THIRD FIVE-YEAR REVIEW REPORT EWAN PROPERTY … · The Ewan Property Superfund Site is in the Atlantic Coastal Plain physiographic province. The overall topography ofthe Site is relatively

THIRD FIVE-YEAR REVIEW REPORT EWAN PROPERTY SUPERFUND SITE

331 Tuckerton Road Shamong Township, New Jersey 08088

Prepared by

UNITEDSTATESENVIRONMENTALPROTECTIONAGENCY Region 2

Emergency and Remedial Response Division 290 Broadway

New York, NY 10007-1866

Walter E. Mugdan, Director Date Emergency and Remedial Response Division

Table of Contents

Executive Summary ....................................................................................................................... i

Five-Year Review ummary Form.............................................................................................. ii

Introduction .................................................................................. ... .............................................. 1

ite Chronology ............................................................................................................................. 1

Question B: Are the exposure assumptions, to ·icity data, cleanup le els and remedial action

Question C: Has any other information come to light that could call into question the protecti enes

Background ................................................................................................................................... 1

Physical Characteristics .......... ........ ... ............ .. ........ .. ..................................................... ........ .............. 2

Site Geology/Hydrogeology ..... ......... ....... ...... .................................................. .. ....... .. .. ......... .... .......... 2

Land and Resource Use ............ .... .... .. .... ...... .... ............................................ ........................................ 2

History of Contamination ................................ ... .... .......... ...... .. ........ .. ........ ..................... .......... ......... .. 3

Basis for Taking Action .. ...... ... .. .. ... ..... ... .. ... ..... .. ....... .. .............. ................. ............... .... ... .. ... .. ... ... ... .... 4

Remedial Action .......................................................................................................................... 5

Remedy Selection ...... .. ........ ....... ....... .. .. ........ ... ..... ... .. .. ...... .. ...... .... .... ......... .. ........ ........... ...... ... .. .. .. .. ... 5

Remedy Implementation .... ..... ..... ...... ......... .. ....................... ........ .. ....... ...... ... ...... .. .... .. ... ... ..... .. ..... ...... 6

System Operation and Maintenance ...... ......... ..................... ...... ...... ... .... ........................ ........ .............. 8

Progress Since La t Five-Year Review ..................................................................................... 10

Five-Year Revielv Proce .......................................................................................................... 11

Administrative Components ................................................... ............................................................ 11

Data Re iew ......... ............ ...... .... ..... ........... .. ... ... ...................................................... .... ........ ... ...... ..... 12

Site Inspection ........ .................. .. ......... ....... ........................................................................................ 14

Institutional Controls Verification .......... .... ... .... .. ........... .. .... ... ..... ....... .......................... ...... .. ..... .... .... 15

Technical Assessment ................................................................................................................. 15

Question A: Is the remedy fu nctioning as intended by the decision document? ........... ....... .. ............ 15

objectives used at the time of the remedy still alid? .................................................................... ..... 17

of the remedy? .......................... .... ... .... ... .... ..... ............... ....................................... ........... .................. 19

Remedy Technical A e ment ummary ................................................................................ 19

Protectivene tatement............................................................................................................ 20

Next Five Year Revielv ............................................................................................................... 21

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Tables Table 1 Chronolow ofSite Events ..................................................................................... 22 Table 2a Remediation Goals for Soil ................................................................................... 24 Table 2b Remediation Goals for Groundwater .................................................................... 25 Table 3 Documents, Data and Information Reviewed in Completing Five-Year Review .. 26 Table 4 Groundwater Monitoring Program ...................................................M ..................

Figures Site Location Map............ : ......................................................................................................... 29 Detailed Site Map ...................................................1................................................................... 30 Groundwater Trend Charts ........................................................................................................ 31

Executive Summary

This is the third five-year review for the Ewan Property Superfund Site (Site). The Site is located in Shamong Township, Burlington County, New Jersey. The purpose of this five-year review is to review information to determine ifthe remedy is and will continue to be protective ofhuman health and the environment. The triggering action for this policy five-year review was the completion ofthe previous five-year review for the Site, dated August 26, 2009.

Five-Year Review Summary Form

SITE IDENTIFICATION

Site Name: Ewan Property

EPA ID: NJD980761365/ NJD0200791

City/County: Town of Shamong, Burlington County

NPL Status: Final

Multiple OUs? Has the Site achieved construction completion? Yes Yes (9/24/1999)

REVIEW STATUS

Lead agency: EPA

Author name (Federal or State Projec;t Manager): Stephen Cipot

Author affiliation: United States Environmental Protection Agency

Review period: 8/2612009-8/26/2014

Date of Site inspection: 12/04/2013

Type of review: Policy

Review number: 3

Triggering action date: 8/26/2009 (Previous Five-Year Review Report)

Due date (five years after triggering action date): 8126/2014

Protectiveness Statements

Operable Unit: Protectiveness Determination: OU2 Protective

Protectiveness Statement: The remedy at OU2 is protective ofhuman health and the environment

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Sitewide Protectiveness Statement

Protectiveness Determination: Protective

Protectiveness Statement: The remedies at the Site are protective ofhuman health and the environment.

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Introduction

The purpose of a five-year review 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 and is functioning as intended by the decision documents. The methods, findings, and conclusions ofreviews are documented in the five-year review. In addition, five­year review reports identify issues found during the review, if any, and document recommendations to address them.

This is the third five-year review for the Ewan Property Superfund Site (the Site). The Site is located in Shamong Township, Burlington County, New Jersey. The purpose of this five-year review is to review information to determine if the remedy is and will continue to be protective ofhuman health and the environment. This five-year review was conducted by the United States Environmental Protection Agency (BPA) Remedial Project Manager (RPM) Stephen Cipot The review was conducted pursuant to Section 121(c) of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), as amended, 42 u:s.c. §9601 et seq. and 40 CFR 300.430(t)(4)(ii), and in accordance with the Comprehensive Five-Year Review Guidance, OSWER Directive 9355.7-03B-P (June 2001). This report will become part of the Site file.

The triggering action for this policy five-year review was the completion ofthe previous five­year review for the Site, dated August 26, 2009.

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The Site has been addressed in two remedial phases~' Operable Unit 1 (OUl) addressed buried drums, disposal trenches, and contaminated soils. The OUl Record ofDecision (ROD) was issued September 29, 1988. The Operable Unit 2 (OU2) remedy addressed the remaining residually contaminated soils and contaminated groundwater. The OU2 ROD was issued on September 29, 1989. EPA issued an ~xPlanation of Significant Differences (BSD) on July 13, 1994. The BSD modified the OU2 soils remedy by combining the OUl and OU2 soils remedies and including them in the OUl r¢edial action such that only a single excavation ofthe contaminated soil was needed.

To date, OUl remedial actl~ns have been completed and contaminants have been remediated to allow for unlimited use/unrestricted exposure ofsoils down to the water table. This OU will not be covered the F'Jl. The OU2 remedial action has been in the Operation and Maintenance phase (O&M) since 1999. This OU is the subject ofthis FYR.

Site Chronology

See Table 1 for the Site chronology.

Background

Site Location

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The Site is located in Shamong Township, Burlington County, New Jersey, off Tuckerton Road, near the intersection ofRoute 206 (see attached Site Location Map). The Site is shown on the Shamong Township tax map as Block 23, lots 31.01 and 32.02.

Physical Characteristics

The Site totals 43 acres; the original bulk disposal-site area, known as Area A, is roughly four acres. A total ofnine acres is fenced, including the Site access road, the original disposal area, a ground water treatment plant building and parking lot (See attached figure, Detailed Site Map). The property that constitutes the Site is privately owned. In June 2011, the owner conveyed a Deed of Conservation Easement in perpetuity for the property to the New Jersey Department of Environmental Protection (NIDEP). The Conservation Easement will assure that the conservation values of the property will be conserved and maintained in perpetuity. This Site falls within the Central Pine Barrens Preservation Area of the New Jersey Pinelands, and is viewed as an ecologically sensitive area.

Site Geology/Hydrogeology

The Ewan Property Superfund Site is in the Atlantic Coastal Plain physiographic province. The overall topography ofthe Site is relatively flat, an<;l it is about 80 feet above mean sea level. ·The Site is underlain by unconsolidated deposits ofclay, silt, sand and gravel which are Quaternary, Tertiary and Cretaceous in age. The Site groundwater lies approximately 10 feet below the ground surface.

The shallow Cohansey Sand immediately underlies the Site and is composed ofunconsolidated sands, silts and fine gravel; it averages 85 feet in thickness. A discontfouous clay layer partially separates the Cohansey Sand from the underlying Kirkwood Aquifer, but the two aquifers are considered to be hydraulically linked at the Site. The deeper Kirkwood Aquifer is estimated to be at a depth of approximately 85 feet. The plume has historically been confined to relatively shallow portions of the groundwater flow system, in an aJ"ea of little to generally slow groundwater flow to the south, south west.

Land and Resource Use

Between 1974 and 1976, a portion of the Ewan property was used as an unregulated industrial waste disposal site. Currently, this area of the Ewan property is fenced and remediation ofthe groundwater is occurring; the last soils excavation event occurred in late 2012. Much ofthe remaining property lies as undeveloped forest and wetlands within the Pinelands Preservation Area. In the roughly one-mile radius that surrounds the Site, land use includes agriculture, wetland, residential, recreational ballfields and forest. Within the past five years, residential uses have increased around the Site. The closest residential property is 2,000 feet to the east of the Site, with the nearest downgradient potable water supply well located roughly three quarters of a mile south ofthe Site, at a recreational ballfield. Off-site water is sampled at selected residential properties and a town well for a park/ball field, located approximately 3/4 mile from the Site.

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This off-site sampling is performed every five years as part of the overall groundwater sampling program. To date, no off-site contaminants have been detected.

