Five-Year Review Report
Third Five-Year Review Report for Zanesville Well Field Superfund Site City of Zanesville Muskingum County, Ohio
May 2011
PREPARED BY: United States Environmental Protection Agency Region 5 Chicago, Illinois
APprov~ Date: /U S--/7 -/ J Richard Karl Director, Superfund Division United States Environmental Protection Agency Region 5
Table of Contents
List of Acronyms iii Executive Summary iv Five-Year Review Summary Form v I. Introduction 1 II. Site Chronology 2 III. Background 2 Physical Characteristics 2 Land and Resource Use 4 History of Contamination 5 Initial Response 5 Basis for Taking Action 6 IV. Remedial Actions 6 Remedy Selection 6 Remedy Implementation 7 System Operation/Operation and Maintenance 9 Institutional Controls 10 Current Status of Institutional Controls 11 V. Five-Year Review Process 12 Administrative Components 12 Document Review 13 Data Review/Groundwater Monitoring 13 Site Inspection 13 Interviews 14 Community Notification and Involvement 14 VI. Progress Since Last Five-Year Review 15 VII. Technical Assessments 18 Question A: Is the remedy functioning as intended by the decision documents? 18 Question B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action objectives used at the time ofremedy selection still valid? 21 Question C: Has any other information come to light that could call into question the protectiveness ofthe remedy? 23 Technical Assessment Summary 23 VIII. Issues 24 IX. Recommendations and Follow-Up Actions 25 x. Protectiveness Statement 26 XI. Next Review 26
1 Tables Table 1 - Chronology of Site Events 2 Table 2 - Comparison of Clean Up Levels 8 Table 3 -Institutional Controls Summary Table 11 Table 4 -- Status of Recommendations and Follow-Up Actions from the Second Five- Year Review, 2006 16 Table 5 - AS/SVE System Performance 2006-2010 18 Table 6 - Indoor Air Screening Levels for Zanesville Well Field 22 Table 7 -- Comparison of Clean Up Levels forZanesville Well Field 23 Table 8 - Issues 24 Table 9 -- Recommendations and Follow-Up Actions 25
Figures Figure 1 - Site Location 3 Figure 2 - Geological Cross-Section of Zanesville Well Field Site .4
Attachments Attachment 1 -- Site Properties 27 Attachment 2 - Inspection Checklist. 28 Attachment 3 -- Interview Records 42 Attachment 4 - Public Notice 45 Attachment 5 - Photos from Site Visit 46 Attachment 6 - Documents Reviewed 48
11 List of Acronyms
AOC Administrative Order by Consent ARAR Applicable or Relevant and Appropriate Requirements AS Air Sparging AS/SVE Air Spargingl Soil Vapor Extraction CD Consent Decree CERCLA Comprehensive Environmental Response, Compensation, and Liability Act COC Contaminant of Concern CQAP Construction Quality Assurance Plan DCE Dichloroethylene EPA Environmental Protection Agency ERP Enhanced Recovery Plan ESD Explanation of Significant Difference FS Feasibility Study IC Institutional Control IRM Interim Remedial Measure MCl Maximum Contaminant levels NCP National Oil and Hazardous Substances Pollution Contingency Plan O&M Operations and Maintenance PCOR Preliminary Close Out Report QAPP Quality Assurance Project Plan RA Remedial Action RAO Remedial Action Objectives RC Restrictive Covenant RD Remedial Design RD/RA Remedial Designl Remedial Action RI Remedial Investigation RI/FS Remedial Investigationl Feasibility Study ROD Record of Decision RPM Remedial Project Manager SOW Statement of Work SVE Soil Vapor Extraction TCE Trichloroethylene UECA Uniform Environmental Covenants Act UTA/UTC United Technologies Automotive I United Technologies Corporation VOC Volatile Organic Compound ZMWF Zanesville Municipal Well Field
III Executive Summary
The remedy for the Zanesville Well Field Superfund Site (the Site) in Zanesville, Ohio, included excavation of contaminated soils, groundwater monitoring, active groundwater restoration involving groundwater pump and treat, air sparging and in situ soil vapor extraction (SVE). The Site, which has no distinct operable units, achieved construction completion with the signing of the Preliminary Close Out Report (PCOR) on September 30, 1996. The trigger for this Five-Year Review was the signing of the Second Five-Year Review Report on September 27,2006. The last Five-Year Review of the Site in 2006 deferred the determination on whether the cleanup was protecting human health and the environment until an investigation of the vapor intrusion pathway was complete; a study of institutional controls was complete; and a plan to improve the groundwater cleanup was complete. All of these activities are now complete. A protectiveness determination is made in this 2011 Five-Year Review Report.
The study of institutional controls was completed in 2007 and draft restrictive covenants are being reviewed by EPA for implementation on parcels identified as not achieving unlimited use and unrestricted exposure. An Enhanced Recovery Plan to improve the groundwater cleanup was completed in 2006 and its recommendations were implemented in late 2008. In 2010, results from a remedy optimization study recommended by the Enhanced Recovery Plan were presented. The vapor intrusion investigation was conducted from October 2010to February 2011, to determine if organic vapors from contaminated groundwater may impact workers in the warehouse building on-site. Two rounds of data indicate no contamination of indoor air above Site-specific screening levels for the compounds of interest.
The remedy at the Zanesville Well Field Site currently protects human health and the environment in the short term because (1) the soil vapor extraction system is functioning as intended and removing contaminants; (2) the groundwater pump and treat system is functioning as intended to control contaminant migration, and decrease and treat contamination; and (3) a recent review of refined cleanup levels determined that they are protective within EPA's acceptable risk limits. However, in order for the remedy to be protective in the long-term, the following actions need to be taken: implement institutional controls for the Site (including finalizing required subordination agreements to ensure the ICs are maintained, monitored, and enforced); revise the Operation & Maintenance Plan to ensure proper monitoring and long-term stewardship; replace the exhaust tubes to the carbon units on the soil vapor extraction system; and conduct verification sampling in three monitoring wells to ensure long-term protectiveness. Once these actions are taken, the remedial actions at the Site will be protective of human health and the environment in the long-term.
iv Fi Y R s F Site Identification
Site Name (From WasteLAN): Zanesville Well Field Site
EPA 10 (From WasteLAN): OHD980794598
City/County: City of Zanesville, Muskingum County
NPL status: Q ~ Final D Deleted D Other (specify):
Remediation Status (choose all that apply): D Under Construction ~ Operating ~ Complete
Multiple OUs? D Yes ~No Construction Complete date: 09/30/1996
Has the site been put into reuse? ~ Yes D No
Review Status
Lead Agency: United States Environmental ProtectionAgency
Author Name: Michelle Kerr
Author Title: Remedial Project Manager Author Affiliation: US EPA Region 5
Review Period (Start and end dates in WasteLAN): 10/15/2010to OS/27/2011
Date(s) of Inspection: 11/10/2010
Type of Review: ~ Post-SARA D Pre-SARA D NPL-Removal only D Non-NPL Remedial Action Site D NPL StatelTribe-lead DRegional Discretion)
Review Number: 3 (Third)
Triggering Action: Previous Five-Year Review
Triggering Action Date: 09/27/2006
Due Date: 09/27/2011
v Five-Year Review Summary Form, Continued
Issues: Institutional Controls a. 8ased upon the IC evaluation activities, follow-up actions are required to assure that the remedy remains protective. b. Long-term stewardship of the Site must be assured.
Soil Vapor Extraction System a. Exhaust tubes to carbon units are from original system construction and are showing signs of deterioration.
Optimization a. Confirmation of non-detects in residential sentry wells is needed.
Recommendations and Follow-up Actions: Institutional Controls a. Implement enhanced institutional controls for the Site, which includes updated environmental covenants, finalizing the required subordination agreements for the Site, and updating the O&M Plan to include long-term stewardship. b. Complete institutional controls action plan, if needed.
Soil Vapor Extraction System a. Replace exhaust tubes to carbon units.
Optimization a. Conduct verification sampling of well 8-10, 8-8S, and 8-9S.
Protectiveness Statement(s): The remedy at the Zanesville Well Field Site currently protects human health and the environment in the short-term because the soil vapor extraction system is functioning as intended and removing contaminants; the groundwater pump and treat system is functioning as intended to control contaminant migration and decrease and treat contamination; and a recent review of refined cleanup levels determined that they are protective within EPA's acceptable risk limits. Investigation of the vapor intrusion pathway is complete; two rounds of indoor air sampling and six rounds of sub-slab sampling indicate that the remedy also currently protects human health from the vapor intrusion pathway. However, in order for the remedy to be protective in the long-term, the following actions need to be taken: (1) implement effective institutional controls for the Site and revise the Operation & Maintenance Plan to ensure proper monitoring and long-term stewardship; (2) replace the exhaust tubes to the carbon units on the soil vapor extraction system; and (3) conduct verification sampling in three wells to ensure long-term protectiveness. Once these actions are taken, the remedial actions at the Site will be protective of human health and the environment in the long-term.
Other Comments:
None.
VI Fill in the data below:
Date of last Regional review of Human Exposure Indicator (from WasteLAN): May 2011 _ Human Exposure Survey Status (from WasteLAN): HEUC _ Date of last Regional review of Groundwater Migration Indicator (from WasteLAN): 12/20/2010 _ Groundwater Migration Survey Status (from WasteLAN): Contaminated Ground Water Migration Under Control _ Ready for Reuse Determination Status (from WasteLAN): _Planned Complete for 9/30/2013 .
Vll Zanesville Well Field Site City of Zanesville Muskingum County, Ohio Third Five-Year Review
I. Introduction
The purpose of five-year review is to determine whether the remedy at a site is protective of human health and the environment. The methods, findings, and conclusions of reviews are documented in five-year review reports. In addition, five-year review reports identify issues found during the review, if any, and recommendations to address them.
The Agency is preparing this five-year review pursuant to the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) §121 and the National Contingency Plan (NCP). CERCLA §121 states:
Ifthe President selects a remedial action that results in any hazardous substances, pollutants, or contaminants remaining at the site, the President shall review such remedial action no less often than each five years after the initiation ofsuch remedial action to assure that human health and the environment are being protected by the remedial action being implemented. In addition, ifupon such review it is the judgment ofthe President that action is appropriate at such site in accordance with section [104J or [106J, the President shall take or require such action. The President shall report to the Congress a list offacilities for which such review is required, the results ofall such reviews, and any actions taken as a result ofsuch reviews.
The agency interpreted this requirement further in the National Contingency Plan; 40 CFR §300.430(f)(4)(ii) states:
Ifa remedial action is selected that results in hazardous substances, pollutants, or contaminants remaining at the site above levels that allow for unlimited use and unrestricted exposure, the lead agency shall review such action no less often than every five years afterthe initiation ofthe selected remedial action.
The United States Environmental Protection Agency (EPA) Region 5 has conducted a Five Year Review of the remedial actions implemented at the Zanesville Well Field Site in Zanesville, Ohio. The Remedial Project Manager (RPM) conducted this review for the Site from October 2010 through May 2011. This report documents the results of the review. The State Site (Project) Coordinator from Ohio Environmental Protection Agency also participated in the review.
This is the third five-year review for the Zanesville Well Field Site. The triggering action for the review is the signing of the Second Five-Year Review Report on September 27,2006. The five-year review is required because hazardous substances, pollutants, or contaminants currently remain at the Site above levels that allow for unlimited use and unrestricted exposure. The Site has no distinct operable units; therefore, this review takes a Site-wide approach.
