1,1-TCA
200
16.1
16.6
1.23
0.13
J
0.68
0.5
U
16.5
21.1
15.2
4.61
3.57
4.97
2.15
1.08
1.26
0.53
1.79
10.5
1,1 -DCA
1,280
58.8
31.8
28.6
35.1
23.9
22.2
3.77
3.79
4.12
8.15
212
227
216
186
143
142
141
114
1,2-DCA
5
0.15 J
0.5
U
0.5
U
0.5
U
0.5
U
0.5
U
0.5
U
0.5
U
0.5
U
0.5
U
0.5
U
0.5
U
0.5
U
0.5
U
0.5
U
0.5
U
0.51
0.47 J
Chloroethane
-
6.07
3.55
6.82
7.25
7.21
4.17
0.35
J
0.34
J
1.23
2.54
14.7
2.05
5.86
6.93
5.72
5.48
0.5
J
1.95
TCE
5
2.07
1
0.5
U
0.5
U
0.5
U
0.5
U
3.86
0.23
J
0.5
U
0.5
U
3.09
2.44
1.98
1.72
1.45
0.69
2.05
1.73
cis-1,2-DCE
70
1.68
1.67
1.52
0.75
1.1
0.66
4.91
0.28
J
0.5
U
0.5
U
1.74
1.85
1.79
1.37
1.39
0.84
0.56
1.34
trans-1,2-DCE
100
0.5 U
0.5
U
0.5
U
0.5
u
0.5
U
0.5
U
0.5
U
0.5
U
0.5
U
0.5
U
0.5
U
0.5
U
0.5
U
0.5
U
0.5
U
0.5
U
0.5
U
0.5 U
1,1 -DCE
7
1.91
1.17
2.55
3.51
1.45
1.38
11.5
1.05
2.11
1.15
30.8
34.4
33.8
26.5
26.4
18.4
71.3
83.8
Vinyl Chloride
2
0.13 J
0.5
U
0.5
U
0.5
u
0.5
U
0.5
U
0.43
J
0.5
U
0.5
U
0.5
U
0.49
J
3.61
3.15
2.86
1.89
1.13
0.14
J
0.36 J
Tetrachloroethylene
5
0.52
0.6
0.5
U
0.5
u
0.5
U
0.5
U
0.96
0.33
J
0.5
U
0.5
U
0.47
J
0.42
J
0.5
U
0.5
U
0.5
U
0.5
U
0.68
0.6
DHG (ng/L)
Methane
-
NS
NS
NS
NS
NS
NS
0.63
u
0.63
u
0.63
U
0.63
U
2.78
3.37
5.68
4.62
6.42
3.84
8.15
21.8
Ethane
-
NS
NS
NS
NS
NS
NS
1.19
u
1.18
u
1.82
1.52
1.17
U
1.37
U
2.01
1.89
1.18
1.64
1.11
U
1.15 U
Ethene
-
NS
NS
NS
NS
NS
NS
1.15
u
1.13
u
1.33
1.18
1.15
U
1.34
U
1.34
U
1.67
U
1.34
U
1.67
1.1
U
1.13 U
General Chemistry (mg/L)
Chloride
-
NS
NS
NS
NS
NS
NS
10
u
10
u
10
U
10
U
640
770
680
550
480
425
55
50
Nitrate-N
-
5 U
5
U
5
U
5
u
5
U
5
U
7
6
5.5
5.2
5
U
5
U
5
U
5
U
5
U
5
U
5
U
5 U
Sulfate
-
NS
NS
NS
NS
NS
NS
10
u
12
11
10
7
U
7
U
7
U
7
U
7
U
7
U
65
62
Alkalinity
-
NS
NS
NS
NS
NS
NS
11
13
11
12
138
157
168
152
142
133
125
118
TOC (mg/L)
-
-
NS
NS
NS
NS
NS
NS
5
u
5
u
5
U
5
U
5
U
5
U
5
U
5
U
5
U
5
U
5
U
5 U
Metals (mg/L)
Iron
-
NS
NS
NS
NS
NS
NS
0.08
0.06
0.07
0.08
0.06
0.07
0.08
0.07
0.07
0.06
0.05
U
0.05 U
Parameters
ORP (mV)
-
46.5
83.6
21.2
78.2
27.2
85.2
92.4
118.1
64.2
98.2
143.2
167.6
128.3
124.5
142.3
116.5
98.2
108.8
Dissolved Oxygen (mg/L)
-
0.35
1.39
0.28
1.25
0.27
1.21
0.21
0.47
0.18
0.43
0.42
0.31
0.38
0.29
0.25
0.34
0.41
0.45
PH
-
5.85
5.82
6.23
6.35
6.3
6.31
5.65
5.61
6.23
6.37
6.11
6.09
6.32
6.59
6.23
6.58
5.89
5.74
Specific Conductance (us/cm)
-
154
126
128
108
167
144
132
146
128
183
1,834
2,634
1,723
2,486
1,793
2,460
426
469
Temperature (Celcius)
-
15.33
15.43
14.98
15.15
14.9
15.55
14.33
14.56
14.12
14.81
17.24
17.4
16.23
16.48
16.63
16.64
16.44
16.28
Notes:
Shaded indicates concentration exceeds ROD cleanup lev
U= not detected above reporting limit shown.