Locally, there are a few resources that have been or could be affected by prior activities on the Site. The Site borders the New Jersey Pinelands National Reserve and is within the Pinelands Preservation Area, located within the Central Pine Barrens Area ofthe New Jersey Pinelands. This area is viewed as ecologically sensitive and development is guided by the Pinelands Comprehensive Management Plan administered by the New Jersey Pinelands Commission in cooperation with units of local, state and federal governments. The Cohansey and Kirkwood Aquifers are the primary supplies for potable drinking water to local residents. An unnamed tributary to Springer's Brook is located adjacent to the northern and western boundaries ofthe property. '

History ofContamination

Disposal activities at the Site were reported to have taken place between 1974 and 1976. The Ewan Site, as defined in the remedial investigation (RI), received industrial waste in the form of bulk liquids and drums from a drum and waste hauler that did business hauling wastes for a nwnber ofcompanies. "

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The 1988 RI found that a nine-acre area identified as Area A was used for disposal ofbulk liquids, drwns, fiberglass, resin and resin hardener. Most liquid wastes were reportedly deposited within drums ofvarying integrity. Disposal trenches were excavated to roughly 10 feet below the surface (depth to groundwater); it appeared as though one trench per truckload was dug, into which the bulk dwnping of liquid wastes and drums occutred. Once the drums and bulk liquids were emptied into or unloaded into a trench, the trench was backfilled and re­contoured. A total of 35 separate trencQes had been identified during the Site RI.

Initial Response /

In September 1982, a call from a concerned citizen prompted an ~vestigation by local officials and the NJDEP. During the initial groundwater sampling event, contamination was discovered on-Site. In addition to the groundwater contamination of the Cohansey aquifer, residual product was evident in the soils of the unsaturated zone as light non-aqueous phase liquid.

EPA completed a preliminary Site assessment in 1984. This investigation was conducted in two phases. The first phase includ~d the installation of five monitoring wells, collection of groundwater and surface water samples and completion ofa preliminary geophysical magnetometer survey to identify electromagnetic conductivity anomalies. The second phase of this investigation included the collection of potable well water and surface water samples. The nearest potable wells, located approximately 3/4 mile from the Site, had not been impacted by Site contamination based on ongoing sampling. In addition, in 1988, a security fence was installed by the potentially responsible parties (PRPs) around Area A, and along the property boundary to restrict Site access and trespassing. The fence is locked and has a signed gate at the county road. This fence remains at the Site and is inspected and maintained regularly.

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Basis for Taking Action

The Ewan Site was proposed for the National Priorities List (NPL) on September 8, 1983. EPA added the Site to the NPL on September 21, 1984. EPA completed a remedial investigation and feasibility study (RI/FS) in 1988. The RI investigation included, but was not limited to, the following: soil and groundwater sampling; installation ofgroundwater monitoring wells; installation oftest pits and soils borings ; geophysical, magnetometer and soil gas sampling; sampling ofdomestic wells; arid surface water and sediment sampling. The major findings ofthe 1988 OUl RI include:

• Approximately 4,500 cubic yards ofsource material was buried on-site, including between 5,000-8,000 drums and drum remnants, and heavily contaminated materials, in 35 trenches. The disposal area encompassed approximately 200,000 square feet. The RI estimated that 29,500 cubic yards ofcontaminated soil was in close proximity to the source material which was later revised in the OU2 Feasibility Study to approximately 22,000 cubic yards of soil that would require Remedial Action ofthe OU2 remedy1;

• Soil and groundwater samples indicated that the source materials contained chlorinated organic compounds, aromatic hydrocarbons and metals. Contaminants include 1,2­dichloroethane, tetra-chloroethene, 1, 1, I-trichloroethane, methylene chloride, trichloroethene, carbon tetrachloride, 1,1-dichloroethane, chloroform, benzene, ethylbenzene, naphthalene, xylenes, toluene, lead, barium, copper, and chromium;

• A groundwater contaminant plume which contained high levels of volatile organic compounds (VOCs) was estimated to be 500 feet long, 600 feet wide and 30 feet deep.

Public health risks posed by Site contaminants prior to remediation at the Site included the potential for direct contact with contaminated wastes and soils, as well as the potential for ingestion ofcon~ated groundwater underlying the Site.

The 1988 and 1989 RODs for OUl and OU2 present the results of the human health risk assessment (HHRA). The Feasibility Study concluded that actual or threatened releases of haz.a.rdous substances from the Site, ifnot adequately addressed, may present an imminent and substantial endangerment to public health, welfare, or the environment. The environmental risk presented by the Site was the continued degredation ofgroundwater in the sensitive ecosystem of the New Jersey Pinelands.

The risk analysis was based on the direct exposure of contaminants due to the soil coming into direct contact with skin, or from the ingestio~ ofthe soil by a child playing in the area, or by direct ingestion or inhalation ofcontaminants in groundwater. The major public health risk posed by the Site was determined to be the potential ingestion of contaminated groundwater from the aquifer. EPA' s sampling ofgroundwater and soils conducted as part of the final June 1988 RI, and during subsequent soils and groundwater sampling in 1989, determined that the organic

1 These estimates, as discussed later in this report, were revised to approximately 16,000 cubic yards ofsoil, and 3,838 drums, excavated during the remedial action.

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contamination ranged from non-detectable to 5,300 micro grams per liter (µg/l ). Inorganic contaminant concentrations ranged from 1 µg/l to 1,800 µg/l. The total Hazard Index (HI) for ingestion of the on-site contaminated, groundwater was 1.9. Contaminated groundwater was associated with an excess lifetime cancer risk of 10-3• The risk drivers were identified as 1,2­dichloroethane, beni:ene, chloroform, and methylene chloride.

An ecological risk assessment was also conducted and indicated that ecological risks assqciated with sediment and surface water were not significant.

Remedial Actions

Remedy Selection

Based upon the RI/FS findings, EPA chose to address Site r~mediation in two operable units (OUs}, referred to as OUl and OU2. The OUl remedy addressed buried drqm.s, bulk disposal trenches, and contaminated soils found at the Site, via excavation and off-site disposal. The OU2 remedy addressed groundwater restoration via the extraction and treatment ofdissolved phase contaminants, with discharge oftiie treated effluent to the underlying aquifer.

On September 29, 1988, EPA issued the ROD for OUI. C9lllponents of the OUl remedy are summarized as follows:

• The excavation and off-site incineration of buried drums;/

• The excavation and off-site disposal or' incineration of source material (heavily contaminated soil);

• Monitoring ofthe air and groundwater during remedial activities; and • Backfilling of trenches.

On September 29, 1989, EPA issue~ the OU2 ROD. The components of the OU2 remedy are summarized as follows: /'

• Excavation and tre~tment, via solvent extraction and soil washing, ofresidually contaminated OU2 soils, followed by placement of the treated soils back onto the Site;

• Collection and treatment ofthe contaminated groundwater, and on-Site reinfiltration of the effluen,t;

• Recontouring and restoration of the disposal areas; • Construction ofan on:-site wetlands area; and • Environmental monitoring to ensure effectiveness of the remedy.

During the OUl design, EPA determined that it was more practicable and cost-effective to handle all the contaminated soils at the same time. As stated above, EPA issued an BSD on July 13, 1994, that modified both remedies by excavating all contaminated soils above the water table during OUl, rather than just the most heavily contaminated soil; thus only a single excavation of contaminated soil would be needed at the Site. The remaining residually contaminated soils would be addressed as part ofthe OU2 groundwater pumping, treatment, and recharge remedy. Any remaining residual contamination in the saturated zone soils after excavation would be flushed in situ during the OU2 remedy to achieve the groundwater remedial action objectives.

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Remedial Action Objectives

The original OUl ROD remedial action objectives for soil is to control source materials and to prevent contamination ofthe underlying aquifer. The overall objective for groundwater is to provide protection to drinking water supplies, as well as preserve and restore Site groundwater in the most heavily protected portion of the Central Pine Barrens Region ofNew Jersey. The OUl ROD identified that the contaminated groundwater plume was to be remediated by a subsequent operable unit (OU2).

The remedial goals for groundwater, as identified in the OU2 ROD, are also the Applicable Relevant and Appropriate Requirements (ARARs) for the Site, consisting of Federal Maximum Contaminant Levels (MCLs), as well as the New Jersey Class 1-PL standards designated by Section 7:9-C.1.5 of the New Jersey Safe Drinking Water Act, and the New Jersey Administrative Code (N.J.A.C.) Title 7, Chapter 9, Subchapter 6~ Section 6, Subsection (a) (N.J.A.C. 7:9-6.6(a)) criteria in the treated effluent.

The final OU2 remedial design (RD) report presented additional remedial objectives which were developed for contaminants not identified in the OU2 ROD, but subsequently detected in Site groundwater, as well as updated NJAC7:9-Cl.5 standards. For inorganic compounds, the RD Report established Site-specific background levels which were developed from upgradient well data, consistent with NJAC 7:9-C.1.5.

The OUl ROD had not anticipated the need for soil remediation goals, and EPA used the July 13, 1994 ESD to clarify the expectations for the soil excavation remedy. Soil goals that were identified in the ESD are presented in Table 2a, Remediation Goals for Soil. After completion of the soil excavation work, a review ofthe post-remediation sampling indicated that the action had removed all soil contamination down to the water table (approximately 10 feet) to an ~estricted use standard. The 1994 ESD also reiterated the groundwater remedial goals for the Site, as identified in the OU2 ROD, and are presented in Table 2b, Remediation Goals/or Groundwater.

Remedy Implementation _,

The PRPs for the Site have been implementing the ROD remedies, as modified by the 1994 ESD, under three Unilateral Admini~ative Orders, with EPA oversight, as follows:

• UAO Index No. II-CERCLA-90114 issued to Chrysler on September 26, 1989, directing it to perform the OUl remedy.

• UAO Index No. II-CERCLA-90114 (note the same index Qo.) issued to 18 additional respondents on June 11, 1990, directing them to cooperate and participate with Chrysler in implementing the OUl remedy. ­

• UAO Index No. II-CERCLA-95-0107 issued to 19 respondents (including Chrysler) on May 19, 1995, directing the PRPs to perform the OU2 remedy.

