Five-Year Review Report, Riverfront Superfund Site, New Haven by qru89250

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									                              Five-Year Review Report 


                              Riverfront Superfund Site 

                                New Haven, Missouri 





                                   November 2009 




                                    Region 7 

                 United States Environmental Protection Agency 

                               Kansas City, Kansas 





Approved by:



                                   //A^/o^
CeciliaTapia                      Dat^:
Superfund-Division Director
U.S. EPA, Region 7


                                                                           ?. o
                                                               30059971

                                                               Superfund
                                                                        RIVERFRONT SUPERFUND SITE
                                                                          FIVE-YEAR REVIEW REPORT

Executive S u m m a r y

A Five Year Review (FYR) has been completed at the Riverfront Site in New Haven, Missouri.
This is the first five year review at the site.


In 1986, the Missouri Department of Natural Resources (MDNR) began testing public-supply
wells in the state for volatile organic compounds (VOCs) and detected the chlorinated solvent
tetrachioroethene (PCE) in New Haven city wells Wl and W2. As a result of numerous
investigations, six Operable Units (OUs) have been identified as sources of contamination. The
six OUs are identified as:
        OU 1: Front Street Site 

        OU2: Keiiwood Site 

        0U3: City Dump 

        OU4: Maiden Lane Area 

        OU5: Old Hat Factory 

        0U6: Domestic Wells 


Time critical removal actions have occurred at OU 1, 0U4, and OU6. Remedies have been
selected and implemented for OUl, OUS, and OUS. A remedy has been recently selected for
0U4, but a remedial action has not begun. This review was conducted froin June 2009 through
October 2009.


OUl (Front Street)


The OU I 2003 ROD called for a combination of institutional controls to restrict exposure to the
shallow aquifer and soil contamination, proprietary controls, an environmental covenant and
easement, installation of an Advanced Remedial Technology (ART) well and associated
equipment, and extension ofthe inonitoring well network to monitor the plume. Institutional
controls are in place. The OUl remedy was declared to be Operational and Functional (O&F) on
November 2, 2005. The remedial system has operated approximately 73 percent ofthe time
since initial start up. If the EPA and MDNR conclude that the ART well system is to keep
operating into the State-lead "Operational & Maintenance" phase, the EPA will ensure the
system is functioning properly and operating as designed, before that transition occurs. The
groundwater pump in the ART system has not been functional for the past year. Therefore if the


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                                                                           RIVERFRONT SUPERFUND SITE
                                                                             FIVE-YEAR REVIEW REPORT

ART well is to remain operational, installation of a new pneumatic groundwater pump is
recomtnended. All groundwater concentrations are below the Alternate Concentration Levels
(ACLs) established from site monitoring results indicating that the system is meeting the
performance goals. However, the performance ofthe ART well is greatly impacted by the
groundwater elevation, which varies depending on the stage ofthe nearby Missouri River.
Therefore if the ART well is to remain operational, a remedy optimization study should be
considered to determine if such activities such as installation of additional instrumentation will
improve the operations and effectiveness ofthe ART well.


The 2003 ROD acknowledged ongoing vapor intrusion studies. Initial results from the two
residences downgradient of OU I were inconclusive. Research for this Five Year Review (FYR)
located data from the second round of indoor air samples conducted in July 2003 and einail
correspondence regarding a meeting conducted in August 2003 to evaluate the results. These
have not been formally documented. The conclusions ofthe meeting were that the high PCE
concentration detected initially in the basement of one of residences was the result of indoor
sources, such as cleaning solutions, dry cleaning, or other household products. Data from the
second residence repeatedly showed no PCE contamination. The team recommended that no
emergency existed at the residence and there was no need to remediate at the time. It also
recommended additional sampling for a year to evaluate seasonal variations. The follow-on
vapor intrusion studies and team meeting conclusions have not been formally documented.


OU2 (Keiiwood Industries)
The Remedial Investigation/Feasibility Study (Rl/FS) for OU2 is ongoing; hence, a remedy for
0U2 has yet to be selected. However, 0U2 is within an area already protected by an
institutional control which restricts future well installations.


OU3 (City Dump)
The 0U3 remedy is functioning as intended. Monitoring ofthe landfill inonitoring wells, surface
seep and nearby domestic wells is occurring per the requirements ofthe 2003 ROD. Institutional
controls have been implemented at 0U3 to enhance the protectiveness ofthe remedy. The




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                                                                                      FIVE-YEAR REVIEW REPORT

institutional controls restrict installation of wells within the OU3 boundary and within 300 feet
(ft) of the dump.


The 2003 ROD specified that if PCE concentrations in groundwater samples remained below the
maximum contaminant level' (MCL) of 5 ng /L after the conclusion of 1 year of quarterly
sampling, sampling would be reduced to every 5 years. Because PCE was not detected above the
MCL during the 2003-2004 quarterly monitoring, sampling decreased to once every 5 years.
Groundwater was sampled in May 2008. None ofthe May 2008 samples from monitoring wells,
an onsite seep, or nearby domestic wells contained detectable quantities of PCE or other volatile
contaminants of concern listed in the 2003 ROD. However, antimony and boron have previously
been determined as potential human-health risks. Based on the 2008 sampling, no substantial
changes in water quality have been observed in monitoring wells, seep, or domestic well
samples, and groundwater quality near OU3 appears stable and relatively unchanged.




OU4 (Maiden Lane Area)
The 2009 ROD for OU4 (Maiden Lane Area) was just recently issued and the remedy for OU4
has not been implemented. Therefore, any conclusions regarding remedy protectiveness would
be premature. However, OU4 is within an area already protected by an institutional control
which restricts future well installations.




OUS (Old Hat Factory)
The 0U5 2006 ROD documented that while the groundwater below OUS was contaminated, the
risk could be addressed with institutional controls and monitoring. Institutional controls are in
place and groundwater inonitoring is ongoing. The remedy was determined to be operational
and functional in May 2009 and post-ROD groundwater monitoring is occurring.




' The ma.\imum contaminant level (MCL) is the maximum permissible level of a contaminant in water which is
delivered to the free-flowing outlet ofthe ultimate user of a public water system. MCLs are promulgated by EPA
pursuant to the Safe Drinking Water Act, 42 U.S.C. §§300j-26 and are codified at 40 CFR Part 141.


                                                     ES-3
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                                                                            FIVE-YEAR REVIEW REPORT

OU6 (Domestic Wells) 

The Remedial Investigation/Feasibility Study (Rl/FS) for OU6 is ongoing with OU2, hence; a 

remedy for 0U6 has yet to be selected. However, OU6 is within an area already protected by an 

institutional control which restricts future well installations. 



PROTECTIVENESS STATEMENTS


The remedies at OU 1, 0U3 and OUS are protective of human health and the environment due to
the use of institutional controls will eliminate exposure pathways for the short and long term.


The 2009 ROD for 0U4 was just recently signed and the remedy for OU4 has not been
implemented. However, OU4 is within an area already protected by an institutional control
which restricts future well installations.


The Rl/FS for 0U2 and OU6 is ongoing; hence, a remedy has yet to be selected. However, OU2
and OU6 are within an area already protected by an institutional control which restricts future
well installations.




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                                                                         FIVE-YEAR REVIEW REPORT

Table of Contents

Section

Executive Summary                                                                          ES-1
List of Acronyms                                                                             iii
Five-Year Review Summary Form                                                                vi

1.0       Introduction                                                                        1
2.0       Site Chronology                                                                     3
3.0       Background                                                                          6
          3.1 Site Name, Location, and Description                                            6
          3.2 Land and Resource Use                                                           7
                  3.2.1 OUl (Front Street)                                                    7
                  3.2.2 0U2 (Keiiwood Industries)                                             8
                  3.2.3 0U3 (Old City Dump)                                                   9
                  3.2.4 OU4 (Maiden Lane Area)                                               10
                  3.2.5 OUS (Old Hat Factory)                                                II
                  3.2.6 0U6 (Domestic Wells)                                                 12
          3.3 Site History and Enforcement Activities                                        12
          3.4 Basis for Taking Action                                                        20
4.0       Remedial Actions                                                                   22
          4.1 Operable Unit 1 (Front Street)                                                  22
                  4.1.1 Remedial Action Objectives (OUl)                                     22
                  4.1.2 Remedy Selection (OUl)                                               2S
                  4.1.3 Remedy Implementation (OUl)                                          27
                  4.1.4 Operational and Functional Activities (OU 1)                         28
                  4.1.5 Institutional Controls (OUl)                                         30
          4.2 Operable Unit 2 (Keiiwood Industries)                                          30
          4.3 Operable Unit 3 (Old City Dump)                                                30
                  4.3.1 Remedial Action Objectives (0U3)                                     30
                  4.3.2 Remedy Selection (0U3)                                               30
                  4.3.3 Remedy Implementation (0U3)                                          32
                  4.3.4 Institutional Controls (OU3)                                         34
          4.4 Operable Unit 4 (Maiden Lane Area)                                             3S
                  4.4.1 Remedial Action Objectives (OU4)                                     3S
                  4.4.2 Remedy Selection (6U4)                                               36
                  4.4.3 Remedy Implementation (OU4)                                          38
                  4.4.4 Institutional Controls (OU4)                                         38
          4.5 Operable Unit S (Old Hat Factory)                                              39
                  4.5.1 Remedial Action Objectives (OUS)                                     39
                  4.5.2 Remedy Selection (OUS)                                               39
                  4.5.3 Remedy Implementation (OUS)                                          40
                  4.5.4 Institutional Controls (OUS)                                         40
          4.6 Operable Unit 6 (Keiiwood Industries)                                          41
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                                                                      FIVE-YEAR REVIEW REPORT



5.0	    Progress Since Last Review                                                        42
6.0	    Five-Year Review Process                                                          43
        6.1 Administrative Components                                                     43
        6.2 Community Involvement                                                         43
        6.3 Document Review                                                               43
        6.4 Data Review                                                                   4S
        6.5 Site Inspection                                                               46
        6.6 Interviews                                                                    46
7.0	    Technical Assessment                                                              48
        7.1	 Operable Unit I (Front Street) 

                Question A
                                                               SO
                Question B
                                                               51
                Question C
                                                               54
        7.2 Operable Unit 2 (Keiiwood Industries)                                         SS
        7.3 Operable Unit 3 (Old City Dump) 

                Question A
                                                               55
                Question B
                                                               57
                Question C
                                                               59
        7.4 Operable Unit 4 (Maiden Lane Area)                                            60
        7.5 Operable Unit 5 (Old Hat Factory) 

                Question A
                                                               60
                Question B
                                                               62
                Question C
                                                               64
        7.6 Operable Unit 6 (Domestic Wells)                                              65
        7.7 Technical Assessment Summary                                                  65
8.0	    Issues                                                                            68
9.0	    Recommendations and Follow-up Actions                                             69
10.0	   Protectiveness Statements                                                         70
11.0	   Next Review                                                                       71

Tables 

Table 1    Chronology of Site Events (Page 3) 

Table 2    Site Chronology for Individual OUs (Page 4) 

Table 3    Issues (Page 68) 

Table 4    Recommendations and Follow-Up Actions (Page 69) 


Figures 

Figure I Site Location 

Figure 2 Special Area 3 

Figure 3 ART Well 


Attachments 

Attachment I: Site Inspection Photographs 

Attachment 2: Site Inspection Checklists and Inspection Rosters 

Attachment 3: Groundwater Data 

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                                                                         FIVE-YEAR REVIEW REPORT

L i s t of A c r o n y m s

ACL               Alternate Concentrations Level
AOC               Administrative Order on Consent
ARP               American Recreation Products, Inc.
ART               Advanced Remediation Technology
AS                Air Sparge

bgl               below ground level
bgs               below ground surface
btoc              below top of casing

CalEPA            California Environmental Protection Agency
CALM              Cleanup Levels for Missouri
CD                Consent Decree
CERCLA            Comprehensive Environmental Response, Compensation, and Liability Act
cis-DCE           cis-1,2-Dichloroethene
COC               Chemical of Concern
COPC              Chemical of Potential Concern
CSR               Code of (Missouri) State Regulations
CT                Carbon Tetrachloride

DAF               Dilution Attenuation Factor
DNAPL             Dense Non-Aqueous Phase Liquid
DO                Dissolved Oxygen

EPA               (United States) Environmental Protection Agency
EPC               Exposure Point Concentration
ERA               Ecological Risk Assessment
ESI               Expanded Site Investigation
ESV               Ecological Screening Values

FS                Feasibility Study
FSP               Field Sampling Plan
FYR               Five Year Review

gpm               Gallons per minute

HHRA              Human Health Risk Assessment

IC                Institutional Controls
IDA               Industrial Development Authority ofthe City of New Haven
IWA               In-Well Aeration

LTM               Long-Term Monitoring
LTRA              Long-Tenn Response Action


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                                                       RIVERFRONT SUPERFUND SITE
                                                         FIVE-YEAR REVIEW REPORT

List of Acronyms (continued)

MCL        Maximum Contaminant Level
MDNR       Missouri Department of Natural Resources
MRBCA      Missouri Risk Based Corrective Action
MSL        Mean Seal Level

NCP        National Contingency Plan
NHMC       New Haven Manufacturing Company
NPDWS      National Primary Drinking Water Standards
NPL        National Priority List

O&F        Operational and Functional
O&M        Operations and Maintenance
ORP        Oxidation-Reduction Potential
OU         Operable Unit

PAH        Polynuclear Aromatic Hydrocarbons
PCE        Tetrachioroethene
PP         Proposed Plan
PPA        Prospective Purchaser Agreement
ppbv       parts per billion by volume
PRG        Preliminary Remediation Goal
PRP        Potentially Responsible Party
PVC        Polyvinyl Chloride

QA/QC      Quality Assurance/Quality Control

RAGS       Risk Assessment Guidance for Superfund
RAO        Remedial Action Objectives
Rl         Remedial Investigation
RME        Reasonable Maximum Exposure
ROD        Record of Decision
ROI         Radius-Of-Influence
RP         Responsible Party
RSL        (EPA) Regional Screening Level
RSMo       Missouri Revised Statutes
RV         Recreational Vehicle
RWI        Residential Well Investigation

SVE         Soil Vapor Extraction

TBC         To-Be-Considered
TCE         Trichloroethene




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                                                   RIVERFRONT SUPERFUND SITE
                                                     FIVE-YEAR REVIEW REPORT

List of Acronyms (continued)

|ig/kg     micrograms per kilogram
|ig/L      micrograms per liter

USAGE      United States Army Corps of Engineers
USGS       United States Geological Survey

VC         Vinyl Chloride
VOC        Volatile Organic Compound

yd^        cubic yard
                                                                              RIVERFRONT SUPERFUND SITE
                                                                                FIVE-YEAR REVIEW REPORT

F i v e - Y e a r Review S u m m a r y F o r m

SITE IDENTIFICA TION
 Site name (from WasteLAN): Riverfront 

 EPA ID (from Wa.steLAN): MOD981720246 

 Region: 7              State: MO         City/County: New Haven/Franklin 



NPL status: V Final D Deleted D Other (specify) 

 Remediation status (choose all that apply): X Under Construction X Operating D Complete 


 Site Wide FYR D YES V NO                        Construction completion date: 

 Has site been put into reuse? D YES V NO 

 REVIEW STATUS 

              v
 Lead agency: " EPA D State D Tribe D Other Federal Agency 

 Author name: Jeff Field 

 Author title: Remedial Project Manager                     Author affiliation: U.S. EPA Region 7 

 Review period: 06/01/2009 to 11/30/ 2009 

 Date(s) of site inspection: 06/23/2009 

 Type of review:             V Statutory 

                              D Policy
                                 V Post-SARA D Pre-SARA                    D NPL-Removal only
                                 D Non-NPL Remedial Action Site            D NPL State/Tribe-lead
                                 D Regional Discretion

 Review number: V I (first) D 2 (second) D 3 (third) D Other (specify)
                         Triggering action:
                                                     V Actual RA Onsite Construction at OU# I
                                                     D Actual RA Start
                                                     D Construction Completion 

                                                     D Previous Five-Year Review Report 

 D Other (specify) 


 Triggering action date (from WasteLAN): 1 1/09/2004 

 Due date (fiveyears after triggering action date): I 1 / 09/2009 





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                                                                                FIVE-YEAR REVIEW REPORT

Issues:

OUl Issues:
1.	 Previous removal actions and the ongoing ART well have inade an impact on the plume. However, the
    groundwater fluctuations influence the overall effectiveness ofthe system.
2.	 The groundwater pump in the ART system has not been functional for the past year.
3.	 The results of follow-on vapor intrusion studies discussed in the ROD need to be formally documented.

OU3 Issues:
1. No written easements with adjacent property owners for access to monitoring wells and sampled private
   wells are in place and access continues to be through verbal agreement.
Recommendations and Follow-up Actions:

OUl Recommendations:

1.	 If the EPA and MDNR conclude that the ART well system is to keep operating into the State-lead
    "Operational & Maintenance" phase, the EPA will ensure the system is functioning properly and operating
    as designed, before that transition occurs. Therefore if the ART well is to remain operational, a remedy
    optimization study should be considered to determine if such activities such as installation of additional
    instrumentation will improve the operations and effectiveness ofthe ART well.
2.	 If the EPA and MDNR conclude that the ART well must be kept operational when MDNR assumes
    operations and maintenance of OUl, installation of a new pneumatic groundwater pump is recommended.
3.	 The results ofthe follow-up vapor intrusion study not formally documented for the public record.

OUS Recommendations:

I.	 Obtain access agreements or easements for future well sampling required by the ROD.

Protectiveness Statement(s):

The remedies at OU 1, 0U3 and OUS currently protect human health and the environment due to the use of
institutional controls which eliminate the priinary exposure pathway of ingestion.

The ROD for 0U4 was just recently signed and the remedy for OU4 has not been implemented. Therefore,
any conclusions regarding remedy protectiveness would be premature.

Remedies for 0U2 and 0U6 have not been selected.

Other Comments:
The OUS ROD calls for sampling bi-annually (twice per year) for the first and second years and then annually
for the next three years to provide data during the first five-year review for OUS. After the first five-year
review, monitoring efforts would then be scaled back to one sampling round every five years to provide a
current data set for the next five-year review. The timing ofthe LTRA sampling events has changed such that
the first semi-annual sampling event was conducted in Fall 2008. In lieu of making any premature changes to
the ROD, the 2007 LTRA Field Sampling Plan and Quality Assurance Project Plan should be followed until
the 2"** FYR and then monitoring efforts be scaled back to annual if data indicates this is appropriate. In
accordance with the ROD, increases in groundwater contaminant levels, migration of groundwater
contamination off-site, and/or identification of new sources of OUS groundwater contamination could result in
the implementation of additional remedial actions.



                                                  VII
                                                                           RIVERFRONT SUPERFUND SITE
                                                                             FIVE-YEAR REVIEW REPORT


LO Introduction

The purpose of Five Year Reviews 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 United States Environmental Protection Agency (EPA) is preparing this five-year review
pursuant to the Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA) Section 121(c) and the National Contingency Plan (NCP). CERCLA § 121(c) states:


If the President selects a remedial action that results in any hazardous substances, pollutants, or
contaminants remaining at the site, the President shall review such remedial action no less often
than each five years after the initiation of such remedial action to assure that human health and
the environment are being protected by the remedial action being implemented. In addition, if
upon such review it is the Judgment ofthe President that action is appropriate at such site in
accordance with section [104] or [106], the President shall take or require such action. The
President shall report to the Congress a list of facilities for which such review is required, the
results of all such reviews, and any actions taken as a result of such reviews.


EPA interpreted this requirement further in the NCP; 40 CFR § 300.430(f)(4)(ii) states:


If a remedial action is selected that results in hazardous substances, pollutants, or contaminants
remaining at the site above levels that allow for unlimited use and unrestricted exposure, the
lead agency shall review such action no less often than every five years after the initiation ofthe
selected remedial action.


EPA Region 7 has conducted a five-year review ofthe remedial actions implemented at the
Riverfront Superfund site located in New Haven, Missouri. The site is comprised of six OUs.
See Figure 1.
                                                                           RIVERFRONT SUPERFUND SITE
                                                                             FIVE-YEAR REVIEW REPORT

The six operable units are identified as:
OUl:   Front Street
OU2:   Keiiwood Site
OU3:   City Dump
OU4:   Maiden Lane Area
OUS:   Old Hat Factory
0U6:   Domestic Wells

Time critical removal actions have occurred at OU I, OU4, and OU6. Remedies have been
selected and implemented for OUl, 0U3, and OUS. A remedy has been recently selected for
.0U4, but a remedial action has not begun. This review was conducted from June 2009 through
November 2009. This report documents the results ofthe review.
                                              1

This is the first five-year review for the Riverfront Superfund Site. The triggering action for this
review is the beginning ofthe start of remedial construction at OU I which was in November
2004. The five-year review is required because hazardous substances, pollutants, or
contaminants remain on the site above levels that allow for unlimited use and unrestricted
exposure. This FYR is evaluating human health and environmental protectiveness ofthe
remedies for OUs 1, 3, and 5. A discussion ofthe other three OUs without remedies in place are
described.
                                                                          RIVERFRONT SUPERFUND SITE
                                                                            FIVE-YEAR REVIEW REPORT

2.0 Site Chronology

A chronology of significant site events and dates is provided in the tables below:
Table 1: Chronology of Site Events
   OU                                    EVENT                                         DATE
Site Wide   Contamination Discovered PWS-1 PWS-2                                        1986
Site Wide   Preliminary Assessment Completed                                            1988
Site Wide   Site Investigation Completed                                                1989
Site Wide   Expanded Site Inspection Completed                                          1994
02          PRP Removal Action Completed                                                1994
02          PRP Monitoring Agreement Established                                        1995
01          Information Repository Established                                       11/17/1999
Site Wide   Hazard Ranking System Package Completed                                     2000
01          Remedial Investigation/Feasibility Study Completed                         6/2000
03          Remedial Investigation/Feasibility Study Completed                         6/2000
Site Wide   Proposal to Place on National Priorities List Prepared                   7/27/2000
01          Emergency Removal Action Completed                                         9/2000
Site wide   NPL Listing                                                               10/2000
Site Wide   Expanded Site Investigation/Remedial Investigation Completed               9/2001
01          Feasibility Study Completed                                                 2002
05          Pre-Remedial Investigation Completed                                        2002
OS          Rl Initiated                                                                2002
06          PRP Emergency Removal Began                                               11/2001
06          Administrative Order of Consent Finalized                                  S/2002
03          Focused Remedial Investigation Report Completed                            1/2003
01          Focused Remedial Investigation Report Completed                            1/2003
01          Feasibility Study Report Completed                                         9/2003
01          Public Meeting Held                                                      7/29/2003
03          Feasibility Study Report Completed                                         9/2003
01          Record of Decision Finalized                                               9/2003
03          Record of Decision Finalized                                               9/2003
01          Consent Agreement Finalized                                                3/2004
06          PRP Remedial Investigation/Feasibility Study Began                       3/16/2004
02          PRP Remedial Investigation/Feasibility Study Began                       3/16/2004
Site Wide   Information Repository Established                                         7/2004
02          Residential Well Investigation Completed                                   7/2004
03          Remedial Design Completed                                                  8/2004
01          Remedial Design Completed                                                  9/2004
01          Construction Started (ART well)                                            11/2004
01          Construction Completed (ART well)                                          2/2005
01          ART Remedial System Startup                                              6/02/2005
01          System Operational and Functional (ART well)                               11/2005
03          Information Repository Established                                         9/2006
OS          Information Repository Established                                         11/2006
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                                                                     FIVE-YEAR REVIEW REPORT

OS         Rl/FS Completed                                                     12/2006
OS         Record of Decision Finalized                                        12/2006
01         Final Long Term Remedial Action Field Sampling Plan                  3/2007
           Completed
01         Interim Remedial Action Report Completed                             6/2007
05         Remedial Action Completed                                          9/28/2007
04         Removal Action Completed                                             4/2008
04         Rl/FS Completed                                                     12/2008
04         Record of Decision Finalized                                         3/2009
05         System Operational and Functional                                    5/2009
03         PRP Remedial Action Competed                                         7/2009
03         Operation and Maintenance                                           Ongoing
01         Long-Term Remedial Action (LTRA)                                    Ongoing
04         Remedial Design                                                     Ongoing

Table 2: Site Chronology for Individual OUs
   OU                                   EVENT                                   DATE 

Site Wide Contamination Discovered PWS-1 PWS-2                                   1986 

Site Wide Preliminary Assessment Completed                                       1988 

Site Wide Site Investigation Completed                                           1989 

Site Wide Expanded Site Inspection Completed                                     1994 

Site Wide Hazard Ranking System Package Completed                             1999-2000 

Site Wide Proposal to Place on National Priorities List Prepared              7/27/2000 

Site Wide Listing National Priority List                                       10/2000 

Site Wide Expanded Site Investigation/Remedial Investigation Completed          9/2001 

Site Wide Information Repository Established                                    7/2004 


01    Information Repository Established                                      11/17/1999
01    Remedial Investigation/Feasibility Study Completed                        6/2000
01    Emergency Removal Action Completed                                        9/2000
01    Focused Remedial Investigation Report Completed                           1/2003
01    Feasibility Study Report Completed                                        9/2003
01    Public Meeting Held                                                     7/29/2003
01    Record of Decision Finalized                                              9/2003
01    Consent Agreement Finalized                                               3/2004
01    Remedial Design Complete                                                  9/2004
01    Construction Started (ART well)                                          11/2004
01    Construction Completed (ART well)                                         2/2005
01    ART Remedial System Startup                                             6/02/2005
01    System Operational and Functional (ART well)                             11/2005
01    Final Long Term Remedial Action Field Sampling Plan Completed             3/2007
01    Interim Remedial Action Report Completed                                  6/2007
01    Long-Term Remedial Action                                                Ongoing
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                                                            FIVE-YEAR REVIEW REPORT


02   PRP Removal Action Completed                                       1994 

02   PRP Monitoring Agreement Established                               1995 

02   PRP Remedial Investigation/Feasibility Study Began              3/16/2004 

02   Residential Well Investigation Completed                          7/2004 


03   Remedial Investigation/Feasibility Study Completed                6/2000 

03   Focused Remedial Investigation Report Completed                   1/2003 

03   Feasibility Study Report Completed                                9/2003 

03   Record of Decision Finalized                                      9/2003 

03   Remedial Design Completed                                         8/2004 

03   Information Repository Established                                9/2006 

03   PRP Remedial Action Completed                                     7/2009 

03   Operation and Maintenance                                        Ongoing 


04   Removal Action Completed                                          4/2008 

04   Remedial Investigation/Feasibility Study Completed               12/2008 

04   Record of Decision Finalized                                      3/2009 

04   Remedial Design                                                  Ongoing 


05   Pre-RI Investigation Completed                                    2002 

OS   Rl Initiated                                                      2002 

05   Information Repository Established                               11/2006 

OS   Remedial Investigation/Feasibility Study Completed               12/2006 

OS   Record of Decision Finalized                                     12/2006 

OS   Remedial Design Completed                                      12/06/2007 

OS   Remedial Action Completed                                      01/30/2008 

OS   System Operational and Functional                                5/2009 


06   PRP Emergency Removal Completed                                   3/2002 

06   Administrative Order of Consent Finalized                         5/2002 

06   PRP Remedial Investigation/Feasibility Study Began              3/16/2004 

                                                                         RIVERFRONT SUPERFUND SITE
                                                                           FIVE-YEAR REVIEW REPORT

3.0 Background

3.1 Site Name, Location, and Description

The Riverfront Site (CERCLIS # M0981720246) is located in New Haven, Missouri (population
1,867), along the southern bank ofthe Missouri River in Franklin County, about SO miles west of
St. Louis, Missouri. The principal road in the city is State Highway 100, which runs along part
of an east-west trending ridge about 1 mile south ofthe Missouri River (Figure 1). The ridge
forms a topographic divide between the Missouri River valley to the north and the Boeuf Creek
valley to the south. The downtown business district is located within a narrow strip of
floodplain and consists of several small shops and restaurants, a few homes, and several small,
old manufacturing facilities. This area of New Haven is surrounded by a flood protection levee
that is maintained by the United States Army Corps of Engineers (USAGE). Land use north of
the State Highway 100, including the downtown area, is mostly residential and light commercial,
and land use outside the city is mostly pasture with some row crops. An industrial park
(developed in the mid-1970s) containing several large manufacturing facilities is located south of
this ridge and State Highway 100.


There are two major aquifers in the New Haven Area; the Ozark aquifer and the Missouri River
alluvial aquifer. Both are used extensively in Missouri; however, in the New Haven area, the
Ozark aquifer is the primary aquifer for domestic, industrial, and public water use. The Missouri
River alluvial aquifer in the New Haven area contains high concentrations of iron and manganese
and is not used for water supply. The Ozark aquifer is a thick sequence of water-bearing
dolostone, limestone, and sandstone formations ranging in age from Late Cambrian to Middle
Devonian. Although these units collectively are a regional aquifer, the water-yielding capacity
ofthe various individual units is variable. Yields of 200 to 1,000 gallons per minute (gpm) are
not unusual for the lower zones in the area.


During 1986, the Missouri Department of Natural Resources (MDNR) began testing public-
supply wells in the state for VOCs and detected the chlorinated solvent tetrachioroethene (PCE)
in New Haven city wells Wl and W2. As a result of numerous investigations, six OUs have
been identified as sources of contamination.
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3.2 Land and Resource Use

3.2.1 OUl (Front Street)
Land Use:
The site is located in the eastern part of downtown New Haven. The site was used for
commercial industrial activities from the 19S0s through the 1970s. The area is currently zoned
commercial. The site is surrounded by residential and commercial property, a parking lot, the
levee and Missouri River to the north, a sanitary sewer lagoon to the east, and a vacant
lot/commercial property to the west. The reasonably anticipated future land use is greenspace or
park and additional parking spaces.


Groundwater Use:
Groundwater at OU I is from the Missouri River alluvial aquifer. Depth to water ranges from 8
to 28 feet (ft), and is directly related to the Missouri River stages. The groundwater flow is
generally to the north, toward the Missouri River, at a velocity of between 35 and 60 feet per
year; however, the flow is highly dependent on the Missouri River water stages; thus, during
high river levels, groundwater flow can reverse directions and flow south. The water contains
high concentrations of iron and manganese and is considered a non-drinking water aquifer in this
area. There is no surface water at OU I.