J = Estimated value below reporting limit.
CVOC= Chlorinated volatile organic compound
DHG= Dissolved hydrocarbon gas
DCE= Dichloroethene
TCE= Trichloroethylene
DCA= 1,1- Dichloroethane
T CA= 1,1,1 - T richloroethane
ORP = Oxidation reduction potential
Hg/L = micrograms per liter
mg/L = milligrams per liter
mV= millivolts
uS/cm = microSiemens per centimeter
NS = Not sampled.
-------
Table 6-15. Summary of EISB Performance Monitoring in the ASA Source area
Wah Chang Five Year Review Report
Well
ROD
PW-78A
PW-78A
PW-78A
PW-78A
PW-98A
Baseline
(7/7/09)
PW-98A
PW-98A
PW-98A
PW-98A
PW-98A
PW-99A
Baseline
(7/8/09)
PW-99A
PW-99A
PW-99A
PW-99A
PW-99A
Date
(5/1/10)
(11/16/10)
(5/10/11)
(11/9/11)
(12/18/09)
(5/1/10)
(12/16/10)
(5/17/11)
(11/15/11)
(12/18/09)
(5/1/10)
(12/16/10)
(5/17/11)
(11/15/11)
CVOCs (ng/L)
Perimeter Well
1,1,1-TCA
200
9.55
2.18
4.38
0.67
504
406
507
183
123
128
27.5
54.6
22.1
7.15
8.94
5.18
1,1 -DCA
1,280
91.1
87.2
73.4
25.8
170
253
458
503
268
384
28.5
60.6
58.3
23.9
41.5
14.8
1,2-DCA
5
0.5
U
0.5
U
0.5
U
0.5
U
4.74
3.71
3.42
2.48
1.08
1.54
0.18
J
0.31
J
0.5
U
0.5
U
0.5
U
0.5 U
Chloroethane
-
0.5
U
0.5
U
0.5
U
0.5
U
3
3.28
3.6
15.6
9.4
8.18
1.52
1.78
5.86
8.12
6.18
7.83
TCE
5
1.94
0.75
0.63
0.55
336
150
108
26.3
46.1
18.4
0.77
1.04
0.23
J
0.5
U
0.5
U
0.5 U
cis-1,2-DCE
70
1.33
0.76
1.21
0.39
J
32.9
77.5
25.9
18.2
12.1
14.5
0.19
J
0.36
J
0.5
U
0.5
U
0.5
U
0.5 U
trans-1,2-DCE
100
0.5
U
0.5
U
0.5
U
0.5
U
0.5 U
1.1
U
1.1 U
1.1 U
1.1 U
1.1 U
0.5
U
0.5
U
0.5
U
0.5
U
0.5
U
0.5 U
1,1 -DCE
7
68.7
57.6
42.3
46.2
1,080
1,070
495
427
125
245
87.8
245
232
186
155
143
Vinyl Chloride
2
0.5
U
0.5
U
0.5
U
0.5
U
8.86
131
95.2
78.2
25.3
34.4
0.32
J
1.53
4.23
5.33
2.48
2.84
Tetrachloroethylene
5
0.72
0.5
U
0.44
J
0.5
U
16.3
8.46
6.84
3.59
3.11
1.57
0.21
J
0.37
J
0.5
u
0.5
U
0.5
U
0.5 U
DHG (ng/L)
Methane
-
3.15
5.81
2.43
4.31
16.4
14.8
429
512
418
412
11.2
6.77
8.21
6.23
8.32
5.18
Ethane
-
1.32
1.15
1.43
1.14
1.2
0.84
J
0.81 J
10.3
0.78 J
8.1
0.76
J
0.49
J
0.49
J
0.88
0.89
0.12
Ethene
-
1.3
1.16
1.31
1.13
0.88
1.48
74.1
52.2
61.4
3.15
0.65
J
1.2
u
0.88
1.23
0.87
2.54
General Chemistry (mg/L)
Chloride
-
45
42
43
28
28.6
30
22.2
18.6
21.5
17
26.7
17
15
14
14
12
Nitrate-N
-
5
U
5
U
5
U
5
U
8.76
5
U
7.5
6.9
2.4
2.4
2.31
5
u
5
u
5
U
5
U
5 U
Sulfate
-
59
57
52
46
17.6
11
18.2
17.3
16.1
15.4
16.8
16
