FOURTH FIVE-YEAR REVIEW REPORT FOR
PALERMO WELL FIELD GROUND WATER CONTAMINATION SUPERFUND SITE
THURSTON COUNTY, WASHINGTON
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SEPTEMBER 2018
Prepared by
U.S. Environmental Protection Agency
Region 10
Seattle, Washington
-for
Sheryl Bilbrey, Director
Office of Environmental Cleanup
Date
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Table of Contents
LIST 01 ABBREVIATIONS & ACRONYMS 4
I. INTRODUCTION 6
Site Background 6
FIVE-YEAR REVIEW SUMMARY FORM 7
II. RESPONSE ACTION SUMMARY 10
Basis for Taking Action 10
Response Actions 10
Status of Implementation 11
Systems Operations/Operation and Maintenance (O&M) 14
III. PROGRESS SINCE THE PREVIOUS REVIEW 15
IV. FIVE-YEAR REVIEW PROCESS 17
Community Notification, Community Involvement and Site Interviews 17
Data Review 18
Site Inspection 20
V. TECHNICAL ASSESSMENT 21
QUESTION A: Is the remedy functioning as intended by the decision documents? 21
QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels and RAOs used at the time of the
remedy selection still valid? 22
QUESTION C: Has any other information come to light that could call into question the protectiveness of the
remedy? 23
VI. ISSUES/RECOMMENDATIONS 23
OTHER FINDINGS 25
VII. PROTECTIVENESS STATEMENT 25
VIII. NEXT REVIEW 25
APPENDIX A - REFERENCE LIST A-1
APPENDIX B - SITE CHRONOLOGY B-l
APPENDIX C - PRESS NOTICE C-l
APPENDIX D - INTERVIEW FORMS D-l
APPENDIX E - SITE INSPECTION CHECKLIST E-l
APPENDIX F - SITE INSPECTION PHOTOS F-l
APPENDIX G - DETAILED DATA ANALYSIS G-l
APPENDIX H - ARARs REVIEW Il-I
Tables
Table 1: Site COCs, by Media 10
Table 2: RAOs and Remedy Components 10
Table 3: Remedial Goals Established in the ROD 11
Table 4: Summary of Planned and/or Implemented Institutional Controls (ICs) 14
Table 5: Protectiveness Determinations/Statements from the 2013 FYR Report 15
Table 6: Status of Recommendations from the 2013 FYR Report 15
Table B-l: Site Chronology B-l
Table G-l: Summary of TCE Detections in Production Wells Prior to Treatment G-l
Table G-2: Summary of Contaminant Concentration Trends in Groundwater (2004 through 2016) G-2
Table G-3: Summary of Subdrain System and Treatment Lagoon Data (2014 through 2017) G-4
Table G-4: Summary of PCE Concentrations Detected in Soil at the Southgate Drycleaners Area (2017) G-5
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Table G-5: Summary of Maximum Screening-Level Vapor Risk Based on 2012 Well Data G-6
Table G-6: Residential Indoor Data (2013 to 2017) G-8
Table H-l: Previous and Current ARARs for Groundwater COCs H-l
Figures
Figure 1: Site Vicinity 8
Figure 2: Site Detail 9
Figure G-l: Conceptual Site Model G-10
Figure G-2: Site Detail Map G-l 1
Figure G-3: Approximate PCE and TCE Plume Boundaries G-12
Figure G-4: Subdrain and Treatment Lagoon Sampling Locations (2016) G-13
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LIST OF ABBREVIATIONS & ACRONYMS
1,1 -DCE 1,1 -Dichloroethene
1,2-DCA 1,2-Dichloroethane
ARAR Applicable or Relevant and Appropriate Requirement
ASAOC Administrative Settlement Agreement and Order on Consent for Response Actions
bgs Below Ground Surface
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
CFR Code of Federal Regulations
cis- 1,2-DCE cis-1,2-Dichlorothene
CIC Community Involvement Coordinator
CMTL Current Materials Testing Lab
COC Chemical of Concern
CSM Conceptual Site Model
DGR Data Gap Investigation Report
Ecology Washington State Department of Ecology
EPA United States Environmental Protection Agency
FMTL Former Materials Testing Lab
FS Feasibility Study
FYR Five-Year Review
HI Hazard Index
HQ Hazard Quotient
IC Institutional Control
J Estimated Value
MCL Maximum Contaminant Level
|ig/L Micrograms per Liter
|ig/m3 Micrograms per cubic meter
mg/kg Milligrams per Kilogram
mg/L Milligrams per Liter
MTCA Model Toxics Control Act
MW Monitoring Well
NCP National Contingency Plan
NPL National Priorities List
NS Not Samples
O&M Operation and Maintenance
OU Operable Unit
PCE Tetrachloroethylene
POC Point of Compliance
PRP Potentially Responsible Party
RAO Remedial Action Objective
RG Remedial Goal
RI/FS Remedial Investigation/Feasibility Study
ROD Record of Decision
RPM Remedial Project Manager
RSL Regional Screening Level
SEIR Summary of Existing Information Report
SVE Soil Vapor Extraction
Southgate Southgate Dry Cleaners
TBC To-Be-Considered
TCE Trichloroethylene
trans- 1,2-DCE trans-1,2-Dichloroethene
U Below Detection
UU/UE Unlimited Use and Unrestricted Exposure
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VOC Volatile Organic Compound
WAC Washington Administrative Code
WDOH Washington State Department of Health
WSDOT Washington State Department of Transportation
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I. INTRODUCTION
The purpose of a five-year review (FYR) is to evaluate the implementation and performance of a remedy to
determine if the remedy is and will continue to be protective of human health and the environment. The methods,
findings and conclusions of reviews are documented in FYR reports such as this one. In addition, FYR reports
identify issues found during the review, if any, and document recommendations to address them.
The U.S. Environmental Protection Agency (EPA) is preparing this FYR pursuant to the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA) Section 121, consistent with the National
Contingency Plan (NCP) (40 Code of Federal Regulations (CFR) Section 300.430(f)(4)(ii)) and considering EPA
policy.
This is the fourth FYR for the Palermo Well Field Ground Water Contamination Superfund site (the Site). The
triggering action for this statutory review is the completion date of the previous FYR (Sept. 30, 2013). The FYR
has been prepared because hazardous substances, pollutants or contaminants remain at the Site above levels that
allow for unlimited use and unrestricted exposure (UU/UE). The Site consists of one operable unit (OU) that
addresses soil and groundwater contamination on the Site.
EPA remedial project manager (RPM) Claire Hong led the FYR. Participants included EPA hydrogeologists
Bernie Zavala and Tim Maley, EPA community involvement coordinator (CIC) Kay Morrison, EPA toxicologist
Elizabeth Allen, EPA ecological risk assessor Joe Goulet, Norm Payton with Washington State Department of
Transportation (WSDOT), Lara Linde and Brandon Brayfield with GeoEngineers Inc. (WSDOT contractor),
Chris Hartman, Dan Smith and Steve Craig with the city of Tumwater (City), and Johnny Zimmerman-Ward and
Claire Marcussen from EPA support contractor Skeo. The review began on 12/20/2017. The Site visit was
conducted on March 22, 2018. Documents used to prepare this FYR are summarized in Appendix A. Appendix B
includes a detailed chronology.
Site Background
The 150-acre Site is located in a light commercial and residential area in Tumwater, Washington (Figure 1). The
western part of the Site is an uplands area that straddles Interstate 5. The western uplands area contains the
Southgate Mall (which includes a dry cleaner facility), restaurants and other small businesses, government
facilities, the former WSDOT materials testing lab (FMTL) and current WSDOT materials testing lab (CMTL). A
60-foot bluff separates the western uplands area from the eastern lowland part of the Site in the Deschutes River
Valley. Immediately below the bluff is the eastern part of the Site that includes the Palermo residential
neighborhood of about 50 houses and the Palermo City Well field (Figure 2). The well field currently utilizes six
water supply wells (TW-3, -4, -6, -8, -16 and -17) drawing water from the shallow alluvium aquifer. The number
of wells used, and frequency of pumping to provide drinking water for the City, depends on demand. The north-
flowing Deschutes River forms the eastern boundary of the Site.
In 1993, the City detected trichloroethylene (TCE) in drinking water supply wells TW-2, -4 and -5, in which TCE
was detected above the drinking water criterion (5 |ig/L) in TW-2. The City temporarily removed the affected
wells from service. The TCE source was determined to be historic operations conducted at the FMTL and CMTL.
In addition, the City and the Washington State Department of Ecology (Ecology) identified Southgate Dry
Cleaners (Southgate) as a source of tetrachloroethylene (PCE). These operations at the FMTL, CMTL and
Southgate resulted in TCE and PCE releases to soil and groundwater.
Geology of the area consists of Deschutes River alluvium that has cut into older glacial deposits (Appendix G,
Figure G-l). Two regional aquifer systems are reported in the study area. The uppermost aquifer system is
contained within the Deschutes River Alluvium and the Vashon Drift. The Palermo Wellfield wells are completed
within the Deschutes River Alluvium at total depths ranging from 70 to 110 feet bgs and with depth to water
generally less than 10 feet bgs. Depth to groundwater in the upland Site wells is approximately 35 to 55 feet bgs.
Depth to groundwater in lower valley monitoring wells is approximately 1 to 8 feet bgs with artesian conditions
observed at some locations near the base of the bluff.
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Groundwater flow across the study area is easterly with a hydraulic gradient of approximately 0.03 feet per foot.
The lower aquifer is identified as the Penultimate Drift, located beneath the interglacial, fine grained deposits of
the Kitsap Formation. The Kitsap Formation is reportedly a confining layer to the Penultimate Drift. All the site
wells are completed in the upper-most aquifer system.
There are two surface water features near the Site: a treatment lagoon (located northeast of the Palermo
neighborhood) which accepts water collected by a subdrain system, promotes aeriation, and then ultimately
discharges the water 2,000 feet north, into the Deschutes River (which flows north, away from the Palermo
neighborhood) (Figure 2), and Barnes Lake, which is located behind the CMTL facility (Figure 1).
FIVE-YEAR REVIEW SUMMARY FORM
SITE IDENTIFICATION
Site Name: Palermo Well Field Ground Water Contamination
EPA ID: WA0000026534
Region: 10
State: WA
City/County: Tumwater/Thurston
NPL Status: Final
Multiple OUs?
No
Has the Site achieved construction completion?
Yes
Lead agency: EPA
Author name: Claire Hong, with additional support provided by Skeo
Author affiliation: EPA Region 10
Review period: 12/20/2018 - 9/7/2018
Date of site inspection: 3/22/2018
Type of review: Statutory
Review number: 4
Triggering action date: 9/30/2013
Due date (fiveyears after triggering action date): 9/30/2018
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Figure 1: Site Vicinity
Capitol
Lake
Olympia
Turn water
Palermo Well Field
Ground Water Contamination
Superfund Site
I CurrenPWSPSMB
!Materials»Testi n g La b(
SouthgateA
Dry Gleaners
Hurt res Jlfake
Palermo
. |Neigiiljferhood
Palermo
Wellfield
Southgate\
Mall , W -
r
Vp
Bluff
rnspfir Rmrl
'Fo^rWSDipT
Materials Testing Lab
250 500
Sources: Esri, DeLorme, DigitalGlobe, AND, Tele Atlas, First American,
UNEP-WCMC, GeoEye, Earthstar Geographies, CNES/Airbus DS, USDA,
USGS, AeroGRID, IGN, the GIS User Community, Figure 1-1 from the site's
2013 FYR and Figure 1-2 from the site's May 2017 GeoEngineers Summary
of Existing Information Report.
^ Skeo
Palermo Well Field Ground Water Contamination Superfund Site
City of Tumwater, Thurston County, Washington
Disclaimer: This map and any boundary lines within the map are approximate and subject to change. The map is not a survey. The map is for informational
purposes only regarding EPA's response actions at the Site and is not intended for any other purpose.
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Figure 2: Site Detail
¦Current WSDOT^
[Materials,Testing"Lab
reet SE
M
J
Palermo
Neighborhood
Palermo
Wellfield
ectionjof
''Directionof
Groundwater Flow
' Southgate
Dry Cleaners
—
Trosper Road
,
• FormeriWSDOT
Materials Testing Lab
SiJHliMi
1,000
HFeet
Sources: Esri, USGS, DigitalGlobe, GeoEye, Earthstar Geographies,
CNES/Airbus DS, USDA, Aerogrid, IGN, the GIS User Community,
Figure 9 from the site's 2018 GeoEngineers Draft Data Gaps
Investigation Report, Figure 1-1 from the site's 2013 FYR, Figure 1-2
from the site's May 2017 GeoEngineers Summary of Existing
Information Report and Figures 8 and F-1 from the site's 2016
GeoEngineers Annual Groundwater Monitoring Report.
Legend
J" j Approximate 2018 PCE/TCE plume
I I Treatment Lagoon
=m=mz Subdrain Tightline Pipe
Subdrain Perforated Pipe
<>Skeo O
V ~ NORTH
Palermo Well Field Ground Water Contamination Superfund Site
City of Tumwater, Thurston County, Washington
Disclaimer: This map and any boundary lines within the map are approximate and subject to change. The map is not a survey. The map is for informational purposes only regarding EPA's response actions at the
Site and is not intended for any other purpose.
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II. RESPONSE ACTION SUMMARY
Basis for Taking Action
Investigations by the City and Ecology between 1988 and 1993 identified a plume of TCE and PCE in
groundwater emanating from sources upgradient of the Palermo Well field. EPA listed the Site on the Superfund
program's National Priorities List (NPL) in April 1997. Between 1997 and 1999, EPA collected samples of soil,
groundwater, ponded water in residential crawl spaces, and surface water as part of the remedial investigation,
which indicated contamination. EPA then completed baseline human health and ecological risk assessments,
which indicate that risks associated with groundwater, surface water, soil and indoor air at the Site are above
acceptable risk levels. A summary of the contaminants of concern (COCs) identified in the Site's 1999 Record of
Decision (ROD) and environmental media is presented in Table 1. Although PCE and TCE can break down to cis-
1,2-dichloroethylene, Irons -1.2-d i ch 1 o roc th y 1 e n e and vinyl chloride, there is no evidence of this occurring at the
Site. Thus, the COCs identified for the Site are PCE and TCE.
Table 1: Site COCs, by Media
coc
Subsurface
Soil3
Groundwater1"
Indoor Airc
PCE
X
X
X
TCE
X
X
X
Notes:
a. Surface soil did not pose unacceptable risks for direct contact; however, contaminated subsurface
soils pose a risk by serving as a residual source of contaminants to groundwater.
b. Includes groundwater from wells and groundwater that has seeped to the surface in crawl spaces
which is referred to as "surface water" in the 1999 ROD.
c. Based on modeled indoor air from groundwater that surfaced into the crawl spaces.
Response Actions
EPA completed two removal actions by installing a soil vapor extraction (SVE) system at Southgate Dry Cleaners
in 1998 and a wellhead treatment system (two air strippers) at the Palermo Well field, which began operation in
February 1999. EPA selected the long-term cleanup plan in the October 1999 ROD that included continued
operation of the SVE and wellhead treatment systems, as well as construction of a subdrain and treatment lagoon
designed to intercept contaminated groundwater and lower the water table elevation in the Palermo residential
neighborhood. A detailed summary of the remedial action objectives (RAOs) and remedy components is in Table
2. The remedial goals for PCE and TCE are listed in Table 3. Due to the limited anaerobic biodegradation across
the Site, only low concentrations of PCE and TCE breakdown products were detected in all media sampled.
Therefore, the risk assessment did not identify PCE and TCE degradation products as COCs. However, the ROD
requires long-term monitoring of groundwater to include PCE and TCE and breakdown products, to monitor if
site environmental conditions change.
Table 2: RAOs and Remedy Components
Environmental
Medium
RAO'
Remedy Componentsb
Subsurface Soil
Prevent soil from contaminating
groundwater above health-based
levels.
• Treat contaminated soil at the Southgate area with the SVE
system installed during the removal action.
• Place deed restrictions on the Southgate property to reduce the
future transfer of contaminants from soil to groundwater.
Groundwater
Clean up the aquifer.
• Treat groundwater withdrawn by the Palermo Well field by
continuing operation and maintenance of the air stripper
system.
• Implement long-term groundwater monitoring program to
include PCE, TCE and degradation products.
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Environmental
Medium
RAO'
Remedy Componentsb
Prevent ingestion of, or exposure
to, groundwater containing
carcinogens in excess of applicable
or relevant and appropriate
requirements (ARARs) and total
excess cancer risk greater than 10~4
to 10"6.
• Implement informational institutional controls to notify
property owners, well drillers and local officials regarding the
location of the groundwater contaminant plume. The
notification will advise that the groundwater in this area is not
safe for domestic use without treatment.
Prevent inhalation of COC vapors
from surface water in residential
crawlspaces at concentrations that
result in a total excess cancer risk
greater than 1 x 10~6.
• Install a subdrain west of the residences along the west side of
Rainier Avenue to lower the water table 18 inches below the
bottom of the building crawl spaces.
• Evaluate standing water in the Palermo community and
determine if remedial action is necessary by either lowering
the water table beneath the houses or by venting the crawl
spaces.
