2016 ANNUAL PROGRESS - upjohnnorthhaven.comESRC Construction Completion Report to USEPA and CTDEEP on June 1, 2016, which achieved an Order Major Milestone. The revised ESRC Construction

2016 ANNUAL PROGRESS REPORT

Corrective Measures Implementation at the

Pharmacia & Upjohn Company LLC Site

North Haven, Connecticut

RCRA I.D. No. CTD001168533

Submitted To: Pfizer Inc on behalf of Pharmacia & Upjohn Company LLC Submitted By: Golder Associates Inc. 200 Century Parkway, Suite C Mt. Laurel, NJ 08054 Distribution: USEPA – Region I CTDEEP Mabbett & Associates, Inc. Booz Allen Hamilton Town of North Haven Pfizer Inc Quantum Management Group, Inc. Woodard & Curran, Inc. Robinson & Cole, LLP NorthStar AECOM Brown and Caldwell TerraTherm, Inc. Vita Nuova, LLC Golder Associates Inc. January 2017 Project No. 033-6231-004

RE

PORT

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January 2017 ES-1 033-6231-004

EXECUTIVE SUMMARY

The 2016 Annual Progress Report (Annual Report) has been prepared on behalf of Pharmacia & Upjohn

Company LLC, (Pharmacia & Upjohn) for the Pharmacia & Upjohn Facility located at 41 Stiles Lane in North

Haven, Connecticut (Site or Facility). The Resource Conservation and Recovery Act (RCRA) identification

number for the Facility is CTD001168533. The Annual Report was prepared in accordance with the

Administrative Order on Consent (Order) issued to Pharmacia & Upjohn by the United States Environmental

Protection Agency (USEPA) pursuant to Section 3008(h) of RCRA. The Order (Docket Number RCRA-01-

2011-0027) was executed on March 31, 2011 and covers Corrective Measures Implementation (CMI) at

the Site.

Pfizer Inc (Pfizer) assumed responsibility for the Site on April 16, 2003 as a result of its acquisition of the

Pharmacia Corporation. Pharmacia Corporation was converted to a limited liability company (LLC) on or

about November 30, 2012 and is now known as Pharmacia LLC. Pharmacia & Upjohn, which owns and

operates the Site, continues to be a subsidiary of Pharmacia LLC. Both Pharmacia & Upjohn and Pharmacia

LLC are indirect wholly-owned subsidiaries of Pfizer. There are no active commercial or industrial activities

at the site, however, current Site use includes the operation and maintenance of the existing interim

remedial systems, including the Groundwater Treatment Facility (GWTF), and the construction and

maintenance of the final Site-wide Corrective Measures selected for the Site on September 10, 2010 by

USEPA with the concurrence of the Connecticut Department of Energy and Environmental Protection

(CTDEEP) and as specified in the Order.

Although Pfizer never operated on the property, Pfizer takes seriously its responsibility to address the

conditions at the Site in order to protect human health and the environment. Pfizer will direct activities

associated with the implementation of the Corrective Measures and compliance with the Order, including

primary interaction with USEPA, CTDEEP and the Town of North Haven. Pfizer will also build upon past

and present community outreach activities to ensure appropriate public engagement during the

implementation of the Corrective Measures. In all cases, representatives of Pfizer are acting on behalf of

Pharmacia & Upjohn, who is the Respondent to the Order.

During 2016, the CMI Team of contractors and consultants assembled by Pharmacia & Upjohn continued

designing, implementing, and maintaining the Corrective Measures in accordance with the Order. Major

activities and achievements included:

With the approval of USEPA, TerraTherm completed operation of the In Situ Thermal Remediation (ISTR) system to treat dense non-aqueous phase liquid (DNAPL) in Subarea A on February 8, 2016. Between February and May 2016, TerraTherm safely decommissioned the full-scale ISTR system. The draft DNAPL Component Construction Completion Report was submitted to USEPA and CTDEEP on September 23, 2016, which achieved an Order Major Milestone. USEPA approved the revised DNAPL Component

g:\projects\2003 projects\033-6231-004 nhaven\200 reports\210 annual rpt\2016\2016 annual rpt_0336231004_013017.docx

January 2017 ES-2 033-6231-004

Construction Completion Report on December 29, 2016, which documented the completion of DNAPL treatment in both Subarea A and Subarea B.

The East Side Remedial Components (ESRC) Team led by NorthStar submitted the draft ESRC Construction Completion Report to USEPA and CTDEEP on June 1, 2016, which achieved an Order Major Milestone. The revised ESRC Construction Completion Report was approved by USEPA, with concurrence from CTDEEP, on August 26, 2016. Members of the ESRC Team performed monitoring and maintenance activities related to the ecological enhancements and tidal wetlands mitigation areas on the eastern side of the Site throughout the year.

Woodard & Curran operated and monitored the post-ESRC groundwater extraction system (GWES), which is a final corrective measure. Based on the monitoring data collected by Golder Associates Inc., the GWES maintained hydraulic control of Unit 1 groundwater during 2016. The extracted groundwater continued to be treated at the GWTF in accordance with the Site National Pollutant Discharge Elimination System (NPDES) permit issued by CTDEEP.

Golder Associates collected groundwater monitoring samples in April and September 2016. The groundwater samples confirmed that samples of Unit 3 groundwater from locations along the Site perimeter remain below the compliance criteria.

As part of the progress towards implementation of the corrective measures, during 2016 the CMI Team has

achieved, ahead of schedule, the following Progress Goals and Major Milestones specifically defined in the

Order:

Activity Milestone Type Milestone

Date Date

Achieved Complete Full-Scale Treatment of DNAPL using ISTR

Progress Goal 12/24/2020 2/8/2016

Submit Construction Completion Report for East Side Areas

Major Milestone 3/31/2020 6/1/2016

Submit DNAPL Component Construction Completion Report

Major Milestone 3/31/2020 9/23/2016

Pfizer and the CMI Team have worked closely with USEPA and CTDEEP and the Town of North Haven

(Town) throughout the year. Progress reports were provided to USEPA, CTDEEP, and the Town on a

quarterly basis. Teleconferences were held with USEPA and CTDEEP on an approximately monthly basis

to keep the agencies apprised of project progress, to obtain agency input and conduct technical reviews,

and coordinate focused teleconferences to discuss specific technical matters. In addition, Pfizer has

involved the Town community during the project, including meeting regularly with the Citizens’ Advisory

Panel (CAP).

In general accordance with the Order, the 2016 Annual Report is divided into the following six Sections:

Section 1 describes the requirements of the Order in relation to the Annual Report and provides a brief summary of background information regarding the Site and the Corrective Measure selected by USEPA with concurrence from CTDEEP


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Section 2 summarizes the principal CMI activities and CM maintenance activities

completed during 2016

Section 3 provides the hydrogeologic and chemical data collected in 2016 as part of the CMI Groundwater Monitoring Program, the GWTF Operations, Monitoring & Maintenance (OM&M), and other sampling efforts.

Section 4 assesses the performance of the existing interim corrective measures and the final Corrective Measures being installed at the Site

Section 5 describes the institutional control monitoring activities conducted during 2016

Section 6 discusses the OM&M monitoring and major CMI activities planned for 2017

A list of acronyms and abbreviations is provided immediately after the Table of Contents. The Annual

Progress report also includes supporting appendices that provide graphical or tabular presentations of key

operational and monitoring data, technical analysis of the data, and copies of the laboratory reports. In

accordance with the Order, copies of this Annual Report are being made available on

the www.upjohnnorthhaven.com website that provides information to the public concerning CMI progress.

Due to the size of the report, not all sections of the 2016 Annual Report have been provided in the website

copy. Interested readers can review the complete report through the digital document repository that can

be accessed from the North Haven Memorial Library, or by contacting Pfizer or USEPA.


http://www.upjohnnorthhaven.com/

January 2017 i 033-6231-002

Table of Contents

EXECUTIVE SUMMARY ........................................................................................................................ ES-1

LIST OF ACRONYMS ................................................................................................................................... iv

1.0 INTRODUCTION .............................................................................................................................. 1 1.1 Overview ............................................................................................................................. 1 1.2 CMI Progress Reporting ..................................................................................................... 2

1.2.1 Annual Progress Reports ....................................................................................... 2 1.2.2 Quarterly Progress Reports ................................................................................... 2

1.3 Site Description ................................................................................................................... 3 1.3.1 Site History and Current Use ................................................................................. 3 1.3.2 Site Geology and Hydrogeology ............................................................................ 4

1.4 Description of Selected Corrective Measure (Remedy) ...................................................... 5 1.5 Performance Standards and Master Plan Schedule ........................................................... 6

2.0 PRINCIPAL ACTIVITIES CONDUCTED ......................................................................................... 9 2.1 Communications with USEPA and CTDEEP ...................................................................... 9 2.2 Groundwater Treatment Facility Permitting and Operation .............................................. 10 2.3 Groundwater Monitoring ................................................................................................... 11

2.3.1 Post-ESRC Groundwater Monitoring ................................................................... 11 2.3.2 Non-Routine Sampling and Monitoring ................................................................ 12

2.4 In-Situ Thermal Remediation ............................................................................................ 12 2.4.1 ISTR System Operation ....................................................................................... 12 2.4.2 ISTR System Decommissioning .......................................................................... 14 2.4.3 DNAPL Component Completion Report .............................................................. 15

2.5 East Side Remedial Components ..................................................................................... 16 2.5.1 ESRC Maintenance ............................................................................................. 16 2.5.2 ESRC Reporting................................................................................................... 18

2.6 West Side Remedial Components .................................................................................... 19 2.7 Community Outreach ........................................................................................................ 19

3.0 DATA SUMMARY AND CONCLUSIONS ...................................................................................... 22 3.1 Assessment of Performance of the Groundwater Extraction Systems and Groundwater

Treatment System ............................................................................................................. 22 3.1.1 Summary of GWES Operations and Maintenance .............................................. 22 3.1.2 Treatment System Monitoring .............................................................................. 23 3.1.3 GWES Hydraulic Control Monitoring ................................................................... 24

3.2 Groundwater Quality Monitoring ....................................................................................... 25 3.2.1 Groundwater Data Collection and Review Activities ............................................ 25 3.2.2 Comparative Criteria ............................................................................................ 26 3.2.3 Unit 1 Groundwater Sample Results.................................................................... 28 3.2.4 Unit 3 Groundwater Sample Results.................................................................... 29

3.3 Other Data Generated ...................................................................................................... 30 3.3.1 Additional Unit 3 Groundwater Monitoring ........................................................... 30 3.3.2 Unit 4 Groundwater Monitoring ............................................................................ 31 3.3.3 GW-LP01 Monitoring ........................................................................................... 31

4.0 ASSESSMENT OF PERFORMANCE OF CORRECTIVE MEASURES ....................................... 32

5.0 INSTITUTIONAL CONTROL MONITORING ACTIVITIES ............................................................ 34 6.0 PROJECTED 2017 MONITORING ACTIVITIES AND MASTER PLAN SCHEDULE ................... 37

6.1 Schedule of OM&M Sampling ........................................................................................... 37 6.1.1 Objective 1: Unit 1 Groundwater Hydraulic Control Monitoring .......................... 37 6.1.2 Objective 2: Evaluation of Post-ESRC Unit 1 Groundwater Flow Directions ..... 39 6.1.3 Objective 3: Monitor Unit 1 Groundwater Quality Outside HBW ........................ 40


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6.1.4 Objective 4: Monitor Unit 3 and Unit 4 Groundwater Flow Directions and Vertical

Gradients .............................................................................................................. 40 6.1.5 Objective 5: Demonstrate Compliance with Unit 3 Performance Standards at

Downgradient Property Boundary ........................................................................ 41 6.1.6 Objective 6: Monitor Groundwater Chemistry in the Vicinity of Unit 3 Well SEC-7D

............................................................................................................................. 42 6.1.7 Objective 7: Monitor Groundwater Chemistry in Unit 4 Well GD-4BR ................. 42 6.1.8 Objective 8: Further evaluation of LNAPL Recoverability in Well GW-LP01 ....... 43

6.2 Proposed Modifications To The Annual OM&M Activities ................................................ 43 6.2.1 O&M Groundwater Monitoring ............................................................................. 43 6.2.2 Master Plan Schedule .......................................................................................... 44

7.0 REFERENCES ............................................................................................................................... 45

List of Tables

Table 1 Summary of Well Completion Information Table 2 Post-ESRC Groundwater Monitoring Scope Table 3 Target Analytes and Comparative Criteria Table 4 Summary of Detected Compounds in Unit 1 Groundwater Data – 2016 Post-ESRC

Groundwater Monitoring Table 5 Summary of Detected Compounds in Unit 3 Groundwater Data – 2016 Post-ESRC

Groundwater Monitoring Table 6 2017 Unit 1 Monitoring Locations Table 7 2017 Units 3 & 4 Monitoring Locations

List of Figures

Figure 1 Site Location Map Figure 2 Base Map Figure 3 Master Plan Schedule (December 31, 2016) Figure 4 Unit 1 Piezometric Contours (April 18, 2016) Figure 5 Unit 1 Piezometric Contours (September 20, 2016) Figure 6 Selected Unit 1 Groundwater Monitoring Results 2015-2016 Figure 7 Post-ESRC Unit 3 Monitoring Results 2016 Figure 8 2017 Unit 1 Monitoring Locations Figure 9 2017 Unit 3 and Unit 4 Monitoring Locations

List of Appendices

Appendix A Key Agency Correspondence Appendix B GWES/GWTF OM&M Data Appendix C Groundwater Elevation Monitoring Appendix C-1 Groundwater Elevation Monitoring Appendix C-2 Continuous Groundwater Elevation Monitoring Appendix D Data Quality Assessment Appendix E Laboratory Data Packages Appendix F Other Data Appendix F-1 Additional Unit 3 Groundwater Monitoring Appendix F-2 Unit 4 Groundwater Monitoring Appendix F-3 GW-LP01


January 2017 iii 033-6231-002

ACRONYM DEFINITION

APS Additional Polluting Substances

ASGECI Amy S. Greene Environmental Consultants, Inc.

BMP Best Management Practice

CAMP CAP

Community Air Monitoring Program Citizens’ Advisory Panel

CCR Construction Completion Report

CM Corrective Measure

CMDR Corrective Measures Design Report

CMI Corrective Measures Implementation

CMS Corrective Measures Study

CTDEEP Connecticut Department of Energy and Environmental Protection

DGA Dense Graded Aggregate

DNAPL Dense Non-Aqueous Phase Liquid

EC Engineered Control

ELUR Environmental Land Use Restrictions

EOI Expression of Interest

ESRC East Side Remedial Components

FBR Fluidized Bed Reactor

FD Final Design

FIR Final Investigation Report

GAC Granular Activated Carbon

gpm Gallons Per Minute

GWES Groundwater Extraction System

GWTF Groundwater Treatment Facility

HBW Hydraulic Barrier Wall

ICVC Industrial/Commercial Volatilization Criteria

IRM Interim Remedial Measure(s)

ISTR In-Situ Thermal Remediation

LLC Limited Liability Company

LNAPL Light Non-aqueous Phase Liquid

MPS MSL

Media Protection Standards Mean Sea Level

NDDB Natural Diversity Data Base

NPDES National Pollutant Discharge Elimination System

OLISP CTDEEP Office of Long Island Sound Programs

OM&M Operation, Monitoring, and Maintenance

PCBs Polychlorinated Biphenyls

PDI Preliminary Design Investigation

PDP Preliminary Design Proposal

PID Photoionization Detector

QA Quality Assurance


January 2017 iv 033-6231-002

ACRONYM DEFINITION

QC Quality Control

QMG Quantum Management Group

RCRA Resource Conservation and Recovery Act

RCSA Regulations of Connecticut State Agencies

RSR Remediation Standard Regulation

SCADA Supervisory Control and Data Acquisition

SIM Selective Ion Monitoring

SRS Solids Removal System

SVOCs Semivolatile Organic Compounds

SWPC Surface Water Protection Criteria

TPH Total Petroleum Hydrocarbons

TSCA Toxic Substances Control Act

TTZ USACE

Target Treatment Zone US Army Corps of Engineers

USEPA United States Environmental Protection Agency

UV/Oxidation Ultra Violet Light/Hydrogen Peroxide

VFD Variable Frequency Drive

VOCs Volatile Organic Compounds

WSRC West Side Remedial Component

WWTR Wastewater Treatment Residuals


January 2017 1 033-6231-004

1.0 INTRODUCTION

1.1 Overview

This 2016 Annual Progress Report (2016 Annual Report) has been prepared by Golder Associates Inc.

