Post on 16-Oct-2020
FIFTH FIVE-YEAR REVIEW REPORT FOR
BIG D CAMPGROUND SUPERFUND SITE
ASHTABULA COUNTY, OHIO
Prepared by
U.S. Environmental Protection Agency
Region 5
Chicago, Illinois
XDouglas Ballotti, Director
Superfund Emergency & Management Division
Signed by: DOUGLAS BALLOTTI
9/30/2019
950945
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Table of Contents LIST OF ABBREVIATIONS & ACRONYMS ........................................................................................ 3 I. INTRODUCTION .................................................................................................................................. 4
Site Background ..................................................................................................................................... 4
Five-Year Review Summary Form ........................................................................................................ 5 II. RESPONSE ACTION SUMMARY ..................................................................................................... 5
Basis for Taking Action ......................................................................................................................... 5 Response Actions ................................................................................................................................... 6 Status of Implementation ....................................................................................................................... 7
Institutional Controls ............................................................................................................................. 8 Systems Operations/Operation & Maintenance ................................................................................... 10
III. PROGRESS SINCE THE LAST REVIEW ...................................................................................... 10
IV. FIVE-YEAR REVIEW PROCESS ................................................................................................... 12 Community Notification, Involvement & Site Interviews ................................................................... 12 Data Review ......................................................................................................................................... 12 Site Inspection ...................................................................................................................................... 13
V. TECHNICAL ASSESSMENT ........................................................................................................... 16 QUESTION A: Is the remedy functioning as intended by the decision documents? ......................... 16
QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action
objectives (RAOs) used at the time of the remedy selection still valid? ............................................. 16 QUESTION C: Has any other information come to light that could call into question the
protectiveness of the remedy? .............................................................................................................. 17 VI. ISSUES/RECOMMENDATIONS .................................................................................................... 17
VII. PROTECTIVENESS STATEMENT ............................................................................................... 18
VIII. NEXT REVIEW .............................................................................................................................. 19
REFERENCE LIST ................................................................................................................................. 20 APPENDIX A…………………………………………………………………………………………...21
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LIST OF ABBREVIATIONS & ACRONYMS
AOC Administrative Order on Consent
ARAR Applicable or Relevant and Appropriate Requirement
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
CFR Code of Federal Regulations
COCs Contaminants of Concern
DAT 2,4 diaminotoluene
DCA Dichloroethane
DCB Dichlorobenzene
DCE Dichloroethene
EPA United States Environmental Protection Agency
ESD Explanation of Significant Differences
FS Feasibility Study
FYR Five-Year Review
ICs Institutional Controls
MCB Monochlorobenzene
MCLs Maximum Contaminant Limits
MEA Monoethanolamine
MNA Monitored Natural Attenuation
NCP National Contingency Plan
NCP National Oil and Hazardous Substances Pollution Contingency Plan
NPL National Priorities List
O&M Operation and Maintenance
OEPA Ohio Environmental Protection Agency
ORP Oxidation Reduction Potential
OSWER Office of Solid Waste and Emergency Response
PCE Perchloroethylene or perchloroethene or tetrachloroethene
QAPP Quality Assurance Project Plan
RAS Remedial Action Standard
RI Remedial Investigation
RI/FS Remedial Investigation/Feasibility Study
PRP Potentially Responsible Party
RAO Remedial Action Objectives
ROD Record of Decision
RPM Remedial Project Manager
Site Big D Campground Superfund Site
TBC To be considereds
UU/UE Unlimited Use and Unrestricted Exposure
VC Vinyl Chloride
VOC Volatile Organic Compound
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I. INTRODUCTION
The purpose of a Five-Year Review (FYR) is to evaluate the implementation and performance of a
remedy in order to determine if the remedy is and will continue to be protective of human health and the
environment. The methods, findings, and conclusions of reviews are documented in FYR reports such as
this one. In addition, FYR reports identify issues found during the review, if any, and document
recommendations to address them.
The United States Environmental Protection Agency (EPA) is preparing this FYR pursuant to the
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Section 121,
consistent with the National Contingency Plan (NCP)(40 CFR Section 300.430(f)(4)(ii)) and considering
EPA policy.
This is the fifth FYR for the Big D Campground Superfund Site (Big D Site or Site). The triggering
action for this statutory review is the completion date of the previous FYR. The FYR has been prepared
due to the fact that hazardous substances, pollutants, or contaminants remain at the site above levels that
allow for unlimited use and unrestricted exposure (UU/UE).
The Site consists of two Operable Units (OUs). Both are addressed in this FYR. The remedy for OU1
addresses groundwater at the site, and the remedy for OU2 addresses the source material.
The Big D Site FYR was led by Bill Ryan and Dion Novak, Remedial Project Managers (RPM) for
EPA. Regan Williams and Scott Aschenbrenner, Project Managers for the Ohio Environmental
Protection Agency (OEPA), provided support in the review of monitoring data and site conditions.
A notice sent to OEPA and the Potentially Responsible Parties (PRPs) on 4/2/2018 officially initiated
this review.
Site Background
The Big D Site is a former sand and gravel quarry located in Kingsville, Ohio, approximately 2.5 miles
south of Lake Erie and 50 miles northeast of Cleveland, Ohio. The Site lies between Creek Road and
Conneaut Creek, with residential areas and the former Big D Campground nearby. The southern portion
of the site contains a small, capped landfill that accepted hazardous and non-hazardous waste for
disposal when the quarry was operating. Known hazardous waste disposed in the landfill at the site
included residues from toluene diisocyanate (TDI) production, toluene diisocyanate, chlorobenzene, and
diaminotoluene. In addition to the known hazardous wastes, other wastes of undocumented type and
quantity were disposed of in the landfill. Available information suggests that these wastes included
drummed halogenated and non-halogenated solvents, caustics, and oily substances. Waste in the landfill
contaminated surrounding soil and groundwater with volatile organic compounds (VOCs) and heavy
metals including barium, chromium, and lead.