• Implement a sampling program to assess indoor air quality.
Surface Water
Prevent discharge of groundwater
containing COCs to the Deschutes
River at concentrations in excess of
ARARs or resulting in an
ecological hazard index (HI)
greater than 1.
• Construct an aeration lagoon to treat the shallow contaminated
groundwater collected from the subdrain and discharge the
water to the stormwater drain that flows to the Deschutes
River.
• Develop and implement a monitoring system for the discharge
from the aerated lagoon to confirm that the water in the
lagoon meets water quality standards before discharge to the
Deschutes River.
Notes:
a. RAOs for soil, groundwater/air and surface water are listed in Table 7-1 of the ROD. Because shallow groundwater
surfaces below the crawl spaces of some residential homes, this water is referred to as surface water.
b. Remedy components consistent with Section 10.2 of the 1999 ROD.
Table 3: Remedial Goals Established in the ROD
COC
ROD Remedial Goals
Soil (mg/kg)a
Groundwater (|ig/L)
Surface Water
(Hg/L)d
Indoor Air
(Hg/m3)e
Crawlspaceb
Public
Supply
Wells0
PCE
0.0858
0.05
5
0.8
4.38
TCE
0.398
0.27
5
2.7
1.46
Notes:
a. Leachability-based values were calculated using the Model Toxics Control Act (MTCA) Method B for entire soil
column.
b. According to the ROD, the remedial goals listed are less than standard analytical detection limits. The actual remedial
goal will be the method detection limit for the analytical method used. These remedial goals were established to help
ensure that air cleanup goals for of 1.46 ng/m3 for TCE and 4.38 ng/m3 for PCE are met in the residences along
Rainier Avenue.
c. Federal Safe Drinking Water Act maximum contaminant levels (MCLs) and MTCA Method B groundwater remedial
goals at the time of the ROD applied to public supply wells post-treatment.
d. National Toxics Rule - Federal Clean Water Act - National Toxics Rule 40 CFR 131.36(b)(1) Human Health (10~6
cancer risk for consumption of water and organisms) applied to the treatment lagoon.
e. MTCA Method B risk-based indoor air concentrations.
mg/kg = milligrams per kilogram
Hg/L = micrograms per liter
Hg/m3 = micrograms per cubic meter
Status of Implementation
A summary of the implementation of each remedy component is provided below.
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Wellhead Treatment
The wellhead treatment system was constructed between February 1998 and February 1999. Testing and
optimization of the treatment system occurred between January and June 1999. Operation and maintenance
(O&M) of this system was transferred to the City in April 1999. The City recently completed a well field
expansion program to increase production at the well field. Since the air strippers were installed, the City had
been operating three of the original six production wells (TW-4, TW-6 and TW-8) to produce water for public
consumption. The City decommissioned production wells TW-2 and TW-5 in 2013 and 2014, respectively. A
third well, TW-3, remains inactive due to its lower pump rate. The City installed two new production wells (TW-
16 and TW-17) in 2012 and 2014, respectively, to replace the two decommissioned wells. In early 2016, the City
connected new supply wells TW-16 and TW-17 to the air stripping treatment system to bring them into use and
increase production of the well field. The City changes the number of production wells in use based on water
demand.
Subdrain and Treatment Lagoon System
EPA conducted the remedial design for the subdrain and treatment lagoon systems between November 1999 and
June 2000. During subdrain design, EPA evaluated the presence or absence of standing water in residential crawl
spaces in the Palermo neighborhood, and any standing water present was sampled. EPA concluded that only
homes on the west side of Rainier Avenue required drainage, but that conveyance piping under Rainier Avenue
and M Street should be oversized to allow future expansion of the drain system, if necessary. The subdrain design
was expected to have some influence under homes on the east side of Rainier Avenue, with a decreasing influence
farther east. EPA constructed the subdrain system and treatment lagoon between August 8, 2000, and January 9,
2001. In 2002, EPA began a long-term groundwater monitoring program and monitoring of subdrain and
treatment lagoon performance.
The ROD goal for subdrain performance was to lower the groundwater elevation to 18 inches below the crawl
space floors for homes west of Rainier Avenue. The floors of these crawl spaces were conservatively estimated to
be 18 inches below ground surface (bgs). Ecology assumed responsibility for performing O&M of these facilities
in February 2002. Ecology then transferred some O&M responsibilities to the City. The City assumed physical
maintenance responsibility for the property easements, equipment, and structures that make up the system.
In 2005, the U.S. government initiated a cost-recovery case against two potentially responsible parties (PRPs),
WSDOT and Southgate Development Corp. In 2007, a settlement was finalized with Southgate regarding PCE
contamination, and the court issued a judgment identifying WSDOT as liable for part of the past and future
response actions related to TCE contamination at the Site. Until 2009, Ecology was responsible for water quality
sampling and measurement of parameters, such as groundwater depths and water flow rate. These responsibilities
were transferred back to EPA in 2009 and then to WSDOT in 2012 as part of the July 2012 Administrative
Settlement Agreement and Order on Consent (ASAOC) between EPA and WSDOT. The ASAOC required that
WSDOT perform monitoring across the Site, to take over the maintenance of components of the remedy that are
not being maintained by the City of Tumwater, to reimburse EPA for future response costs, and to perform a
supplemental remedial investigation and feasibility study (RI/FS) at the Site. The supplemental RI/FS is focused
on all potential exposure pathways including any potential vapor intrusion, better characterization of the source
areas and a more complete delineation of the plumes.
SVE
EPA installed the SVE system near the Southgate PCE source in 1998 which operated from March 1998 to June
2000. EPA decommissioned the SVE system in 2000. Pre- and post-SVE soil samples demonstrated that the SVE
system had reduced PCE concentrations in soil but that concentrations still remain above the remediation goal of
0.0858 milligrams per kilogram (mg/kg).
Additional Data Gap Studies
In 2011 EPA completed an Optimization Evaluation to identify opportunities to improve remedy protectiveness,
effectiveness, and cost efficiency, and to facilitate progress toward site completion. The Optimization Evaluation
concluded that:
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• The TCE/PCE groundwater plumes were not defined.
• Plume capture by the subdrain and well field may not be complete.
• Vapor intrusion remains a concern.
• It is unclear whether the historically identified TCE/PCE sources are ongoing sources for groundwater
contamination at the CMTL, FMTL and Southgate.
In 2013, WSDOT began air and groundwater monitoring as outlined in the 2012 ASAOC and associated work
plans to address the 2011 Optimization Evaluation. WSDOT completed a draft Data Gap Investigation Report
(DGR) in 2018 to fulfill data gaps identified in the 2011 Optimization Evaluation. The data presented in the draft
DGR confirmed that the Southgate area may have ongoing sourcing of PCE to groundwater; however, several
data gaps remain, which WSDOT is addressing with additional investigations.
EPA will continue to evaluate the PCE soil and groundwater data collected in 2018 and ongoing monitoring while
it prepares a supplemental RI and FS for the Site. EPA is finishing their supplemental Southgate Area PCE
investigation, which will provide additional information for the supplemental RI and FS. Using information from
these investigations and monitoring efforts, EPA and WSDOT will identify and screen remedial technologies to
support the FS for both the TCE and PCE contamination, develop remedial alternatives, and select a remedy.
Institutional Control (IC) Review
Because the Site is within a developed area served by municipal water systems, there are no private wells that
could constitute additional points of exposure to groundwater. Further, the City restricts well installation in areas
where a municipal water supply is available. Thus, the ROD selected informational institutional controls to notify
property owners, government officials and well drillers about the extent of the area of groundwater containing
PCE and TCE to ensure that no supply wells will be inadvertently drilled into the plume of groundwater
contamination. In addition, the City's Wellhead Protection Ordinance Chapter 16-26 and the Aquifer Protection
Overlay Ordinance Chapter 18-39 are enforced. These ordinances protect groundwater and the municipal water
supply by prohibiting certain land uses within wellhead protection areas and city limits.
The 2013 FYR Report stated that a fact sheet discussing the contaminated groundwater was mailed to well drillers
and property owners in the area. Although not required by the ROD, WSDOT sent fact sheets to Palermo
neighborhood residents about air monitoring required by the ASAOC. In 2013 and 2017, EPA held public
meetings to inform the neighborhood of ongoing vapor intrusion and groundwater contamination studies and will
continue such meetings as warranted.
The ROD required institutional controls at the Southgate property intended to reduce transfer of residual soil
contamination to groundwater because a confirmation soil sample collected after decommissioning of the SVE
system detected PCE above the remedial goal. The institutional control has not yet been recorded for the
Southgate parcel to ensure the building and asphalt parking lot to function as a barrier. A summary of the
institutional controls planned or in place is provided in Table 4.
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Table 4: Summary of Planned and/or Implemented Institutional Controls (ICs)
Media That Do Not
ICs Called
Support UU/UE
for in the
Title of IC Instrument
Based on Current
Conditions
ICs
Needed
Decision
Documents
Impacted
Parcel(s)
IC
Objective
Implemented and Date
(or planned)
City of Tumwater
Prohibit certain land
Wellhead Protection
uses within wellhead
Ordinance Chapter 16-26
protection areas and
within city limits.1
and Aquifer Protection
Overlay Ordinance Chapter
18-39
There is no ordinance
Groundwater
Yes
Yes
Area above
the PCE and
TCE plumes
Prevent the use of
groundwater for
potable purposes
within the Palermo
neighborhood.
currently in place
restricting the installation
of private drinking water
wells within the Site;
however, the City restricts
installation in areas where
municipal water is
available. Informational
institutional controls have
been implemented, as
required by the ROD.
EPA intends to start
Southgate
Property
Reduce the transfer of
working with the property
owner to file an
Soil
Yes
Yes
contaminants from soil
institutional control on the
to groundwater.
property once the
supplemental RI/FS is
completed.
Systems Operations/Operation and Maintenance (O&M)
Wellhead Treatment Air Stripper Operations
O&M of the wellhead treatment air strippers includes weekly, monthly, semi-annual and annual maintenance,
including periodic change-outs of air filters, equipment lubrication and cleaning, and equipment repair or
replacement, as needed. The City conducts O&M of the wellhead treatment air strippers. WSDOT samples air
stripper effluent as part of long-term groundwater monitoring. The wellhead treatment system captures and treats
hundreds of millions of gallons of water each year. Based on information from the City, it appears that
production from the Palermo Well field has been decreasing for the past decade, with other groundwater sources
(primarily the Bush Middle School Well field about two miles southwest of the Site) making up more of the city
water supply. The City is currently evaluating ways to increase the flow rate from the Palermo Well field,
1 The following uses are prohibited in the designated six-month and one-year wellhead protection areas: 1) land spreading disposal
facilities; 2) agricultural operations, including stockyards and feedlots involving the raising or keeping of farm animals; 3) gas stations,
petroleum products refinement, reprocessing and storage (except underground storage of heating oil or agricultural fueling in quantities less
than 1,100 gallons for consumptive use on the parcel where stored, and aboveground storage for emergency utility purposes), and liquid
petroleum products pipelines; 4) automobile wrecking yards; 5) wood waste landfills; and 6) dry cleaners, excluding drop-off only
facilities. The following uses are prohibited in the designated six-month, and one-, five- and 10-year wellhead protection areas as depicted
on the wellhead protection map available for inspection in the city's community development department: 1) landfills (municipal sanitary
solid waste and hazardous waste); 2) hazardous waste transfer, storage and disposal facilities; 3) wood and wood products preserving; and
4) chemical manufacturing. Accessed on 4/24/2018:
http://www.codepublishing.eom/WA/Tumwater/html/Tumwaterl6/Tumwaterl626.html#16.26.040.
http://www.codepublishing.com/WA/Tumwater/html/Tumwaterl8/Tumwaterl839.html
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including rehabilitation of existing well TW-3 and the installation of two new wells, TW-16 and TW-17, which
replaced decommissioned wells TW-2 and TW-5.
Subdrain and Treatment Lagoon Operations
O&M of physical components of the subdrain system and treatment lagoon follows the 2002 O&M Manual for
the Subdrain System and Treatment Lagoon and the 2013 and 2014 O&M Amendment Manuals. The City
operates and maintains the subdrain/aeration lagoon system. Pursuant to the ASAOC, if the City fails to fulfill its
obligations for the system, WSDOT will ensure that the system operates consistent with the O&M Manual and its
amendments. O&M activities include collection of water samples from eight subdrain and treatment lagoon
locations and measurement of sediment accumulation and discharge rate at 11 subdrain locations. O&M for the
treatment lagoon includes semi-annual monitoring of lagoon inflows and treatment lagoon effluent and ensuring
compliance with remedial goals at the compliance point (Station 364) at the Deschutes River Outfall, which is
located 2,000 feet downstream from the treatment lagoon. Sediment accumulation monitoring occurs annually at
the treatment lagoon. The City performs periodic inspections of the lagoon aerators, repairs and/or replaces the
lagoon aerators as needed and maintains property easements. WSDOT reports that the lagoon system operates as
designed and treated water meets remedial goals before discharge to the Deschutes River.
SVE System Operations and Maintenance
The SVE system at Southgate was decommissioned in 2000; O&M is no longer needed for this remedy
component.
Long-term Air and Groundwater Monitoring
Semi-annual groundwater monitoring has continued on a relatively regular schedule since 2001. Water levels are
collected semi-annually at monitoring wells and piezometers. Annual long-term monitoring reports detail
sampling results. WSDOT is responsible for long-term groundwater monitoring.
III. PROGRESS SINCE THE PREVIOUS REVIEW
This section includes the protectiveness determinations and statements from the previous FYR as well as the
recommendations from the previous FYR and the status of those recommendations.
Table 5: Protectiveness Determinations/Statements from the 2013 FYR Report
ou#
Protectiveness
Determination
Protectiveness Statement
Sitewide
Protectiveness Deferred
At this time, a protectiveness determination of the remedy at the
Palermo Well Field Superfund Site cannot be made for the Site until
further information is obtained. The actions necessary to make the
protectiveness determination and deadlines for completion are above.
It is expected that these actions will take a total of 4 years to complete,
at which time a protectiveness determination will be made.
Table 6: Status of Recommendations from the 2013 FYR E
leport
Issue
Recommendations
Current
Status
Current Implementation Status
Description
Completion Date
(if applicable)
The potential risks from
vapor intrusion in the
Palermo neighborhood
remain a concern.
Complete evaluation of
groundwater-to-indoor-air
pathway and conduct
sufficient air monitoring to
determine whether TCE
and PCE vapor
concentrations in indoor air
remain below the remedial
goal of 1.46 |xg/m3 and
4.38 (ig/m3, respectively.
Ongoing
WSDOT completed additional soil vapor
and indoor air sampling in the winter,
spring and fall of 2017. The data will be
evaluated in a revised baseline risk
assessment in an upcoming RI/FS.
Results showed one home exceeded the
remedial goal for site-related TCE.
WSDOT offered to install a vapor
intrusion mitigation system, but the
home owner declined.
NA
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Issue
Recommendations
Current
Status
Current Implementation Status
Description
Completion Date
(if applicable)
The effectiveness of the
Palermo well field system
at capturing and controlling
contaminant migration
requires further evaluation.
Conduct a three-
dimensional capture zone
analysis to assess whether
the contaminant plumes are
being fully captured by the
operation of the Palermo
Well field.
Completed
WSDOT presented an updated capture
zone analysis in the Site's January 2018
draft DGR. Although EPA continues to
review the draft results, the draft
conclusions indicate that the TCE plume
would not be entirely captured at the
current average usage rates. An updated
capture zone analysis indicated that the
full targeted capture zone could be
obtained by pumping the active well
field wells continuously at a maximum,
though unlikely sustainable rate.
1/26/2018
TCE and PCE groundwater
plumes need better
definition; characterization
of the soil and groundwater
is not complete at the three
source areas, and plume
capture by the subdrain and
well field is likely not
complete.
Evaluate the lateral and
vertical distribution of
contaminants within the
aquifer.
Ongoing
WSDOT completed lateral and vertical
TCE and PCE extent evaluations in
2018. WSDOT concluded that the extent
of TCE was completed at the FMTL.
However, the northern horizontal extent
of the TCE plume remains a data gap at
the CMTL. WSDOT also determined
that the subdrain is not completely
capturing groundwater contamination
near cleanout location 6 (C6). EPA
completed additional PCE groundwater
sampling in October and November
2017 at Southgate but the investigation
and report has not yet been finalized.
NA
TCE in soil at the former
and current WSDOT
facilities and PCE in soil at
Southgate Dry Cleaners
may continue to be sources
of contamination to
groundwater because it is
unknown if significant
masses remain in vadose
zone soil or in shallow
groundwater. Institutional
controls, such as a deed
restriction for the Southgate
Dry Cleaners property, may
be needed if investigations
determine that residual
contamination is present
and poses a potential human
health risk.
Complete investigations at
known and potential source
areas and determine if
institutional controls, such
as a deed restriction for the
Southgate Dry Cleaners
property are needed.