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Operable Unit One

On August I6, I994, the OUI remedial construction commenc¢. Trench excavation activities were completed on July I4, I995. Off-site disposal ofdrums and associated soils was completed by September I995. An estimated 3,800 drums and approximately I6,000 cubic yards of contaminated soil, were excavated to groundwater, a depth ofapproximately I 0 feet for off-site disposal, from 35 disposal trenches in the seasonally unsaturated zone. During excavation, many ofthe drums were found to be damaged or disintegrated. Trench excavations were backfilled with a combination ofclean soil from an off-site borrow pit (for use below the seasonally saturated zone), and Site soil ofacceptable quality generated during excavation. At the conclusion of the QUI remedial construction, confirmatocy side wall samples were collected within the excavation trenches to assure that the soil RAOs had been attained. An earthen berm was constructed around the perimeter of the excavation area to prevent stormwater run-on and run-off.

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The field work for the QUI remedial action was completed in I 995. EPA accepted the work as complete in January I 996.

As part of the OUI RD activities, wetlands delineation was co1;1.ducted at the Site. Wetlands were identified on and surrounding the Site. Concurrent with the QUI remedial action (RA) activities, wetlands mitigation was conducted to create and restore three acres ofwetlands that were impacted by the remedial action and the construction C?f the Site access road. The created and restored wetlands were developed in conjunction wjth the NJDEP and the Pinelands Commission, to be consistent in vegetative characteristics with local wetlands. The wetland­monitoring program was conducted to verify the overall health and condition of the on-Site wetlands, and to ensure that the wetlands that had been created as part of the mitigation activities remain viable and healthy. During the wetlands monitoring program, an invasive tree known as the Russian Olive Tree was identified to be pervasive throughout the wetlands creation area. In 2005, a corrective action plan w~.effectively implemented to address the invasive Russian Olive Tree through removal of trees and seedlings.

Operable Unit Two /

-As described in the I988 OU2 ROD and the I994 ESD, extraction, treatment and on-site reinfiltration of treated groundwater were selected as the remedial action for contaminated groundwater. Treated effluent would be reinfiltrated into the underlying aquif~r within the plume boundaries until the groundwater remedial action objectives have been met. As described above, residual contaminated soils would be' remediated via flushing. After remediation is complete the disposal areas would be restored and recontoured.

The PRPs initiated design ofthe groundwater cleanup remedy in August of 1995, following the removal ofburied drums and associated soils. The design was completed in late 1998, followed by the construction ofthe extraction, treatment and reinfiltration system in February 1999. A total of six reinfiltration basins were constructed, covering approximately 200,000 square feet. From March 1999 to September 1999, the system underwent an extensive six-month period of rigorous tests. In September 1999, the remedial system entered O,&M.­

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In December 19, 1999, the PRPs established a Classification Exemption Area (CEA). The overall purpose of a CEA is to define the groundwater contamination area that could impact human health, and it places restrictions on the installation and use of groundwater supply wells within a CEA until applicable groundwater standards have been restored.

The groundwater extraction, treatment and reinfiltration system was designed to achieve the following objectives:

• establish hydraulic control of the contaminant plume via a closed loop system; • aquifer restoration to meet MCLs, as well as the New Jersey Class I-PL standards, by the

extraction ofaqueous-phase contaminants for ex-situ treatment; and • reinfiltration of the treated effluent within the plume boundaries.

Saturated zone flow modeling was conducted that utilized data from aquifet hydraulic characteristics generated during the OUI and OU2 remedial design investigations. Based on the model results, an extraction system was chosen that consisted ofseven extraction wells and a total extraction rate of 200 gallons per minute (gpm), for a total ofmore than 200,000 gallons per day. As the influent conditions and contaminant concentrations changed over time, the flexible design allowed various components and opetation of the system to be optimized.

The full-scale treatment system operated from 1999 until 2006. At that time cleanup standards were met throughout the majority ofmonitoring wells within the former plume area In 2006, a hot spot treatment dual phase extraction (DPE) pilot test began on two limited residually contaminated soils areas within the reinfiltration basins. DPE extracted water underwent batch treatment in the full-scale treatment plant, followed by recharge ofthe effluent through the existing reinfiltration network. The DPE system continued to operate until 2011, when it was terminated because ofsignificantly reduced groundwater contaminant levels. However, the full­scale extraction and treatment system can be restarted with 24 hours notice, ifnecessary. Throughout the implementation of the OU2 groundwater remedy, the remedy operated as designed, and consistently met the performance goals for the treated effluent.

An extensive sampling network and monitoring program has been established which includes over 70 groundwater monitoring points, that are sampled and monitored regularly. The current groundwater monitoring program is listed in Table' 4, 2013 Monitoring Program.

System Operation and Maintenance

The O&M for the extraction, treatment and reinfiltration system began on September 24, 1999. Early during the O&M phase, EPA commissioned the United States Army Corps ofEngineers (USACE) to provide oversight and technical evaluation ofthe remedy. As part of the adjustments made to optimize and improve performance, system modifications were implemented, and several system components were decommissioned because of declining levels of influent contamination, including the following:

a) In-situ bio-remediation was terminated in early 2000;

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b) The catalytic oxidizer and hydrochloric acid scrubber were taken off-line in January 2002; and,

c) The two air stripping towers were taken off-line in April 2002.

In addition to the above; changes to the remedial system included the following:

d) An aggressive program to periodically cle~ iron fouling ofextraction wells, conveyance lines, and other system components;

e) Plant operations computer and software were upgraded;

f) Extraction well flows and flows to infiltration basins were adjusted to optimally extract contaminants from the groundwater plume, tp maximize the flushing of residual soils , contamination, and to limit the spread ofcontamination vertically and/or horizontally;

g) Supplemental in~situ pilot studies were conducted to evaluate the effectiveness of prospective technologies to enhance the recovery ofresidual soil within soil hotspots;

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h) In 2004, the PRPs conducted a soil sampling program to identify ifany soil hot spots remained within the recharge basin area, and to help determine the overall effectiveness of the soil flushing part of the original remed·{ to reduce soil contamination throughout the former disposal area;

i) During 2003 and 2004, the PRPs conducted a DPE pilot study to evaluate the recovery of contaminants in both soil vapor ~d the aqueous phases. The study revealed that DPE could more efficiently address areas ofresidual contamination in a focused area in a shorter amount of time ~the full-scale groundwater remediation system;

j) In June 2004, soils excavation was conducted in the vicinity ofmonitoring well TC-30, which removed approximately l,100 cubic yards ofcontaminated soils;

k) In 2005, a seasonally saturated soil sampling program identified two areas where residual groundwater contamination was above remedial objectives in the immediate vicinity of wells TC-32NE-2 and TC-33. Sampling also confirmed the effectiveness of2004 contaminant removal in the excavated TC-30 hot-spot area;

1) The groundwater and extraction system was taken off-line on June 20, 2006, to allow a DPE treatment system to address the soil hot spots around monitoring wells TC-32NE-2 and TC-33. In adtµtion, an expanded groundwater monitoring program w~ implemented to evaluate the effectiveness ofthe DPE system.

Since start-up in March 1999, the OU2 groundwater treatment methods, comprising both the full-scale pump and treatment and the DPE systems have operated effectively. They have significantly contained the plume, as well as significantly reducing levels of groundwater

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contamination in all areas. Apprdxim.ately 304 pounds ofcontaminants were recovered through treatment ofthe groundwater via the full-scale treatment system, and an additional 190 pounds were subsequently removed through the OPE system for a total of494 pounds. Over 468 million gallons of contaminated groundwater have been extracted, treated, and returned to the groundwater infiltration system to date.

Progress Since Last Five-Year Review

The last five-year review was issued by EPA on August 30, 2009. That review did not list any issues or recommendation any additional actions for the protection of public health and/or the environment, noting that numerous routine O&M activities were ongoing. Further, the last five­year review concluded that the remedies implemented at this Site were functioning as intended and were protective ofhum.an health and the environment.

Progress since the last five year review of2009 includes the following activities:

a) From June 2006 to May 2010, OPE treatment was conducted in two limited soil hot-spot areas, identified as TC-32NE-2 and TC-33, at flows averaging between 6 gpm to about 10 gpm. Treated effluent was re-infiltrated into the existing recharge basins.

b) From May 1, 2010 to April 2011, the OPE system was operated using a pulsed phased­pumping approach, consisting ofa two month "on" and two month "off" cycle;

c) On April 30, 2011, the OPE system operation was completely shut down and has remained off, while groundwater conditions continue to be evaluated.

d) In June 2011, the PRPs submitted "The DPE System Operation Using a Phased Pumping Approach Pilot Test Report." Groundwater sampling results indicated the OPE system was no longer effective in further reducing levels of contaminants in groundwater in the one hot-spot area identified as the TC-32NE-2 area.

e) In January 2012, the PRPs submitted the "Remedial Approach Program Work Plan" to address the TC-32NE-2 hot-spot area, which outlined a soils and groundwater sampling program to identify the extent of residual soils concentrations that were contributing to groundwater contamination in the TC-32NE-2 hot-spot area.

' t) From March 22, 2012 to March 26, 2012, a soil and groundwater sampling program was conducted in the TC-32NE-2 area to delineate the extent ofresidually contaminated soils. In addition, two shallow monitoring wells (TC-36 and TC-37) were installed.

g) The TC-32NE-2 Excavation Work Plan was submitted to EPA in August 2012, which proposed soil excavation in the TC-32NE-2 area to remove residual soil concentrations that were contributing to the groundwater contamination.

h) From November 12 to 16, 2012, approximately 600 tons of soil were excavate~ from the TC-32NE-2 area and transported off-site for disposal. The excavation was backfilled

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with clean soils. Approximately 15,000 gallons of groundwater in the excavation area was pumped, treated at the on-site treatment plant, and recharged to the recharge basins.

i) The "TC-32/VE-2 Soil Remedial Program Report" was submitted to EPA in February 2013, and EPA approved the report in March 2013.

j) On March 8, and Aprill, 2011, a five-year off-site well sampling event was conducted at properties located approximately 3,000 feet hydraulically downgradient of the Site, the closest off-site properties in the vicinity ofthe Site. EPA and the PRPs' contractor collected nine domestic well samples, one sample from the Shamong Township Recreational Center Well, and one surface water sample.

k) In March 2613, the comprehensive 2.5-year monitoring event was conducted. The 2.5 Year Groundwater Quality Monitoring Report was submitted to EPA in October 2013.