Institutional controls, implemented in layers, were placed at the site. These include a deed
restriction. Prospective Purchaser Agreement (PPA) which requires: 1) only use the site for
surficial uses, 2) not conduct any activities which would disturb contaminated soils, and 3) not
place any well that would penetrate groundwater. In addition to the deed restriction, MDNR
placed a restriction on drilling new wells in the area, and the City of New Haven has a restriction
which controls subsurface excavations, borings, or wells within SOO feet ofthe flood control
levee. All of OUl is within the Special Area 3 as designated by the State of Missouri which
requires that the MDNR be consulted before construction of a new well. See Figure 2 for the
boundaries for Special Area 3. The MDNR will provide specific guidance on well drilling
protocol and construction specifications on a case-by-case basis. The MDNR will provide
written approval for all new wells prior to construction. These restrictions will remain with the
property to prevent future exposure to groundwater.
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3.2.2 OU2 (Keiiwood Industries)
Land Use:
OU2 is located in New Haven, Missouri. OU2 includes the historic operations on and in the
Former Keiiwood Facility, located at 202 Industrial Drive, New Haven, Missouri. The facility is
currently owned and operated by Metalcraft Enterprises. Historical investigative activities have
revealed that there are residual levels of tetrachioroethene (PCE) within OU2 in the soil and
elevated levels in the groundwater. OU2 is located within an industrial park, in a primarily rural
area. Several residences are located nearby. A Rl/FS is currently being completed for OU2.


Groundwater Use:
There are two distinct bedrock flow systems beneath 0U2, a shallow flow system and a deep
flow system. The shallow bedrock flow system consists ofthe Cotter Dolomite and the Jefferson
City Dolomite. Groundwater flow through the shallow flow system near OU2 is to the south,
towards Boeuf Creek. The shallow flow system consists of two sandstone beds, the Upper
Sandstone and the Swan Creek sandstone, which are members ofthe Cotter Dolomite. With the
exception ofthe two sandstone units, the Cotter and Jefferson City Dolomites are poor water-
producing formations and typically have low vertical and horizontal conductivity from a regional
scale. The deep bedrock flow system consists ofthe Roubidoux Formation and older geological
formations, including the Gasconade, Eminence, and Potosi Dolomite. Groundwater flow
through the deep flow system near OU2 (based on water levels measured in monitoring wells
installed in the Roubidoux Formation) is to the northeast, towards the Missouri River. The
Roubidoux Formation is located from approximately 350 to 450 ft bgs, or 120 to 220 ft above
mean sea level (MSL), and is the primary production zone for many ofthe newer domestic water
supply wells.


A well inventory performed by EPA and the United States Geological Survey (USGS) in the
New Haven area found detectable levels of PCE in select residential wells south of OU2. The
area where PCE has been detected in residential wells has been identified as OU6. Since OU2 is
within Special Area 3 as described in Section 3.2.1, MDNR provides specific guidance on well
drilling protocol and construction specifications on a case-by-case basis. The MDNR will
provide written approval for all new wells prior to construction.
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3.2.3 OU3 (Old Citv Dump)
Land Use:
The Old City Dump (0U3) is located in the southeastern part of New Haven along the north side
of State Highway 100. The Old City Dump is currently used as a yard waste/gravel storage area
and compost site. The City of New Haven Public Works Departinent maintains OU3 and its
planned future use will remain the same. A gravel storage area located elsewhere in New Haven
will be consolidated into OU3. The surface ofthe Site is currently a mi.xture of gravel, dirt, and
occasional pieces of weathered asphalt and concrete. The area immediately north and west ofthe
Old City Dump is covered by dense woods of deciduous trees. The topography immediately
north ofthe dump is rugged, consisting of a steep ravine where wastes were dumped until the
entire upper end ofthe ravine was filled to its current level. On the east side ofthe dump, there
is a gravel parking lot. As the city will remain the owner of 0U3 and it intends to maintain the
current type of use, it is reasonable to expect no development will occur in the foreseeable future.
OU3 is surrounded by a mi.xture of coinmercial and residential property.


Groundwater Use:
Currently there is no surface water or groundwater use at OU3. The contaminants seen in one
monitoring well, BW-03, were detected in "perched" water that is moving along bedding planes
and fractures in the bedrock above the water table. This is a common occurrence in limestone
aquifers as infiltrating water works its way down to the water table. Well BW-03 is less than
250 feet from the Old City Dump, and it is not unusual to find that contaminants have migrated
this short distance in the unsaturated zone. The fact that seeps and the intermittent creeks in the
steep ravines north and east ofthe Site have no contaminants suggests that extensive lateral
movement of contaminants is not occurring.


Several residences, in close proximity to OU3 use domestic wells as their water supply. Most
domestic wells in the area target the Roubidoux Formation because it is the first unit that yields
appreciable quantities of water for domestic use. Groundwater age dating in the New Haven area
indicates that most water in the Roubidoux Formation (a permeable sand-rich unit about 300-400
feet deep in the area) is less than 40 years old. Given the age of water and the large amount of
water produced from the Roubidoux Formation compared to shallower units, it is likely, if the
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nearby domestic wells were to be impacted by the Old City Dump, that impacts would already
have been seen. It is extremely unlikely that wells would be installed at the Old City Dump Site
to supply water to residents or future workers because 10 CSR 23-3.010 requires that all new wells
are located at least 300 feet from a landfill.


During investigations, nested wells were installed and all domestic wells within one-half mile of
the OU were sampled. Data from the new nested well cluster confirms the suspected direction of
groundwater flow. The high conductance ofthe wells indicates they are properly placed and
intercepting typical landfill leachate. The absence of contaminants in the four nearby domestic
wells indicates that widespread groundwater contamination from OU3 has not occurred and is
unlikely in the future.                                                        '


3.2.4 OU4 (Maiden Lane Area)
Land Use:
0U4 is a 192-acre area in the north-central part of New Haven. The current OU4 area is
generally bordered on the west by Maupin Avenue, on the south by Roberta Street, and extends
east of Miller Street into undeveloped land within the city limits. OU4 straddles the topographic
divide between the Missouri River to the north and Boeuf Creek to the south. Topography is
asymmetric with steeper slopes to the north and east along the tributaries to the Missouri River
and shallow slopes to the south. Elevations range from about 690 ft MSL at the fonner
Keiiwood Research facility to less than SOO ft MSL in downtown New Haven. The 0U4
boundary encompasses a plume of PCE-contaminated groundwater that extends from a source
area south of Maiden Lane north to the Missouri River. Because OU4 surrounds the
groundwater plume in the bedrock aquifer, OU4 actually underlies OUS (Old Hat Factory) and
OU I (Front Street site). PCE contamination emanating from OU4 migrates through the bedrock
aquifer beneath OU I and OUS. The current and historical land use within 0U4 primarily is
residential. Non-residential land use in OU4 includes the Assumption Catholic Church, located
on a 3.8-acre parcel on the northwest corner ofthe intersection of Miller Street and Maiden Lane.
Future land use within OU4 is anticipated to be similar to its current use.




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Groundwater Use:
Currently, there is no use of groundwater within 0U4. 0U4 is within Special Area 3 as
described in Section 3.2.1. The MDNR will provide specific guidance on well drilling protocol
and construction specifications on a case-by-case basis. The MDNR will provide written
approval for all new wells prior to construction. Because ofthe proximity of OU4 to the
Missouri River valley, which serves as a drain for regional and shallow groundwater flow, the
PCE detected in the shallow bedrock at OU4 is not a threat to the public supply wells W3 and
W4 located south of and upgradient from 0U4 or domestic wells outside ofthe city limits.


3.2.5 OUS (The Old Hat Factory)
Land Use:
The Old Hat Factory (OUS) is located on a 1.9-acre parcel in a mostly residential area at the
southeast comer ofthe intersection of Maupin Avenue (west) and Wall Street (north) just south
of downtown New Haven. At the time ofthe initial field investigation in 2002, OUS consisted of
a three-story 14,000- ft" (square foot) brick building at the northwest corner ofthe property with
an attached 12,000- ft" one-story metal manufacturing building to the east, and an attached
4,200- ft" one-story office building to the south. The south half of the parcel consisted of an
asphalt parking lot. Most ofthe building was demolished during 2003-04 and the site was
extensively re-graded and seeded in 2005. This portion ofthe parcel is currently a grassed
vacant lot. Future use ofthe property is anticipated to remain commercial.


Groundwater Use:
Currently, there is no groundwater or surface water use at OUS. OUS is within Special Area 3 as
described in Section 3.2.1. The MDNR will provide specific guidance on well drilling protocol
and construction specifications on a case-by-case basis. The MDNR will provide written
approval for all new wells prior to construction. It is extremely unlikely that wells would be
installed at OUS to supply water to residents. The shallow groundwater in the 0U5 area is of
low quality and low yield, and any shallow wells would be unable to produce enough water for
domestic supply. In addition, the area is supplied drinking water from the city wells.
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3.2.6 OU6 (Domestic Wells)
Land Use:
In 1999, PCE was discovered in a residential well approximately 2000 ft downgradient of a
landfarm area located at the OU2 Keiiwood Industries Site. Three additional homes were later
identified as having contaminated wells. The area with contaminated residential wells has been
identified as OU6. Land use within OU6 is rural and rural residential and will remain so for the
foreseeable future. A Rl/FS is currently being completed for OU6 and OU2.


Groundwater Use:
All homes within the OU6 area use residential wells for domestic water. Homes whose wells
have been contaminated with PCE have been equipped with whole house treatment systems.
0U6 is within Special Area 3 as described in Section 3.2.1, and as designated by the State of
Missouri which requires that the MDNR be consulted before construction of a new well. The
MDNR will provide specific guidance on well drilling protocol and construction specifications
on a case-by-case basis. The MDNR will provide written approval for all new wells prior to
construction.


3.3 Site History and Enforcement Activities

The Riverfront Site is contaminated with industrial chemicals, primarily chlorinated volatile
organics. In 1986, MDNR began testing public-supply wells in the state for VOCs and detected
the chlorinated solvent PCE in New Haven city wells Wl and W2. These wells were more than
800 ft deep. Concentrations of PCE in water samples from city well W2 increased steadily with
time from the initial detection of 28 micrograms per liter (|ig/L) to a maximum of 140(ig/L
before the well was removed from service in 1993. The concentrations of PCE in water samples
from city well Wl generally were less than the federal allowable MCL of 5 ug/L. However, well
Wl was in the Missouri River floodplain and had a prior history of bacterial contamination
attributed to a poor surface casing seal that resulted in its removal from service in 1989. During
1988 and early 1994, two additional city wells (wells W3 and W4) were installed in the southern
part ofthe city to compensate for the loss of city wells Wl and W2. Wells W3 and W4, while
completed within the same aquifer, are cased several hundred feet deeper than wells Wl and W2.




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Various agencies have sampled city wells W3 and W4; no PCE or other VOCs have been
detected in those samples.


Results from several previous investigations resulted in an overall remedial investigation ofthe
Riverfront Superfund site. During 1993-94, an Expanded Site Investigation (ESI) was conducted
to collect sufficient data to score the site for possible placement on the National Priorities List
("NPL) or Superfund. Because several unresolved questions remained after the completion ofthe
ESI, the EPA conducted an Expanded Site Investigation/Remedial Investigation (ESI/Rl) in
2000 to collect information on groundwater flow and groundwater contamination in the vicinity
of city well W2.


Results from the ESI/RI were used to scope the Remedial Investigation (Rl) ofthe site which
began in 2000 as an investigation into four potential contaminant source areas (operable units)
that by 2003 had expanded into six operable units. The six operable units were identified as:
        OU I: Front Street 

        0U2: Keiiwood Industries 

        OU3: City Dump 

        OU4: Maiden Lane Area 

        OUS: Old Hat Factory 

        OU6: Domestic Wells 



At the start ofthe EPA Rl, little was known about the source of PCE to city wells Wl and W2 or
the potential for future contamination of city wells W3 and W4. By 2007, the EPA had
completed investigations at three ofthe six operable units (OU 1, 0U3 and OUS), installed a
long-term cleanup system for soil and shallow groundwater at one site (OUl), identified and
began cleanup of a major source ofthe PCE that closed city wells Wl and W2 (OU4), and
identified a second major PCE source area in the south part ofthe city, (OU2), that is being
addressed by the Keiiwood Company as a Potential Responsible Party (PRP).



OUl (Front Street)

In 1986, PCE was detected in two public-supply groundwater wells (wells Wl and W2) in the
northern part of New Haven. Following the discovery of contamination, two new public-supply



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wells were installed in the southern part ofthe city, and several investigations were conducted to
identify the source ofthe contamination. The Site became known as the Riverfront Site, and in
December 2000, the PCE contamination prompted the listing ofthe Riverfront Superfund Site on
the National Priorities List (NPL).


Various industries have operated at the Front Street Site since the 19S0s. In the l9S0s, the New
Haven Manufacturing Company (NHMC) began operating at the Site. The NHMC operated at
the Site until 1972. PCE was used as a degreasing solvent in the manufacturing operations ofthe
NHMC. The EPA has confirmed that waste PCE was washed out ofthe south doors ofthe
building, where it pooled in low areas along the south side of Front Street. NHMC dissolved as a
Missouri corporation in 1975. From 1983 to 1989, Riverfront Industries operated at OUl. Since
1989, the Site has been occupied by Transportation Specialists, Inc. (1989 - 1993), who did not
use PCE and by Wiser Enterprises, Inc. (1997 - 2004).


The EPA began a Rl in June 2000 and focused this effort at OUl (Front Street), and OU3 (City
Dump). A feasibility study (FS) for both areas began in the summer of 2002. During July 2000,
the EPA conducted an emergency removal action at OU 1 to replace a PCE contaminated water
line that ran beneath Front Street. The water line was made of polyethylene, which is permeable
to PCE. PCE contamination at OUl infiltrated the water supply line in this segment. The
polyethylene water line was replaced with a steel line. During the removal action, the EPA
removed near surface (less than 8 feet deep) PCE-contaminated soils along the water-line
corridor and in adjacent soils. These soils were some ofthe most contaminated soils at the site
with PCE concentrations as high as 6,200,000 micrograms per kilograms (^g/kg). About 300
yd (cubic yards) of PCE-contaminated soil, containing an estimated PCE mass of about 70
kilograms (kg), were removed during this removal action. In addition to mitigating the PCE
contamination in the water line, the removal action provided a corridor of clean soil surrounding
the water line beneath Front Street and adjacent areas.


The Record of Decision (ROD) was approved in September 2003 for OU 1.




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OU2 (Keiiwood Industries)
Beginning in 1973, Keiiwood Company began operating a tube mill (where small diameter
aluminum tubing was made from aluminum coils and a metal fabrication operation where
aluminum was cut, swaged, bent, and hole-punched) at 202 Industrial Drive. Kellwood's
operations on Industrial Drive were sold to American Recreation Products, Inc. (ARP), an
independent company, on September 30, 1985. In November 1988, Keiiwood bought ARP. In
March 1989, ARP sold the facility at 202 Industrial Drive to Metalcraft Enterprises.


In approximately 1990, ARP and Keiiwood Company were informed by the State of
Missouri that a former employee had stated that at some period during the operation ofthe tube
mill, one or more employees ofthe tube mill disposed of cleaning solvent containing PCE or
trichloroethene (TCE) on the City-owned property just to the north of 202 Industrial Drive.
In April 1994, Keiiwood and MDNR entered into an agreement to remediate the soils on the
city-owned property north ofthe Former Keiiwood Facility and to monitor groundwater. In
accordance with this plan, soils with concentrations of PCE exceeding 380,000 micrograms per
kilogram (|.ig/kg) were excavated and sent to an off-site incinerator. To meet the remedial
objective of reducing levels of PCE and its degradation products in the soil to a concentration of
1,000 ng/kg or below, the remaining soil was land-farmed. This work was completed by
Geotechnology under contract to Keiiwood. In addition, Geotechnology installed, at Kellwood's
expense, a French drain system between the landfarm and the current Metalcraft facility and
installed three monitoring wells north ofthe Former Keiiwood Facility (MW-101, MW-102, and
MW-103). As part ofthe 1995 agreement with MDNR, municipal well W3, the
French drain system, and the three monitoring wells north ofthe Former Keiiwood Facility
(MW-101, MW-102, and MW-103) were sampled on a quarterly basis unfil March 2004. In
June 2004, Keiiwood submitted a written request to MDNR to end the 1994 monitoring
agreement, with the understanding that sampling of these wells would be continued as part ofthe
Rl.


In 1999, following the land-farming activities, a Phase I and Phase II environmental site
assessment was performed by EMA on behalf of a prospective purchaser on properties near the
landfarm area. PCE was detected in two downgradient monitoring wells, MW-2, MW-2A, and


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in a well located approximately 600 feet southwest ofthe landfarm area (MW-4). Between 1999
and 2002, USGS installed groundwater inonitoring wells, and collected soil, groundwater,
residential well water, sediment, surface water, and tree core samples near the Former Keiiwood
Facility. PCE was detected in each of these media. The entire Riverfront Site was listed on the
National Priorities List (NPL) on October 19, 2000.


Currently, the shallow groundwater in portions of 0U2 contains PCE above the MCL. The
current National Primary Drinking Water Regulations (NPDWR or primary standards) for PCE
and TCE (a breakdown product of PCE) sets the MCL for each of these compounds at 5 |.ig/L.
Based on current information, 0U2 is not suspected to have been a source of contamination for
city wells Wl and W2. City well W3 is located 1,000 feet north ofthe Former Keiiwood
Facility. Quarterly sampling performed from 1994 to date at W3 has not shown any
contamination. OU2 is currently in the Rl/FS phase to investigate the nature and extent of
impacted media to develop and evaluate potential remedial alternatives. 0U2 may have affected
selected private wells south of OU2 (i.e., in OU6). PCE well above the MCL was discovered in
residential wells approximately 2,000 feet down gradient from a landfarm area located at the
OU2 Keiiwood Industries Site. A response action conducted under an Administrative Order of
Consent (AOC) dated March 26, 2002 provided whole-house filtration units for PCE-
contaminated residential wells in OU6. Pursuant to the Order, the whole-house filtration units
are sampled quarterly to ensure no one is exposed to contaminated groundwater.


Keiiwood began the investigation of 0U2 and OU6 with a voluntary Residenfial Well
Investigation (RWI). The RWI addresses residential wells south of OU2, which have been
collectively defined as OU6 ofthe Riverfront Superfund Site. The Interval Screening Phase of
the RWI was completed between July and August 2004. In addition, two monitoring well
clusters (MWl and MW2) were installed south of 0U2 between September and November 2004.


OU3 (Old Citv Dump)
During the period ofthe mid-l9S0s through the early 1970s, the old city dump operated under
private ownership and was used as a community dump for domestic and industrial wastes.
During its operation, hundreds of drums of industrial waste including industrial dyes and


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flammable solvents were reportedly placed in the dump. Reports also indicate that the liquid
contents ofthe drums were burned in a pit onsite. The dump was closed in 1972 when the land
was purchased by the City of New Haven. After its closure, the City of New Haven used the
dump for disposal of demolition debris and yard waste.


During the Rl at 0U3, monitoring wells and a seep were sampled. Additional samples were
collected from trees and seeps along the dump face and from streams and springs near the dump.
Water samples also were collected from a bedrock monitoring well (OU3-BW-03). Domestic
wells near OU3 were also inventoried and sampled during the Rl.


During the ESI/RI and Rl, a total of 22 trees and 4 seeps were sampled on and along the slopes
of OU3. AH four seeps were screened for the presence of PCE and other VOCs using the
portable GC.


There are no source materials or dense non-aqueous phase liquids (DNAPL) in the groundwater
constituting a principal threat at OU3. Only trace concentrations of PCE were found in the
groundwater, surface water, and vegetation samples at this OU. The ROD was approved in
September 2003.


OU4 (Maiden Lane Area)
During the 1980s and 1990s, after two public supply wells for the City of New Haven were
found to be contaminated with PCE, the MDNR and the EPA investigated to determine the
source ofthe contamination. In 1998, the EPA requested that the USGS provide technical
assistance in understanding the hydrogeology of New Haven. From 2000 to 2002, the USGS
conducted an ESI and Rl. The investigation included systematically installing bedrock
monitoring wells upgradient ofthe two contaminated City wells. By 2005, the monitoring well
investigation led to a focus on an area around Maiden Lane. At that time, EPA was concerned
that PCE disposed of into the City sewer system at OU2 may have leaked from the sewer lines
around Maiden Lane and created the PCE plume. However, by sampling various media (soils,
tree cores, indoor vapor from homes, sewer water, surface water, and groundwater) and from
discussions with residents, the investigation found that most likely a private citizen had disposed



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of significant amounts of PCE into his home's grey water (sewer) line, which discharged into a
low area behind (south of) Maiden Lane. From here the PCE migrated through the soils into the
bedrock and then into the bedrock aquifer.


At this time, the PCE soil contamination is nearly all confined to this small (less than 0.2 acre)
area south of Maiden Lane. The groundwater plume extends from the shallow groundwater at
the soil-rock interface below the source area soils through the bedrock to the north, possibly as
far as the Missouri River. Groundwater contamination also extends slightly south ofthe soil
source area, due to local topography. Overall, the PCE plume extends from the source area to
city wells Wl (approximately 3,800 ft downgradient) and W2 (approximately 3,000 ft
downgradient) and probably to the Missouri River (approximately 4,000 ft downgradient).


The removal action conducted by EPA at OU4 in 2007 consisted ofthe injection of sodium
permanganate into the Maiden Lane contaminant source area. While this action resulted in the
breakdown of some ofthe PCE into its nonhazardous constituents, the sampling data indicate
that contaminants remain in the soils and that such contaminants continue to mobilize into the
shallow aquifer and migrate Because ofthe proximity of 0U4 to the Missouri River valley,
which serves as a drain for regional and shallow groundwater flow, the PCE detected in the
shallow bedrock at OU4 is not a threat to the public supply wells W3 and W4 located south of
and upgradient from 0U4 or domestic wells outside ofthe city limits.


In March 2009, a ROD for 0U4 was issued.


OUS (Old Hat Factory)


The initial "pre-RI" EPA investigation ofthe old hat factory was limited because interviews with
former employees during previous MDNR and EPA investigations did not indicate that PCE had
been used at the facility. The pre-RI investigation consisted of a site reconnaissance and the
installation of a single monitoring well that was expected to "rule out" the old hat factory as a
possible source ofthe PCE contamination. However, water samples collected in 2002 from the
BW-09A borehole during drilling and from the completed well contained PCE concentrations



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ranging from 49 to 140 |ig/L. Because the old hat factory was within 600 ft and upslope of both
contaminated city wells (Wl and W2), the detection of PCE in samples from monitoring well
BW-09A caused concern that the facility could be a potential source ofthe PCE contamination in
the closed city wells. The old hat factory was designated OUS ofthe Riverfront Superfund Site
in mid-2002 and a Rl was initiated. The primary contaminants at OUS are PCE and its
degradation products such as TCE, cis-I,2-dichIoroethene (cis-DCE), and vinyl chloride (VC).
A monitoring well network was established to confirm groundwater contamination and to
determine if OUS was the source of groundwater contamination for the impacted city wells Wl
and W2. Although elevated concentrations of PCE were found in groundwater, and low levels of
PCE were found in soils, it was determined that OUS was not the source of contamination at the
impacted city wells. An Rl/FS was conducted and coinpleted in June 2006.


The ROD was completed in December 2006.


OU6 (Domestic Wells)


OU2 may have affected selected private wells to the south in 0U6. PCE well above the MCL
was discovered in residential wells approximately 2,000 feet down gradient from a landfarm area
located at the 0U2 Keiiwood Industries Site. A response action conducted under an
Administrative Order of Consent (AOC) dated March 26, 2002 provided whole-house filtration
units for PCE-contaminated residential wells in OU6. Pursuant to the Order, the whole-house
filtration units are sampled quarterly to ensure no one is exposed to contaminated groundwater.


Keiiwood began the investigation of OU2 and 0U6 with the voluntary Residential Well
Investigation (RWl). The RWI addresses residential wells south of 0U2, which have been
collectively defined as OU6 ofthe Riverfront Superfund Site. The Interval Screening Phase of
the RWI was completed between July and August 2004. In addition, two monitoring well
clusters (MWl and MW2) were installed south of 0U2 between September and November 2004.




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3.4 Basis for Taking Action


OUl (Front Street)


The basis for action was to prevent human health risks from occurring due to future exposures to
contamination found in groundwater and soil.


There were no current risks identified from groundwater at the time ofthe OU 1 ROD since all
residences and businesses were on city water. Use of groundwater as a potable source in the
future was assessed to result in significant risks. The primary chemicals of concern (COCs) were
TCE and PCE. VC and benzene also contributed to the estimated risks.


There were no current risks identified from contaminated surface soil at the time ofthe ROD.
Significant risks were estimated for future exposure should the floor slab be removed and the soil
underneath not capped or covered. The primary COCs for future estimated risks were
benzo(a)pyrene, arsenic, and PCE. Other COCs contributing to the overall estimated risk from
the soil were benzo(b)fluoranthene, benzo(a)anthracene, indeno(l,2,3-cd)pyrene, TCE, and VC.
There were no current exposures to subsurface soil COCs at OU 1. In characterizing future
excavation into contaminated soil, arsenic and PCE were found to be the primary COCs.


OU2 (Keiiwood Industries)


0U2 is undergoing a remedial investigation. A remedy has not yet been selected.


OU3 (Old City Dump)


The basis for action at 0U3 was to prevent future human health risks from occurring due to
exposures to contamination found in groundwater and seeps.


There were no current risks identified for OU3. Future potential risks were characterized
assuming residential and commercial uses of contaminated groundwater, with seep water


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concentrations representing the exposure point concentrations for the chemicals of potential
concern (COPCs) - antimony, boron, manganese, nitrate, and PCE. The primary risk drivers were
determined to be antimony, boron, and nitrate in the residential use scenario. For monitoring
purposes, however, ARARs and/or TBCs were listed in the ROD for all COPCs evaluated.


OU4 (Maiden Lane Area)


The ROD was finalized in March 26, 2009. The design ofthe remedy is ongoing. No remedial
action has occurred.


OUS (Old Hat Factory)


The basis for remedial action at OUS was to prevent fijture human health risks from occurring
due to exposures to contamination found in groundwater.


There were no current risks identified from contaminated soil, vapors, or groundwater at OUS.
Future potential risks were characterized and found to be significant, only if residential and
commercial uses of groundwater occurred. PCE was the primary risk driver, and carbon
tetrachloride and chloroform were identified as also contributing to significant risks.


OU6 (Domestic Wells)


OU6 is undergoing a remedial investigation. A remedy has not yet been selected.




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4.0 Remedial Actions
Remedial actions have been completed at OU I, OU3, and OUS. The RODs for OU I and OU3
were signed on September 30, 2003. The Consent Decree for 0U3 was signed by the City of
New Haven and EPA in May 2007. The ROD for OUS is dated December 7, 2006. 0U2 and
OU6 are still undergoing remedial investigations. For completeness ofthe document, the
recently selected remedy for OU4 is included although remedial action has not yet been
implemented. The 0U4 ROD is dated March 26, 2009.

4.1 OUl (Front Street)

4.1.1 Remedial Action Objectives (OUl)
RAOs provide a general description of what the response action is expected to accomplish. The
Remedial Action Objectives (RAOs) for OU I are to: 1) prevent use of groundwater with
contaminant levels exceeding MCLs as a drinking water source; 2) prevent further degradation
ofthe groundwater below the OU and in the plume; and 3) prevent exposure to soil with
contaminant concentrations which result in an excess cancer risk greater than 1 x 10'*or a Non-
Cancer Hazard Index greater than 1.


The EPA generally seeks to return usable groundwater to beneficial use whenever practicable.
When contaminated groundwater is currently or potentially used as a drinking water source, EPA
typically selects a remedy that will restore the groundwater to achieve MCLs and non-zero
Maximum Contaminant Level Goals (MCLGs) established under the Safe Drinking Water Act.
Under limited circumstances specified in CERCLA, Alternate Concentration Level (ACLs) may
be used instead of drinking water standards (typically, MCLs or MCLGs). The use of ACLs
allows flexibility in establishing groundwater cleanup levels under limited circumstances.


The following description presents the specific RAOs and ACLs used in the preferred
alternative. After the completion ofthe FS, the EPA and MDNR continued to explore existing
and innovative mechanisms for addressing contamination at OUl. One ofthe mechanisms
incorporates the use of ACLs and this mechanism was incorporated into an additional alternative
that became the preferred alternative for OU 1.




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The use of ACLs requires that three statutory criteria be met; these criteria are:


1)     The contaminated groundwater has "known or projected points of entry to a surface water
        body".
2)     There must be no "statistically significant increases" of contaminants in the surface water
        body at those points of entry, or at points downstream.
3)      It must be possible to reliably prevent human exposure to the contaminated groundwater
       through the use of institutional controls.


The EPA has determined that conditions at OU 1 meet the criteria to support the use of ACLs.
The following information documents this finding:


Criteria 1: E.xtensive sampling performed during the Rl and during subsequent field
investigations has defined the contaminant plume boundary with a high degree of confidence.
The contaminated groundwater plume originating at the Front Street Site flows to the northeast
approximately 600 feet where it enters the Missouri River. At the widest cross-section, just
before entering the Missouri River, the plume attains a maximum width of about 300 feet. The
"core" of this plume, which contains PCE concentrations above SOO ug/L, is less than 100 feet
wide. Substantial microbial degradation of PCE occurs within the plume, and PCE
concentrations decrease down the plume axis and concentrations of degradation products such as
cis-DCE, VC, and ethene increase. The Rl determined that in the more than 30 years since the
last known use of PCE at the facility, the contaminant plume has reached steady-state conditions,
and concentrations within the plume will remain at their present levels or decrease as the result
of degradation processes within the aquifer.


Criteria 2: During the Rl, surface water and bed-sediment samples were collected from the
Missouri River upstream, within, and downstream ofthe "known or projected" point of entry of
the contaminant plume into the river. The water samples were collected during a low stage of
the river and from the bottom ofthe river to maximize the potential for detecting the contaminant
plume discharge. None ofthe water or bed-sediment samples contained detectable
concentrations of PCE or its degradation products. A conservative analysis was done to



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determine the maximum impact that the plume (the contaminated shallow aquifer) could have on
the Missouri River water quality. The analysis conservatively assumed that the highest
contaminant concentration detected in the core ofthe plume (11,000 (ig/L PCE) discharges
directly into the Missouri River. This concentration is several orders of magnitude larger than
the maximum concentration detected within the groundwater plume in the discharge area along
the Missouri River. The analysis further assumed that this plume discharges continuously for a
distance of 400 feet along the Missouri River, and that the contaminated water entering the river
does not mix with the overlying water. In fact, turbulent conditions at the base ofthe river would
actually result in instantaneous mixing with thousands of cubic feet of surrounding river water,
even during low flow conditions. Using these extremely conservative assumptions, the analysis
concluded that the maximum PCE concentration that could occur at the downstream limit ofthe
discharge zone in the Missouri River would be 1.2 |ig/L, well below the drinking water MCL
value and the Missouri Water Quality Standard for protection of aquatic life, which is 5 |ig/L.
The non-detections of PCE and its degradation products in the river samples collected during the
Rl confirm the conservative nature ofthe analysis and support the "no statistically significant
increase" in contaminant concentrations criteria required for the use of ACLs.