Ongoing
WSDOT completed additional source
area evaluations at FMTL and CMTL in
2017 and 2018 and concluded residual
TCE is not at levels of concern at the
FMTL or CMTL. EPA conducted an
additional investigation regarding
residual PCE at Southgate and
concluded that there is residual PCE in
soil and groundwater above remedial
goals that are intended to protect
groundwater from contamination in
soils. These results support the need for
an institutional control to ensure the
building and asphalt parking lot function
as a barrier at the Southgate area. The
detections in soil, however, are below
residential screening levels.
NA
The long-term groundwater
monitoring system requires
further evaluation.
Based on Actions 2 to 4,
determine whether the
current groundwater
monitoring well network is
adequate to monitor plume
migration and gauge the
effectiveness of
remediation. Install
additional monitoring
wells, if necessary.
Ongoing
Twenty-one new monitoring wells were
installed in 2017 to support
characterization of source areas,
evaluation of the lateral and vertical
extents of PCE and TCE in groundwater,
and a more detailed understanding of
chemical migration pathways.
Additional monitoring well installations
are planned.
NA
New toxicity information
on TCE and PCE may
affect the protectiveness of
the remedy.
Determine whether cleanup
levels need to be modified
based on new toxicity
information on TCE and
PCE.
Ongoing
A supplemental RI/FS is being
completed, including evaluation of
cleanup levels based on current toxicity
information.
NA
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IV. FIVE-YEAR REVIEW PROCESS
Community Notification, Community Involvement and Site Interviews
EPA published a public notice in the Olympian newspaper on 3/22/2018 (Appendix C). It stated that the FYR was
underway and invited the public to submit any comments to EPA. The results of the review and the report will be
made available at the Site's information repository, Tumwater Timberland Library, located at 7023 New Market
Street in Tumwater, Washington.
During the FYR process, interviews were conducted to document any perceived problems or successes with the
remedy that has been implemented to date. The completed interview forms are presented in Appendix D and are
summarized below.
Lara Linde with GeoEngineers, WSDOT's O&M Contractor. Ms. Linde indicated that the project has made
significant progress in the last two years, gaining a better understanding of current groundwater dissolved phase
solvent contamination and water quality conditions across the Site. Semi-annual groundwater monitoring data
generally indicate that concentrations of Site contaminants are slowly decreasing over time. She also indicated
that components of the remedy are effective in removing Site contamination from groundwater, including the
stripper towers and portions of the subdrain system. The subdrain system is not meeting the performance criteria
to lower the water table and this might not be practicable as envisioned because of artesian conditions in the area.
Ms. Linde indicated that GeoEngineers recommends revising the performance criteria for the southern segment of
the subdrain based on flow measurements. GeoEngineers recommends that long-term groundwater monitoring be
reduced to a nine-month frequency; GeoEngineers also recommends the subdrain and treatment lagoon O&M
plan be amended to a nine-month sampling frequency so these activities can be efficiently coordinated.
Norman Payton with WSDOT: Mr. Payton indicated that the project has made substantial progress since the
previous FYR; additional sampling has helped define the groundwater contaminant plume and vapor intrusion
sampling has provided better understanding of this exposure pathway. He believes the City's stripper towers
continue to effectively remove TCE before the water is introduced to the City's drinking water system. The
aeration lagoon continues to treat water removed from the subdrain system to action levels. The subdrain is not
meeting performance criteria to lower the water table to depths below specific levels below neighborhood homes.
Mr. Payton has received inquiries from a local business that raised concerns for office worker safety while field
work was occurring near their office building in the Southgate area. Mr. Payton indicated that his office has
routine communication with the general public and the City by distributing information about upcoming meetings,
sampling events, air monitoring results and access agreements. Mr. Payton is not aware of any potential changes
in projected land use at the Site.
Dan Smith with the City of Tumwater: Mr. Smith believes the treatment system on the city's water supply is
effective and the system is easy to maintain. He feels well informed about the project by all parties, including
EPA, WSDOT and Ecology. He indicated that measures are in place that restrict placement of wells for potable
and irrigation uses within the drinking water system's boundaries.
Andrew Smith with the Department of Ecology, State of Washington: Mr. Smith believes cleanup activities are
being conducted according to the design to protect the public and the environment and he is comfortable with the
institutional controls in place. He indicated that the contaminant concentrations in the well field wells are below
Model Toxics Control Act (MTCA) standards and the contaminant plume is reducing in size. Mr. Smith is not
aware of any residential complaints or inquiries related to the Site cleanup. He indicated that Ecology is updating
its cleanup levels to reflect the new EPA toxicity values for TCE.
Resident 1 in the Palermo neighborhood: Resident 1 has lived in the neighborhood for almost five years and is
well informed about the Site's history and ongoing monitoring. The local community does not talk about the Site.
The neighborhood's Facebook page includes limited information about the Site, except when EPA had an
informational event at a local park. Resident 1 believes that the community receives good communication from
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WSDOT and GeoEngineers. Resident 1 recommends sharing additional EPA information through the
neighborhood Facebook page.
Resident 2 in the Palermo neighborhood: Resident 2 is aware of Site activities and believes the public outreach
and education has been great. People do not seem frustrated and Resident 2 has not heard any concern about home
values declining. Resident 2 would like the community to receive electronic versions of handouts by email after
receiving the hard copies. Overall, EPA has kept the community well informed through in-person meetings and
calls. Resident 2 also stated that GeoEngineers has been great about reaching out to the neighborhood.
Representative from local business: The business person indicated they were not informed of Site activities by
EPA until they received handouts and drawings from EPA in 2016 and September 2017 to inform the business of
upcoming groundwater monitoring. The business person indicated that GeoEngineers was very helpful in
explaining the sampling activities; the business staff had a lot of questions because information focused on what
activities were occurring but not why they were occurring. The business person was frustrated that EPA could not
explain why the sampling was happening and indicated that EPA could not provide anything in writing about the
sampling until it was finalized. The business person emphasized the importance of providing business owners
with easy-to-understand explanations of what is occurring and the purpose of the samples so that staff are not
afraid. The business person would like EPA to update its website to reflect the current site status and email them
and other impacted business owners regularly, to help address the concerns of the business staff.
Data Review
This section details contaminant trends for the last five years to evaluate remedy performance. A Site plan
showing monitoring well locations is provided in Figure G-2.
Wellhead Treatment System
For this FYR period, five of the six city production wells were sampled on a semi-annual basis (TW-4, TW-5,
TW-8, TW-16 and TW-17) between 2013 and 2017. TW-5 was decommissioned in January 2014 due to scale
build-up; data are available through 2013 for this well. The number of production wells used and frequency of
pumping for production varies depending on demand. PCE concentrations in production well samples have been
below laboratory detection limits (1 microgram per liter, or |ig/L) throughout the review period. TCE has been
detected in TW-4 and TW-16 prior to treatment and concentrations in TW-16 exceeded the ROD remedial goal (5
Hg/L) since it was installed in 2014 (see Table G-l). These measurements are concentrations in groundwater prior
to treatment. Air stripping effectively removes TCE and PCE from groundwater and air stripper effluent samples
are consistently below laboratory detection limits.
Well Field Capture Zone
WSDOT presented an updated capture zone analysis in two draft reports in 2018. The draft DGR and the Draft
2017 Annual Groundwater Monitoring Report include an initial capture zone analysis to assess potential pumping
scenarios that could capture the plumes during Palermo Well field pumping and treatment operations. Although
EPA continues to review these reports, they concluded that the TCE plume above the 5 |ig/L remedial goal would
not be entirely captured at the current average usage rates. An updated capture zone analysis indicated that the full
targeted capture zone could be obtained by pumping the active wellfield wells continuously at a maximum,
though unlikely sustainable rate. Additional plume capture assessments will be performed as part of the
supplemental FS.
Plume Delineation and Long-Term Monitoring Adequacy
Since long-term monitoring began in 2004, PCE and TCE concentrations in groundwater have gradually
decreased in most wells or remained steady where these COCs were detected. WSDOT conducted statistical trend
analyses where PCE or TCE has been detected. The analysis shows a statistically significant decreasing trend in
PCE and TCE concentrations in most wells, piezometers and production well TW-4 (Table G-2).
The current general plume map for TCE and PCE (Figure G-3) shows that separate TCE plumes are emanating
from the FMTL and CMTL, and a PCE plume is emanating from the Southgate mall area. These plumes appear to
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merge together in the upland area west of Interstate 5. WSDOT is proposing additional sampling to further
delineate the TCE plume near MW-111 downgradient of the CMTL facility and north of MW-DG-08. In addition,
WSDOT is proposing additional monitoring wells east of MW-DG-10, near MW-DG-16 and near MW-110 to
delineate the vertical extent of TCE in the upper aquifer. EPA is performing a supplemental PCE investigation at
the Southgate Dry Cleaners portion of the Site to further delineate the PCE plume and better understand its
interaction with the TCE plume in this area.
Subdrain System and Treatment Lagoon
The subdrain system intent is to intercept shallow groundwater previously ponding in backyards and crawl spaces
behind the seven southernmost houses west of SE Rainier Avenue (Figure G-4) and conveys the collected water
to the treatment lagoon at the Tumwater Municipal Golf Course. Sampling data indicates that, as contaminated
groundwater travels through the subdrain and is treated by aeration in the treatment lagoon, PCE and TCE
concentrations are reduced to levels below the ROD-established water quality limit at the Deschutes River outfall
(Table G-3). Although the treatment lagoon effectively meets outfall criteria, the subdrain system is not entirely
capturing shallow contaminated groundwater at the southern end, and sometimes at the north end, of Rainier
Street due to artesian conditions. The supplemental RI/FS will identify additional remedies to address this
concern.
Soil Vapor Extraction System at Southgate Dry Cleaners
The SVE system was decommissioned in 2000, when the average soil concentrations met the ROD remedial goal
for PCE in soil. Based on recommendations of the 2011 Optimization Evaluation, EPA conducted a supplemental
investigation for PCE in October and November 2017, of which subsurface soil sampling data in the Southgate
area contained PCE at levels above the ROD remedial goal (maximum PCE of 2.2 mg/kg) (Table G-4). This
indicates that soils could be a continual source of contamination to groundwater.
Soil Vapor and Indoor Air
WSDOT completed a screening-level evaluation of vapor intrusion risks in 2017 as summarized in the Summary
of Existing Information Report (SEIR) for the FMTL, CMTL and Southgate commercial areas using indoor air
concentrations modeled from groundwater data collected in 2012. WSDOT also evaluated vapor risks in the
Palermo neighborhood using indoor air and crawl space data collected from 2013 through 2017. A summary of
the vapor intrusion analysis conducted at the commercial areas and the Palermo neighborhood are summarized
below.
Commercial Areas
The conservative vapor intrusion screen demonstrated that commercial/industrial cancer risks for the FMTL and
CMTL were less than 1 x 10~6 and less than the noncancer HI of 1 (Table G-5). Using maximum concentrations
found at any depth in the Southgate area, the conservative vapor intrusion screen would result in an estimated risk
of 4 x 10 6 and estimated HI of 1. The Southgate screening numbers were based on the TCE concentration in
deeper aquifer monitoring well MW-ES-02. However, where contaminated groundwater is a potential vapor
source, EPA vapor intrusion guidance recommends use of groundwater samples obtained in the uppermost portion
of the aquifer that underlies the study area of interest2. If the assessment utilized the groundwater data from
shallow wells in this area, groundwater concentrations are below the commercial vapor intrusion screening levels.
To confirm these results, WSDOT plans additional vapor intrusion evaluation at the Southgate area.
WSDOT conducted a future residential risk evaluation at the FMTL, CMTL and Southgate commercial areas in
the SEIR. If these commercial areas were used as residential areas, residential risks at these areas would exceed
the risk level of 1 x 10~6 or the noncancer HI of 1 (Table G-5). WSDOT plans to conduct additional vapor
intrusion evaluation because a child daycare facility is located near the CMTL. September 2017 PCE and TCE
concentrations in the groundwater monitoring wells used in the vapor intrusion evaluation are slightly lower than
2012 concentrations used in the SEIR. Therefore, potential risks and hazards in this area from vapor intrusion
would likely be slightly lower than observed in 2012.
2
EPA's 2015 Technical Guide for Assessing and Mitigating the Vapor Intrusion Pathway from Subsurface Vapor Sources to Indoor Air.
OSWER Publication 9200.2-154.
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Palermo Neighborhood
Eight rounds of air monitoring were completed in the Palermo neighborhood between the spring of 2013 and the
fall of 2017. During the winter of 2017, TCE was detected for the first time in indoor air (4.4 micrograms per
cubic meter, or |ig/m3) and crawl space air (3.7 |ig/m3). which are at concentrations above the ROD remedial goal
of 1.46 |ig/m3. and the short-term exposure screening level of 2.0 |ig/m3. This occurred in only one home. During
the spring of 2017, indoor air TCE concentration in this home was 1.8 |ig/m3 which was above the remedial goal
but lower than the short-term exposure screening level. The crawl space air sample was 0.85 |ig/m3 which was
below the remedial goal and short-term screening levels. WSDOT offered to install an EPA-approved vapor
intrusion mitigation system after spring 2017 sampling, but the homeowner declined. This home was resampled in
the fall of 2017 where TCE was detected above the ROD remedial goal and the short-term exposure screening
level in indoor air (4.2 |ig/m3) and crawl space (4.8 |ig/m3) samples. After the fall 2017 results, EPA and WSDOT
tried to contact the homeowners again by various methods, including phone calls and a certified mail letter with a
summary of the fall 2017 results. WSDOT again offered to install a vapor intrusion mitigation system, but the
homeowners have not responded to these inquiries.
Site Inspection
The FYR site inspection took place on 3/22/2018. In attendance were:
• Claire Hong, EPA RPM
• Kay Morrison, EPA CIC
• Bernie Zavala, EPA Hydrogeologist
• Tim Maley, EPA Hydrogeologist
• Elizabeth Allen, EPA Toxicologist
• Joe Goulet, EPA ecological risk assessor
• Norm Payton, Washington State Department of Transportation (PRP)
• Lara Linde, GeoEngineers (PRP contractor)
• Brandon Brayfield, GeoEngineers (PRP contractor)
• Claire Marcussen, Skeo (EPA FYR contractor)
• Johnny Zimmerman-Ward, Skeo (EPA FYR contractor)
The purpose of the inspection was to assess the protectiveness of the remedy. The site inspection checklist and
photographs are provided in Appendices E and F, respectively.
Participants met near the Site and discussed remedial actions and ongoing investigations. Participants proceeded
to tour the former location of the WSDOT FMTL, where a Mobil gas station is currently located. Participants then
toured the Palermo Well field and groundwater treatment system near the Palermo neighborhood and observed six
production wells (TW-3, -4, -6, -8, -16 and -17) and the decommissioned well (TW-5). Participants observed the
interior of the pump house for TW-16, control panels and the air stripping treatment system, which includes two
air stripping towers. The well field and treatment facilities appeared to be in very good condition and operational
except for TW-3, which was being upgraded. Participants then visited the treatment lagoon west of the golf course
where the aerators were operating. The treatment lagoon is surrounded by a locked fence. Participants then
walked down Rainier Avenue to observe the drainage ditch behind homes where the subdrain system is located.
The ditch appeared to be flowing and unobstructed. Participants then visited the Southgate Mall area and the
CMTL area, which included a paved area where the former TCE tank was located. Barnes Lake was observed
behind the CMTL facility. Lastly, participants observed the groundwater monitoring well network around the
CMTL and adjacent daycare facility. All wells observed were flush mounted and secured.
Skeo staff visited the designated Site repository, Tumwater Timberland Library, located at 7023 New Market
Street in Tumwater, Washington. The repository file contained the administrative record through 2013 on
compact disc.
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V. TECHNICAL ASSESSMENT
QUESTION A: Is the remedy functioning as intended by the decision documents?
Question A Summary:
No, the remedy is functioning only partially as intended by the decision documents.
Wellhead Treatment System
The groundwater treatment component of the remedy (air stripping) is effective at reducing VOC contaminants
below MCLs in groundwater prior to distribution.
Well Field Capture Zone
The preliminary capture zone analysis presented in the SEIR was conducted using three pumping scenarios for the
Wellfield based on current average pumping rates, a maximum rate using currently actively pumped wells, and a
maximum pumping rate for a proposed future usage. The results of the analysis indicated that the plume would
not be entirely captured at the current usage rates. The analysis did indicate that, depending on the actual
transmissivity of the aquifer, the full targeted capture zone could be obtained by pumping TW-4, TW-16 and
TW-17 continuously at a maximum rate. The well field operator is not contractually obligated to operate the well
field continuously to ensure complete plume capture. The well field capture zone will be re-evaluated using data
collected as part of the supplemental RI/FS being conducted by WSDOT.
Plume Delineation and Long-Term Monitoring Adequacy
WSDOT and EPA have been working on filling contaminant plume delineation data gaps identified in the
previous FYR Report and the 2011 Optimization Evaluation. WSDOT completed the draft DGR, which included
the presentation of data to improve the delineation and characterization of the TCE plume. The recent data
collected indicate that additional localized data gaps for adequately assessing plume delineation remain. EPA is
completing a supplemental PCE investigation at the Southgate area and surrounding area. Data from the draft
DGR, the additional investigation to fill remaining data gaps, EPA's PCE investigation results, and ongoing
monitoring will be incorporated into the supplemental RI/FS. The supplemental RI/FS will include all sampling
data collected to date, updated plume maps and cross-sections, an updated long-term groundwater monitoring
program, and recommended additional response actions.