As noted previously, groundwater VOC and semi-volatile organic compound (SVOC) concentrations at the Site have continued to decrease, and are below or just slightly above . detectable levels in most all monitoring points on-Site. Contaminant levels in the groundwater will continue to be monitored to determine if any additional actjons are necessary.

'

The three hot-spot areas that were targeted for additional source treatment through excavation and dual-phase extraction (DPE) have shown very significant removal of contamination, although, as noted above, some low-level exceedan9CS of groundwater remedial goals have been observed. Sampling also confirms the effectiveness of2004 contaminant removal in the excavated TC-30 hot-spot area. No identified concentrations of VOCs or semi-volatile organic compounds (SVOCs) remain in unsaturated-soils. Groundwater contaminant levels will continue to be monitored to determine ifany additional actions are necessary. The PRPs, EPA, and the NJDEP continue to evaluate the Site._

Five-Year Review Process

Administrative Components /

The five-year review team included ofStephen Cipot, EPA (remedial project manager (RPM));/

Michael Van Itallie, (EPA attorney); Michael Scorca, EPA (hydrogeologist); Marian Olsen, EPA (human health risk assessor); Michael Clementson, EPA (ecological risk assessor); and Natalie Loney, EPA (community involvement coordinator).

Community Involvement

EPA notified the Township Administrator by telephone on November 6, 2013 that EPA had initiated the five-year review process and extended an invitation to participate in the Site inspection to be held on December 4, 2013. EPA also provided a five-year review notice to the Township Administration on Friday, November 15, 2013. On Monday, December 23, 2013, the Township Administrator informed EPA that the Ewan notice was posted and publicly available on the township's website, and this was verified. The notice indicated that EPA would be

11

conducting a five-year review ofthe remedy at the Ewan Property Site to ensure the remedy remains protective ofhuman health and the environment and is functioning as designed, and that once the five-year review is completed, the results will be made available in the local Site repositories. The notice included the RPM's and CIC's business address and telephone numbers for questions related to the five-year review process for the Site. The Shamong Township Administrator attended the five-year review Site inspection visit held on December 4, 2013, with one other township official in attendance. The officials present during the Site inspection were satisfied with the overall Site progress. The officials present also stated a desire that after the existing groundwater treatment plant is decommissioned, the building shell be left intact and turned over to the local government.

Once the five-year review is completed, the results will be made available at the local Site repository located at the Burlington County Municipal Building Clerk's Office, 851 Old York Road, Burlington County, New Jersey. In addition, efforts will be made to reach out to local public officials to inform them ofthe results.

Document Review

The documents, data, and information which were reviewed in completing the five-year review are summarized on Table 3.

Data Review

The data reviewed included the historical data from the Site file for OUl and OU2, the administrative record, as well as subsequent extensive groundwater monitoring data from the O&M phase ofthe groundwater extraction, tre.atment, recharge remedy (OU2), and OPE system which operated from 2009 through 2011. Please see Section IV, above, for a detailed review of the recently collected data as part ofon-going O&M activities. Groundwater concentration trends are generally downward, as represented on the attached historical trend plot charts, for specific key wells pertinent to the discussion below. '

During the last five years, on-going review ofthe groundwater sampling data provided information for the start-up and shutdown ofthe OPE system and the targeted excavation ofsoils in the area ofwells TC-32 and VE-2.

The current groundwater monitoring network for the Site selects wells for sampling at four different frequencies. Six wells are sampled monthly, 19 wells quarterly, 48 wells semi­annually, and 60 wells every 2.5 years. Samples are analyzed for VOCs, SVOCs, Target Analyte List (TAL) metals, field parameters (redox potential, dissolved oxygen, conductivity, turbidity, pH, and temperature), ammonia, chloride, fluoride, nitrate, phosphate, sulfide, and some wells are analyzed for natural attenuation parameters (including sulfide, ferric iron, ferrous iron, TOC, metabolic acids and gases). Water-level measurements from the full well network are collected at a monthly frequency and plotted as water-level contour maps.

The attached trend plot charts for Extraction Well-3 (EW-3), and monitoring well TC-33, which are located in formerly highly contaminated portions of the groundwater plume, demonstrate the

12

overall downward contaminant trends over time. Concentrations of total VOC and SVOC contamination in groundwater have decreased by over three orders ofmagnitude (well EW-3), and four orders ofmagnitude (~ell TC-33) since the groU)ldwater remedy became operational.

Wells TC-33 and MP-9 are located near one of the former DPE points, and since 2009 have had· only a few documented levels of slightly elevated exceedances ofthe NJDEP Ground Water CEA compliance criteria.

Wells MP-3, IC-12, and TC-30 are in the western part of the Ewan Property, near the area of the 2004 targeted soil excavation. voe concentrations in groundwater have remained low in this area. Total VOCs have been below 4 micrograms per liter (µg/L) since 2010 at well MP-3, and have been less than 1 µg/l at IC-12, except for one sample in 2012 (8.8 µg/L). Concentrations of SVOCs at well TC-30 have shown a slightly increasing trend since 2011, however, there is seasonal variability for this well.

For the TC-32/VE-2 groundwater hot-spot area, in 2011 the PRP's proposed to shut down the DPE treatment system because it appeared that it was no longer e:ffe~tive in further reducing levels ofcontaminants within the hot-spot, and the PRP' s proposed to submit a work plan to address the continued groundwater contamination. Total detected VOC levels had varied from less than a total of 500 ug/L to a high of approximately 1,925 µg/L, consisting mostly of toluene (1,600 µg/L), and xylenes (200 µg/L), above groundwater quality standards, as well as acetone, l, 1-DCA, and TCE (1 µg/L). To address the TC-32NE-2 area, in January 2012, the PRPs proposed a soils and groundwater sampling program tO identify the extent ofresidual soils concentrations that was contributing to the groundwater contamination within the hot-spot. In addition, two shallow TC monitoring wells (TC-316 and TC-37) were proposed to collect groundwater sample locations immediately downgradient of the TC-32NE-2 area. EPA approved the Work Plan in February 2012, and the PRPs implemented the work in March 2012. The two new monitoring wells were incorporated into the ongoing groundwater monitoring program.

,'

The new monitoring well TC-32R is the replacement well for TC-32, which is located in the footprint of the TC-32NE•2 hot-spot area that was excavated in late 2012. Concentrations of total VOCs in groundwater at well TC-32/32R have decreased by two orders ofmagnitude since the targeted soil excavation. Although total SVOC concentrations increased temporarily in the period after the C?CCavation, they have declined since September 2013. Wells TC-36 and TC-37 monitor groundwater quality immediately downgradient of the 2012 excavation area. Total VOC and SVOC concentration are consistently low at < 4 µg/l at TC-36. At well TC-37, VOC concentrations were below 15 µg/l until the most recent sampling after the soils excavation in December 2013, when levels reached a total of 55 µg/L, the primary constituents being toluene, total xylenes, ethyl benzene, and 1,1-dichloroethane, at concentrations well below groundwater quality standards, as well as 1,2-Dichloroethene (1.0 µg/L) and trichloroethene (1.4 µg/L), which are at and slightly above NJ ground water quality standards (NJGWQS), respectively.

Long term results of the groundwater sampling program indicate that the implemented remedies and O&M activities have led to significant progress in improving the water quality at the Site. Review ofoverall groundwater quality for the most recent 2.5-year monitoring period

13

indicates residual groundwater contamination in the former source area of the reinfiltration basins has met remedial objectives with the exception ofconcentrations ofconstituents of concern detected in the one former hot-spot area identified by wells TC-32NE-2, as observed in wells TC-37, TC-32, and TC-32R, and in well TC-30 which is near the area of the 2004 targeted soil excavation. The results in these wells are slightly above and below the remedial objectives. The TC-32NE-2 area was addressed by the TC-32NE-2 excavation program implemented in November and December 2012. Most wells show long-term declines in voe and SVOe concentrations, and more recently have relatively stable low level concentrations, with some fluctuations observed. Metals are not identified as contaminants ofconcern for this Site. Sampling results for all other voes and SVOCs indicate no results above remedial goals. Trend charts for several key wells noted above are attached for reference.

As stated above, as part of the remedial action, an off-site residential well sampling program was conducted in March and April 2011, at nine downgradient residential wells and a private pond, to ensure that no Site-related contamination is impacting local potable wells or surface waters. As with the previous off-site residential well sampling conducted in 2006, the 2011 sampling confirmed that there were no impacts in the sampled off-site locations. The nearest downgradient wells are located approximately % miles southwest of the Site. Off-site wells are sampled once every five-years. T AL metals were either not detected, or detected below standards with the exception ofaluminum, iron and manganese in some wells. The detected concentrations are attributed to background groundwater quality associated with the aquifer. No VOCs were detected above standards in any ofthe off-site samples collected. No SVOCs were detected in any well or pond sample. The same off-site wells are scheduled to be sampled in June 2016.

In June 2008, a number ofoff-site private residential wells were sampled by individual property owners as a result of an initial residential well sampling conducted pursuant to the New Jersey Private Well Testing Act. Subsequent sampling of additional nearby homes conducted by the Burlington County Health Department revealed mercury concentrations detected above the MCLs. These potable wells are located in the vicinity of the Site, but hydraulically upgradient and side gradient to the Site. Review of Site-related data indicates that mercury is not a Site contaminant; it is occasionally detected in off-site and background groundwater samples, but it has never been detected in the wells immediately downgradient of the Site. Regional groundwater studies by the NJDEP and United States Geological Survey indicate that sporadic mercury detections in local potable wells are attributed to regional groundwater contamination likely attributable to various anthropogenic sources, such as atmospheric deposition, and use of pesticides, herbicides, fungicides and preservatives.