Criteria 3: To reliably prevent future exposure to contaminated groundwater associated with
OUl, measures preventing exposure are in place and will be supplemented with additional
institutional controls. The flood protection levee surrounding downtown New Haven is owned
by the city, but was constructed by the USAGE using federal funds. The city is responsible for
maintenance ofthe levee and ensuring that stringent guidelines for construction and other
activities near the levee are followed. To maintain annual certification from the USAGE ofthe
levee's integrity, the city must ensure that these guidelines are followed; these include
controlling subsurface excavations, borings, and the installation of wells within SOO feet ofthe
back ofthe levee. Before any such activities occur, the city and USAGE must review a written
plan ofthe activity. The USAGE provides technical comments, and the city is responsible for
approving or disapproving the plan and ensuring that USAGE guidelines are followed. The city
public works department is responsible for oversight of subsurface activities near the levee.
Given the location ofthe Front Street Site in a highly visible area of downtown New Haven, near
municipal offices and facilities, any subsurface activities conducted at OUl would presumably



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be readily observable and hence controllable. The city has a large financial interest in
monitoring subsurface activities near the levee because if the USAGE guidelines are not
followed, the levee risks losing USAGE certification which would severely affect flood
insurance rates in the area.


4.1.2 Remedy Selection (OUl)

The remedy selected to achieve the remedial action objectives is as follows:

Institutional controls were implemented at OU I in layers to enhance the protectiveness ofthe
remedy. The primary form of institutional proprietary control is an environmental covenant and
easement. This form of proprietary control was selected as it is effective as an informational
device and creates a readily enforceable legal property interest.


The EPA sought the imposition of an environmental covenant and easement on the Site by the
landowner. The MDNR was named the grantee of this environmental covenant and easement
and will have the authority to enforce the environmental covenant and easement. The EPA was
named as a third-party, or intended beneficiary in this instrument so that EPA also had the ability
to enforce the terms ofthe environmental covenant and easement.


The objectives of imposing an environmental covenant and easement on OU I were to eliminate
or minimize exposures to contamination remaining at OU I and to limit the possibility ofthe
spread of contamination. These objectives were achieved by use ofthe environmental covenant
and easement as it: (1) provided notice; (2) limited use; and (3) provided federal and state access.
Specifically, the environmental covenant and easement achieved this by:
    •	   providing notice to prospective purchasers and occupants that there are contaminants in
         soils and the groundwater;
    •	   ensuring that future owners are aware of any engineered controls put into place as part of
         this remedial action;
    •	   prohibiting residential, commercial and industrial uses, except those uses which would be
         consistent with the remedial action;
    •	   limiting the disturbance of contaminated soils;
    •	   prohibiting the placement of groundwater wells;
    •	   prohibiting other ground penetrating activities which may result in the creation of a
         hydraulic conduit between water bearing zones;
    •	   providing access to EPA and the State of Missouri for verifying land use;


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   •	   prescribing actions that must be taken to install and/or maintain engineered controls (if
        applicable); and
   •	   providing access to EPA and the State of Missouri for sampling and the maintenance of
        engineered controls.

One Advanced Remediation Technology (ART) treatment well and three new monitoring wells
were installed as part ofthe selected remedy. The ART well is a combination in-situ air-stripper
well to treat the groundwater and a soil vapor extraction (SVE) well to treat the soil. The
location ofthe ART well was determined during the remedial design, and is very near the area of
highest soil contamination (the southeast corner ofthe Front Street Building). A treatability
study ofthe ART well was conducted during its first quarter of operation. The treatability study
determined the effectiveness ofthe groundwater treatment, confirmed that treatment ofthe ART
system's off-gas is not required, and was used to determine the site-specific Operations and
Maintenance (O&M) requirements for the system.


Three monitoring wells were installed. One well was within the radius ofthe treatment zone,
one well was at the edge ofthe treatment zone, and the last well was at the edge ofthe plume.
These wells, and existing monitoring well G, were used to determine if OUl was in compliance
with the ACLs. All the wells had to comply with the guidelines established by the USAGE for
protection ofthe flood control levee


The selected remedy used inonitoring:
   1)	 to generate the ACLs and then confirm that the ACLs are not being exceeded;
   2)	 to ensure that the groundwater plume does not migrate to new receptors;
   3)	 to determine the effectiveness ofthe ART well's groundwater treatment;
   4)	 to confirm that the off-gas from the ART well does not require treatment; and
   5)	 to confirm that the groundwater plume is not affecting the Missouri River.

The ACLs were set at one order of magnitude (times 10) above the highest concentration
detected to continue to protect the Missouri River. After the ACLs were determined, monitoring
results were compared to the ACLs to evaluate if the Missouri River could be affected by the
groundwater contaminant plume.


The Missouri River water samples were collected from the bottom ofthe river where the shallow
aquifer discharges. The samples were collected during the historical lowest flow month. Since



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groundwater ACLs were not exceeded during the first five years, the Missouri River sampling
will be discontinued.

4.1.3 Remedy Implementation (OUl)

Installation of one Advanced Remedial Technology (ART) treatment well (Figure 3)
The ART technology is a proprietary technology supplied by one vendor. The ART well uses in-
situ physical treatment (in-well aeration [IWA] and pumping/air-stripping for groundwater SVE
for soils) to remediate contaminated groundwater and soils. Based on the Rl groundwater and
soil sampling results, the ART well was installed at the head ofthe groundwater plume. The
head ofthe plume is very near, but not directly below, the location ofthe highest soil
contamination found in the Rl. The ART well's location was selected to maximize the combined
remediation of groundwater and soil. The work was completed in February 2005. The system
became operational in May of 2005. Samples ofthe vapor from the ART system were collected
on June 2, 2005. The purpose ofthe vapor samples was to determine if treatment ofthe vapor
released from the ART system would be required to meet the MDNR emission standards. The
results ofthe vapor sampling indicated that treatment ofthe vapor would not be required.


Installation of three additional inonitoring wells and two piezometers
One monitoring well was installed in the northeast (downgradient) portion ofthe OUl source
area to measure the effectiveness ofthe ART well's treatment. The two piezometers (one
shallow and one deep) were installed next to (within 5 feet of) the ART well to measure the flow
through the ART well. The other two inonitoring wells were installed downgradient from the
ART well to monitor the contaminant plume just before it enters the River. The work was
completed in March of 2005.


Institutional controls implemented in layers to enhance the protectiveness ofthe remedy
The primary form of institutional control to be implemented was a PPA between the United
States, the State of Missouri, and the Industrial Development Authority ofthe City of New
Haven (IDA). This PPA was filed in February 2004 with the EPA Region VII Hearing Clerk
under Docket No. CERCLA-07-2004-0004. Pursuant to the PPA, the IDA agreed to, among
other things:



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           •	   only use the site for surficial uses,
           •	   not conduct any activities which would disturb contaminated soils at the site, and
           •	   not place any groundwater wells at the site or otherwise penetrate the groundwater
                bearing unit(s) at the site.

Pursuant to the PPA. the IDA also granted to EPA and the State access to the site for sampling,
monitoring, or the implementation of response actions, and also agreed to provide actual notice
to any successors-in-interest or lessees ofthe site of any activity and use limitations on the site.
A copy ofthe PPA was also recorded by the IDA with the Franklin County Recorder of Deeds.


Other institutional controls that were implemented were:
           •	   Including OU I in Special Area 3, as defined in 10 CSR 23-3.100(7), which
                requires that the MDNR be consulted before construction of any new well in
                Special Area 3. The MDNR will provide specific guidance on well drilling
                protocol and construction specifications on a case-by-case basis. The MDNR
                will provide written approval for all new wells prior to construction. The MDNR
                filed an emergency rule for Special Area 3 on March 21, 2005, which expired at
                the end of six months. The permanent rule was filed on September 27, 2005 and
                became effective on April 30, 2006.
           •	   City oversight ofthe area around the flood protection levee. The flood protection
                levee surrounding downtown New Haven is owned by the City, but was
                constructed by the USAGE using federal funds. The City is responsible for
                maintenance ofthe levee and ensuring that stringent guidelines for construction
                and other activities near the levee are followed. To maintain annual certification
                from the USAGE ofthe levee's integrity, the City must ensure that certain
                guidelines are followed; these include controlling subsurface excavations,
                borings, and the installation of wells within 500 feet ofthe back ofthe levee.
                This SOO-foot area includes all of OU I. Therefore, before any excavations,
                borings, or well installations take place, the City and the USAGE must review a
                written plan ofthe activity. In this review, the USAGE provides technical
                comments, while the City is responsible for approving or disapproving the plan
                and ensuring that the USAGE comments and guidelines are followed. Because
                OUl is located in a highly visible area next to downtown New Haven, next to the
                City Maintenance Department and near City Hall and the Police Station, any
                subsurface activities conducted at OU I would be readily observable and hence
                controllable.

4.1.4 Operational and Functional Activities (OUl)

The ART well has been active for over four years. During this time, the system has been
operational for about 3 ofthe past 4 years and it appears that it has been effective.



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Unfortunately, the operation ofthe system at optimal levels is highly dependent on the
groundwater table. The efficiency ofthe system is determined by the river stage and subsequent
changes to the groundwater elevation. Due to proximity to the Missouri River, the water table
has fluctuated from between 27 to 6 feet below ground level (bgl). During periods of low water
table the groundwater pump and air sparge (AS) could be affected and during high water level
periods the SVE could be affected. SVE flow is dependent on the geology, the depth to water,
the amount of exposed screen, and the radius of influence ofthe vacuum induced by the blower.
When the water table is down, more screen is exposed, there is an increased flow from the
formation, and the system will operate more effectively. Conversely, when the water table is
high, the amount of screen in the unsaturated zone is decreased and the efficiency and
effectiveness ofthe SVE portion of this system is reduced. The amount of vacuum from the
blower also enters into the equation as there is a direct correlation to the amount of vacuum and
the resulting rise in the water table within the borehole caused by this vacuum. Whenever flow
through the screen is impeded due to either a high water table, high vacuum, or a combination of
both, the SVE portion ofthe system will not function.


A review ofthe system operation relative to groundwater elevation at the ART well indicates
that the groundwater level has played a significant role in the operation ofthe remedial system.
From system startup until early in 2007, the SVE portion ofthe system was operational with at
least IS feet of screen in the unsaturated zone and the SVE likely operated at maximum
effectiveness. However, during this period of low groundwater, two ofthe sampling events
indicated that there was very little water available for the pumping and/or AS portion ofthe
system. From the Spring 2007 sampling event until the Fall 2008 sampling event, the SVE
effectiveness likely dropped off significantly. This was due to a rise in the water table (resulting
from a rise in the Missouri River water levels) which resulted in a shortening ofthe screen
available for flow. During three of these quarterly sampling events, it appears that the screen
was occluded and the SVE likely did not function. Since fall 2008, the ART system has not been
operational due to a pump that is not functioning. Regardless ofthe problems associated with
the fluctuations ofthe water table, all ofthe Chemicals of Concern (COCs) remained well below
the ACLs.




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4.1.S Institutional Controls (OUl)

Institutional controls have been implemented in layers to enhance the protectiveness ofthe
remedy. The institutional controls put in place consist of inclusion ofthe site into Special Area
3, as defined in 10 CSR 23-3.100(7), PPAs, and restrictions due to proximity to the levee The
Institutional Controls are discussed in detail in Section 4.1.3.


4.2 OU2 (Keiiwood Industries) 

OU2 is undergoing a remedial investigation. Since a remedy has not yet been selected, a review 

of protectiveness has not been completed. 



4.3 OU3 (Old City Dump) 


4.3.1 Remedial Action Objectives (OU3) 


The RAO for this action is to minimize contact with contaminated groundwater and surface
water. Currently, no exposure exists that represents an unacceptable risk to human health or the
environment, hence there are no Chemicals of Concern (COCs). The chemicals of potential
concern (COPCs) for the Old City Dump Site include PCE, antimony, nitrate, boron, and
manganese. No Preliminary Remediation Goals (PRGs) have been set for these chemicals, as
they do not currently require remediation, based on the low levels detected. However,
institutional controls will be used, as well as periodic monitoring of residential wells, one seep,
and monitoring wells in the vicinity, to limit any potential future exposure to the COPCs.
Antimony and boron present a potential risk to a resident or occupational worker. This response
action will provide EPA and MDNR the means to evaluate this remedy, monitor any
contaminant migration, and prevent any potential fijture risks from the Old City Dump Site.



4.3.2 Remedy Selection (OU3)

Institutional controls were implemented at 0U3 in layers to enhance the protectiveness ofthe
remedy. The primary form of institutional control will be a proprietary control, specifically an
environmental covenant and easement. This form of proprietary control was selected as it is
effective as an informational device and creates a readily enforceable legal property interest.



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The City of New Haven currently owns OU3. The City of New Haven granted the State of
Missouri an environmental covenant and easement. The EPA was named as a third-party
beneficiary in this instrument so that EPA has the ability to enforce the terms ofthe
environmental covenant and easement in addition to the State of Missouri. This environmental
covenant and easement was patterned on the model environmental covenant and easement found
in the Missouri Uniform Environmental Covenants Act (MoECA), Mo. Rev. Stat §§260.1000­
260.1039. The objectives of imposing an environmental covenant and easement on 0U3 are to
eliminate or minimize exposures to contamination remaining at 0U3 and limiting the possibilit>'
ofthe spread of contamination.


These objectives were achieved by use ofthe environmental covenant and easement as it will:
(1) provide notice; (2) limit use; and (3) provide federal and state access.
Specifically, the environmental covenant and easement achieved this by:
         providing notice to prospective purchasers and occupants that there are contaminants in 

         soils and the groundwater; 

         ensuring that future owners are aware of any engineered controls put into place as part of 

         this remedial action; 

         prohibiting residential, commercial and industrial uses, except those uses which would be 

         consistent with the remedial action; 

         limiting the disturbance of contaminated soils; 

         prohibiting the placement of groundwater wells; 

         prohibiting other ground penetrating activities which may result in the creation of a 

         hydraulic conduit between water bearing zones; 

         providing access to EPA and the State of Missouri for verifying land use; 

         prescribing actions that must be taken to install and/or maintain engineered controls (if 

         applicable); and 

    •	   providing access to EPA and the State of Missouri for sampling and the maintenance of
         engineered controls.


In addition to the above proprietary control, governmental controls operate as effective
institutional controls at 0U3. The MDNR has promulgated regulations pertaining to the location
and construction of wells. These regulations prohibit the placement of a well within 300 feet of a
landfill. This prohibition, found at 10 C.S.R. 23-3.010, precludes the possibility that any well
will be located in OU3.



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The EPA will also provide public education through the preparation and distribution of a
newsletter on the Site and informational meetings, which may be held every five years. The
public education campaign would be intended to inform citizens ofthe potential health hazards
associated with exposure to contaminated groundwater and would remind city officials ofthe
restrictions on OU3.

The selected remedy also uses inonitoring to ensure that the contaminants do not migrate from
the Site and reach new receptors. In the first year, the four existing monitoring wells at the Site
and the most contaminated seep were sampled quarterly. The samples were analyzed for:

1)     VOCs, to confirm that no PCE (or any other VOC) is migrating from OU3 at levels
       above its MCL.
2)     Inorganics, to measure the levels ofthe other COPCs (antimony, boron, manganese, and
       nitrate).
3)     Field parameters (dissolved oxygen [DO], iron II, pH, oxidation-reduction potential
       [ORP], and temperature).

The ROD specified that if PCE concentrations in groundwater samples remained below the MCL
of 5 ug/L after the conclusion of 1 year of quarterly sampling, sampling would be reduced to
every 5 years. Because PCE was not detected above the MCL during the 2003-2004 quarterly
monitoring, sampling decreased to once every 5 years. None ofthe May 2008 samples from
monitoring wells. Seep M, or nearby domestic wells contained detectable quantities of PCE or
other volatile contaminants of concern listed in the ROD.


4.3.3 Remedy Implementation (OU3)

Institutional controls were put in place through the environmental covenant for the OU3 site filed
on April 14, 2008. The grantor ofthe covenant is the current property owner and PRP, the City
of New Haven, Missouri. The holder ofthe covenant is MDNR.


As specified in the ROD, the selected remedy requires, (I) a year of quarterly monitoring at the
old city dump (four inonitoring wells, seep M, and four nearby domestic wells) to establish
baseline conditions (conducted during 2003-2004), (2) to verify that PCE is not present above
the MCLs in groundwater at the dump site or at detectable concentrations in nearby domestic


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wells, and (3) the City must conduct an annual inspections ofthe site. Groundwater monitoring
wells at 0U3 are monitored to ensure that migration of contaminants above regulatory levels
does not occur. All groundwater samples are analyzed for a comprehensive suite of inorganic
constituents and VOCs as specified in the ROD, and the collection procedures described in the
0U3 Long Term Monitoring Quality Assurance Project Plan and Sampling and Analysis Plan.
AH monitoring wells and Seep M were sampled and analyzed quarterly during the first year of
inonitoring (2003-2004) as specified in the ROD to establish baseline conditions. PCE was not
detected above its MCL of 5 ug/L, but has been found in several monitoring wells and seeps at
concentrations less than 1.0 (tg/L. Because no PCE was found above the 5 |jg/L MCL, the
monitoring frequency remained at the 5 year interval specified in the ROD (the year preceding
the Five Year Review).


On the five-year schedule, domestic well samples are analyzed for the same comprehensive suite
of inorganic constituents and VOCs as the monitoring wells. Inorganic constituents in domestic
well samples collected every S years were compared to baseline concentrations of various
constituents derived during the first year of quarterly RA monitoring. If concentrations ofthe
suite of inorganic constituents (sodium, chloride, sulfate, nitrate, boron, iron, and strontium)
commonly elevated in monitoring wells at the dump indicated substantial increasing trends, or
PCE is detected above laboratory reporting levels, the EPA could require annual monitoring of
that particular domestic well or all domestic wells for VOCs or possibly other analytes specified
in the ROD.


The first 5 year monitoring event occurred in 2008. None ofthe 2008 samples from monitoring
wells. Seep M, or nearby domestic wells contained detectable quantities of PCE or other volatile
contaminants of concern listed in the ROD.


Concentrations of most chemical constituents that were above background levels in the baseline
sampling event (2003-2004) generally were above background levels in the 2008 sampling and,
with minor exceptions, generally were within historical ranges and overall no substantive
changes or trends were observed.




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No substantial changes in water quality have been observed in monitoring wells, the seep, or
domestic well samples, and groundwater quality near 0U3 appears stable and relatively
unchanged.


4.3.4 Institutional Controls (OU3)


Institutional controls have been implemented at OU3 in layers to enhance the protectiveness of
the remedy. The priinary form of institutional control is proprietary control, specifically an
environmental covenant and easement. This form of proprietary control was selected as it is
effective as an informational device and creates a readily enforceable legal property interest.
The City of New Haven, which currently owns 0U3 granted to the State of Missouri an
environmental covenant and easement. The environmental covenant is dated April 14, 2008.
The EPA was named as a third-party beneficiary in this instrument so that EPA has the ability to
enforce the terms ofthe environmental covenant and easement in addition to the State of
Missouri. This environmental covenant and easement was patterned on the model environmental
covenant and easement found in the Missouri Uniform Environmental Covenants Act (MoECA),
Mo. Rev.Stat§§260.1000-260.1039.


In addition to the above proprietary control, governmental controls operate as effective
institutional controls at OU3. The MDNR has promulgated regulations pertaining to the location
and construction of wells. These regulations prohibit the placement of a well within 300 feet of a
landfill. This prohibition, found at 10 C.S.R. 23-3.010, precludes the possibility that any well
will be located in OU3.


As described in the Final Operational and Monitoring Plan and Work Plan for Long-term
Monitoring of Operable Unit 3, Riverfront Site, February 2008, site inspections will be
conducted annually by City personnel. Completion ofthe annual site inspection checklist will
provide verification and documentation that the Institutional Controls meet the stated goals in the
ROD.




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A review of institutional controls conducted by USGS and detailed in the 0U3 Monitoring report
(2008) noted:
•	   The City of New Haven retains ownership ofthe dump site, but has no specific city
     ordinance restricting use or activities at the facility,
•	   No written easements with adjacent property owners for access to private wells or for
     monitoring wells for sampling are in place and access continues to be through verbal
     agreement,
•	   Missouri regulations preventing the placement of wells within 300 feet of a landfill continue
     to be in force (10 C.S.R. 23-3.010) and general well drilling regulations are in place. The site
     is not within the Special Area 3 as described in 10 C.S.R. 23- 3.100(7).




4.4 OU4 (Maiden Lane Area)

4.4.1 Remedial Action Objectives (OU4)

The RAOs developed for OU4 soils are:
             •	   For protection of human health - prevent exposure to soils with contaminant
                  concentrations which result in an excess cancer risk greater than 1x10"^ or an HQ
                  greater than 1.0, whichever is less.
             •	   For protection ofthe environment - reduce the soil contaminant levels and
                  prevent/reduce migration of soil contaminants to the groundwater.
The RAOs developed for 0U4 groundwater are:
             •	   For protection of human health - prevent exposure to groundwater with
                  contaminant levels greater than MCLs. For those contaminants without
                  established MCLs, prevent exposure to groundwater with contaminant levels
                  which result in an excess cancer risk greater than 1x10"^ or an HQ greater than
                  1.0, whichever is less.
             •	    For protection ofthe environment - minimize further degradation ofthe local
                  groundwater by the contaminants at OU4.




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4.4.2 Remedy Selection (OU4)


The remedial action selected in the ROD for OU4 addresses contaminated soil and groundwater
in the fractured bedrock and is summarized below.


   Soils - The hazardous substances in the soils at OU4 are tetrachioroethene (PCE),
          trichloroethene (TCE), and vinyl chloride. The remedial action selected to address
          these COCs consists ofthe injection of a chemical oxidant to enhance chemical
          oxidation ofthe COCs, inonitoring, and institutional controls (ICs). The
          contaminated soils at OU4 are considered to be "principal threat" wastes because the
          COCs are considered to be mobile source materials. Although contaminated
          groundwater also poses a risk, it is not considered a principal threat as defined by the
           Environmental Protection Agency (EPA) guidance. The most highly contaminated
          soils in the source area were treated during an EPA-lead removal action conducted in
          2007. The residual contamination that remains following that removal action will be
          addressed as part ofthe selected remedy through in situ chemical oxidation. The
           injection of chemical oxidants will create an in situ reactive zone where the COCs
          will be destroyed. This will result in the remediation ofthe soil source area. EPA
          anticipates that ICs will be effective in reducing the potential for exposure to the
          contaminated soils during the remedial action and until the remedial action objectives
          (RAOs) for the soils have been achieved. The primary IC for soils will be
           informational and educational. EPA, through the five-year review process, will
          continue to periodically inform and educate the owners ofthe properties where soil
          contamination is present ofthe potential health hazards posed by the COCs.


   Fractured Bedrock Groundwater - The hazardous substances in the fractured bedrock
          groundwater plume are PCE; TCE; cis-1,2-dichloroethene; and trans-1,2­
          dichloroethene Remediation ofthe contaminated soil source area will eliminate the
          continued migration of contaminants into the groundwater. It is expected that the
          groundwater plume will discharge over time into the nearby Missouri River. (Due to
          the large volume of water in the river and the relatively small quantity of COCs being


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           discharged into the river from the plume, the plume contaminants are not detectable
           in the river and do not appear to pose a threat.) With the remediation ofthe
           contaminant source area, the contaminant levels in the groundwater are expected to
           decrease over time to a level that is protective of human health.


ICs and long-term groundwater monitoring are also components ofthe selected remedy for the
groundwater. Currently, there is no unacceptable groundwater or surface water exposures at
OU4. All ofthe residences and businesses within OU4 are served by municipal water, and there
are no known wells providing potable water at OU4. 0U4 is within an area designated "Special
Area 3" in the MDNR, Division of Geology and Land Survey, Well Construction Code [10
C.S.R. 23-3.100(7)]. As a result of this designation, well drilling restrictions are in place that
precludes the installation of any well within or near the plume that may result in an unacceptable
exposure of humans to groundwater contamination. In addition to these restrictions, EPA,
through the five-year review process, will continue to periodically inform and educate the
owners ofthe properties where groundwater contamination is present ofthe potential health
hazards posed by the COCs and the need to comply with state well installation requirements.


Long-term groundwater monitoring will be conducted by EPA to track COC movement and
attenuation by physical processes. The monitoring will serve two functions: (1) it will alert EPA
to any changes in plume migration that may result in unacceptable exposures, enabling EPA to
take action to prevent such exposures; and (2) it will generate data on the expected physical
attenuation ofthe COCs in the groundwater plume, thus providing information to EPA regarding
the potential need for additional soil source area response actions and informing EPA and the
state's consideration ofthe need for continuing ICs for 0U4.


Groundwater monitoring will be accomplished by obtaining groundwater samples from existing
bedrock monitoring wells and performing laboratory analysis on the samples for COCs.
Provisions will be made for the abandonment of any inonitoring wells, pursuant to MDNR
requirements, at such time as the RAOs are met or a determination is made by EPA that
monitoring is no longer necessary.




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This selected remedial action provides for the overall protection of human health and the
environment, a "threshold" criterion for remedy selection as set forth in the NCP; however, it
does not meet the second NCP threshold criterion of compliance with ARARs. Due to the highly
fractured and variable bedrock conditions found at OU4, compliance with all ARARs through
containment, collection, treatment, or other technologies is technically impracticable from the
engineering perspective as well as disproportionately expensive for any potential benefit
realized. As a result, a waiver for certain chemical-specific ARARs is invoked in this ROD.

4.4.3 Remedy Implementation (OU4)

The ROD was finalized in March 26, 2009. The design of the remedy is ongoing.


4.4.4 Institutional Controls (OU4)
The selected remedial alternative uses ICs to safeguard against exposures to the contaminated
groundwater. 0U4 is within the previously described Special Area 3 defined by the MDNR,
Division of Geology and Land Survey, Well Construction Code [10 C.S.R. 23-3.100(7)]. As a
result of this designation, well drilling restrictions are in place to prevent the installation of any
well within an area of groundwater contamination which may create an unacceptable exposure to
humans to such contamination. It is unlikely that new wells would be installed near OU4 since
municipal water is readily available in that area. The state regulations will ensure that if any new
well construction or well deepening is planned, state officials will be infonned and can prescribe
methods for ensuring that no exposures to hazardous substances occur. These regulations should
also be effective in preventing the construction of substandard wells which could spread
contamination at or near 0U4. The regulations are considered to be durable, as revocation
would require the affirmative action ofthe state with notification to interested parties.


In addition to this restriction, EPA intends to continue its efforts to inform and educate the
owners ofthe properties where the groundwater contamination is located ofthe potential health
hazards posed by the contaminants present at OU4 and the need to comply with state well
installation requirements. It is expected that EPA will continue to provide public education
through the preparation and distribution of fact sheets and/or a newsletter on the Site and by
providing informational meetings which may be held every five years. The public education


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campaign would be intended to inform citizens ofthe potential health hazards associated with
exposure to contaminated groundwater and would remind the city officials and residents ofthe
restrictions on 0U4.

4.5 OUS (Old Hat Factory)

4.5.1 Remedial Action Objectives (OUS)

The RAOs developed for groundwater at OUS were: (I) minimize contact with the contaminated
groundwater exceeding PRGs, and (2) ensure that the contaminant levels in the groundwater
and/or the volume of contaminated groundwater do not increase.


4.5.2   Remedy Selection (OUS)

The selected remedy includes regular groundwater monitoring to track contaminant levels in, and
the location of the plume. The selected remedy also utilizes institutional controls which involve
the use of existing State of Missouri well construction requirements and public education to
prevent human use ofthe groundwater at OUS. The State of Missouri has enacted well
construction requirements for Special Area 3, which includes the area where OUS is located.
These well construction requirements are embodied in regulations found at 10 C.S.R. 23­
3.100(7). They provide that MDNR be consulted before any new well is constructed or any
existing well is deepened within Special Area 3.


It unlikely that new wells would be installed near OUS since municipal water is available in that
area, and there are currently no known wells in use near OUS. The state regulations will ensure
that if any new well construction or well deepening is planned, state officials will be informed
and can prescribe methods for ensuring that no exposures to hazardous substances occur. These
regulations should also be effective in preventing the construction of substandard wells which
could spread contamination at or near OUS. The regulations are considered to be durable, as
revocation would require the affirmative action ofthe state with notification to interested parties.




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Increases in groundwater contaminant levels, migration of groundwater ofT-site, and/or
identification of new sources of OUS groundwater contamination may result in the
implementation of additional remedial actions.


EPA will also provide public education through the preparation and distribution of fact sheets
and/or a newsletter on OUS and by providing informational meetings which may be held every
five years. The public education campaign would be intended to inform citizens ofthe potential
health hazards associated with exposure to contaminated groundwater and would remind the city
officials and residents ofthe restrictions on OUS.

4.S.3 Remedy Implementation (OUS)

The State of Missouri has enacted well construction restrictions referred to as Special Area 3,
which includes the area where OUS is located. These well construction restrictions are
embodied in regulations found atlO Code of State Regulations (C.S.R.) 23-3.100(7). Special
Area 3 requirements provide that the Missouri Department of Natural Resources (MDNR) be
consulted before any new well is constructed or any existing well is deepened within Special
Area 3.


Groundwater monitoring involves collecting and analyzing groundwater VOC samples from five
site monitoring wells including two newly installed wells. Two rounds of sampling results have
been reported. The data is used to monitor the contamination levels in the plume and determine
if clean up goals (MCLs) are being achieved for the site. The remedy was determined to be
operational and functional in May 2009 and post-ROD groundwater monitoring is occurring.




4.S.4 Institutional Controls (OUS)


The selected remedy utilizes institutional controls which involve the use of existing State of
Missouri well construction requirements and public education to prevent human use ofthe
groundwater at OUS. As described above, the State of Missouri has enacted well construction
requirements for Special Area 3, which includes the area where OUS is located. These well



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construction requirements are embodied in regulations found at 10 C.S.R. 23-3.100(7). They
provide that MDNR be consulted before any new well is constructed or any existing well is
deepened within Special Area 3.


It is expected that the EPA will also provide public education through the preparation and
distribution of fact sheets and/or a newsletter on OUS and by providing informational meetings
which may be held every five years. The public education campaign would be intended to
inform citizens ofthe potential health hazards associated with exposure to contaminated
groundwater and would remind the city officials and residents ofthe restrictions on OUS.


Institutional controls have been implemented in layers to enhance the protectiveness ofthe
remedy. One ofthe institutional controls is applicable to several site OUs: Special Area 3, as
defined in 10 CSR 23-3.100(7), which requires that the MDNR be consulted before construction
a new well in Special Area 3. The MDNR will provide specific guidance on well drilling
protocol and construction specifications on a case-by-case basis. The MDNR will provide
written approval for all new wells prior to construction.


