1111111111111111111111111111111111111111 Five-Year Review …

Five-Year Review Report

141540

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Cosden Chemical Coatings Corporation Superfund Site

City of Beverly

Burlington County, New Jersey

Prepared by:

United States Environment~1 Protection Agency

Region 2

New York, New York

August 2012

Table of Contents

Executive Summary ................................................................ ~ ......... : ................................................................... i

Five:. Year Review Summary Form ................................................................................................................. : ... ii

I. Introduction ......................................................................................................................................... 1

II. Site Chronology ........ ; ........................................................................................................ , ............... 2

III. Site Background ................................................................................... ; ........... : ............ ; .................... 2

IV. Remedial Actions .: ............................................................................................................................... 5

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

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

Operations and Maintenance ..................................................................................................... 9

Institutional Controls ......................... : ................................................................................... 10

V. Progress During the First Five-Year Review Period .................... ; .................................................. 10

VI. Five-Year Review Process ............................................................................................................... 11

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

Community Involvement ...................................................... ,' ......... : ...................................... 11

Document Review ................................................................................................................. 11

Data Review ...... ; ................. : .................................................................................................. 11

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

Interviews / Meetings .............................................................................................................. 14'

VII. Technical Assessment ....................................................................................................................... 14

Question A: Is the remedy functioning as intended by the decision documents .... : ............. 14 . .

Question B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action objectives used at the time of the remedy still valid? ................................................. 15

Question C: Has any other information come to light that could call into question the protectiveness of the remedy? .................... ; .......................................................................... 16

Technical Assessment Summary ........................................................................................... 16

VIII. Issues ........................................................................................ : ......................................... : .............. 16

IX. Recommendations and Follow-Up Actions ..................................................................................... 16

X. Protectiveness Statement. ................................. : ............................................................................... 17

XI. ·Next Review .................................... : ........................................................................ : ....................... 17

Table 1

Table 2

Table 3

Figure 1

Figure 2

Figure 3

Tables / Figures

List of Acronyms

Chronology of Site Events

List of Documents Reviewed

Cosden Historical Groundwater Sampling Data

On-Site Monitoring Wells

Off-Site Monitoring Wells

Site Photo

BGS BTEX CEAlWRA CERCLA

CLP COC CQCC DCE DD DO EMP EPA GQC GWETS IDW LNAPL LTM LTO LTRA MNA MSIMSD Mw' NCP NJDEP NJSPC O&F OU PCB PCMP PPE ppm ppb PGC QA QC Redox RI RW SARA SSHP SVE TBD

LIST OF ACRONYMS I·

Below Ground Surface Benzene, Toluene, Ethylbenzene, Xylene Classification Exception Area/Well Restriction Area Comprehensive Environmental Response, Compensation, and Liability Act Contract Laboratory Program Contaminants of Concern Chemical Quality Control Coordinator Dichloroethylene Decision Document Dissolved Oxygen Effectiveness Monitoring Plan " Environmental Protection Agency Groundwater Quality Criteria Groundwater Extraction and Treatment System Investigati ve-Deri ved Waste Light Non-Aqueous Phase Liquid Long-Tenn Monitoring Long-Tenn Operation Long Tenn Response Action Monitored Natural Attenuation Matrix Spike/Matrix Spike Duplicate Monitoring Well National Contingency Plan New Jersey Department of Environmental Protection New Jersey State Plane Coordinates Operational & Functional Operable Unit Polychlorinated Biphenyls Post Construction Monitoring Program Personal Protective Equipment part per million part per billion Predominant Groundwater Contaminants Quality Assurance Quality Control Oxidation-Reduction Potential Remedial Investigation Recovery Well Superfund Amendments and Reauthorization Act Site Safety and Health Plan Soil Vapor Extraction To Be Detennined

TCE TCL TCLP' TOC TSS USACE VC

Trichloroethylene Target Compound List Toxicity Characteristic Leaching Procedure Total Organic Carbon Total Suspended Solids United States Army Corps of Engineers Vinyl Chloride

Executive Summary

This first Five-Year Review for the Cosden Chemical Coatings Corporation Superfund Sity, located in the City of Beverly, Burlington County, New Jersey, has been completed.

The Site is being addressed in one Operable Unit (OU) based on a Record of Decision issued on September 24, 1992 and modified by an Explanation of Significant Differences (ESD) on September 30, 1998. The 1992 Record of Decision (ROD) addressed the Site in three distinct phases or components, namely: Decontamination and demolition of the building on the Site with disposal ofthe building debris at an appropriate off-site facility, in-situ stabilization of soil contaminated with inorganic compounds and polychlorinated biphenyls, and, extraction of. contaminated groundwater with on-site treatment and recharge to the underlying aquifer. The ESD modified the soil remedy to excavation with off-site treatment and disposal for inorganiccontaminated soils and selected soil vapor extraction for shallow soils contaminated with volatile organic compounds.

This is a policy review. The trigger for this review was the completion of the preliminary closeout report signed in September 2007. The assessment of this five-year review found that the OU-I remedy as modified by the September 1998 ESD is expected upon completion to be . protective of human health and the environment, and in the interim, exposure pathways that could result in unacceptable risks are being controlled. All immediate threats at the Site have been addressed, and the remedy is expected to be fully protective of human health and the environment after the groundwater cleanup goals are achieved. Currently, there are no exposure pathways that could result in unacceptable risks and IJ.one are expected as long as the Site is properly maintained or until the aquifer itself is restored to cleanup goals.

Five-Year Review Summary Form

SITE IDENTIFICATION

Site Name: COSDEN CHEMICAL COATINGS CORPORATION

EPA ID: NJD000565531

2. City/County: BEVERLY 1 BURLINGTON

NPL Status: FINAL.

Multiple OUs?

No

Lead agency: EPA.

Has the site achieved construction completion? YES.

REVIEW STATUS

If "Other Federal Agency" was selected above, enter Agency name:

Author name (Federal or State Project Manager): Edward J. Finnerty.

Author affiliation: U.S. EPA, Region 2

Review period: 09/15/2007 - 713012012

Date of site inspection: 3/26/12

Type of review: Policy.

Review number: 1.

Triggering action date: 09/24/2007

Due date (five years after triggering action date): 912412012

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I

Five-Year Review Summary Form (continued)

The table below is for the purpose of the summary form and associated data entry and does not replace the two tables required in Section VIII and IX by the FYR guidance. Instead, data entry in this section should match information in Section VII and IX of the FYR report. .

IssueslRecommendations

OU(s) without Issues/Recommendations Identified in the Five-Year Review:

Issues and Recommendations Identified in the Five-Year Review:

OU(s}: Issue Category: No Issues Sitewide

Issue Remediation Recommendation:

Affect Current Affect Future Implementing Oversight Milestone Date Protectiven Protectiven Party Party ess ess

Enter date.

To add additional issues/recommendations here, copy and paste the above table as many times as necessary to document all issues/recommendations identified in the FYR report.

Protective ness Stateme nt( s)

Ihclude each individual au protectiveness determination and statement. If you need to add more protectiveness determinations and statements for additional a Us, copy and paste the table below as many times as necessary to complete for each au evaluated in the FYR report.

111

Operable Unit: 01

Protectiveness Statement:

Protectiveness Determination: Protective

Addendum Due Date (if applicable):

Click here to enter date.

