BBLBLASLAND, BOUCK &LEE, INC.engineers & scientists

FILE COPY

October 26, 1995

Ms. Kelly McCartyUnited States Environmental Protection Agency90 Canal StreetBoston, MA 02114

Re: OIS and Monitoring WellAbandonment During NTCRA 1

File: 0480.48023 #2

Transmitted Via: FedExPages Sent: 5 plus attachments

Dear Ms. McCarty:

This letter describes well abandonment activities performed during the implementation of the Non-Time-Critical Removal Action No. 1 (NTCRA 1) at the Solvents Recovery Service of New England, Inc. (SRSNE)Superfund Site in Southington, Connecticut. Between June 2 and September 27, 1995, 25 ground-waterextraction wellpoints associated with the On-Site Interceptor System (OIS) and five ground-water monitoringwells in and near the former SRSNE Operations Area and the NTCRA 1 Containment Area were abandoned(see Figure 1). The abandonment process consisted of overdrilling, removing well materials, and tremiegrouting the borehole, consistent with Connecticut Department of Consumer Protection Well Drilling BoardRules and Regulations, Sec. 25-128-56. This lettersummarizes the abandonment procedures implementedand discusses field observations relating to OIS well construction and dense, non-aqueous phase liquids(DNAPL) encountered during the abandonment of the OIS and monitoring wells.

Background

Purpose of Well Abandonment

The need to abandon selected pre-existing wells as part of NTCRA 1 implementation was discussed at ameeting between the United States Environmental Protection Agency (USEPA); the Connecticut Departmentof Environmental Protection (CT DEP); the Connecticut Department of Health (CT DOH), the SRSNE SitePRP Group Technical Committee; Dr. Bernard Kueper of Queens University in Kingston, Ontario; andBlasland, Bouck & Lee, Inc. (BBL) on May 18, 1995, at CT DEP offices in Hartford, Connecticut. Based onthe likely presence of DNAPL in the former SRSNE Operations Area (Figure 1) and the recognition of DNAPLin the NTCRA 1 Containment Area during compliance piezometer installation, it was recommended thatwells in and around these areas with screens that straddled the overburden/bedrock interface beabandoned to eliminate the potential pathway for DNAPL migration from the overburden to the bedrock.

Wells Selected for Abandonment

In a letter to USEPA dated May 31, 1995, BBL provided an initial list of wells proposed for abandonment(OIS and wells TW-7B, WE-7, and WE-8) and described procedures to be used to abandon the wells.Based on a detailed review of the comprehensive ground-water database and discussions with Dr. Kueper,

6723 Towpath Road • P.O. Box 66 • Syracuse, NY 13214-0066Tel (315) 446-9120 • Voice Mai! (315) 446-2570 • Fax (315) 449-0017 • Offices Nationwide

Ms. Kelly McCarty October 26, 1995 Page 2

additional wells warranting abandonment (DN-1, DN-2, HP-1, MW-502, and WE-4) were identified in subsequent discussions between USEPA, the SRSNE Site PRP Group Technical Committee, and BBL.

Wells selected for abandonmentduring NTCRA1 implementationincluded25ground-waterinterceptorwells (herein referred to as wells IW-1 through IW-25) associated with the OIS, and monitoring wells DN-1, DN-2, HP-1, MW-502, TW-7B, WE-4, WE-7, and WE-8. The OIS wells were installed in 1985 by S.B. Church Company to collect ground water along the downgradient property line of the Operations Area (see photos in Attachment 1). The other wells were installed during several separate phases of hydrogeologic investigation between 1980 and 1995.

The wells selected for abandonment were believed to be screened across the overburden/bedrock interface, based on well-construction and geologic information included in the following documents:

Warzyn, November 1980 (monitoring well TW-7B); Wehran, January 1982 (monitoring wells WE-4, WE-7, and WE-8); Loureiro, November 1984 (OIS wells IW-1 through IW-25); YWC, December 1988 (monitoring wells DN-1, DN-2, and HP-1); and ENSR, June 1995 (monitoring well MW-502).