4.6 OU6 (Domestic Wells) 

0U6 is undergoing a remedial investigation. Since a remedy has not yet been selected, a review 

of protectiveness has not been completed. 





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5.0 Progress Since Last Review 


This is the first Five Year Review for the Riverfront Site. 





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6.0 F i v e - Y e a r R e v i e w P r o c e s s

6.1 Administrative Components

The five-year review process was conducted by the U.S. Army Corps of Engineers, Phil 

Rosewicz, Greg Hattan, Debra Snodgrass and Amy Darpinian in support ofthe Region 7 

Remedial Project Manager (RPM) for the site, Jeff Field. 

The Review components included: 

         Community Involvement
         Document Review
         Data Review
         Site Inspection
         Interviews
         Five-Year Review Report Development and Review

6.2 Community Involvement

Activities to involve the community in the five-year review were initiated with a meeting in May
2009 between the RPM and the Community Involvement Coordinator for the Site. The nofice
announcing the commencement ofthe five-year review process was published in the local
newspaper on June 3, 2009. On June S, 2009, a notice stating the same was sent to the local and
state health department, county commissioners, city council members, and other local and state
officials. A fact sheet was also made available on the EPA's Web site on June 2, 2009.


6.3 Document Review

Documents reviewed as part ofthe Five Year Review included the following:
Site-Wide - Documents Reviewed
    •	 Missouri Well Construction Rules, MDNR April 2009 (Contains Special Area 3)
    •	 Remedial Investigation Administrative Letter Report (USGS, January 2001)
    •	 Site Summary, (EPA Region 7, February 2009)
    •	 Expanded Site Inspection Report (Jacobs Engineering Group Inc.)

Operable Unit 1 - Documents Reviewed
   •	 Baseline Risk Assessment, Operable Unit I (Missouri Department of Health (MDOH),
      Jan 2003)
   •	 Actual ACL Calculations, OU I (EPA, July 16, 2003)


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       ROD (EPA, September 30, 2003) 

       Sampling Data Evaluation Report, Spring 2007 (Black & Veatch., January 11, 2008) 

       Final Data Evaluation Report, Operable Unit 1 (Black & Veatch, November 7, 2006) 

       Interim Remedial Action Report, Operable Unit 1 (Black & Veatch, June 29, 2007)) 

       Final Long-Term Remedial Action Field Sampling Plan (Black & Veatch, March 2007) 

       Final Winter 2007 Sampling Data Evaluation Report Operable Unit I (Black & Veatch, 

       June 14,2007)                  '                 

       Final Summer 2007 Sampling Data Evaluation Report Operable Unit I (Black & Veatch, 

       January 18, 2008) 

       Final Spring 2009 Sampling Data Evaluation Report Operable Unit 1 (Black & Veatch, 

       September 8, 2009) 


Ope able Unit I and 3 - Documents Reviewed
       Focused Remedial Investigation of Operable Units OU 1 And 0U3 (USGS and Black &
       Veatch, January 2003)
       Feasibility Study Report (Black & Veatch, February 28, 2003)

Ope able Unit 3 - Documents Reviewed
       Baseline Risk Assessment, Operable Unit 3 (MDOH, January 2003)
       ROD (EPA, September 30, 2003)
       Consent Decree, OU3 (US District Court, Sept 6, 2007)
       Operational and Monitoring Plan for Operable Unit 3 (Old City Dump) (The City Of
       New Haven, January 16, 2007)
       2008 Environmental Monitoring Report For Operable Unit 3 (Old City Dump) (City of
       New Haven, October 21, 2008)

Ope able Units 2 and 6 - Documents Reviewed
      Statement Of Work, Remedial Investigation/Feasibility Study, Riverfront Superfund Site,
      Operable Unit No. 2 (EPA Region 7)
      Revised Final Remedial Investigation/Feasibility Study Work Plan, Operable Unit No. 2
      (Parsons, February 2, 2006)
      Final Administrative Order on Consent (AOC) For Whole-House Filtration For Residences
      In The South New Haven Area (EPA, March 25, 2002)
      Figure 1, Monitoring and Domestic Well Locations, OU2/OU6 (Parsons, provided by
      EPA on July 20, 2009)
      Tables I through 4, Summary of Data From Quarterly Sampling (last sampled February
      2009), OU2/OU6, (Parsons and provided by EPA on July 20, 2009)

Ope able Unit 4 - Documents Reviewed
       Final Human Health Risk Assessment Report, OU4 (Black & Veatch, July 2008)
       Final Feasibility Study Operable Unit 4 (Black & Veatch, November 12, 2008)
       Focused Remedial Investigation Of Operable Unit 4 (USGS, September, 2008)
       Final Fractured Bedrock Technical Impracticability Evaluation Report Operable Unit 4,
       (Black & Veatch, January 29, 2009) 

       ROD, OU4 (EPA Region 7, March 26, 2009) 



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Operable Unit 5 - Documents Reviewed
   •	 ROD OUS, (EPA Region 7, December 7, 2006)
   •	 Final Long-Term Remedial Action Field Sampling Plan OU5 (Black & Veatch, 

       September 26, 2007) 

   •	 Baseline Human Health Risk Assessment For OUS (Missouri Department Of Health,
      January 2006)
   •	 Final Fall 2008 Sampling Data Evaluation Report OUS (Black & Veatch, April 13, 2009)
   •	 Focused Remedial Investigation of OUS (USGS, June 2006)
   •	 Feasibility Study OUS (Black & Veatch, June 27, 2006)

6.4 Data Review

Data reviewed for the five year review consisted ofthe following:
OUl
For OUl groundwater data, the sampling commencing after the Rl (July 23, 2002) until current
(Sept. 8, 2009), and the remedial action vapor system results from start-up (June 2, 2005) until
current (Sept. 8, 2009) were described in the Final Spring 2009 Sampling Data Evaluation
Report Operable Unit 1 (Black & Veatch, September 8, 2009).


OU2
OU2 and OU6 monitoring well data was summarized in the Rl/FS work plan, including
groundwater treatment plant discharge, soil, surface water, sanitary sewer, tree core, and RWI
sampling conducted in December 2004 and February 2005. The Revised Final Rl/FS Work Plan,
Operable Unit No. 2 was prepared by Parsons and dated February 2, 2006.


OU3
For 0U3 groundwater data, the sampling beginning with the LTM (2003-2004) through current
May 21, 2008 was described in the 2008 Environmental Monitoring Report For Operable Unit 3
(Old City Dump) (City of New Haven, October 21, 2008).


OU4
0U4 sample data reviewed was from the tree cores (2000-2007), surface water and springs
(2000-2005), well water (2000-2007), soil (2001-2005), sanitary sewer samples (2001-2004),




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and indoor air (2002-2004). All these data are in the Focused Remedial Investigation of 

Operable Unit 4 (USGS, September 2008). 



OUS 

OUS data was found in the Final Fall 2008 Sampling Data Evaluation Report OUS (Black & 

Veatch, April 13, 2009) which included historical PCE data from 2004 through 2008 for site 

COCs. Rl data for soil (2001-2003), groundwater (2002-2005), sanitary sewer (2002-2004), and 

stream sampling (2000-2005) was found in the Focused Remedial Investigation of OUS (USGS, 

June 2006). 



OU6 

0U2 and 0U6 monitoring well data was summarized in the Rl/FS work plan, including 

groundwater treatment plant discharge, soil, surface water, sanitary sewer, tree core, and RWI 

sampling conducted in December 2004 and February 2005. The Revised Final Rl/FS Work Plan, 

Operable Unit No. 2 was prepared by Parsons and dated February 2, 2006. OU6 quarterly data 

from Jan 15, 2002 through current (Feb 25, 2009) was provided by EPA as Quarterly Residential 

Summary data tables. 



6.5 Site Inspection

A site inspection was held on June 23, 2009. All six OUs were visited. Participants in the site
inspection included Jeff Field, EPA Region 7 RPM for the site, Evan Kifer, MDNR PM for the
site, Rob Blake, an employee of Black & Veatch, EPA's consultant for the site and Phil
Rosewicz, Greg Hattan, Debbie Snodgrass and Amy Darpinian from USAGE Kansas City
District. A tour of OU2 and OU6 was provided by Lee Gorday, an employee of Parsons
Environmental, the consultant for the PRP. Site Photographs and Site Inspection Checklists can
be found in Attachinent 1 and 2.

6.6 Interviews

Interviews were conducted during the site visit for OU I, OU3, OU4 and OUS where remedies
have been selected. OU2 and OU6 do not have remedies selected to be reviewed. Those



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interviewed included Rob Blake and Evan Kifer. A brief summary of these interviews is
provided below:

Individual Interviewed: Evan Kifer - PM for MDNR

Mr. Kifer was interviewed regarding about OUl, OU3, 0U4 and OUS. Mr. Kifer had no
concerns regarding these OUs. He indicated that he has been kept well informed and
information had been provided in a timely manner.

Individual Interviewed: Rob Blake - Black & Veatch Employee and EPA's Consultant for
the Site.

Mr. Blake was interviewed concerning OU 1 and OUS. Mr. Blake felt the remedy at OU 1 was
functioning adequately and groundwater inonitoring at OUS is effective assessing the migration
ofthe plume.




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7.0 Technical Assessment

The Five Year Review must determine whether the remedy at a site is protective of human health
and the environment. The EPA guidance describes three questions used to provide a framework
for organizing and evaluating data and information and to ensure all relevant issues are
considered when determining the protectiveness of a remedy. These questions are assessed in
the following paragraphs for OUl, OU3 and OU5 where remedies have been selected and
implemented. No remedies have been selected for OU2 or OU6. The OU4 remedy has recently
been selected but not yet implemented. At the end ofthe section is a summary ofthe technical
assessment.



7.1 OPERABLE UNIT 1 (Front Street)

Question A: Is the remedy functioning as intended by the decision documents?
Yes, the remedial action is functioning as intended.


   •   Remedial Action Performance (OUl) and Monitoring Results

The Remedial Action of OU I is operating as designed; however, current subsurface and
mechanical conditions, as described in previous sections, prevent the system from operating as
efficiently or effectively. The ROD called for a combination of institutional controls to control
exposure to shallow aquifer and soil consisting of proprietary controls, an environmental
covenant and easement; installation of an ART well and associated equipment, and additional
monitoring wells and follow up sampling to monitor the plume The OU 1 remedy was declared
to be O&F on November 2, 2005. The remedial system has operated approximately 73 percent
ofthe time since initial start up. AH groundwater concentrations are below the ACLs, so the
system is meeting the performance goals. Total air effluent concentrations are below regulatory
levels under the Missouri Air Pollution Program.


The selected remedy (ART well) has been put in place and OUl is in the LTRA phase ofthe
cleanup process. On-going sampling is being conducted as described in the Final Long-Term



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Remedial Action Field Sampling Plan (FSP) for Riverfront Site, OU 1 (March 2007). During the
quarterly and bi-annual sampling events, groundwater and soil gas samples are collected using
the procedures outlined in the LTRA FSP. During the winter sampling events, when the river's
level is usually lowest, the Missouri River samples are collected. The contaminant concentration
in groundwater samples from nearby monitoring wells has fluctuated overtime. The fluctuations
in contaminant levels appear to correlate with the fluctuations of water table due to changes in
the river stage.


The most recent data available for this review was the Spring 2009 Sampling Data report dated
September 2009. Because the river samples are only collected in winter, that data was captured
in the Winter 2007 Sampling Data report dated June 2007. The Missouri River sampling results
for all samples (upstream and immediately downstream) continue to be all non-detect for the site
COCs.
    •   System Operations and Maintenance (OUl)

The ART well has been active for over four years. The system has been operational for about
three out ofthe last four years and has operated at less than optimal performance due to
fluctuations in the groundwater levels. The system is currently not operational due to an issue
with the groundwater pump.


Soil vapor extraction flow is dependent on the geology, the depth to water, the amount of
exposed screen, and the radius of influence ofthe vacuum induced by the blower. When the
water table goes down, more ofthe screen is exposed, hence, there is an increase of flow from
the formation, and the system will operate more effectively. Early in the operational period this
was the case. Conversely, when the water table is high, the amount screen in the unsaturated
zone is decreased and the efficiency and effectiveness are reduced. The amount of vacuum from
the blower also enters into the equation as there is a direct correlation to the amount of vacuum
and a resulting rise in the water table within the borehole caused by this vacuum. When the
elevated water table impedes flow through the screen, either from a high water table, high
vacuum, or a combination of both, the SVE system will not function as designed. A review of
historical groundwater level measurements indicates that the screened interval was occluded



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during the sampling period for 3 quarters out ofthe last 6 quarters (5/22/2007 event, 6/17/2008
event, and 5/26/2009 event). It is likely the SVE portion ofthe system functioned at a reduced
rate or was not functional during this period. The entire system has been down since the Fall of
2008.


Despite the reduced effectiveness ofthe ART system, the overall inonitoring well analytical data
over the remedial period indicates that contamination levels ofthe entire plume is less than the
ACLs.


    •     Early Indicators of Potential Issues (OUl)

Research for this FYR located data and correspondence regarding the follow-on vapor intrusion
studies. The results have not been formally documented in the administrative record.


    •     Implementation of Institutional Controls and Other Measures (OUl)

Institutional controls, implemented in layers, were placed at the site. These include a deed
restriction PPA which requires I) use ofthe site only for surficial uses, 2) not to conduct any
activities which would disturb contaminated soils, and 3) not place any well that would penetrate
groundwater. In addition to the deed restriction, MDNR placed a restriction on drilling new
wells in the area, and the City of New Haven has a restriction which controls subsurface
excavations, borings, or wells within SOO feet ofthe flood control levee. All of OU 1 is within
the restricted area.


The ROD for OU 1 specifies that quarterly groundwater inonitoring is to be conducted for the
first two years followed by semi-annual monitoring. ACLs, also a component ofthe selected
remedy, were calculated with the first two years of sampling results from downgradient wells
along with sample results from the Rl. The current measured groundwater concentrations are
well below the established ACLs. Since the release was many years ago and there is no expected
future source of contamination, the groundwater concentrations should remain below these
levels.




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Question B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial
action objectives (RAOs) used at the time ofthe remedy selection for OUl still valid?
Yes, the assumptions are still valid.


   •   Changes in Exposure Pathways (OUl)
The human health baseline risk assessment (HHRA) evaluated receptors for potential exposures
to contaminants in groundwater and soil. Future residents were assumed potentially exposed
through the following pathways: ingestion of COPCs in groundwater used as a
potable/household water source; dermal contact with COPCs in water while showering;
inhalation of vapors while showering; incidental ingestion of mixed contaminated soil at the
surface; dermal contact with mi.xed soil, and inhalation of vapors and particulates from mi.xed
soil. Current and future full-time workers were evaluated for ingestion of COPCs in
groundwater and for exposures to soil through ingestion, dermal contact, and inhalation of
vapors and particulates. Current trespassers and future recreationists were evaluated for surface
soil exposures through incidental ingestion, dermal contact, and inhalation exposure pathways.
Future construction/utility workers were assumed exposed to subsurface soil through incidental
ingestion, inhalation of vapors and particulates, and dermal contact exposure pathways. The
HHRA used standard default values for exposure parameters (e.g., ingestion, inhalation rates,
exposure frequency and duration, etc.) and accepted statistical and modeling methods to estimate
exposure point concentrations (EPCs) that, when combined, resulted in conservative, reasonable
maximum exposures (RMEs) for each exposure pathway. No change to these potential exposure
pathways was identified that would result in greater exposure opportunity than what was
evaluated in the HHRA. In fact, with implementation of institutional controls, these exposure
pathways become incomplete


One pathway not evaluated in the HHRA was potential inhalation of vapors migrating from
subsurface contamination and entering the breathing zone of a building. The HHRA (September
2003) identified two residences northeast of OUl and stated that indoor air sampling studies for
OU I were inconclusive and ongoing. PCE was not detected in indoor air in one ofthe homes
and measured at 590 ng/m3 in the basement air ofthe other. The ROD acknowledged ongoing
studies and stated that response measures would be implemented through a CERCLA removal


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action if necessary to reduce risk concluded from this pathway.


Research for this FYR located data and email correspondence regarding the follow-on vapor
intrusion studies. Additional sampling occurred in July 2003 at the two residences. On August
26, 2003 the Riverfront site team met with representatives from the EPA Vapor Intrusion team to
evaluate the indoor air results. Indoor air sampling results for one ofthe homes repeatedly
showed no PCE contamination; PCE was again measured in the other. However, the joint team
concluded that the previously elevated detection of PCE in the basement air likely represented a
concentration based on a source material within the residence and that the second round of data
represented indoor air after the homeowner removed the source. It was found unreasonable to
conclude that subsurface sources were contributing to the concentration measured in the living
room (i.e., 29 |jg/m3), since the two basement sample results were much lower, 3 L (L meaning
biased low) and 1.7 |Jg/m3. Variations in the indoor air results were attributed to cleaning
solutions, dry cleaning, or other household products. The team concluded that no emergency
existed at the residence and there was no need to remediate at the time. The team recommended
additional sampling for a year to evaluate seasonal variations. The indoor air sampling results
and joint team meeting conclusions have not been formally documented.


As discussed in Section 7.1, institutional controls are currently preventing exposure to OUl
contaminated groundwater and surface soils. These controls should also prevent future exposure
to the contaminants in both media.


    •   Changes in Land Use (OUl)

There have been no changes in land use that impact the protectiveness ofthe remedy. Land use
is zoned "light industrial" by the City of New Haven. With the layered institutional controls in
place, changes in land use that might result in potential exposures to contaminated groundwater
or soil are restricted.


    •   Changes in Standards, Newly Promulgated Standards, TBCs (OUl)

EPA determined for the ROD that OU 1 conditions met the criteria to allow Alternate


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Concentrations Levels (ACLs) to be established for groundwater chemicals of concern - PCE,
TCE, VC, and benzene - after two years of monitoring data were collected.


For soil. Cleanup Levels for Missouri (CALM) for Scenario A (residential) were identified for
arsenic (I I mg/kg) and indeno(l,2,3-cd)pyrene (3 mg/kg), respectively. CALM was never
promulgated by the state and subsequent to-be-considered (TBC) criteria are found in Missouri
Risk-Based Corrective Action (MRBCA) guidance. Comparable levels in MRBCA to Scenario
A levels in CALM are for residential land use - Soil Type 1 (sandy), which are 3.89 mg/kg for
arsenic and 3.77 mg/kg for indeno(l,2,3-cd)pyrene. MRBCA levels for industrial land u s e - Soil
Type 1 (sandy) are 15.9 mg/kg for arsenic and 12.8 mg/kg for indeno(l,2,3-cd)pyrene. EPCs for
surface and subsurface soil listed in the ROD indicate that neither arsenic or indeno( 1,2,3­
cd)pyrene are above the MRBCA guidance values.



   •   Changes in Toxicity and Other Contaminant Characteristics (OUl)

Since the time ofthe OU I HHRA, there have been changes in published toxicity values for PCE,
TCE, benzene, and the polynuclear aromatic hydrocarbons (PAHs). While some toxicity values
now indicate greater health concerns, others indicate less. However, changes do not impact the
overall protectiveness ofthe remedy since institutional controls require any land use to be
consistent with the remedy and thus exposure pathways are incomplete.


Although the inhalation data summarized for the HHRA differ from currently published values
for PCE and TCE, information found on the evaluation of indoor air samples collected in July
2003 indicates that toxicity values used by the EPA indoor air workgroup are likely the same as
those currently published. For example, the level of PCE considered acceptable in reviewing the
indoor air results was 0.3 micrograms per cubic meter (^tg/m^* based a one-in-a-million excess
cancer risk. This compares to 0.4 |Jg/m allowable level based on the inhalation cancer unit risk
factor currently used.




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   •   Changes in Risk Assessment Methods (OUl)

In July 2004, EPA finalized Risk Assessment Guidance for Superfund (RAGS): Volume I ­
Human Health Evaluation Manual, Part E, Supplemental Guidance for Dermal Risk Assessment.
There were no significant changes from the interim guidance followed in conducting the OUl
HHRA.


In January 2009, EPA issued RAGS: Part F, Supplemental Guidance for Inhalation Risk
Assessment. The intent of Part F is to achieve consistency between how inhalation exposure
concentrations are estimated and how inhalation toxicity values are developed. The use of
RAGS Part F would result in slightly lower estimated health risks, thus slightly higher allowable
screening levels.


No other changes to exposure factors and risk assessment methods have been identified that have
an impact on the protectiveness ofthe remedy.


Question C: Any Other Information That Could Call Into Question the Protectiveness of
the Remedy?


   •    Ecological Risks (OUl)

The ecological risk assessment (ERA) conducted in 2002 for the entire Riverfront Site complied
with the latest methodology, "Ecological Risk Assessment Guidance for Superfund: Process for
Designing and Conducting Ecological Risk Assessments" (EPA 1997). The ERA considered
stream sediment and surface water in the Missouri River as direct contact media for exposure to
chlorinated solvents and hydrocarbons. Chemical-specific ecological screening values (ESVs)
for sediment were compared to the results of river sediment samples. Ofthe few concentrations
of toluene detected, none was above the ESVs. Chemical-specific ESVs for surface water were
compared to the results of river water samples, and again, the few concentrations of toluene
detected were below the ESVs. The ERA concluded that there were no significant ecological
risks posed by these media. Also assessed was a food chain ingestion model for herbivores
consuming contaminated vegetation. The results of tree core samples, analyzed with a portable



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GC, were converted to average daily doses for representative mammal and bird species. The
doses were compared to wildlife ESVs and it was concluded that there were insignificant risks
posed through the food chain pathway.


The 2006 and 2007 annual Missouri River sampling events show all VOCs continue to be
nondetect in surface water; similar results would be expected for river sediments due to mass
balance and chemicophysical properties of VOCs. Additionally, since contaminant mass
continues to be reduced in soil and groundwater at OUl, tree uptake of VOCs would be expected
to decline. Based on a review of this most recent data, the conclusions ofthe 2002 ERA remain
current and valid.


There is no other information known that could call into question the protectiveness ofthe
remedy.

7.2 OPERABLE UNIT 2 (Keiiwood Industries)

OU2 is undergoing a remedial investigation. Since a remedy is not in place, no evaluation of
protectiveness has been conducted.



7.3 OPERABLE UNIT 3 (Old City Dump)

Question A: Is the remedy functioning at OU3 as intended by the decision documents?
Yes, the remedy is functioning as intended.


    •   Remedial Action Performance and Monitoring Results (OU3)

Institutional controls have been implemented at 0U3 in layers to enhance the protectiveness of
the remedy. The primary form of institutional control is proprietary control, specifically an
environmental covenant and easement. This form of proprietary control was selected as it is
effective as an informational device and creates a readily enforceable legal property interest.
The City of New Haven currently owns OU3. The City of New Haven granted to the State of
Missouri an environmental covenant and easement. The environmental covenant is dated April
14, 2008. The EPA was named as a third-party beneficiary in this instrument so that EPA has


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the ability to enforce the terms ofthe environmental covenant and easement in addition to the
State of Missouri.


The MDNR has promulgated regulations pertaining to the location and construction of wells.
These regulations prohibit the placement of a well within 300 feet of a landfill. This prohibition,
found at 10 C.S.R. 23-3.010, precludes the possibility that any well will be located in 0U3.


Implementation ofthe LTM began in 2003 when the EPA installed three additional monitoring
wells (BW-31, BW-31 A, and BW-32) at the site followed by I year of quarterly monitoring of a
seep, monitoring wells, and the collection of baseline water-quality samples from four nearby
domestic wells. The ROD specified that if PCE concentrations in groundwater samples
remained below the MCL of 5 ug/L after the conclusion of 1 year of quarterly sampling,
sampling would be reduced to every 5 years. Because PCE was not detected above the MCL
during the 2003-2004 quarterly monitoring, sampling decreased to once every 5 years. None of
the May 2008 samples from monitoring wells. Seep M, or nearby domestic wells contained
detectable quantities of PCE or other volatile contaminants of concern listed in the ROD.

Concentrations of most chemical constitutes that were above background in baseline sampling
(2003-2004) generally were above background in the May and August 2008 sampling, and with
minor exceptions, generally were within historical ranges and overall no substantive changes or
trends were observed. The trace elements antimony and boron contributed to the potential
human health risk at OU3 (EPA, 2003a) and, as such, are important constituents for long-term
monitoring ofthe site. The concentration of antimony in the May 2008 sample from Seep M
(15.7 ug/L) exceeded the 6 |jg/L MCL. Antimony concentrations in several previous samples
from this seep also exceeded the MCL, with a maximum concentration of 82 ug/L detected in the
initial sample from 1999. Antimony has been detected only in one other sample from OU3 and
that was 4 ug/L in the December 2003 sample from monitoring well BW-03. The reporting level
for antimony decreased from I |ig/L to 0.1 |jg/L in 2008, and the absence of detections in
samples from sites other than Seep M during 2008 indicates antimony has not migrated beyond
its extent since long-term monitoring began in 2003. Boron concentrations in all 2008
monitoring well samples and both Seep M samples exceeded background levels with the largest



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concentration in the sample from Seep M (1,600 |Jg/L) followed by 455 ug/L in the sample from
BW-31 and 379 |ig/L in the sample from BW-03. Although substantially above background
levels, boron concentrations in samples from May 2008 were within historical ranges in
monitoring well and Seep M samples, but slightly higher in domestic well JS-28. The May 2008
sample from JS-28 contained boron at 13.2 |jg/L as compared to 10 ug/L in April 2003. This
increase is slight and likely within natural variability or possibly analytical or sampling error,
and not related to effects from OU3.


   •    Early Indicators of Potential Issues (OU3)
No written easements with adjacent property owners for access to private wells.or monitoring
wells for sampling are in place and access is granted through verbal agreements prior to
sampling.


   •    Implementation of Institutional Controls and Other Measures (OU3)

Institutional controls prescribed in the ROD are in place.



Question B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial
action objectives (RAOs) used at the time ofthe remedy selection for OU3 still valid?
Yes, the assumptions are still valid.


   •    Changes in Exposure Pathways (OU3)

The HHRA for OU3 was completed in 2002 and assessed hypothetical exposure pathways
assuming potable/domestic use of groundwater. Current residential exposure was assessed for
ingestion of inorganics detected in a domestic well located just west of OU3. A future
residential scenario assessed the following exposure pathways as complete: ingestion of COPCs
in groundwater, dermal contact and vapor inhalation while showering. A future worker scenario
included ingestion of contaminants in groundwater. There were no exposure pathways evaluated
for soil; based on the tree coring data, it was concluded in the Rl that soil was not the source of
PCE groundwater contamination for the Riverfront Site.




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The environmental covenant eliminated exposure opportunities to groundwater by prohibiting
placement of groundwater wells on the property, and minimized exposure opportunities to soil
by limiting disturbance.


Note that the HHRA did not quantify potential risk from recreational exposure to ephemeral seep
water since contact would be sporadic and incidental. This exposure pathway was considered
incomplete. This conclusion remains valid.



      •   Changes in Land Use (OU3)

There have been no changes in land use that would impact the protectiveness ofthe remedy.
Currently, the Old City Dump is used for surface disposal of trees and yard waste. This land use
is consistent with the environmental covenant filed at the Franklin County Recorder of Deeds
office on April 14, 2008, limiting disturbance of contaminated soils and prohibiting placement of
groundwater wells on the property. Missouri regulations restrict placement of wells within 300
feet of a landfill, which assures that groundwater use immediately downgradient of OU3 will not
change. There are no controls beyond 300 ft that would prevent future changes in land or water
use
      •   Changes in Standards, Newly Promulgated Standards, TBCs (OU3)

Federal MCLs were listed in the ROD as standards for antimony (6 (xg/L), nitrate (10,000 ug/L),
and PCE (5 |Jg/L). The standard listed for manganese (SO ug/L) was taken from Missouri 10
CSR 20.7, Water Quality Criteria for Designated Uses. For boron, a TBC value of 600 jug/L was
set based on the Federal Lifetime Health Advisory Level. The basis for the listed concentrations
has not changed and there are no newly promulgated standards for these chemicals.


      •   Changes in Toxicity and Other Contaminant Characteristics (OU3)

Since OU3 HHRA was completed, there have been changes in published toxicity values for PCE.
However, changes to toxicity values for PCE do not impact the protectiveness ofthe remedy
since there have been no recent detections of PCE. Toxicity values for antimony, boron,
manganese, and nitrate have not changed. While the MCL for antimony was listed in the ROD,
the allowable tapwater level based on current toxicity information is 0.66 ug/L to protect to a one


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in a million excess risk level.


    •   Changes in Risk Assessment Methods (OU3)

There were no significant changes in risk assessment methodologies that would affect the
protectiveness ofthe remedy. While EPA finalized Risk Assessment Guidance for Superfund
(RAGS): Volume I - Human Health Evaluation Manual, Part E, Supplemental Guidance for
Dermal Risk Assessment in July 2004, there were no significant changes from the interim
guidance, which was followed in the 0U3 HHRA (EPA 2003).


Question C: Any Other Information That Could Call Into Question the Protectiveness of
the Remedy at OU3?


   • Ecological Risks (OU3)
The ecological risk assessment (ERA) conducted in 2002 for the entire Riverfront Site complied
with the latest methodology, "Ecological Risk Assessment Guidance for Superfund: Process for
Designing and Conducting Ecological Risk Assessments" (EPA 1997). For OU3, analytical
results were evaluated for the sediment and surface water samples collected from the drainage
located to the north. No chlorinated ethenes or other contaminants were detected in either media;
therefore, it was concluded that neither media posed significant ecological risks. PCE, cis-DCE,
benzene and toluene were detected in tree core samples at 0U3 and the estimated average daily
doses for the representative mammal and bird species were compared to ESVs. Based on this
comparison none of these VOCs was present at levels that indicated significant risk to
herbivores. The overall conclusion ofthe ERA was that risks were minimal at OU3.


As previously discussed, the first five-year monitoring event for OU3 occurred in 2008. None of
the samples from groundwater or seep water contained detectable quantities of PCE or other
VOCs of concern listed in the ROD. Based on a review of these results, the conclusions ofthe
2002 ERA remain current and valid.

There is no other information known that could call into question the protectiveness ofthe
remedy.



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7.4 OPERABLE UNIT 4 (Maiden Lane Area)

0U4 recently had a remedy selected, but the remedy is not yet in place. Since a remedy is not in
place, no evaluation of protectiveness has been conducted.


7.5 OPERABLE UNIT S - OLD HAT FACTORY 

Question A: Is the remedy functioning at OUS as intended by the decision documents?
Yes, the remedial action is functioning as intended.