Site Inspection

A Site inspection for this five-year review was conducted on December 4, 2013, by the members of the five-year review team, including representatives from EPA, the PRPs, and local government representatives.

14

)

The team inspected the Site for general conditions, drainage, debris and access controls. The Site was found to be in good condition. The fence surrounding the Site remains intact, there are no visible signs oftrespassing onto the Site, and both the treatment plant building and the Site in general are free ofdebris. The Site drainage gradient allows for maximum rainfall runoff from its surface to off-site areas, including adjacent wetlands, it continues to function as designed. The reinfiltration basins are in good working order. The vegetation found at the Site is a combination ofuplands forest and primarily wetlands vegetation, both ofwhich appeared to be healthy. The restored wetlands continue to support healthy vegetation. This vegetation does not suggest that environmental conditions are being degraded as a result ofproximity to the Site.

Interviews

During the Site inspection, the five-year review team discussed Site status with the PRPs' contractor, and with local government representatives. In addition, there have been on-site meetings with concerned parties and with local government officials and community representatives over the course ofthe remedial action, and during previous five year review Site inspections. EPA regularly communicates with the PRPs, the plant operator, representatives of the NJDEP, the Pinelands Commission, Borough representatives and interested residents, as needed, and stakeholder State agencies regularly receive copies,of all key reports and work ~~ ~

During the Site inspection, the Site RPM was notified by community officials of their wish that after the on-site groundwater treatment plant is decommissioned the building shell be left intact and turned over to the local government for their use.

Institutional Controls Verification

The Site falls within the Central Pine Barrens Preservation Area of the New Jersey Pinelands, and is viewed as an ecologically s~nsitive area, as administered, by the New Jersey Department of Environmental Protection and the New Jersey Pinelands Commission. Institutional Controls are in place at the Site. In 1999, a CEA was established and is still in place for this Site. In addition, in June 2011, a Deed of Conservation Easement in perpetuity was filed for the property for the exclusive purpose ofassuring the conservation values will be conserved and maintained.

Teehnical Assessment

Question A: Is the remedy functioning as intended by the decision document?

Yes, the remedies are functioning as intended in the original RODs and the ESD. As described in Section 4.0, the goals of the OU2 ROD were to address impacts to soil and groundwater through the extraction, treatment and reinfiltration oftreated groundwater. Based upon extensive data collected and evaluated, the remedy is functioning as intended, groundwater contamination is being controlled, the performance goals for the treated effluent have been consistently maintained, and there are substantial overall decreasing trends in concentrations of Site contaminants in Site groundwater.

The basis for this conclusion lies in the following:

15

• Successful operation of the full-scale groundwater extraction, treatment and reinfiltration system, from 1999 to mid-2006;

• Post excavation soil and groundwater sampling programs conducted in the immediate vicinity of the 2004 soils excavation at the former TC-30 hot-spot area indicate soils were successfully removed above the saturated zone;

• The soil sampling program conducted in 2005 within the former disposal and infiltration basins area indicated that no significant concentrations ofVOCs or SVOCs remain in unsaturated soils;

• The implementation ofDPE and pulse pumped DPE to recover residual contamination in the vicinity ofwells TC-32 and TC-33 from 2006 to 2011 was successful in reducing groundwater contamination;

• Post excavation soil and groundwater sampling programs conducted in the immediate vicinity of the 2012 excavation of soils in the TC-32NE-2 area indicate soils were successfully removed above the saturated zone;

• Extensive groundwater monitoring from 1999 to 2013 shows d~ing concentration trends, and sampling results from the area outside of the infiltration basins, consisting ofmonitoring wells IC-8, IC-9, IC-10, IC-11, IC­12, IC-13, IC-14, IC-15 and IC-16, show no new or recent groundwater contamination; and

• The off-site residential and potable well sampling program continues to demonstrate the absence ofany Site-related impacts on tested downgradient wells, including two wells located at the Town's ball fields located 3/4 ofa mile downgradient of the Site.

As described above, the O&M activities in the 1994 ESD were projected to run for a period of approximately 10 years. Although the remedy has operated for over 10 years, and the groundwater remedial objectives have not yet been completely achieved in all areas throughout the Site, significant progress has been made toward achieving the remedial action objectives in most areas. Low residual levels ofcontamination remain localized in very isolated spots in the saturated soils. All contaminated soils above the water table have been removed. The groundwater concentration trends on the attached historical trend plots show the overall progress, with concentration tends generally downward. However, as noted, there is some minor local and seasonal variability. Note that the new monitoring well TC-32R, is the replacement well for TC­32, which is located in the footprint of the TC-32NE-2 area that was excavated in 2012.

As stated previously, a CEA has been in place at the Site since December 1999. The purpose of a CEA is to define a groundwater contamination plume that could impact human health, and it places restrictions on the installation and use ofgroundwater supply wells within a CEA until applicable groundwater standards have been restored. The PRP' s contractor plans to apply for an updated CEA in the future based on updated Site conditions.

16

Question B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action objectives used at the time ofthe remedy still valid?

a. Soil. Soil use at the Site is not expected to change during the next five years. Remaining Site contamination is limited solely to residuals saturated zone soils, and to groundwater, not surface soils or soils above the water table. The exposure analysis used in the 1988 risk assessment followed guidance available at that time. During the implementation of the OUl remedy in 1995, drums and soils were excavated and removed from Area A and the excavation extended to the sidewalls. Clean soil was used to backfill the excavated area. Post­excavation samples were collected from excavated areas sidewalls from September 1994 tq July 1995, and compared to standards listed in the 1994 ESD.

'

Comparison ofthe sidewall sample data to current residential risk based scret?ning levels for potential cancer and non-cancer health effects assuming exposures ofadults''and children for 350 days/year for a period of24 years and 6 years respectively were conducted. This comparison of sidewall data compared to residential risk-based concentrations (RBCs) that meet EPA's goals of protection (i.e., cancer risk ofone in a million and non-cancer HI or'1), indicates that the risks did not exceed EPA's goal ofprotection for any contaminant ~th only one exception, i.e., one sidewall sample arsenic concentration slightly exceeded the non-cancer HI of 1, but it was noted that this is not a chemical ofconcern at the Site.

Given that heavily and moderately contaminated soils were excavated and backfilled with clean soil in 1995 (e.g., OUl), the human exposure pathways have been eliminated. Based on current studies, there appears to be no significant concentrations of contaminants in either saturated or unsaturated soils. Additional analysis may be necessary at a later time, which may include the collection ofadditional soil samples.

Furthermore, in 2011, as noted onjhe Site chronology (see Table 1) a Deed ofConservation Easement was recorded in Burlin'gton County to protect the conservation values of the property in perpetuity. Briefly, the easement is designed to protect natural resource services, including but not limited to watershed'protection, water quality protection, aquifer recharge potential, scenic vistas, and a variety ofwildlife habitat (collectively "Conservation Values"). The Conservation Easement, issued to the NJDEP and subject to completion ofthe remedy, is to assure that the Corlservation Values of the Site are retained forever and to prevent any use ofthe Site that will impair or interfere with the Conservation Values. Among other restrictions, absent prior consent of the State, no structures can be placed on the property, no change in topography can occur, no pavement can be placed, and no activity is permitted that would be detrimental to drainage, flood control, water conservation, erosion control or soil conservation. The State has the authority to enforce the Conservation Easement, and the Conservation Easement is deemed to be a servitude running with the land in perpetuity. The Conservation Easement applies to all legal successors of the property owner, and the State itself has a right of first refusal should the property ever be offered for sale.

The soil remedy remains protective based on a combination ofthe use ofclean soils to backfill excavated areas, the risk assessment identified above, and the easement.

17

b. Groundwater. A CEA is in place to prevent wells from being drilled within the area of groundwater contamination. The March 2013 2.5-year groundwater sampling ofVOCs and SVOCs found that the detected concentrations in all CEA Compliance Wells were below the RAOs. In October 2009, a report evaluating Site conditions for monitored natural attenuation with a proposed revised CEA was submitted to the NJDEP for the Site based upon groundwater quality at that time. The revised CEA proposal was not acted on by the NJDEP and has been deferred. The PRPs' contractor plans to submit a revised CEA proposal to the NJDEP, updated to current Site conditions in 2014.

The evaluation of the direct contact pathways showed that all nearby residents are consuming private well water and the groundwater remedies, coupled with the contaminant reductions already achieved, prevents off-site migration. The OU2 ROD and ESD identify MCLs well as New Jersey Class 1-PL standards designated by NJAC 7:9-Cl.5, for groundwater as ARARs, and these standards remain protective of the groundwater, and, therefore, the 'remedy is protective for this exposure pathway.

In March and April 2011, EPA conducted off-site sampling ofa seasonal-use public ball field irrigation/potable water supply well and eight additional residential wells and found that there were no impacts in the off-site wells from the Site. The off-site wells will be resampled in 2016.

The Deed ofConservation Easement described above also protects groundwater. The groundwater remedy remains protective.

c. Vapor Intrusion. Currently, the groundwater treatment plant is the only building located on the Site. Evaluation of the most recent groundwater concentrations at the Site indicated no sample results exceeded the groundwater screening criteria for Vapor Intrusion (U.S. EPA 2002 OSWER Draft Guidance for Evaluating the Vapor Intrusion to Indoor Air Pathway from Groundwater and Soils Subsurface Vapor Intrusion Guidance), available at:

www.epa.gov/osw/hazard/correctiveaction/eis/vapor/complete.pdf

Although not expected due to the Deed ofConservation Easement associated with the property, if this land were to be developed for residential or industrial purposes in the future, further evaluation ofthis pathway should be conducted. This evaluation should include Site-specific considerations such as the type ofbuilding, the location ofthe building in relation to the maximum detected concentration in groundwater, and the subsurface characteristics at the Site.

d. Are the Cleanup Values Selected in the ROD Still Valid? The purpose of the 1988 OUI ROD remedy for the soils was to remove grossly contaminated soils and hazardous waste above the water table and, therefore, prevent the migration ofhazardous substances, pollutants and contamination from these source areas to Site groundwater. Specific soil goals were later identified in the ESD. As part of the OUl RA, extensive soil excavations were performed and the excavations were backfilled with clean soil in 1995; therefore, the human exposure pathways have been eliminated. Based on current data, there are no significantly elevated concentrations ofcontaminants in either saturated or unsaturated soils.