Monitoring wells HP-1, WE-7, and WE-8 could not be located in the field, despite the use of a magnetometerto help locate steel protective casings for these wells, if present. Borehole grout plugs and pieces of PVC pipe were observed at the approximate locations of wells WE-7 and WE-8 in June 1995, suggesting that these wells might have been abandoned prior to NTCRA 1 implementation. With the exception of wells HP-1, WE-7, and WE-8, the wells selected for abandonment were abandoned as described below.

Well Abandonment Activities

Pre-Abandonment Well Evaluation

Prior to abandonment, the total depth of each well was measured using an electronic water-level indicator. Each well was evaluated for the presence of DNAPL by lowering a 1.25-inch-diameter, transparent, bottom-loading PVC bailer to the base of the well to collect a sample of sediment and/or DNAPL from the bottom of the well. Free-phase DNAPL was not observed in any of the wells abandoned during NTCRA 1 implementation. Sediment samples removed from the OIS wells were evaluated for the presence of residual DNAPL by adding a hydrophobic dye (Sudan IV) to the sediment. The dye changed from dark red to bright red in the presence of sediment from wells IW-12, IW-15, and IW-21, indicating the likely presence of DNAPL in these sediment samples. Sediment from other OIS wells exhibited a sheen, suggesting the potential presence of DNAPL. Where a sheen or positive dye test was observed, the well was bailed to remove sediment and DNAPL to the extent practicable prior to abandonment. No sheen or positive dye test was observed at the five monitoring wells abandoned during NTCRA 1 implementation. Table 1 summarizes pre-abandonmentwell evaluation results.

Abandonment Procedure

The well abandonment procedure consisted of overdrilling the wells with hollow-stem augers advanced to the measured depth of the well. Well risers and screens were then removed from the augers using a tight-fitting strap attached to the top of the riser, or inserting drilling rods into the well. After removal of well materials, the augers and borehole were washed out to the measured depth of the well or the bottom of the augers (if deeper) using a jetting pipe, and/or reamed using a roller bit. The borehole was then tremie grouted to approximately ground surface.

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Ms. Kelly McCarty October 26, 1995 Page 3

At several OIS well locations, corroded, galvanized, wire-wrapped steel screens were removed. However, at other OIS well locations, complete screens could not be removed, and some wells appeared to lack screened sections.

At OIS wells IW-10, IW-13, IW-16, and IW-18, which were anomalously shallow based on pre-abandonment depth measurements, no screen was evident in the boring after the removal of the risers. To evaluate the presence or absence of screen material at these locations, split-spoon samples were obtained, and the augers were advanced several feet past the measured depth of these wells. These methods did not yield any evidence of a screen. While the augers were washed out prior to grouting, the return water was evaluated for the presence of steel screen fragments using a sieve and magnet. This method also revealed no evidence of screen material, suggesting that no screen was installed at wells IW-10, IW-13, IW-16, and IW-18, and the borings were grouted in place.

In the event that an OIS system well screen or a monitoring well screen could not be entirely removed, the annulus between the (remaining) screen and augers was flushed using water, or the screen was reamed and washed out using a roller bit, and the borehole (and remaining screen, if any) was tremie grouted in place.

At monitoring wells DN-1 and DN-2, complete 2-inch-diameterPVC screens and risers were removed. The screens could not be removed at wells MW-502, TW-7B, and WE-4. At these locations, the annulus between the remaining screen and augers was flushed using water (WE-4), or the screen was reamed and washed out using a roller bit (MW-502 and TW-7B), and the borehole (and remaining screen, if any) was tremie grouted in place.

Well Materials

The five abandoned monitoring wells were each constructed of 2-inch-diameter PVC.

Two types of OIS wells were encountered. Wells IW-12, IW-15, and IW-21 consisted of 4-inch-diameter stainless steel risers and screens. The screen lengths ranged from 9.2 to 10.0 feet. None of these wells had a sump at the base of the well. The risers and screens at wells IW-12, IW-15, and IW-21 were completely intact, with minimal rust or staining. These three wells had been installed in 1989 as replacement wells for three OIS wells to enhance the systems's ground-water extraction rate.