15
14
14
11
Alkalinity
-
110
98
101
77
125
317
111
108
108
84.1
67.5
81
78
65
61
55
TOC (mg/L)
-
-
5
U
5
U
5
U
5
U
2.4
5
U
2.3 J
2.2 J
1.8 J
1.8 J
3.11
5
u
6.23
6.18
5.86
5.81
Metals (mg/L)
Iron
-
0.05
U
0.05
U
0.05
U
0.05
U
0.697
0.17
0.42
0.38
0.38
0.18
9.77
0.57
0.61
0.58
0.58
0.45
Parameters
ORP (mV)
-
143.9
92.4
108.9
65.4
-265.1
126
75.7
98.2
87.7
117.2
22.7
138.4
23.1
85.4
29.1
67.4
Dissolved Oxygen (mg/L)
-
0.17
0.44
0.15
0.32
0.28
0.16
0.42
0.15
0.14
0.11
4.25
0.57
0.31
0.44
0.23
0.21
PH
-
6.42
6.48
6.46
6.42
6.69
6.47
4.86
6.84
4.87
6.74
6.16
6.63
6.82
6.48
6.8
6.55
Specific Conductance (us/cm)
-
491
483
549
577
497
763
808
758
785
703
378
270
512
248
444
262
Temperature (Celcius)
-
15.62
15.57
15.4
15.09
18.15
19.6
17.59
17.54
17.92
17.82
15.96
14.48
14.25
14.95
14.03
15.5
Notes:
Shaded indicates concentration exceeds ROD cleanup lev
U= not detected above reporting limit shown.
J = Estimated value below reporting limit.
CVOC= Chlorinated volatile organic compound
DHG= Dissolved hydrocarbon gas
DCE= Dichloroethene
TCE= Trichloroethylene
DCA= 1,1- Dichloroethane
T CA= 1,1,1 - T richloroethane
ORP = Oxidation reduction potential
Hg/L = micrograms per liter
mg/L = milligrams per liter
mV= millivolts
uS/cm = microSiemens per centimeter
NS = Not sampled.
-------
Table 6-16. Summary of COCs detected in Solids area wells from November 2003 to September 2011
Wah Chang Five Year Review Report
Station
Parameter
Units
ROD Cleanup
Level
Nov-03
Oct-04
Sep-05
Aug-06
Jun-07
Nov-08
Sep-09
Sep-10
Sep-11
PW-07
CHLORIDE
mg/L
-
127
48
47
34
24.3
27
25
24
PW-09
CHLORIDE
mg/L
-
591
160
160
89.5
867
670
590
575
PW-17B
CHLORIDE
mg/L
-
2190
1800
1700
2200
1550
820
808
785
PW-18B
CHLORIDE
mg/L
-
85.7
57
57
34.6
70.6
45
50
45
PWA-1
CHLORIDE
mg/L
-
2370
1800
1600
2370
1700
1.6
1.4
1.2
PWA-2
CHLORIDE
mg/L
-
5470
4500
4400
3870
2870
3
2
1.6
PWB-1
CHLORIDE
mg/L
-
111
86
80
57.3
41
53
48
42
PWB-2
CHLORIDE
mg/L
-
117
87
80
66.6
49.9
51
47
43
PWB-3
CHLORIDE
mg/L
-
6760
6300
7600
6440
4860
4.7
4.1
3.8
PWC-1
CHLORIDE
mg/L
-
4.72
10 U
23
7.3
9.22
10
9
7.6
PWC-2
CHLORIDE
mg/L
-
13.6
16
110
13.5
5.92
13
11
10
PWD-1
CHLORIDE
mg/L
-
1890
2000
1500
1760
1500
1780
1580
1430
PWD-2
CHLORIDE
mg/L
-
699
730
880
947
915
592
575
525
PWE-1
CHLORIDE
mg/L
-
324
110
130
106
186
95
94
92
PWE-2
CHLORIDE
mg/L
-
826
700
1100