18

Federal MCLs, state MCLs, and NJGWQS established in NJAC 7:9-C-1.5 were identified as ARARs in the OU2 1989 ROD and the 1994 ESD for remediation ofthe on-Site groundwater. These remain valid and are protective.

The Ecological Risk Assessment in the RI indicates that ecological risks associated with , sediment and surface water were not significant. The soil excavations and backfill along with the groundwater control by the extraction and treatment system have elimiriated exposure to ecological receptors. Although the ecological risk assessment screening values used to support the OUl and OU2 RODs may not necessarily· reflect the current values, the remedy is protective ofecological receptors.

e. Changes in Toxicity Values. The 1988 and 1989 RODs identified the following chemicals ofconcern that ~xceeded the ri* range. The chemicals included, 1,2-dichloroethane, chloroform, methylene chloride and xylenes. Since the last five-year review,.there have been no changes in the toxicity information for the ~ain chemicals of concern. ·' ~

Question C: Has any other information come to light that could call into question th~ protectiveness ofthe remedy?

I'

Based on the evaluation of the potential miman exposures at tlie Site, there is no new information that has been developed that could call into question the protectiveness of this remedy.

Remedy Technical Assessment Summary

• The full-scale groundwater extraction, treatment and recharge system was in operation from September 1999 until June 2006. This system successfully treated groundwater contamination to the appropriate standards. Because of the low, decreasing, concentrations ofconstituents ofconcern observed, the full-scale treatment plant is likely to be decommissioned in the near future.

• The DPE system recovecy of residual contamination in the vicinity ofwells TC-32 and TC-33 operated as designed, from 2006 to 2010.

• Site contaminants are no ionger hydraulically contained in the groundwater phase due to the cessation ofgroundwater extraction, treatment and recharge and DPE system operation in 2011; however, remediation of groundwater has successfully reduced dissolved.concentrations so that no groundwater plume exists and hydraulic containment is not needed. Concentrations in groundwater are limited to sporadic detections below or slightly above remedial objectives in a few limited Site wells. Residually contaminated soils within the Site recharge basins formerly received treated effluent as part ofa soils flushing action. The supplemental soil removal actions of2004 and 2012 effectively removed the residually contaminated soils.

• The security fence around the Site is in good repair and is maintained and inspected on an on-going basis and the CEA is in place to prevent the use of the water as a potable water source as an institutional control for the groundwater.

• While occasional trespassing has occurred, apparently involving off-road recreational vehicle riders, there is presently no evideµce oftrespassing, or damage to the Site remedy or to the monitoring wells.

19

• The off-site well sampling program conducted in 2011 continues to demonstrate the absence of any Site-related impact ofpotable downgradient wells. The closest downgradient withdrawal ofwater for potable purposes is in a well located approximately % mile away. This well has never shown any impact by the Site contamination.

• A Deed ofConservation Easement was filed in 2011 in perpetuity for the Site property for the exclusive purpose ofassuring the conservation values will be conserved and maintained.

Issues

There are no issues that affect the protectiveness of the remedies at this Site.

Issues, Recommendations and ~ollow-Up Actions

There are no specific recommendations as a result of this five-year review. The Site has on­going routine O&M, and long term maintenance and groundwater monitoring activities (see Table 4 for the $1'oundwater monitoring program). As expected by EPA, these activities are subject to routine modifications and adjustments.

EPA will continue with the various comprehensive groundwater monitoring programs, and continue to monitor the progress of the selected remedies.

Protectiveness Statement

Protectiveness Statements

Operable Unit: Protectiveness Determination: OU2 Protective

Protectiveness Statement: The remedy at OU2 is protective ofhuman health and the environment.

Sitewide Protectiveness Statement

Protectiveness Determination: Protective

Protectiveness Statement The remedies are protective of human health and the environment.

20

Next Five Year Review

EPA will conduct another five-year review by September 2019, unless groundwater cleanup objectives are achieved earlier thflll this date.

/

, /

21

T bl a e 1 - Th Ch te ronoIOi!V of Even s Event

Independent waste haulers deposited drums ofsvoc and voe on nronertv owned bv Herbert Ewan. EPA added Ewan Site to the National Priorities List (Superfund).

Remedial Investigation completed by EPA.

EPA issued an OUl ROD for the Site soils and buried drums.

EPA issued an OU2 ROD for the Site soils and groundwater.

EPA issued UAO for design, construction and cleanup of OUl.

EPA issued an ESD for the Site which modified the OU2 soils remedy by including the OUl and OU2 soils remedies in the OUl remedial action, so

,that onlv a simzle excavation ofcontaminated soil was needed at the Site. The OUl remedial action was implemented and completed. EPA issued UAO for design, construction and cleanup ofOU2.

The OU2 design was completed for the on-site groundwater pump, treatment, and recharge system. Final NJDEP Discharge to Groundwater Permit Equivalent and CEA) for the Site were issued.

Construction was completed for the on-site groundwater pump, treatment and recharge system. The Site entered the O&M phase. Under EPA oversight, the PRPs completed a short-term technical evaluation ofthe remedy and implemented the results to optimize the remedial treatment system. Under EPA oversight, the PRPs conducted a pilot-scale study of several technologies to address residually contaminated soil hotspot areas in the saturated zone. Under EPA oversight, the PRPs conducted an investigation in the area of Intermediate Cohansey (IC) Aquifer well IC,-7, and excavated the Top of Cohansev <TC) TC-30 hot.<;not.

First Five-Year Review.

The supplemental OPE) system _was initiated in full-scale operation.

Wetland Creation Area Monitoring Program 2004 Annual Report.

Under EPA oversight, the PRPs conducted the focused subsurface soiVgroundwater seasonally saturated zone sampling.

Date

1974-75

1984

1988

Sept. 1988

Sept. 1989

Sept. 1989

July 1994

1995-96

May 1995

1997

December 1998

Sept. 1999

2000­2002

2003­2004

'

June2004

Sept. 2004

Nov2004

April 2005

June2005

22

Event Date

Self Monitoring Report/ NJPDES Discharge Monitoring Report and 2.5-Year Jpiy2005Growidwater Quality Monitoring Report.

Focused Subsurface Soil/Grmmdwater Seasonally Saturated Zone Sampling Sept. 2005 The groundwater recovery and treatment system was shut down and the DPE June2006system was operated as the sole remedy.

Off-site Well Sampling Report. Nov. 2006

Comprehensive Evaluation conducted ofDual Phase Extraction as the Sole March Remedy. 2007

CEA Biennial Certification Monitoring Report issued. Jan.2008

Self-Monitoring Report/NJPDES Discharge Monitoring Report and 2.5-Year March -

Growidwater Quality Monitoring Report issued. 2008

Under EPA oversight, the PRPs conducted an investigation downgradient of Oct 2008sentinel wells IC-8 and IC-9. ,,,.

Second Five-Year Review. Aug. 2009

May2010Under EPA oversight, apilot test ofthe DPE system operation using a -Aprilphased pumping approach was conducted. 2011

Self-Monitoring Report/NJPDES Discharge Monitoring Report and 2.5-Year March Growidwater Quality Monitoring Report (July-Sept. 2010) issued. 2011

MarchPresent Conditions Report submitted-to EPA. 2011

OPE System Operation Using a Phased Pumping Approach Pilot Test Report June 2011submitted.

Deed of Conservation Easement was recorded in Burlington County by the Site 0 roperty Owner, Verna Dale Donnelly, to protect the conservation values of the June 2011 lnr•--;;·..·t-v in nemetuitv. Off-site Well Sampling Report. July 2011 Under EPA oversight, the TC-32 & VE-2 Remedial Approach Program Work

Mar. 2012Plan was implemented, with soils sampling and groundwater sampling.

Under EPA oversight, TC-32 & VE-2 Soil Remedial Program implemented. Nov. 2012

C-32 & VE-2 Soil Remedial Program Report submitted to EPA. Feb.2013 EPA approval ofTC-32 & VE-2 Soil Remedial Program Report. Mar. 2013 12.5-Year Groundwater Quality Monitoring event conducted. Mar. 2013 12.5 Year Groundwater Quality Monitoring report submitted to EPA. Oct. 2013

23

Table 2a Remediation Goals for Soil

24

\

Table 2a: Soils Remedial_Qbjectives

• ..• Soff Contaminant Excavation Crltarfa

:-.·.. for the Operable Unit Two Remediation of tha Ewan Pioparty

Contamlnant1

Organld Compound• 1, 1,1·TCA 1,1·DCE, . 1,2·0CE ftotalJ. Benzene Chloroform Ethylbanzene Methylene chlorfde PCE ToJuene TCE Xylenea 1,4-dlchlorobanzerte Phenol •

lnorginrc Compound• Arsenic Barium Cadmium Chromium Jron Lead ManganeseMercury Nlckel SeienJum Silver Sodium Thalllum Zinc

''

'i

'''

I • \I 'llf'"M

•.