1 II. Site Chronology
I .. - Site used for manufacturing purposes 1893 - Present Up to 121 drums containing trichloroethylene (TCE) solvent were Early 1970s disposed of inside a dug well on Site Evidence of TCE contamination at the city of Zanesville's water supply 1981 Interim Remedial Measure to address impacted groundwater July 1983 Site placed on the National Priorities List 09/08/1983 EPA, Ohio EPA and UTA enter an Administrative Order by Consent 08/03/1988 (AOC) to perform a Remedial Investigation/Feasibility Study (RifFS) RifFS approved 07/10/1991 Record ofDecision (ROD) signed 09/30/1991 Consent Decree (CD) to perform the Remedial Design/Remedial (RD/RA) 12/10/1992 entered Final RD Design Document approved 10/18/1995 Construction commenced 10/30/1995 Preliminary Close Out Report signed 09/3/1996 First Five- Year Review Report signed 09/27/2001 Second Five- Year Review Report signed 09/27/2006 Explanation ofSignificant Differences signed 09/13/2010
III. Background
Physical Characteristics
The Zanesville Well Field Site (the Site) is located on the east and west banks of the Muskingum River in the City of Zanesville, Ohio (Figure 1). The east and west banks are connected via groundwater under the river. The Site contains the southern portion of the water well field for the City of Zanesville (the Zanesville Municipal Well Field, ZMWF) and the former United Technologies Automotive, Inc., (UTA) facility, the source of the contamination. The ZMWF covers approximately 72 acres and is on a narrow strip of flood plain on the east bank of the river. The city currently pumps 6.0 million of gallons of water per day from a subset of 12 of the uncontaminated wells in the well field. Four of the city's production wells are not used for the water supply. Two of these wells (wells W-6 and W-12) are still contaminated and are pumped to control the contamination plume as part of the remediation effort. One well that was contaminated (W-7) and one well that was never contaminated (W-8) are no longer being pumped to prevent migration of contamination to the clean wells used for the public water supply. The former UTA facility, now a warehouse/commercial-type building, lies on the west bank of the river directly across from the southern portion of the ZMWF. The former UTA facility and grounds cover an area of approximately 28 acres between the river and Linden Avenue.
The UTA Site is underlain by approximately 64 to 87 feet of unconsolidated deposits consisting of fill material, glacial outwash. and alluvial sediments. The fill, predominantly 2 Site Location Superfund U.S. Environmental Protection Agency
Zanesville Well Field Muskingum County, OH OHD980794598
Site IFigure 11
C_IocIIttRInhU-... till 1 ~ 1~ 1~~"'IIr.J..tI!
3 clay, varies in thickness from zero to 16 feet and is located over much of the property. The thickest fill is predominantly along the eastern edge of the Site. Beneath the fill the unconsolidated sediments consist of clayey alluvium, sand and gravel alluvium, and brown and gray outwash sand. The unconsolidated sediments overlie bedrock, which in the vicinity of the Zanesville Well Field Site, consists predominantly of interbedded shale and mudstone . Figure 2, from the Phase" Remedial Investigation Report (January 5, 1990, Geraghty &Miller, Inc.) below shows more detail of an east-west cross-section, with the western point positioned approximately half way between the northern wall of the former UTA facility and the northern tip of the parcel on the west side of the river.
Figure 2. Geological Cross-Section of Zanesville Well Field Site
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Land and Resource Use
The property formerly occupied by UTA was used for manufacturing purposes since 1893 when American Encaustic Tiling Company, a ceramic products manufacturer, constructed the original buildings. The Site has had several owners since 1893. In 1974, UTA acquired the property from the Essex Corporation and operated at the Site until ownership was transferred to the Lear Corporation. In December 2008, Pelican Land Holdings, LLC, purchased the property. They do not operate on the Site. Three sections of the former facility are currently leased to Blommers Candy, Prime Cuts lawn care, and AdverTECH signs. Residences across Linden Avenue are in close proximity to the former UTA Facility. Future use of the property is
4 restricted by Zanesville zoning code to industrial and commercial activities, and the City does not anticipate any changes to the zoning of the Site. The southern portion of the ZMWF is currently not being used as a source of water. After the restoration of the groundwater, this area of the well field could once again be used. At the time of this review, the City was bUilding a new potable water treatment plant with funding support from the American Recovery and Reinvestment Act. Planned completion is November 2011. With the expansion, the City will be able to treat 10 million gallons of water per day, have eight pressure filters, 1 million gallons of total storage, and switch to sodium hypochlorite (from chlorine gas) for disinfection. The service area has approximately 13,000 connections for 30,000 people.
History of Contamination
Due to the long history and varied usage of the Site, many details of past waste storage and disposal practices are not available. However, it has been established that during American Encaustic's ownership of the Site, a dug well 10 feet in diameter and 40 feet deep was installed. Over the years, the dug well fell into disuse and in the early 1970s the well was backfilled. Rubble from the demolition of a bUilding, as well an estimated 121 drums containing trichloroethylene (TCE) solvents, were disposed of inside the well.
Evidence of TCE contamination at the ZMWF was first observed in July 1981, during a random check for volatile organic compounds (VOCs) by EPA. At that time, TCE was detected in the plant tap at the City of Zanesville's water treatment plant. Three wells in the southern end of the well field were found to be contaminated with TCE and 1,2-dichloroethylene (DCE). In late 1981, the City of Zanesville was anonymously notified of the existence of the abandoned dug well at the UTA Facility, which reportedly contained drums of TCE-based solvents. The abandoned well is approximately 900 feet west of the river and directly across the river from the southern portion of the ZMWF.
Initial Response
In July 1983, UTA installed a groundwater extraction and treatment system at the Site consisting of four groundwater extraction wells and an air stripper as an Interim Remedial Measure to address impacted groundwater. At the same time, UTA removed approximately 121 intact and fragmentary drums and contaminated debris from the old well and closed it. A soil vapor extraction system was implemented in 1985 to supplement the groundwater remediation system.
In September 1983, the Site was placed on the National Priorities List (NPL). In August 1988, EPA, the Ohio EPA and UTA entered into an Administrative Order on Consent (AOC) to perform a Remedial Investigation/Feasibility Study (RifFS). The RI was completed in September 1990 and the FS approved in July 1991. A Record ofDecision (ROD), dated September 30, 1991, documented the remedial actions selected for the Site.
5 Basis for Taking Action
Hazardous substances that have been released at the Site in each media include: .
Soil:
Aluminum Chromium Manganese Zinc Antimony Copper Mercury Barium 1,2-Dichlorethylene (DCE) Trichloroethylene (TCE) Cadmium Lead Vanadium
Groundwater:
Trichloroethylene (TeE) 1,2-Dichlorethylene (DCE)
Exposure to contaminated soil and groundwater are associated with significant human health risks, due to exceedances of EPA's risk management criteria for either the average or the reasonable maximum exposure scenarios. The risk was highest for exposures to groundwater due to the high concentrations of carcinogenic TCE and non-carcinogenic DCE that exceed state and federal Maximum Contaminant Levels (MCLs) for drinking water. Risks from exposure to soils were significant due to the presence of carcinogenic TCE as well as DCE and other non-carcinogenic hazards including high concentrations of lead and mercury.
A preliminary ecological assessment was performed at the Site. The only identified potential environmental exposure pathway to contamination at the Site is through groundwater discharge to the Muskingum River with aquatic life being the receptors. TCE and DCE concentrations in the river were calculated in the risk assessment. The estimated concentrations to which aquatic life could be exposed were well below both federal and state of Ohio standards for protection of aquatic life. Therefore, the risk assessment concluded that TCE and DCE pose minimal potential hazard to aquatic life in the river.
IV. Remedial Actions
Remedy Selection
The ROD (September 3D, 1991) documented the Remedial Action Objectives (RAOs) and chosen remedial actions for the Site. RAOs were developed as a result of data collected during the RI to aid in the development and screening of remedial alternatives to be considered for the ROD. The RAOs for the Site were divided into the following:
1. Contain/capture contaminated groundwater and restore the aquifer by remediating contaminated groundwater to achieve groundwater cleanup levels throughout the contamination plume;
2. Remediate source areas or prevent migration from source areas which cause groundwater to be contaminated in concentrations that exceed ARARs or risk-based levels;
6 3. Remediate soils to prevent contaminant migration to groundwater, or direct contact, ingestion, or inhalation with soils that contain contaminant concentrations in excess of MCLs, ARARs, or risk-based levels; and
4. Prevent inhalation of air that contains contaminant concentrations in excess of ARARs or risk-based levels.
The major components of the remedy selected in the ROD include the following:
1. ContainmenUcapture of contaminated groundwater and restoration of the aquifer to cleanup levels through groundwater pumping; 2. Treatment of contaminated groundwater by air stripping; 3. Treatment of soil and source areas contaminated with VOCs by in-situ soil vapor extraction; and 4. Treatment of soil contaminated with inorganic compounds by soil washing.
The remedial action components also included fence installation, pre-design studies, and yearly evaluation of the groundwater extraction system. In addition, the selected remedy included institutional controls such as property restrictions to control the future use of the UTA facility until soil cleanup standards have been met and to control the use and placement of wells in the affected area until groundwater cleanup levels have been met.
Remedy Implementation
On December 10,1992, a Consent Decree executed between UTA and EPA to perform the Remedial Design/Remedial Action (RD/RA) at the Site was entered by the federal district court.
The RD Work Plan was approved on March 12, 1993. A series of Pre-Design Studies that included groundwater and soil sampling, pilot tests and contaminant transport modeling, were completed from May 1993 until November 1994. The Final Design Document was approved on October 18, 1995. Construction commenced on October 3D, 1995.
Soil cleanup levels for organic chemicals of concern were specified in the ROD with the provision that the actual cleanup concentrations would be calculated once additional Site specific data were collected during the pre-design phase. They were set in the ROD with the provision that EPA may allow new cleanup concentrations to.be calculated for individual chemicals as long as the overall soil cleanup level was met (i.e., contamination did not leach to groundwater above MCLs). During the early stages of the RD, modeling completed during the Rl/FS was repeated with new assumptions, corresponding to new Site specific information (the modeling completed during the RI/FS assumed that the initial concentration of organic contaminants in groundwater contacting contaminated soil was at MCLs; the modeling was repeated with the assumption that groundwater contacting contaminated soil was uncontaminated). The soil cleanup levels for organic chemicals of concern were modified in a letter, dated January 26, 1995, on the basis of this information.
Also modified in the letter were inorganic cleanup levels. The January 26, 1995, letter states that the following documents were used to make modifications: UTA letter, dated November 30, 1993; EPA soil screening guidance, dated December 1994; and the EPA Region 3 risk-
7 based concentration table, fourth quarter 1994. The manganese cleanup level was further modified in a letter dated February 13, 1995, which states the background concentrations of manganese may be higher than the concentrations set in the January 26, 1995, letter. After modification of inorganic cleanup levels for soil, it was estimated that the volume of soil requiring treatment under the modified soil cleanup levels would be less. As a result, treatment of inorganic soil contamination by soil washing was replaced with soil excavation and off-Site disposal of contaminated soil. This change in the soil remedy was approved in a letter, dated April 19, 1995, which approved the 30% Design Report for the Zanesville Well Field Site. The method employed to document the change to the soil cleanup levels for inorganic chemicals of concern and the change from soil washing to excavation and off-Site disposal was insufficient. This issue was addressed September 13, 2010, in an Explanation of Significant Differences (ESD) in a follow-up action to the 2006 Five-Year Review. The ESD included a review of the protectiveness of the refined cleanup levels (Table 2). Note in Table 2 that the units for organic contaminants are different from units for inorganic soil contaminants. The refined cleanup levels remain protective of human health and the environment and eventually will allow unrestricted use and unlimited exposure.