(Golder) on behalf of Pharmacia & Upjohn Company LLC (Pharmacia & Upjohn) for the Pharmacia &

Upjohn Facility located at 41 Stiles Lane in North Haven, Connecticut (Facility or Site). The Resource

Conservation and Recovery Act (RCRA) ID number for the Facility is CTD001168533. The location of the

Site is shown on Figure 1. Site monitoring points and features, including the layout of East Side Remedial

Components (ESRC), are shown on the base map provided as Figure 21. This Annual Report was prepared

in accordance with the Administrative Order on Consent (Order) issued to Pharmacia & Upjohn by the

United States Environmental Protection Agency (USEPA) pursuant to Section 3008(h) of RCRA. The Order

(Docket Number RCRA-01-2011-0027) was executed on March 31, 2011 and covers Corrective Measures

Implementation (CMI) at the Site (USEPA, 2011).

USEPA retains lead regulatory oversight and jurisdiction for the CMI phase of work under the Order. The

Connecticut Department of Energy and Environmental Protection (CTDEEP) also provides regulatory

oversight in support of the USEPA. The implementation of the corrective measure is intended to satisfy the

Connecticut Transfer Act requirements and be accepted by the CTDEEP as the Site Remedial Action Plan.

In addition, the implementation of the corrective measure is intended to satisfy CTDEEP’s requirements for

final closure of the RCRA units identified at the Site and to satisfy the CTDEEP Remediation Standard

Regulations (RSRs) (CTDEEP, amended June 27, 2013). Approvals from other regulatory agencies, such

as the US Army Corps of Engineers (USACE), CTDEEP Office of Long Island Sound Programs (OLISP)2,

and from the Town of North Haven will also be obtained as appropriate for the implementation of the

corrective measures.

Pfizer Inc (Pfizer) assumed responsibility for the Site on April 16, 2003 as a result of its acquisition of the

Pharmacia Corporation. Pharmacia Corporation was converted to a limited liability company (LLC) on or

about November 30, 2012 and is now known as Pharmacia LLC. Pharmacia & Upjohn, which owns and

operates the Site, continues to be a subsidiary of Pharmacia LLC. Pharmacia & Upjohn, Pharmacia LLC,

and Upjohn LLC are all indirect wholly-owned subsidiaries of Pfizer. Pfizer, the parent company of

Pharmacia & Upjohn, has assembled a team of consultants and contractors (CMI Team) and directs

activities associated with the implementation of the final Site-wide corrective measure (or remedy) and

compliance with the RCRA 3008(h) Order, including primary interaction with USEPA and CTDEEP. In all

1 This base map contains a snapshot of the monitoring wells present at the Site as of December 31, 2016 and reflects well installations and abandonments completed throughout 2016. As a result, monitoring points appearing as abandoned on Figure 2 may have been used in for a portion of 2016 and discussed in this Annual Report but abandoned at some point later in the year. 2 As of October 3, 2016, OLISP became part of the CTDEEP Land and Water Resources Division (LWRD). g:\projects\2003 projects\033-6231-004 nhaven\200 reports\210 annual rpt\2016\2016 annual rpt_0336231004_013017.docx

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cases, representatives of Pfizer are acting on behalf of Pharmacia & Upjohn, who is the Respondent to the

Order.

1.2 CMI Progress Reporting

Section VII.C of the Order describes the general requirements to provide Annual and Quarterly Progress

Reports to USEPA, as discussed below.

1.2.1 Annual Progress Reports The specific requirements for Annual Reports, as presented in Attachment 3.II.D.2 of the Order, are listed

below and the Section of this Annual Report where each requirement is addressed as shown in parenthesis:

a. A narrative summary of principal activities conducted; (Section 2)

b. Graphical or tabular presentations of key operational and monitoring data and copies of the analytical data; (Section 3)

c. An assessment of the performance of the Corrective Measure during the previous year: (Section 4)

d. A schedule of sampling and field activities to be performed and reported in the following year and any proposed modifications to the annual Operations, Monitoring and Maintenance (OM&M) activities. (Section 6)

e. Confirmation that the institutional control monitoring activities required by Section VII.B.5 have occurred. (Section 5)

“Corrective Measures” as defined by the Order are currently being designed or are in the process of being

installed. Progress updates on Corrective Measures installed during this reporting period are summarized

in Section 2 of this 2016 Annual Report. A description of the Interim Remedial Measures (IRM) is presented

in Section 1.3 and updates to the status of the IRM have been provided to USEPA and CTDEEP on a

quarterly basis throughout 2016. The effectiveness of existing interim remedial measures, the corrective

measures components installed and other controls put in place during CMI in 2016 is summarized in Section

4. As corrective measures design and construction progress, future Annual Reports will cover final

corrective measures effectiveness. Similarly, several of the institutional controls required by the Order, such

as Environmental Land Use Restrictions (ELURs), will not be in place until the corrective measures are

completed, therefore Section 5 of this report focuses on confirming the monitoring of the institutional

controls currently in place.

1.2.2 Quarterly Progress Reports The Order also requires reporting of CMI progress to USEPA on a quarterly basis. During 2016, Pharmacia

& Upjohn submitted quarterly progress reports to USEPA and CTDEEP for the following reporting periods

(submittals dates are in parenthesis):

January through March 2016 (April 29, 2016) g:\projects\2003 projects\033-6231-004 nhaven\200 reports\210 annual rpt\2016\2016 annual rpt_0336231004_013017.docx

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April through June 2016 (July 29, 2016)

July through September 2016 (October 28, 2016)

October through December 2016 (January 26, 2017)

These quarterly progress reports provide a detailed account of CMI progress, list the data collection

activities throughout the year, and provide a short-term projection of work to be completed during the

upcoming reporting period. This Annual Report presents an overview of the CMI activities completed

throughout the year and focuses on the presentation and the evaluation of data collected during the year.

1.3 Site Description

The Site consists of an approximately 80-acre parcel of land located within a commercial/industrial area of

North Haven, Connecticut, as shown on Figure 1. The Site lies within an area of North Haven, Connecticut

that is isolated from residential communities by active rail lines (west side); inactive and active industrial

sites (e.g., the former Circuit Wise facility; Precision Combustion, and SK PT LLC (i.e. Spectrix)), former

off-site landfill, and South Creek (southwest and south sides); the Quinnipiac River and Interstate 91 (east

side); and the State Route 40 highway and embankment, inactive industrial sites (e.g., the Humphrey

Chemical Site), and North Creek (north side). The small parcel of predominantly tidal wetlands adjacent to

the northeast corner of the Site is referred to as the North Haven Land Trust property. The surrounding

properties have been used for a variety of industrial activities since the early 1800s.

1.3.1 Site History and Current Use The Site was used for industrial manufacturing beginning in the mid-1800s, when I.L. Stiles & Sons opened

a clay mine and brick yard which operated into the 1930s. The Site was then used by Carwin Chemical

Company for chemical manufacturing from the mid-1940s to 1962 and by the Burndy Corporation for

electrical component manufacturing from circa 1963 to 1975. Beginning in 1962, Upjohn produced specialty

and industrial chemicals including pharmaceutical, dye, pigment, and photographic intermediates,

agricultural treatment chemicals, ultraviolet curing initiators, coating and adhesive additives, and flavor and

fragrance components. Chemical manufacturing continued until 1993, when the manufacturing facilities

(buildings, tanks, and pipelines) were dismantled and demolished to grade.

Wastes generated at the Site during historical operations primarily included chemical manufacturing

process wastes and wastewater treatment residuals (WWTR) consisting of several different types of organic

chemicals and metals, including, among others, volatile organic compounds (VOCs), semivolatile organic

compounds (SVOCs), polychlorinated biphenyls (PCBs), and lead. A more detailed Site description,

including a detailed conceptual Site model, can be found in the Final Investigation Report (FIR) (Golder,

2006) and the Final Revised Corrective Measures Study (CMS) (Golder, 2010).


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Several IRM have been put in place over the past 20-plus years to protect human health and the

environment while the site investigations and risk assessments were completed and while the corrective

measures are being designed and constructed. These IRM include limiting access to and securing the Site,

construction of interim covers over impacted soils, consolidation and isolation of WWTR, removal and off-

site disposal of some impacted soil and sediment, management of storm water runoff, operation of an

interim groundwater extraction system and construction and continued operation of a state-of-the-art

groundwater treatment system. A more complete description of the IRM completed at the Site can be found

in the Statement of Basis (USEPA, 2010a) and the Final Revised CMS. These IRM will be maintained by

Pharmacia & Upjohn until the final corrective measures are installed. In several portions of the Site, the

IRM will be or have been incorporated into the final remedy.

Since the establishment of the Order, and as described in Section 2 of this report, Pharmacia & Upjohn has

completed construction of several of the major components of the final remedy. Current Site use includes

operation and maintenance of the final remedial systems and remaining IRM, along with CMI construction

activities. Current Site activities include operating the groundwater extraction system (GWES), a

groundwater treatment facility (GWTF)3, and maintaining protective barrier cover and low permeability

cover systems on the east side of the Site. Woodard & Curran, on behalf of Pharmacia & Upjohn, manages

and maintains the Site and provides 24-hour per day presence, controls access to the Site through locked

chain-link fenced gates, maintains signage warning trespassers to keep out, and regularly inspects the Site.

1.3.2 Site Geology and Hydrogeology Geologic units underlying the Site have been correlated with published geologic unit designations and have

then been assigned informal designations, from the youngest (Unit 1) to the oldest geologic unit (Unit 4).

Unit 1, Unit 2 and Unit 3 together comprise the unconsolidated geologic units that overlie bedrock (Unit 4)

and include:

Unit 1 – Undifferentiated, surficial man-made fill, Alluvial Sands, marine estuarine deposits and peat;

Unit 2 – Silty Clay, occasionally varved, assigned to the New Haven Clay or more informally the “Quinnipiac Silt-Clay”. This unit acts as an aquitard, which isolates groundwater in Unit 1 from Unit 3 and Unit 4;

Unit 3 – Deltaic Sand of Muddy River Delta Deposits (Unit 3b) or “lower sand” outwash- of the Quinnipiac River valley (Unit 3a); and,

Unit 4 – New Haven Arkose, bedrock assigned to the Newark Group of the Hartford Basin.

Unit 1 is generally separated hydraulically from Units 3 and 4 by the Unit 2 silty clay/clayey silt layer, with

the exception of a small area where Unit 2 is thinned or absent at the north side of the Site. The surficial

groundwater-bearing unit at the Site is developed within the materials of Unit 1. The groundwater flow in

3 The on-site GWTF is operated by Woodard & Curran in accordance with National Pollutant Discharge Elimination System (NPDES) Permit CT0001341, issued by CTDEEP on January 8, 2010. g:\projects\2003 projects\033-6231-004 nhaven\200 reports\210 annual rpt\2016\2016 annual rpt_0336231004_013017.docx

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Unit 1 generally trends eastward towards the Quinnipiac River. Portions of the Site Unit 1 aquifer have been

impacted by compounds diffusing from the Dense Non-Aqueous Phase Liquid (DNAPL) present in the

Former Production Area on the western side of the site and, to a lesser extent, from the WWTR present on

the eastern side of the Site. Unit 1 groundwater is currently being contained by the combination of the

hydraulic barrier wall (HBW) and the GWES. The collected Unit 1 groundwater is treated by the GWTF prior

to its discharge to adjacent surface waters.

Deeper groundwater circulation enters the Upland Terrace west of the Site (elevation about 20 ft. above

mean sea level (MSL)) and flows easterly through Unit 3 and Unit 4 that underlie the silty clay/clayey-silt

aquitard (Unit 2). Vertical hydraulic gradients are generally downward in the western portion of the Site and

upward in the eastern portion near the river. Chemical impacts to Units 3 and 4 groundwater are significantly

less than chemical impacts to Unit 1 groundwater. Units 3 and 4 groundwater does not flow directly into

surface water. Rather, a component of Unit 3 and Unit 4 groundwater in the eastern portion of the Site

slowly seeps upward through the Unit 2 silty clay/clayey silt into Unit 1 prior to discharge into the Quinnipiac

River and a component of groundwater from Unit 3 and Unit 4 flows southerly along the river.

A complete conceptual Site model, including detailed discussion of the Unit 3 and 4 groundwater to surface

water discharge pathway is discussed in more detail in the FIR and the CMS. During 2014, Pharmacia &

Upjohn updated the Site conceptual hydrogeologic and chemical transport model for Unit 3 groundwater in

the vicinity of Unit 3 monitoring well SEC-7D. The refinements to this model in the northern portion of the

Site were presented in the revised SEC-7D Pre-Design Investigation Report and Preliminary Design

Proposal (SEC-7D PDI/PDP), which was submitted to USEPA and CTDEEP in February 2014 (Golder,

2014b). The conceptual Site model continues to evolve as new hydrogeologic and chemical data is

collected as part of the CMI and post-ESRC monitoring programs.

1.4 Description of Selected Corrective Measure (Remedy)

The Corrective Measure selected by USEPA for the Site is presented in the USEPA Final Decision and

Response to Comments Document (USEPA, 2010b) and is described in the Order as follows:

Construction of a hydraulic control system for shallow groundwater (hydrogeologic Unit 1) consisting of a perimeter sub-grade low-permeability vertical barrier and a groundwater extraction system that will intercept contaminated groundwater, thus preventing impacts to the Quinnipiac River and to the adjacent North Creek and South Creek. Collected groundwater will be treated in the existing on-site Groundwater Treatment Facility prior to discharge in accordance with a CTDEEP National Pollutant Discharge Elimination System (NPDES) Permit;

Construction, regular sampling and evaluation of data from monitoring wells and piezometers both inside and outside the hydraulic barrier wall to verify long-term performance of the Unit 1 hydraulic control system;

Monitoring of deep groundwater (in hydrogeologic Units 3 and 4) to assess continued compliance with the groundwater Performance Standards. This component of the remedy


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includes further investigation of well SEC-7D and implementation of focused remedial measures, if determined necessary by USEPA;

Treatment of the most highly contaminated area on the Site, which contains Dense Non-Aqueous Phase Liquid (DNAPL), using in-situ thermal remediation (ISTR), including operation of appropriate air pollution controls, thereby eliminating this area as the most highly contaminated area of the Site;

On-site management of polychlorinated biphenyl (PCB)-impacted materials below protective barrier cover systems and low permeability cover systems under a Determination of Toxic Substances Control Act (TSCA) PCB Risk-Based Disposal Approval (40 C.F.R. § 761.61(c));

Stabilization and installation of low-permeability cover systems for both the North and South Piles on the east side of the Site to safely contain contaminated materials, prevent future contact with the materials, reduce infiltration into these areas, and reduce groundwater impacts from the Piles;

Construction of protective barrier and low-permeability cover systems over remaining portions of the east side of the Site to allow it to be safely used by maintenance workers and visitors;

Construction of protective barrier covers over the west side of the Site to allow safe commercial/light industrial redevelopment of this portion of the Site;

Focused remediation of Quinnipiac River sediment in two areas of the tidal mud flats (portions of Tidal Flat Nos. 1 and 2) and in a small stretch of South Creek, in a manner that will balance ecological benefits derived from the removal of the highest concentrations of key contaminants while minimizing the damage to ecological habitat that would result from sediment removal;

Enhancement of the east side ecological habitat, including creation of higher ecological value uplands and freshwater wetlands habitat. Construction of walking trails for interpretative environmental education and guided viewing of the enhanced habitats, which habitats will be maintained as an ecological preserve overlaying the constructed protective remedy;

Placement of institutional controls, including CTDEEP Environmental Land Use Restrictions, to prohibit residential4 development and other residential uses (e.g., schools, hospitals, day care centers), restrict groundwater use, and prevent disturbance to or demolition of engineered controls constructed on the Site; and

Long-term operation, monitoring, and maintenance (OM&M) of the Site to verify continued protection of human health and the environment and compliance with Performance Standards.

1.5 Performance Standards and Master Plan Schedule

The Order includes “Performance Standards” which define the performance requirements for the corrective

measure. The Performance Standards are provided in Attachment 2 of the Order, and contain both

numerical criteria and narrative requirements, such as references to meeting the requirements of specific

Sections of the CTDEEP RSRs.

4 Section VII.B.5.b.i of the new RCRA 3008(h) Order excludes ‘controlled community access via guided interpretive trails on the east side’ from ‘outdoor recreational use,’ which is included in the definition of ‘residential use’ under the CT RSRs at Section 22a-133q-1. g:\projects\2003 projects\033-6231-004 nhaven\200 reports\210 annual rpt\2016\2016 annual rpt_0336231004_013017.docx

January 2017 7 033-6231-004

The Order also includes the CMI “Master Plan Schedule,” (Order Attachment 6) which contains projected

completion dates (Major Milestones and Project Goals) for major work plans, design documents, field work,

construction work, and reports necessary to comply with the Order and implement the Corrective Measures.