The current land use for the surrounding area is both residential and recreational, and Conneaut Creek is
used for fishing and swimming. EPA anticipates that these land uses will continue into the foreseeable
future. The Site is currently fenced, and the incinerated waste and soils are contained within the fenced
area under a landfill cap. Groundwater at the Site is currently not used as a source of drinking water, and
the PRP for the Site, Olin Corporation (Olin), has acquired the groundwater rights of the surrounding
property owners. Olin has also placed deed restrictions on these nearby properties to prohibit the future
use of groundwater.
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FIVE-YEAR REVIEW SUMMARY FORM
SITE IDENTIFICATION
Site Name: Big D Campground
EPA ID: OHD 980611735
Region: 5 State: OH City/County: Kingsville/Ashtabula
SITE STATUS
NPL Status: Final
Multiple OUs? Yes Has the site achieved construction completion? Yes
REVIEW STATUS
Lead agency: EPA, Region 5
Author name: Bill Ryan and Dion Novak
Author affiliation: EPA Region 5
Review period: 4/2/2018 – 8/10/2019
Date of site inspection: 5/23/2018, 8/13/2019
Type of review: Statutory
Review number: 5
Triggering action date: 4/16/2014
Due date (five years after triggering action date): 4/16/2019
II. RESPONSE ACTION SUMMARY
Basis for Taking Action
Hazardous substances have been released at the Big D Site. As recorded in the 1989 Record of Decision
(ROD), these substances included:
Source Area Soil Groundwater Surface Water
barium barium barium barium
lead beryllium beryllium beryllium
nickel lead lead lead
chlorobenzene nickel nickel nickel
1,2-dichlorobenzene chlorobenzene chlorobenzene chlorobenzene
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1,4-dichlorobenzene 1,2-dichlorobenzene 1,2-dichlorobenzene
trichloroethene 1,4-dichlorobenzene 1,4-dichlorobenzene
tetrachloroethene trichloroethene trans-1,2 dichloroethene
vinyl chloride tetrachloroethene diaminotoluene
vinyl chloride trichloroethene
tetrachloroethene
vinyl chloride
The primary risks at the Site were from ingestion of contaminated groundwater. VOCs were detected in
shallow wells screened in the water table aquifer and in wells screened in the alluvial over bank deposits
along Conneaut Creek. No contamination was found in the confined bedrock aquifer. No VOCs
attributable to site activities were detected in the residential wells sampled. Surface water samples from
Conneaut Creek indicated that no contaminants of concern (COCs) were present above Remedial Action
Standards (RASs). Chlorobenzene was the only organic compound detected in surface water samples
from Conneaut Creek; however, all detections were below RASs. No sediment contamination
attributable to site activities was detected. Groundwater monitoring continues at the site and is focused
on residual VOCs.
Response Actions
Big D was proposed for the National Priorities List (NPL) in December 1982 and it became final on
the NPL in September 1983. EPA subsequently conducted a fund-financed Remedial Investigation (RI)
from November 1986 to October 1988 to: 1) determine the nature and extent of contamination at the
Site, 2) determine whether substances migrating from the Site endangered public health, welfare, or
the environment, and 3) gather the data necessary to support a feasibility study. EPA concluded in the
RI report that the waste buried in the former landfill had contaminated soil and groundwater.
EPA subsequently completed a fund-financed Feasibility Study (FS) of cleanup alternatives to address
the contaminated media.
The Big D site was divided into two OUs: groundwater (OU1) and source area material (OU2).
Both organic compounds and certain heavy metals were initially identified as COCs in the RI/FS report,
but in 1993 EPA issued an Explanation of Significant Differences (ESD) removing metals as COCs. The
current COCs include perchloroethene (PCE), trichloroethene (TCE), trans-1,2-dichloroethene (tDCE),
vinyl chloride (VC), diaminotoluene (2,4-DAT), and monochlorobenzene (MCB). These COCs are
found in the water table aquifer that flows northward from the former landfill. The water table aquifer is
underlain by a glacial till aquitard and is not hydraulically connected to the underlying bedrock aquifer.
EPA issued a ROD in 1989 to clean up both OUs. The selected remedy required the following:
• Site fencing
• Excavation and on-site incineration of source area material
• On-site disposal of treated residuals and backfilling
• Groundwater extraction and treatment
• Discharge of treated groundwater to Conneaut Creek
• Groundwater and surface water monitoring
• Deed restrictions
The groundwater extraction and treatment remedy was modified in an ESD to include an interceptor
trench that was installed adjacent to Conneaut Creek.
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EPA also issued a Unilateral Administrative Order (UAO) in 1989, requiring Olin to conduct the
selected cleanup actions. Olin excavated and incinerated waste materials on-site, placed a clay cap
over the former landfill, and began operating the groundwater extraction and treatment system in 1994.
Olin also connected nearby residences to municipal water and placed deed restrictions on the
surrounding properties to prohibit the current and future use of groundwater as well as limiting
excavation in specific Site areas. EPA approved the Remedial Action Implementation Report
documenting compliance with remedy requirements in March 1995.
Remedial Action Objectives (RAOs) for the Site were established to address risk and comply with
Applicable or Relevant and Appropriate Requirements (ARARs). They include the following:
• Adequately protect the environment and public health from ingestion or direct contact with
contaminated groundwater at the Site, and
• Reduce the concentrations of Site COCs in groundwater to their respective cleanup goals.
RASs for the Site for groundwater are as follows:
Contaminant of Concern Cleanup Goal (μg/L) PCE 5 TCE 5 tDCE 100 VC 2
MCB 100 2,4-DAT 50
Status of Implementation
Source Area Excavation
A total of 93,219 tons of material were excavated from the former landfill and incinerated. This resulted
in an excavated area of approximately 2.7 acres with dimensions of 230 feet wide by 510 feet long and
18 feet deep. The excavated area was backfilled with ash and covered with clean fill and vegetated
topsoil.
On-site incineration
The incinerator trial burn was conducted in September 1992 under the terms of an EPA interim burn
approval. The interim burn continued until February 1993, when EPA approved the trial burn report,
from which full burn production commenced. During the trial burn, ash was tested in accordance with
the Confirmation of Incinerator Ash Delistability Plan. The combination of the trial burn and the
periodic ash sampling analysis confirmed that the ash was eligible for delisting and EPA allowed the ash
to be placed into the landfill. Wastes excavated from the former landfill were incinerated and the ash
was sampled prior to being placed back into the landfill.