Table 2. Comparison of Cleanup Levels for the Zanesville Well Field
Nov. 1993 May 2010 EPA Proposed Jan. 1995 Feb. 1995 Regional 1991 ROD by Proposed by Proposed by Screening Units and SOW SECOR EPA EPA Levels Barium mglkg 77 13,077 5,500 5,500 15,000 Cadmium mg/kg 4 187 39 '39 70 Copper mg/kg 315 7473 2,900 2,900 3,100 Lead mg/kg 12 500-1QOO 400 400 400 Manganese mglkg 771 18,681 390 1,200 1,800 Mercury mg/kg 3 56 23 23 23 Zinc . ma/ka 1,410 56,044 23000 23,000 23,000 Trichloroethylene . ~g/kg 6.3 -- 70 70 2,800 cis-Dichloroethylene . ~g/kg 34.3 - 980 980 160,000 trans-Dichloroethvlene IJg/kg 59 - 1,400 1,400 150,000
The Inorganic Soil Removal Work Plan portion of the remedial design presented the methodology for completing the inorganic soil excavation. The excavation activities were completed in accordance with the specifications and methods outlined in the plan. The volume of soil to be excavated was estimated to be approximately 304 cubic yards. The actual volume of soil excavated to achieve the inorganic soil clean-up levels was approximately 1,880 cubic yards, close to the estimate in the Final Feasibility Study for the Zanesville Well Field Site (July 12, 1991). Confirmation soil samples indicated that removal of inorganic-impacted soils in excess of the modified soil cleanup levels had been achieved.
• November 2010 US EPA Regional Screening Levels
8 The results of the Preliminary Pre-Design Data Report for the Organic Impacted Soils Investigation did not identify any new source area of volatile organic compounds (VOCs). The only source areas identified were the Drum Storage Area and the northeast corner of the main building. As a result of this conclusion, a shallow soil vapor extraction (SVE) system was designed to focus on the Drum Storage Area and the northeast comer of the main building. The deep SVE system was designed to provide soil vapor extraction from the area of suspected deeper zone impacted soil and to provide for the extraction of vapors produced through operations of the air sparging system. Although not required in the ROD, UTA proposed air sparging (AS) as an enhancement to the required SVE system. An AS/SVE system was designed to remediate the organic-impacted soils and groundwater. A total of 16 soil vapor extraction wells, five nested air sparging wells, 5,500 linear feet of conveyance piping, and the AS/SVE equipment, and equipment enclosure were constructed. The AS/SVE system was completed according to the technical specifications and design drawings presented in the Final Design. Based on the results of the AS/SVE Pilot Testing, the AS/SVE system is expected to achieve the modified cleanup standards.
The groundwater remediation system design was based on the results of groundwater modeling, groundwater sampling and analysis, the historical performance of the interim groundwater extraction and treatment system, and the results of the AS/SVE pilot test that was performed. The four existing groundwater extraction wells were incorporated into the final groundwater remediation system, as were two contaminated production wells for the ZMWF. Three outfalls discharge to the Muskingum River, and the effluent meets the substantive requirements of a National Pollutant Discharge Elimination Permit in Ohio. Two of the outfalls are located on the east bank of the river and discharge water from the municipal wells, and the other is on the west bank of the river, discharging effluent from the air stripper. No discharge standards were exceeded in the review period. Although the data used to monitor the groundwater remediation system are trending toward achieving tfle cleanup standards specified in the ROD, the groundwater remediation system has not met the goal of rapid restoration of the aquifer. The most recent modeling from UTA's 2002 Enhanced Recovery Plan suggests that the time to achieve cleanup standards is approximately 25 years (from 2002) .
Construction activities at the Site were consistent with the ROD and all work plans. A Quality Assurance Project Plan (QAPP) was approved on March 12, 1993, for all pre-design studies. All sample collection and analytical activities were conducted in accordance with the approved QAPP. The Construction Quality Assurance Plan (CQAP) was approved on October 12,1995. Remedial Action (RA) work was conducted with EPA oversight. All construction activities were conducted in accordance with the approved CQAP.
System Operation/Operation and Maintenance
UTA is conducting long-term monitoring and maintenance activities according to the Operation and Maintenance (O&M) Plan.
The primary activities associated with the O&M include the following: 1. Inspection of conditions of groundwater monitoring wells, air sparging, SVE wells and groundwater extraction wells;
9 2. Environmental monitoring: biennial and yearly monitoring of the groundwater conditions; and 3. Maintenance on remediation systems: air sparge system, SVE system, and groundwater pump and treat system.
These activities are ongoing at the Site. No unusual problems or incidents of vandalism or trespassing were reported during the current review period . In 2008, when the property was sold to Pelican Land Holdings LLC, work was begun to install new electrical feeds for United Technologies Corp. (UTC) to separate their usage and billing from the new owner. This work was completed in 2010. Maintenance on the remedial systems was routine during the review period . In 2008, a knockout tank in the SVE system was refabricated. During the summer of 2010, maintenance to abate poison ivy on the way to Outfall 1 on the western slope to the riverbank was done. Mineral build up on the air stripper is removed monthly by acid treatment. Due to corrosion over time from these acids, maintenance on the building adjacent to the air stripper is planned. Carbon for the SVE system is changed routinely based on sampling of the discharge air stream, and maintenance is performed on this system monthly. The exhaust hoses to the carbon units are old and showing signs of deterioration; replacement is planned during the next carbon change - approximately June 2011. During the review period all monitoring wells were renumbered for consistency, and corresponding changes were made in UTC's database. This caused a delay in reporting during 2010, but it has been corrected to date.
The remedy for the Site is meant to remove inorganic soil contamination and treat organic contamination of soil and groundwater. Observations indicate that the SVE and groundwater pump and treat systems are functioning as designed, that monitoring wells are well maintained, and O&M buildings are clean, neat, and labeled. O&M at this Site appears to be functional, well run, and effective at running the remedy. Maintaining these systems is critical to the remedy continuing progress to meet cleanup goals, which ensure protection of human health and the environment. .
According to information provided by UTC, annual O&M costs for this Site are approximately $280,000, exclusive of EPA oversight costs ($59,000 annual average 2007-2011) and special projects such as the vapor intrusion investigation.
Institutional Controls
Institutional controls (ICs) are non-engineered instruments, such as administrative and legal controls, that help to minimize the potential for exposure to contamination and that protect the integrity of the remedy. ICs are required to assure long-term protectiveness for any areas which do not allow for unlimited use or unrestricted exposure (UU/UE).
The ROD requires ICs to be implemented during remediation to assure protection until a health-based cleanup has been achieved . Section 111.8 of the Statement of Work (SOW), Appendix 8 of the Consent Decree, sets forth the following requirements for ICs at the Site: "[UTA] shall implement the deed restrictions in Attachment I to prohibit the use of contaminated groundwater underlying the UTA facility, the adjacent railroad and the City of Zanesville Well Field until groundwater performance standards are met; to prohibit disturbance of the UTA facility until soil performance standards have been met; and to prohibit interference with remedial action components." Attachment 1 to the SOW was intended to set forth specific
10 land and groundwater use restrictions forthe Site to be developed by UTA. Cleanup goals for soil were based on residential use. For groundwater, cleanup goals were based on drinking water standards.
Attachment 1 identifies properties that do not support unlimited use and unrestricted exposure. Table 3 below summarizes ICs for these areas.
Table 3. Institutional Controls Summary Table Media, Engineered Controls, & Areas IC Objective Title of Institutional Control that Do Not Support UUlUE Based on Instrument Implemented Current Conditions. (note If planned) UTA Facility owned byPelican Land Prohibit residential use, Declaration of Restrictions on Use Holdings, LLC ("Pelican'?; formerly owned prohibit use of groundwater of Real Property was in book 1072. by Lear Corporation EEDS & Interiors flk/a until standards are met, County recorder's office on United Technologies Automotive lnc.; prohibit interference with the 12/24/92. Parcel # 8536017000) remedy components or any aspect of work to be Environmental covenant per the • Soil - Area of soil treated to industrial performed. UECA - under review by EPA- to cleanup standards in the portion of ~e UTA be recorded by UTC. parcel north of the building. - Groundwater- current area that exceeds groundwater cleanup standards is covered by the UTA and ZMWF parcels. City ofZanesville Well Field owned by the Prohibit residential use, Declaration of Restrictions on Use City· (Southern Portion ofParcel prohibit use of groundwater of Real Property was in book 1083. #8460101000;known as "Zanesville Well (except as allowed by the County recorder's office on 9/9/93. Field Parcel'? remedy) until standards are met; prohibit interference with -- Groundwater- current area that exceeds remedy components or any Environment Covenant per the groundwater cleanup standards is covered by aspect of work to be UECA - under review by EPA- to the UTA and ZMWF parcels, oerformed. be recorded by UTC. A portion ofthe parcel between the Site Prohibit residential use, and the Muskingum River owned by prohibit consumptive use of Genesee & Wyoming Inc., formerly owned groundwater until standards Environment Covenant per the by Norwalk & Western Railroad and have been met ; UECA - under review by EPA- to known as "Railroad Parcel'? prohibit interference with be recorded by UTC. remedy components or any aspect ofwork to be performed.
Maps which depict the current conditions of the site and areas which do not allow for UU/UE will be developed as part of the IC evaluation activities.
Current Status of Institutional Controls
In a letter to EPA, dated January 11, 1993, UTA stated, "a certified copy of the Consent Decree, an access agreement on behalf of United Technologies Automotive, Inc., and the Declaration of Restriction on Use of Real Property were recorded with the Muskingum County Recorder on December 23, 1992." Since 1992, significant changes have occurred that warranted a study of les at the Site. The State of Ohio enacted the Ohio Uniform Environmental Covenants Act (UECA) in December 2004, which allows the creation of environmental covenants that run with the land and are enforceable by a third party, in this case, EPA. See ORC §§ 5301.80 - 5301.92. Properly drafted UECA covenants will ensure that the restrictions are enforceable and run with the land help to ensure long-term Site stewardship. The UECA specifically provides that an owner of property may enter into a restrictive covenant and also be a "holder" of the covenant, with the right to enforce it against a
11 third party even after it sells the property. Also, a plan for long-term stewardship of the Site is needed to ensure effective ICs are maintained, monitored and enforced.
In addition, the extent of residual soil and groundwater contamination at the Site has changed since UTA recorded a declaration of restrictions in 1992 because of the implementation of the cleanup remedy. Therefore, EPA requested UTA to conduct a study of the ICs for the Site. The IC study evaluated the existing proprietary controls and encumbrances at the Site, evaluated and described areas not meeting soil or groundwater standards that require ICs, proposed draft environmental covenants consistent with the UECA, and proposed modifications to the Operation and Maintenance Plan for routine monitoring of compliance with use restrictions in restricted areas of the Site. The IC study was completed in May 2007.
Based on the IC study, UTA and EPA planned, but have not completed, the steps necessary to ensure that effective les are implemented and maintained. The plan includes implementation actions, progress reporting, and monitoring to ensure that effective ICs are maintained for the Site as well as planning for long-term stewardship.
Long-Term Stewardship: Long-term protectiveness at the Site requires compliance with use restrictions to assure the remedy continues to function as intended. To assure proper maintenance and monitoring and effective ICs, long term stewardship procedures will be reviewed and a plan developed. The plan will call for regular inspection of ICs at the Site and certification to EPA that the required ICs are in place and effective. Additionally, development of a communications plan and a one-call system should be explored for long term stewardship, until all cleanup standards are achieved to allow for UU/UE.