A copy of the Master Plan Schedule is provided as Figure 3. Completion symbols and dates have been

added to this schedule indicating when the Major Milestones and Progress Goals have been achieved to

date. A table summarizing the status of the milestones is provided below. As discussed in the Sections

below, Pharmacia & Upjohn has accelerated the CMI schedule, when possible, and will strive to continue

this accelerated pace throughout the CMI.

Activity Milestone Type

Milestone Date

Date Achieved

Status as of December 31, 2016

2011 Submit NPDES Request for Determination Concerning

Wastewaters from ISTR Pilot System Operation

Progress Goal

8/26/2011 6/1/2011 Approved by CTDEEP.

No USEPA approval required.

Submit Draft ISTR Pilot System Design and Pilot-Study Work

Plan

Major Milestone

6/16/2011 6/3/2011 Approved by USEPA and CTDEEP after

revisions.

Submit CMI Work Plan Major

Milestone 11/18/2011 9/30/2011

Approved by USEPA and CTDEEP after

revisions. Submit ESRC Component Implementation Work Plan

(including PDI Sampling and Analysis Plan)

Major Milestone


revisions.

2012 Complete ISTR Pilot System

Construction Progress

Goal 1/22/2013 4/16/2012 Completed.

Submit Sediment PDI Report and Sediment Remediation PDP

Progress Goal

6/28/2013 8/28/2012 Approved by USEPA

and CTDEEP.

Submit SEC-7D PDI/PDP Progress

Goal 3/21/2013 9/14/2012

Approved by USEPA after revisions;

CTDEEP deferred review to USEPA.

Complete ISTR Pilot Study Progress

Goal 3/18/2013 11/14/2012 Completed.

2013 Submit NPDES Request for Determination Concerning Wastewaters from ESRC

Construction Activities

Progress Goal



Submit Unit 1 Groundwater Hydraulic Controls Draft final

Design Package

Major Milestone


revisions.

5 The Groundwater Extraction System (GWES) Hydrogeologic Design Draft Final Design (DFD), Appendix H of the ESRC CMDR, was submitted on May 6, 2013 (Golder, 2013c). g:\projects\2003 projects\033-6231-004 nhaven\200 reports\210 annual rpt\2016\2016 annual rpt_0336231004_013017.docx

January 2017 8 033-6231-004

Activity Milestone Type

Milestone Date

Date Achieved

Status as of December 31, 2016

Submit Draft Final Design Package for Remaining ESRCs

Major Milestone


revisions.

Submit ISTR Pilot Study Report and PDP

Major Milestone

11/13/2014 8/30/2013



2014

Submit Full-Scale ISTR Draft Final Design

Progress Goal

9/25/2015 12/11/2014



2015 Submit GWTF NPDES Request for Determination of Permit Modification to CTDEEP related to Operation of the Full-Scale ISTR

Progress Goal



Complete Full-Scale ISTR System Construction

Progress Goal

10/26/2017 5/29/2015 Completed.

2016 Complete Full-Scale Treatment of DNAPL using ISTR

Progress Goal

12/24/2019 2/8/2016 Completed.

Submit Construction Completion Report for East Side Areas

Major Milestone


revisions.

Submit DNAPL Component Construction Completion Report

Major Milestone

3/31/2020 9/23/2016



The Order provides a process for modifying the “Master Plan Schedule” and documents these changes in

the Quarterly Progress Reports. Figure 3 reflects that the milestone date associated with the Progress Goal

“Submit Draft Final Design of West Side Remedial Components (WSRC)” was revised to March 31, 20186.

USEPA was notified of the intent to change the target completion for this Progress Goal in the 3rd Quarter

2016 Progress Report and in a letter to USEPA dated November 3, 2016. USEPA approved the change to

the Progress Goal on November 14, 2016. Revising the Progress Goal date associated with the submittal

of the Draft Final Design of the WSRC to March 31, 2018 is not anticipated to impact the ability to achieve

the May 29, 2020 Major Milestone associated with “Submit the Construction Completion Report for West

Side Areas”.

6 This Progress Goal was revised from August 28, 2015 to November 16, 2016 during the 2nd quarter of 2015 and modified again during the 3rd quarter of 2016.


January 2017 9 033-6231-004

2.0 PRINCIPAL ACTIVITIES CONDUCTED

Given its scope and magnitude, Pharmacia & Upjohn has divided the corrective measure selected by

USEPA into separate components and has assembled the CMI Team to design and construct them. The

CMI Team is comprised of several entities with various roles and responsibilities as summarized below.

Pharmacia & Upjohn Company LLC (Site Owner and Operator) – Overall project direction and management provided by Pfizer on behalf of Pharmacia & Upjohn

Quantum Management Group, Inc. (QMG) - Assists Pfizer with project management

Woodard & Curran – Site management, operation and maintenance of the GWES and GWTF, and groundwater treatment facility upgrades

Golder Associates Inc. (Golder) – Environmental Consultant and Construction Quality Assurance

AECOM (formerly URS) - Construction Manager and Health and Safety oversight

East Side Remedial Components (ESRC) Team [NorthStar (formerly WRS), Brown and Caldwell, and Amy S. Greene Environmental Consultants, Inc. (ASGECI)] – Design and construction of the ESRC which is a major Corrective Measure component

TerraTherm, Inc. (TerraTherm) – Design and Operation of the full-scale ISTR system to address DNAPL Subareas A and B, which is a major Corrective Measure component

Vita Nuova, LLC (Vita Nuova) - Ecological Enhancement, West Side redevelopment, and Community Relations consultant

This Section addresses the Annual Report requirements to provide a narrative summary of principal

activities completed in the reporting year. As such, this Section provides a summary of the principal CMI

activities performed by the CMI Team during 2016.

2.1 Communications with USEPA and CTDEEP

Representatives of the USEPA, CTDEEP and the CMI Team participated in progress update

teleconferences on an approximately monthly basis throughout 2016. Progress teleconferences were held

on January 20, February 17, March 16, April 27, May 18, June 15, July 20, August 17, September 27,

November 16, and December 21, 2016. A variety of topics were discussed during the teleconferences

including the progress of USEPA and CTDEEP technical reviews of CMI Team submittals, full-scale ISTR

system operation and decommissioning, ESRC maintenance activities, groundwater monitoring results,

and community outreach activities. Representatives of USEPA, CTDEEP, and a smaller selection of CMI

Team Members also participated in focused teleconferences regarding the progress of ISTR operations on

January 6, and February 3, 2016. The ISTR-specific teleconferences were discontinued after the full-scale

ISTR system completed operations on February 8, 2016.

The CMI Team remained in regular communication with the USEPA and CTDEEP during 2016 through

email correspondence and telephone conversations between Pfizer and various Agency staff.

Teleconferences to address specific technical matters were also conducted, and are detailed below as part


January 2017 10 033-6231-004

of the discussion of specific aspects of the CMI. Key correspondence between the Agencies and the CMI

Team is provided in Appendix A.

2.2 Groundwater Treatment Facility Permitting and Operation

Throughout 2016, Woodard & Curran continued to operate the GWTF in accordance with NPDES Permit

CT0001341, issued by CTDEEP on January 8, 2010 (CTDEEP, 2010). An application to renew the Site

NPDES permit, which was due to expire on January 7, 2015, was submitted to CTDEEP on July 3, 2014.

CTDEEP communicated that the review process for the revised permit would not be completed by January

7, 2015 and that, as provided by the State of CT regulations, by the timely and administratively complete

submittal of the permit renewal application, the GWTF should continue to operate in accordance with the

current permit and Regulations of Connecticut State Agencies (RCSA) 22a 430-3(i) approvals until such

time as the new permit is issued.

In response to comments from CTDEEP regarding the NPDES permit renewal application, Woodard &

Curran collected surface water samples from a location in the Quinnipiac River immediately upstream from

the Site on an approximately monthly basis between April and December 2015. The background

concentration data of selected chemicals was submitted to CTDEEP on February 12, 2016.

On February 25, 2016, Woodard & Curran notified CTDEEP that several reagents, including commercially

available cleaning solutions ZEP™ and Capsur® and/or diesel were being considered for use during the

decontamination of the full-scale ISTR equipment. Additional information was provided to the CTDEEP on

March 1, 2016 along with a Facility and Wastewater Treatment System Modification Notification and

Request for Approval under RCSA 22a-430-3(i). CTDEEP approval to manage wastewaters containing

these decontamination agents in the on-Site GWTF was received on March 16, 2016. A copy of this

approval is included in Appendix A.

Two, 10,000-pound granular activated carbon (GAC) vessels and various other system modifications were

constructed during the 2nd quarter of 2015 to assist with the treatment of the aqueous waste streams

associated with full-scale ISTR operation and decommissioning. These modifications to the GWTF to pre-

treat the aqueous waste streams associated with ISTR were approved by CTDEEP under RCSA 22a-430-

3(i) on March 18, 2015. After full-scale ISTR decommissioning was completed in May 2016, Woodard &

Curran began decommissioning the pre-treatment equipment. These decommissioning activities were

completed in October 2016. Certain components of the GWTF that had come in contact with the ISTR

aqueous waste streams, such as the Equalization Tanks, were decontaminated, as necessary.

As discussed in Section 3, flow to the GWTF has decreased following construction of the hydraulic barrier

wall and ESRC cover systems. On September 26, 2016, Pfizer and its representatives met with CTDEEP

to discuss how redesign of the GWTF for lower flows would affect the NPDES permit renewal application


January 2017 11 033-6231-004

administrative process. On December 14, 2016, CTDEEP provided a request for additional information

following completion of a technical review of the information provided prior to the September 26, 2016

meeting. Pharmacia & Upjohn intends to provide submissions to CTDEEP, including responses to the

CTDEEP comments and a supplement to the NPDES permit renewal application describing preliminary

conceptual design information regarding certain features of the GWTF during the first quarter of 2017.

2.3 Groundwater Monitoring

The 2015 Annual Progress Report (2015 Annual Report), which summarized the 2015 CMI progress and

the results of the 2015 groundwater monitoring program, was submitted to USEPA and CTDEEP on

February 1, 2016. Section 6.1 of the 2015 Annual Report provided the scope and schedule for the

groundwater monitoring activities that were anticipated to be performed in 2016 to fulfill the Order

requirements to conduct groundwater monitoring. The groundwater activities conducted in 2016 are, in part,

a continuation of the groundwater monitoring activities previously reported to USEPA and CTDEEP in the

2011, 2012, 2013, 2014, and 2015 Annual Reports (Golder, 2012a, 2013a, 2014a, 2015, 2016). On March

9, 2016, the CMI Team received approval of the 2016 groundwater sampling objectives, scope, and

schedule discussed in Section 6.1 of the 2015 Annual Report. On May 4, 2016, USEPA approved the

remainder of the 2015 Annual Report. (See Appendix A).

2.3.1 Post-ESRC Groundwater Monitoring The following routine post-ESRC groundwater monitoring activities derived from the Post-CMI Groundwater

Monitoring Plan (Golder, 2014d), approved as Appendix D of the ESRC Corrective Measures Design Report

(CMDR),7 were implemented in 2016, and are discussed in Section 3.0 of this report:

Synoptic groundwater level measurements were collected from selected Unit 1, Unit 3 and Unit 4 wells on April 18, 2016 and September 19 and 20, 2016.

The data from the continuous water level measurement devices (dataloggers) installed along the periphery of the Site were analyzed and used to adjust GWES operation as necessary to maintain Unit 1 hydraulic control. The dataloggers were downloaded and the data evaluated on an approximately monthly basis throughout 2016.

Groundwater samples were collected from Unit 1 monitoring wells GW-NFPA07, GW-HBW03, GW-HBW11, GD-5S, DM-5S, DM-7S, GW-HBW12, GW-HBW06, GW-HBW13 and GW-HBW07, which are located outside the HBW, and Unit 3 perimeter monitoring locations DM-5D, DM-7D, DM-9D, MP-20DR, MW-35D, GD-3D, and GD-4D between September 19, 2016 and September 23, 2016. These samples were collected concurrently with the non-routine samples discussed below.

7 While the ESRC CMDR used the term “post-CMI Groundwater Monitoring,” and included the Post-CMI Groundwater Monitoring Plan, the plan described the monitoring activities to be performed during the first two to three years following completion of the ESRC. As the post-CMI period will formally begin after approval of the overall Site Construction Completion Report (coinciding with issuance of the CTDEEP Stewardship Permit and termination of the USEPA Order), the term post-ESRC groundwater monitoring will be used during the remainder of this report and during the period between completion of the ESRC and the official start of the post-CMI period. It is anticipated that the data collected between the completion of the ESRC and the submission of the Stewardship Permit Application will be used to develop a long-term Post-CMI Groundwater Monitoring Plan associated with the Stewardship Permit. g:\projects\2003 projects\033-6231-004 nhaven\200 reports\210 annual rpt\2016\2016 annual rpt_0336231004_013017.docx

January 2017 12 033-6231-004

The data from these monitoring activities implemented by Golder in 2016 are presented and evaluated in

Section 3.0 of this 2016 Annual Report.

2.3.2 Non-Routine Sampling and Monitoring Various non-routine well installation, water level monitoring and groundwater sampling activities were

implemented in 2016 to collect information related to monitoring CMI activities, the performance of the

Corrective Measures, and to provide data to develop the scope of longer-term monitoring activities. These

non-routine sampling and monitoring activities included:

Additional dataloggers were deployed in Unit 1 at various times during 2016 to collect supplemental Unit 1 groundwater hydraulic control data.

Groundwater samples were collected from Unit 3 wells GD-3D, GD-4D, GW-U305, GW-U311, GW-U312, GW-U313, SEC-7D, and deep unconfined aquifer wells GW-HBW17 and GW-U309 between April 18, 2016 and April 19, 2016 as part of the combined spring 2016 groundwater monitoring event to monitor groundwater conditions downgradient of full-scale ISTR and in the vicinity on Unit 3 monitoring well SEC-7D.

Groundwater samples were collected from shallow Unit 1 wells GW-HBW16, GW-HBW19, GW-U103, and TPW-1N to provide continued monitoring of shallow groundwater in the vicinity of Unit 3 monitoring well SEC-7D between September 19, 2016 and September 23, 2016.

Groundwater samples were collected from the 25 Unit 3 wells remaining on Site after the ESRC construction, including the wells named as part of the routine monitoring program, as part of the consolidated fall monitoring event conducted between September 19, 2016 and September 23, 2016. These samples provide data regarding groundwater conditions downgradient of full-scale ISTR, in the vicinity on Unit 3 monitoring well SEC-7D, and to assess changes in groundwater quality since the pre-ESRC baseline monitoring in 2011.

Groundwater samples were collected from the ten Unit 4 wells present on Site after the ESRC construction as part of the consolidated fall monitoring event conducted between September 19, 2016 and September 23, 2016. These samples provide data to assess changes in Unit 4 groundwater since the pre-ESRC baseline monitoring in 2011 and to monitor groundwater in the vicinity of well GW-U402B.

Unit 1 well GW-LP01 was monitored for the presence of recoverable light non-aqueous phase liquid (LNAPL) on January, 7, April 19, June 16, October 23, and November 30, 2016. While small amounts of LNAPL continued to be observed in the well, the viscosity prevented recovery.

Data generated from these non-routine activities are discussed briefly in Section 3.3 and are provided to

USEPA and CTDEEP in the Appendices to this 2016 Annual Report.

2.4 In-Situ Thermal Remediation

2.4.1 ISTR System Operation The full-scale ISTR system in DNAPL Subareas A and B was constructed between August 2014 and May

2015, in accordance with the USEPA approved Full-Scale ISTR Final Design (ISTR FD, TerraTherm and


January 2017 13 033-6231-004

Golder, 2015)8. Completion of the ISTR system construction on May 29, 2015 achieved the Order Master

Plan Progress Goal “Complete Full-Scale ISTR System Construction”. Vapor and liquid extraction from the

Subarea A and Subarea B treatment zones began on June 5, 2015 and subsurface heating began on June

15, 2015, after USEPA authorized the operation of the full-scale ISTR system by approval of the ISTR FD

and responses to USEPA comments on June 4, 2015. Section 2.4 of the 2015 Annual Report describes

the operation of the full-scale ISTR system during 2015, including heater cycling to shift a portion of the

power demand to off-peak hours (and thereby “greener” power sources), modification of the liquid handling

process equipment in response to operational issues, air emissions compliance monitoring (aka stack

testing), and 24-hour perimeter air quality monitoring associated with the Community Air Monitoring

Program (CAMP).

By October 30, 2015, the primary ISTR treatment objectives had been reached for Subarea B including

reaching a target treatment temperature of approximately 100°C at 90% of the individual temperature

sensors located at centroid locations throughout the treatment zone, and a mass removal rate of less than

approximately 10% of the peak mass removal rate for 7 consecutive days. On October 30, 2015, Pharmacia

& Upjohn submitted a Subarea B shutdown request to USEPA. On November 5, 2015, USEPA notified

Pharmacia & Upjohn that it had determined that the operation of Subarea B had successfully attained the

completion criteria. Power input to Subarea B was ramped down beginning on November 5, 2015. Vapor

and liquid extraction continued from Subarea B until November 30 and December 4, 2015, respectively.