The remaining 22 OIS wells consisted of 4- to 15-foot threaded sections of 2.5-inch-diameter carbon steel riser, and various lengths of 1.5-inch-diametergalvanized steel riser and wire-wrapped screen. At the union between the 2.5-inch riser and the 1.5-inch riser or screen, no bushings or threaded couplings were observed. On several of the wells, however, layers of electrical tape were present on the portion of the 1.5­inch riser or screen that was within the 2.5-inch riser. In general, OIS screens removed during abandonment were severely corroded, rusted, and encrusted with fine sediment. The bottom portions of most OIS screens, where removable, were crushed and bent.

With the exception of wells IW-12, IW-15, and IW-21, soil cuttings generated at the OIS wells did not contain evidence of sand pack material. Table 1 summarizes the well materials removed during OIS abandonment. Photos of the typical materials removed during OIS well abandonment are included in Attachment 2.

Grouting Procedure

Following removal of well materials and jetting and/or reaming of the borehole, the borehole was grouted from the bottom to the top using a one-inch-diameter tremie pipe. At the well locations where the screen was not removed, the tremie pipe was inserted within the screen portion to the measured depth, and the

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Ms. Kelly McCarty October 26, 1995 Page 4

screen was grouted in place. The volumes of grout used and the tremie depths are summarized in Table 1.

Discussion of Observations

QIS System Wells

Measurements of the well depths and lengths of well casings and screens removed during the abandonment of the OIS indicated incongruities with the pre-build design drawings and profile views of the OIS multi-point ground-water interceptor system (Loureiro, November 1984). These departures from design may help clarify the relatively poor performance of the OIS system in terms of ground-water extraction and hydraulic containment. According to a February 1-2, 1989 USEPA Inspection Report, the OIS was not operating as a continuous hydraulic barrier to downgradient ground-water flow. Subsequently, three extraction wells (IW-12, IW-15, and IW-21) were removed and replaced in 1989 in an attempt to improve the ground-water extraction rate of the OIS.

According to the OIS design document (Loureiro, November 1984), the system was to consist of 25 combination overburden/bedrock ground-water interceptor wells. The wells were to include 1.5-inch­diameter galvanized steel screens installed into sockets drilled 3 feet into the top of bedrock, and riser sections consisting of 1.5-inch-diametergalvanized pipe connected to 2.5-inch-diametersteel riser sections. Photographs of the OIS installation are included in Attachment 1.

The installation of the OIS wells, as observed during their removal and abandonment, differed from the design in the following respects:

• Several of the well depths, as measured prior to abandonment, were less than the depth to the top of bedrock encountered during overdrilling. Ten of the 25 OIS wells evidently were not installed to or into the bedrock. Only 15 of the OIS wells appear to have been installed to or into the bedrock (Table 1);

• Several of the OIS well screens were considerably shorter than expected, based on the design drawings, or were missing (Table 1);

• In general, the OIS well screens were severely bent and/or crushed, suggesting that they had been driven to refusal within the till layer or on the top of rock, or were not installed into a socket drilled into the top of rock. Some of the 1.5-inch casings were also bent at the bottom (see photos in Attachment 2). The interpretation that the wells were driven rather than drilled is supported by the photos of drilling rigs used to install the OIS, some of which did not have rotary drilling capability, but were equipped with 300-pound drive hammers (see photos in Attachment 1); and

• Rather than using a bushing/connection between the 1.5-inch riser and the 2.5-inch riser, electrical tape was the only connecting material used between the well screen and the riser pipes at many of the OIS wells.

The observations listed above, particularly those regarding missing, bent, crushed, rusty, and corroded well screens, are consistent with the observed ineffectiveness of the OIS.