The Remedial Action Implementation Report was approved by EPA in March 1995.
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Water Table Aquifer Groundwater Collection System
The selected remedy for the water table aquifer was two interceptor trenches: one at the downgradient
edge of the contaminant plume and one at the north end of the source area. Olin designed a modified
groundwater extraction system to include the use of active groundwater pumping using wells in the
water table aquifer and an approximately 500-foot-long artificial recharge trench. This design change
was approved by EPA in a 1993 ESD.
Eight extraction wells were installed. Ten monitoring wells were installed to be sampled quarterly to
determine the extent of the groundwater plume. The potable water recharge system, supplied by city
water, was installed at the north end of the excavation.
The groundwater extraction system was shut down in 1999 in order to complete a pilot study evaluating
monitored natural attenuation (MNA) as a Site remedy for groundwater. The system has remained shut
down as additional groundwater monitoring information has been collected. A Focused Feasibility Study
was submitted to EPA in 2018, in which the PRPs were asked to summarize existing groundwater data
and to present information to support a potential remedy change to MNA. EPA has asked the PRPs to
update the contaminant trend analyses to more fully depict current conditions.
Confined Bedrock Aquifer Groundwater Collection System
The selected ROD remedy called for groundwater extraction in the bedrock aquifer. However,
information collected during the remedy design indicated that the bedrock aquifer was not impacted by
the Site. As memorialized in the 1993 ESD, groundwater extraction from the bedrock aquifer was
replaced by annual monitoring of the bedrock aquifer.
On-site groundwater treatment
All groundwater was processed through the existing treatment plant and effluent sampling was
conducted. A treatability study was performed to demonstrate compliance with treatment requirements
prior to full treatment plant design. The initial treatment included metals removal, air stripping, and
GAC polish treatment. In November 1997, EPA approved a change in treatment, eliminating the metals
removal requirement.
An 8-inch PVC pipe conveyed treated water to a discharge point north of Conneaut Creek when the
treatment plant was in operation. All water discharged from the treatment plant complied with
applicable regulations.
Institutional Controls
Institutional controls (ICs) are required at the Site to ensure the protectiveness of the remedy. ICs are
non-engineered instruments, such as administrative and/or legal controls, that help minimize the
potential for exposure to contamination and protect the integrity of the remedy. Compliance with ICs is
required to assure long-term protectiveness for any areas which do not allow for UU/UE.
A summary of the implemented and planned ICs for the Site is listed in Table 1 and are further
discussed below. A map showing the area in which the ICs apply can be found in the 2010 Institutional
Control Communication Plan for the Site.
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Table 1: Summary of Planned and/or Implemented ICs
Media,
engineered
controls, and
areas that do
not support
UU/UE based
on current
conditions
ICs
Nee
ded
ICs Called
for in the
Decision
Documents
Impacted
Parcel(s)
IC
Objective
Title of IC
Instrument
Implemented
and Date (or
planned)
Landfill
Cover Yes Yes
270060004803
270060004800
Olin to have full and unrestricted
access; prohibited from making any
changes to surface contours;
prohibited from conducting interfering
activities;
prohibited from drilling wells or
extracting groundwater;
prohibited from excavating the former
Olin project site (270060004800);
prohibited from any excavation on the
exclusion area at the northwest corner
of the property;
prohibited from excavating below 12
feet on the remainder of parcel
270060004803, except that there shall
be no limit on excavating on the
property south of Conneuaut Creek;
commercial development or residential
development on the property north of
Conneaut Creek is prohibited;
owner of parcel 270060004803 may
construct for his personal use or
residential dwelling at the area of
highest elevation along Creek Road;
existing fences on parcel
270060004800 are to be maintained by
the owner as is in order to restrict the
presence of anyone not involved in
administering the administrative order
or CERLCA remedy;
prohibited from erecting any building
or structure unless approved by Olin
or
EPA as a necessary component of the
administrative order or CERCLA
remedy
Grandfathered
deed
restriction
under Ohio's
UECA, June
11, 2009
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Residential
properties
Yes Yes Numerous
properties
Residential properties are required to
have no use of well water and are
prohibited from excavating below an
agreed upon depth
Grandfathered
deed
restriction
under Ohio's
UECA, June
11, 2009
Status of Access Restrictions and ICs: Restrictive easements were placed on the properties overlying
the source area and contaminant plume, as required in the ROD, to prohibit installation or use of
drinking water wells in any of the three aquifers present at the Site.
In 2009, EPA conducted an evaluation of ICs and determined that the existing deed restrictions at the
site were legally enforceable and to be grandfathered under Ohio's Uniform Environmental Covenant
Act (UECA), Ohio Revised Code Section 5301.85(c). This determination was based upon information
Olin provided to EPA in November 2008. Upon EPA request, Olin provided additional site ICs
information for review in March 2010 including the 2010 Institutional Control Communication Plan,
which contains information on governmental controls, a communications plan, mapping, title work for
individual parcels, and planned development.
Current Compliance: Based on current inspections of the Site, EPA is not aware of Site or media uses
which are inconsistent with the stated objectives to be achieved by the ICs. No Site uses which are
inconsistent with the implemented ICs or remedy IC objectives have been noted during Site inspections.
IC Follow up Actions Needed: There are no IC follow up actions needed.
Long-Term Stewardship: As stated in the EPA approved 2010 Institutional Control Communication
Plan for the Site, Olin conducts an annual deed review to determine if any of the properties with Olin
imparted restrictive covenants have changed ownership. If a change has occurred, Olin mails a
description of the covenants placed on the property deeds to the new owner. Olin also provides a contact
phone number to the affected residents for any follow-up questions. Olin has completed this process
several times since the plan was approved, as was discussed during the recent Site inspection.
Systems Operations/Operation & Maintenance
Olin periodically conducts site operation and maintenance (O&M) on the landfill cap (e.g., repairing
animal holes, maintaining the vegetative cover) and ensures site security by inspecting the site and
maintaining the site fence. Additionally, groundwater and surface water monitoring is conducted
annually. Since the last FYR, the building housing the treatment system was vandalized and the
treatment system was damaged beyond repair, as documented during the recent Site inspection
(the system hasn’t been in operation since 1999).