The remedies at the Cosden Chemi~al Coating Site .are expected to be protective of human health and the environment upon completion, and in the interim, exposure pathways that could result in unacceptable risks are being controlled.

Sitewide Protectiveness Statement (if applicable)

For sites that have achieved construction completion, enter a site wide protectiveness determination and statement.

Protectiveness Determination: Addendum Due Date (if applicable): Protective Click here to enter date.

Protectiveness Statement:

The remedies at the Cosden Chemical Coating Site are expected to be protective of human health and the environment upon completion, and in the interim, exposure pathways that could result in unacceptable risks are being controlled.

IV

I. Introduction

This first Five-Year Review for the Cosden ChemiCal Coatings Superfund Site, located in the City of Beverly, Burlington County, New Jersey, was conducted by the Environmental Protection Agency (EPA) Remedial Project Manager (RPM), Edward Finnerty in accordance with the Comprehensive Five-Year Review Guidance, OSWER Directive 9355.7-03B-P (June 2001) and the updated Five-Year Review Summary Form, OSWER-9200.2-105 (December 2011). The purpose of five-year reviews is to ensure that sites remain protective of public health and the environment and site remedies function as designed. This document will become part of the Site file.

The 1992 Record of Decision (ROD) addressed the Site in three distinct phases or components:

Decontamination and demolition of the building on the Site with disposal of the building debris at an appropriate off-site facility;

In-situ stabilization of approximately 8,000 cubic yards of soil contaminated with inorganic compounds and polychlorinated biphenyls;

Extraction of contaminated groundwater with on-site treatment and recharge to the underlying aquifer;

A remedial action construction contract for decontamination, demolition and disposal of all onsite structures, equipment and debris at an appropriate off-site facility was awarded in May 1995 .. That work was completed in January 1996. A pre-design investigation related to the soil r~medy revealed that the contamination was widely scattered throughout the Site which would make insitu treatment more costly and less effective than localized excavation with off-site treatment and disposal. An Explanation of Significant Differences (ESD) was issued in September 1998 to change the soil remedy to excavation with off-site treatment and disposal. The design of the soil remedy was completed in June 1999. Field work for the soil cleanup began in June and was progressing well when the period of performance for th~t contractor expired in December 1999. Work resumed under a: new contract with the last of the excavation/off-site disposal effort taking place in January 2002 and the final backfilling/landscaping effort completed in March 2002. The design of the groundwater remedy, which included an extensive hydrogeologic investigation, took place over several years culminating in the approval of the 100% design in September 2005.

In accordance with Section 1.2.2 of the five-year review guidance, this first five-year review and all subsequent five-year reviews for this Site will be a matter of policy rather than a statutory requirement. Upon completion ofthe groundwater remedy, it is expected that the Site will no longer have waste in place above levels that allow for unrestricted use and unlimited exposure. The trigger for this first five year review was the signature of the Preliminary Close-Out Report

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completed on September 24, 2007.

In accordance with the Section 1.3.3 of the five-year review guidance, a subsequent five-year review is required every five years. The trigger for the second five-year review will be the completion of this first five-year review which is expected to be in August 30 2012.

II. Site Chronology

Table 1 (attached) summarizes the site-related events from discovery up to this first five-year reVIew.

III. Site Background

Site Location and Description

The Cosden Chemical Coatings Corporation Superfund Site (the Site) is located in the southeastern comer of the City of Beverly in Burlington County, New Jersey. The Site is at the intersection of Manor Road and Cherry Street within a residential area of Beverly. It is bounded on the north and east by residential streets, on the south by Conrail tracks and farmland, and on the. west by undeveloped land. The nearest residence is approximately 300 feet to the north of the Site. The Beverly Elementary School is located 0.2 mile to the northeast. The neighboring area is suburban with some light industry. The Delaware River is approximately 4,000 feet to the north, and Rancocas Creek approximately 1.5 miles to the southwest of the Site. Population within a one-mile radius ofthe Site is approximately 800 people.

The Site encompasses 6.7 acres and originally consisted of a single process building situated in . the eastern part of the property, with a concrete platform used as a drum staging area located to the west of the process building. The western two-thirds of the property were undeveloped and heavily vegetated. .

Site Geology and Hydrology

The Site is located in the Atlantic Coastal Plain physiographic province of southern New Jersey. Unconsolidated sediments in the shallow subsurface soil at the Site are alluvial deposits consisting mainly of sand and gravel with minor amounts of clay. The Potomac-RaritanMagothy (PRM) aquifer is the primary aquifer in the area of the Site and a significant source of municipal water for the region. This regional aquifer system is composed of three sandy aquifers (designated Lower, Middle, and Upper) which are separated by intervening confining units

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composed of silt and clay. The Upper PRM aquifer is not present at the Site. The contaminated aquifer at the Site is the Middle PRM aquifer.

Under current condition, regional groundwater flow in the area of the Site is to the northnortheast towards the Delaware River. It was observed that the regional groundwater flow has not significantly changed since the municipal well has stopped pumping. The Delaware River is the major surface water feature located approximately 4,000 feet north ofthe Site and is classified as a Class IIa aquifer (a potential drinking water supply).

The projected 100-year flood of the Delaware River is expected to extend no closer than 3,000 feet north of the Site. The closest distance that the 500-year flood is expected to occur is approximately 1,900 feet to the north.

Static groundwater levels collected in September 2011 during the semi-annual groundwater sampling event indicated the water table was located approximately 13 feet below the ground surface on the Site property. An EPA well survey conducted in May 1991 found no private wells used for drinking water in the vicinity of the Site. Two public supply wells owned and operated by New Jersey-American Water Company (Wells No. 15 and 16) are located approximately 3,200 feet north of the Site but are no longer in use (Figure 2).

Land and Resource Use

The Site encompasses 6.7 acres and when the ROD was issued, the property consisted of a single , process building situated in the eastern part of the property; a concrete platform that was used as

a drum staging area was west of the process building. The western two-thirds of the property were undeveloped and heavily vegetated. Currently, there are the groundwater treatment and soil vapor extraction buildings in the eastern portion of the property as well as recovery wells, infiltration basins and SVE ports. The western portion is park-like in appearance. In the ' immediate vicinity of the Site the area is suburban with some light industry.

The City of Beverly is the residential community located nearest to the Site. The land to the . north, east and west of the Site is largely residential. The area to the south is bounded by a light rail line and properties occupied by commercial or light industrial facilities.

A New Jersey-American Water Company municipal water system serves the City of Beverly which accounts for approximately 2,600 residential users. General land use and drinking water sources in the vicinity of the Site have not changed since the signing of the groundwater and source control RODs. Currently, the Site is surrounded by a chain-link fence with only authorized access. The municipal authorities are in the process of determining the best use/reuse of the property when the enviro~ental goals are met. '

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History of Contamination

Cosden Chemical Coatings Corporation was a paint formulation and manufacturing facility which produced coatings for industrial applications. In the manufacturing process, pigments were mixed with resins and solvents in both ball and sand mills. The material was then placed into a mixing tank where other ingredients were added to produce the final coating products. Mixing tanks were then washed out with solvents, and the rinsate was transferred to drums. Organic solvents used in the manufacturing process were recycled until 1974. After 1974, drums containing spent solvents were stored on-site; some of these drums leaked onto the ground causing soil and groundwater contamination. Fresh solvents were stored in underground tanks, which may have leaked.