BLASLAND BOUCK & LEE INC

engineers & scientists

Ms. Kelly McCarty October 26, 1995 Page 5

DNAPL Observations

During the well abandonment process, DNAPL was inferred or confirmed present at several wells. DNAPL was identified in the soil at the bottom of IW-1 2, IW-1 5, and IW-16 near the center of the OIS, based on field screening of sediment from the base of the wells using hydrophobic dye (Sudan IV). At wells IW-1 3, IW-1 9, IW-20, and IW-21, sheens were also observed on the sediment from the base of the well and/or in the recirculation water during the flushing of the borehole prior to grouting (Table 1).

During the grouting process at IW-23, free-phase DNAPL was displaced out of the borehole and was collected for chemical analysis of volatile organic compounds (VOCs) by Method 8240, semivolatile organic compounds (SVOCs) by modified Methods 8270/8040, and pesticides/PCBs by Method 8080. While the material from OIS well IW-23 submitted for analysis was a mixture of DNAPL and grout, the analytical results confirmed the presence of DNAPL, in that concentrations of several VOCs exceeded their respective pure-phase solubility limit, including : 1 9,01 9 ppm of trichloroethene; 1 5,052 ppm of tetrachloroethene;9,1 30 ppm of total xylenes; 6,636 ppm of toluene; 1,834 ppm of 1,1,1-trichloroethane; and 784 ppm of styrene.

These observations indicate that DNAPL was present in proximity to many of the OIS wells. Thus, several OIS wells could have provided a pathway for vertical migration of DNAPL within the overburden or between the overburden and bedrock. Well IW-23, where free-phase DNAPL was encountered, is approximately 100 feet directly upgradient from wells MWD-601 and RW-5, where free-phase DNAPL has also been observed during NTCRA 1 implementation.

During the abandonment of monitoring well TW-7B, the base of the PVC riser section removed from the borehole was found to be relatively thin, tapered, and folded, suggesting possible exposure to solvent DNAPL in the subsurface. Thus, well TW-7B could have provided a pathway for DNAPL migration from overburden to bedrock. This interpretation is consistent with the anomalously high concentrations of VOCs historically observed at bedrock monitoring well MW-125C, which is approximately 25 feet downgradient of well TW-7B.

If you have any questions or comments regarding the well abandonment conducted during NTCRA 1, please do not hesitate to contact me.

Very truly yours,

BLASLAND, BOUCK & LEE, INC.

Edward R. Lynch, P.E. Executive Vice President

DFS/mbl Attachments 2995842NN

cc: Mr. Mark Lewis, Connecticut Department of Environmental Protection Mr. Robert Kirsch, Esq., Hale & Dorr Mr. A.J. Moody, James River Corporation Mr. John Rudisill, Avery Dennison Mr. Bruce Thompson, de maximis, inc.

BLASLAND BOUCK & LEE, INC

engineer:: & s c i e n t < i t s

REFERENCES

ENSR Consulting and Engineering, Letter to Mr. Bruce Thompson, de maximis, inc. (re: Results of Comprehensive Groundwater Sampling, SRSNE, Southington, CT, March/April 1995), June 19, 1995.

Loureiro Engineering Associates, Final Design Plans and Specifications for Multi-Point Shallow Well Groundwater Recovery System, October 20, 1983 (rev. November 19, 1984).

Warzyn Engineering, Inc., Hydrogeologic Investigation, EPA/JRB Associates, Town of Southington, Connecticut, November 12, 1980.

Wehran Engineering, Discussion Draft: Hydrogeologic Assessment and Recommendation for a Remedial Action Plan to Recover and Treat Ground Water, Prepared for Solvents Recovery Service of New England, Inc., Southington, Connecticut, January 1982.

2995842NN 10/27/95

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Figure 1

Attachment 1 OIS Installation Photos (1985)

TARGET SHEET

THE MATERIAL DESCRIBED BELOW WAS NOT SCANNED BECAUSE:

() OVERSIZED

0 NON-PAPER MEDIA

(X) OTHER: COLOR PHOTOCOPIES OF PHOTOGRAPHS.

DESCRIPTION: DOC# 5584 ATTACHMENT 1, OIS INSTALLATION PHOTOS (1985).