Current Compliance: Based on inspections and interviews, EPA is not aware of Site or media uses which are inconsistent with the stated objectives of the currently implemented or subsequently planned ICs. ICs currently in place meet restrictions called for in the ROD and Site use is consistent with these restrictions so that no exposures are occurring. Planned ICs expand the area covered and enhance long-term stewardship by conforming to Ohio's UECA. The remedy appears to be functioning as intended.
v. Five-Year Review Process
Administrative Components
The Zanesville Well Field Third Five-Year Review team included Michelle Kerr, EPA's Remedial Project Manager for the Site and Michael D. Sherron, Ohio EPA's Site Coordinator for the Site. An update of the Administrative Record was completed in September 2010, and an update of the community information repository was completed in October 2010. EPA notified Ohio EPA, EPA Site Attorney, EPA Community Involvement Coordinator, Region 5 Five-Year Review Coordinator, UTA's Project Manager, and a representative of the property owner in an October 15, 2010, letter that the five-year review process had begun. A public notice was placed in the April 3, 2011 edition of the Zanesville Times Recorder. The Ohio EPA Site Coordinator, the EPA Site Attorney, and the Region 5 Five-Year Review Coordinator were provided a draft of this Five-Year Review in Spring 2011. Their comments have been incorporated into this report. In addition, UTA provided information that has been incorporated into this report. This final report has been completed in May 2011. It will be followed by
12 distribution to stakeholders, the community information repository, and a short public notice summarizing the review in the Zanesville Times Recorder.
Document Review
This Five-Year Review considered relevant documents including: the Site's ROD, the Statement of WorK for the Remedial Design and Remedial Action WorK Plan, the First Five Year Review Report, the Second Five Year Review Report, Remedial Action Construction Report, O&M Plan, the Explanation ofSignificant Differences (ESD), groundwater monitoring data 2006-2010, SVE system data 2006-2010, and discharge data 2006-2010. Applicable groundwater cleanup standards, as listed in the ROD and ESD were reviewed. RAOs were obtained from the ROD.
Data Review/Groundwater Monitoring
Groundwater monitoring has been conducted at the Site since the early 1980s. In general, the highest concentrations of contamination were observed during the first few years of the initial response (1983 to 1986). The TCE plume is located in the upper and middle portions of the Muskingum River Buried Valley Aquifer. On the UTA Facility side of the river, the highest concentrations of TCE are in the upper aquifer, while on the ZMWF side, the highest concentrations of TCE are in the middle portion of the aquifer. Trends show that TCE and total DCE are decreasing in nearly all of the wells (40 of 46 wells statistically analyzed). For the first half of 2010 monitoring period, 43% of the 75 groundwater samples had no TCE or DCE above laboratory detection limits. Results for TCE above the MCl were reported for 21 well locations and for DCE above the MCl for two locations. All wells with contaminants above MCl are Within capture zones of the interceptor wells on the Site or the city containment wells.
Methods to better demonstrate the capture of the target contaminant plume at W-12 were identified during the review of the Enhanced Recovery Plan (ERP), and have been implemented.
Air stripper and AS/SVE system performance reports, groundwater VOC reports for the interceptor wells and the city wells, and discharge reports are provided to EPA on a monthly basis. Review of data in these reports confirms the general trend of decreasing VOC concentrations over time. Additional documents consulted for data review included the Remedial Action Construction Report for confirmatory soil sampling, and the Vapor Intrusion WorK Plan, Sub-slab soil Gas and Indoor Air Sampling Results ofDecember 10, 2010, and Sub-slab soil Gas and Indoor Air Sampling Results ofApril 5, 2011 for soil gas and indoor air data.
Site Inspection
A Site inspection was conducted on November 10, 2010. Areas of concern at both the UTA Facility and the ZMWF were inspected with EPA Remedial Project Manager Michelle Kerr, Ohio EPA Site Coordinator, Michael D. Sherron, and John Mcinnes of Stantec, UTA's contractor. A Five-Year Review Site Inspection Checklist was used as part of the inspection and is contained in Attachment 2. All monitoring and interceptor wells, discharge points, and system buildings were inspected. No significant issues have been identified regarding the
13 condition of the groundwater extraction wells, groundwater monitoring wells, air sparging wells, the SVE wells, or the fence.
On October 8,2010, EPA RPM visited, organized, and updated the local Site repository at the Muskingum County Library, EPA updated the repository in July and October 2010, and updated the administrative record index in September 2010. The local Site repository files are in order.
Interviews
There has been low community interest in this Site as demonstrated by the fact that neither the RPM nor the CIC has been contacted by the community in the past five years. In addition, no community members responded to the Five-Year Review public notice that invited readers to contact the CIC or the RPM for more information on the Five-Year Review process. Therefore, no interviews were conducted with the public. However, two interviews were conducted with stakeholders. The Water Superintendent for the City of Zanesville Water Department was interviewed on November 10, 2010, at the City's drinking water treatment plant. Renovation of the plant, treatment technologies, contacts with UTA's contractor, plant capacity and service area , and pumping volumes were discussed. The Director and Zoning Administrator from the City of Zanesville Community Development Department and the Executive Director of Muskingum County Port Authority were interviewed in a group-format also on November 10, 2010, at City Hall. Reuse and zoning of the UTA facility were discussed. Additional details are available in the Interview Records in Attachment 3.
Community Notification and Involvement
The Comprehensive Five- Year Review Guidance states that the community should be notified when a Five-Year Review is being conducted. In accordance with guidance, a public notice was placed by EPA in the Sunday, April 3, 2011 edition of the Zanesville Times Recorder announcing the Five-Year Review. A copy of the public notice is located in Attachment 4. The public notice described the Zanesville Well Field Site, stated that a Five-Year Review of the cleanup was being conducted by EPA, and that the public could participate in the process. No comments were received in response to the public notice. EPA will provide the public with a notice of completion of this Five-Year Review. In addition, a copy of the completed 2011 Third Five-Year Review Report will be sent to the local Site repository.
14 VI. Progress Since Last Five-Year Review
This is the Third Five-Year Review for the Site. The First Five-Year Review determined the remedy would be protective after the cleanup levels were achieved for both groundwater and soil. The Second Five-Year Review deferred a determination on whether the remedy was protective until information was obtained on the vapor intrusion pathway, a study of institutional controls was completed, and a plan to improve the groundwater cleanup was completed. These activities are complete. A protectiveness determination is made in this Five-Year Review Report. Most follow up actions from the Second Five-Year Review are complete, and one is underway.
15 Ta bl e 4- Sta tusofRecommend af Ions andFIIo ow-UAf,p C Ionsf rom thSe econd FIve- Y ear Revew, I 2006 Issue Recommendationsl Party Completion Issues Action Number Follow-up Actions Responsible Date ERP completed, revised groundwater Monitoring monitoring plan network not ERP to be 9/2002, presented, ERP 1a clearly completed and UTA 3/2007, implementation demonstrating implemented. 1/2010 reported in containment Remedial System Optimization Report Rapid restoration of ERP to be ERP completed, 9/2002, 1b groundwater completed and UTA implementation 1/2010 aquifer not implemented. reported in RSOR achieved Determine and Proper 2 complete proper EPA ESD completed 9/2010 documentation documentation Vapor Study to be 3 Intrusion UTA Study completed 4/2011 completed pathway Study to be Effectiveness completed and 4a of institutional UTA Study completed 5/2007 follow-up actions controls. implemented. Long-term Complete IC Action 4b EPA Incomplete stewardship Plan -- Steps will be taken Direct access in order to prevent Locked fencing, 5a to discharge direct contact with UTA signage placed 3/2008 points water discharging restricting access from wells Steps will be taken Well head platforms Direct access in order to prevent replaced with new 5b to W-6 and interference with UTA platforms and 3/2007 W-7 well pumps on W-6 ladders that lock to and W-12 prevent access
1a) In March 2007, a revised groundwater monitoring plan for the Site was presented to EPA. A table describing pumping rates for all four interceptor wells was added to the semi-annual groundwater reports beginning in 2009, and well 8-10 was sampled during the second half of 2009. Results from 8-10 were 309 ~g/L in 2007 and non-detect in 2009. This information
16 indicates containment of the contaminant plume. However, an additional two rounds of sampling well 8-10 are recommended to confirm the non-detect results. Additionally, due to the location of wells 8-8S and 8-9S and the concern for vapor intrusion in nearby residential properties, two rounds of monitoring are recommended for these wells. The intermediate and deep wells in the 8-8 and 8-9 set show consistent non-detects for TCE and DCE since at least June 2007.
1b) The ERP was completed in 2002 and implemented during winter 2008-2009. The ERP entailed increasing pumping at the interceptor wells and decreasing at the recovery wells on the east bank W-6 and W-12 wells. Results of the implementation were presented to EPA in the 2010 Remedial System Optimization Report (RSOR) with recommendations to maintain the current pumping regime, due to a marginal acceleration in overall remediation time, in order to minimize potential risk of contamination of city wells.
2) Producing an ESD in 2010 required a review of Site decision documents, site history, and a current evaluation of cleanup levels. It had the intended effect of properly documenting the 1995 changes to cleanup levels. All refined cleanup levels are protective of human health and the environment based on current information and science.
3) The results of the vapor intrusion pathway investigation, implemented in 2010-2011, allowed Site decision makers to conclude, based on multiple lines of evidence, that the pathway is complete but no contaminants of concern exceed risk-based screening levels for indoor air. Site-specific screening levels based on an industrial worker exposure scenario were developed for TCE, DCE, and vinyl chloride. UTC began sampling sub-slab soil gas in August 2008, completing six rounds through February 2011. Some sub-slab sampling points exceeded screening levels for TCE beginning in 2009, so indoor air samples were collected in the early fall of 2010 and late winter of 2011. After two rounds of sampling, no indoor air results were above screening levels. A physical building survey was also conducted during the investigation and contributed to the evidence used to make the assessment. Now that data collection is finished, follow up actions with UTC to complete the vapor intrusion investigation are planned. This includes communicating results to the property owner and lessee(s) and adding a statement to a deed notice about potential vapor intrusion.
4a and 4b) The IC Study completed in 2007 was effective to review current encumbrances on Site parcels and generate revised draft ICs for implementation on affected parcels. The next step is for the follow up actions to be taken, which include implementing and monitoring additionallCs.
5a and 5b) The steps taken in 2008 to prevent direct access to the discharge points along the Muskingum River and the municipal wellheads are effective. Locked fencing restricts access to the discharge points from the banks, and signs warn boaters to keep clear of the discharges. The wellhead platforms were removed and replaced with new steel platforms and locking ladders with steel plates to prevent access to the wellhead.
17 VII. Technical Assessments
Question A: Is the remedy functioning as intended by the decision documents?
Yes, the review of documents, ARARs, risk assumptions, and the results of the Site inspection indicates that the remedy is functioning as intended by the ROD. Systems are operating normally, and regular O&M has been maintaining the effectiveness of the remedy. According to UTA, no unusual costs were incurred during the reporting period of this review, and neither they nor EPA sees any early indicators of potential issues of concern. Opportunities for remedy optimization have been considered, tested, and evaluated over the past nine years, and are discussed below. Implementation of additional institutional controls is needed for the remedy to be protective in the long-term. This is discussed further below.
Soil
Soil excavation minimized the migration of inorganic contaminants to groundwater.and surface water, and prevents direct contact with, inhalation, or ingestion of inorganic contaminants in soil. The AS/SVE system is removing volatile organics from the soil and groundwater. The AS/SVE system is expected to achieve the clean-up standards. Table 4 below summarizes the amount of VOCs removed by the SVE system during the review period.