Initial Response

A grass fire that occurred at the Site on April 22, 1980 prompted the Burlington County Department of Public Safety to report the Site conditions to the New Jersey Department of Environmental Protection (NJDEP). Subsequent visits by the NJDEP revealed the presence of surface spills, and several hundred unsecured drums. Various court actions and negotiations undertak~n by NJDEP against Cosden Chemical Coatings Corporation resulted in a judicial consent order on February 5, 1985 that ordered Cosden Chemical Coatings Corporation to clean up the Site. Cosden Chemical Coatings Corporation initiated the cleanup in February 1985, but abandoned cleanup efforts after 88 of 695 drums were removed. In January 1986, NJDEP then undertook an emergency removal of the drummed material, and cleanup of surface spills around the drum storage areas.

The Site was placed on the National Priorities List (NPL) in July 1987. On December 17, 1987, EP A issued a Special Notice Letter to Mr. Louis Oller, President of Cosden Chemical Coatings Corporation, informing him of his potential liability under CERCLA, and provided him the opportunity to undertake or finance the Remedial Investigation (RI) and Feasibility Study (FS). No response was received. On July 29, 1992, EPA issued General Notice Letters to the Cosden Chemical Coatings Corporation and to Mr. Louis Oller, President, Cosden Chemical Coatings Corporation, informing them of their potential liability, providing them the opportunity to comment on the Proposed Plan for the Site, and encouraging them to either finance or voluntarily undertake the remediation at the Site. No response was received by EPA. Paint manufacturing continued on a small scale until May 1989, during which time additional drums accumulated on Site. The plant owner ceased operations in May 1989. In June 1989, EPA initiated emergency cleanup activities at the Site by constructing a fence around areas of soil contamination; and began removing the remaining drums, paint cans, pigment bags, mixing tanks, and underground storage tank contents. On May 28, 1990, as the removal action was nearly completed, a fire occurred inside the process building which consumed a majority of the building. On May 31, 1990, the building was condemned by the Beverly City building inspector.

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Basis for Taking Action

Soon after the Site was placed on the NPL, EPA selected a contractor, Ebasco Services Inc. to conduct a remedial investigation and feasibility study (RIIFS). As a result ofthe risk assessment

, conducted as a part of the, remedial investigation, ingestion of contaminated groundwater in a future use scenario indicated that an elevated risk to human health existed since the hazard indices were estimated to be 1.6 for children, and 1.1 for adults. In addition, the concentrations of the following contaminants were found above promulgated Federal and/or State Maximum Contaminant Levels (MCLs): toluene, xylene, trichloroethene, chromium, and lead. Both lead and polychlorinated biphenyls (PCBs) were present in Site soils at unacceptable concentrations. Lead in soil was present in the soil at a maximum concentration of 6580 parts per million (ppm), and on and in the building at percentage levels (greater than 10,000 ppm). PCBs were detected in soil at concentrations up to 120 parts per million.

The environmental evaluation provides a qualitative assessment of the actual or potential impacts associated with the Site on plants and animals (other than people or domesticated species). The primary objectives of this assessment are to identify the ecosystems, habitats, and populations likely to be found at the Site and to characterize the contaminants, exposure routes and potential impacts on the identified environmental components. There were no endangered species, . sensitive ecosystems, or sensitive habitats identified on the Site. The environmental assessment concluded that adverse impacts to on-site plants and animals from on-site contamination is not likely.

IV. Remedial Actions

Remedy Selection

Based on that study, a ROD was prepared, opened to public comment, and signed on September 30, 1992. The remedial action objectives in the 1992 ROD are:

• Prevent exposure to contaminant sources that present a significant human health risk and;

• Restore contaminated groundwater to ,drinking water standards.

The major components of the selected remedy include:

• Decontamination and demolition of the building on the Site with disposal of the building debris at an appropriate off-site facility;

• In-situ stabilization of soil contaminated with inorganic compounds and PCBs;

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• Extraction of contaminated groundwater with on-site treatment and recharge to the underlying aquifer;

The proposed contaminated soil remedy was reviewed during the design stage. A pre-design investigation related to this component uncovered conditions which led EPA to issue an Explanation of Significant Differences (ESD) in September 1998. This resulted in the 1992 ROD being modified as follows:

• In-situ treatment of contaminated soils was modified to excavation with off- site treatment (if necessary) and disposal;

• Construction of a soil vapor extraction (SVE) system to address the remaining contaminants present in soil above the water table (the vadose zone); and,

• The lead cleanup goal for soils was modified from 500 ppm to 400 ppm.

Remedy Implementation

Building Demolition

The first component of the design called for the decontamination, demolition, and disposal of the process building and equipment. This portion of the remedy was handled by the Philadelphia District of the North Atlantic Division of the U.S. Army Corps of Engineers (USACE). The demolition was conducted by CAn, Inc. from Hoboken, NJ under contract to the USACE.

This work included demolition of the former process building that was situated in the central section of the property. It occupied approximately 15,000 square feet (ft2) and contained mixing rooms, tank rooms, staging areas, a boiler room, lockers, a laboratory, and offices.

This first component was initiated in July 1995 and completed in January 1996. All structures _ were decontaminated and demolished. All demolition debris including asbestos was disposed of off-site.

Contaminated Soils Remediation

The contaminated soils remediation was conducted by the EPA Region 2 Removal Action Branch with technical support provided by EPA's Environmental Response Team (ERT). ERT, along with its private contractor REAC (Respon'se Engineering and Analytical Contract), performed an extensive screening effort at the Site employing XRF (x-ray fluorescence) technology to identify the grid nodes, concentration and depth of inorganic contamination (principally lead and chromium). The data were recorded on design drawings along with all the other RI and pre-design information to define the areal extent and depth of the excavation.

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The soil cleanup was conducted to meet the NJDEP Residential Direct Contact Soil Cleanup Criteria (RDCSCC). For PCBs, the soil cleanup objective was the federal residential cleanup criterion of 1 ppm. However, post-excavation sampling indicated that the soil removal ultimately met NJDEP's more stringent RDCSCC level of 0.49 ppm for PCBs. Each time a pocket of contamination was encountered, the process of pre-excavation sampling, excavation, and post-excavation sampling would begin again. The excavated areas and maximum excavated depths are: the Eastern Wooded Area (two feet below grade), the Former Pad Area (after it had been removed under the soil remedy (two feet below grade), the Deep Volatile Organic Compounds (VOC) Pit (16 feet below grade), the Former Stockpile Area (one foot below grade), the Hexavalent Chromium Pit (four feet below grade), the inorganic contamination grids (four feet below grade), the PCB grids (six feet below grade), the Buried Drum and Geophysical Survey Area (various test pit depths), and the Final VOC Excavation Area (11 feet below grade). The NJDEP RDCSCC levels were ultimately achieved by expanding the excavation in places where post-excavation sample results exceeded RDSCC(s). The soil remediation was accomplished in phases from Jun'e 1999 to March 2002. All contaminated soils, underground storage tanks (USTs), and residual liquids were sent off-site for disposal, and/or treatment, if necessary. A Remedial Action Report, dated September 2003, was submitted to Region II .by the REAC contractor documenting in detail the cleanup undertaken fO,r this component which generated and disposed of 13,000 tons of contaminated solid waste and debris, four USTs, plus 2,600 gallons of liquid waste. Therefore, the Site soils do not have contaminants remaining above the unlimited use/unrestricted exposure levels, nor is a fence required to restrict access to the property.