III. PROGRESS SINCE THE LAST REVIEW
This section includes the protectiveness determinations and statements from the last FYR as well as the
recommendations from the last FYR and the current status of those recommendations.
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Table 2: Protectiveness Determinations/Statements from the 2014 FYR
OU # Protectiveness
Determination Protectiveness Statement
1 Protective in the short term The OU l remedy is protective of human health and the
environment in the short-term because no one is drinking
contaminated groundwater and institutional controls (ICs) are
in place to prevent groundwater use. However, in order for the
remedy to be protective in the long term, the following actions
need to be taken: complete the evaluation of MNA as a
treatment option. If EPA determines that MNA is a viable
remedy for reaching the groundwater cleanup standards, a
decision document to alter the originally-selected groundwater
remedial action to MNA will be completed. If EPA determines
that MNA is not a viable remedy, then the groundwater
treatment system will be reactivated and operated to achieve
the groundwater cleanup goals. 2 Protective The OU2 remedy is protective of human health and the
environment because the source materials have been
incinerated and residual contaminants are contained in the
landfill, thus, no unacceptable exposures exist. ICs are in place
to prevent disturbance of the landfill cap. Site-wide Protective in the short
term
The remedial actions are protective of human health and the
environment in the short-term. However, in order for the
remedy to be protective in the long term, a decision must be
made by EPA as to the most viable remedy for reaching the
groundwater cleanup standards within a reasonable time period
and the operation of that remedy to achieve the groundwater
cleanup goals.
Table 3: Status of Recommendations from the 2014 FYR
OU # Issue Recommendations
Current
Status
Current Implementation Status
Description
Completion
Date (if
applicable) Complete the
evaluation of MNA
as a viable option for
groundwater cleanup
EPA, in consultation
with OEPA, should
make a determination
whether MNA is a
viable option based
on the information
provided by Olin*
*If EPA determines
that MNA is a viable
remedy for reaching
the groundwater
cleanup standards, it
will issue a decision
document to alter the
originally-selected
groundwater remedial
action to MNA. If
EPA determines that
MNA is not a viable
Ongoing EPA has requested additional
information regarding the MNA
assessment, which was included in a
focused FS report submitted in 2018.
EPA will provide comments on this
report when the Site PRP amends the
assessment to include additional
aquifer trend analyses.
NA
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groundwater remedial
action to meet the
groundwater cleanup
goals in a reasonable
amount of time, then
Olin will reactivate
the groundwater
treatment system
with appropriate
operation and
maintenance
In addition, the following activity was identified during the 2014 FYR to be completed that does not
affect current nor future protectiveness:
Olin submitted a long-term monitoring plan to EPA in July 2012. The plan calls for a reduction in the
number of monitoring wells and the number of analytes. EPA has not commented on the long-term
monitoring plan to date but plans to do so after it makes its determination concerning the viability of
MNA at the Big D Campground site. This plan will be updated as necessary based on current
groundwater conditions and EPA’s determination regarding the viability of MNA for the groundwater
remedy.
IV. FIVE-YEAR REVIEW PROCESS
Community Notification, Involvement & Site Interviews
A public notice was made available by publishing a notice in a local newspaper, the Star Beacon, on
4/28/2018, stating that there was a FYR and inviting the public to submit any comments to EPA.
The results of the review and the report will be made available to the public at the following locations:
Kingsville Public Library
6006 Academy Street
Kingsville, OH 44048
EPA’s Chicago office
Superfund Records Center, 7th Floor
77 W Jackson Blvd.
Chicago, IL 60604
Data Review
Olin collects groundwater monitoring samples on a semi-annual basis. Water samples are collected from
19 monitoring wells during the spring sampling event and from 25 monitoring wells during the fall
sampling event. The samples are collected using low-flow sampling techniques and then analyzed for
Site COCs and for natural attenuation parameters. The field sampling parameters are: dissolved oxygen,
iron (II), oxidation reduction potential (ORP), pH, specific conductance, temperature, and turbidity.
The laboratory sampling parameters are VOCs, carbon dioxide, chloride, total organic carbon, ethylene,
methane, nitrate, sulfate, sulfide total alkalinity and hydrogen. Groundwater level measurements are also
performed. Sampling is conducted in accordance with the EPA approved quality assurance project plan
(January 2000).
Groundwater data from this review period indicates that chlorobenzene and vinyl chloride were detected
above regulatory standards at a number of on-site well locations. Other contaminants, such as
tetrachloroethane, cis 1,2-dichloroethylene, and 1,1-dichloroethylene, have been detected sporadically at
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levels above MCLs. Detected concentrations for chlorobenzene range to 14,000 parts per billion (ppb)
(the cleanup goal is the federal maximum contaminant level (MCL) established under the Safe Drinking
Water Act of 100 ppb), although results trended downward in more recent sampling. The detected
concentrations for vinyl chloride ranged to 140 ppb (the MCL for vinyl chloride is 2 ppb) again with
downward trends throughout the review period. A more complete summary of groundwater data during
the last five years is included in Appendix A.
EPA has requested sampling of several residential wells located south of Conneaut Creek to assist in
determining whether the deeper shale aquifer is being impacted by the Site. This information will be
used for the overall MNA determination for the site. Previous monitoring does not show impacts in this
lower aquifer where these wells are located. The current groundwater plume remains stable according to
existing groundwater monitoring information, but this additional sampling will help to supplement
previous data and is expected to confirm the existing understanding of the groundwater plume.
The groundwater treatment system that was constructed remains shut down while EPA continues to
evaluate the viability of MNA as a cleanup option for groundwater. The Site inspection noted that the
inside of the water treatment building had been vandalized. If EPA requires the restart of the
groundwater pump and treat system, the treatment infrastructure will have to be completely rebuilt.
Groundwater monitoring data collected within the last five years has indicated that the contaminant
plumes remain within the deed restricted area. Residents in the area of the Site are connected to the
municipal water supply and, as such, there is no current exposure based on available monitoring data.
However, additional data will be used to review the previous determination and ultimately will be used
to make a decision for MNA.