Table 5. ASISVE System Performance 2006-2010
Units = Pounds Shallow Mixed Shallow Silty Deep Sand SVE Total Fill SVE Sand SVE '2006 159.1 485.5 337.0 981.6 2007 106.0 69.6 448.3 623.9 2008 20.8 11.3 360.8 392.9 2009 31.0 34.6 325.5 391.1 2010 106.7 41.9 241.8 390.4
Groundwater
The groundwater pump and treat system did not achieve cleanup standards within the rapid timeframe predicted by an early groundwater model, but is removing contamination from the area, with decreasing levels of contamination documented in a majority of wells. The groundwater remediation, originally expected to be complete within 10 years, is now estimated to take an additional 20 years using the current remediation system. Although initial models of the groundwater remediation system indicated that a rapid restoration was possible (four years for the ZMWF side of the river and ten years for the UTA side), projections from the ERP suggest that the initial timeframe was grossly underestimated. The underestimation may have occurred due to an underestimation of the source term in the original model, or overestimation of contaminant extraction, or more simply, the inadequacies of model algorithms of that era.
Because there was no significant decrease in TCE and DCE concentration levels over a two year consecutive period, an ERP was required. The ERP identified a conceptual approach for accelerating the remediation of the ZMWF side of the Site through optimization of groundwater extraction and for improvement of groundwater monitoring. The remedial system optimization 18 approach is intended to adjust extraction well rates to maximize capture on Site and mitigate potential migration to the City of Zanesville public water supply well field. In general, the optimization procedure consisted of minimizing extraction on the east side of the Muskingum River (wells W-6 and W-12) while maintaining current maximum extraction on the west side of the Muskingum River (Site interceptor wells 1-1, 1-2, 1-3 and 1-4). Field-testing of five different pumping scenarios was completed by December 2008 and UTA submitted a report to EPA analyzing results in January 2010. The essential observation by UTA was that capture of target zones was maintained in all scenarios, but in some scenarios, the margin of safety between the well field divide and the impacted groundwater was reduced, with relatively minimal « 8 years) acceleration of remediation. 8ased on this observation and additional information on system operations and Site hydraulic conditions generated by field-testing the ERP, UTA recommended maintaining normal extraction rates and current safety margins.
Improvements to groundwater monitoring were needed and implemented so that the current monitoring network fully demonstrates containment of the target contaminants TCE and DCE. Specific steps taken to document lines of evidence included reporting pumping rates in the semi-annual groundwater reports, running statistics on previous and current groundwater monitoring data, checking groundwater level data points against field sheets, implementing the ERP, implementing a revised groundwater monitoring plan, showing that interceptor wells are pumping continuously, and sampling well 8-10 in the second quarter of 2009. The revised groundwater monitoring plan has been implemented and the results of the enhanced groundwater elevation monitoring and analysis are presented in the Semi-Annual Reports for the second half of 2007 and the first half of 2008. The monitoring program has confirmed with multiple lines of evidence that the area of vac impact is contained by the groundwater pumping wells.
Regarding well 8-10, results from 8-10 were 309IJg/L ofVaCs in 2007 and non-detect in 2009. This information indicates containment of the contaminant plume. However, an additional one or two rounds of sampling well 8-10 are recommended to confirm the non detect results. Additionally, due to the sentry-like location of wells 8-8S and 8-9S and the potential concern for vapor intrusion, two rounds of monitoring are recommended for these wells . The intermediate and deep wells in the-B-8 and 8-9 set show consistent non-detects for TCE and DCE since at least June 2007.
An IC Study was submitted for review by EPA to ensure long-term protectiveness. Long-term protectiveness will not be achieved until groundwater cleanup standards are met and effective ICs are implemented, monitored maintained and enforced. Long-term protectiveness also requires compliance with effective ICs which will be ensured by implementing, monitoring, maintaining and enforcing them as well as maintaining the site remedy components. Long term stewardship must be ensured to verify compliance with ICs. To that end, an IC Plan can address revised and updated ICs.
Institutional Controls les are required at the Site because the groundwater remedy has not yet achieved full protectiveness necessary for UU/UE. The remaining levels of contaminants in soil do not allow for UU/UE; however, the Site soils currently meet standards for commercial/industrial use.
19 EPA investigated the vapor intrusion pathway, and based on the results, the proposed ICs do not require modification.
In an effort to ensure long-term protectiveness for the remedy, existing institutional controls will be enhanced at the Site. This entails expanding the area covered by existing ICs and recording covenants consistent with Ohio's UECA. Affected properties are depicted in Attachment 1. The second Five-Year Review recommended an IC study to evaluate the existing proprietary controls and encumbrances at the Site, evaluate and describe areas not meeting soil or groundwater standards that require ICs, propose draft environmental covenants consistent with the recently enacted Ohio UECA, O.R.C. §§ 5301.80 -5301.92, and propose modifications to the Operation and Maintenance Plan for routine monitoring of compliance with use restrictions in restricted areas of the Site. On September 14,2006, EPA requested that UTC conduct an IC Study. UTC submitted the IC study to EPA on May 15, 2007. The study evaluated the existing proprietary controls and encumbrances at the Site, evaluated and described areas not meeting soil or groundwater standards that require ICs, proposed draft environmental covenants consistent with the UECA, and proposed modifications to the Operation and Maintenance Plan to ensure long-term stewardship. EPA reviewed the study, and the suggested steps are being taken to ensure effective institutional controls for the Site are implemented, monitored, enforced, and maintained. EPA agreed with the approach suggested by the PRPs and has been working with them to get work underway as is described further below.
As part of the IC study, UTC noted that several ICs has been recorded for the Site, However, among other issues, they did not encompass all the areas nor include all the required objectives. UTC submitted draft environmental covenants for the three parcels that comprise the Site: (1) a parcel formerly owned by Lear that was recently acquired by Pelican Land Holdings, LLC (Pelican); (2) a parcel owned by Ohio Central Railroad (Railroad); and (3) a parcel owned by the City of Zanesville (City). Also , encumbrances identified during the title search which might impact the ICs include: Industrial Gas Corporation known as National Gas & Oil Cooperative (National) which is a holder of a Grant of Right of Way. A subordination agreement for that parcel has been completed and is under review.
Revised environmental covenants, consistent with UECA, must be recorded for all three of these parcels, and subordination agreements must be obtained for two of the three parcels. Draft environmental covenants and subordination agreements were submitted to EPA for approval. Once the covenants and subordination agreements were approved, UTC began working to get the environmental covenants and subordination agreements executed and recorded. During the course of UTC's efforts and correspondence in 2009-2010 with EPA, EPA determined that one of the subordination agreements for Pelican parcel was not needed. The other Pelican parcel subordination agreement and the restrictive covenant was revised and delivered to EPA in 2010 for review, along with UTC's request for direction and assistance from EPA with getting restrictive covenants for the Railroad and City parcels recorded. To address long-term management of potential risk from the vapor intrusion pathway, a brief statement of the issue and 2011 study findings may be appropriate to include in any deed or title transfer notices for the UTA parcel. Full implementation of ICs and subordination agreements is anticipated in 2012 . ICs must be implemented to ensure that the remedy functions as intended.
20 Current Compliance: Based on the Site inspection and data reviewed, EPA is not aware of Site or media uses that are inconsistent with the objectives of the ICs and cleanup goals. Long-term protectiveness requires compliance with and monitoring of effective ICs.
Long-Term Stewardship: Long-term protectiveness at the Site requires compliance with ICs to assure the remedy continues to function as intended. To assure proper maintenance, monitoring, and enforcement of effective ICs, effective long-term stewardship procedures will be reviewed and the O&M plan will be revised. The plan will include a provision for regular inspection of ICs at the Site and periodic (e.g., annual) certification to EPA that the required ICs are in place and effective.
Question B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action objectives used at the time ofremedy selection still valid?
Yes. There have been no changes in the physical conditions of the Site that would affect the protectiveness of the remedy. Land uses on both sides of the river have not changed and expected uses of both properties have not changed since the selection of the remedy. RAGs described in Section V. of this report 'are still valid and steady progress to reach those RAGs is being made. No new contaminants or sources have been identified or are indicated at the Site.
Exposure Assumptions
Exposure assumptions and pathways evaluated during the remedy selection are still valid, however vapor intrusion was not considered during the remedy selection. TCE and DCE, which are volatile organic chemicals (VOCs), contaminated soil and groundwater in close proximity to an existing commercial/industrial building. VOCs from soil and groundwater in proximity to buildings have been known to vaporize and enter buildings through cracks, spaces, or by permeating through the foundation materials of those buildings. VOCs discovered in close proximity to a building is sufficient information to trigger an additional investigation as prescribed in the 2002 US EPA OSWER Draft Guidance for Evaluating the Vapor Intrusion to Indoor AirPathway from Groundwater and Soils.
This pathway was evaluated to ensure the remedy is comprehensive and protective. Sub-slab soil gas samples were collected by UTC. When sub-slab screening levels were exceeded, EPA directed UTC to take indoor air samples. In total, UTC completed two rounds of sampling of indoor air and six rounds of sub-slab soil gas sampling. For this vapor intrusion investigation, COCs include TCE, cis-DCE, trans-DCE, and vinyl chloride. Chronic and acute screening levels for the Site are based on an industrial worker exposure scenario and 2010 toxicity data. The Site-specific sub-slab soil gas screening level for TCE was set at 6,100 IJg/m3forthe same scenario using an updated toxicity value and a 1 in 10,000 excess lifetime cancer risk. The following screening levels1 for indoor air are based on an industrial/commercial worker exposure assumption of eight hours per day for 250 days per year for 25 years:
1 Calculated from Risk Assessment Guidance for Superfund Part F using current slope factors or reference doses in the May 2010 Regional Screening Level Tables. 21 Ta ble 6- I n door A"Ir ScreenmgLI eve s Jor Zanesvi"II e We II F"IeId Screening Level Acute (Lifetime Cancer risk of 1 Chronic (Lifetime Cancer risk 3 in 10,000 or Hazard Index of 3) of 1 in 100,000 or Hazard index Units = J,lg/m of 1) Trichloroethylene 610 61 cis-1,2-Dichloroethylene 465 154 trans-1,2- 796 265 Dichloroethylene Vinyl chloride 310 31
Despite exceedances of screening levels for sub-slab soil gas at four different points over approximately three and a half years, results for indoor air from October 8, 2010, and February 9, 2011, show COC levels below Site-specific screening levels. EPA recommends working with UTC to communicate the results of the study to the current and future property owner(s) and lessee(s) and adding a notice in title transfers about potential vapor intrusion. These actions are part of the follow up activities of the vapor intrusion investigation.
Toxicity Data
Toxicity data of parent contaminants (TCE & DCE) have been updated. The Integrated Risk Information System (IRIS) assessments for cis- and trans-1 ,2-dichloroethene were both updated in September 2010 . TCE is currently being updated and will be publicly available by December 2011 . The most current values for both compounds were used for setting Site specific screening levels for the vapor intrusion investigation (Table 5).
Toxicity data of inorganic chemicals of concern, except copper, have been updated since the 1991 ROD. The IRIS assessments for cancer and non-cancer risk for barium, cadmium, lead, manganese, mercury, and zinc have been updated, primarily during 1998-2005. As part of the 2010 ESD, a new risk evaluation was completed on all contaminates of concern, using the most current values. Site risk is still within EPA's acceptable range; therefore, none of these updates affect the protectiveness of the remedy. See Table 6 and below.
Cleanup Levels
Cleanup levels for groundwater have not changed, are still consistent with National Primary Drinking Water Standards, and are consequently considered still protective.