Vapor Intrusion Evaluation
The conservative vapor intrusion screening using existing groundwater data to model indoor air concentrations in
the Southgate areas resulted in an estimated cancer risk of 4 x 10"6 and an HI of 1 due to the TCE concentration
detected in deep well MW-ES-02. It should be noted that where contaminated groundwater is a potential vapor
source, EPA's 2015 vapor intrusion guidance recommends use of groundwater samples obtained in the uppermost
portion of the aquifer that underlies the study area of interest. If the groundwater data from shallow wells in this
area are used, groundwater concentrations are below commercial vapor intrusion screening levels. To confirm
results, WSDOT plans to conduct additional soil vapor sampling and evaluation at the Southgate area. In addition,
WSDOT plans additional soil vapor evaluation near a daycare facility cross-gradient of the CMTL to confirm that
TCE groundwater concentrations are protective of children and adults at the facility.
WSDOT also evaluated vapor intrusion in the Palermo neighborhood where the results of two indoor air samples
collected in spring and fall of 2017 at one of the homes exceeded the TCE remedial goal. WSDOT offered to
install an EPA-approved vapor intrusion mitigation system after the spring 2017 sampling, but the homeowner
declined. After resampling this home in the fall of 2017 EPA and WSDOT tried again to contact the homeowner
by various methods with a summary of the fall 2017 results and WSDOT again offered to install a vapor intrusion
mitigation system. The homeowners have not responded to these inquiries.
Subdrain System and Treatment Lagoon
Based on the data presented in the 2016 Annual Report, the SEIR and the draft DGR, the subdrain system
achieves ROD performance criteria in the central portion of Rainier Avenue but not at the south end area, and
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sometimes not at the north end area, due to artesian conditions. Groundwater is shallower in this area than the
required three feet under some homes, which can increase the risk of vapor intrusion. The treatment lagoon treats
TCE and PCE concentrations to below the performance criteria. TCE and PCE are occasionally detected in
receiving water outfall but at concentrations below the ROD-established water quality limit.
Soil Vapor Extraction System at Southgate Dry Cleaners
The SVE system operated from 1998 to 2000 and decommissioned in 2000. Pre- and post-SVE soil samples
demonstrated that the SVE system had reduced PCE concentrations in soil but that concentrations still remain
above the remediation goal of 0.0858 milligrams per kilogram (mg/kg). EPA conducted additional subsurface
investigations in fall 2017 and identified additional locations in soil under the Southgate area that exceed the
remedial goal for PCE. As a result, an institutional control was required to ensure the building and asphalt parking
lot function as a barrier. An institutional control has not yet been filed.
Institutional Control Assessment
Because the Site is located in a developed area served by municipal water systems, there are no private wells that
could constitute additional routes of exposure to groundwater. Further, a City ordinance restricts water well
installation in areas where the municipal water supply is available. The institutional control required by the ROD
for the Southgate property has not been filed. Public notification of contaminated groundwater was completed in
accordance with the ROD. The 2013 FYR stated that a fact sheet about the contaminated groundwater was mailed
to well drillers and property owners in the area. Although not required by the ROD, WSDOT sent fact sheets to
Palermo neighborhood residents about air monitoring required by the ASAOC. In 2013 and 2017, EPA held
public meetings to inform the neighborhood of ongoing vapor intrusion and groundwater contamination studies.
EPA will continue such meetings as warranted.
QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels and RAOs used at the time of the
remedy selection still valid?
Question B Summary:
No. Not all exposure assumptions, toxicity data, cleanup levels and RAOs at the time of the remedy selection are
still valid.
According to the SEIR, incidental ingestion and dermal contact with groundwater discharging at seeps along the
south and west sides of the Palermo neighborhood were identified as incomplete or minor exposure pathways
based on the monitoring results of these seeps in 2012 and 2014. However, the draft DGR identified exposure to
seep water as complete or potentially complete for current and future residents and recreational users. This change
in designation is due to feedback received by WSDOT from Palermo neighborhood residents who expressed
concerns on potential exposure to the seeps/surface water when WSDOT conducted subdrain monitoring and air
monitoring activities over the past four years. WSDOT is addressing this data gap to determine if additional
response action is warranted.
This FYR reviewed remedial goals to determine if they remain valid. Federal ARARs have not changed since the
previous FYR (Appendix H). In the previous FYR, EPA Region 10 issued a recommendation to use a health
protective TCE air concentration of 2.0 (.ig/ni3 for residential short-term exposures and 8.4 (.ig/ni3 for commercial/
industrial short-term exposures (21-day exposure) based on noncancer health effects and recommends expeditious
exposure reduction if this level is exceeded.3 In response to the EPA Region 10 recommendation, WSDOT
prepared a draft Time-Critical Action Decision Matrix in 2013 to outline requirements for time-critical action if
the short-term TCE level is exceeded. In addition, in the previous FYR, updated MTCA cleanup level
concentrations for surface water were considered not applicable to the Site unless the current ROD-selected
remedy is determined to be not protective for the surface water exposure pathway. It is recommended that risk
from exposure to surface water pathway be evaluated to determine if the remedy (including ARAR revisions)
3 Memorandum from Joyce C. Kelly, Director, Office of Environmental Assessment to Rick Albright, Director of Office of
Environmental Cleanup and Kate Kelly, Director of Office of Air, Waste and Toxics, December 13, 2012.
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needs to be altered by a decision document. EPA should also evaluate toxicity value changes and ARAR changes
during the RI/FS and determine whether any remedial goals should be revised in a decision document once any
additional remedial responses are selected. EPA should incorporate the short-term health protective level for TCE
in a decision document and include the Time-Critical Action Decision Matrix.
The ROD established an RAO for shallow groundwater under residential crawl spaces but referred to this crawl
space water as surface water. WSDOT recommended replacing the current RAO addressing inhalation of COC
vapors from surface water in residential crawl spaces with an RAO that addresses inhalation of COC vapors from
neighborhood groundwater to promote clarity in the RAOs in a future decision document.
The RAO for preventing inhalation of COC vapors from surface water in one residential crawl space at
concentrations that result in total excess cancer risk greater than 1 x 10"6 is not being met. The RAO for
preventing soil from contaminating groundwater has not been met at the Southgate area.
QUESTION C : Has any other information come to light that could call into question the protectiveness of the
remedy?
No additional information has come to light since the previous FYR that calls into question the protectiveness of
the remedy.
VI. ISSUES/RECOMMENDATIONS
Issues/Recommendations
()l (s) without Issues/Recommendations Identified in the l-'Yk:
None
Issues and Recommendations Identified in the I VR:
OU(s): Sitewide
Issue Category: Remedy Performance
Issue: Vapor intrusion risks in one home of the Palermo neighborhood are a
concern based on short-term exposure.
Recommendation: Although EPA and WSDOT have made multiple attempts to
contact the resident to share the indoor air results and offer mitigation of this
exposure, the resident has not responded. Continue to pursue communications
with the resident to mitigate this exposure pathway.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party
Responsible
Oversight Party
Milestone Date
Yes
Yes
PRP
EPA/State
12/1/2018
23
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OU(s): Sitewide
Issue Category: Remedy Performance
Issue: Vapor intrusion risks have not been evaluated using soil vapor or indoor air
at the Southgate area or the day care near the CMTL.
Recommendation: Evaluate the vapor intrusion pathway at the Southgate area
and daycare facility near the CMTL using multiple lines of evidence.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party
Responsible
Oversight Party
Milestone Date
Yes
Yes
EPA/State
EPA/State
12/1/2018
OU(s): Sitewide
Issue Category: Remedy Performance
Issue: The previous FYR identified that new toxicity information on TCE and
PCE exists that may affect the protectiveness of the remedy.
Recommendation: Complete additional risk characterization of human and
ecological health as part of the supplemental RI/FS to determine if the remedy
(including ARAR and cleanup goal revisions) need to be revised and include in a
decision document.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party
Responsible
Oversight Party
Milestone Date
Yes
Yes
EPA/State
EPA/State
12/1/2018
OU(s): Sitewide
Issue Category: Remedy Performance
Issue: PCE and TCE have not been fully delineated in groundwater The Palermo
Well Field is not achieving capture with its current usage rates. In addition, the
subdrain is not capturing contaminated groundwater at the southern end and
sometimes at the north end of Rainier Street due to artesian conditions.
Recommendation: Complete delineation of PCE and TCE in groundwater,
update the capture zone analysis and evaluate whether subdrain performance can
be improved.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party
Responsible
Oversight Party
Milestone Date
No
Yes
EPA/State
EPA/State
8/1/2020
OU(s): Sitewide
Issue Category: Monitoring
Issue: Direct exposure of resident or recreational receptors to surface water
ditches along the south and west sides of the neighborhood has not quantitatively
been evaluated based on a current understanding of site contamination.
Recommendation: Collect surface water samples from the ditches and evaluate
human health risks to residents and recreators.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party
Responsible
Oversight Party
Milestone Date
No
Yes
PRP
EPA/State
8/1/2019
24
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OU(s): Sitewide
Issue Category: Institutional Controls
Issue: Due to PCE in subsurface soil above remedial goals underlying the
Southgate area, restrictions are needed to prevent disturbing paved areas
potentially mobilizing soil contamination to groundwater.
Recommendation: File an institutional control to prevent disturbing paved areas
in order to prevent mobilization of soil contamination to groundwater.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party
Responsible
Oversight Party
Milestone Date
No
Yes
EPA
EPA
8/1/2019
OTHER FINDINGS
Several additional recommendations were identified during the FYR. These recommendations do not affect
current and/or future protectiveness.
• Revise the RAO for surface water under homes to refer to shallow groundwater to promote clarity and
differentiate from surface water in ditches.
• Update the Site's information repository to include post-2013 documents.
VII. PROTECTIVENESS STATEMENT
Sitewide Protectiveness Statement
Operable Unit: Protectiveness Determination:
Sitewide Not Protective
Protectiveness Statement: The remedy is not protective because VOC vapors have been detected above
the remedial goal for TCE and the short-term exposure screening level, that appear to be migrating
from groundwater and into one residential crawl space indoor air. Although EPA has already made
repeated attempts to contact the resident to address this concern, the resident has not responded.
Additional remedial response is warranted to assess and mitigate the exposure pathway or to reduce
contaminant levels entering indoor air. The vapor intrusion investigations need to be completed at the
Southgate area and day care facility near the CMTL using multiple lines of evidence. In addition,
additional risk characterization of human and ecological health should be completed as part of the
supplemental RI/FS to determine if the remedy (including ARAR and cleanup goal revisions) need to
be revised and included in a decision document. To ensure long-term protectiveness of the remedy the
following the actions need to be taken:
• Complete delineation of PCE and TCE in groundwater, update the capture zone analysis and
evaluate whether subdrain performance can be improved.
• Collect surface water samples from the ditches and evaluate human health risks to residents
and recreators.
• File an institutional control to prevent disturbing paved areas in order to prevent mobilization
of soil contamination to groundwater.
VIII. NEXT REVIEW
The next FYR Report for the Palermo Well Field Ground Water Contamination Superfund site is required five
years from the completion date of this review.
25
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APPENDIX A - REFERENCE LIST
Air Monitoring Report - Fall 2017. Palermo Well Field Superfund Site Tumwater, Washington
Prepared by GeoEngineers, Inc. for Washington State Department of Transportation. Draft. April 2018.
Air Monitoring Report - Winter and Spring 2017. Palermo Well Field Superfund Site Tumwater, Washington
Prepared by GeoEngineers, Inc. for Washington State Department of Transportation. October 2017.
Draft 2017 Annual Groundwater Monitoring Report. Palermo Well Field Superfund Site Tumwater, Washington.
Prepared by GeoEngineers, Inc. for Washington State Department of Transportation. January 2018.
2014 Annual Groundwater Monitoring Report. Palermo Well Field Superfund Site Tumwater, Washington.
Prepare by GeoEngineers, Inc. for Washington State Department of Transportation. February 2017.
2015 Annual Groundwater Monitoring Report. Palermo Well Field Superfund Site Tumwater, Washington.
Prepare by GeoEngineers, Inc. for Washington State Department of Transportation. April 2017.
2016 Annual Groundwater Monitoring Report. Palermo Well Field Superfund Site Tumwater, Washington.
Prepare by GeoEngineers, Inc. for Washington State Department of Transportation. April 2017.
2016 Semiannual Groundwater Monitoring Report. Palermo Well Field Superfund Site Tumwater, Washington.
Prepared by GeoEngineers, Inc. for Washington State Department of Transportation. April 2017.
First Five-Year Review Report: Palermo Well Field Superfund Site, Tumwater, Washington. Prepared by URS
for EPA Region 10 under Remedial Action Contract No. 68-W98-228. September 2003.
Summary of Existing Information Report (SEIR). Palermo Well Field Superfund Site Tumwater, Washington
Prepared by GeoEngineers, Inc. for Washington State Department of Transportation. May 2017.
Draft Data Gaps Investigation Report. Palermo Well Field Superfund Site Tumwater, Washington. Prepared by
GeoEngineers, Inc. for Washington State Department of Transportation. January 2018.
Record of Decision, Palermo Well Field, City of Tumwater, Thurston County, Washington. EPA/ROD/R10-
00/049. EPA Region 10, Seattle, Washington. October 1999.
Preliminary Closeout Report, Palermo Well Field Superfund Site, Tumwater, Washington. Prepared by EPA
Region 10 and signed by Michael Gearhead, Director, Office of Environmental Cleanup, Region 10, Seattle,
Washington. February 2001.
Office of Environmental Assessment (OEA) Recommendations Regarding Trichloroethylene Toxicity in
Human Health Risk Assessment. Memorandum from Joyce C. Kelly, Director, OEA to Rick Albright, Director of
Office of Environmental Cleanup and Kate Kelly, Director of Office of Air, Waste and Toxics, December 13,
2012.
Optimization Evaluation, Palermo Well Field Superfund Site, City of Tumwater, Thurston County, Washington.
Office of Solid Waste and Emergency Response. November 2011.
Operation and Maintenance Manual, Subdrain System and Treatment Lagoon, Palermo Well Field Superfund
Site, Tumwater, Washington. Prepared for EPA Region 10 under Remedial Action Contract No. 68-W-98-228.
August 2002.
A-l
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Third Five-Year Review Report: Palermo Well Field Superfund Site, Tumwater, Washington. Prepared by
CH2MHill for EPA Region 10 under Contract No. 68-S7-04-01. September 2013.
A-2
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APPENDIX B - SITE CHRONOLOGY
Table B-l: Site Chronology
Event
Date
City of Tumwater discovered TCE exceeding the MCL at the Palermo well field
August 1993
EPA completed an expanded site investigation
April 1996
EPA proposed the Site for listing on the NPL
December 20, 1996
EPA finalized the Site's listing on the NPL
April 1, 1997
EPA started the RI/FS
Mid 1997
EPA installed an SVE unit at Southgate as part of a removal action
March 24, 1998
EPA completed construction of wellhead treatment system as part of a removal action
(construction complete)
February 1999
Initial RI/FS completed
June 30, 1999
EPA signed the Site's ROD
November 16, 1999
PRP began the remedial design for the subdrain and treatment lagoon
November 1999
PRP completed the remedial design for the subdrain and treatment lagoon
June 9, 2000
EPA decommissioned the SVE system at Southgate
June 2000
PRP began remedial construction for the subdrain and treatment lagoon
August 8, 2000
PRP completed remedial construction for the subdrain and treatment lagoon
January 9, 2001
EPA signed the Site's Preliminary Close-Out Report
February 22, 2001
PRP initiated remedial action
June 1, 2001
EPA began semi-annual long-term groundwater monitoring of the Site with periodic
indoor air monitoring
August 2001
EPA completed the one-year validation period for the subdrain and treatment lagoon
January 2002
Ecology began O&M activities for the subdrain and treatment lagoon, transferring
some responsibilities to the City
February 2002
EPA signed the Site's first FYR Report
September 29, 2003
EPA signed the Site's second FYR Report
September 30, 2008
EPA prepared the Site's Remedy Optimization Evaluation Report
November 11, 2011
EPA and WSDOT entered into the ASAOC
July 6, 2012
PRP prepared the draft SEIR
January 31, 2013
PRP began Palermo neighborhood air monitoring investigation for vapor intrusion
March 2013
EPA signed the Site's third FYR Report
September 30, 2013
WSDOT sampled indoor air in the Palermo neighborhood
October 2013
WSDOT sampled indoor air in the Palermo neighborhood
February 2014
WSDOT sampled indoor air in the Palermo neighborhood
September 2014
WSDOT sampled indoor air in the Palermo neighborhood
September 2015
WSDOT sampled indoor air in the Palermo neighborhood
May 2016
PRP completed the Supplemental Remedial Investigation Data Gaps Work Plan
August 10, 2016
PRP finalized the 2014 Annual Groundwater Monitoring Report
February 24, 2017
WSDOT sampled indoor air in the Palermo neighborhood
March 2017
PRP finalized the 2015 Annual Groundwater Monitoring Report
April 7, 2017
PRP finalized the 2016 Annual Groundwater Monitoring Report
April 21, 2017
PRP finalized the SEIR
May 19, 2017
WSDOT sampled indoor air in the Palermo neighborhood
May 2017
PRP prepared the Winter and Spring 2017 Air Monitoring Report
October 19, 2017
EPA collected additional soil and groundwater data at Southgate area
October/November 2017
WSDOT sampled indoor air in the Palermo neighborhood
December 2017
PRP drafted the 2017 Annual Groundwater Monitoring Report
January 10, 2018
PRP completed the draft DGR
January 26, 2018
PRP collected additional monitoring data to fill data gaps
February 2018
PRP prepared the Fall 2017 Draft Air Monitoring Report
April 2,2018
B-l
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APPENDIX C - PRESS NOTICE
Cleanup Review Underway
Asking for Public Input
Palermo Wellfield Ground Water
Contamination Superfund Site
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C-l
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APPENDIX D - INTERVIEW FORMS
Palermo Well Field Ground Water Five-Year Review Interview Form
Contamination Superfund Site
Site Name: Palermo Well Field Ground EPA ID No.: WA0000026534
Water Contamination
Subject Name: Lara Linde Affiliation: GeoEngineers
Subject Contact Information: (253) 383-4940 linde@geoengineers.com
Time: 11:15 A.M. Date: 04/22/2018
Interview Location: Tacoma, Washington
Interview Format: Email Response
Interview Category: O&M Contractor
1. What is your overall impression of the project, including cleanup, maintenance and reuse activities (as
appropriate)?