VOC Soils and Groundwater Remediation

As noted above, EPA entered into an Interagency Agreement (lAG) with USACE-NAB . (Baltimore) to provide the overall design for the Cosden RA, the biggest element of which was the groundwater treatment facility. The remedial design of that component is based upon extensive on-site and off-site groundwater sampling conducted by URS during an extended predesign phase. The volume and contaminant concentration of the groundwater to be treated were expected to be reduced due to the prior excavation of contaminated soil, while the proposed use of an SVE system was expected to further reduce the expected life-cycle costs of the new water treatment system itself. As stated in the 1992 ROD, the goal of the treatment facility is torestore groundwater to drinking water quality standards which are State and/or federal MCLs.

Based on a pilot study conducted during the design, there was a concern that the high water table might restrict the amount of treated groundwater that could be reinjected into the aquifer. However, after careful analysis, it was determined that the treated groundwater volume could be safely handled if the infiltration trenches were placed far enough apart. The 6.7 -acre Cosden Site could in fact accommodate this requirement and the two infiltration galleries were placed 2,000 feet apart, one close to the eastern end the Site, i.e., near Manor Road, and the other near the western end of the Site. .

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Under an Interagency Agreement with US ACE-NAP (Philadelphia), a request for proposals went out in December 2005 to pre-qualified contractors for the construction of the treatment facility at Cosden. When the proposals were received and evaluated, the low bidder was Environmental Chemical Corporation (ECC), and on March 1 st 2006, the remedial action contract was awarded to ECC.

In July 2006, ECC's mobilization took place at Cosden to begin the construction of a highly automated treatment facility that could extract up to 95 gallons per minute of contaminated groundwater. The extracted contaminated groundwater passes through four down-flow media filters before entering two large liquid-phase granular activated carbon (LPGAC) units, in series. The clean effluent is returned to the aquifer via reinjection trenches at both ends of the property. The process building also houses an inclined plate separator and a filter press to precipitate and concentrate the solids. In addition to the water treatment system, there are three banks of buried SVE wells and collection lines, operated in sequence, that allow contaminated vapors to be extracted from the vadose zone and then treated by passing them through vapor phase granulated activated carbon which is housed in a separate, adjacent building. A fence was installed around the treatment facilities to provide security and prevent trespassing.

Data collected to date indicate that the treatment system is efficiently removing contaminants from the groundwater prior to on-site reinjection. The primary contaminants of concern, as noted in the 1992 ROD and again in the September 2006 New Jersey Pollutant Discharge Elimination System (NJPDES) Permit Equivalent for Cosden, are ethylbenzene, toluene, xylene and trichloroethylene (TCE). The treatment system will reduce levels of any contaminants present to meet the New Jersey Groundwater Quality Criteria Class IIa standards before the groundwater is reinjected back into the aquifer. .

On July 25,2007, a pre-final inspection. of the groundwater treatment and SVE systems was conducted by EPA, US ACE and the NJDEP. No major deficiencies were identified; however, a punch list of outstanding items was developed. These items were completed by the end of September 2007.

Based upon the results of the pre-final inspection, EPA determined that the construction activity for the entire Site had been completed, that the remedy was implemented consistent with the ROD, as modified by the ESD, and that the contractor had constructed the remedy in accordance with the ~ plans and specifications, as modified by the as-built drawings.

During the Remedial Investigation, considerable concern was placed on the off-site groundwater because there were two large public supply wells located downgradient on the bank of the Delaware River. Though the off-site groundwater contamination concentrations were moderate and there were no other private wells in area, the State and the EPA thought it prudent to carefully monitor the many on-site and off-site wells installed during the design. Data from these wells indicated that natural attenuation was taking place, and in conjunction with the

8

soUrce removal performed under the ROD and ESD, it was determined that, over time, the offsite plume would be remediated. Further, the downgradient receptors, the two wells owned by New Jersey American Water, were closed more than ten years ago when the company opened a much bigger potable water plant further down on the Delaware River. Despite the elimination of this primary risk, EPA continues to adhere to the extensive monitoring program noted in the State's September 2006 NJPDES Permit Equivalent.

Operations and Maintenance

The annual operation and maintenance costs for the contractor, plus the USACE oversight costs, are currently l}lIlI1ing about $1.2 million/year under the long-term response action.

The operation and maintenance requirements and activities are specified in the Cosden Chemical Site October 11,2007, Operation and Maintenance Plan for the Groundwater Extraction and Treatment System and Soil Vapor Extraction System. The manual provides that for the groundwater treatment plant's operational duration, the operator is responsible for the inspection, preventive maintenance, and unscheduled maintenance of all components of the groundwater, extraction, treatment, and discharge systems. The operator is responsible for monitoring treatment system performance, permit compliance, and remedial progress. The operator maintains and submits a Monthly Operating Log which includes but is not limited to: inventory, Site visitors, waste disposal quantities, operating conditions, maintenance, recommendations, and an inspection report. During the system operations, the largest problem has been fouling caused by iron that naturally occurs in groundwater in the area. The contractor has taken actions such as variation in treatment processes to optimize performance and pump restoration to enhance efficiency. There have been no reported compliance issues with the NJDEP permit equivaiency for the discharge of treated groundwater.

The NJDEP permit equivalent requires semi-annual groundwater quality monitoring of monitoring wells MW-l, MW-3, MW-4, MW-9S, PZ-llS and EW-l and bi-monthly treatment system operation samples. Also, groundwater levels are measured quarterly at approximately 28 wells to determine the direction of groundwater flow. Under pumping conditions, on-property groundwater flows towards the recovery wells (RW-l and RW-2) while off- property groundwater flows to the north-northeast towards the Delaware River.

In addition, since the inception of the groundwater extraction and treatment system in 2009, groundwater quality is sampled at seven on-property and seven off-property monitoring wells semi-annually or when deemed necessary to assess changes to the system (see Figures 1 and 2 for well locations). Groundwater samples are analyzed for volatile organic compounds (VOCs) by EPA Method 8260B plus Chromium [total], and Lead. The analytical data are evaluated and compared to monitoring results before system start-up, as well as to EPA's MCLs and NJDEP Ground Water Quality Criteria (GWQC). Currently no monitoring ofSVE system data occurs since the system is not operating.

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Institutional Controls

Although the 1992 ROD indicated that a deed notice restricting future land use would be required, the 1998 ESD indicates that attainment of soil cleanup objectives with the modified contaminated soils remedy will eliminate the need for a deed restriction. The groundwater treatment plant has been operational and functional since 2009. Currently, no Classification Exception Area (CEA) groundwater well restriction institutional control is required by the 1992 ROD or the 1998 ESD. The current data indicate that the contaminated groundwater is contained within the Cosden property boundaries. The property is fenced; the groundwater treatment system is located in this area and a plant operator is present on average five days' per week making it highly improbable that installation of a potable well could occur. Therefore, no CEA is currently planned, however, if monitoring data indicates that the plume has migrated off-site, EPA will implement a CEA and incorporate it into a decision document.