The liquid and vapor lines from Subarea B were subsequently isolated from the main process while

treatment of DNAPL Subarea A continued. The completion of treatment in Subarea B more quickly than

the completion of treatment in Subarea A was expected based on the modelling performed during the ISTR

system design process.

By January 6, 2016, multiple lines of evidence indicated that the primary ISTR treatment objectives had

been reached in Subarea A. The lines of evidence included reaching a target treatment temperature of

approximately 100°C at 95.1% of the individual temperature sensors located at centroid locations

throughout the treatment zone, the mass removal rate had fallen to approximately 10% of the peak mass

removal rate for seven consecutive days, and sufficient energy had been injected into the treatment zone

to bring the Subarea to target treatment temperature and to remove DNAPL to the maximum extent prudent.

On January 6, 2016, Pharmacia & Upjohn submitted an ISTR shutdown request for Subarea A to USEPA,

and on January 14, 2016, USEPA notified Pharmacia & Upjohn that it had determined that the ISTR

treatment of Subarea A had met the completion criteria (Appendix A). Power input to the ISTR heaters in

Subarea A was ramped down beginning on January 14, 2016.

8 CTDEEP deferred review of the ISTR FD to USEPA. g:\projects\2003 projects\033-6231-004 nhaven\200 reports\210 annual rpt\2016\2016 annual rpt_0336231004_013017.docx

January 2017 14 033-6231-004

On January 13, 2016, Pfizer notified USEPA and CTDEEP that vapor treatment during the initial cool-down

period would be accomplished using the vapor carbon system due to a failure in the thermal oxidizer system

process blowers. The use of the vapor carbon in place of the thermal oxidizer was in accordance with the

contingency plan stated in the ISTR FD. TerraTherm proactively performed a carbon change-out on

January 18, 2016 to provide sufficient vapor treatment capacity for the remainder of the operational period.

Vapor extraction continued from Subarea A until February 1, 2016 during the initial sub-surface cooling

period, as described in the ISTR FD. The vapor extraction and treatment system was placed back online

for a short time beginning on February 4 through 8, 2016 as a result of nuisance odors identified around

the wellfield. The permanent shut-down of the ISTR vapor extraction and treatment system on February 8,

2016 achieved the Order Master Plan Schedule Progress Goal “Complete Full-Scale Treatment of DNAPL

Using ISTR” (Progress Goal date December 24, 2019).

2.4.2 ISTR System Decommissioning During 2016, TerraTherm continued to operate and maintain the Emilcott Greenlight™ continuous-

monitoring perimeter photoionization detector (PID) system associated with the ISTR CAMP. In accordance

with the CAMP, the system was operated continuously during full-scale system operation and during

working hours once decommissioning activities began. No verified exceedances were identified at any of

the perimeter monitoring stations during 2016. The data from the monthly TO-15 air samples continued to

indicate the presence of various VOCs at levels consistent with background conditions and consistent with

the PID data. The data from the CAMP monitoring was provided to USEPA and CTDEEP as part of the

DNAPL Component Completion Report.

ISTR system decontamination and decommissioning began in February 2016 following the initial cool-down

period. Initial activities focused on removal and disposal of accumulated DNAPL, decontamination and wipe

testing of the liquid treatment system components (e.g., frac tank, weir tank, multi-bag filter skids), and

return of rental equipment to vendors once wipe testing demonstrated that PCB concentrations were below

the unrestricted use criteria of ≤ 10 ug/100 cm2 Total PCBs. In accordance with the decontamination

procedures outlined in the ISTR Design Report and the HASP, equipment was cleaned via several

methods: mechanical brush cleaning, pressure washing and/or steam cleaning. Also, due to the difficulties

in achieving the PCB decontamination wipe sample result of ≤ 10 ug/100 cm2, commercial cleaning

solutions (ZEP™ and Capsur® and/or diesel-soaked rags) were used to further decontaminate non-porous

surfaces. Aqueous decontamination wastes containing these agents were initially captured for off-site

disposal. Aqueous decontamination wastes were treated in the onsite GWTF following CTDEEP

authorization under RCSA 22a 430-3(i) on March 16, 2016.


January 2017 15 033-6231-004

Highlights of the ISTR decommissioning included:

The thermal oxidizer was removed from the Site during the week of April 18, 2016. Major treatment system components continued to be decommissioned and decontaminated throughout April and May, with the final major components demobilized the week of May 27, 2016.

Cascade abandoned (i.e. filled with grout, and capped or plugged) the multi-phase extraction wells, heater wells and other subsurface penetrations between May 5, 2016 and May 13, 2016.

The imported fill layer and cover system from Subarea B was placed adjacent to the northwestern side of Subarea A, covered with poly liner to reduce infiltration and then covered with dense graded aggregate (DGA) during the week of May 13, 2016. USEPA and CTDEEP concurred with the interim measures to manage the Subarea B cover system materials on April 28, 2016. (See Appendix A)

Subarea B was repaved on May 23, 2016 which restored full access to the northern side of the GWTF.

TerraTherm completed decommissioning activities and demobilized from the Site the week of May 27,

2016. The communication with USEPA regarding the CAMP system shutdown with the completion of

decommissioning activities is provided in Appendix A.

The Subarea A wellfield cover and the relocated fill layer and cover system from Subarea B are being used

as an interim cover system until such time as the final cover system for the West Side of the Site is designed

and constructed.

Northwest side of Subarea A after well abandonment and relocation of the Subarea B cover system and East side of Subarea A showing restored roadway

2.4.3 DNAPL Component Completion Report The draft DNAPL Component Completion Report, which includes information regarding the construction

and operation of the full-scale ISTR system in Subareas A and B, as well as the treatment of DNAPL in

Subarea C as part of the ISTR Pilot Study, was submitted to USEPA and CTDEEP on September 23, 2016


January 2017 16 033-6231-004

(TerraTherm and Golder, 2016a). The submission of the draft DNAPL Component Completion Report

achieved the Order Master Plan Schedule Major Milestone “Submit DNAPL Component Completion Report”

(Milestone date March 31, 2020).

USEPA provided comments on the draft DNAPL Component Completion Report on December 1, 2016. On

December 7, 2016, USEPA communicated that the CMI Team responses dated December 6, 2016 were

acceptable (Appendix A). The updated, final DNAPL Component Completion Report (TerraTherm and

Golder Associates, 2016b) was distributed to USEPA, CTDEEP and other stakeholders on DVD, and

replacement pages in hard copy when requested, on December 23, 2016, which completes the review and

revision cycle for the DNAPL Component Completion Report. A copy of the December 29, 2016 letter from

USEPA approving the DNAPL Component Completion Report is included in Appendix A.

2.5 East Side Remedial Components

2.5.1 ESRC Maintenance The ESRC construction activities were substantially completed by July 2015. During periodic mobilizations

during the remainder of 2015, NorthStar and the ESRC Team also completed the restoration and erosion

protection of the South Creek bank adjacent to the new south Tidal Wetland (Creation Area C),

decommissioned the pore-water extraction system on the South Pile, completed final details related to the

GWES infrastructure, installed the cover system transition markers requested by CTDEEP, and installed a

pedestrian bridge to improve walkability of the trail system where it crosses the outlet of the North Best

Management Practice (BMP). The locations of the features mentioned above are shown on Figure 2.

NorthStar mobilized to the Site in mid-March 2016 to repair erosion to some limited areas of the ESRC.

The erosion was limited to surface soils and did not impact cover system integrity. The repairs were largely

focused on the South Pile cover system and consisted of replacing gravel on the lower access road on the

South Pile, removing silt from drainage swales, and filling in small erosion channels along the slopes. A

new pipe was placed between two swales in the southern portion of the top of the South Pile to eliminate a

low area of minor ponding. The pipe was installed within the top portion of the clean cover system. Some

minor erosion along the sidewall of the overflow between the northern BMP and the Tier I wetland in the

area between the new foot-bridge was also repaired.

On May 19, 2016, representatives of the Town of North Haven inspected the site and authorized the

removal of silt fence and construction erosion control measures along the access road. As of December

31, 2016 all temporary ESRC construction erosion and sedimentation control measures have been

removed.

As discussed further in Section 3, anomalous groundwater elevations, suggestive of localized infiltration,

were observed at monitoring well GW-HBW15 between late-February and mid-April 2016. On May 26,


January 2017 17 033-6231-004

2016, representatives of NorthStar and Golder Associates investigated the well and discovered evidence

of both a faulty seal between the PVC well casing and the surface riser pipe and damage to the

geomembrane boot surrounding the well. Repairs to the well and replacement of the geomembrane boot

were completed between June 3, 2016 and June 17, 2016.

ASGECI continued the ongoing maintenance and monitoring of the ecological enhancements throughout

2016, as required by the Inland Wetlands Commission Permit to Conduct Regulated Activity and Site Plan

Referral I12-11. In April, irrigation was restarted on the southern portions of the Site, which were the last

areas to have been planted. May and June activities included reseeding and replanting limited areas. By

late July, the plantings were sufficiently established, to allow removal of the waterfowl barrier (i.e., stakes,

string, and reflective flags). Monitoring of the ecological enhancements was conducted periodically between

August 2, 2016 and September 26, 2016.

Purple Loosestrife Integrated Pest Management

Efforts to control invasive species in the ecological enhancement and tidal wetland mitigation areas

continued throughout 2016. ASGECI and Pfizer reached out to the University of Connecticut to discuss an

integrated pest management program to mitigate the purple loosestrife invasive through the use of beetles.

Staff from the University visited the Site on May 24, 2016 and beetle habitats were constructed on the Site

in June. On June 13, 2016, Weeds Inc., under subcontract to the ESRC Team, submitted a request for an

herbicide application permit to CTDEEP related to the control of invasive species. This permit required the


January 2017 18 033-6231-004

submittal of an updated Natural Diversity Data Base (NDDB) review, which was obtained from the CTDEEP

on August 15, 2016 (Appendix A). The herbicide applicator permit, which is valid through December 31,

2018, was approved by CTDEEP on August 25, 2016 (Appendix A). Herbicide application in focused areas

of the Site occurred on October 5 - 6, 2016.

2.5.2 ESRC Reporting The ESRC Construction Completion Report (CCR; NorthStar 2016a) was submitted to USEPA and

CTDEEP for review on June 1, 2016, which achieved the Order Master Plan Schedule Major Milestone

“Submit Construction Completion Report for East Side Areas” (Milestone date March 31, 2020). USEPA

provided comments on the ESRC CCR on August 3, 2016. On August 19, 2016, the CMI Team provided

responses to USEPA’s comments. USEPA approved the response to comments on the ESRC CCR on

August 25, 2016 and CTDEEP confirmed their concurrence with the approval of the ESRC CCR on August

26, 2016 (Appendix A). The final ESRC CCR (NorthStar 2016b) was distributed to USEPA, CTDEEP and

other stakeholders on DVD, and in hard copy when requested, on September 26, 2016, which completes

the review and revision cycle for the ESRC CCR.

Under the terms of CTDEEP Office of Long Island Sound Programs (OLISP) permits #2013005533-KR and

#201410692-KR, Record Drawings (aka as-built drawings) for the completed sediment remediation and

Tidal Wetland Mitigation were to be submitted to CTDEEP OLISP within 90 days of completion of the work.

On August 27, 2015, CTDEEP approved an extension until 4th Quarter of 2015 since the relevant drawings

are part of the larger set of Site ESRC Record Drawings. On December 21, 2015, the ESRC Team

requested and CTDEEP approved a further extension until February 15, 2016.

An Annual Mitigation Monitoring Report is due to the US Army Corps of Engineers (USACE) by December

15th of each year for the tidal wetlands mitigation work associated with Permit NAE 2012-1039. On

December 3, 2015 the ESRC Team requested and USACE approved an extension until January 31, 2016

to prepare and submit the first Mitigation Monitoring Report. On January 27, 2016 USACE approved a

further submittal deadline extension until February 15, 2016 (Appendix A). Based on the revised submission

schedule approved by USACE and OLISP, the first annual Tidal Wetland Mitigation Monitoring Report and

the wetlands mitigation Record Drawings were submitted to CTDEEP OLISP and USACE on February 12,

2016, with courtesy copies provided to the USEPA and CTDEEP Project Managers.

The 2015 ESRC Ecological Enhancements Monitoring Report was submitted to the North Haven Inland

Wetlands Commission on June 29, 2016, with courtesy copies provided to the USEPA and CTDEEP Project

Managers. This monitoring report was required by the Inland Wetlands Commission Permit to Conduct

Regulated Activity and Site Plan Referral I12-11.


January 2017 19 033-6231-004

The 2016 Tidal Wetland Mitigation Monitoring Report, which reports on the second year of monitoring for

the tidal wetland mitigation areas was submitted to CTDEEP OLISP and USACE on December 15, 2016,

with courtesy copies provided to the USEPA and CTDEEP Project Managers. The 2016 Ecological

Enhancements Monitoring Report was submitted to the North Haven Inland Wetlands Commission on

December 29, 2016, with courtesy copies provided to the USEPA and CTDEEP Project Managers.

2.6 West Side Remedial Components

With the substantial completion of the DNAPL remedial component, Pharmacia & Upjohn began exploring

the potential to integrate final remedial actions with redevelopment on the west side of the Site. Pharmacia

& Upjohn initiated a confidential Expression of Interest (EOI) process to identify market interest in future

uses for the west side of the Site. The EOI process was initiated in the first quarter of 2016 with outreach

to the Town of North Haven and state and regional economic development leaders to identify potentially

interested developers. A formal Request for Expressions of Interest was released in February 2016. Several

site tours were conducted and meetings held with potentially interested developers and real estate

professionals in March and April 2016. Initial responses to the EOI were received in April, and based upon

the submittals, Pharmacia & Upjohn requested additional information from select respondents. Responses

to the second request for information from potential developers were received in September 2016, and

based upon the submittals Pharmacia & Upjohn is continuing to evaluate potential redevelopment

opportunities. A decision whether to move forward with one of the responding parties, or to proceed with

installation of the cover system independent of redevelopment, is expected in early 2017.

As previously mentioned, Pharmacia & Upjohn has revised the Order Progress Goal “Submit Draft Final

Design of West Side Remedial Components (WSRC)” to March 31, 2018 to allow time to complete the EOI

process and determine whether the design of the WSRC cover system will incorporate redevelopment at

this point, or whether an initial cover system will be installed which could be modified in the future to

accommodate redevelopment. Revising the Progress Goal date associated with the submittal of the Draft

Final Design of the WSRC to March 31, 2018 is not anticipated to impact the ability to achieve the May 29,

2020 Major Milestone associated with “Submit the Construction Completion Report for West Side Areas”.

2.7 Community Outreach

Pfizer and the CMI Team have conducted a number of local meetings and presentations as part of

implementing the Community Relations Plan (Appendix H of the CMI Work Plan; Golder, 2012b). Key

community outreach activities during 2016 included:

The CMI Team maintained regular contact with the Town of North Haven throughout the year to inform them of construction activities and work hours, public outreach events, and to discuss redevelopment opportunities related to the west side of the property.

The CMI Team continued to post information about CMI progress on the project website at www.UpjohnNorthHaven.com, and to maintain the Site Repository digital library which


http://www.upjohnnorthhaven.com/

January 2017 20 033-6231-004

can be accessed at the North Haven Memorial Library. CMI Team members met the new Director of the North Haven Public Library on September 14, 2016 to review the North Haven Document Repository and how to access the information.

The CMI Team reached out to the Town of North Haven Emergency Response organizations via email during the first quarter of 2016 to inform them of the site activities planned for 2016. Outreach was made to the Police, Fire and Public Works departments.

Representatives of the CMI Team attended the biannual North Haven Economic Development Breakfast meetings held April 14, and October 20, 2016 to interact with local stakeholders.

On April 9, 2016, the CMI Team hosted a booth at the annual North Haven Earth Day event to engage with local stakeholders and communicate site progress.

The CMI Team participated in the June 23, 2016 meeting of the North Haven Citizens’ Advisory Panel (CAP). The presentation to the CAP focused on the completion of the ISTR operations and east side corrective measures, as well as green and sustainable remediation efforts conducted at the site.

The CMI Team held a showcase event on October 1, 2016 for officials from the Town of North Haven, members of the CAP, and other community stakeholders such as the North Haven Land Trust, and The North Haven Trails Association to celebrate the completion of the ESRC.

The CMI Team made a presentation before the North Haven Inland Wetland Commission on November 30, 2016 on the ESRC, with an emphasis on the newly created inland wetlands and ecological restoration. The presentation was well received and the Commission thanked Pharmacia & Upjohn for their efforts.