THE OMITTED MATERIAL IS AVAILABLE FOR REVIEW BY APPOINTMENT

AT THE EPA NEW ENGLAND SUPERFUND RECORDS CENTER, BOSTON, MA

Attachment 2 Typical OIS Well Materials Photos (1995)

TARGET SHEET

THE MATERIAL DESCRIBED BELOW WAS NOT SCANNED BECAUSE:

0 OVERSIZED

() NON-PAPER MEDIA

(X) OTHER: COLOR PHOTOCOPIES OF PHOTOGRAPHS.

DESCRIPTION: DOC# 5584, ATTACHMENT 2, TYPICAL OIS WELL MATERIALS PHOTOS (1995).

THE OMITTED MATERIAL IS AVAILABLE FOR REVIEW BY APPOINTMENT

AT THE EPA NEW ENGLAND SUPERFUND RECORDS CENTER, BOSTON, MA

Attachment 3 IW-23 Sample (DNAPL/Grout) Analytical Results

r July 28, 1995

Blasland, Bauch & Lee 6723 Towpath Rd. Box 66 Syracuse, NY 13214

Attn: Mr. Mike Gefell

Please find attached laboratory report(s) for the samples submitted on July 14, 1995

All pertinent information for this analysis is located on the report. Should it be necessary to contact us regarding billing and or the test results, please have the following information readily available :

LAB No. 75-328-1 PO/JOB No. N/A INVOICE No. 53098 ORDER NO. 33162 CUSTOMER No. 1055

Please feel free to contact us if you have any questions.

Very truly yo

tephen J. hranco Laboratory Director PH-0547

Connecticut ^testing STEPHEN]. FRANCO

Laboratory Director laboratories me. PHONE • 203/634-3731

WATER • SOIL • AIR 165CRACEYAVENUEH MERIDEN,CTB 06451

Client Lab No. PO No. Rep. Date

: 75-328-1 : N/A : 7-28-95

: Blasland, Bouck & Lee

EPA METHOD 8240 GC/MS

Matrix Type CTL SAMPLE # Field ID

Dichlorodif luoromethane Chloromethane Vinyl Chloride Chloroethane Bromomethane Trichlor of luoromethane Acrolein 1, 1-Dichloroethylene lodomethane Allyl Chloride Acrylonitrile Methylene Chloride trans-l, 2-Dichloroethylene 1, 1-Dichloroethane 2-Butanone(MEK) cis-l, 2-Dichloroethylene Chloroform Methacrylonitrile Propionitrile 1, 1, 1-Trichloroethane Carbontetrachloride Benzene 1, 2-Dichloroethane Trichloroethylene 1, 2-Dichloropropane Methyl Methacrylate Bromodi Chloromethane Dibromomethane 2-Chlorethylvinylether 4-Methyl-2-pentanone (MIBK) cis-1, 3-Dichloropropylene Toluene trans-l, SDichloropropylene 2-Hexanone(MBK) Ethyl Methacrylate

Date Analyzed : 7/25-7/26/95

Analyst : YK

Date Samples Rec'd: 7-14-95

O 9094 IW-23

MDL

5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5

BDL BDL BDL BDL BDL BDL BDL 418.0 BDL BDL BDL 50.0

BDL 38.0

BDL 1,254.0 BDL BDL BDL

1,834.0 BDL 11.0

BDL 19,019.0

BDL BDL BDL BDL BDL BDL BDL

6,636.0 BDL BDL BDL

MDL = Minimum Detectable Level/BDL= Below Detection Level/UNITS= PPM

Matrix Type: W= Water/Aqueous S= Soil/Solid O= Oil/Hydrocarbons CONNECTICUT TESTING LABORATORIES, INC.

