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• Five-Year Review Report
Second Five-Year Review Report
For
Midwest EVianufacturing/North Farm Site
Kellogg
Jasper County, Iowa
November 2005
Prepared By:
U.S. Environmental Protection AgencyRegion VII, Superfund Division
901 N. 5th StreetKansas City, Kansas 66101
Cecilia Tapia,Superfund Division V
Date:
40224565
SUPERFUND RECORDS
List of Acronyms
ARAR Applicable or Relevant and Appropriate Requirement
CD Consent Decree
CERCLA Comprehensive Environmental Response, Compensation, and LiabilityAct of 1980, as amended by the Superfund Amendments andReauthorization Act of 1986
cis 1,2-DCE cis 1,2-Dichloroethylene
CFR Code of Federal Regulations
CWA Clean Water Act
EPA United States Environmental Protection Agency
IDNR Iowa Department of Natural Resources
MCL Maximum Contaminant Level
O&M Operation and Maintenance
MW Monitoring Well
NCP National Oil and Hazardous Substances Contingency Plan
NPL National Priorities List
OU Operable Unit
PCE Tetrachloroethylene
PRP Potentially Responsible Party
RA Remedial Action
RAO Remedial Action Objective
RCRA Resource Conservation and Recovery Act
RD Remedial Design
RJ/FS Remedial Investigation/Feasibility Study
ROD Record of Decision
RPM Remedial Project Manager
TCA 1,1,1-Trichloroethane
TCE Trichloroethylene
VC Vinyl Chloride
VOC Volatile Organic Compounds
WasteLan EPA's database of Superfund sites
Executive Summary
The Midwest Manufacturing/North Farm Superfund site consists of twononcontiguous pieces of property known as the North Farm Operable Unit and theMidwest Manufacturing Operable Unit. The North Farm Operable Unit is located twomiles north and one-half mile east of Kellogg, Iowa. The Midwest ManufacturingOperable Unit is located in the city of Kellogg, Iowa.
This North Farm Operable Unit was used for disposal of sludges generated at theMidwest Operable Unit during the 1977 and 1978 time period. The first five-year reviewfor the Midwest Manufacturing/North Farm Superfund site indicated that no additionalground water monitoring was needed for the North Farm Operable Unit. None have beenconducted during the past five-year review period. The EPA did verify that the land userestrictions remain in place for this operable unit and property use remains unchanged.
The remedy for the Midwest Manufacturing Operable Unit is ongoing. Thisremedy includes land use and ground water use restrictions and ground water monitoring.The assessment of the first five-year review found that the amended remedy wasconstructed in accordance with the requirements of the Record of Decision (ROD). Theremedy addressed immediate and long-term threats and is operating as designed.
The second five-year review of the Midwest Manufacturing/North Farm site inKellogg, Iowa, has been completed. The results of the second five-year review indicatethat the remedy is protective of human health and the environment. The remedy ofground water monitoring and institutional controls has been shown to be effective. Therehas been no change in the ownership of these properties. The responsible partiescontinue to own the Midwest Manufacturing/North Farm site, have maintained the site,and are continuing to conduct ground water monitoring at the Midwest ManufacturingPlant site and institutional controls at both the Midwest Manufacturing Plant site and atthe North Farm site in compliance with the Consent Decree 4-92-CV-80417. Nodeficiencies were observed during the five-year review site inspection.
For the Midwest Manufacturing Operable Unit, inorganic and volatile organiccontaminant concentrations have been decreasing, which allowed EPA to reduce theamount of sampling performed. The EPA and IDNR agreed to reduce the ground watermonitoring to three wells in two locations and to conduct monitoring on a semi-annualbasis. Monitoring wells not included in the semi-annual ground water sampling wereabandoned in October 1998. Sampling of the city supply wells was discontinued inNovember 1997 after nine quarters of sampling showed that none of the city supply wellscontained Midwest Manufacturing contaminants of concern. Semi-annual ground watermonitoring continues for the following selected volatile organic contaminants: 1,1,1-trichloroethane, trichloroethylene, tetrachloroethylene, vinyl chloride, and cis-1, 2-dichloroethylene. Figure 1 shows the Midwest Manufacturing/North Farm site location.
in
Five-Year Review Summary Form
Site name (from WasteLAN): Midwest Manufacturing/North FarmEPA ID (from WasteLAN): IAD069625655Region: 7 | State: IA I City/County: Kellogg/Jasper
NPL status: El Final D Deleted D Other (specify)Remediation status (choose all that apply): D Under Construction E] Operating D CompletedMultiple Operable Units?* El YES D NO | Construction completion date: 2/18/1997Has the site been put into reuse? YES X NO, site use not affected by the ongoing monitoring work.North Farm site remains as pastureland. No reuse has occurred for either operable unit.
Lead agency: t3 EPA D State D Tribe D Other Federal AgencyAuthor name: Diane Easley,Review period:** 4/10/2005 to 10/31/2005Date(s) of site inspection: 5 /18/ 2005Type of review:
H Post-SARA D Pre-SARA D NPL-Removal onlyD Non-NPL Remedial Action Site D NPL State/Tribe-leadD Regional Discretion
Review number: D 1 (first) El 2 (second) D 3 (third) D Other (specify)Triggering action:D Actual RA Onsite Construction at Operable Unit #D Construction CompletionD Other (specify)
D Actual RA Start at Operable Unit #IS Previous Five-Year Review Report
Triggering action date (from WasteLAN]: 11 / 20 / 2000Due date (five years after triggering action date): 11 / 20 / 2005* [Review period should correspond to the actual start and end dates of the Five-Year Review in WasteLAN.]
IV
Five-Year Review Summary Form, cont'd.
Issues: Review land use restrictions to make sure they are effective.