A full analysis of collected groundwater data will be conducted that will build on the previously
submitted monitoring results reports, the MNA demonstration report submitted in 2010, the focused
feasibility for MNA submitted in 2018, and the additional residential well sampling to be completed by
the end of 2019. The FFS was determined to be incomplete because a complete site-wide analysis of
contaminant trends was not included to help make a complete determination on the viability of MNA for
groundwater. The MNA evaluation will include full trend analyses for all collected data and EPA will
use this information to ultimately determine whether the ongoing shutdown of the groundwater
extraction system remains appropriate, or if groundwater conditions warrant restart of the system to
achieve the groundwater cleanup goals.
Site Inspection
There were two inspections of the Site. The first was conducted by Bill Ryan on May 23, 2018.
The second was conducted by Dion Novak on August 13, 2019. For the August 13, 2019 inspection, in
attendance were Dion Novak, EPA RPM, Scott Aschenbrenner, OEPA, and James Cashwell
representing Olin Corporation. The purpose of the inspections was to assess the protectiveness of the
remedy.
EPA and OEPA inspected the water treatment building, the landfill cover, monitoring wells and
piezometers, and Conneaut Creek. The inspection discovered that the inside of the water treatment
building had been vandalized with most of the infrastructure damaged beyond repair. Mr. Cashwell
indicated that a police report had been filed and the decision was made not to press charges against the
perpetrators. The vegetation on the cover was in good condition and all observed monitoring wells were
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also in good condition. The monitoring wells near the Creek were also in good condition and locked.
Signs were present on the site fencing prohibiting trespassing. All fencing was in good condition.
Mr. Cashwell indicated that if EPA ultimately requires the restart of the groundwater pump and treat, the
treatment infrastructure will have to be completely rebuilt. This determination will be made following
the completion of the evaluation for MNA.
The following photographs were taken during the site inspection:
Southern site boundary on bluff
facing Conneaut Creek
Landfill cover and perimeter fence along
creek looking north
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Landfill cover
looking north
Front gate to site
Vandalized groundwater
treatment system
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V. TECHNICAL ASSESSMENT
QUESTION A: Is the remedy functioning as intended by the decision documents?
Question A Summary:
Yes. A review of the relevant documents and the results of the FYR site inspection indicate that the
remedy is functioning as intended by the ROD. Major remedy construction (source area excavation,
incineration on-site, disposal of treated material and backfilling on-site) was successfully completed in
1995. Materials consolidated on-site, including incineration treatment residuals, are adequately
contained beneath the vegetated cover. Access controls and ICs are currently effective in preventing
exposure to on-site covered materials and contaminated groundwater.
The groundwater treatment system that was constructed remains shut down while EPA continues to
evaluate the viability of MNA as a cleanup option for groundwater. The Site inspection noted that the
inside of the water treatment building had been vandalized. If EPA requires the restart of the
groundwater pump and treat, the treatment infrastructure will have to be completely rebuilt.
Groundwater monitoring data collected within the last five years has indicated that the contaminant
plumes remain within the deed restricted area. However, additional groundwater monitoring including
residential well sampling of wells south of Conneaut Creek, will be used to update the previous data.
Previous monitoring does not show impacts in the lower aquifer where these wells are located.
The current groundwater plume remains stable according to existing groundwater monitoring
information. This additional sampling will help to supplement previous data and is expected to confirm
the existing understanding of the groundwater plume. Residents in the area of the Site are connected to
the municipal water supply and, as such, there is no current exposure based on available monitoring
data.
An IC Study was performed by Olin and EPA has found that adequate and enforceable ICs are in place,
including prohibitions on: (1) use of groundwater; (2) excavation activities; (3) disturbance of the cap;
and (4) any other activities or actions that might interfere with the implemented remedy. No activities
were observed that would have violated the ICs, except for the vandalism of the treatment building and
destruction of the treatment system. If the results of the MNA analysis indicate that the groundwater
treatment system should be reactivated, Olin will have to rebuild or repair the existing system to ensure
proper groundwater treatment operations. The cap and the surrounding area were undisturbed, and no
new uses of groundwater were observed at the Site during the Site inspection.
QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action
objectives (RAOs) used at the time of the remedy selection still valid?
Question B Summary:
Yes. There have been no changes in the physical conditions of the site that would affect the
protectiveness of the selected remedy. There have been no changes in the ARARs requirements that
would affect the protectiveness of the remedy. There have not been any changes in the use of the
property during the last five years. There have been no changes in land use near the site, nor are changes
expected in the near future. There have been no newly observed species or ecological settings.
There have been no changes in most of the human and ecological exposure assumptions or the toxicity
17
data that were used in the risk assessment at the time of the remedy selection that would affect the
protectiveness of the remedy. EPA has released revised Vapor Intrusion screening and risk assessment
guidance since the time of the remedy selection. While not expected to be an issue affecting the
protectiveness of the remedy, in an abundance of caution, EPA and OEPA have requested vapor
intrusion sampling to the south of the Site to determine if this is a potential exposure pathway.
There have been no other changes in the standardized risk assessment methodology that would affect
the protectiveness of the remedy. The RAOs used at the time of remedy selection are still valid.
QUESTION C: Has any other information come to light that could call into question the protectiveness
of the remedy?
No. There is no other information that calls into question the protectiveness of the remedy.
VI. ISSUES/RECOMMENDATIONS
OU(s) without Issues/Recommendations Identified in the Five-Year Review:
2
Issues and Recommendations Identified in the Five-Year Review:
OU(s): 1 Issue Category: Remedy Performance
Issue: Complete the evaluation of MNA as a viable option for groundwater
cleanup.
Recommendation: EPA, in consultation with OEPA, should finalize a
determination on whether MNA is a viable option based on the information
provided by Olin*.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party
Responsible
Oversight Party Milestone Date
No Yes PRP EPA/State 9/30/2020
*EPA must complete a determination on whether MNA is a viable remedy for reaching the
groundwater cleanup standards in a reasonable timeframe. If EPA determines that MNA is not a
viable groundwater remedial action to meet the groundwater cleanup goals in a reasonable
amount of time, then EPA will direct Olin to immediately reactivate the groundwater treatment
system, with associated operation and maintenance.