V. Progress During the First Five-Year Review Period

This is the first five-year review for the Site.

Since the preliminary close-out report was signed, the following major activities have commenced.

Based on the Remedial Investigation and pilot studies, two areas of the Site which demonstrated the highe.st groundwater contaminant concentrations of the contaminants of concern (COCs) were selected for the placement of two extraction wells to supply the raw feed for the new treatment facility. The 100% design called for a small, automated facility that would ideally reduce the staff needed to operate the plant and thus its long-term life-cycle costs. The innovative part of the design called for the use of four multi-media filters (MMF) rather than a large clarifier that was the industry standard for many years. To further speed up the period of remediation, an extensive SVE system was added to the groundwater system. The system consisted of three banks of five wells, each which would normally be operated in sequence. The use of three banks was designed to provide the broadest areal extent or coverage for the SVE system. However, the shallow vadose zone proved to be a limitation in the amount of vapor that could extracted with this system.

Since Cosden is located next to a residential area and there were low levels of COCs detected in the off-site groundwater, the design contractor did a very extensive vapor intrusion investigation at the closest homes. However, they found no evidence of vapor intrusion at any of the tested homes.

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vI. Five-Year Review Process

Administrative Components

The five-year review team included Edward J. Finnerty (RPM), Michael Scorca and Roberta McIntyre (Hydro-geologists), and Charles Nace (Risk Assessor) all of the EPA, plus Francisco Barba, Reuben Wade, Daniel Sirkis, and Joseph Loeper of the USACE- Philadelphia District.

Community Involvement

Oli May 25,2012, the EPA Community Involvement Coordinator for the Cosden Chemical Site, published a notice in the Burlington County Times, the area newspaper, notifying the community of the initiation of the five-year review process. The notice indicated that upon completion of the five-year review, the document would be available to the public at both the Beverly Municipal Building and the Burlington County Library. In addition, the notice included both the name and phone number of the CIC contact as well as the RPMs name, address and telephone numbers for questions related to the five-year review process or the Cosden Chemical Site in general.

Document Review

The documents, data, and information which were reviewed in completing this First Five-Year Review are summarized in Table 2 (attached).

Data Review

Groundwater

Groundwater levels are measured quarterly at approximately 28 wells to determine the direction of groundwater flow. Under pumping conditions, on-property groundwater flows towards the , recovery wells (RW-l and RW-2) while off- property groundwater flows to the north-northeast towards the Delaware River. '

Since the inception of the groundwater extraction and treatment system in 2009, groundwater quality is sampled at seven on-property and seven off-property monitoring wells semi-annually or when deemed necessary to assess changes to the system (see Figures 1 and 2 for well

11

locations). Groundwater samples are analyzed for volatile organic compounds (VOCs) by EPA -Method 8260B plus Chromium [total], and Lead. The analytical data are evaluated and compared to monitoring results before system start-up, as well as to EPA's MCLs and NJDEP Grolind Water Quality Criteria (GWQC). '

Groundwater COCs addressed in the ROD (and their GWQC) are Toluene (1,000 micrograms per liter [~g/L] ), TCE (1 ~g/L), Ethylbenzene (700 ~g/L), and Total Xylenes (44 ~g/L).

A review of the historical gro,undwater sample data for the monitoring wells indicates a trend of significant reduction in the VOC concentrations (Table 3).

VOC concentrations in on-property monitoring well MW-l increased since its initial sampling in 1988 to as high as 84,000 ~g/L for Toluene, 99 ~g/L for TCE, 18,000 ~g/L for Ethylbenzene, and 84,000 ~g/L for Tqtal Xylenes in February 2008. Following the start-up and continued operation of the groundwater treatment system in 2009, concentrations have declined significantly, although they remain high. Concentrations at MW-l Were 43 Ilg/L for Toluene, 18 Ilg/L for TCE, 8,300 Ilg/L for Ethylbenzene, and 9,300 Ilg/L for Total Xylene in September 2011. Based on the most recent sampling data, MW -1 appears to be the only well with high concentrations of COCs, likely due to localized residual contamination. This well will continue to be monitored over the next several sampling periods to evaluate the ongoing effectiveness of the pump and treat system, to confirm a downward trend of concentrations, and to assess the performance of the pump and treat to address the localized residual contamination.

Another on-property monitoring well, MW-9S, reported its historically high concentrations of Toluene (2,100 Ilg/L), TCE (35 Ilg/L), Ethylbenzene (28,000 Ilg/L), and Total Xylenes (127,000 ~g/L) in February 2008; however, all VOC concentrations have fallen below EPA's MCLs and NJDEP GWQC during the September 2011 groundwater sampling round, with the exception of TCE at 1.8 Ilg/L, which is just slightly above the GWQC of I Ilg/L.

- Well MW-OS-7D, about 260 feet north of the property, is the off-property well that historically has had the highest VOC concentrations. After concentrations peaked in 2001, recent samples since 2008 have had significantly lower concentrations;

Groundwater samples from all other monitoring wells oh- and off-property (Figures 1 and 2 and Table 3) were below the GWQC for all analytes of concern during the September 2011 sampling round.

Pump and Treat System

Currently, the two Cosden ~xtraction wells, RW-l and RW-2, pump an average of93 gallons per minute (gpm), very close to the design rate of95 gpm. VOC concentrations detected in the combined influent of the extraction wells have remained consistently high since the system went on-line, which supports the premise that the treatment system is capturing contaminated

12

groundwater in the source area. Additionally, the post-treatment samples collected after the Liquid Phase Granular-Activated-Carbon unit have remained below the required concentration criteria of the State Pollutant Discharge Elimination System (NJSPDES) permit for discharge to groundwater. This, along with the observed declining VOC concentrations in the on- and offproperty monitoring wells (including MW-l, MW-9S, MW-3), suggests the groundwater remedy is operating effectively and is ensuring the protectiveness of the groundwater. Optimization of the remedy could be used to adjust the system and better capture the groundwater near inonitoring well MW;..l and any residual contamination

SVE System

The Cosden SVE system includes 15 later,al intake screens installed in three separate banks identified as SVE Bank 1 , Bank 2, and Bank 3. During a demonstration in July of2007,ECC encountered difficulties operating the SVE system while drawing from well Banks 1 and 3 due to excessive entrainment of shallow groundwater leading to overloading of the condensate removal system. However, the demonstration was successfully completed for well Bank 2 which is located in the center of the remedial target area. After considerable effort to establish efficient air flow without entrainment, the system operations continued.

During the second quarter of2008, the influent contamination concentration levels were measured weekly using a photo-ionization detector (PID). PID readings initially measured Total VOC concentrations in the range of 100-300 parts per million (ppm). The Total VOC concentrations as measured by the PID instrument, began to decline throughout the rest of the year. By December 2008, PID readings consistently ranged under 100 ppm throughout the first half of2009. Several Tedlar Bag samples taken at the SVE influent in 2009, measured Total VOC concentrations under 10 ppm.