News articles reporting on progress at the Site appeared in The North Haven Citizen on October 3, 2016 and in the Meriden Record Journal on October 2, 2016.

North Haven Earth Day

The Site also participated in several outreach activities that reached a wider public audience. In particular:

The Pharmacia & Upjohn Site was recognized for its sustainability initiatives and green remediation best management practices. The project received the 2016 GreenCircle


January 2017 21 033-6231-004

Sustainability Award from CTDEEP during a ceremony on May 23, 2016. Articles on the GreenCircle Award, and the Site appeared in the Hartford Business Journal on May 31, 2016 and August 22, 2016.

A Site tour was conducted on August 16, 2016 for representatives of USEPA and participants from the 2016 Tribal Lands & Environment Forum, which was hosted by the Mohegan Sun Resort in Uncasaville, CT.

Tribal Environmental Professionals tour the ESRC


January 2017 22 033-6231-004

3.0 DATA SUMMARY AND CONCLUSIONS

The Order includes a requirement to conduct groundwater monitoring both during corrective measures

implementation (CMI groundwater monitoring) and during long-term OM&M following the completion of

remedy construction (post-CMI groundwater monitoring). The Post-CMI Groundwater Monitoring Plan,

approved as Appendix D of the ESRC CMDR, made provisions to adapt the groundwater monitoring to

changes in Site conditions and linked the process of communicating the modifications to the groundwater

monitoring program to USEPA and CTDEEP to the Annual Reports. Accordingly, the intended groundwater

monitoring to be implemented in 2016 was described in Section 6.1 of the 2015 Annual Report. USEPA

reviewed Section 6.1 of the 2015 Annual Report and on March 9, 2016 confirmed that they had no

comments on the proposed 2016 monitoring program (see Appendix A).

Section 6.1 of the 2015 Annual Report laid out ten objectives for the groundwater data collection activities

to be conducted during 2016. The routine monitoring objectives, and the associated monitoring activities,

were drawn from the monitoring programs described in the Post-CMI Groundwater Monitoring Plan. The

Full-Scale ISTR FD and the SEC-7D PDI/PDP also described CMI groundwater monitoring activities, which

are captured in these objectives. The objectives for groundwater monitoring in 2016 were as follows:

Objective 1: Monitor Unit 1 Groundwater Hydraulic Control

Objective 2: Evaluate Post-ESRC Groundwater Flow Directions in Units 1

Objective 3: Monitor Unit 1 Groundwater Quality Outside the HBW

Objective 4: Monitor Unit 3 & 4 Groundwater Flow Directions and Vertical Gradients

Objective 5: Demonstrate Compliance with Unit 3 Performance Standards at Downgradient Property Boundary

Objective 6: Monitor Groundwater Chemistry in the Vicinity of Unit 3 Well SEC-7D

Objective 7: Monitor Changes in Unit 3 Groundwater Quality During Full Scale ISTR

Objective 8: Post-ESRC Unit 3 Synoptic Monitoring

Objective 9: GW-U402B and Post-ESRC Unit 4 Monitoring

Objective 10: Monitor Well GW-LP01

Section 3 of the 2016 Annual Report summarizes the data collected to monitor operations of the GWES

and GWTF, and the groundwater monitoring data collected during 2016 in accordance with the objectives

described above.

3.1 Assessment of Performance of the Groundwater Extraction Systems and Groundwater Treatment System

3.1.1 Summary of GWES Operations and Maintenance During the 2016 monitoring period, Pharmacia & Upjohn operated the Post-ESRC GWES consisting of

extraction wells PW-1R, PW-2RA, PW-4R, PW-9, PW-10, PW-16A, TPW-1N, and the extraction sumps


January 2017 23 033-6231-004

within both the north and the south groundwater collection trenches (S1N, S2N, S2S, and S1S)9. The

locations of the GWES extraction wells and sumps are shown on Figure 2. Table 1 summarizes the screen

length and placement for the extraction wells and the surrounding monitoring wells.

During the 2016 monitoring period, the GWES was operated to maintain target water elevations in the

extraction wells and collection trenches. Flow rates from each extraction well were varied by changing pump

speed via variable frequency drives (VFD) to achieve the target elevations. As discussed in Section 3.1.3,

these target elevations were modified periodically, based on the data collected as part of the hydraulic

control monitoring. Daily averages of instantaneous pumping rates are summarized in Table B-1 in

Appendix B. The flow readings from PW-16A prior to May 17, 2016 are believed to underestimate the flow

due to a malfunctioning flow meter. Since the PW-16A flow meter was repaired, the total average

instantaneous pumping rate for the GWES has ranged from 52 to 79 gallons per minute (gpm), and

averaged 61 gpm.

During the 2016 reporting period, maintenance and redevelopment activities continued at the Site to

improve groundwater extraction efficiency and/or repair extraction well components. The extraction wells

were maintained on an as-needed basis as part of the preventative maintenance program to help achieve

consistent performance and as needed based on observed increases in VFD speed and decreased

pumping rate. Pharmacia & Upjohn maintains an emergency spare parts inventory on site. Inventory items

include pump heads and motors, flow sensors and meters, and electrical leads for the extraction well

system. In addition, spare electrical conduit and power lines to the extraction wells have been installed as

part of Site improvements. Appendix B summarizes the extraction well maintenance activities performed

and significant events that occurred during the 2016 monitoring period. A notable maintenance activity

included changing the type of pump installed in the North Groundwater Collection Trench from the

Blackhawk piston pump originally specified by the ESRC design to a Grundfos submersible pump with a

VFD equivalent to those installed in the extraction wells. This post-construction pump modification was

made to aid in future maintenance of the extraction sumps.

3.1.2 Treatment System Monitoring Pharmacia & Upjohn also continued to operate, monitor, and maintain the GWTF to treat the extracted

groundwater and the CMI wastewater flows. The GWTF at the Site consists of a Fluidized Bed Reactor

(FBR) Unit (installed in 1995), a Solids Removal System (SRS) (installed in 2001), and an Ultraviolet

Light/Hydrogen Peroxide (UV/Oxidation) System (installed in 2001). The FBR Unit degrades organic

compounds with activated biological growth attached to suspended carbon media. The SRS removes

suspended solids, metals, and some organics adhered to the solids from the FBR effluent. The

9 Well PW-5R was taken offline in February 2015 due to operational issues. As hydraulic control in this portion of the Site was sufficiently maintained by PW-1R and PW-4R, PW-5R was not operated during 2016. The well is being maintained as part of the GWES as a contingency groundwater extraction location. g:\projects\2003 projects\033-6231-004 nhaven\200 reports\210 annual rpt\2016\2016 annual rpt_0336231004_013017.docx

January 2017 24 033-6231-004

UV/Oxidation System further degrades the organic compounds by using ultraviolet light in conjunction with

hydrogen peroxide to oxidize and destroy the compounds. The GWTF operates and is monitored under a

NPDES permit (CT0001341) issued by CTDEEP that regulates the treatment of groundwater and the

subsequent discharge of the treated water to the Quinnipiac River.

Granulated Activated Carbon (GAC), multi-media filters, upgraded pumps feeding the GAC vessels, in-line

ultraviolet transmittance sensors downstream of the GAC vessels, and minor modification to the piping

system for the equalization tanks to provide greater backflow prevention and containment were added to

the GWTF in 2015 to pre-treat the wastewater streams from full-scale ISTR operations. These modifications

to the GWTF were approved by CTDEEP under RCSA 22a-430-3(i) on March 18, 2015. The pre-treatment

system was operated in a batch mode beginning in May 2015 through the completion of the ISTR

decommissioning in July 2016.

The total volume treated by the GWTF during the 2016 reporting period is estimated to be approximately

37,411,550 gallons. The material treated by the GWTF included groundwater extracted from the perimeter

of the Site by the GWES, and wastewater generated by full-scale ISTR operations which included

groundwater extracted from DNAPL Subareas A and B, condensate and scrubber blowdown, and

decontamination waters. Approximately 576,000 gallons of wastewater generated by ISTR processes were

pretreated prior to introduction into the main process train of the GWTF.

3.1.3 GWES Hydraulic Control Monitoring During 2016, GWES monitoring included the collection of manual and continuous water level monitoring

data to verify hydraulic control of Unit 1 groundwater. Groundwater level monitoring was conducted, in

accordance with Objectives 1 and 2 in Section 6.1 of the 2015 Annual Report, to evaluate changes in Unit

1 groundwater elevations as a result of CMI and equilibration of the Site to post-ESRC conditions and to

assess post-ESRC Unit 1 groundwater flow patterns, elevations, and gradients. Once these evaluations

were completed, groundwater extraction rates were adjusted, if needed. Manual groundwater elevation

readings are included in Appendix C-1 and continuous groundwater elevation data are presented in

Appendix C-2.

Consistent with the Post-CMI Groundwater Monitoring Plan, the correlation of groundwater elevation

measurement with tides is no longer required following installation of the HBW; however, during 2016

groundwater elevation measurements were targeted toward low-mid-tide to allow for Site groundwater

levels exterior to the HBW to be influenced by an approximately one-hour slack high tide followed by four

hours of ebbing tide prior to water level collection10. In general, the manual measurements indicate Unit 1

groundwater flows from west to east, toward the GWES, from a high elevation of approximately 12 to 14

10 Low-mid-tide is defined to be five hours after high groundwater elevation occurs at MP-22S. g:\projects\2003 projects\033-6231-004 nhaven\200 reports\210 annual rpt\2016\2016 annual rpt_0336231004_013017.docx

January 2017 25 033-6231-004

feet National Geodetic Vertical Datum of 1929 (NGVD29) on the west side of the Site to less than 0 feet

NGVD29 on the east side of the Site where groundwater is collected by the GWES. Unit 1 groundwater

hydraulic control is shown on Figures 4 and 5 by the depressions in the Unit 1 groundwater surface depicted

inside the HBW on the northern, eastern, and southern perimeters of the Site and groundwater and surface

water (i.e., the Quinnipiac River) exterior to the HBW and the Site.

The continuous monitoring data presented in Appendix C-2 shows the effectiveness of the GWES and HBW

at maintaining Unit 1 groundwater within the HBW at elevations lower than those measured in the exterior

monitoring points (monitoring wells or the Quinnipiac River) during the 2016 monitoring period. Following

completion of the final ESRC GWES control system, these low interior groundwater elevations were

maintained by the establishment of a set point within each extraction well or sump. If continuous monitoring

data indicated of the potential for an outward gradient, then the extraction well level set point was changed

(or extraction well rehabilitated) to reestablish inward gradients. The continuous monitoring data and the

corrective actions taken to re-establish inward gradients are discussed in Appendix C-2.

In summary, these manual and continuous groundwater level data indicated that the GWES provided

hydraulic control of Unit 1 groundwater. This conclusion is consistent with the findings of previous hydraulic

control analyses (see previous Annual Reports).

3.2 Groundwater Quality Monitoring

This section presents and discusses the groundwater monitoring data collected to achieve Objectives 3

and 5, which are derived from the Post-CMI Groundwater Monitoring Plan. The approved Post-CMI

Groundwater Monitoring Plan described the intended monitoring network, procedures for groundwater

monitoring, and associated Quality Assurance (QA) protocols for groundwater sampling and analyses at

the Site during the first two to three years following completion of ESRC construction. The year 2015 was

considered the first year of post-ESRC monitoring as the ESRC construction was considered complete in

July 2015.

3.2.1 Groundwater Data Collection and Review Activities Post-ESRC Groundwater Sampling and Analyses

The second year of the post-ESRC groundwater monitoring program was conducted 2016. In September

2016, samples were collected from ten Unit 1 wells located outside the HBW (GW-NFPA07, GW-HBW03,

GW-HBW11, GD-5S, DM-5S, DM-7S, GW-HBW12, GW-HBW06, GW-HBW13, and GW-HBW07) and

seven perimeter Unit 3 wells (GD-3D, GD-4D11, MP-20DR, DM-5D, DM-7D, DM-9D, MW-35D).

11 Samples were also collected from wells GD-3D and GD-4D in April 2016 in support of Objective 6. The results from these samples are discussed in Section 3.3 and Appendix F-1. g:\projects\2003 projects\033-6231-004 nhaven\200 reports\210 annual rpt\2016\2016 annual rpt_0336231004_013017.docx

January 2017 26 033-6231-004

The samples were collected in accordance with the sampling procedures provided in the Post-CMI

Groundwater Monitoring Plan. Wells DM-5S, DM-7S, GD-5S, GW-HBW03, and GW-HBW11, which show

tidal influence, were sampled between two and six hours following low tide. Wells GW-HBW12 and

GW-HBW13, which show little temperature variation with tidal changes were sampled during the four-hour

period following low tide. Wells GW-HBW07 and GW-HBW06 were sampled during the two-hour period

following low tide. The Unit 3 samples were collected without reference to the tidal cycle.

All groundwater samples were submitted to Alpha Analytical, who utilized both their Mansfield and

Westborough, MA facilities to perform the requested VOC and SVOC analyses. The specific sampling dates

and parameters for analysis are summarized in Table 2.

Data Quality Review

In accordance with the Post-CMI Groundwater Monitoring Plan, the data reported by the analytical

laboratory underwent a data quality assessment to identify quality issues which could affect the use of the

data. After completion of the data quality assessment, 99.8 percent of the groundwater sample data

reported by Alpha were found to be acceptable for project use, which met the project completeness goal of

85 percent. The detailed findings of the data quality assessment are presented in Appendix D along with

tables summarizing the laboratory results with the qualifiers applied. Laboratory data reports, which include

the Chains-of-Custody, are provided on CD-ROM in Appendix E. The routine post-ESRC groundwater

monitoring samples were collected concurrently with samples that were collected to fulfill other monitoring

objectives. Therefore, Appendices D and E address and include all of the data reported by Alpha in 2016.

3.2.2 Comparative Criteria This Annual Report evaluates the groundwater analytical data in relation to two sets of comparative criteria.

The first set of comparative criteria is the groundwater Media Protection Standards (MPS) defined in

Attachment 2, Tables 3 and 4, of the Order. As explained in the footnotes to Tables 3 and 4 (Order

Attachment 2) and as further clarified in Appendix J of the CMS, the criteria used to develop the MPS were

based on 1) provisional (draft) RSR values which were advanced by CTDEEP in 2007 (CTDEEP, 2007)

and subsequently withdrawn in May 2009, as well as 2) RSR values for Additional Polluting Substances

(APS) proposed by Pharmacia & Upjohn in June 2007 (Golder, 2007). As noted in the footnotes on Tables

3 and 4 of the Order, “The criteria provided as MPS are subject to change based on revisions to the RSRs,

among other factors. The promulgated RSRs or approved Site-specific RSRs for APS at the time of remedy

implementation are the applicable MPS.”

The second set of comparative criteria is the CTDEEP RSRs. The RSR comparative criteria used in the

2016 Annual Report and the approach to comparing the 2016 data to the comparative criteria are the same

as those used in the 2015 Annual Report. The RSR criteria are currently in transition while CTDEEP


January 2017 27 033-6231-004

implements a multi-year transformation in the statues and regulations underlying the Site cleanup program

in accordance with the requirements of Public Act 12-196 (CTDEEP, 2012b). In June 2013, CTDEEP

promulgated the first wave of revisions to the RSRs. However, with the exception of revisions to the criteria

for Total Petroleum Hydrocarbons (TPH) and lead, did not revise the Surface Water Protection Criteria

(SWPC) and the Industrial/Commercial Volatilization Criteria (ICVC) criteria from those originally published

in 1996. The June 2013 revisions to the RSRs also formalized the withdrawal of certain of the interim criteria

previously used for comparative purposes in previous Annual Reports. On December 10, 2015, CTDEEP

released selected APS and alternative criteria12 that could be requested for expedited Site-Specific

approval (CTDEEP, 2015c). These criteria are based on recent toxicological information for these

chemicals, provide updated criteria for many common chemicals, but do not include criteria for all the

chemicals for which Site-specific APS were developed and approved.

The RSR criteria used in the Annual Reports also include the RSRs for APS criteria approved by CTDEEP

for Site-specific use in December 2008 (CTDEEP, 2008) and March 2012 (CTDEEP, 2012a)13.

After discussion with CTDEEP, the hierarchy of RSR criteria, in descending order, used for comparative

purposes in the 2015 and 2016 Annual Reports is as follows:

Surface Water Protection Criteria

The SWPC promulgated in Appendix D of the June 2013 RSRs

The RSRs for APS criteria approved by CTDEEP for Site-specific use in December 2008

The SWPC Alternative criteria published for potential approval on December 10, 2015, when no Site-Specific APS criteria had been approved14

Industrial/Commercial Volatilization Criteria

The 2003 revised criteria for the chemicals where ICVC are promulgated in Appendix E of the June 2013 RSRs, which are still approvable for Site-Specific Use.