OTHER FINDINGS
In addition, the following are recommendations that were identified during the FYR and (may improve
performance of the remedy, reduce costs, improve management of O&M, accelerate site close out,
conserve energy, promote sustainability, etc.), but do not affect current nor future protectiveness:
• sampling of several residential wells located south of Conneaut Creek to assist in determining if
the deeper shale aquifer is being impacted by the Site; and
18
• vapor intrusion sampling to the south of the Site to determine whether this is a potential pathway
of concern.
VII. PROTECTIVENESS STATEMENT
Protectiveness Statement(s)
Operable Unit:
1
Protectiveness Determination:
Short-term protective
Protectiveness Statement:
The OU1 remedy is currently protective of human health and the environment because no one is drinking
contaminated groundwater and ICs are in place to prevent groundwater use. However, in order for the
remedy to be protective in the long term, the following actions need to be taken to ensure protectiveness:
EPA will complete the evaluation of MNA and determine if MNA is a viable remedy for reaching the
groundwater cleanup standards in a reasonable timeframe. If EPA determines that MNA is not a viable
remedy, then the groundwater treatment system will be immediately reactivated and operated to achieve
the groundwater cleanup goals.
Protectiveness Statement(s)
Operable Unit:
2
Protectiveness Determination:
Protective
Protectiveness Statement:
The OU2 remedy is protective of human health and the environment because the source materials have
been incinerated, residual contaminants are contained in the landfill, and no unacceptable exposures
exist. Effective ICs are in place to prevent disturbance of the landfill cap.
Sitewide Protectiveness Statement
Protectiveness Determination:
Short-term protective
Protectiveness Statement:
The remedy at the Big D Campground site is currently protective of human health and the environment
because source materials have been incinerated, residual contaminants are contained in the landfill, no
one is drinking the groundwater, and no unacceptable exposures exist. Effective ICs are in place to
prevent disturbance of the landfill cap and to prevent groundwater use. However, in order for the remedy
to be protective in the long term, the following action needs to be taken to ensure protectiveness: EPA
needs to finalize a determination on whether MNA is a viable option for reaching the groundwater
cleanup standards within a reasonable time period and, if not, direct the immediate reactivation of the
groundwater treatment system, with associated operation and maintenance.
19
VIII. NEXT REVIEW
The next FYR report for the Big D Campground Superfund Site is required five years from EPA’s
signature date of this review.
20
REFERENCE LIST
• 4th Five Year Review April 16, 2014
• Record of Decision September 29, 1989
• Institutional Control Communication Plan-2010
• Focused Feasibility Study – 2018
21
APPENDIX A: Groundwater Data Summary
Result Qualifier Result Qualifier Result Qualifier Result Qualifier Result Qualifier Result Qualifier Result Qualifier Result Qualifier Result Qualifierug/l 5/8/14 0.8 U 590 0.8 U 1.6 0.8 U 0.8 U 0.5 JQ 3.7ug/l 10/2/14 2 U 1800 2 U 2 U 2 U 2 U 2 U 2 Uug/l 5/7/15 2 U 760 2 U 2.5 2 U 2 U 2 U 0.9 JQug/l 10/7/15 2 U 1900 2 U 6 2 U 3.1 2 U 2 Uug/l 10/2/14 1 U 50 U 2.4 1 U 1 U 1 U 1 U 1 U 1 UJug/l 10/8/15 1 U 50 UJ 0.36 JQ 1 U 1 U 1 U 1 U 1 U 1 Uug/l 10/4/16 50 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 11/7/17 50 UJ 1 U 1 U 1 U 1 U 1 U 1 Uug/l 10/30/18 170 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 10/2/14 10 U 100 5500 10 U 10 U 10 U 10 U 10 U 10 Uug/l 10/8/15 20 U 59 J 12000 20 U 20 U 20 U 20 U 20 U 20 Uug/l 10/4/16 160 10000 50 U 50 U 50 U 50 U 50 Uug/l 11/7/17 30 JQ 6200 20 U 20 U 20 U 20 U 20 Uug/l 10/30/18 110 JQ 14000 25 U 25 U 25 U 25 U 25 Uug/l 5/8/14 1 U 1 U 1 U 1.9 1 U 1 U 8.2 1 Uug/l 10/1/14 1 U 50 UJ 1 U 1 U 2 1 U 1 U 7.2 1 Uug/l 5/6/15 1 U 1 U 1 U 1 U 1 U 1 U 11 1 Uug/l 10/7/15 1 U 50 UJ 1 U 1 U 2.4 1 U 1 U 7.1 1 Uug/l 5/8/14 1 U 1 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 10/1/14 1 U 50 UJ 1 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 5/6/15 1 U 1 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 10/7/15 1 U 50 UJ 1 