In July 2009, HydrogeologicInc. (HGL) took over the operations and maintenance. Again, the SVE influent contamination concentration levels were measured weekly and found to be consistently less than 10 (ppm) of total volatile organic compounds, as rrieasured by a calibrated photo-ionization detector. Field testing showed that of the 15 SVE wells, only well VE-5 showed any measureable readings with a calibrated PID meter. Well VE-5 consistently had a VOC concentration of approximately 100 ppm ..

The USACE requested that the SVE system be cycled off for a short period of time to evaluate the potential benefits of intermittent operation of the system, and on November 6,2009, HGL shut the system down. The system was restarted on November 11, 2009. PID monitoring results . continued to show VOC concentrations of less than 10 ppm upon restart and over the next few weeks. The USACE requested that the SVE system be turned off indefinitely, until more data was obtained. While the system was off, HGL monitored the VOC levels in the air within the 15 SVE extraction wells and proximal wells SY·Ol and SV-02. It was noted that the VOCs in'well

, VE-5 decreased over time until the results were 0 ppm on the PID.

13

On June 1,2010, the system operations ended indefinitely but will be periodically restarted especially if the water table level significantly lowers to allow continuous operations.

Site Inspection

The five-year review Site inspection was held with the five-year review team on March 26, 2012. In addition, EP A routinely evaluates the effectiveness ofthe individual unit operations by sampling the groundwater passing through the treatment units. The plant operators are present on the Site about five days a week to make sure everything is functioning smoothly and all required testing and sampling is being carried out on schedule. Similarly, the USACE is on the Site as needed during the long-term response action (LTRA) to arrange the change out ofcarbon, dispose of waste sludge, handle all visitors, as well as conduct field activities such as sampling and investigations.

Interviews / Meetings

There is daily contact between the plant operators and USACE personnel in charge of oversight. There is weekly contact between the EPA and USACE oversight in New Jersey and USACE technical- support in Kansas City, MO. as needed. There are meetings, phone calls and correspondence with the State, particularly in regard to meeting the terms of the permit equivalents specified in the State-issued NJPDES.

VII. Technical Assessment

Question A: Is the remedy functioning as intended by the decision documents

As indicated in the 1992 ROD and clarified in the 1998 ESD, the goal of the soils excavation remedy and the SVE system were to prevent exposure to inorganic and PCB contaminant sources that present a significant human health risk and to address VOC contaminant sources contributing to groundwater contamination. Upon completion, these activities would remediate soils to levels that allow for unrestricted use and unlimited exposure.

The 1992 ROD called for the excavation and off-site disposal of inorganic and PCBcontaminated soils. This activity was completed in 2002 and both the ROD and State cleanup standards have been achieved for lead, chromium and PCBs. The 1998 ESD called for SVE to address shallow soils contaminated with VOCs. The SVE system, in conjunction with the groundwater treatment system, began operation in 2009. To date, 8420 lbs ofVOCs have been

14

removed from groundwater amd 116 million gallons of contaminated groundwater have be'en treated to cleanup standards. Effluent concentrations are decreasing indicating that the system is effectively addressing soil contamination. The SVE system is currently not operating since soil vapor concentrations in the vadose zone dropped below levels requiring treatment.

As indicated in the 1992 ROD, the goal ofthe groundwater remediation is to restore groundwater to levels that would allow for unlimited use without restriction. The 1992 ROD called for a groundwater treatment system to contain the groundwater contaminant plume and to restore gro~dwater quality at the Site. The system has operated since 2009. The system is worki~g effectively to capture the source area contamination through recovery wells RW-l and RW-2. Residual groundwater contamination remains on the Site in the vicinity ofMWl. All other monitoring well sampling data for both on-site and off-site are below GWQS. Continued elevated concentrations at MW -1 could indicate a residual source still remaining in the soil in this area. It is recommended that this residual contamination be investigated. The system effluent also meets all NJPDES permitting requirements for subsurface reinjection. The facility will soon be entering the fourth year of the L TRA and functioning as intended by the decision documents.

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

Based on the Si~e visit and review of existing data, the remedial actions that were taken at the Site (i.e., soil removal and building removal) have eliminated any potential exposure pathways. The construction and operation of the pump and treat system is functioning as intended and there are no completed groundwater or vapor intrusion pathways.

Human Health - The exposure assumptions, pathways, and receptors that were used to estimate the potential risks and hazards to human health followed the standard risk assessment paradigm . in use at the time. Ingestion, dermal contact, and inhalation exposures to groundwater, surface soil and subsurface soil were evaluated for trespassers, future Site residents, and future Site workers. The exposure assumptions, pathways, and receptors are still valid. The toxicity values that were used to calculate the risks and hazards were reported in Table 4 of the 1992 ROD. Some of the toxicity values that were used in the 1992 ROD have changed; however, the changes would not impact the remedial decision that was made for the Site. The cleanup values that were used are reported in Table 7 of the 1992 ROD. These cleanup values are still valid. Based on the data that was reviewed, the remedial action objectives (RAOs) presented in the 1992 ROD were (1) prevent exposure to contaminant sources that present a significant human health risk, and (2) restore contaminated groundwater to drinking water standards. These RAOs are all still valid.

15

· Since the primary contaminants of concern at the Site are volatile organic compounds, vapor intrusion was evaluated in March 2004 by collecting vapor intrusion samples. There were no VOCs detected above EPA's screening criteria and it was determined that the vapor intrusion pathway was not complete. No other information has come to light that could call into question the protectiveness of the remedy.

Ecological Risk:.. The ecological risk assessment indicated that there were no endangered species, sensitive ecosystems, or sensitive habitats identified on the Site. The assessment concluded that adverse impacts to on-site plants and animals from on-site contamination are not likely. The assumptions used in the assessment are still valid. Soils have been remediated and the groundwater does not impact any surface water bodies. Therefore, no ecological receptors are impacted.

Question C: Has any other information come to light that could call into question the protectiveness of the remedy?

No.

Technical Assessment Summary

Based upon the results of this first five-year review, it has been determined that the extraction/treatment system are both operating within its design parameters. Access to the property and the groundwater is currently restricted, thus preventing any unacceptable exposure until final cleanup standards are achieved. Persistent elevated levels of VOCs in MWI indicate that residual source material may be present.· .

VIII. ISsues

There are no issues stemming from this five-year review.

IX. Recommendations and Follow-Up Actions·

There are no re.commendatiQns or follow up actions stemming from this five-year review.

16

X. Protectiveness Statement

The remedies at the Cosden Chemical Coating Site are expected to be protective of human health and the environment upon completion, and in the interim, exposure pathways that could result in unacceptable risks are being controlled.

XI. Next Review

The second five-year review for the Cosden Chemical Coatings Site should be completed by August 2017.