The RSRs for APS criteria approved by CTDEEP for Site-specific use in December 2008 and the criteria for naphthalene approved March 2012.

The ICVC Alternative criteria published for potential approval on December 10, 2015, when no Site-Specific APS criteria had been approved15

The above MPS and RSR comparison criteria, along with the target compounds for each analysis, are

summarized on Table 3. The SWPC MPS and RSRs apply to all water bearing units at the Site, while the

12 http://www.ct.gov/deep/cwp/view.asp?a=2715&q=484634&deepNav_GID=1626 13 The Site-specific ICVC for naphthalene of12 ug/l was revised to 3,099 ug/L by CTDEEP in March 2012. 14 For example, the generic SWPC for 1,4-dioxane released in December 2015 is 960 ug/L, and was calculated using a generic dilution factor of 10. The site-specific SWPC for 1,4-dioxane is 5,300 ug/L and incorporates a Site-Specific dilution factor. For the purposes of this report, the site-specific SWPC of 5,300 is being considered the compliance concentration for 1,4-dioxane. The affected VOCs and SVOCs are 1,1-dichloroethane, cis-1,2-dichloroethene, total xylenes, aniline, benzidine, carbazole, 4-chloroaniline, 3,3’-dichlorobenzidine, 1,4-dioxane, 1-methylnaphthalene, naphthalene, phenanthrene, 1,2,4-trichlorobenzene. 15 Chloroethane and 1-methylnaphthalene have both a site-specific and a 2015 Alternative ICVC criteria. g:\projects\2003 projects\033-6231-004 nhaven\200 reports\210 annual rpt\2016\2016 annual rpt_0336231004_013017.docx

http://www.ct.gov/deep/cwp/view.asp?a=2715&q=484634&deepNav_GID=1626

January 2017 28 033-6231-004

ICVC MPS and RSRs only apply to Unit 1 groundwater, in particular that portion of Unit 1 groundwater

within 15 feet of the ground surface or a building.

3.2.3 Unit 1 Groundwater Sample Results While the primary objective of collecting the Unit 1 groundwater sample data in 2016 was to monitor

groundwater quality to allow future assessment of attenuation of residual Unit 1 groundwater impacts

outside the HBW, the Unit 1 groundwater sample results have been compared to the SWPC and ICVC

criteria discussed above. The compounds detected in the Unit 1 groundwater samples are summarized in

Table 4 and the concentrations of compounds exceeding one or more of the comparative criteria indicated.

Complete results for the Unit 1 sample analyses (which include non-detected compounds) are provided in

Appendix D.

As shown in the results summarized in Table 4, the following compounds were detected above the SWPC

comparative criteria in one or more Unit 1 monitoring locations outside the HBW during 2016:

Benzidine

2-Chloroaniline

3,3’-Dichlorobenzidine

All of the 2016 results were below the ICVC comparative criteria in the post-ESRC Unit 1 monitoring

locations outside the HBW.

The concentration of the five primary organic compounds identified in Unit 1 groundwater at the Site

(benzene, chlorobenzene, 1,4-dioxane, 2-chloroaniline, and 3,3’-dichlorobenzidine16) along with the

additional chemicals that exceed one or more of the comparative criteria in 2015 or 2016 are summarized

on Figure 6.

With two exceptions, all sample results from the six wells in the northern portion of the Site (GW-NFPA07,

GW-HBW03, GW-HBW11, GD-5S, DM-5S, and DM-7S) are below the comparative criteria. The exceptions

are:

The concentration of benzidine in the field duplicate sample from well DM-5S (1.4 J ug/L) was between the SWPC MPS (1 ug/L) and the approved site-specific SWPC (26.5 ug/L). While benzidine was not detected in the primary sample (< 0.45 UJ ug/L), benzidine has previously been detected in the well, most recently in 2006 (2 J ug/L). As the results are below the approved site-specific SWPC, and are consistent with historical groundwater data, this detection is not of concern.

The concentration of 3,3’-dichlorobenzidine in the field duplicate sample from well DM-5S (1.7 J ug/L) was between the SWPC MPS (0.850 ug/L) and the approved site-specific SWPC (12.19 ug/L). While 3,3’-dichlorobenzidine was not detected in the primary sample (< 0.48 UJ ug/L), the field duplicate results are consistent with the July and October 2015

16 These five organic compounds are considered to be the primary organic compounds on-site, based on frequency and/or magnitude of detection. These five compounds were previously identified as compounds of concern (COCs). g:\projects\2003 projects\033-6231-004 nhaven\200 reports\210 annual rpt\2016\2016 annual rpt_0336231004_013017.docx

January 2017 29 033-6231-004

samples from DM-5S (2.0 and 2.7 ug/L, respectively). These results are also consistent with historical results from groundwater samples collected before ESRC construction, where concentrations between non-detect and 5 ug/L have been reported in DM-5S in the eight samples collected between September 2003 and March 2007. As the results are below the approved site-specific SWPC, and consistent with known impacts in well DM-5S, they are not of concern.

The following two exceedances observed in 2015 did not persist in 2016:

The July 2015 sample from well DM-7S contained 3,3’-dichlorobenzidine (1.2 J ug/L) at a concentration between the SWPC MPS (0.850 ug/L) and the approved site-specific SWPC (12.19 ug/L). 3,3’-Dichlorobenzidine was non-detect in the September 2016 sample (< 0.48 U ug/L).

The concentration of vinyl chloride in the September 2016 sample and field duplicate sample from GW-NFPA07 (42 ug/L and 40 ug/L, respectively) was below the ICVC RSR (52 ug/L). This represents a decrease from the October 2015 sample (54 ug/L) and is consistent with the generally decreasing vinyl chloride concentrations observed since 2005 in well GW-NFPA07. Concentrations of vinyl chloride in GW-NFPA07 have decreased from 190 ug/L in December 2005 and 110 ug/L in October 2013 to 42 ug/L detected during the most recent sampling event. Well GW-NFPA07 is not located within 15 feet of any currently existing occupied buildings and, due to the location on the Site perimeter, is unlikely to be within 30 feet of future buildings; therefore, the presence of vinyl chloride at concentrations above the ICVC comparative criteria are not of concern.

As in 2015, the remainder of the sample results above the comparative criteria are from groundwater

samples collected from the four wells installed immediately outside the HBW adjacent to the South Pile.

While the concentration of 2-chloroaniline in groundwater from wells GW-HBW06 (160 ug/L) and GW-HBW07 (62 ug/L) are above the Site-specific SWPC (53 ug/L), the concentrations of 2-chloroaniline in these wells have decreased since October 2015 (340 ug/L in GW-HBW06 and 260 ug/L in GW-HBW07). The concentration of 3,3’-dimethylbenzidine has also decreased in these wells and the concentrations in the September 2016 samples are below the comparative criteria.

The concentration of 2-chloroaniline in well GW-HBW12 (88 ug/L) remains above the Site-specific SWPC and is of a similar concentration as the October 2015 sample (72 ug/L). Benzidine was also present in the September 2016 sample from well GW-HBW12 (3.5 ug/L) at a concentration between the MPS (1 ug/L) and the Site-specific SWPC RSR (26.5 ug/L).

The concentration of benzene in well GW-HBW13 has decreased from 380 ug/L detected in October 2015

to 210 ug/L and is now below the comparative criteria. The concentration of 2-chloroaniline in well GW-

HBW13 has also decreased from 55 J ug/L in October 2015 to 36 ug/L in September 2015 and is also now

below the comparative criteria.

3.2.4 Unit 3 Groundwater Sample Results Groundwater samples were collected from seven Unit 3 wells (GD-3D, GD-4D, DM-5D, DM-7D, DM-9D,

MP-20DR, and MW-35D) to monitor conditions at the downgradient Site perimeter during September 2016.

The primary objective of these Unit 3 samples was to assess whether chemical concentrations in Unit 3


January 2017 30 033-6231-004

groundwater at the Site perimeter remain below the comparative criteria and thereby meet the Unit 3

Performance Standards presented in the Order. The chemicals detected in Unit 3 groundwater in these

routine post-ESRC Unit 3 monitoring samples are summarized in Table 5, where they are compared to the

SWPC criteria described above. Complete results for the Unit 3 sample analyses (which include non-

detected results) are provided in Appendix D.

As shown on Figure 7, with one exception, all results from the Unit 3 Site perimeter monitoring samples

collected as part of the routine post-ESRC monitoring were below the comparative criteria. The exception

is the result for benzidine (4.3 ug/L) in well DM-7D, which was greater than the SWPC MPS (1.0 ug/L) but

less than the Site-Specific SWPC (26.5 ug/L). While the result for benzidine in well DM-7D was greater

than the SWPC MPS, the chemistry results for organic compounds in the downgradient Site perimeter wells

sampled as part of the 2016 post-ESRC groundwater monitoring program are all below the RSR and APS-

based SWPC criteria, which are the compliance criteria for the Site.

3.3 Other Data Generated

As discussed in Section 2.0, a number of non-routine data collection activities were performed in support

of various CMI activities. The results from the analysis of these samples are provided in appendices to this

Annual Report.

3.3.1 Additional Unit 3 Groundwater Monitoring In addition to the Site perimeter Unit 3 groundwater samples collected as part of the post-ESRC compliance

monitoring, during 2016 Pharmacia & Upjohn collected additional groundwater samples from Unit 3 and

deep unconfined groundwater wells present on the property to gather data relevant to the following

objectives:

Objective 6: Monitor Groundwater Chemistry in the Vicinity of Unit 3 Well SEC-7D

Objective 7: Monitor Changes in Unit 3 Groundwater Quality During Full Scale ISTR

Objective 8: Post-ESRC Unit 3 Synoptic Monitoring

In support of these objectives, groundwater samples were collected from seven Unit 3 wells (GD-3D,

GD-4D, GW-U305, GW-U311, GW-U312, GW-U313, SEC-7D), and two deep unconfined aquifer wells

(GW-HBW17 and GW-U309) between April 18, 2016 and April 19, 2016 as part of the combined spring

2016 groundwater monitoring event to monitor groundwater conditions downgradient of full-scale ISTR and

in the vicinity on Unit 3 monitoring well SEC-7D. Groundwater samples were collected between September

19, 2016 and September 23, 2016 from the 25 Unit 3 wells present on Site in 2016 to provide data regarding

groundwater conditions downgradient of full-scale ISTR, in the vicinity on Unit 3 monitoring well SEC-7D,

and to assess changes in groundwater quality since the pre-ESRC baseline monitoring in 2011.

Groundwater samples were also collected from four shallow Unit 1 wells (GW-HBW16, GW HBW19, GW-

U103, and TPW-1N) to provide continued monitoring of shallow groundwater in the vicinity of Unit 3


January 2017 31 033-6231-004

monitoring well SEC-7D between September 19, 2016 and September 23, 2016. The data collected during

2016 in support of Objectives 6, 7, and 8 are discussed in an integrated fashion in Appendix F-1. The data

quality assessment for this data was integrated with the data quality assessment for the post-ESRC

monitoring data and is provided in Appendix D. The laboratory data packages are provided in Appendix E.

3.3.2 Unit 4 Groundwater Monitoring Between September 19, 2016 and September 23, 2016 Pharmacia & Upjohn voluntarily collected samples

from the ten Unit 4 wells present on the property (GD-1BR, GD-2BR, GD-4BR, GD-5BR, GD-6BR, GD-

9BR, GW-U402B, GW-U403, GW-U404, and GW-U405). In addition to providing data to evaluate changes

in groundwater chemistry since the last round of synoptic monitoring was completed immediately prior to

the start of ESRC construction in 2011, these samples were used to monitor groundwater quality in the

vicinity of well GW-U402B. The data collected as part of the Unit 4 groundwater monitoring, in support of

Objective 9, are discussed in Appendix F-2. The data quality assessment for the 2016 Unit 4 data was

integrated with the data quality assessment for the post-ESRC monitoring data and is provided in Appendix

D. The laboratory data packages are provided in Appendix E.

3.3.3 GW-LP01 Monitoring In accordance with Objective 10, Pharmacia & Upjohn gauged the LNAPL thickness in GW-LP01 on an

approximately quarterly basis throughout 2016 to confirm that LNAPL is not re-accumulating in the well and

that it has been removed to the extent practicable, as required by Connecticut regulation RCSA 22a-449(d)-

106(f). The results of these observations are discussed in Appendix F-3.


January 2017 32 033-6231-004

4.0 ASSESSMENT OF PERFORMANCE OF CORRECTIVE MEASURES

The Order requires that the Annual Report provide an assessment of the performance of the Corrective

Measures during the previous year. The ESRC, which include the Unit 1 groundwater hydraulic controls,

cover systems on the east side of the site, focused remediation of sediment in Tidal Flat No. 1 and 2 and

the South Creek, and the installation of ecological enhancements, were completed in 2016. The full-scale

ISTR treatment of DNAPL subareas A and B was also completed in 2016, which completes the DNAPL

Corrective Measure. The remaining final “Corrective Measures” as defined by the Order, are in process of

design, construction, or operation and have not been completed to date. Therefore, this section of the 2016

Annual Report discusses the effectiveness of the Corrective Measure components that have been

constructed to date, namely the Unit 1 groundwater hydraulic controls and final cover systems constructed

on the eastern portion of the Site as part of the ESRC, along with the remaining IRM and interim covers

remaining in place on the west side of the Site. Subsequent Annual Reports will provide specific

assessments of the performance of the final Corrective Measures once they are fully constructed at the

Site and when appropriate, will discuss progress toward achievement of the Order Performance Standards.

The groundwater migration controls and direct exposure controls described below, along with the ongoing

Site management procedures and institutional controls (as discussed in Section 5.0) will continue to

mitigate and provide protection of human and environmental exposures to impacted media throughout the

CMI period until final Corrective Measures are fully implemented at the Site.

Groundwater Migration Controls

Pharmacia and Upjohn installed, operates, and maintains the Unit 1 groundwater hydraulic controls, which

include the GWES and the state-of-the-art GWTF, that control potential threats to human health and the

environment from releases of groundwater to surface waters (i.e., Quinnipiac River, North Creek and South

Creek) by providing effective containment and treatment of impacted groundwater. The performance of the

post-ESRC GWES which is a final Corrective Measure, and the GWTF are discussed in Section 3.1 of this

Annual Report. Consistent with the findings of previous hydraulic control analyses, in 2016 the HBW in

conjunction with the GWES operation provided effective hydraulic control of Unit 1 groundwater.

Direct Exposure Controls

Prior to the start of CMI in 2011, Pharmacia & Upjohn had installed IRM and various RCRA and non-RCRA

covers to mitigate human and ecological direct contact with impacted soil and WWTR and institutional

controls such as perimeter fencing to prevent unauthorized entry. Based on these IRM covers and

institutional controls, USEPA approved stabilization measures under the Environmental Indicators for

Current Human Exposures Under Control (CA-725) in 1999. In essence, this meant that there were no

unacceptable human exposures to soil/WWTR at the Site, based on the Site uses in 1999.


January 2017 33 033-6231-004

As described in Section 2.0, construction of the ESRC is complete and the impacted media located on the

east side of the Site is covered by the approved low permeability and protective barrier covers. These ESRC

cover systems effectively prevent both human and ecological direct contact exposures. Routine inspections

during 2016 confirmed that these final corrective measure cover systems continued to function as designed.

On the western side of the Site, after decontaminating, decommissioning and removing former

manufacturing buildings and storage tanks, Pharmacia & Upjohn paved the majority of the western portion

of the Site (including the Former Production Area) with asphalt to mitigate direct exposures in 1993. During

2013 and 2014, a portion of the interim asphalt cover along the northwestern and southwestern property

boundaries was disturbed to install the groundwater extraction trenches and the other infrastructure related

to the post-ESRC GWES. The disturbed areas were repaired with asphalt pavement (in the south) or

asphalt millings (in the north) that prevent direct contact to underlying impacted media.

Pharmacia & Upjohn installed a chain-link fence and locking gates around the north, west, and south

property boundaries, installed warning signs, and provided 24-hour per day Site security to minimize

unauthorized entry to impacted areas of the Site. Pharmacia & Upjohn also constructed an IRM for the

Relic Firewater Pond, which provides a geosynthetic membrane and soil cover to prevent human and

ecological exposures.