   •   Remedial Action Performance and Monitoring Results (OUS)

The ROD was signed in December 2006. The ROD documented that while the groundwater
below OUS was contaminated, the risk could be addressed with institutional controls and
monitoring.


The selected remedy utilizes institutional controls which involve the use of existing State of
Missouri well construction requirements and public education to prevent human use ofthe
groundwater at OUS. The State of Missouri has enacted well construction requirements for
Special Area 3, which includes the area where OUS is located. These well construction
requirements are embodied in regulations found in 10 C.S.R. 23-3.100(7) and provides that
MDNR is to be consulted before any new well is constructed or any existing well is deepened
within Special Area 3. The MDNR will provide specific guidance on well drilling protocol and
construction specifications on a case-by-case basis. The MDNR will provide written approval
for all new wells prior to construction.


Groundwater sampling and analysis was conducted in the Fall of 2008 as part of a formal
monitoring program for LTRA efforts to evaluate the contamination levels present at OUS. The
extent of contamination in groundwater at the OUS site was evaluated from the monitoring wells
on site. The three original wells (BW-9, -9A, and -12A) were sampled at one interval. The two
wells installed for the LTRA, BW-15 and BW-16, were sampled at multiple intervals. The wells
were sampled and analyzed for the presence of VOCs: the COCs at the site are PCE, Carbon


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Tetrachloride (CT), and chloroform. During the Fall 2008 event, PCE and CT were detected, but
chloroform was not. Trichloroethene was also detected in one well. AH other VOCs that were
analyzed for in the samples were non-detect.


The PCE concentration in BW-9A has fluctuated since sampling began in July 2002. The
variation in PCE data could be related to precipitation events because there appears to be perched
water at BW-9A. The Fall 2008 water level at BW-9A was 4 feet higher than at BW-12A and 34
feet higher than at BW-16, which is located approximately 150 feet north of BW-9A.
Samples from BW-16 and BW-9A contained PCE above its MCL of 5 ug/L. PCE was not
detected in the background well, BW-IS, or in the sidegradient well, BW-I2A. The BW-9A PCE
concentration was 30 ug/L and was collected at 40 ft btoc. The BW-16 PCE concentrations were
27 and 32 |Jg/L, collected at 73 and 76 ft btoc, respectively. The PCE concentration in the Fall
2008 sample was similar to, although a bit lower than, the concentrations in the grab sample
collected from BW-16 in January 2008, 49 ug/L. PCE was also detected in BW-9 at 0.59 \ig/L at
166.1 ft bgs which was below the PCE MCL. The carbon tetrachloride concentration in BW-16
was 7.7 |Jg/L and 8.8 ug/L at depths of 73 and 76 ft btoc, respectively. These concentrations
exceed the 5 |jg/L MCL for CT. As expected, the installation of BW-IS has provided a
background well that does not contain any ofthe OUS COCs.


BW-16 was installed in an attempt to define the downgradient end ofthe plume. However, the
initial COC concentrafions indicate the plume extends beyond the location of BW-16. The exact
flow path to and from BW-16 is unknown due to the highly weathered bedrock encountered as
BW-16 was installed and the unknown nature ofthe fracture and joint system in the bedrock.


The ongoing monitoring appears to adequately track contaminant levels in, and the location of
the plume. However, the downgradient end ofthe plume has not been defined. During the site
inspection, it was pointed out that installation of additional downgradient wells is not possible
due to a steep drop in elevation at the site boundary. OUS is also within the boundary of OU4
which has a technical impracticability waiver for certain chemical-specific ARARs within the
fractured bedrock.




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   •    Opportunities for Optimization (OUS)
The OUS remedy should continue to be monitored as described in the ROD.


   •    Early Indicators of Potential Issues (OUS)
The ROD called for sampling biannually (twice per year) for the first and second years and then
annually for the next three years to provide data during the first five-year review for OUS. After
the first five-year review, monitoring efforts would then be scaled back to one sampling round
every five years to provide a current data set for the next five-year review. The timing ofthe
LTRA sampling events has changed such that the first biannual sampling event was conducted in
Fall 2008. In lieu of making any premature changes to the ROD, it is recommended that the
2007 LTRA Field Sampling Plan and Quality Assurance Project Plan be followed until the 2"''
FYR and then inonitoring efforts can be scaled back to annually if the data indicates this is
appropriate. In accordance with the ROD, increases in groundwater contaminant levels,
migration of groundwater off-site, and/or identification of new sources of OU5 groundwater
contamination could result in the implementation of additional remedial actions.


    •   Implementation of Institutional Controls and Other Measures (OUS)
The institutional controls that were put in place as described in the ROD minimize future contact
with the contaminated groundwater exceeding PRGs.


Question B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial
action objectives (RAOs) used at the time ofthe remedy selection for OUS still valid?
Yes, the assumptions are still valid.


   •    Changes in Exposure Pathways (OUS)

The 2006 HHRA assessed potentially completed exposure pathways to COPCs in soil and
groundwater. Current workers and future residents, workers, and construction workers were
assumed exposed through ingestion, dermal contact, and vapor inhalation pathways. Vapors that
may intrude into buildings were modeled from groundwater, and vapors that could migrate into
the breathing zone of outdoor workers were modeled from soil. Since public water is currently
available, only future residents and workers were assumed to use groundwater as a potable or


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domestic source.


There have been no known changes in exposure pathways since the time ofthe OUS HHRA.



   •   Changes in Land Use (OUS)

There have been no changes in land use since completion ofthe HHRA. Most ofthe old hat
factory buildings have been torn down with the exception ofthe historic opera house section,
which has been undergoing renovation. Future land use is expected to remain commercial.


OUS is within an area designated by Missouri as Special Area 3 under the Well Construction
Code [lOC.S.R. 23-3.100(7)]. This designation restricts well drilling and is designed to preclude
the installation of wells within an area of groundwater contamination. In addition to this
restriction on groundwater use, institutional controls in the ROD include continued efforts by
EPA to inform and educate property owners where groundwater contamination is located and the
associated potential health risks from exposure.


   •   Changes in Standards, Newly Promulgated Standards, TBCs (OUS)

PCE was the risk driver. Its MCL is 5 ug/L. The only other contaminants in groundwater that
contributed to excess cancer risk above one-in-a-million (1 X 10'^) were carbon tetrachloride and
chloroform. The MCL for carbon tetrachloride is 5 ug/L. The MCL and MCL goal were both
listed for chloroform, 80 ug/L and 70 [Jg/L. The former applies to total trichloromethanes that
may be detected in water. These standards have not changed and there are no newly
promulgated standards.


Since there were no significant risks from exposures to soil, there were changes to be evaluated.


   •   Changes in Toxicity and Other Contaminant Characteristics (OUS)

An oral slope factor from CalEPA is now available for assessing ingestion/dermal exposures to
chloroform. The EPA Regional Screening Level (RSL) (April 2009) of 0.19 |jg/L for screening
tap water is based on this slope factor. The only detection in groundwater at OUS was 0.29


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|.ig/L, and this concentration was qualified with a J, meaning it was estimated. Considering the
MCL for chloroform is identified in the ROD, this change in available toxicity information has
no impact on the protectiveness of remedy.


   •   Changes in Risk Assessment Methods (OUS)

There were no significant changes in risk assessment methodologies that would affect the
protectiveness ofthe remedy. While EPA finalized Risk Assessment Guidance for Superfund
(RAGS): Volume I - Human Health Evaluation Manual, Part E, Supplemental Guidance for
Dermal Risk Assessment in July 2004, there were no significant changes from the interim
guidance, which was followed in the OU3 HHRA (EPA 2003).


Question C: Any Other Information That Could Call Into Question the Protectiveness of
the Remedy at OUS?


   •   Ecological Risks (OUS)

The ecological risk assessment (ERA) conducted in 2002 for the entire Riverfront Site complied
with the latest methodology, "Ecological Risk Assessment Guidance for Superfund: Process for
Designing and Conducting Ecological Risk Assessments" (EPA 1997). Since OUS was not
identified as a potential source area of contamination at the time ofthe ERA, the 2006 OUS Rl
compared OUS data to that collected from OU 1, which is located within 500 yards. Data from
the Missouri River samples and the absence of VOC detections in surface water samples
collected from creeks located near OUS, supported the conclusion that there were no significant
ecological risks being posed from surface water in the vicinity of OUS. The food chain
modeling conducted for the 2002 ERA was also assessed in the 2006 OUS Rl. Since
concentrations of VOCs in soil and groundwater were considerably less than those detected at
OU I, it was reasonable to expect that there would be less contamination and therefore no
significant risk to herbivores at OU5.




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Recent groundwater monitoring results show VOCs less than those detected at OU I during the
time in which the 2002 ERA was conducted. Therefore, the conclusions drawn from the 2002
ERA and the 2006 OUS ERA update remain current and valid.


There is no other information known that could call into question the protectiveness ofthe
remedy.


7.6 OPERABLE UNIT 6 (Domestic Wells)

OU6 is undergoing a remedial investigation. Since a remedy is not in place, no evaluation of
protectiveness has been conducted.

7.7 Technical Assessment Summary

OUl (Front Street)


The OU 1 remedy was declared to be Operational and Functional (O&F) on November 2, 2005.
All groundwater concentrations are below the ACLs so the remedy is meeting the performance
goals. The ROD called for a combination of institutional controls to restrict exposure to shallow
aquifer and soil, proprietary controls, an environmental covenant and easement, installation of an
Advanced Remedial Technology (ART) well and associated equipment, and extension ofthe
monitoring well network to monitor the plume. Institutional controls have been implemented.
The ART well has been operational for about 3 ofthe past 4 years and it appears that it has been
effective when operational.


The exposure assumptions, toxicity data, cleanup levels, and remedial action objectives (RAOs)
used at the time ofthe remedy selection for OU 1 are still valid. No change to potential exposure
pathways was identified that would result in greater exposure opportunity than what was
evaluated in the HHRA. In fact, with implementation of institutional controls, these exposure
pathways become incomplete. There have been no changes in land use that would impact the
protectiveness ofthe remedy.




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OU2 (Keiiwood Industries) 

No remedy has been selected. However, 0U2 is within Special Area 3 and is therefore already 

protected by an institutional control which restricts future well installations. 



OU3 (Old City Dump) 

The remedy is functioning as intended. Institutional controls have been implemented at OU3 to 

enhance the protectiveness ofthe remedy. The City of New Haven granted to the State of 

Missouri an environmental covenant and easement. The environmental covenant is dated April 

14,2008. 


The ROD specified that if PCE concentrations in groundwater samples remained below the MCL 

of 5 |jg/L after the conclusion of I year of quarterly sampling, sampling would be reduced to 

every 5 years. Because PCE was not detected above the MCL during the 2003-2004 quarterly 

monitoring, sampling decreased to once every 5 years. None ofthe May 2008 samples from 

inonitoring wells. Seep M, or nearby domestic wells contained detectable quantities of PCE or 

other volatile contaminants of concern listed in the ROD. 



The exposure assumptions, toxicity data, cleanup levels, and remedial action objectives (RAOs) 

used at the time ofthe remedy selection for OU3 are still valid. Exposure pathways have 

changed in a positive way. Opportunities for exposure to all media (soil, groundwater, and seep 

water) have been minimized or eliminated by institutional controls. There were no significant 

changes in risk assessment methodologies that would affect the protectiveness ofthe remedy. 

There have been no changes in land use that would impact the protectiveness ofthe remedy. 



OU4 (Maiden Lane Area) 

The ROD for OU4 was just recently signed and the remedy for OU4 has not been implemented. 

Therefore, any conclusions regarding remedy protectiveness would be premature. However, 

OU4 is within Special Area 3 and is therefore already protected by an institutional control which 

restricts future well installations. 





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OUS (Old Hat Factory) 

The remedy is functioning as intended. The ROD documented that while the groundwater below 

OUS was contaminated, the risk could be addressed with institutional controls and monitoring. 

Institutional controls have been implemented at OUS and monitoring is ongoing. The exposure 

assumptions, toxicity data, cleanup levels, and remedial action objectives (RAOs) used at the 

time ofthe remedy selection for OUS are still valid. Changes at OUS are likely to result in less 

exposure opportunity than what was conservatively characterized in the HHRA. There were no 

significant changes in risk assessment methodologies that would affect the protectiveness ofthe 

remedy. There have been no changes in land use that would impact the protectiveness ofthe 

remedy. 



OU6 (Domestic Wells) 

No remedy has been selected. However, OU6 is within Special Area 3 and is therefore already 

protected by an institutional control which restricts fijture well installations. 





                                                   67 

                                                                      RIVERFRONT SUPERFUND SITE
                                                                        FIVE-YEAR REVIEW REPORT

8.0 Issues


Table 3: Issues
                                                                  Affects Protectiveness
     Issue #                          Issue                               (Y/N)
                                                                  Current        Future
                   OUl ISSUES
                   Previous removal actions and the ongoing
                   ART well have made an impact on the
                   plume. However, the groundwater
         1                                                          No              No
                   fluctuations have made it difficult to
                   determine the overall effectiveness ofthe
                   system.
                   The groundwater pump in the ART system
        2                                                           No              No
                   has not been functional for the past year.
                   The results of follow-on vapor intrusion
        3                                                           No              No
                   studies have not been formally documented.
                   OU3 ISSUES
                   No written easements with adjacent
                   property owners for access to inonitoring
        4          wells and sampled private wells are in place     No              No
                   and access continues to be through verbal
                   agreement.
                   OUS ISSUES
                   None


The ROD for OU4 was just recently signed and the remedy for OU4 has not been implemented.
The Rl/FS for OU2 and OU6 has not been coinpleted. Therefore, remedies for 0U2 and OU6
have not yet been selected.




                                               68 

                                                                         RIVERFRONT SUPERFUND SITE
                                                                           FIVE-YEAR REVIEW REPORT

9.0 Recommendations and Follow-Up Actions

Below is a list of recommended actions to address the issues identified in section 8.0 above.

 'able 4: Recommendations and Follow-Up Actions
                                                              Party      Oversight    Milestone 

  Issue #    Recommendations/ Follow-up Actions
                                                           Responsible    Agency        Date 

             OUl RECOMMENDATIONS
             If the EPA and MDNR conclude that
             the ART well system is to keep operating
             into the State-lead "Operational &
             Maintenance" phase, the EPA will ensure
             the system is functioning properly and
             operating as designed, before that
      1      transition occurs." Therefore if the ART         EPA         MDNR        Nov 2011 

             well is to remain operational, a remedy
             optimization study should be considered
             to determine if activities such as
             installation of additional instrumentation
             will improve the operations and
             effectiveness ofthe ART well.
             If the EPA and MDNR conclude that
             the ART well system is to keep operating
              into the State-lead "Operational &
             Maintenance" phase, the EPA will ensure
             the system is functioning properly and
     2                                                        EPA         MDNR        Nov 2010 

             operating as designed, before that
             transition occurs." Therefore if the ART
             well is to remain operational, installation
             of a new pneumatic groundwater pump is
             recommended.
             The results ofthe follow-up vapor
     3       intrusion study should be formally               EPA         MDNR        Nov 2010 

             documented in the public record.
             OU3 RECOMMENDATIONS
             Obtain access agreements or easements
     4       for future well sampling required by the         EPA         MDNR        Nov 2013 

             ROD.




                                                69 

                                                                           RIVERFRONT SUPERFUND SITE
                                                                             FIVE-YEAR REVIEW REPORT

10.0 Protectiveness Statements

The remedies at OUl, OU3 and OUS are protective of human health and the environment based
on the nine criteria used in the selection ofthe remedies and due to the use of institutional
controls will eliminate exposure pathways for the short and long term.


The ROD for 0U4 was just recently signed and the remedy for OU4 has not been implemented.
Therefore, any conclusions regarding remedy protectiveness would be premature. However,
0U4 is within an area already protected by an institutional control which restricts future well
installations.


Remedies for OU2 and OU6 have not been selected. However, OU2 and OU6 are within Special
Area 3 and are already protected by this institutional control which restricts future well
installations.




                                                 70 

                                                                        RIVERFRONT SUPERFUND SITE
                                                                          FIVE-YEAR REVIEW REPORT

11. Next Review
The next five-year review for the Riverfront Site in New Haven, Missouri is required by
November 9, 2014, five years from the date of this review.




                                               71 

FIGURES 

                                                                           91 13 30                                                                     9r'l2'3D'


                                                                                                                                                               OU1 t/y




38=*36' 





BS^BS
            Ba>*.- tror.-, V S Ucolosucol Sur.c;. J i t i U l J j t j .   . lUOjOOO. .<»2" L niVk;r.s.; Ir.;ni.LrN<.' McrcalOf projcctior. Z o o c 15
                                                                                                                                                               SCALE

                                                                                                                                                                                3
                                                                                EXPL.AN.MION                                                 D                      2.000   4.000 FEET

                                           NEW H.AVEN CITY LIMIT                                            CZl              0PFR,\BLEL^rr4(0U)

                                           ROAD                                                            Bv,.n             MOMTORING WELL IX BEDROCK. .\ND IDENTIFIER RFD
                                                                                                                             INDir.-MES WELL SAMPLE CONTMNFD MORE TH.\N 1W ug L
                                                                                                                             (MICROCiR.AMS PER LITER* TtTR.->iCHLUROETHENE (PCE. GREEN
                                           STRt.AM                                                                           INDICATES PCE DETECTED BETWEEN :^}.\^D IW ug L. 3LLE
                                                                                                                             INDICATES PCF LES.S THAN 5.0 ug I
                                           MAJOR STREAM
                                                                                                                             PLBLIC-SUPPLV OR INDLSTRIAL WELL AND IDENTIFIER BLUE
                                                                                                              %              INDICATES NO PCt DETECTED. GREENE INDICATE PCE
                                                                                                                             DETECTED BETWEEN 5.0 AND 1») MICRO(iR.AMS PER LITER




                                                        FIGURE 1: Site Figure, Riverfront Superfund Site
                                                        Source: Record of Decision, Riverfront Site, Operable Unit 4, March 2009
                        \//y7.
                                                                    ^i
                         \C^i 	
                         U ' r y ' ^.^ r /   .• - f / J i




                                                                    *llof
                          Wy 	                                      iwn 45 N
                                                                    Rng 3 W
                                                                    See 36
         S e nsit i ve%'p^a'^-r-v'v'-;.,




                                       rtl of               All-J
                                       Twn 44 N             AtestHalf
                  /	                   Rng3W                Twn 44 N
                                       Gee I I              Rng a w '
                                       nurlfi of            Ser'12
                                       Be ouf Creek         north of     /"
                                                            BsuUf
                                                            Creek




                                                                               Figure 2: Special Area 3
                                                                               Riverfront Superfund Site
Source: Missouri Well Regulations (4-09)
                                                               Oiesolved
                                                                Oxygen
                                             .     y /Lq'
                                                            (HOI to •cola)




                                    Figure 3: ART Well
                                    Typical ART well Operations Diagram
                                    Riverfront Superfund Site

Source: Operable Unit 1 RA Report
        ATTACHMENT 1 

SITE INSPECTION PHOTOGRAPHS 

OUl Front Street Site - Bird's eye view with north at top (Bing Maps 2009).




OUl Front Street Site (June 24, 2009) - View between two onsite structures of 

white bam and one of two residences located north of site. 

OUl Front Street Site (June 24, 2009) - ART Treatment System Shed (facing NE
from concrete area).




 OUl Front Street Site (June 24, 2009) - Interior ART Treatment System Shed.
0U2 Keiiwood Site - Bird's eye view with north at top (Bing Maps 2009).




OU2 Keiiwood Site (June 24, 2009) - Facing south along Industrial Drive. 

                                                                               V




   OU2 Keiiwood Site (June 24, 2009) - Area of interim action (facing east).




OU2 Keiiwood Site (June 24, 2009) - Monitoring well and former landfarm area
north of interim action area shown in previous photograph.
  OUS Old City Dump Site - Bird's eye view with north at top (Bing Maps 2009).




0U3 Old City Dump Site (June 24, 2009) - Entrance along Highway C (facing west). 

   0U3 Old City Dump Site (June 24, 2009) - Access Gate (facing north).




OU3 Old City Dump Site (June 24, 2009) - Composting project in background
(facing north).
OU4 Maiden Lane Site - Bird's eye view with north at top
(Bing Maps 2009).




0U4 Maiden Lane Site (June 24, 2009) - Street view of 104 

Maiden Lane (facing south). 

OU4 Maiden Lane Site (June 24, 2009) - Interim action area in background
(facing south).




 OU4 Maiden Lane Site (June 24, 2009) - View to west of TCE hotspot.
OUS Old Hat Factory Site - Bird's eye view with north at top (Bing Maps 2009).




OUS Old Hat Factory Site (June 24, 2009) - Remaining historic opera house section 

remains along Maupin Street (facing north). 

                     T^. 





OUS Old Hat Factory Site (June 24, 2009) - View from former main production
building area facing east and the intersection of Washington and Wall Streets.




        OUS Old Hat Factory Site (June 24, 2009) - Monitoring Well
0U6 Domestic Well Removal Site - Bird's eye view of residence near intersection
of Highway C and Wildcat Creek Lane. Wells on property bound eastern extent of
groundwater plume associated with OU2 Keiiwood Site (north at top) (Bing Map
2009).




OU6 Domestic Well Removal Site (June 24, 2009) - Residence on Bouef
Lutheran Drive. (View south from OU2 Keiiwood Site.)
                ATTACHMENT 2 

SITE INSPECTION CHECKLIST/INSPECTION ROSTER 

                                  Site Inspection Checklist (OUl)

                                           I. SITE INFORMATION
Site name: Riverfront GUI Front Street Site               Date of inspection: June 24, 2009
Location and Region: New Haven, County, Missouri          EPA ID: MOD007452I54
Agency, office, or company leading tiie five-year         Weather/temperature: Sunny, 90s
review: USACE-NWK.
Remedy Includes: (Check all that apply)
        r~| Landfill cover/containment           O Monitored natural attenuation
        ^ Access controls                        CD Groundwater containment
        ^ Institutional controls                 n Vertical barrier walls
        r~l Groundwater pump and treatment
        • Surface water collection and treatment
        ^ Other: Remedy includes Advanced Remedial Technology (ART) Treatment System

Attachments:          Inspection team roster attached         I I Site map attached

                                    II. INTERVIEWS (Check all that apply)
      O&M site manager Rob Blake                  Black and Veatch Corp 	                       6/24/2009
                                       Name Title                         Date
      Interviewed ^ at site • at office • by phone Phone no. 913-458-6681
      Problems, suggestions; O Report attached




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

          Agency     USEPA
          Contact     Jeff Field                        Remedial Proiect Mgr_   June 24. 2009 (913)551-7548
                              Name                            Title                Date        Phone no.
           Problems; suggestions; • Report attached     None




           Other interviews (optional) Q Report attached. Evan Kiffer MDNR




                                           Five-year Review Report - 1
               III. ON-SITE DOCUMENTS & RECORDS VERIFIED (Check all that apply)
1. 	     O&M Documents
         ^ O&M manual                      ^ Readily available     ^ Up to date       • N/A
         ^ As-built drawings               13 Readily available    | 3 Up to date     D N/A
         ^ Maintenance logs                13 Readily available    | 3 Up to date     G N/A
         Remarks Inspection/maintenance loRS dating back to svstem startup. Instruction for inspection and
         maintenance procedures provided (D loes. BSCO electric O&M
                                           n
2. 	     Site-Specific Health and Safety Plan            ^ Readily available ^ Up to date        DN/A
         ^ Contingency plan/emergency response plan ^ Readily available ^ Up to date             DN/A
         Remarks Inspection checklist identifies contact numbers in case of problems.

3. 	     O&M and OSHA Training Records              ^   Readily available      D Up to date      QN/A
         Remarks  O &M Records


4. 	     Permits and Service Agreements
         • Air discharge permit 	                   •   Readily   available    •    Up to date   13 N/A
         • Effluent discharge                       •   Readily   available    •    Up to date   13 N/A
         n Waste disposal, POTW                     •   Readily   available    •    Up to date   13 N/A
         r~| Other permits                          n   Readily   available    fl   Up to date   ^N/A
         Remarks with Citv


5. 	     Gas Generation Records            n Readily available          Q Up to date     ^ N/A
         Remarks


6. 	     Settlement Monument Records                •   Readily available       •   Up to date   13 N/A
         Remarks


7. 	     Groundwater Monitoring Records             ^ Readily available        ^    Up to date   DN/A
         Remarks


8. 	     Leachate Extraction Records                •   Readily available       •   Up to date   13 N/A
         Remarks


9. 	     Discharge Compliance Records
         QAir                              • Readily available          D Up to date     ^ N/A
         n Water (effluent)                n Readily available          D Up to date     ^ N/A
         Remarks


 10. 	   Daily Access/Security Logs                 ^   Readily available       ^   Up to date   DN/A
         Remarks




                                          Five-year Review Report - 2
                                              IV. O&M COSTS
       O&M Organization 

       I I State in-house              Q Contractor for State 

       • PRP in-house                 D Contractor for PRP 

       I I Federal Facility in-house  • Contractor for Federal Facility 

       M Other EPA lead :Contractor Black and Veatch 



       O&M Cost Records 

       ^ Readily available      ^ Up to date 

       I I Funding mechanism/agreement in place 

       Original O&M cost estimate                            •   Breakdown attached 




        Unanticipated or Unusually High O&M Costs During Review Period 

        Describe costs and reasons: Pump replacement after 4 vears 





               V. ACCESS AND INSTITUTIONAL CONTROLS [ 3 Applicable D N/A

A. Fencing
        Fencing damaged            •   Location shown on site map       •   Gates secured         ^ N/A
        Remarks


B. Other Access Restrictions
        Signs and other security measures         ^ Location shown on site map         f"! N/A
        Remarks Lock on remedial building. Part of Special Area 3, public notification well restictions, drilling
        restrictions




                                          Five-year Review Report - 3
C. Institutional Controls (ICs)
I.	     Implementation and enforcement
        Site conditions imply ICs not properly implemented                     • Yes ^ No • N/A
        Site conditions imply ICs not being fully enforced                     • Yes ^ No Q N/A

        Type of monitoring {e.g., self-reporting, drive by) Scheduled Bi-annual monitoring
        Frequency Weeklv OMM checks
        Responsible party/agency EPA Region 7
        Contact      Jeffery Field             Remedial Proiect Manager          June 24.2009 (913)551
        7548
                           Name	                           Title                  Date       Phone no.

        Reporting is up-to-date                                                ^ Yes D No D N/A
        Reports are verified by the lead agency                                ^ Yes • No • N/A

        Specific requirements in deed or decision documents have been met      ^ Yes O No • N/A
        Violations have been reported                                          Q Yes • No ^ N/A
        Other problems or suggestions:      Q Report attached




        Adequacy               ^ ICs are adequate            • ICs are inadequate                • N/A
        Remarks Within Special Area 3
D. General
I.	     Vandalism/trespassing      Q Location shown on site map         ^ No vandalism evident
        Remarks

2.	     Land use changes on site • N/A
        RemarksThere had been no change in land use on site.

        Land use changes off site Q N/A
        Remarks No apparent change in land use in vicinity of site.

                                    VI. GENERAL SITE CONDITIONS
A. Roads         ^ Applicable      Q N/A
        Roads damaged              • Location shown on site map         ^ Roads adequate         • N/A
        Remarks




                                          Five-year Review Report - 4
B.	 Other Site Conditions
        Remarks       None




        Treatment Train (Check components that apply)
        r~l Metals removal            Q Oil/water separation               Q Bioremediation
        ^ Air stripping               ^ Carbon adsorbers
        • Filters 

        r~l Additive {e.g., chelation agent, flocculent)_ 

        n Others 

        [~~| Good condition                   Q Needs Maintenance 

        n Sampling ports properly marked and functional 

        13 Sampling/maintenance log displayed and up to date 

        13 Equipment properly identified 

        r~l Quantity of groundwater treated annually        NA      

        Q Quantity of surface water treated annually 

        Remarks       ART Well (Not fully operational at the time of 

        inspection)

2.	     Electrical Enclosures and Panels (properly rated and functional)
        • N/A            ^ Good condition          • Needs Maintenance 

        Remarks 


        Tanks, Vaults, Storage Vessels
        r~l N/A          ^ Good condition          Q Proper secondary containment Q Needs Maintenance
        Remarks

        Discharge Structure and Appurtenances 

        r~l N/A         ^ Good condition        • Needs Maintenance 

        Remarks     SVE Effluent 


        Treatment Building(s)
        n N/A           ^ Good condition (esp. roof and doorways)          O Needs repair
        I I Chemicals and equipment properly stored
        Remarks

        Monitoring Wells (pump and treatment remedy)
        13 Properly secured/locked      ^ Functioning ^ Routinely sampled         ^ Good condition
        ^ All required wells located     Q Needs Maintenance                      [I] N/A
        Remarks

D. Monitoring Data ­

                                        Five-year Review Report - 5
1. Mo        nitoring Data
          13 Is routinely submitted on time                 ^ Is of acceptable quality
2. Mo        nitoring data suggests:
          ^ Groundwater plume is effectively contained ^ Contaminant concentrations are declining
E. Monitored Natural Attenuation
1.        Monitoring Wells (natural attenuation remedy)
          I I Properly secured/locked        O Functioning • Routinely sampled               • Good condition
          n All required wells located       Q Needs Maintenance                            • N/A
          Remarks Yes, molar study but not part ofthe remedy

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




                                              Five-year Review Report - 6
                             XI. OVERALL OBSERVATIONS

Implementation ofthe Remedy
Describe issues and observations relating to whether the remedy is effective and functioning as designed.
Begin with a brief statement of what the remedy is to accomplish (i.e., to contain contaminant plume,
minimize infiltration and gas emission, etc.).
_De5igned to remove mass at the head ofthe plume. Operating as designed with periodic repairs
_remedial wells screens are acid washed regularly




Adequacy of O&M
Describe issues and observations related to the implementation and scope of O&M procedures. In
particular, discuss their relationship to the current and long-term protectiveness ofthe remedy.
_Yes. continue to work on equipment long term with regular acidification of remedial well screen.