Soil cleanup levels were modified during the initial stages of the RD, and fall into two categories: risk-based and leaching-based. The ROD provides soil cleanup levels for TCE and DCE based upon potential for leaching into groundwater at levels higher than the MCLs. Modeling that took place during the RD utilized assumptions reflective of Site conditions and allowed for less stringent cleanup levels while still satisfying RAOs. New cleanup levels were issued in a letter, dated January 26, 1995. These modified criteria for organic COCs are consistent with the intentions of the ROD and are considered protective of the environment. Inorganic chemicals of concern fall into the risk-based category. ROD soil cleanup levels for 22 inorganic COCs at the Site were determined based on a risk calculation. At the time, this risk calculation and change in inorganic cleanup levels was not documented sufficiently. The appropriate documentation (an ESD) for the modification of the soil cleanup levels was completed in order to provide the additional information needed to make a protectiveness determination. Table 6 below describes current cleanup levels for the Site and compares them to current screening levels, which are set by EPA and are protective of human health and the environment. Cleanup levels for the Site are more stringent than current health-based screening levels.
Table 7 - Comparison of Cleanup Levels for the Zanesville Well Field
Current Health-Based Current 1991 ROD Screening Cleanup Units and SOW Levels Levels Barium mg/kg 77 15,000 5,500 Cadmium mglkg 4 70 39 Copper mg/kg 315 3,100 2,900 Lead mg/kg 12 400 400 Manganese mglkg 771 1,800 1,200 Mercury mglkg 3 23 23 Zinc . mg/kg 1,410 23,000 23,000 Trichloroethylene . IJg/kg 6.3 2,800 70 cis-Dichloroethylene . IJg/kg 34.3 160,000 980 trans-Dichloroethylene IJg/kg 59 150,000 1,400
Question C: Has any other information come to light that could call into question the protectiveness ofthe remedy?
No other information, such as previously unidentified ecological risks or natural disaster impacts, has become known that could call into question the protectiveness of the remedy.
Technical Assessment Summary
According to the data reviewed and the Site inspection, the remedy is functioning as intended. However, rapid restoration of the groundwater aquifer, a goal of the ROD, has not been achieved. Restoration of the groundwater aquifer using the current remediation system has been estimated to take an additional 20 years.
RAOs and exposure pathways are still valid. The vapor intrusion exposure pathway was identified as needing evaluation in the 2006 Five-year Review. This evaluation is now complete. Adequate documentation is now provided in Site records supporting the decision to
• November 2010 EPA Regional Screening Levels. Note different units.
23 revise the soil cleanup levels. Based on this documentation, refined soil cleanup levels have been determined to be protective.
VIII. Issues Table 8 - Issues Affects Current Affects Future Issue Issues Protectiveness Protectiveness Number (YIN) (YIN) Based upon the IC evaluation activities, follow-up 1a actions are required to assure that the remedy N Y remains protective. 1b Long-term stewardship of the site must be assured. N y Soil vapor extraction exhaust tubes to carbon units 2 N y are from original system. Confirmation of non-detects in residential sentry 3 N y wells is needed.
Also, groundwater reports could be optimized. This issue does not affect the protectiveness of the remedy, but represents an opportunity for more efficiency at the Site. UTC is expected to present ideas on how reporting for the Site can be streamlined and to work together with EPA to identify any areas for improvement.
24 IX. Recommendations and Follow-Up Actions
Table 9 - Recommendations and Follow-Up Actions
Affects Party Mile- Protectiveness Issue Recommendationsl Oversight Issues Responsi- stone (YIN) Number Follow-up Actions Agency ble Date Cur- Future rent Based upon Implement updated the IC ICs for the Site evaluation including any activities, changes to title follow-up notices and 1a actions are UTC EPA 10/2011 N Y subordination required to agreements, and assure that the update 0 & M Plan to remedy include long-term remains stewardship. protective. Long-term stewardship of Complete IC action 1b EPA EPA 12/2012 N Y the site must plan, if needed. be assured. Soil vapor extraction exhaust tubes Replace exhaust 2 to carbon units UTC EPA 6/2011 N Y tubes to carbon units. are from original system. Confirmation of Conduct verification non-detects in sampling of well B- 3 residential UTC EPA 6/2012 N Y 10, B-8S and B-9S. sentry wells is needed.
25 X. Protectiveness Statement
The remedy at the Zanesville Well Field Site currently protects human health and the environment in the short-term because the soil vapor extraction system is functioning as intended and removing contaminants, the groundwater pump and treat system is functioning as intended to control contaminant migration and decrease and treat contamination, and a recent review of refined cleanup levels determined that they are protective within EPA's acceptable risk limits. The vapor intrusion pathway investigation has been completed, and two rounds of indoor air sampling and six rounds of sub-slab sampling indicate that the remedy also currently protects human health from the vapor intrusion pathway. However, in order for the remedy to be protective in the long-term, the following actions need to be taken: implement enhanced institutional controls for the Site and revise the O&M Plan to ensure proper monitoring, replace the exhaust tubes to the carbon units on the soil vapor extraction system, and conduct verification sampling in three wells to ensure long-term protectiveness. Once these actions are taken, the remedial actions at the Site will be protective of human health and the environment in the long-term.
XI. Next Review
The next five-year review for the Zanesville Well Field Site is required by May 2016, five years from the signature date of this Third Five-Year Review.
26
Attachment 1 - Site Properties
Institutional Control (IC] Review Superfund Sil p. B:Js e M;;p U. S. Environmental Protection Agency
zanesville Well Field Muskingum County.OH OHD980794598
Legend o UTABullding lanesVille Wet FlElld e->alby8__
us I!PAR!o;Ion~an:fJ1Ulll APM: Sam Clnlmmar I
27
Attachment 2 - Inspection Checklist
Site Inspection Checklist
L SITE INFORMATION Sfte.oame: Dale ofDJspenlon:
Remedy tndudell: (Oleck .lIlIlhBlllppl)' .Li,ndfillcoYeJlconlainmel1t _Monitored natural auenuauon :c ess conrrols • OroundwlIter con1aiDmesrt stitUlioooJ conUols • Venical burrierwuJls ~• rolll1llwuter pump andtm!lment _Sudxe WtUef (ollec:cion lind teeatmem SOtber "til y~ ~~rro ..~
Attaehmenl5: _ Inspectionteam rQll;ler UJse~ .Site mapattached
1. O&l'tf sItemanager_- 2. O&MstatJ 1»-~ Name rflle lmer'lie\\o\1ld@)1 s1le .aloffice _by phone Phone DO. _ Problems. suggc-stions: • Report lln,cl.ed _ Site IIIspecuonChecklist· I 28 3. Local regnta!l)"" autborities and I't'SPOI\lll! &geDdes (i.e.•State and TriboJ offlces, emergency response office, police depilJtment, office of public healthOf environmental heaUh. zoningoffice. rcoordB of deeds, Of 04bcr cily and oouncy uff.ces.l:1c.) Fill in till Ihal apply. 4tr:i:~ Agency -ill] ContAlct ,J)I;J ~~ .111"/~,(J t1 Nnme Til Date PIIODC 00. " Problems; $uggC5I iOl1S~rt ~,~hed A"OCY~~I~ COL1 IlJCl )ik,~,ry~ \\}1ol,v -t'iO' ~5~ ' C(, Name TIlle Dale Ptlom: no. Problems; SU88estions~n lIuac:1Jed : ~:~~ u...~ )I<~...I.. ~ ~o.~;S .ci~) Name Tille Dale PhotIC no. ProblenlS; s Ui8est i OO5~ rt auacbed . - .. - Agency ~~ 5t:ll~ Contact . \M.A "'~~fW ~ cls o r~.'iS) , 4O ~" Name l'nJc Date Phone nn.. Problems; S Ll88est I Ol ~ Repo It aIl3Ctled 4. OtlJer interviews Coptionll)) .Rrport attached. () , l ~r~ ~k-. .Lll( tl t~."J Ic.L .. .:Jltt {~ ~ . iATtt. . I I ~\.v. ~4~ SUtl e..«: t ~l~ . ~1i•.'i ~K ~ ....1Jb Sjre Impcct.ion Checklist . 2 29 JII. ONoSJTEDOCUMENTS" RF£ORDS VERIFIED (Check oJ! that nppl)') (}) (~~m \'\1(, .. Mmanual ~eadil)' available _Upto dale .N1A buill drawings ~e.adiIY a~if.able _Up10date .NlA • OIinlenance togs eadily avaibble 6lJp to date .NJA marQ ( f) Site-Specilil:Htlalth and Safd)' Pla~~ro _Readily IIVlloilable .Up to dace • Nt" .--- @:onlingoncy plan/emergency respotl plOin ~3d i~)' OIvailable @Jptodale .NlA Re,ua.b 0'" ...... Jv-# . . ~ ~adi]Y available .NlA (f1--'"'l. ~~d~~'~~ i1j!i! to dale 4. Penmts and Serrice A&reemeots • Airdischargep«mit • Readilyimlilablc .Up to dace .N/A ~ffhlent-disctltree ------.Aeadtly·a:...silable- - ltUp-todaae .NIA-- .W3S1edi<>posa!. POIW .R£adilyavailable .Up to date .NIA .Other permits .1U'Bdily availuble .Up to dlltc .N1A Remilrks ...