In August 2014, the interim asphalt cover in a portion of the Former Production Area was disturbed as part

of constructing the full-scale ISTR system in Subareas A and B. The clean fill and concrete thermal covers

placed over Subareas A and B during construction of the Target Treatment Zone (TTZ), and the concrete

and gravel equipment pads that hold the process treatment equipment prevented direct contact to

underlying contaminated media through the ISTR operations and decommissioning during the first half of

2016. During operations and decommissioning, the ISTR TTZ was surrounded by physical barriers to deter

entry and warning signs alert site personnel of the hazards associated with the operating ISTR system and

decommissioning activities. As part of the ISTR decommissioning, the TTZ infrastructure for Subarea B

was removed and the pavement in Subarea B adjacent to the GWTF was restored. The imported fill layer

and thermal cover material from Subarea B was relocated adjacent to Subarea A and stabilized as

described in the DNAPL Component Completion Report. The Subarea A well-field cover, the relocated fill

layer, and the new asphalt cover system over Subarea B are being utilized as interim cover systems to

prevent human contact with impacted soils within the former production area until such time as the final

cover system for the West Side of the Site is designed and constructed. These IRMs continue to effectively

protect against direct contact exposures to impacted environmental media on the western side of the site.


January 2017 34 033-6231-004

5.0 INSTITUTIONAL CONTROL MONITORING ACTIVITIES

The Order defines institutional controls as “(a) the prohibitions of various land and water use activities set

forth by Section VII.B.5.d and e of this Order to limit human exposure to the contaminants at the Facility

and ensure the protectiveness of the Corrective Measures as well as (b) the Environmental Land Use

Restrictions (ELURs) that Respondent shall put into place pursuant to Section VII.B.5.b of this Order.”

Section V.B.5.c of the Order requires that as part of the Annual Report, the Respondent shall confirm that

it has conducted long-term institutional control monitoring activities. The majority of the institutional controls

identified in the Order, in particular the ELURs, will not be implemented until after completion of Corrective

Measures construction. However, several institutional controls have been implemented at the Site, are

incorporated into Site OM&M, and have been monitored during the 2016 CMI reporting period as

summarized below. This section of the Annual Report serves to fulfil the requirement to at least annually

report to USEPA and CTDEEP that the institutional control monitoring activities required by the Order have

been completed.

Site-Wide Controls

Woodard & Curran is the contractor hired by Pharmacia & Upjohn to maintain a 24-hour per day on-site

presence, control the automatic locking Site entrance gate, and to operate and maintain the GWES and

GWTF. Unauthorized entry into the accessible portions of the western side of the Site is restricted by a

chain link fence installed around the western boundary and portions of the northern and southern boundary.

Access through the fenced area is controlled by three gates which are locked 24 hours a day when not in

use. A key card entry lock system and a surveillance camera is installed at the front gate (41 Stiles Lane).

The entry points include signage identifying that portions of the Site are undergoing environmental

remediation. All Site visitors are required to sign in upon entry to the Site and to obey Site health and safety

requirements. The primary visitor sign-in area is located in the south GWTF building entrance and managed

by Woodard & Curran.

All fences, gates, and security measures are checked periodically for vandalism or other evidence of

trespassing and the gates are checked to ensure they are locked and locks are in working order. Woodard

& Curran staff is present on-site 24 hours per day and security checks of controlled areas are made several

times a day. There were no documented trespassing incidents in 2016.

Entry to the eastern side of the Site is controlled by natural features which render the area inaccessible.

Access to these portions of the Site is controlled by the following:

Eastern Portions of the North Side: The Highway 40 corridor’s steep embankment, North Creek waterway, dense vegetation, and tidal marsh;

Eastern Portion of the South Side: Neighboring industrial/commercial facilities, South Creek Waterway, and tidal marsh, and;


January 2017 35 033-6231-004

East Side: Quinnipiac River and tidal marsh.

The warning signs previously located within the tidal marsh under a Certificate of Permission from CTDEEP

OLISP were removed as part of the completion of the ESRC. While the primary purpose is to protect the

ecological enhancements during the initial establishment period, the deer fencing installed along the site

perimeter as part of ESRC will also deter unauthorized human entry to the Site from the east.

Woodard & Curran staff are responsible for other institutional control monitoring activities specified in the

Order. During 2016, Woodard & Curran staff periodically inspected the interim covers on the west side of

the Site and the final covers on the east side of the site to assess damage, thereby fulfilling the requirement

to at least annually verify that cover systems and engineered controls (ECs) are in good order. Repairs

were made to the cover systems, as appropriate, to address the minor damage to the cover soils, primarily

due to erosion.

Woodard & Curran staff also routinely inspect the well-heads and equipment enclosures associated with

the pumping and monitoring wells for damage or evidence of tampering, thereby fulfilling the requirement

to at least annually inspect active monitoring wellheads to determine if wellhead locks are in place and if

repairs to the wellheads are required. The pumping wells and associated enclosures are locked when not

being actively inspected and maintained. While the Order suggests that active monitoring wellheads should

be locked, locks are not installed on the wells being used for the continuous water level monitoring program

and several of the temporary wells on the western side of the site do not have protective casings that can

be locked. Instead, the monitoring well network is secured through the use of the overall Site entry controls.

Markers have been erected on the East side of the Site to identify the locations of the underground ESRC

components and these markers are inspected at least annually by Woodard & Curran, thereby fulfilling the

requirement to at least annually verify that appropriate notification signs are in place that reinforce the

institutional controls. The Order also suggests that additional notification signs may be appropriate to

reinforce the Institutional Controls, for instance signs on individual well-heads warning people not to disturb

them. Pharmacia & Upjohn considers the signs at the entryway to the Site to be sufficient reinforcement of

this institutional control based on the current use of the Site for groundwater remediation and CMI activities

by staff with training to work at a remediation Site, but will consider the need for signs on individual well-

heads prior to opening ecological enhancements on the East side of the Site to controlled public access

and passive recreational use.

Current Land Use Restrictions

While the ELUR described in the Order will not be implemented until final Corrective Measures (CMs) are

installed, Site use restrictions are currently recorded on the existing property deed, stating that the Site

shall not be used in any manner that the USEPA determines would adversely affect the integrity of any


January 2017 36 033-6231-004

containment system, treatment system, or monitoring system. After completion of the CMs, ELUR(s) will

be implemented for purposes of: (1) allowing passive recreational use on the East Side where ecological

habitat will be restored, created and/or maintained, and (2) allowing commercial or light industrial use on

the West Side. Pharmacia & Upjohn has verified that through its oversight that current Site use is consistent

with the conditions of the existing deed restriction.

Summary

As Site Owner, Pharmacia & Upjohn remains in control and maintains the Site in accordance with current

land use requirements, therefore institutional control provisions related to site ownership/property deed

transfer are not relevant. As Site Owner, Pharmacia & Upjohn has also verified that during 2016 on-Site

groundwater is not being used and no new buildings have been constructed. Prohibited uses of the Site,

such as the use for residential activities, are not occurring.

The Site continues to be used for environmental remediation activities in accordance with USEPA and

CTDEEP approved work plans. While CMI activities, in particular the construction of the groundwater

collection trenches and full-scale ISTR system, have disturbed previously existing IRM, these activities

were performed with the knowledge and consent of USEPA and CTDEEP and in accordance with the

approved work plans for these CMI activities. Due to these measures, no uncontrolled exposure to Site

contaminants has occurred or is currently occurring.


January 2017 37 033-6231-004

6.0 PROJECTED 2017 MONITORING ACTIVITIES AND MASTER PLAN

SCHEDULE

The following Sections fulfill the Order requirement for the Annual Report to provide a schedule of sampling

and field activities to be performed and reported in the following year, along with any proposed modifications

to the OM&M activities. This Section also summarizes milestones and progress goals that Pharmacia &

Upjohn anticipates will be fulfilled in the upcoming year.

6.1 Schedule of OM&M Sampling

The approved Post-CMI Groundwater Monitoring Plan, described the intended monitoring network,

procedures for groundwater monitoring, and associated QA protocols for groundwater sampling and

analyses at the Site during the first two to three years following completion of ESRC construction, and

concurrent with the implementation of the remaining Corrective Measures. The ESRC construction was

considered essentially complete in July 2015, when the NorthStar Team demobilized, and the transition to

the post-ESRC monitoring described in the Post-CMI Groundwater Monitoring Plan occurred in mid-2015.

Therefore the third and final year of post-ESRC monitoring, as described in the Post-CMI Groundwater

Monitoring Plan, is expected to occur in 2017.

The objectives, scope and schedule of the planned 2017 monitoring activities, including both monitoring

specified in the Post-CMI Groundwater Monitoring Plan and planned non-routine monitoring, are described

in the sections that follow. The groundwater monitoring activities described below will be conducted in

general accordance with the approved monitoring procedures and data quality objectives included in the

Post-CMI Groundwater Monitoring Plan; therefore, detailed sampling procedures are not provided. While it

is anticipated that the spring monitoring event described below will occur in March or April 2017 and the fall

monitoring event will occur in September or October 2017, the scope and the schedule of the groundwater

monitoring activities discussed below may be adjusted as 2017 progresses. USEPA and CTDEEP will be

kept informed of changes to the planned monitoring program via the quarterly progress reports, progress

teleconferences, or by email, as necessary throughout the year.

6.1.1 Objective 1: Unit 1 Groundwater Hydraulic Control Monitoring Objective

Verify hydraulic control of Unit 1 groundwater, and recommend adjustment to groundwater extraction rates,

if needed.

Scope and Schedule

To achieve this objective, Unit 1 groundwater elevation measurements will continue to be taken along the

Site perimeter and the HBW alignment at selected locations on a continuous basis using portable electronic


January 2017 38 033-6231-004

datalogger devices. As described in both the GWES Final Design (Golder, July 2014) and the Post-CMI

Groundwater Monitoring Plan, periodic manual water level measurements will also be taken at the locations

where the dataloggers are installed to verify the accuracy of the datalogger devices and provide a basis for

data correction, if necessary. These continuous groundwater elevation measurements will be

supplemented by periodic manual groundwater elevation measurements at selected perimeter wells

between the continuous monitoring locations.

During 2017, the portable dataloggers will be deployed at the locations indicated in Table 6 and shown on

Figure 8. This configuration is similar to the configuration described in the Post-CMI Groundwater

Monitoring Plan; however, it incorporates changes in response to ESRC as-built conditions (e.g. the use of

replacement wells when those referenced in the Post-CMI Groundwater Monitoring Plan were damaged by

construction, and the changes to which wells will be used for extraction on the South Pile). It also contains

adjustments to the monitoring locations based on the data collected during the 2015 and 2016 monitoring

periods, including the installation of dataloggers in the Groundwater Collection Trenches due to the difficulty

of accessing the monitoring points to collect manual measurements in these areas during the winter. The

datalogger configuration for 2017 will be similar to that used during the 4th Quarter of 2016 with the following

modifications:

As described in Section 3.1, an additional datalogger monitoring pair was installed in GW-HBW19/STP-03 to better define hydraulic gradients above the westernmost segment of the North Groundwater Collection Trench. Dataloggers will be retained in both GW-NFPA06/STP-01 and GW-HBW19/STP-01 through the spring thaw and then one of the two monitoring pairs will be selected for continued monitoring.

The dataloggers will be removed from GW-HBW01 & GW-HBW02. This monitoring pair exhibited 100% inward gradients during the 2016 monitoring period. In 2017, water level measurements at these locations will be monitored manually at the same time that the dataloggers are downloaded.

A datalogger will be temporarily installed from approximately February 2017 to April 2017 in well PW-5R to verify the effectiveness of the repairs to the well casing and geomembrane boot at well GW-HBW15.

Dataloggers were installed in all exterior wells adjacent to the South Pile in December 2016. The dataloggers in GW-HBW06, GW-HBW12 and GW-HBW13 will be retained through the spring wet season. Subsequently, up to two datalogger locations will be retained to use as comparison points for the water levels on the interior of the South Pile for the remainder of 2017.

As specified in the 2015 Annual Report, the dataloggers were downloaded and evaluated on an

approximately quarterly basis in 2016 (spring, summer, fall, and winter) and verified with manual

groundwater levels from the supplemental monitoring points on a semiannual basis (spring and fall). During

selected parts of 2016, the information was downloaded on an approximately monthly basis to provide

information more frequently in areas where GWES operational changes were being considered. Pharmacia

& Upjohn intends to continue downloading and evaluating the datalogger data on an approximately

quarterly basis in 2017 (spring, summer, fall, and winter) and verifying the accuracy of the dataloggers with


January 2017 39 033-6231-004

manual groundwater levels from the supplemental monitoring points on a semiannual basis (spring and

fall). The dataloggers may be downloaded more frequently in selected areas of the Site during certain time-

periods (e.g. the locations named above for monitoring through the spring wet season prior to an adjustment

to the datalogger network).

The frequency of the evaluation of the continuous water level monitoring data and the locations used for

continuous water level monitoring will be further evaluated near the end of 2017. Based on additional

observations of the correlation between pumping well set point elevations, monitoring point groundwater

elevations, and the Quinnipiac River elevation as recorded by the supervisory control and data acquisition

(SCADA) system, the monitoring network for 2018 may be further refined. The scope and schedule of the

2018 monitoring will be provided in the 2017 Annual Report.

6.1.2 Objective 2: Evaluation of Post-ESRC Unit 1 Groundwater Flow Directions Objective

Monitor post-ESRC Unit 1 groundwater elevations, flow patterns, and vertical gradients.

Scope and Schedule

This objective will be achieved by the collection of periodic manual water level measurements at wells

screened in Unit 1. The perimeter and interior Unit 1 wells to be included during the manual water level

monitoring program in 2017 are shown on Figure 8 and listed on Table 6. A few wells on the west side of

the Site have temporarily been added to the water level monitoring program to provide additional

groundwater flow information in the central portion of the Site (GW-DPLX10, GW-DPLX11, GW-DPLX12,

PA-05, PA-06, and PA-24), though it is anticipated that these locations may be abandoned as part of WSRC

construction.

To fulfill the objective to evaluate and assess groundwater flow directions, manual water level

measurements will be collected approximately semiannually. These synoptic water level monitoring events

are anticipated in spring and fall 2017. The schedule for the 2017 monitoring events is consistent with the

Post-CMI Groundwater Monitoring Plan, which anticipated that, after an initial period of quarterly monitoring

(completed in 2015), the verification of the interior water level elevations would be performed semiannually

for the first two years following ESRC construction completion. The scope and schedule for the 2018

monitoring will be provided in the 2017 Annual Report.


January 2017 40 033-6231-004

6.1.3 Objective 3: Monitor Unit 1 Groundwater Quality Outside HBW Objective

Monitor Unit 1 groundwater quality outside the HBW to allow the future assessment of attenuation of

residual Unit 1 groundwater impacts outside the HBW.

Scope and Schedule

The scope and schedule for this objective are unchanged from 2016. This objective will be achieved by the

collection of groundwater samples for VOC and SVOC analysis from 10 Unit 1 monitoring wells located

outside the HBW (GW-NFPA07, GW-HBW03, GW-HBW11, GD-5S, DM-5S, DM-7S, GW-HBW12,

GW-HBW06, GW-HBW13 and GW-HBW07). These samples will be collected during the consolidated

Annual Groundwater Monitoring event in fall 2017. The wells to be sampled are listed in Table 6 and shown

on Figure 8.

Target times, relative to low tide, for collecting Unit 1 groundwater samples will remain unchanged in 2017.

During the 2017 sampling, it is anticipated that wells DM-5S, DM-7S, GD-5S, GW-HBW03, GW-HBW06,

GW-HBW07, GW-HBW11, GW-HBW12, and GW-HBW13, which show tidal influence, will be sampled

between approximately two and six hours following low tide. Wells GW-HBW12 and GW-HBW13, which

show little temperature variation with tidal changes will be sampled during the four hour period following

low tide.

The schedule for the 2017 monitoring is consistent with the Post-CMI Groundwater Monitoring Plan, which

anticipated that after an initial baseline was established by collecting samples quarterly for a period of six

months following completion of the ESRC (completed in 2015) that groundwater samples would be

collected annually for the first two years following ESRC construction completion at a time that generally

coincided with the low river stage. Low river stage typically occurs between mid-September and early

October. Therefore, the annual monitoring event in 2017 will target this low river stage timeframe. In

addition, to the extent practical, the groundwater sampling events will be scheduled to avoid periods of

abnormally high river discharge (e.g., due to significant storm events). The scope and schedule for the 2018

monitoring will be provided in the 2017 Annual Report.

6.1.4 Objective 4: Monitor Unit 3 and Unit 4 Groundwater Flow Directions and Vertical Gradients

Objective

Monitor post-ESRC groundwater elevations, flow patterns, and vertical gradients within Units 3 and 4 and

the area of deep unconfined groundwater in the northern part of the Site.


January 2017 41 033-6231-004

Scope and Schedule

The scope and schedule for this objective are unchanged from 2016. This objective will be achieved by

collecting manual water level measurements semiannually at wells screened in Units 3 and 4 and at wells

screened within the deep unconfined groundwater in the northern part of the Site. The perimeter and interior

Unit 3 and 4 wells to be included during the manual water level monitoring program in 2017 are shown on

Figure 9 and listed on Table 7. These synoptic water level monitoring events are anticipated in spring and

fall 2017. This groundwater elevation data will also be used to assess the effectiveness of TPW-1N at

hydraulically controlling the impacts seen at SEC-7D and GW-HBW17.