1460
641
1520
1460
1380
PWF-1
CHLORIDE
mg/L
-
206
99
170
498
439
1.1
1.2
1.1
PWF-2
CHLORIDE
mg/L
-
341
110
190
1400
1170
1.4
1.1
1.1
PW-07
FLUORIDE
mg/L
2
9.21
1 U
1 U
0.12
0.19
1 U
1 U
1 U
PW-09
FLUORIDE
mg/L
2
1.998
3
3
3.6
1.57
2
1 U
1 U
PW-17B
FLUORIDE
mg/L
2
2 U
1 U
1 U
0.37
1.22
1 U
1 U
1 U
PW-18B
FLUORIDE
mg/L
2
2.49
2
2
1.9
1.6
2
2
1.8
PWA-1
FLUORIDE
mg/L
2
1 U
1 U
1 U
PWA-2
FLUORIDE
mg/L
2
2 U
1 U
1 U
PWB-1
FLUORIDE
mg/L
2
2.45
2
3
2.1
2.32
2
2
2
PWB-2
FLUORIDE
mg/L
2
2.51
2
3
2.1
2.16
2
1 U
1 U
PWB-3
FLUORIDE
mg/L
2
2 U
2
2
1.7
2.01
2
2
1.7
PWC-1
FLUORIDE
mg/L
2
0.33
1 U
1 U
PWC-2
FLUORIDE
mg/L
2
0.1 U
1 U
1 U
PWD-1
FLUORIDE
mg/L
2
0.1 U
1 U
1 U
PWD-2
FLUORIDE
mg/L
2
0.1 U
1 U
1 U
PWE-1
FLUORIDE
mg/L
2
3.73
5
4
4.1
4.32
3.9
2.7
2.1
PWE-2
FLUORIDE
mg/L
2
0.3
1 U
1 U
0.18
0.16
1 U
1 U
1 U
PWF-1
FLUORIDE
mg/L
2
0.708
1 U
1
PWF-2
FLUORIDE
mg/L
2
0.864
1 U
1
PW-07
MANGANESE
mg/L
-
2.44
1.8
1.5
1.3
1.64
1.35
0.6
0.55
0.53
PW-09
MANGANESE
mg/L
-
3.07
1.4
0.97
4
1.44
10.5
5.1
4.9
4.7
PW-17B
MANGANESE
mg/L
-
24.6
19
20
15
17.3
19.9
7.6
7.2
6.8
PW-18B
MANGANESE
mg/L
-
0.981
0.5
0.82
0.56
0.214
0.636
0.23
0.19
0.17
PWA-1
MANGANESE
mg/L
-
11.9
00
CO
8.7
9.7
11.3
10.5
7.9
8.1
7.7
PWA-2
MANGANESE
mg/L
-
20.4
16
17
13
15.9
14.5
13
12.1
12
PWB-1
MANGANESE
mg/L
-
0.984
1
0.91
1.1
0.976
0.974
0.8
0.7
0.6
PWB-2
MANGANESE
mg/L
-
1.05
0.96
0.84
0.8
0.969
0.872
0.84
0.77
0.73
PWB-3
MANGANESE
mg/L
-
19.4
14
14
9.1
14
14.2
13
12
10
PWC-1
MANGANESE
mg/L
-
0.623
0.79
1.4
1
1.2
1.25
0.98
0.87
0.79
PWC-2
MANGANESE
mg/L
-
0.85
0.88
0.98
0.35
0.955
1.09
0.97
0.89
0.86
PWD-1
MANGANESE
mg/L
-
10.5
9.7
8
7.5
9.25
8.74
8.3
8.1
7.5
PWD-2
MANGANESE
mg/L
-
0.948
0.99
1.1
1.1
1.3
1.45
1.2
1
0.98
PWE-1
MANGANESE
mg/L
-
2.01
1.1
1.1
1.1
1.02
1.21
1.1
0.99
0.85
PWE-2
MANGANESE
mg/L
-
6.47
5.6
8.6
13
13.9
7.84
5.1
4.9
4.6
PWF-1
MANGANESE
mg/L
-
1.01
0.68
0.74
0.13
1.72
2.65
2.3
1.8
1.8
PWF-2
MANGANESE
mg/L
-
0.899
0.43
0.5
0.12
3.5
3.42
2.7
2.4
2.3
PW-07
NITRATE
mg/L
10
17.917
5 U
5 U
3.9
1.76
5 U
5 U
5 U
PWF-1
NITRATE
mg/L
10
32.4
7
5 U
0.01 U
0.25
5 U
5 U
5 U
PWF-2
NITRATE
mg/L
10
32.1
8
5 U
0.01 U
0.01 U
5 U
5 U
5 U
PW-07
RADIUM 226
pCi/L
5
2.5
5 U
5.9
0.86
40 U
5 U
2.5 U
PW-07
RADIUM 228
pCi/L
5
1 U
5 U
10 U
3.6
40 U
5 U
2.5 U
*Bold values indicate samplign results were the method detection limit is above the ROD performance level concentations