The project has made significant progress in the last two years, gaining a better understanding of current
groundwater dissolved phase solvent contamination and water quality conditions across the Site that will
update the conceptual site model and inform future potential cleanup alternatives.
2. What is your assessment of the current performance of the remedy in place at the Site?
The stripper towers have continued to be effective at removing site contaminants from groundwater. The
subdrain continues to be effective at transporting shallow groundwater containing site contaminants to the
aeration lagoon for treatment, even though portions of the subdrain are not meeting some of the
performance criteria to lower the water table. Lowering of the water table may not be practicable as
envisioned because of artesian conditions in the area.
3. What are the findings from the monitoring data? What are the key trends in contaminant levels that are
being documented over time at the Site?
Semiannual groundwater monitoring data generally indicate that concentrations of site
contaminants are slowly decreasing over time. Concentration trends are best described in the
Draft 2017 Annual Groundwater Monitoring Report and has been excerpted below:
Concentrations of PCE and TCE in groundwater samples collected in 2017 are generally
consistent with previous monitoring events in 2013 through 2016. With one exception,
concentration trends for PCE and TCE are either decreasing or stable based on Mann-Kendall
trend tests performed using long-term groundwater monitoring data obtained since 2004. The
TCE concentration trend in groundwater samples from piezometer PZ-719 showed a slight
increasing trend; however, the concentrations remain below the ROD remedial goal of 5 jug/L. This minor
increasing trend was not observed in 2013 through 2015.
4. Is there a continuous on-site O&M presence? If so, please describe staff responsibilities and activities.
Alternatively, please describe staff responsibilities and the frequency of site inspections and activities if
there is not a continuous on-site O&M presence.
For the portions of O&M that WSDOT (GeoEngineers) is involved with, there is no continuous
on-site presence. GeoEngineers' activities are limited to implementing the O&M Plan for the
subdrain and treatment lagoon. These activities are performed twice a year for the subdrain
and once a year for the lagoon.
D-l
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5. Have there been any significant changes in site O&M requirements, maintenance schedules or sampling
routines since start-up or in the last five years? If so, do they affect the protectiveness or effectiveness of
the remedy? Please describe changes and impacts.
No changes to GeoEngineers' O&M tasks have taken place in the last five years.
6. Have there been unexpected O&M difficulties or costs at the Site since start-up or in the last five years? If
so, please provide details.
No unexpected O&M difficulties have been observed or unexpected costs incurred from the tasks
completed by GeoEngineers.
7. Have there been opportunities to optimize O&M activities or sampling efforts? Please describe changes
and any resulting or desired cost savings or improved efficiencies.
Yes, O&M sampling and monitoring activities have been optimized so that they occur
simultaneously with either indoor air monitoring or semiannual groundwater monitoring for
efficiency and to provide a broader set of data for site understanding.
8. Do you have any comments, suggestions or recommendations regarding O&M activities and schedules at
the Site?
GeoEngineers' recommends revising the performance criteria for the southern segment of the subdrain to
more closely reflect the current operation of the subdrain, which is affected by artesian conditions that
naturally occur in this area and inhibit further reduction of the groundwater level. A suggestion to
consider for a performance criteria revision for the southern segment may be an evaluation of whether
flow continues throughout the southern segment (Cleanouts C06, C07 and C08). This could be
completed by visually observing the water inside the three cleanouts for movement (flow) and by
continuing to take flow measurements that are already a part of the twice-yearly subdrain O&M activities.
The remaining evaluation could consist of comparing upstream (C08) and downstream (C06) flow rates
and visual observations to determine whether flow continues to occur. GeoEngineers recommends a
monitoring reduction to a nine-month frequency at long-term groundwater monitoring locations. This
recommendation is consistent with the frequency proposed in the Draft Interim Long-Term Monitoring
Plan. GeoEngineers also recommends amending the subdrain and treatment lagoon O&M Plan to the
same nine-month frequency so that these activities can continue to be efficiently coordinated together.
9. Do you consent to have your name included along with your responses to this questionnaire in the FYR
Report?
The respondent should be identified as GeoEngineers.
D-2
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Palermo Well Field Ground Water Five-Year Review Interview Form
Contamination Superfund Site
Site Name: Palermo Well Field Ground EPA ID No.: WA0000026534
Water Contamination
Subject Name: Norman Pavton Affiliation: Washington State Department of
Transportation
Subject Contact Information: 360-705-7848 / pavtonn@wsdot.wa.gov
Time: 3:23 P.M. Date: 04/12/2018
Interview Location: WSDOT Headquarters
Interview Format (circle one): In Person Phone Mail Other: Email
Interview Category: State Agency
1. What is your overall impression of the project, including cleanup, maintenance and reuse activities (as
appropriate)?
The project has made substantial progress since the last FYR. With the membrane interface probe data,
confirmation sampling and new wells, we have a better definition of the groundwater plume. Continued vapor
intrusion sampling has provided us with a better understanding of this exposure pathway.
2. What is your assessment of the current performance of the remedy in place at the Site?
The City's stripper towers continue to be effective in removing TCE prior to the water being introduced to the
City's drinking water system. The aeration lagoon continues to treat water being removed from the subdrain
system to action levels. The subdrain is not meeting performance criteria to lower the water table to depths
below specific levels below neighborhood homes.
3. Are you aware of any complaints or inquiries regarding site-related environmental issues or remedial
activities from residents in the past five years?
One homeowner with indoor air results above short-term risk-based concentration for TCE (2.0 (.ig/nr1).
requested that WSDOT install an energy recovery ventilator in their home to mitigate for TCE. WSDOT
informed the homeowner that that his proposed system did not reflect EPA's guidance, and we would not be
installing his option. WSDOT had offered that homeowner a combination subgrade (crawlspace + subslab)
vapor barrier and depressurization system at no cost to the homeowner. The homeowner declined WSDOT's
offer.
A homeowner who sold his house in 2015 threatened to sue WSDOT due to claims he had to sell his house at
a reduced price due to site contamination. Last month, this same individual requested that WSDOT disclose
how much WSDOT has paid to property owners for damages from site cleanup due to TCE. Our agency
responded by stating that WSDOT has not paid any dollar amount to property owners for damages within the
Site for TCE.
Approximately two months ago, a member of the public requested information on ambient TCE air levels in
the site area. We referred him to the air reports located at the repository at the Timberland Library. A few
years ago, two neighbors with homes near the toe of the bluff inquired about increased standing water in their
back yards west of the subdrain. They were wondering if the higher water level was due to a problem with the
subdrain. Numerous times, new homeowners stated that they did not know that they were purchasing a home
on a Superfund site.
Approximately one month ago, a resident asked why we need to keep coming back to do more work, and why
have Superfund activities increased in the last two years.
D-3
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Inquiries about the amount of field work near the 9000 Building. Inquiries about worker exposure due to
levels of contaminants in soil and groundwater near the building.
4. Has your office conducted any site-related activities or communications in the past five years? If so, please
describe the purpose and results of these activities.
• Request for participation in vapor intrusion sampling via letters, post cards, door to door solicitation.
• Distribution of air monitoring result letters.
• Distribution of groundwater monitoring result letters.
• Drilling notification. Flyers on doors for residents. Handouts to commercial businesses.
• Access agreement solicitation - letters, emails, phone calls, in person.
• Communication with City - letters, emails, phone calls, in person
• Updates to the state legislature regarding vapor intrusion sampling.
• Update to the Governor's Office regarding vapor intrusion sampling.
• Presentation to an environmental science class at Olympia High School.
5. Are you aware of any changes to state laws that might affect the protectiveness of the Site's remedy?
No.
6. Are you comfortable with the status of the institutional controls at the Site? If not, what are the associated
outstanding issues?
I don't believe there are any institutional controls at the Site.
7. Are you aware of any changes in projected land use(s) at the Site?
I am not aware of any potential changes in projected land use. Dan Smith with the City would be a good
contact for this question.
8. Do you have any comments, suggestions or recommendations regarding the management or operation of the
Site's remedy?
As we have stated in our draft Long-Term Monitoring Plan, we believe those groundwater wells currently
being sampled on a semi-annual basis could be sampled every nine months. The Optimization Evaluation
stated that annual sampling is recommended for some wells.
9. Do you consent to have your name included along with your responses to this questionnaire in the FYR
Report?
Yes.
D-4
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Palermo Well Field Ground Water Five-Year Review Interview Form
Contamination Superfund Site
Site Name: Palermo Well Field Ground EPA ID No.: WA0000026534
Water Contamination
Subject Name: Dan Smith Affiliation: City of Tumwater
Subject Contact Information: phone and/or email
Time: 2:55 P.M. Date: 05/08/2018
Interview Location: Tumwater Public Works. Office
Interview Format (circle one): In Person Phone Mail Other: Email
Interview Category: City
1. What is your overall impression of the project, including cleanup, maintenance and reuse activities (as
appropriate)?
Overall, it is effective. Coordination with the parties has been excellent, particularly with the project
managers. Concerns have been addressed, access needs requested well in advance, and most project activities
are clearly understood before getting underway. We are very appreciative of the parties - EPA, WSDOT,
Ecology and the consultants have all done a good job keeping the City in the loop and coordinating with us.
Keep it up.
2. What is your assessment of the current performance of the remedy in place at the Site?
It works! We have no detections of volatile organic compounds entering our distribution system. The system
appears to be protective of public health, and it has been relatively easy maintenance.
3. What are the findings from the monitoring data? What are the key trends in contaminant levels that are being
documented overtime at the Site?
(This is probably more pertinent for EPA/WSDOT, or consultants, to summarize.)
4. Is there a continuous on-site O&M presence? If so, please describe staff responsibilities and activities.
Alternatively, please describe staff responsibilities and the frequency of site inspections and activities if there
is not a continuous on-site O&M presence.
Yes. City staff maintain the Well field and treatment system regularly and are accessible 24/7, throughout the
year. Standard operational hours are 7 a.m. through 5:30 p.m. After-hours support available through site
alarms or customer notification. Operations Manager Steve Craig can provide additional information on
routine and preventative maintenance schedules.
5. Have there been any significant changes in site O&M requirements, maintenance schedules or sampling
routines since start-up or in the last five years? If so, do they affect the protectiveness or effectiveness of the
remedy? Please describe changes and impacts.
There has been a major well field upgrade - two new wells, auxiliary power for the entire production and
treatment process, and updated Supervisory Control and Data Acquisition controls. These add to O&M
schedules, but none effect the protectiveness or effectiveness of the remedy. The project sought to increase
production, to the treatment level of the remedy.
6. Have there been unexpected O&M difficulties or costs at the Site since start-up or in the last five years? If so,
please provide details.
There have been no unexpected O&M difficulties.
D-5
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7. Have there been opportunities to optimize O&M activities or sampling efforts? Please describe changes and
any resulting or desired cost savings or improved efficiencies.
The City routinely evaluates processes for costs savings and operational efficiency. Most recently, the
upgrades noted in #5 have allowed us to replace less efficient pumps in other wells to save power. Any
additional recommendations to improve efficiency or save costs are always welcome.
8. What measures are in place to restrict placement of wells (potable, irrigation, etc.) within the drinking water
system's boundaries?
Our region operates under the Coordinated Water System Plan, adopted by all the regional jurisdictions. This
restricts Group A and Group B water systems, as well as exempt wells, within close proximity to the existing
water system. Where Group A or B systems are permitted, approvals are given temporarily and they are
required to connect when city water reaches their parcel.
9. Do you have any comments, suggestions or recommendations regarding O&M activities and schedules at the
Site?
Public Works Operations has been implementing an effective and functional preventative maintenance
program.
10. Do you consent to have your name included along with your responses to this questionnaire in the FYR
Report?
Yes.
D-6
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Palermo Well Field Ground Water Five-Year Review Interview Form
Contamination Superfund Site
Site Name: Palermo Well Field Ground EPA ID No.: WA0000026534
Water Contamination
Subject Name: Andrew Smith Affiliation: Department of Ecology. State
of Washington
Subject Contact Information: Andrew.smith@ecv.wa.gov
Time: 9:47 am Date: 05/23/2018
Interview Location: Ecology/Lacev, WA
Interview Format (circle one): In Person Phone Mail Other: Filled out
Form
Interview Category: State Agency
1. What is your overall impression of the project, including cleanup, maintenance and reuse activities (as
appropriate)?
It appears the site is cleaning up as designed. It appears that the environment and the public are being
protected.
2. What is your assessment of the current performance of the remedy in place at the Site?
It appears the contaminant concentrations in the well field wells are below MTCA standards. It appears that
the contaminant plume is reducing.
3. Are you aware of any complaints or inquiries regarding site-related environmental issues or remedial
activities from residents in the past five years?
No.
4. Has your office conducted any site-related activities or communications in the past five years? If so, please
describe the purpose and results of these activities.
No.
5. Are you aware of any changes to state laws that might affect the protectiveness of the Site's remedy?
Ecology is updating its cleanup levels to reflect the new EPA Integrated Risk Information System toxicity
values for TCE.
6. Are you comfortable with the status of the institutional controls at the Site? If not, what are the associated
outstanding issues?
Yes
7. Are you aware of any changes in projected land use(s) at the Site?
No
8. Do you have any comments, suggestions or recommendations regarding the management or operation of the
Site's remedy?
D-7
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No
9. Do you consent to have your name included along with your responses to this questionnaire in the FYR
report?
Yes
D-8
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Palermo Well Field Ground Water Five-Year Review Interview Form
Contamination Superfund Site
Site Name: Palermo Well Field Ground EPA ID No.: WA0000026534
Water Contamination
Interviewer Name: Kav Morrison Affiliation: EPA
Subject Name: Resident Affiliation: Resident of Palermo
neighborhood
Time: 9:30 A.M. Date: 03/22/2018
Interview Format: In Person
Interview Category: Resident 1
1. Are you aware of the former environmental issues at the Site and the cleanup activities that have taken place
to date?
Yes. I have lived here for almost five years and have been told about the history and why they are doing the
in-house sampling. I understand the need to collect the data and it is not a big deal to let the sampling happen
in my house.
2. What is your overall impression of the project, including cleanup, maintenance and reuse activities (as
appropriate)?
Before today, I did not know about the water treatment next to the park, but we are aware of when they are
doing work in the neighborhood. I have had a good impression.
3. What have been the effects of the Site on the surrounding community, if any?
No one really talks about the Site. We have a neighborhood Facebook group and it is not mentioned much
there. We did have a post on the Facebook page when EPA had the informational event at the park.
4. Have there been any problems with unusual or unexpected activities at the Site, such as emergency response,
vandalism or trespassing?
No. This is a safe part of town and I love the neighborhood; I am familiar with most of the residents.
5. Has EPA kept involved parties and surrounding neighbors informed of activities at the Site? How can EPA
best provide site-related information in the future?
We get good communication from WSDOT and GeoEngineers; I get letters that say how the sampling went
and I'm not sure I need more information than that. I don't feel like I need information directly from EPA as I
feel like I'm getting what I need already. If additional EPA information was shared, it would be best through
the neighborhood Facebook page; I wouldn't really look at a website.
6. Do you own a private well in addition to or instead of accessing city/municipal water supplies? If so, for what
purpose(s) is your private well used?
No.
7. Do you have any comments, suggestions or recommendations regarding any aspects of the project?
No, I think you guys are doing a great job. I get the information I need and everyone has been friendly, nice
and respectful.
D-9
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Palermo Well Field Ground Water
Contamination Superfund Site
Five-Year Review Interview Form
Site Name: Palermo Well Field Ground
Water Contamination
EPA ID No.: WA0000026534
Interviewer Name:
Subject Name:
Time: 2:00 P.M.