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 5/9/14 5 U 1900 5 U 36 36 0.95 JQ 65 3.8 JQug/l 10/2/14 4 U 5400 J 4 U 53 J 92 4 U 140 4 Uug/l 5/7/15 20 U 5400 20 U 71 130 20 U 190 20 Uug/l 10/8/15 20 U 9000 20 U 78 J 110 J 20 U 290 20 Uug/l 5/6/14 1 U 1 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 9/30/14 1 U 1 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 5/5/15 1 U 1 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 10/6/15 1 U 1 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 10/5/16 1 U 1 U 1 U 1 U 1 U 1 Uug/l 11/7/17 1 U 1 U 1 U 1 U 1 U 1 Uug/l 10/30/18 1 U 1 U 1 U 1 U 1 U 1 Uug/l 5/7/14 1 U 1 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 9/30/14 1 U 1 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 5/5/15 1 U 1 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 10/6/15 1 U 1 U 1 U 1 U 1 U 1 U 1 U 1 U
MW
-27-
SM
W-0
7-D
RM
W-0
7-SR
MW
-17-
SM
W-1
8-S
MW
-20-
SM
W-3
2-S
Vinyl Chloride
MW
-03-
S
Well Sample Date 1,1-Dichloroethene Chlorobenzene Chloroethane cis-1,2-
DichloroetheneTetrachloroethene
(PCE)trans-1,2-
DichloroetheneTrichloroethene
(TCE)Unit 2,4 and/or 2,6-Diaminotoluene
Result Qualifier Result Qualifier Result Qualifier Result Qualifier Result Qualifier Result Qualifier Result Qualifier Result Qualifier Result Qualifierug/l 5/8/14 2.8 2100 2 U 140 2 U 3.6 52 19ug/l 10/1/14 2 U 2400 2 U 150 2 U 2 U 43 14ug/l 5/7/15 20 U 2500 20 U 180 20 U 20 U 57 17 JQug/l 10/7/15 1 U 1900 1 U 85 1 U 2 9.9 8.5ug/l 10/5/16 1 U 4.6 1 U 1 U 1 U 1 Uug/l 10/30/18 890 52 5 U 5 U 2.2 JQ 5.4
MW
-34S
-D
ug/l 11/7/17 690 83 1 U 1 U 1 U 11
MW
-34S
-I
ug/l 11/7/17 84 1 U 1 U 1 U 1 U 1 U
MW
-34S
-S
ug/l 11/7/17 36 5.4 36 1 U 1 U 1 U
ug/l 5/6/14 1 U 1 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 9/30/14 1 U 1 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 5/5/15 1 U 1 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 10/6/15 1 U 1 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 5/7/14 1 U 1 U 1 U 98 1 U 1 U 1 U 7.2ug/l 9/30/14 1 U 1 U 1 U 120 1 U 1 U 1 U 7.8ug/l 5/6/15 1 U 1 U 1 U 130 1 U 1 U 1 U 8.5ug/l 10/6/15 1 U 1 U 1 U 120 1 U 1 U 1 U 6ug/l 10/5/16 1 U 1 U 1 U 1 U 1 U 1 Uug/l 11/7/17 1 U 4.8 J 1 U 1 U 1 U 1.6 Jug/l 10/30/18 1 U 42 1 U 1 U 1 U 1.8
MW
-39S
-D
ug/l 12/21/16 1 U 76 1 U 1 U 1 U 3.5
Well
MW
-34-
SM
W-3
7-S
Sample Date 1,1-Dichloroethene
MW
-39-
S
2,4 and/or 2,6-Diaminotoluene Vinyl ChlorideTetrachloroethene
(PCE)trans-1,2-
DichloroetheneTrichloroethene
(TCE)Unit Chloroethane cis-1,2-DichloroetheneChlorobenzene
Result Qualifier Result Qualifier Result Qualifier Result Qualifier Result Qualifier Result Qualifier Result Qualifier Result Qualifier Result Qualifier
MW
-39S
-I
ug/l 12/21/16 1 U 1.6 1 U 1 U 1 U 1.5
MW
-39S
-S
ug/l 12/21/16 1 U 1 U 1 U 1 U 1 U 1 U
ug/l 5/7/14 1 U 1 U 1 U 1 U 1 U 1 U 1 U 9.6ug/l 9/30/14 1 U 1 U 1 U 1 U 1 U 1 U 1 U 11ug/l 5/5/15 1 U 1 U 1 U 1 U 1 U 1 U 1 U 7.3ug/l 10/6/15 1 U 1 U 1 U 1 U 1 U 1 U 1 U 8.4ug/l 10/5/16 1 U 1 U 1 U 1 U 1 U 1 Uug/l 10/30/18 1 U 1 U 1 U 1 U 1 U 3
MW
-43S
-D
ug/l 11/7/17 1 U 1 U 1 U 1 U 1 U 3.7
MW
-43S
-I
ug/l 11/7/17 1 U 1 U 1 U 1 U 1 U 1 U
MW
-43S
-S
ug/l 11/7/17 1 U 1 U 1 U 1 U 1 U 1 U
ug/l 5/5/14 1 U 1 U 1 U 1 U 1 U 1 U 1 U 6.4ug/l 9/29/14 1 U 1 U 1 U 1 U 1 U 1 U 1 U 9.7ug/l 5/4/15 1 U 1 U 1 U 1 U 1 U 1 U 1 U 9.9ug/l 10/5/15 1 U 1 U 1 U 1 U 1 U 1 U 1 U 16ug/l 10/5/16 1 U 1 U 1 U 1 U 1 U 11ug/l 11/7/17 1 U 1 U 1 U 1 U 1 U 12ug/l 10/30/18 1 U 1 U 1 U 1 U 1 U 1 U
MW
-43-
S
Well
MW
-45-
S
Chlorobenzene2,4 and/or 2,6-Diaminotoluene
Sample Date 1,1-Dichloroethene Trichloroethene
(TCE) Vinyl ChlorideTetrachloroethene (PCE)
trans-1,2-DichloroetheneUnit Chloroethane cis-1,2-
Dichloroethene
Result Qualifier Result Qualifier Result Qualifier Result Qualifier Result Qualifier Result Qualifier Result Qualifier Result Qualifier Result Qualifierug/l 5/6/14 1 U 1 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 9/29/14 1 U 1 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 5/4/15 1 U 1 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 10/5/15 1 U 1 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 10/5/16 1 U 1 U 1 U 1 U 1 U 1 Uug/l 11/7/17 1 U 1 U 1 U 1 U 1 U 1 Uug/l 10/30/18 1 U 1 U 1 U 1 U 1 U 1 Uug/l 5/7/14 1 U 1 U 1 U 1 U 1 U 1 U 1 U 5.9ug/l 10/1/14 1 U 1 U 1 U 1 U 1 U 1 U 1 U 5.6ug/l 5/6/15 1 U 1 U 1 U 1 U 1 U 1 U 1 U 5.1ug/l 10/7/15 1 U 1 U 1 U 1 U 1 U 1 U 1 U 5.5ug/l 10/5/16 1 U 1 U 1 U 1 U 1 U 1 Uug/l 10/30/18 1 U 1 U 1 U 1 U 1 U 1 U