~-alter E. Mugdan, irector Dlte J

Emergency and Remedial Response Division

17

Table' 1: Chronology of Site Events

Event Date(s)

Cosden Facility Operations Closed May '87

USEPA Initiates Emergency Cleanup Activities June '87

Cosden Site Placed on NPL July '87

Remedial Investigation Work Plan Sept '88

Phase II Remedial Investigation Field Operations Plan Sept '90

Record of Decision Signed Sept '92

Cosden Facility Demolition & Removal Initiated July '95

Explanation of Significant Differences for OU-2 Sept '98

Contaminated Soil Removal Initiated June'99

Phase III Pre-Design Investigation of Natural Attenuation Mar '02

Pre-Design / Design Groundwater Investigations Fall '02-'04

Groundwater 100% Design Submitted Sept '05

USACE awards the construction contract for the groundwater/SVE facility Mar '06

USACE awards O&M contract for the startup year of the new facility May '08

USACE awards O&M contract for the base year of the L'TRA June '09

USACE awards O&M contract for the second year of the L TRA June '10

USACE awards O&M contract for the third year of the L TRA June '11

18

Table 2: Documents, Data, and Information Reviewed in Completing the first Five-Year Review

Interim Remedial Investigation Report, Ebasco Services, October 1989

Phase I Remedial Investigation Report, Ebasco Services, 1990

Phase II Remedial Investigation Results Report, Ebasco Services, June 1992

Contaminant Fate & Transport Study / Risk Assessment, Ebasco Services, June 1992

Final Feasibility Report, Ebasco Services, July 1992

Continuous Groundwater Monitoring Report, USACE Baltimore, September 1997

Site Investigation! Remedial Design Report, Roy F.Weston! REAC, April 1998

Remedial Action Report (Soil), REAC, September 2003

35% Groundwater Remedial Design Report, URS Group Inc. ,May 2004

100% Groundwater Remedial Design Report, URS Group Inc. , Sept. 2005

Semi-Annual groundwater sampling was taken and analyzed between the fall of2009 and the fall of2011by the contractor, and reviewed byUSACE and the EPA.

Similarly, the treatment plant influent and effluent was monitored during that same period to confirm that the remedy was operating effectively in accordance with the design and the O&M manual

19

MW-1 Oate 12/1/88

Volatile Organics Ethylbenzene . 8600 Total Xylenes 46000 Toluene 990 Trichloroethene cis-1 ,2-0ichloroethene 1 ,1-0ichloroethane 1,1,1-Trichloroethane

Inorganics Chromium 61 Lead 27

MW-3 Oate 12/1/88

Volatile Organics Ethylbenzene . 560 Total Xylenes 3500 Toluene 4400 Trichloroethene cis-1,2-0ichloroethene 1 ,1-0ichloroethane 1,1,1-Trichloroethane

Inorganics Chromium 20 Lead

MW-4 Oate 12/1/88

Volatile Organics Ethylbenzene NS Total Xylenes NS Toluene NS Trichloroethene NS cis-1,2-0ichloroethene NS 1 ,1-0ichloroethane NS 1,1,1-Trichloroethane NS

Inorganics Chromium NS Lead NS

NA - Not Analyzed

TABLE 3 Cosden Chemicals Historical Groundwater Sampling Data

On- and Off-site

On-Site Wells

411101 9/1/02 5/15/07 9/25/07 2/5108 2/19/08 3/12/08

16000 18000 16000 18000 20000 18000 2000 65000 65000 75000 89000· 85000 84000 9500 840 210 270 1300 1400 1700 790 53 NO 6.1 93 75 99 45 43 NA NA NA NA NA NO NA NA NA NA NA NO NA NA NA NA NA

NO NA NA NA NA NA NO NA NA NA NA NA

411101 9/1/02 5/15/07 9/25/07 2/5108 2/19/08 3/12/08

.NA 1800 6300 1800 980 440 42 NA 2000 14800 6860 1749 684 134 NA 1000 9900 33 42 32 13 NA NO NO NO NO NO NO NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA

NA NA NA NA NA NA NA NA NA NA NA NA

411101 9/1/02 5/15/07 9/25/07 2/5108 2/19/08 3/12/08

NO NS NO NO NO NO NO NO NS 1.9 NO NO NO NO NO NS NO NO NO NO NO NO NS NO NO NO NO NO NO NS NA NA NA NA NA NO NS NA NA NA NA NA NO NS NA NA NA NA NA

3.2J NS NA NA NA NA NA NO NS NA NA NA NA NA

1 of 5

7/1108 3/29/10 3/14/11 9/12/11

8600 4800 8300 34100 16400 9300

72 49 43 2.8 0.5 18 NA NA NA NA NA NA NA NA NA

NA NA NA NA NA NA

7/1108 3/29/10 3/14/11 9/12/11

NS 230 NO 0.13 NS 680 NO 0.58 NS 860 NO . 0.42 NS NO NO NO NS NA NA NA NS NA NA NA NS NA NA NA

NS NA NA NA NS NA NA NA

7/1108 3/29/10 3/14/11 9/12/11

NS NO NO NO NS NO NO NO NS NO NO NO NS NO NO NO· NS NA NA NA NS NA NA NA NS NA NA NA


ND - Non-detect NS - Not Sampled

MW-9S Oate 12/1/88


In organics Chromium NS Lead NS

MW-101 Oate 12/1/88

Volatile Organics Ethylbenzene NS Total Xylenes NS Toluene NS T rich loroethene NS cis-1,2-0ichloroethene NS 1,1-0ichloroethane NS 1,1,1-Trichloroethane NS


PZ-11S Oate 1211/88


Inorganics Chromium NS


On- and Off-site

On-Site Wells

411101 9/1/02 5/15/07 9/25/07 2/5108 2/19/08 3/12/08

NA 24000 4600 20000 25000 28000 8200 NA 120000 17200 94000 115000 127000 42500 NA 2500 57 1400 2100 2100 560 NA 92 2J NO NO 35 NO NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA

NA NA NA NA NA NA NA NA NA NA NA NA NA NA

411101 9/1/02 5/15/07 9/25/07 2/5108 2/19/08 3/12/08

NS NS NS NS NS NS NS NS NS NS NS NS NS NS NS NS NS NS NS NS NS NS NS NS NS NS NS NS NS NS NS NS NS NS NS NS NS NS NS NS NS NS NS NS NS NS NS NS NS

NS NS NS NS NS NS NS NS NS NS NS NS NS NS

4/1/01 9/1/02 5/15/07 9/25/07 2/5108 2/19/08 3/12/08

NA NS 170 23 9 110 NO NA NS 670 7.3 NO 20 NO NA NS NO NO NO NO NO NA NS NO NO NO NO NO NA NS NA NA NA NA NA NA NS NA NA NA NA NA NA NS NA NA NA NA NA

NA NS NA NA NA NA NA

2 of 5

7/1108 3/29/10 3/14/11 9/12/11

NS 1.5 180 0.43 NS 7.5 830 3.39 NS NO 1.1 NO NS NO 0.5 1.8 NS NA NA NA NS NA NA NA NS NA NA NA


7/1108 3/29/10 3/14/11 9/12/11

NS 31 NS NS NS 29.1 NS NS NS NO NS NS NS 1.1 NS NS NS NA NS NS NS NA NS NS NS NA NS NS

NS NA NS NS NS NA NS NS

7/1108 3/29/10 3/14/11 9/12/11

NS NO NO NO NS NO NO 0.32 NS NO NO 0.18 NS NO NO NO NS NA NA NA NS NA NA NA NS NA NA NA

NS NA NA NA

Lead

EW-1 Oate 12/1/88

Volatile Organics Ethylbenzene NS Total Xylenes NS Toluene NS Trichloroethene NS cis-1 ,2-0ichloroethene NS 1 ,1-0ichloroethane NS 1,1,1-Trichloroethane NS