                                  Five-year Review Report - 7
C.   Early Indicators of Potential Remedy Problems
     Describe issues and observations such as unexpected changes in the cost or scope of O&M or a high
     frequency of unscheduled repairs, that suggest that the protectiveness ofthe remedy may be
     compromised in the future.
     Acidification is necessary for continued well function




D.   Opportunities for Optimization
     Describe possible opportunities for optimization in monitoring tasks or the operation ofthe remedy.
      As above




                                      Five-year Review Report - 8
                                Site Inspection Checklist (OU3)

                                         I. SITE INFORMATION

Site name: Riverfront OU3 Front Street Site             Date of inspection: June 24, 2009

Location and Region: New Haven, County, Missouri        EPA ID: MOD007452154

Agency, office, or company leading the five-year        Weather/temperature: Sunny, 90s
review: USACE-NWK
Remedy Includes: (Check all that apply)
        r~l Landfill cover/containment             Q Monitored natural attenuation
        13 Access controls                         I I Groundwater containment
        13 Institutional controls                  n Vertical barrier walls
        I I Groundwater pump and treatment
        I I Surface water collection and treatment
        13 Other: Monitoring

Attachments:        Inspection team roster attached         I I Site map attached

                                  II. INTERVIEWS (Check all that apply)
I. O&M site manager John Schumacher                   USGS
                                    Name    Title                              Date
   Interviewed Q at site Q at office Q by phone Phone no. _
   Problems, suggestions; • Report attached     Not Interviewed_



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

        Agency    USEPA
        Contact     JeffField                         Remedial Proiect Mgr_   June 24. 2009 (913)551-7548
                           Name                             Title                Date        Phone no.
        Problems; suggestions; O Report attached
           None




        Other interviews (optional) \Z\ Report attached.
Evan Kiffer - MDNR RPM - No problems noted




                                         Five-year Review Report - 1
              III. ON-SITE DOCUMENTS & RECORDS VERIFIED (Check all that apply)
1.	     O&M Documents
        ^ O&M manual                      ^ Readily available        | 3 Up to date   D N/A
        n As-built drawings               D Readily available        Q Up to date     ^ N/A
        ^ Maintenance logs                ^ Readily available        ^ Up to date     D N/A
        Remarks Info not present at inspection but fonvarded shortly after inspection

2. 	    Site-Specific Health and Safety Plan         • Readily available •            Up to date      DN/A 

        1 1 Contingency plan/emergency response plan Q Readily available ^            Up to date      DN/A 

        Remarks Well sampling and walk through inspections

3. 	    O&M and OSHA Training Records             ^    Readily available          n Up to date        DN/A 

        Remarks  Inpsection reports available


4. 	    Permits and Service Agreements
        • Air discharge pemiit	                   •    Readily   available        n   Up to   date    13 N/A
        • Effluent discharge                      •    Readily   available        n   Up to   date    13 N/A
        n Waste disposal, POTW                    •    Readily   available        n   Up to   date    ^N/A
        r~| Other permits                         fl   Readily   available        n   Up to   date    13 N/A
        Remarks with Cit^'


5. 	    Gas Generation Records           •   Readily available         •     Up to date       ^ N/A
        Remarks


6. 	    Settlement Monument Records               •    Readily available          n Up to date        ^N/A
        Remarks


7. 	    Groundwater Monitoring Records            ^ Readily available             ^   Up to date      DN/A
        Remarks


8. 	    Leachate Extraction Records               •    Readily available          n Up to date        13 N/A
        Remarks


9. 	    Discharge Compliance Records
        n Air                            n Readily available           • Up to date           ^ N/A
        n Water (effluent)               D Readily available            D U p to date         ^ N/A
        Remarks


10. 	   Daily Access/Security Logs                •    Readily available          n Up to date        13 N/A
        Remarks




                                        Five-year Review Report -;
                                             IV. O&M COSTS
       O&M Organization 

       r~l State in-house              Q Contractor for State 

       • PRP in-house                   | 3 Contractor for PRP
       • Federal Facility in-house      • Contractor for Federal Facility 

       ^ Other Joint Inspections with Civ of New Haven and contractor (USGS) 


       O&M Cost Records 

       r~l Readily available    • Up to date 

       13 Funding mechanism/agreement in place 

       Original O&M cost estimate                           Q Breakdown attached 



       Unanticipated or Unusually High O&M Costs During Review Period 

       Describe costs and reasons: None 





               V. ACCESS AND INSTITUTIONAL CONTROLS ^Applicable D N/A
A. Fencing
1.	     Fencing damaged        • Location shown on site map            ^ Gates secured           Q N/A
        Remarks Fencing intact



B. Other Access Restrictions
        Signs and other security measures         O Location shown on site map           Q N/A
        Remarks_Gated and locked, no trespassing and site description signs in place




                                         Five-year Review Report - 3
C. Institutional Controls (ICs)
        Implementation and enforcement
        Site conditions imply ICs not properly implemented	                      Q Yes ^ No \Z\ N/A
        Site conditions imply ICs not being fully enforced	                      • Yes ^ No • N/A

        Type of monitoring {e.g., self-reporting, drive by) _inspection annually and groundwater monitoring
        every 5

        Responsible party/agency      Citv of New Haven/EPA

        Contact       Jeffery Field           Remedial Proiect Manager           June 24,2009 (913)551-7548
                            Name                        Title                        Date       Phone no.

        Reporting is up-to-date                                                  ^ Yes D No Q N/A
        Reports are verified by the lead agency                                  ^ Yes • No • N/A

        Specific requirements in deed or decision documents have been met        ^ Yes O No • N/A
        Violations have been reported	                                           • Yes ^ No • N/A
        Other problems or suggestions:      Q Report attached




        Adequacy                  ^ ICs are adequate           • ICs are inadequate               Q N/A
        Remarks: Restrictive covenant filed by citv in place. Site on the Missouri Registry of Confirmed
        Abandoned or Uncontrolled Hazardous Waste Disposal Sites. Any substantial change in property use
        must be approved by MDNR.
D. General
        Vandalism/trespassing      Q Location shown on site map           ^ No vandalism evident
        Remarks

        Land use changes on site • N/A
        Remarks There had been no change in land use on site._

        Land use changes off site Q N/A
        Remarks No apparent change in land use in vicinity of site.

                                      VI. GENERAL SITE CONDITIONS
A. Roads          g] Applicable       DN/A
1.	     Roads damaged                 Q Location shown on site map        ^ Roads adequate         f l N/A 

        Remarks 





                                            Five-year Review Report - 4
B. Other Site Conditions
        Remarks        None




                              VII. LANDFILL COVERS           Q Applicable 3 N/A

A. Landfill Surface: Inspected but landfill cover requirement not spelled out in ROD
1. 	    Settlement (Low spots)               • Location shown on site map           ^ Settlement not evident
        Areal extent                         Depth 

        Remarks 



2. 	    Cracks                               •   Location shown on site map         ^ Cracking not evident
        Lengths                 W   idths                  Depths
        Remarks


3. 	    Erosion                              • Location shown on site map           [ 3 Erosion not evident
        Areal extent                         Depth
        Remarks


4. 	    Holes                                n Location shown on site map           ^   Holes not evident
        Areal extent                         Depth
        Remarks


5. 	    Vegetative Cover           ^ Grass                ^ Cover properly established ^ No signs of stress
        G Trees/Shrubs (indicate size and locations on a diagram)
        Remarks


6. 	    Alternative Cover (armored rock, concrete, etc.)                  •   N/A
        Remarks


7. 	    Bulges                               • Location shown on site map           ^ Bulges not evident
        Areal extent                         Height
        Remarks




                                            Five-year Review Report - 5
        Wet Areas/Water Damage           ^ Wet areas/water damage not evident 

        O Wet areas                      O Location shown on site map       Areal extent_ 

        r~l Ponding                       H
                                         C Location shown on site map       Areal extent_ 

        ^ Seeps                          0 Location shown on site map       Areal e,xtent_ 

        r~l Soft subgrade                1 I Location shown on site map      Areal extent_ 

        Remarks Seeps previously identified in ROD and sampling required. 


        Slope Instability       • Slides     n Location shown on site map ^ No evidence of slope instability
        Areal extent
        Remarks

B.	 Benches               • Applicable | 3 N/A
        (Horizontally constructed mounds of earth placed across a steep landfill side slope to interrupt the slope
        in order to slow down the velocity of surface runoff and intercept and convey the runoff to a lined
        channel.)
C.	 Letdown Channels • Applicable ^ N/A
        (Channel lined with erosion control mats, riprap, grout bags, or gabions that descend down the steep side
        slope ofthe cover and will allow the runoff water collected by the benches to move off of the landfill
        cover without creating erosion gullies.)




                                           Five-year Review Report - 6
D. Cover Penetrations      •   Applicable    ^ N/A


E. Gas Collection and Treatment              •       Applicable    13 N/A
F. Cover Drainage Layer                          •   .Applicable               ^ N/A Existing Drainage Adequate

G. Detention/Sedimentation Ponds                 •   Applicable                13 N/A

H. Retaining Walls                  n Applicable          ^ N/A

1. Perimeter Ditches/Off-Site Discharge                   •   Applicable       | 3 N/A                ;

1. 	     Siltation         Q Location shown on site map            ^ Siltation not evident
         Areal extent                     Depth
         Remarks


2. 	     Vegetative Growth       • Location shown on site map                  • N/A
         ^ Vegetation does not impede flow
         Areal extent                     Type
         Remarks


3. 	     Erosion                    •	   Location shown on site map            ^ Erosion not evident
         Areal extent                         Depth
         Remarks


4. 	     Discharge Structure       ^ Functioning          • N/A
         Remarks .'\dequate surface drainage


                        VIH. VERTICAL BARRIER WALLS                        •   Applicable ^ N/A


            IX. GROUNDWATER/SURFACE WATER REMEDIES                                •      Applicable       | 3 N/A

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




                                            Five-year Review Report - 7
                             XI. OVERALL OBSERVATIONS
Implementation ofthe Remedy
Describe issues and observations relating to whether the remedy is effective and functioning as designed. 

Begin with a brief statement of vvhat the remedy is to accomplish (i.e., to contain contaminant plume, 

minimize infiltration and gas emission, etc.). 

Restrictive Covenant in place. No contamination in adjacent wells 





Adequacy of O&M
Describe issues and observations related to the implementation and scope of O&M procedures. In
particular, discuss their relationship to the current and long-term protectiveness ofthe remedy.
None




                                  Five-year Review Report - 8
     Early Indicators of Potential Remedy Problems
     Describe issues and observations such as unexpected changes in the cost or scope of O&M or a high
     frequency of unscheduled repairs, that suggest that the protectiveness ofthe remedy may be
     compromised in the future.
     None




D.   Opportunities for Optimization
     Describe possible opportunities for optimization in monitoring tasks or the operation ofthe remedy.
      Site Currently used as tree and brush site and compost facility. Citv would like to
     store sand and gravel at the site




                                      Five-year Review Report - 9
                                Site Inspection Checklist (OU4)

                                           I. SITE INFORMATION
Site name: Riverfront Site - 0U4 	                       Date of inspection: June 24, 2009
Location and Region: New Haven, Franklin County,         EPA ID: MOD981720246
Missouri
Agency, office, or company leading the five-year         Weather/temperature: Sunny, 80s
review: U.S. EPA Region 7
Remedy Includes: (Check all that apply)
        r~l Landfill cover/containment             Q Monitored natural attenuation
        ^ Access controls                          • Groundwater containment
        • Institutional controls                   • Vertical barrier walls
        Q Groundwater pump and treatment
        r~l Surface water collection and treatment
        13 Other: Soil source area treatment with in situ chemical oxidation
        13 Other: G roundwater long-term monitoring
Attachments:        Inspection team roster attached           I I Site map attached
                                     II. INTERVIEWS (Check all that apply)
1.	 O&M site manager      NA
                                    Name Title
                                    name i lue                           Date
                                                                         u                                       

   Interviewed O at site • at office • by phone Phone no. 

   Problems, suggestions; • Report attached     Remedy not implemented yet 




2. O & M staff
                           Name Title                                    Date
   Interviewed Q at site O at office \Z\ by phone Phone no.
   Problems, suggestions; Q Report aftached


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

        Agency     USEPA Region 7
        Contact    JeffField. Remedial Proiect Manager                 June 24, 2009             913-551-7548
                            Name                            Title                  Date          Phone no.
        Problems; suggestions; Q Report attached     Project is in RD phase to develop soil source chemical
        oxidation design and Long term monitoring plan.



        Other interviews (optional) Q Report attached. Evan Kiffer



                                           Five-year Review Report - I
              III. ON-SITE DOCUMENTS & RECORDS VERIFIED (Check all that apply)
        0U4 is in the RD phase for soil source treatment and LTM Plan development. No On-site documents
        are available to review yet.



                                              IV. O&M COSTS
         0U4 is in the RD phase for soil source treatment and LTM Plan development, No On-site documents
         are available to review yet.




               V. ACCESS AND INSTITUTIONAL CONTROLS | 3 Applicable •                         N/A

A. Fencing

1. 	    Fencing damaged           •   Location shown on site map        •   Gates secured          13 N/A


B. Other Access Restrictions

1. 	    Signs and other security measures           •   Location shown on site map          ^N/A



C. Institutional Controls (ICs)
I.	     Implementation and enforcement
        Site conditions imply ICs not properly implemented                       •   Yes ^ No • N/A
        Site conditions imply ICs not being flilly enforced                      •   Yes ^ No • N/A

        Type of monitoring {e.g., self-reporting, drive by) Visual inspection of OU4 area.
        Frequency Inspections as part ofthe Five year review process.
        Responsible party/agency EPA/State of Missouri
        Contact _ JeffField. Remedial Proiect Manager                June 24, 2009             913-551-7548
                           Name	                          Title                    Date           Phone no.

        Reporting is up-to-date                                                  13 Yes D N o      • N/A 

        Reports are verified by the lead agency                                  13 Yes • N o      • N/A 

        Specific requirements in deed or decision documents have been me t
                                                                     ;en met     M Yes • No • N/A
        Violations have been reported 	                                          • Yes • No 13 N/A
        Other problems or suggestions:       • Report aftached
              0U4 is contained with Special Area 3. Area 3, as defined in 10 CSR 23-3.100(7), which requires
        that the MDNR be consulted before construction a new well in Special Area 3. The MDNR will provide
        specific guidance on well drilling protocol and construction specifications on a case-by-case basis. The
        MDNR will provide written approval for all new wells prior to construction. The MDNR first filed
        Special Area 3 on March 21, 2005, and re-filed on September 27, 2005. Special Area 3 became
        effective on April 30, 2006.




                                          Five-year Review Report - 2
        Adequacy                 ^ ICs are adequate          • ICs are inadequate                • N/A
        Remarks Reviewed te.xt of 10 CSR 23-3.100(7),
D. General
1.	     Vandalism/trespassing     • Location shown on site map          ^ No vandalism evident
        Remarks

        Land use changes on site ^ N/A 

        Remarks There had been no change in land use on site. 


        Land use changes off site ^ N/A 

        Remarks No apparent change in land use in vicinity of site. 


                                   VI. GENERAL SITE CONDITIONS
A. Roads         ^Applicable      • N/A
        Roads damaged           • Location shown on site map      ^ Roads adequate               • N/A
        Remarks Roads used to access 0U4 area during inspection were adequate.

B.	 Other Site Conditions
        Remarks All areas inspected were in very good condition and appeared to be well maintained.




                           VII. LANDFILL COVERS •              Applicable | 3 N/A
                     VIII. VERTICAL BARRIER WALLS                 •Applicable | 3 N/A

             IX. GROUNDWATER/SURFACE WATER REMEDIES ^Applicable                             • N/A

A. Groundwater Extraction Wells, Pumps, and Pipelines	                          • Applicable     ^ N/A

B. Surface Water Collection Structures, Pumps, and Pipelines            •Applicable     ^ N/A
C. Treatment System               • Applicable      ^ N/A
D. Monitoring Data - LTM Plan is still under development. Monitoring wells were observed and are in good
condition.
E. Monitored Natural Attenuation or LTM             ^   Applicable      • N/A
1.	     Monitoring Wells (natural attenuation remedy or LTM Plan)
        ^ Properly secured/locked          • Functioning • Routinely sampled           • Good condition
        • All required wells located       • Needs Maintenance                         • N/A
        Remarks Wells needed for LTM are not yet defined.




                                         Five-year Review Report - 3
                        X. OTHER REMEDIES • Applicable | 3 N/A
If there are remedies applied at the site which are not covered above, attach an inspection sheet describing
the physical nature and condition of any facility associated with the remedy. An example would be soil
vapor extraction.




                                     Five-year Review Report - 4
                                  XI. OVERALL OBSERVATIONS 

A.   Implementation of the Remedy
     Describe issues and observations relating to whether the remedy is effective and functioning as designed.
     Begin with a brief statement of vvhat the remedy is to accomplish (i.e., to contain contaminant plume,
     minimize infiltration and gas emission, etc.).
      NA



     Adequacy of O&M
     Describe issues and observations related to the implementation and scope of O&M procedures. In
     particular, discuss their relationship to the current and long-term protectiveness ofthe remedy.
      NA




     Early Indicators of Potential Remedy Problems
     Describe issues and observations such as unexpected changes in the cost or scope of O&M or a high
     frequency of unscheduled repairs that suggest that the protectiveness ofthe remedy may be compromised
     in the future.
      NA




     Opportunities for Optimization
     Describe possible opportunities for optimization in monitoring tasks or the operation ofthe remedy.




                                       Five-year Review Report - 5
                                Site Inspection Checklist (OUS)

                                         I. SITE INFORMATION
Site name: Riverfront Site - OUS                              Date of inspection: June 24, 2009
Location and Region: New Haven, Franklin County,              EPA ID: MOD981720246
Missouri
Agency, office, or company leading the five-year              Weather/temperature: Sunny, 80s
review: U.S. EPA Region 7
Remedy Includes: (Check all that apply)
        • Landfill cover/containment                      I I Monitored natural attenuation
        • Access controls                                 I I Groundwater containment 

        ^ Institutional controls                          I I Vertical barrier walls 

        • Groundwater pump and treatment 

        I I Surface water collection and treatment    

        13 Other: Lon g term monitoring 


Attachments:        Inspection team roster attached               I I Site map attached

                                   IL INTERVIEWS (Check all that apply)
I. O&M site manager Robert Blake                Black and Veatch                                  6/24/2009
                                    Name Title           Date 

   Interviewed ^ at site • at office • by phone Phone no. 

   Problems, suggestions; • Report attached 





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

        Agency    USEPA Region 7
        Contact   JeffField. Remedial Proiect Manager              June 24. 2009                      913-551-7548
                           Name                          Title                 Date                   Phone no.
        Problems; suggestions; • Report attached
        Sampling is ongoing under the Long Term Remedial Action Sampling Plan.



4.      Other interviews (optional) •   Report attached. Evan Kiffer




                                         Five-year Review Report - 1
               III. ON-SITE DOCUMENTS & RECORDS VERIFIED (Check all that apply)

I.	      O&M Documents
         No o n - g o i n g O&M a t 0U5.        LTM P l a n i n p l a c e       for   remedy.

2. 	     Site-Specific Health and Safety Plan            ^ Readily available • Up to date    • N/A
         • Contingency plan/emergency response plan • Readily available • Up to date         • N/A
         Remarks A site-specific health and safety plan for LTRA was prepared by Black and Veatch in 2007
         and is available for review and use.
3.       OSHA Training R e c o r d s ^ Readily available •     Up to date              •   N/A
         Remarks


4. 	     Permits and Service Agreements
         • Air discharge permit                        •   Readily    available        •   Up to   date    13 N/A
         • Effluent discharge                          •   Readily    available        •   Up to   date    13 N/A
         • Waste disposal, POTW                        •   Readily    available        •   Up to   date    13 N/A
         n Other permits                               •   Readily    available        •   Up to   date    13 N/A
         Remarks


5. 	     Gas Generation Records             •     Readily available         •     Up to date     ^ N/A
         Remarks


6. 	     Settlement Monument Records                   •   Readily available           •   Up to date      13 N/A
         Remarks


7. 	     Groundwater Monitoring Records                ^ Readily available             ^ Up to date        • N/A
         Remarks


8. 	     Leachate Extraction Records                   •   Readily available           •   Up to date      13 N/A
         Remarks


9. 	     Discharge Compliance Records
         • Air                              •     Readily available         •     Up to date       ^ N/A
         • Water (effluent)                 •     Readily available         •     Up to date       ^ N/A
         Remarks


 10. 	   Daily Access/Security Logs                    •   Readily available           •   Up to date      13 N/A
         Remarks




                                           Five-year Review Report - 2
                                            IV. O&M COSTS
        O&M Organization
        • State in-house                 • Contractor for State
        • PRP in-house                   • Contractor for PRP
        I I Federal Facility in-house     • Contractor for Federal Facility
        13 Other: Contractor to EPA

        O&M Cost Records
        ^ Readily available      ^ Up to date
        I I Funding mechanism/agreement in place
        Original O&M cost estimate                        • Breakdown attached


        Unanticipated or Unusually High O&M Costs During Review Period
        Describe costs and reasons: ^None Sampling only




               V. ACCESS AND INSTITUTIONAL CONTROLS | 3 Applicable • N / A
A. Fencing
I.	     Fencing damaged           • Location shown on site map        • Gates secured            ^ N/A
        Remarks
B. Other Access Restrictions
        Signs and other security measures          • Location shown on site map         13 N/A
        Remarks
C. Institutional Controls (ICs)




                                        Five-year Review Report - 3
       Implementation and enforcement
       Site conditions imply ICs not properly implemented	                      •   Yes ^ No     •   N/A
       Site conditions imply ICs not being ftilly enforced	                     •   Yes ^ No     •   N/A

       Type of monitoring {e.g., self-reporting, drive by) _Visual Inspection of OUS area.
       Frequency Inspections as part regular sampling events and the Five year review process.
       Responsible party/agency EPA/State of Missouri
       Contact     JeffField. Remedial Proiect Manager            _ J u n e 24, 2009       913-551-7548
                          Name	                           Title                      Date     Phone no.
       Reporting is up-to-date                                                  13 Yes • N o • N/A 

       Reports are verified by the lead agency                                  13 Yes • No • N/A 

       Specific requirements in deed or decision documents have been met        13 Yes • N o • N/A
       Violations have been reported 	                                          • Yes • No ^ N / A
       Other problems or suggestions:       • Report attached
             OUS is contained with Special Area 3. Area 3, as defined in 10 CSR 23-3.100(7), which requires
       that the MDNR be consulted before construction a new well in Special Area 3. The MDNR will provide
       specific guidance on well drilling protocol and construction specifications on a case-by-case basis. The
       MDNR will provide written approval for all new wells prior to construction. The MDNR first filed
       Special Area 3 on March 21, 2005, and re-filed on September 27, 2005. Special Area 3 became
       effective on April 30, 2006.




2.	    Adequacy               ^ ICs are adequate              •   ICs are inadequate             •   N/A
       Remarks Reviewed text of 10 CSR 23-3.100(7)^
D. General

1.	     Vandalism/trespassing     •    Location shown on site map     ^   No vandalism evident
        Remarks                           .


2.	    Land use changes on site • N/A
       Remarks Land use was previously commercial. Construction is on-going on site for site
       redevelopment.


3.	     Land use changes off site • N/A
        Remarks No apparent change in land use in vicinity of site.


                                      VI. GENERAL SITE CONDITIONS

A. Roads         13 Applicable    •    N/A

1.	     Roads damaged           • Location shown on site map      ^ Roads adequate               •   N/A
        Remarks Roads used to access OUS during inspection were adequate.


B. Other Site Conditions




                                          Five-year Review Report - 4
          Remarks All areas inspected were in very good condition and appeared to be well maintained.

                              VII. LANDFILL COVERS             •Applicable | 3 N/A 

                       VIH. VERTICAL BARRIER WALLS                    •Applicable | 3 N/A 


             IX. GROUNDWATER/SURFACE WATER REMEDIES                           | 3 Applicable     • N/A 


A. Groundwater Extraction Wells, Pumps, and Pipelines	                             • Applicable       ^ N/A

B. Surface Water Collection Structures, Pumps, and Pipelines                •Applicable      13 N/A
C. Treatment System                  • Applicable       ^ N/A
D. Monitoring Data
1. Mo        nitoring Data
          13 Is routinely submitted on time                 ^ Is of acceptable quality
2. Mo        nitoring data suggests:
          13 Groundwater plume is effectively contained • Contaminant concentrations are declining
E. Monitored Natural Attenuation or LTM                 ^   Applicable • N/A
I.	       Monitoring Wells (natural attenuation remedy or LTM Plan)
          ^ Properly secured/locked          | 3 Functioning ^ Routinely sampled            ^ Good condition
          • All required wells located       • Needs Maintenance                            • N/A
          Remarks

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




                                              Five-year Review Report - 5
                                  XI. OVERALL OBSERVATIONS
     Implementation ofthe Remedy

     Describe issues and observations relating to whether the remedy is effective and functioning as designed.
     Begin with a brief statement of what the remedy is to accomplish (i.e., to contain contaminant plume,
     minimize infiltration and gas emission, etc.).
      Monitoring is conducted per ROD & I C s in place




B.   Adequacy of O&M
     Describe issues and observations related to the implementation and scope of O&M procedures. In
     particular, discuss their relationship to the current and long-term protectiveness ofthe remedy.
      Contamination in farthest down gradient well but no room for additional wells down
     gradient due to topography. Contamination in down gradient would be detected in
     upgradient well of OUl                                                    >_



C.   Early Indicators of Potential Remedy Problems
     Describe issues and observations such as unexpected changes in the cost or scope of O&M or a high
     frequency of unscheduled repairs, that suggest that the protectiveness ofthe remedy may be
     compromised in the future.
       None noted



D.   Opportunities for Optimization
     Describe possible opportunities for optimization in monitoring tasks or the operation ofthe remedy.
      None Noted




                                       Five-year Review Report - 6
                              Site Inspection Team Roster

Personnel                     Representing                     Phone Number

JeffField                     EPA                              913-551-7548

Robert Blake                  Black and Veatch                 816-458-6681

Evan Kifer                    MDNR                             573-751-1990

Lee Gorday (OU2 & 0U6 only)   Parsons                          314-576-7330

Phil Rosewicz                 USAGE                            816-389-3902

Greg Hattan                   USAGE                            816-389-3579

Debra Snodgrass               USAGE                            816-389-3574

Amy Darpinian                 USAGE                            816-389-3897




                                 Five-year Review Report - 7
  ATTACHMENT 3 

GROUNDWATER DATA 

                  0U1
                    Final
Spring 2009 Sampling Data Evaluation Report
         Riverfront Superfund Site
           New Haven, Missouri

             Operable Unit 1 

             Front Street Site 

                                                                                                             BOAT RAMP




                                                                                                      Sewage lagoon




SOURCE: USGS OUl Rl
                                                                                                SCALE

                                            EXPLANATION                                             100      200 FEET

                      STREAM                                      O    NEW RA MONITORING WELLS (TW-H, -I AND -J)
                      BUILDING 
                           U
                                                          O i-TW-A g    EXISTING MONITORING WELL
                                                                       AND NUMBER 

                      FRONT STREET SITE PROPERTY LINE 

                                                                 ®     ART WELL, ART-1 AND PIEZOMETERS
                      APPROXIMATE AREA CONTAINING COCs ABOVE           PZ-1 AND PZ-2
                      THE MCL OF 5.0 MICROGRAMS PER LFFER


                      APPROXIMATE AREA CONTAINING COCs ABOVE 

                      500 MICROGRAMS PER LITER 


                                                                            FIGURE 1
                      NOTE:                                                 APPROXIMATE EXTENT OF PCE
                      \. COCs ARE PCE, TCE, C-DCE AND VC                    GROUNDWATER PLUME,
                      2.	 WELL G SHOWN IN THE CORE OF THE                   MAY 2009
                          PLUME EVEN THOUGH IT'S COCs ONLY 

                          TOTAL 90 ug/L. 
                                  OPERABLE UNIT I
                      3.	 HIGH GROUNDWATER LEVELS MAY HAVE                  RIVERFRONT SUPERFUND SITE
                          BIASED THE SAMPLE                                 OPERABLE UNIT I LTRA
                          RESULTS LOW, ESPECL\LLY AT WELLS
                          B, C.ANDD                                         Z:\044722\NEW HAVENOU 1 \USGS\C0008420 07/01/2009
Table 2
OU 1 Remedial Action Groundwater Results
 From the End of Rl Sampling (7/23/02) to Spring (5/26/09) 2009 Sampling

Well A                         Date        7/23/2002       7/24/2003        4/21/2005       5/31/2005        9/20/2005    12/13/2005
Parameter                      Units         Pump            Pump             Pump                              PDB          PDB
cis-1,2-Dichloroethene         ug/L               1 U             1 U             10 U           NS                 5 U          1 UJ
Tetrachioroethene              ug/L               1 U             1 U             10 U           NS                 5 U          1 U
Trichloroethene                ug/L               1 U             1 U             10 U           NS                 5 U          1 UJ
Vinyl Chloride                 ug/L               2 U             2 U             10 U           NS                 5 U          1 U

                               Date        2/15/2006       5/23/2006        8/15/2006       11/14/2006
Parameter                      Units          PDB             PDB              PDB             PDB
cis-1,2-Dichloroethene         ug/L             0.5 U             1 U              1 U           0.5 U
Tetrachioroethene              ug/L             1.3               1 U              1 U           0.5 U
Trichloroethene                ug/L             0.5 U             1 U              1 U           0.5 U
Vinyl Chloride                 ug/L             0.5 U             1 UJ             1 U           0.5 U

                               Date        3/8/2007        5/22/2007        8/14/2007       3/11/2008                     10/27/2008
Parameter                      Units         PDB              PDB              PDB             PDB             PDB        Upper Pump    Lower Pump
cis-1,2-Dichloroethene         ug/L             0.5   U           1 U              1 U             1 U            1   U          1 U           1 U
Tetrachioroethene              ug/L             0.5   U           1 U             10 U             1 U            1   U          1 U           1 U
Trichloroethene                ug/L             0.5   U           1 U              1 U             1 U            1   U          1 U           1 U
Vinyl Chloride                 ug/L             0.5   U           1 U              1 U             1 U            1   U          1 U           1 U

                               Date        5/26/2009
Parameter                      Units          PDB
cis-1,2-Dichloroethene         ug/L             0.5 U
Tetrachioroethene              ug/L             0.5 U
Trichloroethene                ug/L             0.5 U
Vinyl Chloride                 ug/L             0.5 U

In February 2006, Acetone was detected at 7.9 ug/L and Cyclohexane was detected at 0.56 ug/L.
In November 2006, Cyclohexane was detected at 1.7 ug/L.
In March 2007, Cyclohexane was detected at 2,1 ug/L.                                  PDB - Passive Diffusion Bag
In May 2009, Acetone was detected at 12 ug/L.                                         Pump - Perstaltic Pump
For all PDB samples, Well A was sampled at 31 ft.                                     NS - Not Sampled
U - Not detected. Number Is the detection limit.
UJ ­ Not detected. Number is the detection limit. The detection limit is an estimate.