The schedule for the 2017 groundwater level monitoring events is consistent with the Post-CMI

Groundwater Monitoring Plan, which anticipated that, after an initial period of quarterly monitoring

(completed in 2015), verification of the interior water level elevations would be performed semiannually for

the first two years following ESRC construction completion. Revisions to the scope and schedule for the

2018 monitoring will be provided in the 2017 Annual Report.

6.1.5 Objective 5: Demonstrate Compliance with Unit 3 Performance Standards at Downgradient Property Boundary

Objective

Demonstrate compliance with the Unit 3 Performance Standards established in the Order at wells along

the downgradient property boundary.

Scope and Schedule

The scope and schedule for this objective are unchanged from 2016. This objective will be achieved by the

collection of Unit 3 groundwater samples for VOC and SVOC analysis from seven Unit 3 monitoring

locations (DM-5D, DM-7D, DM-9D, MP-20DR, MW-35D, GD-3D, and GD-4D) during the annual monitoring

event in fall 2017. The Unit 3 wells that will be sampled are listed in Table 7 and shown on Figure 9. The

data from several of these wells will also be used to evaluate conditions in the vicinity of Unit 3 well SEC-7D.

The schedule for the 2017 monitoring events is consistent with the Post-CMI Groundwater Monitoring Plan.

Any proposed revisions to the scope and schedule for the 2018 monitoring will be provided in the 2017

Annual Report.


January 2017 42 033-6231-004

6.1.6 Objective 6: Monitor Groundwater Chemistry in the Vicinity of Unit 3 Well SEC-7D Objective

Continued monitoring of groundwater chemistry in the vicinity of Unit 3 well SEC-7D.

Scope and Schedule

The SEC-7D PDI/PDP proposed collecting samples from a refined group of Unit 3 and other select wells in

the vicinity of SEC-7D semiannually in spring and fall of each year during 2015 and 2016. As discussed in

Appendix F-1, now that the SEC-7D PDI/PDP monitoring program is complete, the focus of the SEC-7D

area monitoring is shifting from identification of source areas towards monitoring to confirm that the impacts

identified interior to the Site in Unit 3 and the area where Unit 2 is thinned/absent attenuate prior to reaching

the Site perimeter. Therefore, during 2017, fewer interior groundwater samples are anticipated to be

collected. The Unit 3 wells that will be sampled are listed in Table 7 and shown on Figure 9.

Accordingly, groundwater samples will be collected for VOC and SVOC analysis from two Site perimeter

Unit 3 wells (GD-3D, GD-4D) and one unconfined Site perimeter well (GW-U309) in the spring of 2017.

These samples are being collected in part to determine whether the 2-chloroaniline concentration detected

well GW-U309 in the spring of 2015 is attributable to seasonal effects or to temporary decreased pumping

flow rates at well TPW-1N.

Groundwater samples will be collected in the fall of 2017 from two shallow Unit 1 wells (GW-U103, and

GW-NFPA07), three deep unconfined wells (GW-HBW17, GW-U303, and GW-U309), and three Unit 3

wells (SEC-7D, GD-3D, and GD-4D). Unit 1 well GW-NFPA07 and Unit 3 wells GD-3D, and GD-4D are

also part of the post-ESRC monitoring. The samples will be analyzed for VOCs and SVOCs. Samples will

not be collected in 2017 from interior shallow Unit 1 wells (GW-HBW16, GW-HBW19, and TPW-1N) and

upgradient wells (GD-2D, GW-U305, GW-U310, GW-U311 and GW-U312), which were part of the SEC-7D

area monitoring in 2016. Samples will also not be collected from well GW-U313 in 2017.

6.1.7 Objective 7: Monitor Groundwater Chemistry in Unit 4 Well GD-4BR Objective

Monitor groundwater quality in well GD-4BR.

Scope and Schedule

As discussed in Appendix F-2, concentrations of VOCs and SVOCs were below the comparative criteria in

all of the Unit 4 samples collected in 2016. A very limited Unit 4 monitoring program will be implemented in

2017. Groundwater samples will be collected in the spring and fall of 2017 from well GD-4BR since higher


January 2017 43 033-6231-004

concentrations were detected in the fall 2016 sample than were detected in the October 2014 sample.

These samples will be analyzed for VOCs and SVOCs.

6.1.8 Objective 8: Further evaluation of LNAPL Recoverability in Well GW-LP01 Objective

Determine whether the LNAPL present in Unit 1 monitoring well GW-LP01 is recoverable using passive

absorbent technology.

Scope and Schedule

Per Connecticut regulation RCSA 22a-449(d)-106(f), LNAPL must be removed to the extent practicable. As

discussed in Appendix F-3, LNAPL continues to be present in well GW-LP01, though attempts to gauge

the product thickness during 2016 were unsuccessful due to the viscosity of the material. Similarly, attempts

to remove product via bailing in 2016 were not successful as the material inconsistently adhered to the

outside of the bailer rather than entering the chamber of the bailer.

As described in Appendix F-3, during 2017 Pharmacia & Upjohn plans to implement a short-term pilot-scale

study to gauge the effectiveness of using an absorbent sock to recover the LNAPL present in GW-LP01.

The pilot test is anticipated to last for approximately 6 months. Pharmacia & Upjohn will review the data

and observations obtained upon completion of the pilot-scale study and present the path forward for the

LNAPL at GW-LP01 in the 2017 Annual Report, or other focused communications with USEPA and

CTDEEP.

6.2 Proposed Modifications To The Annual OM&M Activities

Woodard & Curran will continue to operate the GWTF in accordance with the Site NPDES Permit and will

continue the NPDES permit renewal process with CTDEEP. Woodard & Curran will continue to operate,

monitor and maintain the post-ESRC GWES, inspect the ESRC cover systems, inspect the interim west

side covers, and monitor existing institutional controls at the Site. Golder Associates will continue to monitor

water levels, assess the performance of the Unit 1 hydraulic controls, and collect the groundwater quality

monitoring samples. No changes to routine OM&M activities, such as redevelopment and maintenance of

extraction wells (as needed) and inspection of the fences and signs at the Site are anticipated. While daily

operating parameters may be adjusted to accommodate the CMI wastewater streams, these changes will

be implemented in accordance with the NPDES permit and CTDEEP approvals.

6.2.1 O&M Groundwater Monitoring As discussed in Section 6.1, the Post-CMI Groundwater Monitoring Plan was intended to cover the first two

to three years following the ESRC construction while the site equilibrated to the presence of the completed

CM. The 2017 monitoring program described above represents the third year of monitoring under the Post- g:\projects\2003 projects\033-6231-004 nhaven\200 reports\210 annual rpt\2016\2016 annual rpt_0336231004_013017.docx

January 2017 44 033-6231-004

CMI Groundwater Monitoring Plan. During 2017, Pharmacia & Upjohn intends to discuss future

groundwater monitoring needs at the Site with CTDEEP and USEPA and to establish the outlines of the

2018 – 2020 groundwater monitoring program. Following the completion of these discussions, a new long-

term monitoring plan is anticipated to be prepared for the Site to document the agreed upon monitoring

scope and schedule.

Also in 2017, Pharmacia & Upjohn anticipates clarifying the CTDEEP RSR comparative criteria that will be

used to evaluate future groundwater data. Pharmacia & Upjohn is discussing the possibility of requesting

approval of additional Site-specific criteria with CTDEEP.

6.2.2 Master Plan Schedule As discussed in Section 1.5, the Master Plan Schedule included one Progress Goal in 2016, namely the

revised Progress Goal date of November 16, 2016 related to “Submit Draft Final Design of the West Side

Remedial Components (WSRC).” Pharmacia & Upjohn followed the process for modifying the “Master Plan

Schedule” and on November 14, 2016, USEPA approved revising the Progress Goal “Submit Draft Final

Design of West Side Remedial Components (WSRC)” to March 31, 2018. Revising the Progress Goal date

associated with the submittal of the Draft Final Design of the WSRC to March 31, 2018 is not anticipated

to impact the ability to achieve the May 29, 2020 Major Milestone associated with “Submit the Construction

Completion Report for West Side Areas”. Pharmacia & Upjohn will communicate progress towards this

Progress Goal and the associated process toward assessing future development needs with USEPA and

CTDEEP during the progress teleconferences and other communication channels, as appropriate.

To date, the CMI Team has not encountered any delays or technical difficulties that would negatively impact

the ability to meet the Master Plan Schedule. The CMI Team, on behalf of Pharmacia & Upjohn, is striving

to accelerate the design and construction schedule to efficiently implement the Corrective Measures, where

possible. In particular, Pharmacia & Upjohn achieved the Major Milestones “Submit Construction

Completion Report for East Side Areas” on June 1, 2016 (Milestone date 3/31/2020) and “Submit DNAPL

Component Completion Report” on September 23, 2016 (Milestone date 3/21/2020) by the submission of

the ESRC Construction Completion Report and the Full-Scale ISTR Construction Completion Report to

USEPA and CTDEEP for review.

Section IV of the quarterly progress reports describes and provides more detail on specific CMI activities

planned for 2017, including details of Corrective Measure implementation that lead to the Order Major

Milestones and Progress Goals highlighted above. USEPA and CTDEEP will be kept informed of any

schedule changes through the quarterly progress reports and routinely scheduled teleconferences. USEPA

and CTDEEP will also continue to be consulted, regarding technical and regulatory matters (e.g. to solicit

input on WSRC design), as necessary during 2017.


January 2017 45 033-6231-004

7.0 REFERENCES

CTDEEP, 2003. Connecticut’s Remediation Standard Regulations Volatilization Criteria, Proposed Revisions. March 2003.

CTDEEP, 2007. Draft Proposed Revisions to the Remediation Standard Regulations, October 2007.

CTDEEP, 2008. Letter from Patrick F. Bowe (CTDEEP) to Russ Downey (Pharmacia & Upjohn) “Request for Criteria for Additional Polluting Substances” dated December 22, 2008.

CTDEEP, 2010. NPDES Permit Issued to Pharmacia & Upjohn Company LLC (Permit ID CT0001341), January 2010.

CTDEEP, 2011, Ms. Kim Hudak, “Approval of Facility Modification Treatment System Modification Approval”. Letter to Mr. Russell Downey, June 11, 2011.

CTDEEP, 2012a. Letter from Patrick F. Bowe (CTDEEP) to Tim Carr (GeoDesign) “Request for Criteria for Additional Polluting Substances” dated March 23, 2012.

CTDEEP, 2012b. June 2012, Substitute House Bill No. 5343 Public Act No. 12-196: An Act Concerning Economic Development Through Streamlined And Improved Brownfield Remediation Programs, Exempting Certain Airport Conveyances From The Department Of Transportation To The Connecticut Airport Authority From The Hazardous Waste Establishment Transfer Act, And Holding Harmless And Indemnifying The Connecticut Airport Authority And Its Employees And Directors.

CTDEEP 2013b, Remediation Standard, RCSA 22a-133k-1 through 22a-133k-1, July 2013.

CTDEEP, 2015a, Ms. Kim E. Hudak, CTDEEP. “Approval of Facility Modification, Treatment System Modification Approval”. Letter to Mr. Russell G. Downey, March 18, 2015.

CTDEEP, 2015b, Mr. Oswald Inglese, Jr., CTDEEP. “Approval of Facility Modification”. Letter to Mr. Russell G. Downey August 5, 2015

CTDEEP, 2015c. Request for Fast-track Approval of Criteria for Additional Polluting Substances and Certain Alternative Criteria. December 10, 2015.

CTDEEP, 2016, Ms. Kim Hudak, “Approval of Facility Modification” Letter to Mr. Russell Downey. March 16, 2016.

Golder Associates Inc., 2006. Final Investigation Report, Pharmacia & Upjohn Company LLC Site, North Haven, Connecticut, August 2006.

Golder Associates Inc. (Golder), 2007. Proposed RSR Criteria for Additional Polluting Substances (Revision 1), June 2007.

Golder Associates Inc., 2010. Final Revised Corrective Measures Study, Pharmacia & Upjohn Company LLC Site and Lake A LLC Site, North Haven, Connecticut, Golder Associates Inc., June 2010.

Golder Associates, 2012a. 2011 Annual Progress Report, Pharmacia & Upjohn Company LLC Site, North Haven, Connecticut, February 2012.

Golder Associates, 2012b. Corrective Measures Implementation Work Plan, Pharmacia & Upjohn Company LLC Site, North Haven, Connecticut, February 2012.


January 2017 46 033-6231-004

Golder Associates, 2013a. 2012 Annual Progress Report, Pharmacia & Upjohn Company LLC Site, North

Haven, Connecticut, January 2013.

Golder Associates, 2013b. Groundwater Extraction System Hydrogeologic Draft Final Design (Appendix H of the Draft Final East Side Remedial Components Design Report) Pharmacia & Upjohn Company LLC Site, North Haven, Connecticut, May 2013.

Golder Associates, 2014a. 2013 Annual Progress Report, Pharmacia & Upjohn Company LLC Site, North Haven, Connecticut, January 2014.

Golder Associates, 2014b. SEC-7D Pre-Design Investigation Report and Preliminary Design Proposal, Pharmacia & Upjohn Company LLC Site, North Haven, Connecticut, revised February 2014.

Golder Associates, 2014c. Groundwater Extraction System Hydrogeologic Final Design (Appendix H of the East Side Remedial Components Design Report) Pharmacia & Upjohn Company LLC Site, North Haven, Connecticut, July 2014.

Golder Associates, 2014d. Post-CMI Groundwater Monitoring Plan (Attachment A to Appendix D of the East Side Remedial Components Design Report) Pharmacia & Upjohn Company LLC Site, North Haven, Connecticut, July 2014.

Golder Associates, 2015. 2014 Annual Progress Report, Pharmacia & Upjohn Company LLC Site, North Haven, Connecticut, January 2015.

Golder Associates, 2016. 2015 Annual Progress Report, Pharmacia & Upjohn Company LLC Site, North Haven, Connecticut, February 2016.

NorthStar and Brown and Caldwell, 2016a, Draft Construction Completion Report, East Side Remedial Components, Pharmacia & Upjohn Company LLC Site, USEPA RCRA ID No. CTD 001168533 North Haven, Connecticut, May 2016.

NorthStar and Brown and Caldwell, 2016b, Construction Completion Report, East Side Remedial Components, Pharmacia & Upjohn Company LLC Site, USEPA RCRA ID No. CTD 001168533 North Haven, Connecticut, August 2016.

TerraTherm and Golder Associates, 2013. Draft In-Situ Thermal Remediation Pilot Study Final Report and Full-Scale Preliminary Design Proposal, Pharmacia and Upjohn Company LLC, North Haven, Connecticut, August 2013.

TerraTherm and Golder Associates, 2014. Full Scale In Situ Thermal Remediation Draft Final Design Report, Pharmacia and Upjohn Company LLC, North Haven, Connecticut, December 2014.

TerraTherm and Golder Associates, 2015. Full Scale In Situ Thermal Remediation Final Design Report, Pharmacia and Upjohn Company LLC, North Haven, Connecticut, July 2015.

TerraTherm and Golder Associates, 2016a. Draft DNAPL Component In Situ Thermal Remediation Completion Report, September 2016.

TerraTherm and Golder Associates, 2016b, DNAPL Component In Situ Thermal Remediation Completion Report, December 2016.

USEPA, 2010a. Statement of Basis for Pharmacia & Upjohn Company LLC Site, North Haven, Connecticut, June 2010.


January 2017 47 033-6231-004

USEPA, 2010b. Final Decision and Response to Comments for Pharmacia & Upjohn Company LLC Site,

North Haven, Connecticut, September 2010.

USEPA, 2011. Administrative Order on Consent in the Matter of the Pharmacia & Upjohn Company LLC, 41 Stiles Lane, North Haven, CT, (USEPA Docket Number RCRA-01-2011-0027), March 2011.

WRS and Brown and Caldwell, 2013a. Final Draft Corrective Measures Design Report East Side Remedial Components, Pharmacia & Upjohn Company LLC Site, North Haven, Connecticut, March 2013.

WRS, Brown and Caldwell, and Golder, 2013b. Engineered Control Fact Sheets for the Remaining ESRC, Pharmacia & Upjohn Company LLC Site, North Haven, Connecticut, October 2013. Revised March 2014.

WRS, Brown and Caldwell, and Golder, 2014. Corrective Measures Design Report East Side Remedial Components, Pharmacia & Upjohn Company LLC Site, North Haven, Connecticut. August 2014.


Documents

2016 ANNUAL PROGRESS - upjohnnorthhaven.comESRC Construction Completion Report to USEPA and CTDEEP on June 1, 2016, which achieved an Order Major Milestone. The revised ESRC Construction