Interview Format:
Kav Morrison
Nearby Business
Employee
In Person
Affiliation:
Affiliation:
EPA
Affected Business
Date: 03/22/2018
Interview Category: Resident 2
1. Are you aware of the former environmental issues at the Site and the cleanup activities that have taken place
to date?
Yes, the "what" (WSDOT and dry-cleaning waste in the water) was brought to us as a plan to monitor
groundwater at depth. That's what I knew first. I got handouts and drawings from EPA (Claire Hong) and it
was news to us and we had no idea what was happening at the Site or with the drilling. We got new building
owners and I had to try to tell them what was happening at the building to explain the access agreements.
In September 2017,1 received the first notice that they were coming to our parking lot to do drilling. Then we
saw tents, hard hats, drills, trucks, etc. The only communication we received was from the vendors because I
walked outside and asked them questions. GeoEngineers was very helpful; we would get notice that they were
coming to our parking lot. With the drilling machine, my staff had a lot of questions. My records show that
aside from the early 2016 information from EPA RPM, we only got information one additional time in
September 2017 - which was the "what" but not the "why" drilling and sampling was occurring. The
businesses listed in the materials that were to be impacted did not include our building.
EPA didn't share why this work was happening. I asked for information from EPA to communicate to staff. I
was told that EPA couldn't provide information because sampling was incomplete and nothing could be
provided in writing because it wasn't yet finalized. Vendors seemed prohibited from providing information
(CH2MHill was helpful in trying to obtain information but came back with the same message). We were
frustrated we couldn't get answers about why the drilling was happening. We were blasted recently in an
employee safety survey because we couldn't get answers to employees about the sampling and drilling. Some
worked from home because of concerns about what the drilling potentially meant. We went to the EPA
website and it was not up to date, it included scientific jargon, and it felt like something was being hidden. It
was not helpful to pull information to potentially share with concerned on-site staff.
I was provided information from a vendor who shared some statistics that told us what they are monitoring,
but what does it mean? I tried to tell people that the tap water was being treated. Except for initial contact
from EPA, we have only had contact with the vendors. We tried for phone calls to ask for a couple of
paragraphs to share and couldn't get it. It made me feel like I was an inconvenience and made me
disconcerted. It reinforced that what EPA is doing is scientific, secretive and dangerous. Every time
GeoEngineers was out there with tents and trucks, it struck anxiety with my staff; we thought they were done,
and then they would come back again. It's not the inconvenience of the drilling, it is the not knowing why
there is drilling.
I told my executives the vague information I had and shared that I couldn't get good information from EPA,
but it is not enough. I believe it is time that EPA updates its website to the current status and emails us, and
other impacted business owners, with regular updates.
Sometimes it feels like we are the tallest, biggest and most-heard building in the area and we should speak up,
because the smaller businesses don't have the time or manpower. I have not been sure to who escalate this
D-10
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issue to. As a neighbor and government office, we should stand up. We have not been updated by EPA since
the initial information was shared, which was not well explained. Nobody would argue against this being
implemented, but we would like to know why.
We have a budget, attorneys and elected officials. Politics get involved and it's one thing if our staff is
unsettled, but it brings up another issue on the insurance side: now who pays for what?
If you look up the Site online, it is scary and I'm surprised it hasn't come out as a bigger public problem. I
have been really disappointed with not hearing from EPA about the status, why and if the work is done, what
is happening out there now and going forward. Without enough information from EPA, we fill in our own
blanks. The vendors have been fantastic. For the internal safety survey, I would like to have a response for
concerned staff. I don't have one and it makes me feel helpless.
Let's get better communication going forward. I've been with this agency 25 years and I've earned influence,
which I protect. It's hard because I couldn't tell staff anything, but my executive wanted to me to share
something, but I couldn't make anything up.
2. What is your overall impression of the project, including cleanup, maintenance and reuse activities (as
appropriate)?
See above.
3. What have been the effects of the Site on the surrounding community, if any?
It has made some employees fearful (see above).
4. Have there been any problems with unusual or unexpected activities at the Site, such as emergency response,
vandalism or trespassing?
Drilling and sampling mentioned above.
5. Has EPA kept involved parties and surrounding neighbors informed of activities at the Site? How can EPA
best provide site-related information in the future?
No. We want statements in writing to show what is happening. Will this be ongoing? When will it be done?
What is the status? We don't need EPA staff here to speak to staff, we just need a couple paragraphs to share
with them. It needs to be written without scientific jargon; I'd prefer to not have to rewrite it. It should be
something your neighbor or grandmother could read and understand. We are excited to get this. It will be nice
to have a response to provide to concerned staff from the employee safety survey. It will be nice to share this
progress and we can let executives know that we have a response coming to deal with staff comments. It will
be nice to have a qualified response. This information can also be used to update the EPA website to make it
current. We would like to know why it is a Superfund site, what the status is, when it will be done, what does
it mean, etc.
6. Do you own a private well in addition to or instead of accessing city/municipal water supplies? If so, for what
purpose(s) is your private well used?
No.
7. Do you have any comments, suggestions or recommendations regarding any aspects of the project?
See above.
D-ll
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Palermo Well Field Ground Water
Contamination Superfund Site
Five-Year Review Interview Form
Site Name: Palermo Well Field Ground
Water Contamination
EPA ID No.: WA0000026534
Interviewer Name:
Subject Name:
Time: 3:00 P.M.
Interview Format:
Kav Morrison
Resident
In Person
Affiliation:
Affiliation:
EPA
Resident of Palermo
Date:
neighborhood
03/22/2018
Interview Category: Resident 3
1. Are you aware of the former environmental issues at the Site and the cleanup activities that have taken place
to date?
Yes, very much so. Props to everyone involved. Lara Linde is great to work with. Public outreach and
education has been great.
2. What is your overall impression of the project, including cleanup, maintenance and reuse activities (as
appropriate)?
Very positive.
3. What have been the effects of the Site on the surrounding community, if any?
The neighborhood is not very cohesive, but the Site really hasn't been a topic of conversation. I have had
some interaction with one neighbor who is a former state employee (I am also a local government employee)
and I don't get a sense of a high level of concern. If I were pregnant, I would have more concern. People do
not seem frustrated and I haven't heard any concern about home values declining. No news is good news.
4. Have there been any problems with unusual or unexpected activities at the Site, such as emergency response,
vandalism or trespassing?
No, not at all.
5. Has EPA kept involved parties and surrounding neighbors informed of activities at the Site? How can EPA
best provide site-related information in the future?
Yes, I think definitely. It would be great to receive electronic versions of handouts by email after receiving
the hard copies. We had a great meeting at the restaurant at the golf course and you've done a great job
keeping us informed. We mostly have received handouts at meetings, calls and occasional sampling results.
We don't receive emails and maybe more digital outreach would help - email would be great. It is great to
receive educational materials in paper format but would be great to get them electronically as well, as a
backup. I don't personally use social media but it does work for a lot of people; the younger generation is
geared toward social media. I think sharing the information through as many media as possibly is the best
way to get it to the most people. We see GeoEngineers in the neighborhood all the time; they are great about
reaching out.
6. Do you own a private well in addition to or instead of accessing city/municipal water supplies? If so, for what
purpose(s) is your private well used?
D-12
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Everyone is on city water. I am not aware of any in the neighborhood and I don't have one. Our house had an
old septic tank that we filled in when we did a renovation, and it is possible that other houses have those relics
as well.
7. Do you have any comments, suggestions or recommendations regarding any aspects of the project?
I think you guys have really done a good job.
Request: I know you take water heights and it would be great to share that information with interested
residents via a live website, if possible.
Response: EPA explained the data is not available in real time. But could be something to consider in the
future.
Request: Are any soil boring details of the property available (from when wells were dug) to see the geology
of the property?
Response: EPA will look to see if there are any geological profiles available to share.
D-13
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APPENDIX E - SITE INSPECTION CHECKLIST
FIVE-YEAR REVIEW SITE INSPECTION CHECKLIST
L SITE INFORMATION
Site Name: Palermo Well Field Ground Water
Contamination
Date of Inspection: 3/22/2018
Location and Region: Tumwater, WA 10
EPA ID: WA0000026534
Agency, Office or Company Leading the Five-Year
Review: RggionK)
Weather/Temperature: 42 degrees F/rainv
~ Monitored natural attenuation
~ Groundwater containment
~ Vertical barrier walls
Remedy Includes: (Check all that apply)
~ Landfill cover/containment
~ Access controls
^ Institutional controls
^ Groundwater pump and treatment
~ Surface water collection and treatment
^ Other: SVE operated from 1998 to 2000 at the Southgate facility : subdrain and aeration lagoon, well head
treatment at Palermo Well field: and long-term groundwater monitoring.
Attachments: EH Inspection team roster attached
~ Site map attached
II. INTERVIEWS (check all that apply)
1. O&M Site Manager Steve Craig
Name
Interviewed ~ at site ~ at office ~ by phone
Problems, suggestions ~ Report attached:
Operations Manager
Title
Date
Phone:
2. O&M Staff
Name
Interviewed ~ at site ~ at office ~ by phone
Problems/suggestions ~ Report attached:
Title
Phone:
Date
3. Local Regulatory Authorities and Response Agencies (i.e., state and tribal offices, emergency
response office, police department, office of public health or environmental health, zoning office, recorder of
deeds, or other city and county offices). Fill in all that apply.
Agency City of Tumwater
Contact Dan Smith
Name
Water Resources
Program Manager
Title
5/8/2018
Date
Phone No.
Problems/suggestions ~ Report attached:
Agency WSDOT
Contact Norm Pavton Site Manager
Name Title
Problems/suggestions ~ Report attached:
4/12/2018 360-705-7848
Date Phone No.
Agency
Contact
Name Title
Problems/suggestions ~ Report attached:
Date
Phone No.
Agency
Contact
Name Title
Problems/suggestions ~ Report attached:
Date
Phone No.
E-l
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Asencv
Contact
Name Title
Problcms/suaaestions r~| Report attached:
Date
Phone No.
4. Other Interviews (optional) I-! Report attached:
Lara Linde, GeoEngineers, Project Manager (WSDOT Contractor)
Two residents of Palermo neighborhood
Businessman in an office building in the Southgate area
HI. ON-SITE DOCUMENTS AND RECORDS VERIFIED (check all that apply)
1. O&M Documents
1)^1 O&M manual ^ Readily available
EUp date
~ n/a
1^1 As-built drawings ^ Readily available
E|Up to date
~ n/a
1)^1 Maintenance logs ^ Readily available
E|Up to date
~ n/a
Remarks:
2. Site-Specific Health and Safety Plan
~ Readily available
~ Up to date
El n/a
~ Contingency plan/emergency response plan
~ Readily available
~ Up to date
El n/a
Remarks:
3. O&M and OSHA Training Records
~ Readily available
~ Up to date
ElN/A
Remarks:
4. Permits and Service Agreements
~ Air discharge permit
~ Readily available
~ Up to date
El N/A
1)^1 Effluent discharge
Readily available
EUp to date
~ n/a
~ Waste disposal, POTW
~ Readily available
~ Up to date
El N/a
I-! Other Dcrmits:
~ Readily available
~ Up to date
El N/a
Remarks: Discharge ooint of compliance is downeradient of the treatment lasoon before dischareine to the
Deschutes River.
5. Gas Generation Records
~ Readily available
~ Up to date
El N/A
Remarks:
6. Settlement Monument Records
~ Readily available
~ Up to date
El N/A
Remarks:
7. Groundwater Monitoring Records
Readily available
EUp to date
~ n/a
Remarks:
8. Leachate Extraction Records
^ Readily available
E|Up to date
~ n/a
Remarks:
9. Discharge Compliance Records
~ Air ~ Readily available
~ Up to date
El
N/A
M Water (effluent) ^ Readily available
E|Up to date
~ n/a
E-2
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Remarks: Discharge Dcrmit reauired and in olacc for treatment lasoon but no air Dcrmit is reauired for the air
strippers.
10. Daily Access/Security Logs
~ Readily available ~ Up to date ^ N/A
Remarks:
IV.
O&M COSTS
1. O&M Organization
1 1 State in-house
1 1 Contractor for state
1 1 PRP in-house
^Contractor for PRP
1 1 Federal facility in-house
1 1 Contractor for Federal facility
n
2. O&M Cost Records
1 1 Readily available
1 1 Up to date
1 1 Funding mechanism/agreement in place £
^ Unavailable
Orieinal O&M cost estimate: PI Breakdown attached
Total annual cost by year for review period if available
From: To:
I-! Breakdown attached
Date Date
Total cost
From: To:
I-! Breakdown attached
Date Date
Total cost
From: To:
I-! Breakdown attached
Date Date
Total cost
From: To:
I-! Breakdown attached
Date Date
Total cost
From: To:
I-! Breakdown attached
Date Date
Total cost
3. Unanticipated or Unusually High O&M Costs during Review Period
Describe costs and reasons:
V. ACCESS AND INSTITUTIONAL CONTROLS ^Applicable ~ N/A
A. Fencing
1. Fencing Damaged ~ Location shown on site map ^ Gates secured I~1 N/A
Remarks: Fencins around treatment lasoon and Palermo Well field: fencins in sood condition.
B. Other Access Restrictions
1. Signs and Other Security Measures
~ Location shown on site map ^ N/A
Remarks:
C. Institutional Controls (ICs)
E-3
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1. Implementation and Enforcement
Site conditions imply ICs not properly implemented ~ Yes E| No ~ N/A
Site conditions imply ICs not being fully enforced I I Yes Rl No ~ N/A
Type of monitoring (e.g., self-reporting, drive by):
Frequency:
Responsible party/agency:
Contact
Name Title
Reporting is up to date
Reports are verified by the lead agency
Specific requirements in deed or decision documents have been met
Violations have been reported
Other problems or suggestions: ~ Report attached
Date
Phone no.
I~1 Yes
~
No
IK|n/a
I~1 Yes
~
No
IK|n/a
I~1 Yes
IEI
No
~ n/a
I~1 Yes
~
No
[XI n/a
2. Adequacy ~ ICs are adequate ^ ICs are inadequate ~ N/A
Remarks: Currently, no institutional control is recorded for the Southgate Dry Cleaners. However, the land use
has not changed since the ROD.
D. General
1. Vandalism/Trespassing ~ Location shown on site map ^ No vandalism evident
Remarks:
2. Land Use Changes On Site ^ N/A
Remarks:
3. Land Use Changes Off Site ^ N/A
Remarks:
VI. GENERAL SITE CONDITIONS
A. Roads Applicable ~ N/A
1. Roads Damaged ~ Location shown on site map ^ Roads adequate ~ N/A
Remarks:
B. Other Site Conditions
Remarks:
VII. LANDFILL COVERS ~ Applicable [XI N/A
VHI. VERTICAL BARRIER WALLS ~ Applicable [XI N/A
IX. GROUND WATER/SURFACE WATER REMEDIES ^Applicable ~ N/A
A. Groundwater Extraction Wells, Pumps and Pipelines ~ Applicable ^ N/A
1. Pumps, Wellhead Plumbing and Electrical
~ Good condition ~ All required wells properly operating ~ Needs maintenance ~ N/A
Remarks:
E-4
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2. Extraction System Pipelines, Valves, Valve Boxes and Other Appurtenances
~ Good condition ~ Needs maintenance
Remarks:
3. Spare Parts and Equipment
~ Readily available ~ Good condition ~ Requires upgrade ~ Needs to be provided
Remarks:
B. Surface Water Collection Structures, Pumps and Pipelines ~ Applicable ^ N/A
1. Collection Structures, Pumps and Electrical
~ Good condition ~ Needs maintenance
Remarks:
2. Surface Water Collection System Pipelines, Valves, Valve Boxes and Other Appurtenances
~ Good condition ~ Needs maintenance
Remarks:
3. Spare Parts and Equipment
~ Readily available ~ Good condition ~ Requires upgrade ~ Needs to be provided
Remarks:
C. Treatment System ^ Applicable ~ N/A
1. Treatment Train (check components that apply)
~ Metals removal ~ Oil/water separation ~ Bioremediation
M Air stripping ~ Carbon adsorbers
1)^1 Filters: Air used by air strippers is filtered.
1)^1 Additive (e.g., chelation agent, flocculent): Disinfection.
^Others: Acid used to strip build-up of chlorite from media in the strippers.
M Good condition ~ Needs maintenance
1)^1 Sampling ports properly marked and functional
M Sampling/maintenance log displayed and up to date
M Equipment properly identified
~ Quantity of groundwater treated annually:
~ Quantity of surface water treated annually:
Remarks: Treatment lagoon operates aerators to treat groundwater collected by the subdrain.