9/9/2009                                                                         1 of 14
Table 2 (Continued)
OU 1 Remedial Action Groundwater Results
From the End of Rl Sannpling (7/23/02) to Spring (5/26/09) 2009 Sampling

Well B
1                              Date        7/23/2002        7/24/2003        4/21/2005          5/31/2005            9/20/2005       12/13/2005
Parameter                      Units         Pump             Pump             Pump                                     PDB             PDB
cis-1,2-Dichloroethene         ug/L               1 U             1 U              10 U                 NS                  5 U            1.5
Tetrachioroethene              ug/L            0.32 J             1 U              10 U                 NS                  5 U           4.7
Trichloroethene                ug/L               1 U             1 U              10 U                 NS                  5 U            1.5 J
Vinyl Chloride                 ug/L               2 U             2 U              10 U                 NS                  5 U              1 U
Methyl Tert-Butyl Ether        ug/L               2 U             2 U              10 U                 NS                  5 U            1.8 J

                               Date        2/15/2006        5/23/2006        8/15/2006          11/14/2006
Parameter                      Units          PDB              PDB              PDB                PDB
cis-1,2-Dichloroethene         ug/L             3.6               1 U             1.2                    1.1
Tetrachioroethene              ug/L              11             7.3               3.3                    4.9
Trichloroethene                ug/L               3               1 U             1.2                      1
Vinyl Chloride                 ug/L             0.5 U             1 UJ              1 U                  0.5 U
Methyl Tert-Butyl Ether        ug/L             0.5 U             1 UJ              1 U                 0.77

                               Date         3/8/2007        5/22/2007        8/14/2007          3/11/2008                                     10/28/2008
Parameter                      Units          PDB              PDB              PDB                PDB                 PDB          Upper Pump    Upper Pump (DUP)   Lower Pump
cis-1,2-Dichloroethene         ug/L            0.67               1 U               1 U                 1.1                 1 u             1 U              1 U             1 U
Tetrachioroethene              up/L                7              1 U             1.3                   2.1                 1 u           3.0              2.9            2.7
Trichloroethene                ug/L            0.68               1 U               1 U                     1 u             1 u             1 U              1 U             1 U
Vinyl Chloride                 ug/L              0.5 U            1 U                1 u                    1 u             1 U             1 U              1 U             1 U
Methyl Tert-Butyl Ether        ug/L            0.89             1.5                1.6                  3.6               2.3             1.8              1.8             1.8

                               Date                   5/26/2009        1
Parameter                      Units          PDB             PDB DUP
cls-1,2-Dichloroethene         ug/L             0.5    U         0.5 U
Tetrachioroethene              ug/L             0.5    U         0.5 U
Trichloroethene                ug/L             0.5    U         0.5 U
Vinyl Chloride                 ug/L             0.5    U         0.5 U
Methyl Tert-Butyl Ether        ug/L               2                2

In February 2006, Acetone was detected at 60 ug/L and Cyclohexane at 0.93 ug/L.                               NS - Not Sampled
In November 2006, Cyclohexane at 2.8 ug/L.                                                                    U - Not detected. Number is the detection limit.
In May 2007, Bromoform was detected in the sample and in the LDL trip blank at 1.2 ug/L.                      J - Result is an estimate.
In May 2009, Cyclohexane at 0.6 ug/L.
For all PDB samples. Well B was sampled at 31 ft.                                                             Pump - Perstaltic Pump
PDB - Passive Diffusion Bag




9/9/2009                                                                                   2 of 14
 Table 2 (Continued)
 OU 1 Rennedial Action Groundwater Results
 Fronn the End of Rl Sampling (7/23/02) to Spring (5/26/09) 2009 Sampling

WellC                           Date        7/23/2002       4/9/2003       7/24/2003       4/21/2005              5/31/2005             9/20/2005   12/13/2005
Parameter                       Units         Pump            Pump           Pump            Pump            PDB *            Pump         PDB        PDB"
cls-1,2-Dlchloroethene          ug/L             23              21            6.5           3,700            250              180         470          310
Tetrachioroethene               ug/L             23              14             10           5,000            140              410         320          260
Trichloroethene                 ug/L            9.5             4.8            3.6           2,300            140              150         210          220
Vinyl Chloride                  ug/L           0.69 J             1 J            2 U         1,000 U           2.5 U            7.6 U         5 U         5 U

                                Date        2/15/2006       5/23/2006      8/15/2006      11/14/2006        3/8/2007              5/22/2007         8/14/2007
Parameter                       Units         Bailer           PDB            PDB            PDB              PDB             PDB        PDB DUP       PDB
cis-1,2-Dlchloroethene          ug/L           610              130            110             94              170             79            77         7.9
Tetrachioroethene               ug/L         1,100              150            210            180              500            330           320         48
Trichloroethene                 ug/L           170              110             60             20              150             79            80           8
Vinyl Chloride                  ug/L            10 U              5 U            5 U             5 U             5 UJ           5 U           5 U         5 U

                                Date                3/11/2008                              10/29/2008
Parameter                       Units         PDB           PDB DUP           PDB            Pump         Pump DUP
cls-1,2-Dichloroethene          ug/L           39               35             340           1,000         1,100
Tetrachioroethene               ug/L          190              210             160             450           450
Trichloroethene                 ug/L           40               35             110             300           300
Vinyl Chloride                  ug/L            5     U          5 U             5 U             5 U           5 U

                               Date                 5/26/2009        1
 Parameter                     Units          PDB           PDB DUP
 cis-1,2-Dlchloroethene        ug/L            25               22
 Tetrachioroethene             ug/L           200              200
rrrichloroethene               ug/L            25               25
(vinyl Chloride                ug/L             5     U          5 U

In December 2005, Acetone was detected at 7.6 ug/L.                                PDB - Passive Diffusion Bag
In May 2006, Acetone was detected at 480 J ug/L.                                   Pump - Perstaltic Pump
In October 2008, t-DCE was detected In the Primary sample at 6.2 ug/L and in the duplicate sample at 6.0 ug/L.
In May 2009, methylene chloride was detected In the duplicate sample at 5.4 ug/L.
For the PDB samples through May 2006, Well C was sampled at 30 ft.                 U - Not detected. Number is the detection limit.
* - Results may be biased low. Vial cap was not tight.                             J - Result Is an estimate.
" - Results may be inaccurate or biased low, since PDB was not completely submerged.




9/9/2009                                                                                    3 of 14
Table 2 (Continued)
OU 1 Remedial Action Groundwater Results
From the End of Rl Sampling (7/23/02) to Spring (5/26/09) 2009 Sampling
WellD                         Date        7/23/2002    4/9/2003         7/24/2003        4/21/2005    5/31/2005       9/20/2005    12/13/2005
Parameter                     Units         Pump        Pump              Pump             Pump                          PDB          PDB
cis-1,2-Dichloroethene        ug/L             1.1          1.6             0.98 J             10 U       NS                 5 U          1 U
Tetrachioroethene             ug/L             1.5            1 U           0.27 J             10 U       NS                 5 U          1 U
Trichloroethene               ug/L            0.44 J      0.87 J            0.38 J             10 U       NS                 5 U          1 UJ
Vinyl Chloride                ug/L               1 U          2 U              2 U             10 U       NS                 5 U          1 U

                              Date        2/15/2006    5/23/2006        8/15/2006        11/14/2006   3/8/2007        5/22/2007    8/14/2007
Parameter                     Units          PDB          PDB              PDB              PDB         PDB              PDB          PDB
cis-1,2-Dichloroethene        ug/L             0.8          1.3                1 U           0.77          2.2               1 U        1.7
Tetrachioroethene             ug/L             0.5 U          1 U              1 U            0.5 U        0.5    U          1 U          1 U
Trichloroethene               ug/L             0.5 U          1 U              1 U            0.5 U        0.5    U          1 U          1 U
Vinyl Chloride                ug/L             0.5 U          1 UJ             1 U            0.5 U        0.5    U          1 U          1 U
Cyclohexane                   uq/L            0.93            1 U              1 U            4.2          0.5    U          1 U          1 U

                              Date        3/11/2008                    10/28/2008
Parameter                     Units          PDB         PDB           Upper Pump j Lower Pump
cis-1,2-Dichloroethene        ug/L               1 U                         1.3          1.1
Tetrachioroethene             ug/L               1 U         1   U             1 U          1 U
Trichloroethene               ug/L               1 U         1   U             1 U          1 U
Vinyl Chloride                ug/L               1 U         1   U             1 U          1 U
Cyclohexane                   ug/L             1.4           1   U             1 U          1 U

                              Date        5/26/2009
Parameter                     Units          PDB
cis-1,2-Dichloroethene        ug/L            0.63
Tetrachioroethene             ug/L             0.5 U
Trichloroethene               ug/L             0.5 U
Vinyl Chloride                ug/L             0.5 U
Cyclohexane                   ug/L             1.1

In February 2006, Acetone was detected at 6.6 ug/L.                  PDB - Passive Diffusion Bag
For the PDB samples, Well D was sampled at 28 ft.                    Pump - Perstaltic Pump
NS - Not Sampled
U - Not detected. Number is the detection limit.                     J - Result Is an estimate.




9/9/2009                                                                             4 of 14
Table 2 (Continued)
OU 1 Remedial Action Groundwater Results
From the End of Rl Sampling (7/23/02) to Spring (5/26/09) 2009 Sampling

Well E                          Date    7/23/2002        7/24/2003        4/21/2005         5/31/2005     9/20/2005    12/13/2005
Parameter                       Units     Pump             Pump             Pump              Bailer         Dry           Dry
cis-1,2-Dichloroethene          ug/L          52              91                45                75           NS           NS
Tetrachioroethene               ug/L        210              260                70              220            NS           NS
Trichloroethene                 ug/L          36              72                45                59           NS           NS
Vinyl Chloride                  ug/L          10 U            13 U              10 U             3.8 U         NS           NS

                                Date    2/15/2006       5/23/2006         8/15/2006        11/14/2006
Parameter                       Units      Dry            Bailer             Dry               Dry
cis-1,2-Dichloroethene          ug/L         NS             5.8                NS               NS
Tetrachioroethene               ug/L         NS             130                NS               NS
Trichloroethene                 ug/L         NS              15                NS               NS
Vin^Chloride                    ug/L         NS                1 UJ            NS               NS

                                Date    3/8/2007        5/22/2007         8/14/2007         3/11/2008     10/29/2008
Parameter                       Units      Dry            Bailer            Bailer            Bailer        Bailer
cis-1,2-Dichloroethene          ug/L         NS              13                  5 U              15            49
Tetrachioroethene               ug/L         NS             130                 95                86           110
Trichloroethene                 ug/L         NS              16                 10                 9            15
Vinyl Chloride                  ug/L         NS                1 U               5 U               5 U           5 U

                                Date    5/26/2009
Parameter                       Units     Bailer
cis-1,2-Dichloroethene          ug/L          23
Tetrachioroethene               ug/L          62
Trichloroethene                 ug/L          11
Vinyl Chloride                  ug/L           5 U

Pump - Perstaltic Pump                               NS - Not Sampled/ Dry Well 

Dry - Well dry, unable to sample.                    U - Not detected. Number is the detection limit. 




9/9/2009                                                                 5 of 14
Table 2 (Continued)
OU 1 Remedial Action Groundwater Results
From the End of Rl Sampling (7/23/02) to Spring (5/26/09) 2009 Sampling

WellF                         Date        7/23/2002    7/24/2003       4/21/2005        5/31/2005        9/20/2005     12/13/2005
Parameter                     Units         Pump         Pump            Pump                               PDB
cis-1,2-Dichloroethene        ug/L               1 U       0.21 J            10 U            NS                 5 U         NS
Tetrachioroethene             ug/L               1 U          1 U            10 U            NS                 5 U         NS
Trichloroethene               ug/L               1 U          1 U            10 U            NS                 5 U         NS
Vin^l Chloride                ug/L               2 U          2 U            10 U            NS                 5 U         NS

                              Date        2/15/2006    5/23/2006        8/15/2006        Well
Parameter                     Units                                                   Permanently
cis-1,2-Dichloroethene        ug/L            NS           NS                 NS        Closed,
Tetrachioroethene             ug/L            NS           NS                 NS        October
Trichloroethene               ug/L            NS           NS                 NS         2006
Vinyl Chloride                ug/L            NS           NS                 NS

PDB - Passive Diffusion Bag                                         NA - Not Analyzed
Pump - Perstaltic Pump                                              NS - Not Sampled
For the PDB samples, Well F was sampled at 33 ft.                   U - Not detected. Number is the detection limit.




9/9/2009                                                            6 of 14
Table 2 (Continued)
OU 1 Remedial Action Groundwater Results
From the End of Rl Sampling (7/23/02) to Spring (5/26/09) 2009 Sampling
WellG                       Date       5/9/2002      5/17/2002              7/23/2002                        4/9/2003              7/24/2003
Parameter                   Units       Pump           Pump            Pump          Pump              Pump           Pump           Pump
cis-1,2-Dichloroethene      ug/L          370            170            370           380               190            190             250
Tetrachioroethene           ug/L            41            40            130           150                2.1 J          1.8 J           65
Trichloroethene             ug/L            17            18             45            48                1.2 J          1.3 J           27
Vinyl Chloride              ug/L            71            13             25 J          25 J               60            61              37

                            Date      4/21/2005     12/13/2005       2/15/2006         5/23/2006    8/15/2006         11/14/2006
Parameter                   Units       Pump           PDB              PDB               PDB          PDB               PDB
cis-1,2-Dichloroethene      ug/L          160           420              260               120          260               330
Tetrachioroethene           ug/L           20 U         100               25 U               5 U         37               8.5
Trichloroethene             ug/L           20 U          53               25 U             5.6           18                  5 U
Vinyl Chloride              ug/L           25            28               52                35           55               110

                            Date       3/8/2007      5/22/2007                                      8/14/2007         3/11/2008          10/29/2008
Parameter                   Units        PDB            PDB                             ACLs           PDB               PDB         PDB          Pump
cis-1,2-Dichloroethene      ug/L          140             28                           140,000          120                62         150           210
Tetrachioroethene           ug/L             5 U           5 U                          11,000           16                 5 U         5 U          23
Trichloroethene             ug/L             5 U         5.9                             8,600          9.7                 5 U         5 U          13
Vinyl Chloride              ug/L            21 J           5 U                           9,000            5 U             9.9          49            22

                            Date      5/26/2009
Parameter                   Units        PDB
cis-1,2-Dichloroethene      ug/L           37
Tetrachioroethene           ug/L            5 U
Thchloroethene              ug/L            5 U
Vinyl Chloride              ug/L           53

For the PDB samples, Well G was sampled at 38 ft.                  ACLs - Alternate Concentration Limits, in ug/L
In May 2009, Methylene Chloride detected at 15 ug/L.               There is also an ACL for t-DCE of 6,700 ug/L.
PDB - Passive Diffusion Bag                                        U - Not detected. Number is the detection limit.
Pump - Perstaltic Pump                                             J - Result is an estimate.
NA - Not Analyzed
Well G was not sampled on May 31, 2005 or on September 20, 2005.




9/9/2009                                                                     7 of 14
 Table 2 (Continued)
 OU 1 Remedial Action Groundwater Results
 From Baseline Sampling (4/21/05) to Spring (5/26/09) 2009 Sampling

WellH                          Date       4/21/2005                                       9/20/2005                                               12/13/2005          1
                              Sample
                              Method        Pump              PDB          PDB             PBD                PBD               PBD           PBD*         PBD
Parameter                      Units       38' btoc          19'btoc      24' btoc        28' btoc           34' btoc          39' btoc      28' btoc     39' btoc
cis-1,2-Dichloroethene         ug/L            81               8.7           62               81              140                140            43          230
trans-1,2-Dichloroethene       ug/L            10 U               5 U           5 U              5 U            7.2                7.6             5 U        13
Tetrachioroethene              ug/L            85              140           200              240              430                400           350          540
Trichloroethene                ug/L            20                18           38               52                85                 92           65          130
Vinyl Chloride                 ug/L            10 U               5 U           5 U              5 U              5 U                5 U           5 U          5 U

                               Date       2/15/2006         5/23/2006    8/15/2006       11/14/2006          3/8/2007      5/22/2007 1
                              Sample
                              Method        PDB               PDB          PDB             PDB                PDB               PDB
Parameter                      Units       39' btoc          39' btoc     39' btoc        39' btoc           39' btoc          39' btoc
cis-1,2-Dichloroethene         ug/L           280                83          210              260                29                15
trans-1,2-Dichloroethene       ug/L             19                 5 U        9.6               14                5 U                5 U
Tetrachioroethene              ug/L           250               180         440               310                65                68
Trichloroethene                ug/L            71                44           61               91                12                14
Vifiyl Chloride                ug/L            10 U                5 U         12                5 U              5 UJ               5 U

                               Date                        8/14/2007     3/11/2008                                10/29/2006
                              Sample
                              Method                         PDB           PDB          Upper PDB        Lower PDB       Upper Pump        Lower Pump
Parameter                      Units       ACLs             34' btoc      34'btoc        34' btoc         39' btoc         22' btoc          32' btoc
cis-1,2-Dichloroethene         ug/L       140,000               51            53              83              82              100               110
trans-1,2-Dichloroethene       ug/L         6,700                 5 U          5 U              5 U            5 U               5 U               5 U
Tetrachioroethene              ug/L        11,000              160          120              190 J          150               150               190
Trichloroethene                ug/L         8,600               34            31              28              20               30                34
Vinyl Chloride                 ug/L         9,000                 5 U          5 U              5 U            5 U               5 U               5 U

                               Date                 5/26/ 2009
                              Sample
                              Method     Upper PDB         Lower PDB
 Parameter                     Units      34' btoc          39' btoc
 cis-1,2-Dichloroethene        ug/L           35                34
 trans-1,2-Dichloroethene      ug/L             5 U               5 U
 Tetrachioroethene             ug/L          110                76
 Trichloroethene               ug/L           20                15
[Vinyl Chloride                ug/L             5 U               5 U

In December 2005, Acetone was detected in the 28' sample at 7.7 ug/L and in the 39' sample at 7.0 ug/L.
In November 2006, Cyclohexane was detected at 6.7 ug/L.                                                 PDB - Passive Diffusion Bag
In May 2009, Methylene Chloride was detected at 8.4 ug/L.                                               Pump - Perstaltic Pump
U - Not detected. Number is the detection limit.                                                        btoc - below top of casing
* - Results may be inaccurate or biased low, since PDB was not completely submerged.




9/9/2009                                                                                           8 of 14
 Table 2 (Continued)
 OU 1 Remedial Action Groundwater Results
 From Baseline Sampling (4/21/05) to Spring (5/26/09) 2009 Sampling

Weill                           Date                 4/21/2005                                                9/20/2005                                                 12/13/2005
                               Sample
                               Method         Pump             Pump            PDB             PDB               PDB                PDB            PBD        PDB*        PDB             PDB
Parameter                       Units        38' btoc      38' btoc DUP       19'btoc         24' btoc         28' btoc            34' btoc      39' btoc    28' btoc   39' btoc     39' btoc DUP
cis-1,2-Dichloroethene          ufl/L         3,600             3,800           150            2,800           4,100               6,100          6,400       4,800      8,300            8,300
trans-1,2-Dichloroethene        ug/L             48                39              5 U             13             19                   26            22          14         11               10
Tetrachioroethene               ug/L            720               720           210               610            950               1,100            900         790        100              120
Trichloroethene                 ug/L            450               460             44              420            700                 860            690         420         14               18
Vinyl Chloride                  ug/L             75                76              5 U             17             36                   62           110         120        340              350
1,1-Dichloroethene              ug/L               5 U              5 U            5 U               5 U           5    U               5 U            5 U       11         11               10

                                Date                 2/15 /2006             5/23/2006        8/15/2006        11/14/2006           3/8/2007     5/22/2007
                               Sample
                               Method         PDB               PDB            PDB             PDB               PDB                PDB           PDB
Parameter                       Units       39' btoc       39' btoc DUP      39' btoc         39' btoc         39' bloc            39' btoc      39' btoc
cis-1,2-Dichloroethene          ug/L        12.000            12,000          1,600           14,000          14,000               1,100            990
trans-1,2-Dichloroethene        ug/L           670     U           55             15               21             35                   15            9.9
Tetrachioroethene               ug/L           670     U           11           950               200            650    J            540            620
Trichloroethene                 ug/L           670     U           35           660               190            460    J            360            300
Vinyl Chloride                  ug/L           670     U          340 J          8.1              900 J          430    J               5 UJ          26
1,1-Dichloroethene              ug/L           670     U           28              5 U             68             30                    5 U            5 U

                                Date                         8/14/2007      3/11/2008                                 10/29/2008
                               Sample
                               Method                          PDB            PDB           Upper PDB         Lower PDB        Upper Pump      Lower Pump
Parameter                       Units        ACLs             34' btoc       34' btoc        34' btoc          39' btoc         22.9' btoc      32.9' btoc
cis-1,2-Dichloroethene          ug/L       140,000             2,200            770            2,500           2,900             1,800           2,500
trans-1,2-Dichlorx)ethene       ug/L         6,700                6.1              8                5 U           7.1               16                17
Tetrachioroethene               ug/L        11,000                650           680              390             430    J          620 J            620 J
Trichloroethene                 ug/L         8,600                200           260               23             110               210              230
Vinyl Chloride                  ug/L         9,000                180              8           1.100             680               330              360
1,1-Dichloroethene              ug/L                                5 U            5 U              6             7.9                 5 U            5.8

                                Date                 5/26 /2009
                               Sample
                               Method      Upper PDB        Lower PDB
Parameter                       Units       34' btoc         39' btoc
cis-1,2-Dichloroethene          ug/L           550               540
trans-1.2-Oichloroethene        ug/L              5 U              5 U
Tetrachioroethene               ug/L           350               180
Trichloroethene                 ug/L           110                89
Vinyl Chloride                  ug/L            26                62
1,1-Dichloroethene              ug/L              5 U              5 U

In December 2005, Acetone was detected in the 28' sample at 6.7 ug/L and in the 39' sample at 7.4 ug/L (7.2 ug/L in the Duplicate).
In November 2006, Cyclohexane was detected at 13 ug/L.                             PDB - Passive Diffusion Bag
Well I was not sampled in May 2005.                                                Pump - Perstaltic Pump
U - Not detected. Number is the detection limit.                                    btoc - below top of casing
* - Results may be inaccurate or biased low. since PDB was not completely submerged.




                                                                                                                9 of 14
9/9/2009
Table 2 (Continued)
OU 1 Remedial Action Groundwater Results
From Baseline Sampling (4/21/05) to Spring (5/26/09) 2009 Sampling
Well J
                               Date       4/21/2005                5/31/2005                                          9/20/2005                                     12/13/2005           1
                              Sample
                              Method        Pump               PDB          Pump            PDB 
            PDB                 PDB               PDB           PDB*          PDB
Parameter                      Units       30' btoc          30' btoc      30' btoc        20' btoc 
       25' btoc         25' btoc Dup        30' btoc       25' btoc      30' btoc
cis-1,2-Dichloroethene         ug/L         1,700               870         2,000 
            140 
         1,200               1,300           1,100            370           660
trans-1,2-Dichloroethene       ug/L            15                NA            NA 
               5 U            10                  10              8               5 U           5 U
Tetrachioroethene              ug/L         6,200             3,300         4,800 
            880           3,200               3,200           6,200          1,000           300
Trichloroethene                ug/L         3,000               920         2,700 
            110              520                540             770            150           110
Vinyl Chloride                 ug/L            30                NA            NA 
               5 U             5 U                 5 U           10               5 U          70


                               Date       2/15/2006                5/23/2006              8/15/2006                   11/14/2006            1
                              Sample
                              Method        PDB                PDB        PDB Dup           PDB              PDB              PDB Dup
Parameter                      Units       30' btoc          30' btoc      30' btoc        30' btoc         30' btoc           30' btoc
cis-1,2-Dichloroethene         ug/L           680               300           300            1,000           1,300              1,100
trans-1,2-Dichlorciethene      ug/L            67 U                5 U           5 U            10               14                 13
Tetrachioroethene              ug/L           170             1,300         1,400            1,100           1,500              1,200
Trichloroethene                ug/L           140               290           290              360              310                270
Vinyl Chloride                 ug/L            67 U                5 U           5 U            46               15                 15


                               Date                 3/8/2007              5/22/2007       8/14/2007        3/11/2008                                  10/29/2008
                              Sample
                              Method         PDB           PDB (DUP)        PDB            PDB 
             PDB             Upper PDB          Lower PDB     Upper Pump    Lower Pump
Parameter                      Units       30' btoc         30' btoc       30' btoc       25' btoc 
        25' btoc          25' btoc           30' btoc      23.5' btoc    29.5' btoc
cis-1.2-Dichloroethene         ug/L           320              290            110              95 
          1,300                120              450          1,200         2,500
trans-1,2-Dichloroethene       ug/L            50 U             50 U             5 U             5 U             11                 5 U             6.8            39            42
Tetrachioroethene              ug/L         2,300            2,300            920             870             2,600            1,200 J           1,300    J     3,000         6,800
Trichloroethene                ug/L           320              310                            100             1,200               170              250            710         1,400
Vinyl Chloride                 ug/L            50 UJ            50 UJ           5     U          5 U             20                 5 U               5 U                        12


                               Date                 5/26/ 2009
                              Sample
                              Method     Upper PDB         Lower PDB
Parameter                      Units      25' btoc          29.5' btoc
cis-1,2-Dichloroethene         ug/L          340                720
trans-1,2-Dichloroethene       ug/L             5 U                5 U
Tetrachioroethene              ug/L           590            2,200
Trichloroethene                ug/L           180               580
Vinyl Chloride                 ug/L             5     U            5 U

In December 2005, Acetone was detected in the 30' sample at 7.4 ug/L and in the 25' sample at 6.0 ug/L.
In November 2006,1,1,2-TCA was detected at 12 ug/L in the primary sample and 11 ug/L in the duplicate sample.
btoc - below top of casing
U - Not detected. Number is the detection limit.                                                   PDB - Passive Diffusion Bag
* - Results may be inaccurate or biased low, because PDB was not submerged.                        Pump - Perstaltic Pump




9/9/2009                                                                                                10 of 14
Table 2 (Continued)
OU 1 Remedial Action Groundwater Results
From Baseline Sampling (4/21/05) to Spring (5/26/09) 2009 Sampling

PZ-1                           Date       4/21/2005      5/31/2005     9/20/2005     12/13/2005    2/15/2006     5/23/2006    8/15/2006   11/14/2006
Parameter                      Units                       Pump                                      Bailer         PDB          PDB         PDB
cis-1,2-Dichloroethene         ug/L          NS            2,750           NS            NS            90           630          550          400
trans-1,2-Dichloroethene       ug/L          NS               NA           NS            NS            25 U          6.4            5 U        6.7
Tetrachioroethene              ug/L          NS          23,500            NS            NS           220         1,100        2,300        1,400
Trichloroethene                ug/L          NS            2,480           NS            NS            28           320          310          160
Vinyl Chloride                 ug/L          NS               NA           NS            NS            25 U            5 U          5 U          5 U

                               Date        3/8/2007      5/22/2007     8/14/2007     3/11/2008             6/17/2008                10/29/2008
Parameter                      Units         PDB            PDB           PDB           PDB            PDB      1 PDB (DUP)     PDB           Pump
cis-1,2-Dichloroethene         ug/L          110              68           30            99          1,100         1,100       3,900         1,600
trans-1,2-Dichloroethene       ug/L             5              5 U           5 U           5 U          11            17          29            13
Tetrachioroethene              ug/L          430             470           42         2,100          4,700 J       4,300 J     9,300 J      4,000 J
Trichloroethene                ug/L           42              42           18           121          1,300 J       1,200 J     3,100        1,300
Vinyl Chloride                 ug/L             5 UJ           5 U           5 U           5 U           5 U           5 U         5 U           5 U


                               Date       5/26/2009
Parameter                      Units         PDB
cis-1,2-Dichloroethene         ug/L          850
trans-1,2-Dichloroethene       ug/L            5 U
Tetrachioroethene              ug/L       2,900
Trichloroethene                ug/L         600
Vinyl Chloride                 ug/L            5 U

In Novemeber 2006,1,1,2-TCA was detected at 12 ug/L.               Pump- Perstaltic Pump 

In June 2008, bromodichloromethane was detected in the Primary sample at 12 ug/L and in the duplicate sample at 11 ug/L. 

For the PDB samples, Well PZ-1 was sampled at 28 ft.               NS- Not sampled. 

PDB - Passive Diffusion Bag                                        U - Not detected. Number is the detection limit. 





9/9/2009                                                                 11 of 14
Table 2 (Continued)
OU 1 Remedial Action Groundwater Results
From Baseline Sampling (4/21/05) to Spring (5/26/09) 2009 Sampling

ART-1                         Date        4/21/2005          5/31/2005       9/20/2005       12/13/2005
Parameter                     Units                            Pump            Pump
cis-1,2-Dichloroethene        ug/L             NS             10.475            2,100              NS
Tetrachioroethene             ug/L             NS               6,000           1,900              NS
Trichloroethene               ug/L             NS                 898             330              NS
Vinyl Chloride                ug/L             NS                  NA              13              NS

                              Date        2/15/2006          5/23/2006               8/15/2006                11/14/2005
Parameter                     Units                            Pump            Pump          Pump Dup           Pump
cis-1,2-Dichloroethene        ug/L             NS                140             420            410                 54
Tetrachioroethene             ug/L             NS                160             400            400                230 J
Trichloroethene               ug/L             NS                  43            150            150                 25 J
Vinyl Chloride                ug/L             NS                   5 U            5 U            5 U                5 U

                              Date         3/8/2007          5/22/2007       8/14/2007        3/11/2008        6/17/2008     10/29/2008
Parameter                     Units         Pump               Pump             PDB                              Pump          Pump
cis-1,2-Dichloroethene        ug/L            200                  11               5 U            NS              190           290
Tetrachioroethene             ug/L            210                  62 J             5 U            NS              260 J         290 J
Trichloroethene               ug/L              72                8.6               5 U            NS              110 J           62
Vinyl Chloride                ug/L               5 UJ               5 U             5 U            NS                 5 U           5 U

                              Date        5/26/2009
Parameter                     Units         Bailer
cis-1,2-Dichloroethene        ug/L            260
Tetrachioroethene             ug/L            820
Trichloroethene               ug/L            270
Vinyl Chloride                ug/L               5 U

Pump - System's Well Pump                                                 NS - Not Sampled
The ART system's pump intake is approximately 29 feet bgs.                U - Not detected. Number is the detection limit.