MW
-49-
D
ug/l 11/7/17 1 U 1 U 1 U 1 U 1 U 1 U
MW
-49S
-I
ug/l 11/7/17 1 U 1 U 1 U 1 U 1 U 4.5
MW
-49S
-S
ug/l 11/7/17 1 U 1 U 1 U 1 U 1 U 1.4
ug/l 5/14/14 1 U 1 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 9/29/14 1 U 1 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 5/4/15 1 U 1 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 10/5/15 1 U 1 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 10/5/16 1 U 1 U 1 U 1 U 1 U 1 Uug/l 11/7/17 1 U 1 U 1 U 1 U 1 U 1 Uug/l 10/30/18 1 U 1 U 1 U 1 U 1 U 1 U
MW
-47-
SM
W-4
9-S
MW
-50-
S
Well Sample Date 1,1-Dichloroethene 2,4 and/or 2,6-
Diaminotoluene Chlorobenzene Tetrachloroethene (PCE)
trans-1,2-Dichloroethene
Trichloroethene (TCE) Vinyl ChlorideUnit Chloroethane cis-1,2-
Dichloroethene
Result Qualifier Result Qualifier Result Qualifier Result Qualifier Result Qualifier Result Qualifier Result Qualifier Result Qualifier Result Qualifierug/l 10/2/14 8 U 240 8200 8 U 8 U 8 U 8 U 81 J 8 Uug/l 10/8/15 200 U 82 J 18000 200 U 200 U 200 U 200 U 200 U 200 Uug/l 10/4/16 170 13000 50 U 50 U 50 U 50 U 50 Uug/l 11/7/17 120 J 10000 J 50 U 50 U 50 U 50 U 50 Uug/l 10/30/18 120 JQ 6600 J 20 UJ 20 U 20 U 20 U 20 U
ug/l 11/7/17 50 UJ 1 U 1 U 1 U 1 U 1 U 1 U
ug/l 10/30/18 170 U 1.2 1 U 0.35 JQ 1 U 1 U 1 U
ug/l 10/2/14 1 U 50 U 2.1 1 U 1 U 1 U 1 U 1 U 1 U
ug/l 10/8/15 1 U 50 UJ 1.3 1 U 1 U 1 U 1 U 1 U 1 U
ug/l 5/5/14 1 U 1 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 9/29/14 1 U 1 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 5/4/15 1 U 1 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 10/5/15 1 U 1 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 10/5/16 1 U 1 U 1 U 1 U 1 U 1 Uug/l 11/7/17 1 U 1 U 1 U 1 U 1 U 1 Uug/l 10/30/18 1 U 1 U 1 U 1 U 1 U 1 Uug/l 5/8/14 1 U 1 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 10/1/14 1.4 450 1 U 240 1 U 400 8.2 86ug/l 5/7/15 1 U 0.39 JQ 1 U 6.8 1 U 10 1 U 1.3ug/l 10/7/15 1 U 370 1 U 330 1 U 490 12 140ug/l 10/5/16 130 200 1 U 400 1.3 120ug/l 10/30/18 55 57 1 U 82 1 U 55 J
PW03
-D
ug/l 11/7/17 260 140 1 U 250 1 U 79
PW03
-I
ug/l 11/7/17 19 34 1 U 59 1 U 13
PW03
-S
ug/l 11/7/17 1 U 1 U 1 U 1 U 1 U 1.4
PW-0
3M
W-5
2-D
MW
-52-
SM
W-5
3-D
MW
-54-
SRX
UnitWell Sample Date 1,1-Dichloroethene Tetrachloroethene
(PCE)trans-1,2-
DichloroetheneTrichloroethene
(TCE) Vinyl Chloridecis-1,2-Dichloroethene
2,4 and/or 2,6-Diaminotoluene Chlorobenzene Chloroethane
Result Qualifier Result Qualifier Result Qualifier Result Qualifier Result Qualifier Result Qualifier Result Qualifier Result Qualifier Result Qualifierug/l 5/6/14 1 U 1 U 1 U 9.4 1 U 1 U 1 U 1 Uug/l 9/30/14 1 U 1 U 1 U 75 1 U 3.7 1 U 21ug/l 5/5/15 1 U 1 U 1 U 5.5 1 U 1 U 1 U 1 Uug/l 10/6/15 1 U 1 U 1 U 48 1 U 5.6 1 U 22ug/l 5/6/14 1 U 1 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 9/29/14 1 U 1 U 1 U 1 U 1 U 1 U 1 U 24ug/l 5/5/15 1 U 1 U 1 U 1 U 1 U 1 U 1 U 3.8ug/l 10/6/15 1 U 1 U 1 U 1 U 1 U 1 U 1 U 16ug/l 5/5/14 1 U 1 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 9/29/14 1 U 1 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 5/4/15 1 U 1 U 1 U 1 U 1 U 1 U 1 U 4.2ug/l 10/5/15 1 U 1 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 10/2/14 1 U 50 U 1.7 1 U 1 U 1 U 1 U 1 U 1 Uug/l 10/8/15 1 U 50 UJ 2 1 U 1 U 1 U 1 U 1 U 1 Uug/l 10/4/16 50 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 11/7/17 50 UJ 1 U 1 U 1 U 1 U 1 U 1 Uug/l 10/30/18 170 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 10/2/14 1 U 50 U 1 1 U 1 U 1 U 1 U 1 U 1 Uug/l 10/8/15 1 U 50 UJ 1.9 1 U 1 U 1 U 1 U 1 U 1 Uug/l 10/4/16 50 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 11/7/17 50 UJ 1 U 1 U 1 U 1 U 1 U 1 Uug/l 10/30/18 170 U 0.49 JQ 1 U 1 U 1 U 1 U 1 Uug/l 10/2/14 1 U 50 U 1 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 10/8/15 1 U 50 UJ 1 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 10/4/16 50 U 1.2 1 U 1 U 1 U 1 U 1 Uug/l 11/7/17 50 UJ 1 U 1 U 1 U 1 U 1 U 1 Uug/l 10/30/18 170 U 1 U 1 U 1 U 1 U 1 U 1 U
SW-0
2SW
-03
PW-0
4PW
-05
PW-0
8SW
-01
Well Tetrachloroethene (PCE)
trans-1,2-Dichloroethene
Trichloroethene (TCE) Vinyl ChlorideSample
Date 1,1-Dichloroethene 2,4 and/or 2,6-Diaminotoluene Chlorobenzene ChloroethaneUnit cis-1,2-
Dichloroethene