2. Electrical Enclosures and Panels (properly rated and functional)
~ N/A Good condition ~ Needs maintenance
Remarks:
3. Tanks, Vaults, Storage Vessels
~ N/A Good condition ~ Proper secondary containment ~ Needs maintenance
E-5
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Remarks:
4. Discharge Structure and Appurtenances
~ N/A Good condition ~ Needs maintenance
Remarks:
5. Treatment Building(s)
~ N/A Good condition (esp. roof and doorways) ~ Needs repair
1)^1 Chemicals and equipment properly stored
Remarks:
6. Monitoring Wells (pump and treatment remedy)
1^1 Properly secured/locked ^ Functioning ^Routinely sampled ^ Good condition
1^1 All required wells located ~ Needs maintenance ~ N/A
Remarks:
D. Monitoring Data
1. Monitoring Data
1)^1 Is routinely submitted on time
Is of acceptable quality
2. Monitoring Data Suggests:
1 1 Groundwater plume is effectively contained
~ Contaminant concentrations are declining
E. Monitored Natural Attenuation
1. Monitoring Wells (natural attenuation remedy)
~ Properly secured/locked ~ Functioning ~ Routinely sampled ~ Good condition
~ All required wells located ~ Needs maintenance ^ N/A
Remarks:
X. OTHER REMEDIES
If there are remedies applied at the site and not covered above, attach an inspection sheet describing the physical
nature and condition of any facility associated with the remedy. An example would be soil vapor extraction.
XL OVERALL OBSERVATIONS
A . Implementation of the Remedy
Describe issues and observations relating to whether the remedy is effective and functioning as designed. Begin
with a brief statement of what the remedy is designed to accomplish (e.g., to contain contaminant plume,
minimize infiltration and gas emissions).
The remedy included continuing the operation of the wellhead treatment system (using air stripping) at the
Palermo Well field and the SVE system at the Southgate area installed as early actions. The remedy also included
the construction of a subdrain system in the Palermo neighborhood to lower the groundwater water table 18
inches below the residential crawl spaces: construction of an aeration lagoon to treat groundwater collected from
the subdrain and discharge to the Deschutes River: long-term groundwater monitoring and monitoring of the
discharge from the aeration lagoon: and institutional controls (notification of groundwater contamination and
institutional controls on the Southgate area to reduce leaching of soil contamination to groundwater).
Groundwater concentrations show a general decline since remediation started: however, the concentrations of
PCE and TCE remain above ROD remedial goals. In addition, delineation of the TCE and PCE plumes is ongoing
at the CMTL (TCE) and at the Southgate area (PCE and TCE). Further, the subdrain does not capture all of the
shallow groundwater, resulting in some exceedances of vapor intrusion risk at one home due to contaminated
groundwater surfacing under the crawl space and affecting indoor air. Current data suggest that there may be
more sourcing occurring From soil lo groundwater at the Southgate area.
B . Adequacy of O&M
Describe issues and observations related to the implementation and scope of O&M procedures. In particular,
discuss their relationship to the current and long-term protectiveness of the remedy.
E-6
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O&M activities are conducted to maintain the wellhead treatment system, subdrain system and aeration lagoon.
No issues were identified with the current O&M activities.
C. Early Indicators of Potential Remedy Problems
Describe issues and observations such as unexpected changes in the cost or scope of O&M or a high frequency of
unscheduled repairs that suggest that the protectiveness of the remedy may be compromised in the future.
The city well field does not pump at high enough rates to contain the plume. Also, the subdrain system has been
successful in achieving performance criteria required by the ROD in the central portion of Rainier Avenue but not
at its south end or. occasionally, at the north end oF the street due to artesian conditions.
D . Opportunities for Optimization
Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy.
WSDOT and EPA are currently filling data gaps to support the evaluation of addition remedies to address
contamination that remains above ROD re medial goals.
E-7
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APPENDIX F - SITE INSPECTION PHOTOS
Palermo well field drinking water system treatment building
Palermo well field well houses
F-l
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Air strippers inside the drinking water treatment building
F-2
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- 1 PALERMO
c -1 tin »
tumwater park
Palermo Park, with drinking water well field and treatment building in the background
F-3
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U1W
m-
Treatment lagoon and aeration units with golf course in the background
i a ¦ k
DG-15 and DG-16 located on SE Palermo Ave in the Palermo neighborhood
F-4
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MW-DG-05 near CMTL building
ISPS
V, ~~
Dry cleaner at the Southgate Mall
F-5
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The CMTL
Regular
The Mobil gas station, location of the FMTL
F-6
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Drainage ditch area behind house near the subdrain area off M Street
F-7
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APPENDIX G - DETAILED DATA ANALYSIS
This appendix details contaminant trends for the last five years to evaluate remedy performance. Figure G-l is a
Site plan showing production wells and monitoring well locations.
Wellhead Treatment System
For this FYR period, four of the six city production wells were sampled on a semi-annual basis (TW-4, TW-5,
TW-8 and TW-16). TW-5 was decommissioned in January 2014 due to scale build-up; data are available through
2013 for this well. TW-3 is inactive due to its lower pump rate and was not sampled during this FYR period. The
number of production wells used for production varies depending on demand. TW-17 was installed in 2012 but
has not been operating. PCE concentrations in production well samples have been below laboratory detection
limits (0.2 |ig/L) throughout the review period. TCE has been detected in TW-4 and TW-16 before treatment;
concentrations in TW-16 exceeded the ROD remedial goal (5 j^ig/L) during each sampling event since it was
installed in 2014 (Table G-l). The City runs the treatment system using air stripper towers (ST-1 or ST-2). Air
stripping effectively removes TCE and PCE from groundwater; air stripper effluent samples are consistently
below laboratory detection limits. This demonstrates that the wellhead treatment system effectively eliminates
PCE and TCE contamination from groundwater before distribution.
Table G-l: Summary of TCE Detections in Production Wells Prior to Treatment
Production Well
TCE Concentrations (jig/L)a
TW-4
TW-16
September 2013
1.3
-
April 2014
0.43
9.6
August 2014
0.89
19
March 2015
<0.2
10
September 2015
0.89
18
April 2016
NA
NA
August 2016
0.6
NA
March 2017b
<0.2
7.1
August/Sept 2017b
<0.2
7.8
Notes:
a. Detailed results for all wells can be locatedin the following
reports:
2013 through 2015: 2016 Semiannual Groundwater Monitoring
Report, Table 3.
2016: 2016 Annual Groundwater Monitoring Report, Table B-5.
2017: Draft 2017 Annual Groundwater Monitoring Report,
Table 2.
- = well installed in 2012 and monitoring began in 2014.
NA = the City was performing upgrades to the treatment system so
no samples were collected from TW-4 and TW-16.
Bold = sample exceeds remedial goal of 5 ug/L.
Well Field Capture Zone
As part of evaluating the nature and extent of volatile organic compound contamination in Site groundwater,
WSDOT presented an updated capture zone analysis in the draft DGR and the draft 2017 Annual Groundwater
Monitoring reports issued in 2018. Although EPA continues to review these reports, they concluded that the TCE
plume would not be entirely captured at the current average usage rates. An updated capture zone analysis
indicated that the full targeted capture zone could be obtained by pumping the active wellfield wells continuously
at a maximum, though unlikely sustainable rate. The well field operator is not contractually obligated to
continually operate the well field to ensure complete plume capture. EPA and WSDOT will re-evaluate the well
field capture zone using data collected for the supplemental RI/FS.
G-l
-------
Plume Delineation and Long-Term Monitoring Adequacy
Since long-term monitoring began in 2004, PCE and TCE concentrations in groundwater have gradually
decreased in most wells where these COCs were detected as illustrated in the 2016 and 2017 annual groundwater
monitoring reports (GeoEngineering, 2016; 2017). WSDOT conducted statistical trend analyses where PCE or
TCE has been detected. The analysis shows a statistically significant decreasing trend in PCE and TCE
concentrations in most wells, piezometers, and production well TW-4 (Table G-2).
Table G-2: Summary of Contaminant Concentration Trends in Groundwater (2004 through 2016)
i rrAtrn'", O
Tutai Number or VOC
Samp.es Collected*
PCE Maximum
Concentration
Deterieu*
tpg/U/Date
Genera1 Long reirr> POfc Concentration
Statistics I'erd
95 P'eicent Confidence L.mst-
TCE Maximum
Co^cr'itration
Detected*
>.Lg, L), Date
General Long Term TCE Concentration
Statistical TrtnJ
(95 Percent Conriaenco lim^j
W 1 il£
1 ' vi, ;n \
f r
icyV-
Mt\ 10 U
j ;
fvil'l
Decreasing
o t 4 1 V
. " r e.k r j
vtu
-1 . '!•
0.26/ May 2004
WW 1 c
ju
wn
\ »' I'ft.M.A.
ti H P >
Mo JOi 4
>VnS
MvV , i
ivn
No ^ t
> , No, J L •
r > w
: i ;
Nir vi
t\"S i s >V . It'
Decreasing
w i ^ r
Decreasing
-r:
42 / Sep 2004
— ~
•lv\^ 1
- V' 4
h. ut-.t u ;
1 d \L> : - 1 n< o i' ir %
\H\ t i
£
Decreasing
M\7 t" »
Jt 1 4= 'bn2""jr
In c •'~ S , f k ml frr-i 0
'i ¦>(H»
,s * R
WA t
0.1 / Mar 2006
. t ,» me,
i 1 \
DvCt _ S-. - 3
' 1W ( ' >
25
ri> Vu ! ,
H
"Ms
mu rc> m
NO
Nu
hi "i 4
Decreasing
JO
\P
V t'.v
/ -
n ,
f ' L
11
i I . »•-
?h<'s < 'i n '\ v ' f ti <•» t Trend
Aur^'i M*»
No Statistically Significant Trend
r~ •
JJ . J X.'
' v u*- *
>S i\( «i ~
N 1» - lJiv b ?u 1 « a if T'C it.
eV \ i
- - t i
87 / May 2008
Nv ^ J.-bLuciU I.t. IU
11.
i\i:}
Nut - t 1t
-"4" Or-r?Al4
N ^ i is tU > ^nt i s-it Taml
PZ-726
1
'4' ' .'M'lu i
. ^ ::
No1. 'j
K
-------
beneath SE Rainier Avenue and SE M Street, then drains to the treatment lagoon at the Municipal Golf Course.
Water samples are collected from three subdrain cleanout locations (stations 357, 358 and 359) and four discharge
locations to the treatment lagoon (350, 356, 360 and 362) (Figure G-4). Treatment lagoon effluent (Station 361)
and the Deschutes River outfall location (Station 364), located about 2,000 feet downstream of the treatment
lagoon, are also sampled by WSDOT (Figure G-4). As shown in Table G-3, PCE and TCE concentrations are
reduced below the remedial goal as contaminated groundwater from the subdrain system and is treated by aeration
in the treatment lagoon.
Although the treatment lagoon meets performance criteria, the subdrain system may not be capturing all
contaminated groundwater as reported in the SEIR and the draft DGR. These reports indicate that the subdrain
system has achieved ROD performance criteria in the central portion of Rainier Avenue, but not at its south end
or, sometimes, at the north end of the street due to artesian conditions. These reports imply that the subdrain is not
effectively eliminating surface seeps along the base of the bluff as anticipated. WSDOT is preparing a
supplemental RI/FS that will identify additional remedies to address this concern.
G-3
-------
Table G-3: Summary of Subdrain System and Treatment Lagoon Data (2014 through 2017)
Location
PCE (ug/L)
TCE (us
/L)
Spring
2014
Summer
2014
Spring
2015
Summei
2015
Spring
2016
Fall
2016
Spring
2017
Fall
2017
Spring
2014
Summei
2014
Spring
2015
Summer
2015
Spring
2016
Fall
2016
Spring
2017
Fall
2017
Subdrain Qeanouts
357-Cleanout CO-6
10
12
11
11
10
11
9.2
9.8
8.4
6.0
7
6.5
7.9
6.0
11
8.0
358-Cleanout CO-4
7.0
8.0
8.1
8.0
7.0
7.3
6.0
5.0
15
14
14
14
14
14
14
17
359-Cleanout CO-1
4.6
4.3
4.2
4.6
4.4
4.0
3.9
4.4
12
10
10
11
10
11
10
11
Outfalls to Treatment Lagoon
350-M Street Drain
Outfall
0.2U
0.2U
0.2U
0.2U
0.2U
0.2U
0.2U
0.2U
1.2
1.0
1.2
1.4
1.3
1.5
1.2
0.37
356-Inflow from
Upstream Wetlands
0.2U
0.2U
0.2U
0.2U
0.2U
0.2U
0.2U
0.2U
0.2U
0.2U
0.23
0.2U
0.2U
0.2U
0.2U
0.2U
360-Tightline
Outfall
4.0
4.4
3.5
3.9
4.1
3.3
3.3
4.0
11
11
8.6
9.7
9.6
9.6
9.0
10
362-M Street
Terminus Catch
Basin Outfall
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
Treatment Lagoon Effluent
361-Lagoon Effluent | 0.3 | 0.3 | 0.24 | 0.27 | 0.26 | 0.20 | 0.24 | 0.39 | 0.95 | 0.82 | 0.76 | 0.86 | 0.73 | 0.66 | 0.81 | 1.1
Deschutes River Outfall
364-Point of
Compliance*
0.2U
0.2
0.2U
0.2U
0.2U
0.2U
0.2U
0.2U
0.5
0.5
0.2U
0.37
0.41
0.42
0.2U
0.38
Deschutes River
Discharge Remedial
Goal
0.8
2.7
Notes:
* = ROD remedial goals for the point of compliance for PCE and TCE are 0.8 jig/L and 2.7 ng/L, respectively.
Bold= concentrations of PCE or TCE that exceed the point of compliance discharge remedial goal. The remedial goal applies only at the outfall to the Deschutes River; however, thebolded values are
shown to highlight that concentrations are declining as PCE and TCE are treated in the lagoon.
U = below detection.
NS = not sampled.
G-4
-------
Soil Vapor Extraction System at Southgate Dry Cleaners
An SVE system operated from 1998 to 2000; it was decommissioned in 2000 when the average soil concentration
met the ROD remedial goal for PCE in soil. However, a confirmation sample collected after decommissioning
contained 0.232 mg/kg PCE, which exceeds the ROD remedial goal of 0.0858 mg/kg. EPA conducted a
supplemental investigation in October and November 2017; PCE concentrations in soil ranged from below
detection to 2.2 mg/kg (at SB-01) at the Southgate area. Samples SB-01 through SB-04 were collected under the
building slab. Samples SB-05 through SB-08 were collected in the parking lot in front of the Southgate Dry
Cleaner building. As shown in Table G-4, PCE was detected in seven of eight soil boring samples at
concentrations above the ROD remedial goal based on leaching to groundwater. The highest concentrations are in
SB-01 (2.2 mg/kg), which is the location of the former drywell where PCE was disposed. These results indicate
that soils in this area are potentially a continuing source to groundwater. The PCE detections do not appear to
pose a residential direct contact concern as the maximum concentration of 2.2. mg/kg is below EPA's 2017 RSL
of 24 mg/kg k) and the noncancer-based RSL of 81 mg/kg (based on an HQ of 1). These soils also are located
beneath a paved parking lot.
Table G-4: Summary of PCE Concentrations Detected in Soil at the Southgate Drycleaners Area (2017)
Sample
Feet (bgs)
Sample Date
PCE (mg/kg)
5
11/05/17
2.2
SB-01
11
11/05/17
1.9
14
11/05/17
0.240
3
11/05/17
0.770
SB-02
10
11/05/17
1.6
12.5
11/05/17
1.1
8
11/05/17
1.4
SB-03
9
11/05/17
0.860
14
11/05/17
1.0
8
11/05/17
0.520
SB-04
11
11/05/17
0.650
14
11/05/17
1.1
13
10/17/17
0.140
SB-05
18
10/17/17
0.0015U
33
10/17/17
0.0063
14
10/20/17
0.300
17
10/20/17
0.150
SB-06
19
10/20/17
0.160
28
10/20/17
0.020
34
10/20/17
0.015
13
10/19/17
0.360
16
10/19/17
0.220
SB-07
22
10/19/17
0.0035
26
10/19/17
0.034
36
10/19/17
0.034
9
10/23/17
0.0091
SB-08
18
10/23/17
0.025
28
10/23/17
0.016J
33
10/23/17
0.0095
Notes:
J = the identification of the analyte is acceptable; the reported value is an estimate.
Bold = sample exceeds the ROD remedial goal of 0.0858 mg/kg.
G-5
-------
Soil Vapor and Indoor Air
EPA selected groundwater remedies to address the RAO of preventing inhalation of COC vapors from residential
crawl spaces at concentrations that result in a total excess cancer risk of greater than 1 x 10~6. WSDOT completed
a screening-level evaluation of vapor intrusion risks in the SEIR for the three commercial areas (FMTL, CMTL
and Southgate) using indoor air concentrations modeled from groundwater data collected in 2012. WSDOT also
evaluated vapor risks in the Palermo neighborhood using indoor air and crawl space data collected from 2013
through 2017.
Commercial Areas
As shown in Table G-5, the conservative vapor intrusion screen using groundwater data demonstrated that
commercial/industrial cancer risks for the FMTL and CMTL were less than 1 x 10"6 and less than the noncancer
HI of 1. Results from the Southgate area indicate that using the maximum from shallow or deep wells results in
maximum cancer risk of 4 x 10~6 and maximum HI of 1 due to TCE in deep well MW-ES-02. According to the
draft DGR, if shallow wells at this area are used, groundwater concentrations are below the commercial vapor
intrusion screening levels. To confirm results of the shallow groundwater data, EPA and WSDOT are in the
process of planning for additional vapor intrusion evaluation at the Southgate area using multiple lines of
evidence.