9/9/2009                                                                   12 of 14
Table 2 (Continued)
OU 1 Remedial Action Groundwater Results
From Baseline Sampling (4/21/05) to Spring (5/26/09) 2009 Sampling

PZ-2                          Date       5/22/2007     8/14/2007
Parameter                     Units        Bailer        Bailer
cis-1,2-Dichloroethene        ug/L        3,300        11,000
trans-1,2-Dichloroethene      ug/L           23            50
Tetrachioroethene             ug/L        2,600         7,600
Trichloroethene               ug/L          950         3,600
Vinyl Chloride                ug/L            5 UJ           5 U
1,1-Dichloroethene            ug/L            5 U            8

                              Date      3/11/2008      6/17/2008     10/29/2008
Parameter                     Units       Bailer         Bailer        Pump
cis-1,2-Dichloroethene        ug/L      25,000          2,100         13,000
trans-1,2-Dichloroethene      ug/L         320             13             81
Tetrachioroethene             ug/L      11,000          3,900 J       17,000 J
Trichloroethene               ug/L       8,700            640 J       13,000
Vinyl Chloride                ug/L          7.7              5 U         9.5
1,1-Dichloroethene            ug/L           10              5 U          20

                              Date       5/26/2009
Parameter                     Units        Bailer
cis-1,2-Dichloroethene        ug/L        9,500
trans-1,2-Dichloroethene      ug/L           56
Tetrachioroethene             ug/L        7,800
Trichloroethene               ug/L        5,100
Vinyl Chloride                ug/L            5 U
1,1-Dichloroethene            ug/L            5 U

U - Not detected. Number is the detection limit. 

Well PZ-2 was not sampled in 2005, 2006, or March 2007 because it was dry. 




9/9/2009                                                                 13 of 14
Table 2 (Continued)
OU 1 Remedial Action Groundwater Results
From Baseline Sampling (4/21/05) to Spring (5/26/09) 2009 Sampling

Quality Control - Trip Blanks
                               Date      4/21/2005      5/31/2005        9/20/2005     12/13/2005
Parameter                      Units
cls-1,2-Dlchloroethene         ug/L          10   U        10   U            5   U             5   U
trans-1,2-Dichloroethene       ug/L          10   U        10   U            5   U             5   U
Tetrachioroethene              ug/L          10   U        10   U            5   U             5   U
Trichloroethene                ug/L          10   U        10   U            5   U             5   U
Vinyl Chloride                 ug/L          10   U        10   U            5   U             5   U

                               Date             2/15/2006                      5/23/2006                      8/15/2006                     11/14/2006
Parameter                      Units       Normal         LDL             Normal        LDL              Normal         LDL             Normal       LDL
cis-1,2-Dichloroethene         ug/L         10 U         0.5    U            5 U          1 U                5 U         1 U               5 U       0.5   U
trans-1,2-Dichloroethene       ug/L         10 U         0.5    U            5 U          1 U                5 U         1 U               5 U       0.5   U
Tetrachioroethene              ug/L         10 U         0.5    U            5 U          1 U                5 U         1 U               5 U       0.5   U
Trichloroethene                ug/L         10 U         0.5    U            5 U          1 U                5 U         1 U               5 U       0.5   U
Vinyl Chloride                 ug/L         10 U         0.5    U            5 U          1 UJ               5 U         1 UJ              5 U       0.5   UJ

                               Date             3/8/2007                       5/22/2007                      8/14/2007       f
Parameter                      Units       Normal         LDL             Normal        LDL              Normal         LDL
cis-1,2-Dlchloroethene         ug/L          5 U         0.5    U            5 U          1        U         5 U          1 U
trans-1,2-Dlchloroethene       ug/L          5 U         0.5    U            5 U          1        U         5 U          1 U
Tetrachioroethene              ug/L          5 U         0.5    U            5 U          1        U         5 U          1 U
Trichloroethene                ug/L          5 U         0.5    U            5 U          1        U         5 U          1 U
Vinyl Chloride                 ug/L          5 UJ        0.5    U            5 U          1        U         5 U          1 U

                               Date             3/11/2008                6/17/2008     10/29/2008      10/27/2008                           5/26/2009
Parameter                      Units       Normal         LDL             Normal         Normal           LDL                           Normal       LDL
cls-1,2-Dichloroethene         ug/L          5 U                              5 U            5 U             1 U                           5 U       0.5   U
trans-1,2-Dichloroethene       ug/L          5 U                              5 U            5 U             1 U                           5 U       0.5   U
Tetrachioroethene              ug/L          5 U                              5 U            5 U             1 U                           5 U       0.5   U
Trichloroethene                ug/L          5 U                              5 U            5 U             1 U                           5 U       0.5   U
Vinyl Chloride                 ug/L          5 U              U               5 U            5 U             1 U                           5 U       0.5   U

In December 2005, Acetone was detected at 5.1 ug/L.                                  LDL - Low Detection Limits
In May 2007, Bromoform was detected in the LDL trip blank at 1.2 ug/L.               U - Not detected. Number is the detection limit.
NA - Not Analyzed



9/9/2009                                                                             14of 14
               OUS
2008 ENVIRONMENTAL MONITORING
  REPORT FOR OPERABLE UNIT 3
(OLD CITY DUMP), RIVERFRONT SITE,
        NEW HAVEN, MISSOURI
T a b l e E l . Summary of ground-watar quality data for O U 3 .
                     <lMtGWgrauidi V . C B l d , l
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BM-ta                         iznam           1400           «1            <1      «1             «1               100.13          a
BWMO                          owan*           1030           <1            «1      <1             <1               04.02            8
BW03                          mrniM           1430           <1            «1      <1             «1               B4 34           .1
BWOS                          osaim           laoo           <1            «1      «1     [      J3J        1      B3.83           2
BW41                          maain           1010           «1            <1      <1             <1               BOM             2
BW^ai                         lanus           1430           <1            «1      <1             <1               aoiN            a
BWUI                          i2naraa         1440           <1            <1      «1             <1               80J8            a
BVIM1                         0«1«D4          1480           <1            <1      «1             <1               84.04           a
BVIU1                         OT/oam          1900   1        2i           «1      «1             <1               84 71           a
BW-11                         oaaoDS          144S           <1            <1      <1             <1                83.7           A
BWUIA                         07a3«3          2000           «1            <1      «1             <1               3BJB             .1
BW01A                         12nM3           1430           <1            «1      «1             <1               3881            8.0
BWM1A                         OMam            1SD0                                 <1
                                                             <1            «1                     <1                 -             1.4
BW41A4UP                      oviam           151S           <1            <1      <1             «1               38M             1.4
BWU1A                         OTiorm          1S18   1        aa                   <1             «1               38/42            8
BW41A                         osaiAs          1400           <i            «1      «1             10               3714            ^a
BVIU2                         07/2303         14SS           <i            <1      <1             «1               23JS           1.8
BW-32                         12n8«3          1230           «i            «1      <1             «1               208            1.8
BWL32                         04n4O«          1440           «i            «1      <1             «1               2041           IS
BW-32                         07flBn«         1210           <i            <1      <1             «1               21/48          2J
BW«                           oaai/OB         1300           <i            «1     .18J    J       <1                17.7          38
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JS«                           ovians          1880           <i                    <1             «1                 -             22
js-sa                         oaouoa          1733           <i                    «1             <1                 -             4i>
JUS                           ovzwi           1190           <i                    «1             <1                 -              -
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PB-17                         osaim           1818           <i                    «1             «1                 -              -
PB-17                         oviam           laa            «i                    <1             <1               130J            22
PB-17                         oaoim           1888           <i                    «1             <1                 -              -




   OU3_VOC_tabla-2008dj(ls Tsbto E1_repart-tafalfr2008                                                                                     1or7
Table E l . Summary cH ground-water quality data for OU3 -Continued.
                                                                                                              T B K ni^L. nOQtiiD pv I




                                                                                         Tnipntn.   CiUuni.       MvMkan.         PoUrium,
8 1 * (IB. 2)                             Mm        pH    • pN(Wl)   c m     Oand(tab)   MMrdtgC     irgA.          mod.            molL

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                                                              -      ijgo        -         143        161              69                23
                                         04/1304    7.1
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BW41                                     0V14O4     7.1                                    164                         94            1/4
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BW.aiA                                   i2nam      12        -      IJW          -        13.0       124              04                1.0
BW41A                                    04/1MI4    ia        -      1«0          -        17J        123              96                1.0
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BW-31A4tv                                070704     ia               IJEO                  168        124              04                u
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                                                             TJ4     i.m       I.ITD       160        113             88J                IJ

BW42                                     07/23m     IA               1J10                  14.0       127              62                IJ
BW^                                      i2fiam     ia        -      1JI0        -         14.7       112              61                17
BW-32                                    04/14m     ia               \2B                   14.7       122              78                1/4
BW32                                     07mm       12        -      1«0         -         168        116              78                IJ
BW«                                      osoim      ia       T.I     12K       1270         13        123             7ej            0L76

SMpU                                     07/1Bm              TJ)     ijao      1J00         18        146             ISA                40    1
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SMpM4iup                                 oaoim      IA       12      1.410     1/488        18        184             88.7           284       1
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JSJa                                     04nam      12        -      an          -          14J       83               40                14
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   OU3_VOC_labl»200ad.xl8 Tabis E1_report-tabla-2008                                                                                           2of7
k

k    T a b l e E l . Summary of giound-water quaBty data for O U 3 -Continued.
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                                     snoF
                                       tiinm
                                       mam             87             468                  488              8T1        240      0.1     18 1
                                       07/2402         68             487                  481              963        120      0.1      14 

                                       t2XI8m          88             480                  4S2              682        200      01       IT 

                                       04/1304         78             433                  439              611        100      ai       IT 

                                       maiKA          8BJ
                                                                        ­                  484              601        203      ai6     106 

                                       06oim           82             468                  478              680        1T0      OJ       20            

                                       07/23«                                                                                   OJ       IB        

                                       i2n9m
                                                       78
                                                       78
                                                                      407
                                                                      407
                                                                                            -

                                                                                           409
                                                                                                            400
                                                                                                            490
                                                                                                                       160
                                                                                                                       ISO      02       10                    

                                       i2nMn           60             4S3                  482              S68        190      OJ       21    

                                       04/1404         88             473                  473              877        180      OJ       20                

                                       07/0604                                                                         188      022     18J                        

                                       OBOom
                                                      87J
                                                                        ­                  903              614

                                       07/23m          30             428                  431              826        IT       OJ      30
                                       isnam           28             810                  913              628        18       ai       18
                                       04/1804         26             SOO                  810                         20       ai       14
                                       04/1804         26             808                  810              822        19       ai       14
                                       07/07/04        20             SOO                  SOO              820        18        01      14 

                                       oaoim          23J
                                                                        ­                  480              887       28J       0.18    1ZT 

                                       07/23m         43              683                  848              686         SB      OJ      28
                                       12/1 s m        36             448                  484              884         78      ai      18
                                       04/14m         41              886                  878              702         S8      01      2T
                                       07/SaO4        40              882                  861              684         80      OJ      24
                                       OHim           57J                                  682              TOS        38.7     022     32.9

                                       07/iam          107              -                    ~               ~         183       OJ 
   laT
                                       04/I8O1
                                       06/11/01                                                                         -                -
                                       03/tMB
                                                       63             482                  466              688        120      0.1     16                             1

                                       mam                            818                  B23              638        170              13 

                                                       88
                                       04/1 o m                                                                                  ai
                                                       82             478                  483              880        130              14 

                                       07/23m                                                                                    ai
                                                       80             683                  866              6B3        210              IT                             1

                                       12mm                                                                                      ai
                                       04/1304         71             810                  816              830        100              12 

                                                                                                                       130       ai
                                                       110            840                  843              683 

                                       07/D6O4
                                       07/0604         110            840                  843              683        130 
     OJ
                                                                                                                                 OJ 

                                                                                                                                        " 1 

                                                                                                                                        IT 1
                                       osoim           so                                  627              843        03.7             10J 

                                       oaoim          90J               _                    -               -         83J
                                                                                                                                eo.i2
                                                                                                                                E0.11   104 

                                       02n7m          8J8             331                  336              410       4.70       OJ     13J
                                       ountm            9             378                                              4J        01      13
                                       oBoim          9.78                                                            373        0.19   13J
                                       010401
                                       04/18m         24              247                  290              309        2J       <.10    9J
                                                      2J1                                  298              383         .
                                                                                                                       17       E012    984
                                       V I MOO}        14             411          i       4JI              Ml         20        0.1     |]
                                       OBorm           18     1         -                  382              468        27 1 
   aie     13J
                                       030106
                                       OVIMB                          387                                              44       01       14
                                       oaotm          OJO                                  379              462        4JB      017     13J




       OU3_VOC_tabla-200ad.xls Table E1_report-taUe-2008                                                                                                                    3of7
       TaUe E l . Summary of ground-water quality dataforOUS -Continued.
                                    i l n a t OW o m M M k n Oond. •                                            lM2SdVM>Ca>*Wll         m^BAgianipv
                                                                          If iiporai|WMllQrQfBHicooiiipoindi RirafscHOQiistoHno
       U hiiri H t n t a U k e . R i G M . « k . « I M W U » I                            •aiaailail,     hiiMd<aUili«mm«aha*B»»Ma|

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                                                      -                         -          -          -             -          -           -              -
       MlMUlGWHandard'                                                                    lOOO                                                            8
                                                      -               -         -                     -             -          -           -
        •i8oewi,1998)                                             19          OA          1J0                                             2J              <1
         E d m a M Naw Ha«an n a graund-
                                                      -                                               -             -         <.os

        MUrbadwouid'                                              19          OO*
                                                      -                                    2          -             -         <JB         3J              <1
       j U p ^ UMI (VHI (iMbUK ; M NMi
                                                                  14          oot         11                                                              <l
                                                      -                                               _             -          _           -
                                                 Mmn                  —         -          -          .             —          _           —              —
       tttMa-                                    tanon                -         -          -          _             _          _           -              -
       BW03                                       OTOVOO
                                                                      -                    .-                                                             -
       BW«3                                       OTOVOB          96          <J01        9J0        <ay                      <JB         26             <1
       BW«3                                       120Bm          190          J8          340        <J01           -          JI6        3oa             4         1
       BWOS                                       04n3O4          74          JB                    <ji                                    a             <1
                                                  07/07/04        78          Jll
       BW«3                                                                               640       <ji             -         <ja         22             <1
       BW4I3                                      oaoim          06J         OJB          804       <J)02      EOJOS          *a*                        «.1

       BW41                                       07a3m          110          «JH         SJO       <01                       a*          oa              <1
                                                  i2n9m          110           M          820       <j)i                      aa
       BWai                                                                                                      -                        14              <1
       BWL31                                      i2n5ra         110          <m          940       <0l\         -            22          IJ              <1
       BW41                                       04n«D4         120          a           640        «.01        -            <m          IJ              <1
       BW41                                       07/0804        120         <jii         660        «ji         -            ai          3J              <1
                                                                 127         <a62                               nim
       BW41                                       oaoom                                   6T0       aoos                     Eoja                        <.!
       BW41A                                      07O3m          ITS          Ol          <J2        <01                      M            a              <1




i

       BW-31A                                     i2flam         240          <jii        <J2        <jii        -            <m           a              «1
       BW41A                                      04n8O4         220          J2          <J2        <01         -            <JB         A               «1
       BW.31/MUP                                  04nao4         220           m          <J2        <01         -            <JB         A               <1
                                                                 220          ji          <J2        <.ai
       BW.31/MUP
       BW41A
                                                  07/D7O4
                                                                 101         ED J l l     <UM       0002
                                                                                                                 -
                                                                                                               Ea004
                                                                                                                              <J2
                                                                                                                              <JM
                                                                                                                                          92              «1
                                                  osoim                                                                                                  «.1

       BW42                                       07a3m           40          <il1        210       <J1                        .04        460




i
                                                                                                                                                          «1
       BW«                                        i2n5m           84          <J>1        380       <01                        JB          a              <1
       BW.32                                      0471404         41          <n          230       <J1             -         <m          1.1            <1



 I

       BW42                                                       47          *a\         280       «01                                   3.7            <1
       BW«                                                       42J         4.02         1J6       <jn2        0JI72         JO                         <.1
       Sa^>M                                                     298           a          18J0      OOOT        OJBI                                      62        1
       SMpM                                                       -
       SaapM                                      osnim           -             -          -          -             -           -          -              -
  I
   SaapM
       SaapM
       SaapM
       SaapM
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                                                  ma*m
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                                                                  -
                                                                 120
                                                                 210
                                                                 170
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                                                                               .13
                                                                               .11
                                                                                           -
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                                                                                                                                                          T
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       SaapM                                      1208U          78           «J01        4J0        «jn                      <m           a              <i
       SaapM                                      04^304         240           .10        2J0       OJSO                      ai          02              3
       SaapM                                      OTosm          200           J»         2J0        *01            -          .10        3oa             2
       SaaplMup                                   07OSO4         200           jn         tiO        •«ji                      JI7        10J             2
       SaapM                                      oaoim          239           a          OJO       0.004       0J036          JI9                       19.T
       SaapM-dup                                  osoim          234           m          0J8       0.004       0JM1           JO                        101


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       J8.28                                      osoim          748                      1.74       *002                     <04          -             <.1
       J»48                                       01OV0I          •   -


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                                                                                                                  -           <JB         <1              <1
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 !     JMI                                        VIVWIl          17          001          23                   <.0I0         <.0I         J              <l
       JMI                                        OBorm           22          <J2         2.77       <ja2       E.008         <.04                        <.1
       PB-1T                                      osoim               -                    -         <J1                                   J
                                                                                                                                                           -
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       PB-1T                                      04nam          08           OJ04        1.10                      -         «.(n
       PB-1T                                      osoim          7J6          <&02        146        <ja2           a         <M            -             «.1




N

          OU3_VOC_tabls-2008djd8 Table E1_rBport-(able-2008                                                                                                             4of7 


II 

I

    Table E l . Summary of ground-water quaSty data for 0U3 -Continued.
    | M n , i n i r t m u M U i i i f l l i i t a w o i n u n a M M r . C B n d . B i e i i m t i i i a n l n i n u i i M i n M i p a r t t i a i M l B a a a d a g t M i O — • : uoO iBkjuipHi pv M K n i ^ ^ niBvani par ten
     ~iMdrtK ^ M B I H I C E. MlmMri oBnMnlBiv I^ i A n M i d bHM nporttao liMl k r MQMC ooflipound! R.n|KltdduilDlidd
    U knd a i h a t b i M k n ndBMH <aka i t a M iMenAiy MndMl or Mhioul vound M l v Mndnd: biMKa n d Muds bidkaki                                                                      • MCq

                                                                                                      BaiyOuii*                          Cadinian.
    8lliC>l0-2l                                                  AiaanlcuB* Barluni, ug6                ugA              Borai, ugA        up9     OvDnAini. uglt C o b A ugA Ooppar, lOA                              hon, ugH
                                                                                       2000               T                                  T
    USEPA                                                                                                                                                                                              ijno               300
         1GW                                                           90              2000                4               2000                8                 100                1000               1J00               300
         iquOto                        (ImM
    •ria>iara,l996)                                                    <1               100              <0J                <20               <1                  <8                  <3                 IT

    ynoRMvataf backsraund                                               <1              130                <1               13J               <1                  <8                  <3                 21                10
    [Wl* IWiM W l IWUPIIII W I I
                                                                                         114               <l                II
    BW-O'                                       SWOBT
    Bwm'                                          MOOSO
    awes                                          07/avco
    BW«3                                          ma»m                  ••4             130               <1                382               «J                  <1                 «1                  42                 3
    BWOl                                          12/06m       1        10              170               «1               1J40              *a                   <1                 IJ                  <2               334
    BW03                                          04/1304              «4               130               «1                                 <a                   <1                 <1                  <2               «2
    BW09                                          07/D7/D4     1        6               120               <1                340              <a                   <1                 <1                  <2                <2
    BW«3                                          osoim                OS               118               <J                379             eojM                  04                  J               eojso                eo
    BW-31                                         07/23m               «4                03               <1                                  <a                  <1                  «1                 <2                6
    BW41                                          i2nsm                «4                02               <1                482               <.8                  1                  «1                 <2                10
    BW-31                                         i2nBro               «4                89               <1                437               *a                  <1                  <1                 <2                8
    BW41                                          04/14/04              4               100               <1                                  <a                  «1                  <1                 <2                4
    BW41                                          070804                B                07               <1                                  <a                  <1                  «1                 <2                «a
    BW41                                                               OO               SOI               <J                                EOJM                  04                                     14                <8
                                                  osoom                                                                     488                                                       J

    BW41A                                         masm                  <4               40               <1                                  <a                  <1                  <1                 «2               TTB
    BW-31A                                        ^2ntm                 <4               37               «1                                  <a                  <1                  <1                 <2              0840
    BW41A                                         0V19/04      1         4               34               «1                                  <a                  <1                  «l                 <a              2,T20
    BWkSIA-dup                                    04/19»4               «4               34               <1                 13               <2                  «1                  «1                 <2              2JTD
    BWaiArdup                                     0TOT/D4      1         T               30               <1                                  < j                 «1                  «1                 <2               182
    BW41A                                         oaoim                Ol               31J               <2         I      101 I eojn                            02                  J                  <1              2.100

    BW.32                                         maam                  <4               72               <1                                  < j                  1                  <1                 <2                6
    BW32                                          i2n8m                 «4               47               <1                 12               <a                   1                  «1                 <2               1S8
    BW«                                           04n4O4                <4               70               «1                 17               <s                  <1                  <1                 <2                6



I
    BW-33                                         0TOBa4                8                63               *l                 IB               <a                  <1                  «1                 <2                T
    BW42                                          oooim                OJ                107              <2                101             6003                  IJ                  .1                 «1               ES

    SaapM                                         07/1M0                                 111              <1J              2.710                                  1.T                                                     <10
    SaapM                                         04nM)1
    SavM                                          oanioi
    SaapM                                         03n»l2
    SaapM                                         0T/2«D2                                61                <1              1.180              4J                  41                  41                 42                 0
    SaipM                                         04n6m                                 160                <1              1J60               OJ                  41                  41                 42                 4
    SamM                                          07/23m                                100                <1              1430               4J                  41                  41                  2                 0
    SaapM                                         1208m                 <4              130       1        <1               391               4J                  41                  41                 42                42
    SaapM                                         04^304                <4              140                <1              1JS0               4J                  41                  2JI                42                14
    SaapM                                         0T/08O4                               120                41              1JM0               4J                  41                  IJ                  3                23


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    SaapM-dup                                     OKim                 OJ               07.T               4 j             1J00              OJO                 eo.i                  4                2.83               E6

    JS«
    JS«
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    JS-26                                         osoim                Ol                48                4 j              104              *a*                    3                  .1                 T
    J»26                                          01/2401                                                                                                                                               4J7
    JS-2B                                         04/1H0S
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                                                                                                                                                                                                                            —
                                                                                                                                                                                                                            3
    J&a                                           osoim                OJ                118               4 j              13J      1       4JM                 E0.1                 .1                1JM                 16
    JUI                                           4n«oaoi              «4                S9                41                10               4]                  41                  41                  6                 <2
    JMI                                           060708               OJ                87                42               71               OJS                  03                  02                                    3
    PB-1T                                         osoim
    PB-1T                                         oviom                 44                                 41                8                4J                  41                  <1                  2                 42
    PB-1T                                         osoim                 .1              408                4 j              OS               4JM                  02                   .1               247                 48




       OU3_VOC_labl»2008d Jds Table E1.rBport-table-2<)08                                                                                                                                                                         5of7




I
       T a b l e E l . Summary of ground-water quaHty data for 0 U 3 - C o n t i n u e d .
       |MCLmMnaimai»M*l««l«»itGWgi«MaMBr.Oond.ipiJ8eanaudMBn«ii4riia>iMap«riMrtiMfciiiaadiyrawn>ata.i^inlBBgiirap«rMg
        -., nDdito. <,tatf Ovn; E, • f t i M H l cnordnlDa; J. ndmaMbimfr^juaiylKMltorafBBKCBnipauid; R,nd>ctalduiiolMflsraHidrMoii(l
       U . iKid u t K r . boUMi M c r i M « k a M O M MemlBy MndBd V I M H U I vound M M Mndnrt. boldkM n d « a d i iricMM Mlut i t a M M O j


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       and oOMn, 1996)                                  410         47                                           <10             41             62             41
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       Bwgs                                              —           —             —                               —                             —              —
                                          mama           3          3                             42              3             41              280            42
       Bw^a                               i2oam         42          13           1.160            42              13            41              810            42
       BW03                               04^304        42                                        42                            41                             42
                                                                                                                  3                             240
       Bwes                               07/0704       43                                        42              3             41              230            42
       BW43                               osoim         R                         14              <2             3J4            4.1             271           4JM
       BW«3
       BW41                               07O3m         42                                         42             2             41              280            42
       BW31                               i2/iBm        42                                         42             4             41              2T0            <
       BW41                               i2ng«         <                                          42             3             41              270            42
       awdi                               04/i4m        42                                                        2             41              300            43
       BW41                               07/0004       <                                          42   •         1             41              260            42
       BW-31                              08/20m         R                                        E01             41
                                                                                                                   .            4.1             306           E0J2

       BW41A                              masm          42          13            4S              8               8             41              190            43
       BW41A                              i2nam         42                        at              42              3             41              190            42
       BW.31A                             04/1S04       42                        67              42              2             41              180            42
       BWJI/Mup                           04/iaO4       42                        67              42              3             41              180            42
       BW-31Ardup                         07/07/04      <                         31              42              4             41              170            42
       BW41A                              otRim          R                        T6              02             240            4.1             167           *a*
       BW«                                0703m         42                        18               42             4             41              290            42
       BW-32                              iznam         <                         12               42             7             41              220            42
       BW«                                04/1VD4       42                        4                <3             8             41              270            42
       BW-32                              mmaM          <                         4                42             9             41              240            43
       BW«                                oaoim          R                        1               EOJ            242            4.1             433           4J04




1
       SaapM                              OT/iom       41 JO        13            147             07             23J            410             438           4.80
       SaapM                              04nooi
       SavM                               osnioi
       SaapM                              oansm
       SaapM                              OTOUB         42          0             81
       SaapM                              04/iara       42          19            271
       SaapM                              masm          42          12           284
       SaapH                              i20om         <           4              2
       SaapM                              04nsot        42          14           2J»
       SaapM                              07/0004       42          8             898
       BaapMdup                           07/0004       <           8             819
       SaapM                              osaim          R          20            138
       SaapM-dup                                         R          20            138


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                                          oeoim
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       JS-28                              osoim 

       JS-28                              01/2401 



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ll 
     OU3_VOC_tsble-2008djds Table E1_rBport-table-2008                                                                                                              eof7


II 

I

     Tabto E l . Summary of ground-water quafity data fdr OU3 -Continued.




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     BW41A                                       i^em                41               2
     BW41A                                       04/1904             41               2
     BW^I/Ubp                                    04nBO4              41               42
     BW-31/Mup                                   070704              41               S
     BW-SIA                                      osoim                1               TJ
     BW-32                                       07/23m             41                42
     BW-32                                       i2nam              4i                3
     BW-32                                       04n4O4             41                2
     BW-32                                       07/0604            41                6
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     SaapM                                       otnooi                                _
     SaapM                                       oonioi               -                _
     SaapM                                       osnsm                                 -
     SaapM                                       07O«a               41              182
     SaapM                                       04nora              <1              287
     SaapM                                       masm                41              181
     SaapM                                       i2O0m               41               4
     SaapM                                       04n3O4              41              202
     SaapM                                       07/0604             41              ISO
                                                 07/0604             41              128




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     SaapM                                       oaoim [ ^            2              387
     SaapM4up                                    oaoim                1              380
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     JS-2B                               oemm            OJ                17J
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        OU3_VOC_table-2008d,xi8 TaUa E1_repo(MBbl»-2008                                                                                                                                                   7ot7


il
I
                  OUS
                     Final
Fall 2008 Sampling Data Evaluation Report
          Riverfront Superfund Site
            New Haven, Missouri

            Operable Unit 5 

           Old Hat Factory Site 

                                                 Table 4-2 

                                      Historical PCE Data Summary 

                                           Riverfront 01)5 Site 


                             Well Number           Sample Date            PCE (uc|/L) 1
                                                     10/27/04              0.46 
   J
                                                     02/01/05              0.49 
 J
                                                     09/21/05              0.70 
 J
                                 BW-09'            . 10/29/07              2.3
        i
                                                   10/23/2008'             0.87 
  J
                                                     10/28/08              0.59
      1
                                                     07/29/02               49 

                                                     08/12/03               37 

                                                     08/19/04               27 

                                                     02/01/05              110 

                               BW-09A '                                     52 

                                                     06/14/05
                                                     09/21/05               47 

                                                     10/25/07               24 

                                                     10/28/08             30(26) 

                                                     04/26/04               1.0 

                                                                                    ^
                                                     08/19/04              0.49 

                                                                                    '
                                                     02/01/05              0.23 
   J
                               BW-12A '
                                                     09/21/05               1.0 
   U
                                                     09/20/06               1.0 
   U
                                                     10/28/08               0.5 
   u
                                 BW-15
                                                     01/30/08               0.5 
   u
                                                     10/28/08               0.5 
   u
                                                     01/30/08             49(19)
          1
                                 BW-16
                                                     10/28/08               32 

                             1 - All PCE data except from 10/28/08 provided by USGS 2009. 

                             2 - Data collected by USGS. 

                             U = Not detected at or above the reportable level shovwi. 

                               =
                             J • The associated numerical value Is an estimated quantity. 

                             ug/L = micrograms per liter 

                             Shaded results indicate wfiere contaminant was detected 

                             above cleanup level (PCE and Carbon Tetrachloride = 5 ug/L). 

                             Duplicate sample results in parentheses. 





II


     Riverfront Site - OUS                                                                       044752 

     LTRA                                                    4-7                               Apnl 2009 

                                                     Table 4-3 

                                          COC Results Summary - Fall 2008 

                                               Riverfront OUS Site 


                                                                       PCE                C a r b o n Tetrachloride
                                 Well Number                          (ug/L)                       (ug/L)

                                                                  October 2008                 October 2008

                                          Sample Depth
                      Groundwater
                                              (ft btoc)
                            BW-9                  166                0 59                          05           U         

                           BW-9A                   40               30(26)                         0.5          U     

                           BW-12A                  40                 0.5             u            0.5          U

                                                  70.5                NS 	                         NS

                           BW15
                                                  73.5                0.5 	           u            0.5           U
                                                  76.5                0.5             U            0.5           U
                                                  79.5 	              0.5             U            05            U
                                                   70                 NS                           NS
                           BW-16 	                 73                 27                           7.7
                                                   76                 32                           8.S


                    ug/L = micrograms per liter
                    Stiaded results indicate where contaminant was detected above cleanup level
                      (PCE and Carbon Tetrachloride = 5 ug/L).
                    Ctilorfrom was not detected
                    Result U = Not detected at or atiove the reportable level showa
                    Duplicate sanple results in parentheses.
                    NS = Not Availat>le to tie sampled because of low water level.
                    ft btoc = feet below top of casing
                    Other VOCs detected infrequently at low concentrations include:
                      TCE was detected at 3.2 ug/L in the primary sample for Well BW-9Aandat3.1 ug/L 

                       in the BW-9A duplicate sample. 





Riverfiom She OUS                                                                                                               044752 

LTRA                                                                4-8                                                       April 2009 


								
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