MW-OS1 Oate 12/1/88

Volatile Organics Ethylbenzene NS Total Xylenes NS Toluene NS Trichloroethene NS cis-1,2-0ichloroethene NS 1,1-0ichloroethane NS 1,1,1-Trichloroethane NS


MW-OS2 Oate 12/1/88



On- and Off-site

NA NA NA NA NA NA

On-Site Wells

411101 9/1/02 5/15/07 9/25/07 2/5108 2/19/08 3/12/08

NA NS 2200 NO NO NO NO NA NS 3819 NO NO NO NO NA NS 1.6J NO NO NO NO NA NS NO NO NO 1 NO NA NS NA NA NA NA NA NA NS NA NA NA NA NA NA NS NA NA NA NA NA

NA NS NA NA NA NA NA NA NS NA NA NA NA NA

Off-Site Wells

411101 9/1/02 5/15/07 9/25/07 2/5108 2119/08 3/12/08

NO 17 NS NS NS NS NS NO 61 NS NS NS NS NS NO 9 NS NS NS NS NS NO NO NS NS NS NS NS NO 9 NS NS NS NS NS NO 5J NS NS NS NS NS NO NO NS NS NS NS NS

NO NO NS NS NS NS NS NO NO NS NS NS NS NS

411101 9/1/02 5/15/07 9/25/07 2/5108 2/19/08 3/12/08

NO 7 NS NS NS NS NS NO 28 NS NS NS NS NS NO NO NS NS NS NS NS NO NO NS NS NS NS NS 50 16 NS NS NS NS NS 27 10 NS NS NS NS NS NO NO NS NS NS NS NS

30f5

NS NA NA NA

7/1108 3/29/10 3/14/11 9/12/11

NS NS NO 0.1J NS NS NO 0.15J NS NS NO 0.21J NS NS NO NO NS NS NA NA NS NS NA NA NS NS NA NA

NS NS NA NA NS NS NA NA

7/1108 3/29/10 3/14/11 9/12/11

NO. NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO 5.6 NA NA NA NO NA NA NA NO NA NA NA

12 NA NA NA 9.8 NA NA NA

7/1108 3/29/10 3/14/11 9/12/11

NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO. 5.3 NA NA NA NO NA NA NA NO NA NA NA


MW-OS3 Oate 12/1/88

Volatile Organics Ethylbenzene NS Total Xylenes NS Toluene NS Trichloroethene NS cis-1 ,2-0ichloroethene NS 1 ,1-0ichloroethane NS 1,1,1-Trichloroethane NS


MW-OS4 Oate 12/1/88

Volatile Organics Ethylbenzene NS Total Xylenes NS Toluene NS Trichloroethene NS cis-1,2-0ichloroethene NS 1 ,1-0ichloroethane NS. 1 ,1 ,1-Trichloroethane NS


MW-OS5 Oate 12/1/88

Volatile Organics Ethylbenzene NS Total Xylenes NS Toluene NS Trichloroethene NS cis-1,2-0ichloroethene NS 1,1-0ichloroethane .NS 1,1,1-Trichloroethane NS

NO NO


On- and Off-site

2.3J NS NS NS NS NS NO NS 'NS NS NS NS

Off-Site Wells

411101 9/1/02 5/15/07 9/25/07 2/5108 2/19/08 3/12/08

NO 10 NS NS NS .NS NS NO 43 NS NS . NS NS NS NO NO NS NS NS NS NS NO NO NS NS NS NS NS NO 16 NS NS NS NS NS NO 10 NS NS NS NS NS NO NO NS NS NS NS NS


411101 9/1/02 5/15/07 9/25/07 2/5108 2/19/08 3/12/08

NO 3J NS NS NS NS NS NO 13 NS NS· NS NS NS NO 2J NS NS NS NS NS NO 2J NS NS NS NS NS NO 3J NS NS NS NS NS NO NO NS NS NS NS NS NO NO NS NS NS NS NS


411101 9/1/02 5/15/07 9/25/07 2/5108 2/19/08 3/12/08

NO 5J NS NS NS NS NS NO 21 NS NS NS NS NS NO NO NS NS NS NS NS 3 NO NS NS NS NS NS 5 NO NS NS NS NS NS


4 of 5

6.2 NA NA NA NO NA NA NA

7/1108 3/29/10 3/14/11 9/12/11

NO NO NO NO NO' NO NO 0.16J NO NO NO 0.12J NO NO NO NO NO NA NA NA NO NA NA NA NO NA NA NA

6.1 NA NA NA 14 NA NA NA

7/1108 3/29/10 3/14/11 9/12/11

NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO 0.17J NO NA NA NA NO NA NA NA NO NA NA NA

17 NA NA NA 15 NA NA NA

7/1108 3/29/10 3/14/11 9/12/11

NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NA NA NA NO NA. NA NA NO NA NA NA

/norganics Chromium NS Lead NS

MW-OS7 Oate 1211/88

Volatile Organics Ethylbenzene NS Total Xylenes NS Toluene NS Trichloroethene NS cis-1,2-0ichloroethene NS 1,1-0ichloroethane NS 1,1,1-Trichloroethane NS


MW-OS7D Oate 12/1/88

Volatile Organics Ethylbenzene NS Total Xylenes NS Toluene NS T richloroethene NS cis-1 ,2-0ichloroethene NS 1,1-0ichloroethane NS 1,1,1-Trichloroethane NS


NO NO


On- and Off-site

NO NS NS NS NS NS NO NS NS NS NS NS

Off-Site Wells

4/1/01 9/1/02 5/15/07 9/25/07 2/5108 2/19/08 3/12/08

NO 4J NS NS NS NS NS NO 15 NS NS NS NS NS NO 2J NS NS NS NS NS NO NO NS NS NS NS NS NO NO NS NS NS NS NS NO Nd NS NS NS NS NS NO NO NS NS NS NS NS


411101 9/1/02 5/15/07 9/25/07 2/5108 2/19/08 3/12/08

1700 6 NS NS NS NS NS 7900 19 NS NS NS NS NS

7 2J NS NS NS NS NS NO NO NS NS NS NS NS NO NO NS NS NS NS NS NO NO NS NS NS NS NS NO NO NS NS NS NS NS

-NO NO NS NS NS NS NS NO NO NS NS NS NS NS

50f5


7/1108 3/29/10 3/14/11 9/12/11

NO NO NO NO NO NO NO 0.27J NO NO NO 0.22J NO NO NO NO NO NA NA NA NO NA NA NA NO NA NA NA


7/1108 3/29/10 3/14/11 9/12/11

0.76 47 NO 0.13J 15 310 NO 0.15J NO NO NO 0.50J NO NO NO NO NO NA NA NA NO NA NA NA NO NA NA NA

6.3 NA NA NA NO NA NA NA

•......

... -.. '

o MW-101 MW-9S O~ RW-2

RW-1 () OMW-1 EW-1 0

o PZ-11S MW-40

o MW-3

! DE"WARE RIVER

\ . \ ' ./

~~~q k------l m , ~ \I,.."", CO".

FIGURE 6-8

. 0 OFF-SITE MONITORING WELLS .

COSOEN SUPERFUND SITE

<>I i n1l,nH," ' 1'>~.d . 1!>/'IIO lTool".1

, ! i