WSDOT conducted a future residential risk evaluation at the three commercial areas (FMTL, CMTL and
Southgate) in the SEIR. Residential risks at all three areas exceed the risk level of 1 x 10~6 or the noncancer HI of
1 (Table G-5) Although use of the areas is anticipated to remain commercial, additional vapor intrusion evaluation
is needed at the day care facility near the CMTL to further evaluate this pathway. Additional vapor intrusion
evaluation is needed at the Southgate area to verify that shallow groundwater does not pose unacceptable risks to
building occupants.
The screening-level vapor risks included in the SEIR were based on 2012 data. September 2017 PCE and TCE
concentrations in these wells are slightly lower than 2012 concentrations used in the SEIR. Therefore, potential
risks and hazards in this area from vapor intrusion would be slightly lower than observed in 2012.
Table G-5: Summary of Maximum Screening-Level Vapor Risk Based on 2012 Well Data
Groundwater
Occupational"
Future Residential"
Area
Concentration (|ig/L)
Cancer Risk
Noncancer HI
Cancer Risk
Noncancer HI
FMTL
Well 109
PCE - 0.5U/0.2U
1 x 10"6
0.4
9 x 106
3
TCE - 13/12
CMTL
Well 111
3
PCE - 0.5U/0.2U
9 x 10"7
0.3
8 x 106
(only at
TCE - 12/6.3
MW-111)
Southgate
Well MW-ES-02
PCE - 0.5U/0.2U
TCE-47/35
4 x 10 6
(4 x 10"7)b
1
(0.032)b
3 x 105
12
Notes:
a. Occupational and residential results as presented in Table 5-9 and Table 5-10 of the 2017 SEIR,
respectively.
b. Using only the maximum shallow well concentrations (MW-ES-06), the risk and HI are lower.
Bold = cancer risk exceeds the ROD target risk level of 1 x 10~6 or the noncancer HI of 1.
/ = value is the September 2017 concentration as presented in Table 2 of the Draft 2017 Annual
Groundwater Monitoring Report.
Palermo Neighborhood
Eight rounds of air monitoring took place in the Palermo neighborhood between spring 2013 and fall 2017. Not
until winter 2017 was TCE detected in indoor air (4.4 |ig/m3) and crawl space air (3.7 |ig/m3) at concentrations
above the ROD remedial goal of 1.46 |ig/m3 and the short-term exposure screening level of 2.0 |ig/m3: this
occurred in only one home (Table G-6). This home was resampled in spring 2017 and the TCE indoor air
G-6
-------
concentration (1.8 |ig/m3) was above the remedial goal but lower than the short-term exposure advisory level;
crawl space air (0.85 |ig/m3) was below the remedial goal and short-term advisory level. WSDOT offered to
install an EPA-approved vapor intrusion mitigation system after the spring 2017 sampling, but the homeowner
declined. This home was resampled in fall 2017; TCE was detected above the ROD remedial goal of 1.46 |ig/m3
and the short-term exposure advisory level of 2.0 |ig/m3 in the air (4.2 |ig/m3) and crawl space (4.8 |ig/m3)
samples. After the fall 2017 results, EPA and WSDOT tried to contact the homeowners in December 2017 and
January 2018 by various methods, including phone calls and a certified mail letter with a summary of the fall
2017 results; in the letter, WSDOT again offered to install a vapor intrusion mitigation system. The homeowners
have not responded to these inquiries.
PCE was detected in indoor air of four other homes at concentrations above the remedial goal of 4.38 |ig/m3.
WSDOT and EPA determined that PCE detected in these homes is likely attributable to indoor sources such as
dry-cleaned clothing, scented candles, air fresheners, craft supplies or other household solvents based on crawl
space air data, soil vapor data, shallow groundwater data and a home building survey.
G-7
-------
Table G-6: Residential Indoor Data (2013 to 2017)
Home Samples
Sample Location
Sample Event
TCE1
PCE1
Indoor | Crawlspace
Indoor | Crawlspace
Mg/m3
HN 43
Spring 2013
No samples collected (declined to participate)
Fall 2013
No samples collected (home being remodeled)
Winter 2014
0.048 U
0.048 U
0.056 U
0.056 U
Summer 2014
0.13
0.16
0.27
0.36
Summer 2015
0.048 U
0.048 U
0.080
0.14
Spring 2016
0.048 U
0.048 U
0.056 U
0.11
Winter 2017
0.048 U
0.048 U
0.073
0.056 U
HN1
Spring 2013
0.048 U
0.048 U
0.23
0.14
Fall 2013
0.048 U
0.048 U
0.27
0.17
Winter 2014
No samples collected (declined to participate)
Summer 2014
No samples collected (declined to participate)
Summer 2015
Neighborhood Zone 1 Home No samples collected (declined to participate)
Spring 2016
Neighborhood Zone 1 Home No samples collected (declined to participate)
Winter 2017
0.048 U
0.048 U
0 J.
0.12
HN 21
Spring 2013
0.15
0.24
0.65
0.056 U
Fall 2013
No samples collected (unable to schedule)
Winter 2014
0.46 | n/a*** | 0.44 | n/a***
Summer 2014
No samples collected (declined to participate)
Summer 2015
Neighborhood Zone 1 Home No samples collected (declined to participate)
Spring 2016
Neighborhood Zone 1 Home No samples collected (declined to participate)
Winter 2017 (March)
Winter 2017 (May)
4.4
3.7
0.35
0.067
1.8
0.85
0.45
0.058
HN 12
Spring 2013
No samples collected (declined to participate)
Fall 2013
No samples collected (declined to participate)
Winter 2014
0.20
0.22
0.049 U
0.049 U
Summer 2014
0.18
0.79
0.047 U
0.047 U
Summer 2015
Neighborhood Zone 1 Home - No samples collected (declined to participate)
Spring 2016
0.19 0.30 0.18 0.059
Winter 2017
0J.9 0.19
0.056 U
0.056 U
HN 44
Spring 2013
0.044 U
0.044 U
0.064
0.052 U
Fall 2013
0.048 U
0.048 U
0.19
0.081
Winter 2014
0.048 U
0.048 U
0.056 U
0.056 U
Summer 2014
0.044 U
0.044 U
0.051 U
0.051 U
Summer 2015
0.048 U
0.054
0.057 U
0.057 U
Spring 2016
0.048 U
0.048 U
0.056 U
0.056 U
Winter 2017
0.048 U
0.048 U
0.056 U
0.056 U
HN 46
Spring 2013
0.053
0.049
2.0
0.053 U
Fall 2013
No samples collected (declined to participate)
Winter 2014
0.059 | 0.052 | 0.28 | 0.047 U
Summer 2014
No samples collected (declined to participate)
Summer 2015
Neighborhood Zone 1 Home No samples collected (declined to participate)
Spring 2016
Neighborhood Zone 1 Home No samples collected (declined to participate)
Winter 2017
0.050 U 0.050 U 0.061 | 0.058 U
HN 9
Spring 2013
No samples collected (declined to participate)
Fall 2013
0.35 | 0.58 | 0.12 | 0.099
Winter 2014
No samples collected (declined to participate)
Summer 2014
No samples collected (declined to participate)
Summer 2015
Neighborhood Zone 1 Home • No samples collected (declined to participate)
Spring 2016
Neighborhood Zone 1 Home No samples collected (declined to participate)
Winter 2017
0.12 0.15 0.082 | 0.054 U
HN 2
Spring 2013
No samples collected (declined to participate)
Fall 2013
No samples collected (declined to participate)
Winter 2014
0.060
0.12
0.062
0.049 U
Summer 2014
0.094
0.53
0.054 U
0.054 U
Summer 2015
0.11
0.62
0.056 U
0.056 U
Spring 2016
0.050 U
0.16
0.077
0.058 U
Winter 2017
0.048 U
0.066
0.19
0.056 U
HN 22
Winter 2017
0.047 U
0.047 U
0.055 U
0.055 U
Ambient Samples
Sample Location
Sample Event
TCE1 1 PCE1
Vg/m3
South end Rainier Avenue
Spring 2013
0.046 U
0.054 U
Fall 2013
0.044 U
0.12
Winter 2014
0.045 U (3)
0.044 U (3)
0.053 U (3)
0.051 U (3)
Summer 2014
0.046 U (3)
0.046 U (3)
0.053 U (3)
0.054 U (3)
Summer 2015
0.045 U
0.053 U
Spring 2016
0.046 U
0.053 U
Winter 2017
0.045 U
0.053 U
G-8
-------
TCE1
PCE1
Sample Location
Sample Event
Indoor | Crawlspace
Indoor | Crawlspace
pg/mJ
Spring 2013
0.046 U
0.056
Fall 2013
0.044 U
0.059
Winter 2014
0.045 U (3)
0.044 U (3)
0.053 U (3)
0.051 U (3)
North end Rainier Avenue
Summer 2014
0.046 U (3)
0.046 U (3)
0.053 U (3)
0.065(3)
Summer 2015
0.045 U
0.053 U
Spring 2016
0.046 U
0.053 U
Winter 2017
0.045 U
0.053 U
Spring 2013
0.046 U
0.054 U
Fall 2013
0.044 U
0.062
Winter 2014
0.045 U (3)
0.044 U (3)
0.053 U (3)
0.051 U (3)
South end Palermo Avenue
Summer 2014
0.046 U {3)
0.046 U (3)
0.053 U (3)
0.054 U (3)
Summer 2015
0.045 U
0.053 U
Spring 2016
0.046 U
0.053 U
Winter 2017
No samples analyzed (samplers were missing on the day they were to be retrieved)
Spring 2013
0.046 U
0.054 U
Fall 2013
0.044 U
0.068
Winter 2014
0.045 U (3)
0.044 U (3)
0.053 U (3)
0.051 U (3)
North end Palermo Avenue
Summer 2014
0.046 U (3)
0.046 U (3)
0.053 U (3)
0.054 U (3)
Summer 2015
0.045 U
0.053 U
Spring 2016
0.046 U
0.053 U
Winter 2017
0.045 U
0.053 U
Spring 2013
0.046 U
0.055
Fall 2013
0.044 U
0.051 U
Winter 2014
0.045 U (3)
0.044 U (3)
0.053 U (3)
0.051 U (3)
East end N Street
Summer 2014
0.046 U (3)
0.046 U (3)
0.053 U (3)
0.054 U (3)
Summer 2015
0.045 U
0.053 U
Spring 2016
0.046 U
0.053 U
Winter 2017
0.057
0.053 U
Notes:
11999 ROD Indoor Air Cleanup Goals (EPA 1999): TCE - 1.46 Mg/m3 and PCE - 4.38
Shaded blue cell indicate the Winter and Spring 2017 sampling event location and analytical results.
Shaded orange cell indicates TCE exceeded the ROD Indoor Air Cleanup Goal.
HN ¦ House Number
U » The compound was not detected at a concentration greater than the reporting limit
J = Estimated concentration
n/a ¦ not applicable
EPA - Environmental Protection Agency
ROD - 1999 Record of Decision
(1) - Primary sample location
(2) ¦ Secondary sample location
(3) » Samples collected over different time periods
Mg/m3 - microgram per cubic meter
b = Indoor air sample collected in the basement of this home
sv » Sub slab soil vapor sample was collected using a 6-Liter Summa Canister with a 30-minute flow controller
* - Crawl space not accessible
** = Slab on-Grade/No Crawl Space. No soil vapor (sv) sample collected
*** - Unable to retrieve deployed sampler
Bold Type indicates the compound was detected at a concentration greater than the reporting limit
G-9
-------
Figure G-l: Conceptual Site Model
z
£
I
.d
Source: Obtained from the 2013 FYR.
"-POSSIBLE
CQHT1NUING
PCESOURCE
TCE
PLUME
PCE
PLUME
WEST
FCRMER
WSDOT
MTL
WSDOT
MTL
iNtHT-i OF
GECTlOftfl
POSSIBLE
VAPOR
JNTRU5/OW
150 —
SOUTHGATE
SHOPPING
CENTER
¦— POSSIBLE
CONTINUING
TCESOURCE
VASHON
RECESSIONAL
OUTWASH
\W5HCN
TILL
TERTIARY
BEDROCK
III
G-10
E.4ST
-------
Figure G-2: Site Detail Map
t Neighborhood Area
- Kgfrfti-
f
/ Southgate Area
¦ >*•'«_ ¦ PZ 725; :g
Seep I -.
Jfi1 • T *
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Testing Laboratory Area
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Lake SG; 1
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r Jmw-103 $
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former WSDOT Materials
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MW-93-02 ®
atsa
rwtf
MW-96-17W5
f.
Source: Draft Data Gap Report. Prepared by GeoEngineers, Inc. for Washington State Department of Transportation. January 2018.
G-ll
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Figure G-3: Approximate PCE and TCE Plume Boundaries
,StS>N
-
mZ '¦/ m
MW-ES-08
0
MW-100 ®
1. The locations c* all features shewn are approximate.
2-ThfedrawingisiOfiFitomiaiionBurpasea.lt
to assist >n stowing features discussed in
GeoEngtfieers, Inc. cannot guarantee the
of electronic files. The master rile is stored by GeoEngmeets, Ine.
and will serve as the official record of this communicaston.
X TW-3 is installed but not operating.
4. Approximate ICE 5 ug/L plume boundary estimated using SurfcM (Golden
Software I 8.0 contouring software using the Natural Neighbor grldding method.
5. Approximate PCE 5 pg/l plume Goundsry iricijdes data
celiected by EPA in 2017 and GeeEnginsers in 2016 and 2017.
Approximate PCE 5 ug/L plume boundary interpreted by EPA.
Data Source: St-eets from Thurston County GIS 2014,
HiiJshade from Thurston County GI5, 2011.
'Source: Provided by EPA on August 18, 2018.
Groundwater seep and identifier
City production well and identifier
City test well and identifier
Stripper tower and identifier
Former city production well and identifier
Former monitoring well and identifier
Direct sensing boring and identifier
Approximate PCE 5 pg/L Plume Boundary
Approximate TCE 5 \ig/L Plume Boundary
Subdrain and treatment lagoon alignment
Palermo Wellfield Superfund Site
GeoEngineersj^
Figure 9
G-12
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Figure G-4: Subdrain and Treatment Lagoon Sampling Locations (2016)
Deschutes
River P< >C
Flow(gprn)
TCEfuxi/U
Flow(gpm)
pcjjusM
tcewl)
flow(gpm)
(Lagoon
effluent)
(M St storm
drain)
Flcw(gpm)
TW-0 9-0,1
Fkw(gpm)
PCE Cmq/L)
tce(w/l)
Flow(gprri)
(Upstream)
(inactive)]
TW.-5
^inactive)!
TW-4T*1
Source: 2016 Semi-annual Groundwater Monitoring Report. Prepared by GeoEngineers. Figure 7.
G-13
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APPENDIX H - ARARs REVIEW
CERCLA Section 121(d)(1) requires that Superfund remedial actions attain "a degree of cleanup of hazardous
substance, pollutants, and contaminants released into the environment and of control of further release at a
minimum which assures protection of human health and the environment." The remedial action must achieve a
level of cleanup that at least attains those requirements that are legally applicable or relevant and appropriate. In
performing the FYR for compliance with ARARs, only those ARARs that address the protectiveness of the
remedy are reviewed.
Groundwater
According to the 1999 ROD, state MTCA and implementing regulations (WAC 173-340) were identified as
applicable for the establishment of cleanup levels for groundwater, surface water, soil and ambient air in Palermo
homes. The 1999 ROD identified MCLs established under the State Safe Drinking Water Act and implementing
regulations (WAC 246-290) as ARARs for groundwater. The state adopted federal MCLs for volatile organic
compounds. The MCLs for PCE and TCE have not changed since the previous Five-Year Review.
Table H-l: Previous and Current ARARs for Groundwater COCs
Current
coc
1999 ROD ARAR (ug/L)a
ARAR (jig/L)
ARAR Change
PCE
5
5
No change
TCE
5
5
No change
Notes:
a. Based on the SWD A primary MCL. Current SDWA standards can be found at
lUtDs://\Yww.CDa.aoY/aroiind-\vatcr-and-dri nkiim-watcr/tablc-rcmilatcd-dri nkiim-watcr-
contaminants (accessed 3/5/2018).
Surface Water
The 1999 ROD remedial goals for surface water were the Washington Clean Water Act and implementing
regulations (WAC 173-220-130) and the National Toxics Rule (40 CFR § 131.36) values for the protection of
human health protection based on ingestion of water and organisms as determined by the National Toxics Rule to
be met within the aeration lagoon. According to the previous FYR, updated MTCA cleanup level concentrations
are not applicable to the Site unless the current ROD-selected remedy is determined to be not protective for the
surface water exposure pathway. If it is concluded that the current remedy is not protective of human health
and/or the environment, then EPA can decide if the remedy (including ARAR revisions) needs to be altered by a
decision document.
Soil ARARs
EPA has not established ARARs for soil.
H-l
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