165 Gracey Avenue / Meriden, CT 06451-2268 (203)-634-3731

Connecticut Certification No. PH-0547

Client Blasland, Bouck & Lee Date Analyzed : 7/25-7 /26/9S Lab No. 75-328-1 PO No. N/A Rep. Date 7-28-95

EPA METHOD 8240 GC/MS

Matrix Type CTL SAMPLE # Field ID

1,1,2-Trichloroethane Tetrachloroethylene Dibromochloromethane _ 1,2-Dibromoethane(EDB) Chlorobenzene 1,1,1,2-Tetrachloroethane Ethylbenzene ~ P/M Xylenes O xylene Styrene Broraoform ̂ 1,1,2,2-Tetrachloroethane 1,2,3-Trichloropropane l,4-Dichloro-2-butene Pentachloroethane Benzyl Chloride DBCP

Analyst : YK

Date Samples Rec'd: 7-14-95

MDL

5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5

O 9094 IW-23

BDL 15,052.0

BDL BDL BDL BDL

3,891.0 5,512.0 2 ,727 .0 784.0 BDL BDL BDL BDL BDL BDL BDL

MDL = Minimum Detectable Level/BDL = Below Detection Level/UNITS= PPM

Matrix Type: W= Water/Aqueous S = Soil/Solid O= Oil/Hydrocarbons

CONNECTICUT TESTING LABORATORIES, INC. 165 Gracey Avenue / Meriden, CT 06451-2268

(203)-634-3731 Connecticut Certification No. PH-0547

Client Lab No. PO No. Date

75-421-1 N/A8-1-95

Blasland Bouch & Lee Date Reed

TCLP Semi-Volatile Organics

Matrix Type CTL Sample No, Field ID

o-Cresol m-Cresol p-Cresol 2,4-Dinitrotoluene Hexachlorobenzene Hexachloro-1,3-butad±ene_ Hexachloroethane ~ Nitrobenzene Pentachlorophenol Pyridine 2,4,6-Trichlorophenol_ 2,4,5-Trichlorophenol"

Date Extracted Date Tested Analyst

7-14-95 7-24-95 7-25-95 YK

MDL

2 .0 "2.0" "2.0" "2.0" "2 . 0" "2.0" "2 .0" "2.0" "2.0" "2.0" "2.0" "2.0"

O 9094 IW-23

BDL ~BDL" "BDL" "BDL" ~BDL" "BDL" "BDL" "BDL" ~BDL~ "BDL_ "BDL "BDL"

MDL= Minimum Detectable Level/BDL= Below Detection Level/UNITS= PPM

Matrix Type : W= Water/Aqueous S= Soil/Solid O= Oil/Hydrocarbons

CONNECTICUT TESTING LABORATORIES, INC. 165 Gracey Avenue / Meriden, CT 06451-2268

{203}-634-3731 Connecticut Certification No. PH-0547

Client : Blasland, Bauck & Lee Date Extracted 7-27-95 Lab No. : 75-332-1 Date Analyzed 7-27-95 PO No. : N/A Analyst SG Rep. Date : 7-28-95

EPA METHOD 608/8080 Date Samples Rec'd : 7-14-95

Matrix Type : O CTL SAMPLE # : 9094 Field ID : IW-23

MDL

Aldrin 50 BDL a - BHC 50 BDL b - BHC 50 BDL d - BHC 50 BDL Lindane 50 BDL Chlordane 50 BDL 4,4' - ODD" 50 BDL 4,4 ' - DDE 50 BDL 4,4' - DDT 50 BDL Dieldrin 50 BDL Endosulfan I 100 BDL Endosulfan II 100 BDL Endosulfan Sulfate 100 BDL Endrin ̂ 1.0 BDL Endrin Aldehyde 50 BDL Heptachlor ^̂ 50 BDL Heptachlor Epoxide 50 BDL Methoxychlor 50 BDL Toxaphene 50 BDL PCB - 1016 100 BDL PCB - 1221 100 BDL PCB - 1232 100 BDL PCB - 1242 100 BDL PCB - 1248 100 BDL PCB - 1254 100 730 PCB - 1260 100 BDL

MDL= Minimum Detectable Level/BDL= Below Detection Level/UNITS= PPB

Matrix Type : W= Water/Aqueous S= Soil/Solid O= Oil/Hydrocarbons

CONNECTICUT TESTING LABORATORIES, INC. 165 Gracey Avenue/ Meriden, CT 06451-2268

(203)-634-3731 Connecticut Certification No. PH-0547