~A ~ - -l ~ ..lJft:£;~ 5. Gas Generalbld Records .Readilyavaila.ble .Up todate @ RemOlb ..~ ~ -- _ . ~.- - -- 7 6- Seltlement MoolIIIImt R;ITtrd5 . k .ReadiLy available .Uptodnle -. iiN1i\ ; Remurb ~ if« 5Lr "i. Groundw.tcr MonJloring Re(lO~L .i.Ji)::OOilYavailable .Up IOdate .NJA Remarks ,r'-.. ~ A. • ~ • 8. Leacha1eExtrudoa Records .Readily available .Up to dale c;N/~ Remn.rlcs - .. ( Discblll'ge Complilnce ltecords 9 .Air • Readily aYailable • Up to dale .NJA @Vate, (effl uent) ~lldilY available l8lJplo dace .NlA Remn.rlcs . 1110 I OlIif)' ArcessISKDrily Lop • Readily available .Up to dare cyJA ( :Y Remora Sile Inspection Cbeckllsc • 3 30 rv, Q8cM COSTS 0&./\01 Organizalicm .state in·house .c.Of'lUOlll;lot for S'3le ..... L '~ .PRP in·house @On.lr3CUlt for PRP - ~ • Federal Facility in-bouse• Col1ttactor for Federal Focility .Other ~__~ From To .B~ali:down attaelM:d Date: D V. ACCESS AND JNmnmONAL CONTROI(f • Applicable""\N'A A. Fencing B. Other AcCIKll Rtttridions Slem nd other secant}' meJ}SPJe'S .Location shown on 5jE~ map Remark.... t/ 6\1..- Site lrupection Checklist· 4 31 C. Institu.tlonal Controls (IClO} I. Implement.tion Inti enforcement Sitecondit ions imply IC:,> nOl properly implemented .Yes .N.~'A SicecoBditions imply lCs not being fuUy cnrorc~ • Yes .No IA Type ofmonitoring (~.& .• sclf·n:pming, drh'e by) Freqm:rn;y Responsible ~lty/agency Ccmtaet Name Tide Dale Phone no. Reponifl3 is Up.IO-4n.te • Yes .No ,~ Reports lI1C verified b)'the !cadagency .Yes .No • A SpecifIC requireme.nlS indeedor decubondocuments h~\Ie beenmet • Yes .No Violntionll ha..oe beenreported • Yes .No ~r'ANlA Other problems or suggestions: • Report ollaclled d* Lv! d 'L1iYJiI ~-tM~ ~): - 2. Adequaqr • leI. areadequlIJe ~/t.- .N/A Remarks [;1¢"s =X1 I \. D~ne,..) r VlUlda'~d _.LocJion slIown on site map '&0 \InndnlismC\lickfll Remarks "oc i M') 2. Land URI changes on site • NIA t RemllTtS \AA.i\..l ~ t ... .1- .l ... 3. Land ose chaqe5 off 5ke ~ Rcma.r1s ~ . . . VI. CENERAl. SITE CONDIT1ONS \ ~oads 1·4PuCo.ble .N/A ~ation Sbownc:,Bi~ l. RoadB damaaed",,~ : L _r:Jo~~ adequDlc .N/A RcmMb ." • ... I.b _A<, -~ ,...... oil ...J. lA l ~ ,.. l'l.::lt~ . I '(J SitelBspecclon Checklist · 5 32 B. OtherSite Conditions .. Remarks . - ..- " ... /--\ .. VlL LANDFILLCOVERS • Appl~abt{ • NIt)..- } - ./ <. .'!-. La~~nl' _Surf.aee ~...... , (Low ' ....l • LocJltion soownon sit-e map .Scetl.cmem not evrdent AreaJ extent Depth moru -_. _.- .. 2: - i1l.Da11ion sboWh 01'!llie map .Cracti~ nole\1itteN $ Widths Depths Remarks '...... <, 3. Erosion .I,.ocatjoo soown on siremap • Erosion not evidcna Areal extent <. nq,th Rt:moru <, <, 4. ({iJlcs .~sbown on she map • Holes rIOt evldenl Areal ellrenl Depth .. Remub <, <, <, 5. Vegetative CO"" .Gmss .CoVCl' estabJisbcd .No signsof stress .TrecslShrubs (indi~.c size tlDd Io<:alicms On A diagram) Remarks <, <, 6. AiterD:ll11veCover (anoored !'Ott, c~ncrete,elc.) .N/A Rema.rb <, <, 7. Bal&es d,OCllticm sbown!»1 site mllp .BuIge' ...."<, Areal extem He.lghc Remarb '\. Site ImpeclDon ~ckllst ~ 6 33 ~ Wei ArnsIW3ler Iklm fj,e • Wet arns!water dal11llgc fUJt evident • Wet areas .IAC:WQIl shownon site mllp Arc.11 e,lCtenl • Ponding • Location ShOWB on site nUlp Anal exeent \ .Seeps • Locationshown on site PUlp Areal extent \~~ subgrade .Locution shownon site map ArC'~J eXCCn! wks 9. ~1o~lbillty • Slides • Locutionshownon sne map .No evidence of slope instability Areale t Remarks\. "\ 8. _.. ~Ii I. Fi~5 B)'p;lSS '& ndl ", • Locution shovmon site map .N/A Of okay Renl;lrks \. -p-- .. . 2. Bellc:h Bretc:hed \ .Loc:Uioo SOOWfl Of! site'l~ap • N/A oroby Remarks '\ 3. Bmch Overtopped .~onshoW1l on site map .N1A or eta)' Remarks \. C. LeJdo_ Cho..... o AppHcohl. oN/A ~ (CballJlCllincd with erosion contrul mats. riprnp. bags, or gabions Ihat descend down tile steep side slope or the cover WId will allow che ruouf( Wl1te" c; cctcd by the benchesto moveoffof the I.mdflll covet wltboutcreating erosion gullies.) J. Sctlh:meDt • Loc4Ition shewn On sne rna~"'-.. • No evidenceofscttlemcm Ate.tl ext~U Depth . Remarks -. '\, 2. Material Dfgradation • Locution soown on she map .No~:ceof dcgradalion MareriallytJe Area.l e:llleni Remarks '\. 3. Erosion .Location shiOwn on si.te map .No evidence O~O!lion Arc~~1 extent Depth , Remarks ", Silt Inspection Cbeckl5si • 1 34 , • Location shown on site l1llIp • No c'L'idcf\CC of undercuuinll Arcatextent Depth 4\r--·Remarks 5. ~~mns • No obstructions .Lo tion shownTypeon site map AmaI extent Size Re.mar~ \. I 6, _ vev~G",odl 1)pe .No e'L'idence excessi..oe growth • Vegetillion in Is docs notobstruct flow .Locatloo shown sitemap Areal extenl Remarks \.. .•.. - -- D. Cover Peaeb'atlons • Appll~le .N/A l. G..V_ ~"'" .... . - .Properly secured11ocked.Fu ioning • R.o.ulinel)' llll.mp~d .0000 oondition • Evidence of lcalmge4C pcnc:t!at • Needs Maintenance .NfA Remarks _ \. 2. ~ •Go...... Pooped)' sccuredl10ckcd • Functioning RGutinel)' sampled .Good condition .Evidence of leakage 4. Ltecbate ExtncdoD W~Ds , .Properly secu~ked ."u1lClioDing .ao..,.." .....~~OOOd,,,,Ii". • Evidenceof leakageat penetration .Needs Malnrenan .NJA Remark:,. '- S. Settlement Monomeo15 • Located • Routinel)' slIfVcycd "'"• NIA RClJ1llrks ", ~, Sim Inspection ~klist - 8 35 Eo GillS CMtectlon and Treltmen1 .Appllcable _N/A I . Gas Trea1ment FacilitHs '. .flaring • ThermnI de.s11't,lC\ion • Collection for fWlIC .Oood ool'ldilion • Needs MaitllellaDCe marts 2. ~~d" W..... M...... PIp'... .0 ndilion _ Neros Mo.intcnaDCc I«marb '\ 3. Ga, MouI~""(~~:: ...... nnori..01.....cent bomesoe oo;Id;..s] .Good ctmditio Needs Malllleil3,l)Ce . N/A R.etlla:rk.~ \. F. CO~'ef' Dram.ae lAyer -, • Applicablt .N/A I . Oolktl'ip"Jnsp«Md • f\lQ~[iQRi llg ,N/A Rc!marks -. -, 2. ODd~ Rock Inspected ~nctioning .N/A R,c·marks '\ G. DmntionlScdimenla1ion I'uJlllb .Appl~1e .N/A I. SiltalionAreaJ exte:1l1 De'hth .N/A • SI113tion ootevidefll Remarks -, -, 2.- BrosIon Areal elltellt Depth "- • Erosionnotevident Remllrks -.-, 3. Oodet WOI'U • FWlCliooing .NfA Rcmnrks -.-, 4. Dam • Functioning .NfA ReJnllrks -, " SiteInspectionChecklist· 9 36 ~. Retaining Wal"" • Applicable .N/A 1 ~_&M • Location ~wn on site map .Deformation nOI evident HorizonlllldisplacelJlCnt Vertical displacement RolationoJ displlWCmclII marks 2. ~lItion • Locationshown on site mop • Degradation not evident Re:mIlr ~ -, L Pel"itnmr Dilc~.sileDischarge • Applicable .N/A L Sib.tion ~rioD shown map .SillarLoD not eVida\l Arettl wetenl = Remarks -, -, 2. Vegetallve GrowIh .~~'iIIIl onsile mnp .NJA .VCiJ:taliPJU1oc5not..impcd~ Ill) ______._-_._- .._---- Areal eltent. 'f Remarks -'\. "- 3. Erosion .LocationshoWfl o ~ map .ErosIon oot e... l~ Areal extent DqnJI Remarks -, '\. 4. DiKharge SInJdun: • functioning .JIIIA Remarks -. "- VIIL VERTICAL BARRIER WALL..~ .App~able .N/A L Sec~ement .Location s!Jo..... n 00 site map .seLtJe~k)t evident Areal extent Depth Rem:arks \. 2. PerfOI"llllUkll Moailoringiype of mcmitoring .Perfotmance BOt monllOfed F'requ~rxy • Evidenceofbreaclling Head diffi:rcntial Remarks -.<, Site lmpcction C1Lecklist - 10 37 asWER No. 9JH.1-0JIJ.P IX. GROllNDWAnRJ5ti1lFACE WATER RiMED a ~/A l. I. r.1111:1B. .... 1!J1!drimI G Needa f¥lmilllmance Z. 5.,.....Wa4...C~..~ V.lva, V...... :udI 01 r ApputCQHCN G QOOII colld.don G Needt. Milnrc:p~ Jlemllllal~ ~ ~~ _ 3. SptIre hrfsu4Iq_lpallat GR.enwIII'''ReldiJJawilaWr· C Goad eamtiIiun -_--10bt proyidecl _ L~ ~ ~~Y1VJ'&--, l ~ ~~~(~~~~""4fJ.~~(vc.-*)~J (J.1...l,- ~av--; .v:"",r~ (-",-.oJ.) .:- \,,\" . 1..~ • AI'.) ~t W~ ~t:l-( . ~sk. ~II'-~ .... ~~~ . ~~~~.~ ~ c..v-:.\'.7~~~.\\\~ AAfkJ \Jo)l~,,". 4(.. ~ ~~~.,. , &,8tt~~lt~ . ~..v A. ~~ tv('~ ;.ts c!2~t .u.r~I!> . ~'~l~~~- 1).11 38 C. Treatment System (' .Applic .N/A I. Treatment Tntn (Checkcomponents that apply) .Metals removal .00tJwa.1er separation • Biorcmediation (jAiT strippiDg .Carbon adgorbers .Fi[tcrs'-- ~ _ .Addilivc {eo g., chelationagent. flocculent) _ .Odlers, --:--:-:- _ • Good condition • Needs Mnintenllncc (j6I111lpJjng portsproperly markedandfunctiooal • • SampHlIglmaintenance log displnyed and up to date _ ,,.... ~ t ~ iPmen. properl)' ldeotified mit)'of groundwater "eared 3.l1nl,l"I1)' _ • Quafdit)'or surface water ~ ann y-~~.f4---:--- 4Eemarks;__~!!l..t:~~W~/:6I!LlQQ,~.su:~~.::z£j~~~~U~~-"'lf"""-- z. IUecU'b1 Enc~nd P8DCb (properly ntod Slid functional) _. ~~~~m _ ~ ;~tta_DJ1_DC-e-----~- .. __ -- 3. Tanu. Vaults, SPt.rage ,tMSels ~.. ~ood C4.,ndi.lion~per .N/ARemarks secondary comainmclll _ 4. 