Excavatlol'.I Criteria (Hm par mfUJonl

100 100 100 100 100 100 100

1 100 100 100

10 100

10 181 2.9 58

100,261 144

. 76 0.18

22 4.3 0.9 389

0.88 68

From July 1994 ESD

Table 2b: Ground Water Remedial Objectives

Ground Water Remadlal ObJ1ctJv11 -for the pparable Unit :rwo R•medlatlon ot the

Ewan Property ,,·

ccmumlnanll Oe••• ''?Im Squrca

Aldrfn/Dleldrln 0.003 1 Ammonia 50 1 Arsenic 50 3 Barium 1000 1 Benzene. 1 ·2 Banzldlne 0.1 1 Blologlcal Oxygen ~emend 3. . 1 Cadmium 10 1 Carbon tetracl'llorlda 2 2 Chlordane 0.9 2 Chlarobenzene ·4 2 Chloride 10,000 1. Chromium . 50 1

\Coliform Bacteria . 40 CFR 141 · Cofor .1 NTU 3 ·copper 60 1 Corroslvltv Non·Corrosive 3 Cyanide 200 1 DDT and metabolltes o. 00~ 1 m·dlohlorobenzene 600 1 p·dlchlorobenzane 75 3 o·dlchlorobanzane 600 3 1,1·dlchloroathane. 2 2 1,1-dlchloroethylane 2 2 trans•1,2·dlchloroathylena 10 2 2,4-dlchlorophanoxyacetlo acid 100' 3 Ethylbenzane 700 3 Endrln 0.004 1 Fluoride 40 CFA 141 Foaming Agents 50 3Gro11 alpha activity .. 15 pCl/I 3 Hydrogen aulf.fde 50 l Iron. 300 3Lead 50 3Llndane .· 4 3Manganese 50 3Mercury 2 3

From July 1994 ESD

Table 2b: Ground Water Remedial Objectives

Ground Watat Ramedlal ObJac:dvaa' . for the 0fJerabfe Unit Two Remediation of the

Ewa~ Property (c:ontfnuad)

Cgntamlnaots Ggafl luqOI SoUCGI 1,

Methoxychlor 100 3 Methylene 'Chtorlde 2 2 Nlckef 13.4 2 Nitrate-nitrogen 2000 1 Odor 3, 3

Threshold. Odor

pH Phenols

N.umber 4.,a.a.a

300 1 1

Polychlorfnated blphanyla 0.001 1 Ptiosphate 700 1 Radlonuclfdas 40 CFR 141 Radium 5 ·3 Selenfum ~- 10 . 3 Sliver ...... ' .. 50 3 Sodium 10 1 Strontium Sulfate

8 pCl/I 15, 000

3 l

2,4,S·TP Sllvex ~ 10 3 Tetrachloroat~yfena 1 2 Toluene 2000 3 Total Olasolved Sofldi 100 1. Toxaphana 5 3 Trlchlorobenzene a 1 ·Trichloroethvlene 1 2 Trlhalomethanas 100 3 Tritium 20 nC Ill 3 Turbidity 40 CFA 141 1, 1,1 ·trichloroethane 26 2 Vinyl chloride 2 3 Xylenes 44 2 Zinc 5000 3

1). N.J.A.C. 7:9-6.6(a), 2). N.1.A.C 7:10-S, N.l.A.C. 7:10-7, A·280. J), 40 CfR 141, 40 CPR 143. pCi/l =Picocilries per liter. nCi/I • Nanocuriea per liter.

From July.1994 ESD

,­

Table 2b Remediation Goals for Groundwater

25

Table3 Documents, Data and Information Reviewed in Completing the

Five-year Review

Final Report for Operable Unit One, Remedial Action Oversight Report

Ewan OUl Record ofDecision

Ewan OUl Record ofDecision

Explanation of Significant Differences (ESD)

Self-Monitoring Reports/NJPDES Discharge Monitoring Reports, Produced Monthly from October I 999 to April 2004

First Ewan Site Five-Year Review

Focused Subsurface Soil/Groundwater Seasonally Saturated Zone Sampling Report \

Off-site Well Sampling Report

Classification Exception Area (CEA) Biennial. Certification Monitoring Report

Second Ewan Site Five-Year Review

Present Conditions Report, documenting the conditions of the project site at the time that a conservation easement is to be conveyed, was submitted to the Green Acres Program, NJDEP and EPA.

The Self-Monitoring Report/New Jersey Pollutant Discharge Elimination System (NJPDES) Discharge Monitoring Report and 2.5­Year Groundwater Quality Monitoring Report (July-Sept. 2010) was issued.

Off-site Well Sampling Report

Deed of Conservation Easement of the property in perpetuity

OPE System Operation Using a Phased Pumping Approach Pilot Test Report

Quarterly Self Monitoring Reports, and NJPDES Discharge Monitoring Reports Comprehensive Site-Wide 2.5 Year Groundwater Quality Monitoring Reports

TC-32 & VE-2 Soil Remedial Program Report

3/1996

9/1988

9/1989

7/1994

10/1999 to 4/2004

11/2004

912005

11/2006

1/2008

8/2009

3/20II

3/20II

7/2011

6/2011

6/20II

1212002 - 10/13

12/2002 - 10/13

2/2013

26

Table 4 - 2013 and current Groundwater Mom•tonn1 proe:ram Sam-'' ·-F...,aeorr

MoallllJ Gn1Wldwater Quarterly Grcnmdwllter Sem>Amnlal Groaadwater Samp6ag Roaad Sampliq Samphag Sampling

Indiealor*** & NataniAaalylical Panmeten: VOCllSVOCI Incbcator Panmeten*** Attenuation Panmeten*****

Well C6Wellsl 119Wtlfs) f48Wellsl

EW-1 x EW-2 x EW-3 x EW-4 x EW-5 x EW~ x EW-7 x EP-1 EP-2 x EP-3 TC-3 x rcq x TC-12 TC-14* x TC-18* x TC-19 x TC-20* x TC-21* x x TC-22 x x TC-23 x TC-24R. TC-25 x x x TC-28 TC-29 x x TC-30 x x TC-31 x TC-32R. •• x x x TC-33 •• x x TC-34 x TC-35* x TC-36+ x x x TC-37+ x x x IC-IB. IC-2 x IC-3 x IC-6 x IC0 7* x x BC-2 Bc-s• x BC-II BC-15* x BC-16 x BC-17* x x TK-4* TK-10 P·2 MP-3 x x MP-7 x x MP-9 MP-12 x TP-9 x x TP-12 x TP-13 x IC-8 x x IC-9 x x IC-10 x IC·ll x IC-12 x IC·13* x x JC-14 x IC.IS x x JC-16 x x

CEA Compbance Well•• Srte Low Flow Sampbng Proc:edwe to be used to collect samples ftom CEA Compbance-1ls Car analyaes.

Tiie 2.5-Year cmmt Will be conducted mplace ofan annual event.••• Indicator Parameten ladmle. TCL VOCs, SVOCs, TAL mctala uamg EPA SW-846 methods; ammonia, chlonde,

lluonde, rutrate, phosphate and suliido.•••• Natani Atteaaalloa Panmeten Include sulfide, feai<: ~ ferrous mm,TOC, metabolic acids and gases,

redox poteDllai, dissolved oxygen, conducbvrty, twbtcbty, alkalmtty, pH and temperalul'O...... Natural Altemtatton Parameters Will be analyud dunng the annual or 2 S-year eveDIB only Level IV labaratmy dellVCl'lbles wtth data vabdabon uamg EPA Region Udata valtdattoa protocol& will be conducted on the annual or 2.S-year event only , Wells TC-36 and TC-37 were mstalled m May 2012 and added to the poundwater momtoruts prognua in June 2012

2.5 Year Grmmdwalel' Samphag

Indicator*** & Natani Attenuation Parametenu••

(60Wtlfsl

x x x x x x x x x x x x x x x x x x x x x x x x x x x x x x x x x x x x x

x x x x x x x x x x x x

x x x x x x x x x x x

27

FIGURES

Site Location Map Detailed Site Map Attached Groundwater Trend Charts

28

TABERNACL TOWNSHIPTUCl(ERTON R O

r,.. SHAMONG 7 ..," ><\0"'1·

0 \('° "'

.., z

0

& "' ::i 'i ~ a ~

0 i5 •EWAN SITE

' QUEBEC CT.

\ s

0

"' 0:z:

0

"' :::i.,,"' ~

<O

LlNAP[ f'ATit

FAWN Cl 0 :>000 rT

SOURCE: ROAD MAP­SHAMQNG TOWNSHIP

• REV 8/2000

!•L-~~~~~~~__J--~~~__;_~.......;.~~-"P-~--"L---'-~~~

::\FOUR NESHAMINY INT[RPLEX . SUllE JOO ENVIRONMENTAL I CONSUL TING ENGINEERS • TREVOSE PENNSYLVANIA 1905J e ~ i PRO ECT llTLE i

SITE LOCATION MAP & EWAN PROPERTY SUPERFUND SITE 0

'.;

SCAl [: DAH:. :; ~ ~COM FIVE-YEAR REVIEW 09/20131"=2000" ¥ SHAMONG TOWNSHIP

f !CURE NO.PROJECT NO~ BURLINGTON CO. NJ J 60285384 L

- --SOUM:CS ,Wol£S C ~ '5SOC:.A""n f..c °""4.\llNC ~D 1.0"" l2.01 A..-.C lZ02. B~JI( 230'. ~~Jt. ~ COUN"'I'. '·t ~.I'(; "VM~ Cl. DATO 4-- 29-10 u~~- .oACOl'5 • COJOA C~TINC CNClht£ftS. CJWw"-.c ntLC ~"'IAL -au L"" lOoOC!tAPMT OPCAAltU """fT o-.r· QN.W""1C ,..UM9Vt -oP'O- · ·. OA"El> ot-20-n SU~ CO»fl'AH'I', "iC., ~ Fl"iALASB ~ W""lC TITtD ~E:IJ."'lC>I Plt()J( - f>M ,.--~--z - DOI.*.( SW1C CA.lt ShOW'...C r"""" .S-BUIL TOPOCIW'W'I' "'ND l.OCA~ JOI NO H-00$. owe .-.o 001. DATtD 01 -13-H V.UW:0 AS"SOC.ATQ• ..C Q4t.A."111. °'IC TI!UD ·.-s-BUtl· PLAN-tft"A.' ~ Sf'r SHA.VO"i' rc.rt"''S'f!P - roa:

SUR-.ftrt"CTO.... COU...\TY,"" '°"°· °""""" "° •ll022.~-::T!,··, I - _,.,I.JN(

- wrn...... I.JN( ~ LOT.]/ - wcn..tiHD ~QW[T!Jt• - ..,...,_.. wru. ............. • __ ......- "'"""'°' ......

\ I - DUAL ~ Dl'TRACnON WllJ.