Highlighted cell indicates analyte was detected above the ROD cleanup level
U = Not detected at specified reporting limit
-- = ROD performance level not established
-------
Table 6-17. Summary of VOCs detected in Farm Pond wells from June 2000 to September 2011
Wah Chang Five Year Review Report
Station
Parameter
ROD
Jun-00
Sep-00
Mar-01
Sep-01
Mar-02
Sep-02
Sep-03
Sep-04
Sep-05
Jun-07
Sep-08
Oct-09
Sep-10
Sep-11
PW-40S
TCA
200
1 U
1 U
1 U
1 U
1 U
0.5 U
1 U
0.5 U
0.5 U
0.5 U
0.1 u
0.5 U
0.5 U
0.5 U
PW-65S
TCA
200
1 u
1 u
1 U
1 u
1 U
0.5 U
0.5 U
0.1 u
0.5 U
0.5 U
0.5 U
SS
TCA
200
0.6 J
1 u
1 u
1 u
0.5 U
1 u
0.5 U
0.5 U
1.2
1.3
0.16 J
0.5 U
0.5 U
PW-40S
DCA
42.2
9
26.7
35
26.2
31.03
30.78
28.09
30.5
32
35
14.3
12.7
9.8
PW-65S
DCA
3
3
2.2
2.95
2.4
3.38
3.4
6.2
4.17
3.9
2.68
SS
DCA
2.3
1J
1.7
1 U
1.51
1.83
1.79
2.3
8.4
8.3
0.33 J
0.29 J
0.5 U
PW-40S
DCE
7
2.8
2.5
1.6
1.9
1.2
1.97
1.56
0.87
0.67
0.4 J
0.6
0.5 U
0.5 U
0.5 U
PW-65S
DCE
7
1 U
1 U
1 U
1 U
1 U
0.5 U
0.5 U
0.1 U
0.5 U
0.5 U
0.5 U
SS
DCE
7
1 U
1 U
1 U
1 U
0.5 U
1 U
0.5 U
0.5 U
1.5
1.5
0.5 U
0.5 U
0.5 U
PW-40S
CIS-DCE
70
41.6
7.1
26.5
37.6
22.6
42.22
45.08
31.9
21.8
10.5
23
0.74
0.61
0.52
PW-65S
CIS-DCE
70
1 U
1 U
1 U
1 U
1 U
0.5 U
0.5 U
0.2 J
0.11J
0.5 U
0.5 U
SS
CIS-DCE
70
2.9
1
1.7
1 U
1.22
1.27
0.88
1.1
3.9
3.7
0.5 U
0.5 U
0.5 U
PW-40S
PCE
5
2.5
2.5
1.9
1.8
1.1
0.54
1 U
0.5 U
0.77
1.2
0.1 U
0.57
0.55
0.43 J
PW-65S
PCE
5
1 U
1 U
1 U
1 U
1 U
0.5 U
0.5 U
0.1 U
0.5 U
0.5 U
0.5 U
SS
PCE
5
22.5
7.8
16
1.9
8.7
12.72
14.22
14.7
40.4
49
2.52
2.13
1.45
PW-40S
TCE
5
18
15.9
9.3
8.5
7.1
5.63
4.11
1.89
1.5
1.4
0.7
0.49 J
0.5 U
0.5 U
PW-65S
TCE
5
1 U
1 U
1 U
1 U
1 U
0.5 U
0.5 U
0.1 U
0.5 U
0.5 U
0.5 U
SS
TCE
5
6.2
2.1
3.9
1 U
2.91
3.66
3.35
3.8
11.3
13
0.26 J
0.25 J
0.5 U
PW-40S
VC
2
2.9
3.4
1.8
4.2
1.1
4.67
3.25
2.97
1.7
0.85
2.4
0.5 U
0.5 U
0.5 U
PW-65S
VC
2
1 U
1 U
1 U
1 U
1 U
0.5 U
0.5 U
0.1 J
0.5 U
0.5 U
0.5 U
SS
VC
2
1 U
1 U
1 U
1 U
0.5 U
1 U
0.5 U
0.5 U
0.5 U
0.1 U
0.5 U
0.5 U
0.5 U
Notes:
TCA = 1,1,1-trichloroethane
DCA = 1,1-dichloroethane
cis-DCE = cis-l,2-dichloroethene
PCE = tetrachloroethene
TCE = trichloroethene
VC = vinyl chloride
U = Parameter not detected above the method reporting limit
J = Estimated value below reporting limit
Shading indicates that ROD Cleanup level was exceeded
------- |