5. Treatment B.. II~(8' .<"..,., .NJA 'c,ooooroDdition (esp.. root andOOOT'Wa)'s) tsJ:hem~ls andequipment p~ty store416- ~ ~marts, _ 6. Moaitoriog Wells (pump and treatment r:; ~tySClC1lJ'CdJloctcci~uncti~g • u(indy sampled C;C~~:~lired wells IoCltc:a-' ~ccds inteNlnC1: ~r1C5,"T"-·or_---T""t__-=-.._------=__:___=_fr--..,.._I_--__:__.::::~ Nl.J D. Monitorina Dim I. Monitoring Da1a . .Is routinct,.. tubmitted OD time • of a.c~~3b~ qualil)' Z. MonllOfing d;sta suggests: )fOundwatet plume ks effecti't'd)' comaiced Dtaminant conccntraliolls liredeclining Site InspecuonClIccklist - II 39 It. Monitored Natural Attenuation to -- Wells Inaturalaucnuationremedy) • ~ly sec ~~t1ins • Rooaillflly sampled .Good ~ndicion • AU required wc:lts lOl:i.L,ed iii Need1 ~c .NJA Remuks ---...... X. O'I'HHR REMEDIES If there are remedies applied at the site whichare DOt ooveled ~bove. attach an inspection wetdescribing tbe pbysiC1lI natureand condition ofan)' fucility associa.ted withthe remedy. Allcxamp!ewouldbesoil vaporatraction, St.... /Y\,jAJ~ l')'voO ~~' Xl. OVERALL OBSERVATIONS , A. Implement.tlon of too Remedy - Describeissaesand observatioosreLnting to whether~medy is effecct\Oe aoo functioniog as desillil!lea::- BesOt witha brief statementofwhat(beremedy is 1.0 ace \te., (0 contain conllllminllJltplume. minimi:r.e infiltratiooand gllS emission. tIC.). ,:n:::4 ~~~~j~~~':-t:.it) ~ Srrt + ~ pc'...... , ... Ntd LA k+°ah"'",*Ad...,wd, O~ ~~'* ...... i ~ 5 wttl-L'1t 0 4-18 bv.:.y.''''¥''~¥ ~~'~, , O~ B. Adequacyor . .. Dcsmbc: imlcs .nd observations related to the implcmentntioD and scopeof O&.M proceduteso In ~;O~g§?~~ ;\I.. ~..,4. Sir.e Illspection Checkliit ~ L2 40 C. Barly Indicaton orPOlential ItGrMdy Problems Describe issues aRd observations suchas unexpec1ed changesin thecosc or scopeor O&M or a bigh ficqucot'y ofUJlS(tleduled repairs. lhat suggesllhal.he prorec:ti"cDtSS ofthe remedy maybe comprumised in the future. N~ ~r;;;:tw... D. Opporlunille8 for Oplimizadoo .... po"ibleoppmwo~i<5~"'~ I>=rib< .. Of die_.'ion ofthc remody. _... . -_.... =;~~==:;;~~~ Sire I~[lo~ Cilecklisl- t3 41 Attachment 3 - Interview Records INTERVIEW RECORD Orpnimdoa: TeIepboDe Nac FuNot E·N.UAddress: \, o-t\.. . \a.. e", ~l. • ~ SUID II'Y or Coavenation StanIM III 871<1 Guion Rbold 5lbe S Ind'atl.lpCf1511i1 ~ Tel (31r,l8J6.el15 F~l : (Ill) II764ll82 CtIl(ll rt 294-9167 fohnmem~ 42 INTERVIEW RECORD SiteName: :cw~ EPAIDNo.1 ~(\;t S"~ SUbject: 1M "l .t.. .-#\ 1",\t..w;~') Time: rl l IJ>ate: l'\'\)\ 10) T,pe: 9 Tdt:pbone ~ 9 Othc:r 9 Jncomina 9cmtgoiRi Loclltion ofVisit: c.~ ~ \\~ ~ ,..\v\ '-~ ~ ~,w Contact Made B)': ~~jM .~ Name: ...~~ (. '1 0", ofP- ~ ITille: Orwlllnization: ~J~ }~ '- .(.o""""1 <, IndJ\lklU81 Contacted: Name: ITIdE: Oqlll_lion: ~ Telqbone No: ¥\~ sum Addn:&lA FuNo: CltJ.State. ZIp; E-Mail Addnss: Summary Of ConV~l'SlItlOD 'u.; ~ ~ . cr--1~ I~v:~ ~c.. ' , \...... ~: .(.: """ .... fiAS~ ~u~ p J ftIIe,: ~'.~ '"'l~ ")c.. ~~~~~-t.~~~~t~ ~"", f ....\v...... ~ p"~ ~ : ()~~ ~~,""\.~ "6> .....4"..... ~~ Jb '~~ ~ '. ~ ...... l_~··...r...t)' -1..) ~~f.,...tL.~(~; J:~ et,;~ i~ I i~ ~ ~~~,e---> (...I "'r-' ...-...., ..h..-)Ah~, ~ ~~~ ~ ~ ~-i''''''' ~ ' . ~\.r Aa.l>~ ~v.i -ll. ~r~ ,-h:.J.y...... p't; / ~...... ~~ ...~.ID'to.:.o ~....: h'-b A.wk...... ~- ~,..Ju\ ~ ~ ""'~ \v .~\-.tr-.-. c; '"'t. , f'A)'. "~l ,. ~~ . '>tIA ..~~~. t~i.~~ ~~C.1~"" ;..LJ) .:--- ~ L ~I Ar.'¥4-''''- - 0_ t~..a-d 'b ~~.ltLM~ ~_i.\I'.AA (~) . ~ ·t ~~ ~ ~ J ~ tNW .~~"""* .V\L .~\,~ " b "l.~ I\\"t ~ e-~: c.'~',> \")t~ ~~"""",,,i.~"'" 'i~ Ci&d. ~ '\- ~ 'Ooot. -~~-6 f"~~ ' .!'\\ ~ fC'\~.J ~ ~..v. -, ~-\- Iv ~ ~.... ~~.\ -\t.N"~ . ~ 4c-o. u, !~·.N.~~ 'II ~9+oU'~? ~c.~_\'-~ ~J .AI" "''4 '~'~' ~b2tt~ . ~t,; tAl.-. ~~1. ''i>I~/~') : NlJ ~ : ~.,..shL.L ...s ".fJ ~ ~~. '- (~ : W,J,h,~ C ~ ~ k ~~.Ih 1~-4 I \-.".. ~"Uf\ ~ ~ ~ ~ ~. yJ.l~ ~ aA~, PII 101--1.- TH E e ll'Y Of ~ ...... 0,.." ...... Mike Jacoby, C&:D STACY A. CLAPP EucuIIve DWc10r D~r.ck.,( ComlTlUfit)' DeYelopnlQnl DepHnment 2~ NClICIl RIlaI Stm1 740-t5S-0'7W ~purlCXllll 740-~9977 CeU 43 INTERVIEW RECORD ContactMDde By: ~_ In.d.iridual Contorted: Tille: OI'gllnization: Telepboae No: Slnet Address: 'uNo: <"lty.SU_. Zip: E-Mail Address: fz>uA Summary Of Conversation "'IJ ~\fJ.." L~~ .~ . ~ iwdl4 ~\..Jc- i-~~"""' <&.~ ~ ·',·1.- .....,, ·~r I q>iPa,I"2..)i ~ ~~ S~ @ ...... (,~~~I~ to, ·II:''1IIS ;It",r~IY< .:lD ~~:.... ~. ~~ f',fN> ~ 1 SCr/o'QA- ~.JtA- ~ ~ '':>~ ~ . ~ \' ~ ~V04~. I.&. ~~ ·t 1tA.c1\ ..vd1 '~ ~~. ~~ ~-,.<,W 2DiLO\'*'''~R\Ls iW~'oM~ ~ l~ ~) I ~v..-- ~f6e~ .k. ~~ t4(')) I ~~o'n.\, ~ ~-\o "'r'ii. ~l>\I),-'lJW-~ \v~ VI~ v..o:.. ~ #., ~\,~ ~. U ~ ~ lc... w ~ U/l~ ~Q..b Q.Al ~~ · lb .... ciJ.,v.~ . '5OO~\\"2P\-c....Je... ~~IM. TOIf.-.,.. ~~ ~ r.tJ", w viJf ~~ ~,,",,. NWrW .4.v.>,-~",,~~:~ "-k.) ~ ~ ~~. bJ 1~~ ~t,.k'r-Iepw-n'" (tt.-l/ ~ 1Jtn'I~~ \oJ'~ot.v . ~.l-1.wdk~~~~' Paae 1 or-l-. Cill' (J( z~.WI), CU;lU o.-/l8J:'1I'lC'fi1 (II p~ Sdf~I';1.' Paul E. Mills 1~~lo?J $!Jp,"InIi""~1 fAW, ES U. "" {NQ} .(SS-{11fiGOfl.1;c W 44 Attachment 4 - Public Notice SundlJ, April!. 2QlI I 38 Glz-ntloo..::.-.~"'---...-' nous ~PrH~Ioll"",.,It~.""~"''''tao_1JloWo:lrtul 8'l,IIIIIftda. UlUJllRJN 1b:·lhto)'tlIIl:"O:-iulItIJ1lC!IU;' ... I'1I ..HI1anr.-.. buoa 0l!P:I; .....-.-q-_ ¥bDII1 NlIM. /I1"-xarr ~b'IIlI_~ 1a:oediliJ~~ UM~ 31~1 -~~p ~ Vtia...,,~011n-lIto1.r....il ~l.'OU::!l) :IOp,." ~ of U\R.-.oI _ 'l'l'w._1Dw&.cwe-ILM4 A1llIe1h18 taw from e bank1ti3 mng hiju:dtoogOOd to ~ up. WIth btl ~paymentS. Oe!libla tetma. ~ ~~ snell !lllme-day cr~C«l8. nOW'S the Ume to ge'l1Il81 fW!NI cr uaedcstortruck Y'Oll'w been wa'q for: ,t\p;J/yanl:ho. 0# pull t'rlg }'OIo4l'neo-.t l,J.il.liIll1lk. lm3bank. 45 Attachment 5 - Photos from Site Visit Municipal wellhead. 6/15/10. Discharge point to Muskingim River, looking west. 6/15/10. Air stripper tower, exterior and interior ofbuilding. 6/15/10 and 11/10/1O. 46 Carbon unit on soil vapor extraction system. 6/15/10 and 11/10/10. Soil vapor extraction system, interior ofbuilding. 11/10.10. Former United Technologies warehouse, looking north. 6/15/1 O. 47 Attachment 6 - List of Documents Reviewed Geraghty & Miller, Inc. (1990). Phase II Remedial Investigation Report, Zanesville Well Field Site. SECOR International Inc. (1996). Remedial Action Construction Report for Zanesville Well Field Site. SECOR International Inc. (2002). Enhanced Recovery Plan for Zanesville Well Field Site. Stantec Consulting Corp. (2006). December Discharge Monitoring Reports for Zanesville Well Field Site. Stantec Consulting Corp . (2007). December Discharge Monitoring Reports for Zanesville Well Field Site. Stantec Consulting Corp. (2007). First and Second HalfGroundwater Monitoring Reports for the Zanesville Well Field Site. Stantec Consulting Corp . (2008). December Discharge Monitoring Reports for Zanesville Well Field Site. Stantec Consulting Corp. (2008). First and Second HalfGroundwater Monitoring Reporst for the Zanesville Well Field Site. Stantec Consulting Corp. (2009). December Discharge Monitoring Reports for Zanesville Well Field Site. Stantec Consulting Corp . (2009). First and Second HalfGroundwater Monitoring Reports for the Zanesville Well Field Site. Stantec Consulting Corp. (2010). December Discharge Monitoring Reports for Zanesville Well Field Site. Stantec Consulting Corp. (2010). First HalfGroundwater Monitoring Report for the Zanesville Well Field Site. Stantec Consulting Corp. (2010). Remedial System Optimization Report for Zanesville Well Field Site. Stantec Consulting Corp . (2010). Sub-slab Soil Gas and Indoor Air Sampling Results Zanesville Well Field Site. Stantec Consulting Corp. (2010). Vapor Intrusion Work Plan for Zanesville Well Field Site. Stantec Consulting Corp. (2011). Sub-slab Soil Gas and Indoor Air Sampling Results Zanesville Well Field Site. United States vs. United Technologies Automotive, Inc., (1992) Consent Decree, Civil Action No. CT 92-795. U.S. EPA. (1991). Record ofDecision for Zanesville Well Field, Zanesville OH. [Available http://cfpub.epa.gov/superrods/index.cfm?fuseaction=main.search ]. Accessed August 10,2010. U.S. EPA. (1991). Statement ofWork for Zanesville Well Field, Zanesville OH. U.S. EPA. (2001). Five year review ofZanesville Well Field, Zanesville OH. 48 u.s. EPA. (2002). OSWER Draft Guidance for Evaluating the Vapor Intrusion to Indoor Air Pathway from Groundwater and Soils. u.s. EPA. (2006). Five year review ofZanesville Well Field, Zanesville OH. u.s.EPA. (2010). Regional Screening Levels Risk-Based Concentration Table. [Available: http://www.epa.gov/reg3hwmd/risk/human/rb-concentrationtable/GenericTables/index.htm ]. Accessed December 30,2010. 49