LOTJJ - UJil ~ O' 200• OlCAV4) - U'TS 0£ ?Otl DU:.AV,\"'Of\j

OICAV4"'10N D(p,.; 11 !ICS '

'

'

I '

LPTJI

o· 200' 400'

~ SCALE

SITE PLAN WITH WELL AND SOIL EXCAVATIO LOCATIONS

f'lVE-YEAR RE\/1EW EWAN PROPERTY SUPERFVND SITE

331 TUCl<ERTON ROAD SHAMONC TOWNSHIP, NEW JERSEY 05088

~COM 6026538•JUNE 2014

Ewan Property Site - Total VOC Concentrations over Time TC-30

400

350

300

-...J-C> :::i.-Cl) (.) 0 > ~-{:.

250

200

150

100

~· •

I

I I

J

50

. 0 Sep-03

•II\. I'v'

Sep-04 Sep-05

~ Sep-06

~ - ~

~ ~ ~

Sep-07

A~

Sep-08

-~

- - - -T - ~

Sep-09

- ~

T -

Sep-10

-T

....

Sep-11

- ~ - -T

Sep-12

~ --Sep-13

Date

Ewan Property Site - Total VOC Concentrations TC-30 (2008-2013)

50

45

40

35

-...J-C) 30 •

:::::s.-Cl) (.)

0 > "'-

25

20

J

II

~

15

10

5

J

I I

_....... ..... ~~~ - - ~ ~ ~ ­

~~ ·­Mar-08 Sep-08 Mar-09 Sep-09 Mar-10 Sep-10 Mar-11 Sep-11 Mar-12 Sep-12 Mar-13 Sep-13

Date

0

Ewan Property Site - Total SVOC Concentrations over Time TC-30

1,200 -...J-C> :::1.

1,000 Cl)

(.) 0 >Cl) 800

"' {:.­

600

o .._-------..---~........~----.._.,..._._...._....................._.......~..._._._._......._..::::::;;::::::..._.,~--_..:.:::;;;:....__~----~;....,...--­

sep-o3 Sep-04 Sep-05 Sep-06 Sep-07 Sep-08 Sep-09 Sep-10 Sep-11 Sep-12 Sep-13

Date

200

Ewan Property Site - Total SVOC Concentrations TC-30 (2008-2013)

180

160

140-...J-C'> ::::::i. 120-Cl)

(.)

0 > 100

ti)

ca 80 -~ 60

40

o ._~~~...-___;:.,___,._~~_...~;;;_;,~_,...~.....;.~....,....~...,_-=::::IF'-~~~.......~~~,.......~~--.,.--~~"'"""'T~......~-.-~--'

Mar-08 Sep-08 Mar-09 Sep-09 Mar-10 Sep-10 Mar-11 Sep-11 Mar-12 Sep-12 Mar-13 Sep-13

Date

Ewan Property Site - Total VOC Concentrations over Time TC-32/TC-32R

60.000 ,.....-------------------------------------­.......----.

Well abandonment and --~ soi l removal action

-..J-C) :::1.-(I)

u 0 > ti:!-{:.

40,000

30,000

20,000

Sep-00 Sep-02 Sep-04 Sep-06

Date

Sep-08 Sep-1 O Sep-12

Ewan Property Site - Total VOC Concentrations TC-32/TC-32R (2008-2013)

-..J-C'l ::1.-Cl)

0 0 > ta-~

Well abandonment and --­soil removal action

2,000

1,500

1,000

o ~........--........__._________,,...:..________...,,..:~--............;:!!:...-.......,.;....--........_,,.--.,....,___---------..-._.--,,.L.......:-,:.,...:,...~..,_...,.....,

Mar-08 Sep-08 Mar-09 Sep-09 Mar-10 Sep-10 Mar-11 Sep-11 Mar-12 Sep-12 Mar-13 Sep-13

Date

Ewan Property Site - Total SVOC Concentrations over Time TC-32/TC-32R

-...J C') -::::1.-Cl) (.) 0 >en 1a-~

Well abandonment and--~ soil removal action

2,000

1,500

1,000

o +--~---.-~~......-~--.-~~..--~--.--¥-~....--:~..........~~~~~ .....~.....,._.....,..,._.,._..llJil.._......~~-­sep-98 Sep-00 Sep-02 Sep-04 Sep-06 Sep-08 Sep-10 Sep-12

Date

200

Ewan Property Site - Total SVOC Concentrations TC-32/TC-32R (2008-2013)

Well abandonment and soil removal action

180

160

140 -...J C) -::::1. 120-en (.) 0 100>"' -"' 80

~

60

40

20

o ~~~~.,.:.................._:,i=:;=~:..,.....,......,....:;=*;::::;::::::::;..........,.....¥.-.1'"'-_,.~_..._.,......,......,.....,......,........~.....:..~::...,.......,............,._....,.1..........,._.....,.....,............,.....,.....~~

Mar-08 Sep-08 Mar-09 Sep-09 Mar-10 Sep-10 Mar-11 Sep-11 Mar-12 Sep-12 Mar-13 Sep-13

Date

Ewan Property Site - Total VOC Concentrations over Time TC-33

-...J C) - 15,000 :::::1.-<I)

0 0 > "'- 10,000 ~

0 +-~~..-~~.--~--.~~....~!L.......~~~C..::~..................~.........~...........+'1~-+4..................................... Sep-98 Sep-00 Sep-02 Sep-04 Sep-06 Sep-08 Sep-10 Sep-12

Date

Ewan Property Site - Total VOC Concentrations TC-33 (2008-2013)

Cl) (.)0 25 +-~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~--t

> "' {:. 20-

O+--,...........--.-....--,_..,..-.--.--.........--....--.--.,...........--....-.-............---.---.-.........~--.--.--.,.........................................---.-.............,z:.......-..-._......................,.....,....;;:;::..,.~......-..................::;;,.......,...........__,.......,.....,...............,,

Mar-08 Sep-08 Mar-09 Sep-09 Mar-10 Sep-10 Mar-11 Sep-11 Mar-12 Sep-12 Mar-13 Sep-13

Date

- -------- - - - - - - -

1000

900

, 800

- 700

...J-C') ::::L- 600 ' 1 Cl)

(.) 0 >"' n:s-

500 \

' ' 400

~

300

~ 200

100

0

Ewan Property Site - Total SVOC Concentrations over Time TC-33

I i " ••A.• '

~

\ \ ~ ~'', \ ~

~ ~ ~ - . . .. .... .... ... . . . .............. .... .... .... - .... ,...

Sep-98 Sep-00 Sep-02 Sep-04 Sep-06 Sep-08 Sep-10 Sep-12

Date

Ewan Property Site - Total SVOC Concentrations TC-33 (2008-2013)

10

9

8

-..J-C> :::i.-en 0 0 >"' "'-~

7

6

5

4

3

2

0 Mar-08

•(\ I \ I \. ~

Sep-08 -.

Mar-09 -. -.

Sep-09 -.

-I~

- - - j I. -­. . . . Mar-10 Sep-10

'\ - - j \ _ -. . . . ,.

Mar-11 Sep-11

'

-. Mar-12

-. -. Sep-12

-. -.. Mar-13

~

/\I \. ~

Sep-13

Date

Ewan Property Site - Total VOC Concentrations over Time TC-36

20

18

16

- 14

..J-C> ::1.- 12 Cl) (.) 0 10 > ta- 8 ~

6

4

2

0 I ~

" - ~ -- - / /\.

~ - /r

-A

I

~ ~

I -

Jun-12 Aug-12 Oct-12 Dec-12 Feb-13 Apr-13 Jun-13 Aug-13 Oct-13 Dec-13

Date

Ewan Property Site - Total SVOC Concentrations over Time TC-36

100

90

80

- 70 ...J-C) :::1. 60-en

(.) 500

>"" "'- 40

~ 30

20

10

0 Jun-12

•

-

f\ I \ I \ I \ I \

/\J \ -T ' T ' T I T

Aug-12 Oct-12 Dec-12

-T -~.

Feb-13

- -T I ~

Apr-13 -T T

Jun-13

-"

Aug-13 - -Oct-13

___. -Dec-13

Date

Ewan Property Site - Total VOC Trends over Time EW-3

5,000

4,500 0

4.000

-..J-3,500 I'I<~

C) ::1.- 3,000 ·~

en 0 0 >

2,500

"'-{!. 2,000

1,500

1,000

500

I<

~

... ~A-\

~ .~ ~ ~

~ ~ ~ - ­ ...... ........................- ­ ........... ... ... ... ..... ... ..... ... ~ - .... ..........................- .............. - ­ ~ - ~- ~- ~ -~

-~

-~

Date

Ewan Property Site - Total VOC Trends EW-3 (2008-2013)

10

9

8

-...J-C) ::::1.-Cl)

(..)

0 > "'-{:.

7

6

5

4

3 -

A2 I \ 0 Mar-08

v -Sep-08

•

/\ ~ ~

Mar-09 Sep-09

T

~

Mar-10 Sep-10

-

Mar-11

~-

Sep-11

I,J T

Mar-12

•

/""'""'­-

Sep-12 Mar-13

-

Sep-13

Date

Ewan Property Site - Total SVOC Trends over Time EW-3

60

-...J-C) 50 ::::!.-Cl) (.) 0 40>en

"' 30 -{:. 20

o ---.----..~...---.---.---.---.---.---....~...---.-........~~~,.._....................~....,.~~+-11~-e---11--........-.---4~..-....... / r/1~/ / /"/"// ~.p/ //////./~I////_,"~r11"~#""r11""_,~~~",,,_,"~r11~

Date

Ewan Property Site - Total SVOC Trends EW-3 (2008-2013)

10

9

8

7 -..J-en :::i.- 6en 0 0 > 5

"' ~-~ 4

3

2

0 -+-~4~--___,,..,.___,...,_--4.,_--4.,_--4~........--4~........~.,._~~~....~~~~........~~~.....~~~.....~~~.....~~~~~.....~~---,.........: Mar-08 Sep-08 Mar-09 Sep-09 Mar-10 Sep-10 Mar-11 Sep-11 Mar-12 Sep-12 Mar-13 Sep-13

Date