Recommendations and Follow-up Actions: No further response actions arerecommended. Semi-annual ground water sampling will occur at the MidwestManufacturing Operable Unit until the contaminant levels remain at or below themaximum contaminant levels (MCLs) for four consecutive sampling periods.Contamination in one monitoring well (PAMW-2B) remains above the MCL for vinylchloride (VC), a contaminant of concern. The most recent sampling event (August 2005)indicated that VC was present at 2.2 micrograms per liter (ug/1). The MCL for vinylchloride is 2.0 ug/1. Other wells tested remain below the MCLs for the site'scontaminants of concern.
Protectiveness Statement(s): For the North Farm Operable Unit, the remedy isprotective of human health and the environment as long as no vegetables are planted inthe area and the ground water is not used for domestic uses. Land use restrictions arecurrently in place preventing such use. For the Midwest Manufacturing PlantOperable Unit, the remedy is expected to be protective of human health and theenvironment once the ground water monitoring results indicate that all contaminants ofconcern are present below the MCL for the contaminant. Land use restrictions remain inplace preventing the installation of ground water domestic supply wells. Accessrestrictions (fencing) remain in place surrounding the plant site. Because the remedialactions at both operable units are protective, the site is protective of human health and theenvironment.
Other Comments: The potentially responsible parties continue to collect ground watersamples from the three monitoring wells that have shown to contain the contaminants ofconcern. The Midwest Manufacturing Plant site is located next to a public park and theNorth Skunk River. A fence, restricting public access, surrounds the plant site. The EPAanticipates the MCLs will be achieved for all the site contaminants of concern within thenext three years. Once ground water monitoring verifies the achievement of the MCLs, atwo-year monitoring period will start. If the levels remain below the MCLs for the nexttwo years, the EPA will initiate site deletion activities.
I. Introduction
The purpose of the five-year review is to determine whether the remedy at a site isprotective of human health and the environment. The methods, findings, and conclusions of thereview are documented in five-year review reports. In addition, five-year review reports identifyissues found during the review, if any, and identify recommendations to address them.
The Agency is preparing this second five-year review report pursuant to theComprehensive Environmental Response, Compensation, and Liability Act (CERCLA) §121 andthe National Oil and Hazardous Substances Contingency Plan (NCP). CERCLA §121 states:
If the President selects a remedial action that results in any hazardous substances, pollutants,or contaminants remaining at the site, the President shall review such remedial-action no less
often than each five years after the initiation of such remedial action to assure that humanhealth and the environmental are being protected by the remedial action being implemented.
In addition, if upon such review it is the judgment of the President that action is appropriate atsuch site in accordance with section [104J or [106], the President shall take or require suchaction. The President shall report to the Congress a list of facilities for which such review isrequired, the results of all such reviews, and any actions taken as a result of such reviews.
The Agency interpreted this requirement further in the NCP; 40 CFR §300.430(f)(4)(ii)states:
If a remedial action is selected that results in hazardous substances, pollutants, orcontaminants remaining at the site above levels that allow for unlimited use and unrestricted
exposure, the lead agency shall review such action no less than every five years after theinitiation of the selected remedial action.
The United States Environmental Protection Agency (EPA), Region VII, has previouslycompleted the first five-year review report of the remedy implemented at the MidwestManufacturing/North Farm Superfund site, Kellogg, Iowa. In accordance with CERCLA §121and the NCP, the first five-year review was triggered by the initiation of the first remedial action(RA) that left hazardous substances, pollutants, or contaminants onsite above levels that allowfor unlimited use and unrestricted exposure. The first five-year review was conducted fromApril 27, 2000, to September 5, 2000. The first five-year review report, which was signed onNovember 20, 2000, documented the results of the review.
This is the second five-year review for the Midwest Manufacturing/North Farm site. Thetriggering action for this review is the signature date of the first five-year review report, asshown in EPA's WasteLan Database: 11/20/2000. The EPA, Region VII, conducted this secondfive-year review from April 2005 through October 2005 for the entire site. This reportdocuments the results of the review.
II. Site Chronology
Table 1 - Chronology of Site Events
EventInitial Discovery of ProblemNPL ListingSpecial Notice Issued
Remedial Investigation/Feasibility Srudy(RI/FS) Completion - North FarmRecord of Decision (ROD) Signature -North FarmROD Signature - Midwest ManufacturingROD Amendment - Both Operable UnitsConsent DecreeRemedial Design (RD) StartRD CompletionPre-National Priorities List (NPL) ResponsesRemedial Action (RA) StartConstruction CompletionLetter Revisions to Quarterly MonitoringSite Visit - Abandonment of WellsFirst Five-Year Review Site VisitCompletion of First Five-Year ReviewCollection of Ground Water Monitoring SamplesCollection of Ground Water Monitoring SamplesCollection of Ground Water Monitoring SamplesCollection of Ground Water Monitoring SamplesCollection of Ground Water Monitoring SamplesRemoval from State of Iowa's Registry of Hazardous Waste SitesCollection of Ground Water Monitoring SamplesCollection of Ground Water Monitoring SamplesCollection of Ground Water Monitoring SamplesCollection of Ground Water Monitoring SamplesCollection of Ground Water Monitoring SamplesCollection of Ground Water Monitoring SamplesNotice to Midwest Manufacturing Regarding Second Five-Year ReviewSecond Five-Year Review Site VisitRelease of Fact Sheet Regarding Second Five-Year ReviewPublic Notice in Paper for Five-Year ReviewCollection of Ground Water Monitoring SamplesGround Water Monitoring Report
DateNov. 1, 1979Jun. 6, 1986
Nov. 25, 1988 andNov. 7, 1990
Sept. 30, 1988Sept. 30, 1988Sept. 27, 1990Sept. 29, 1993Dec. 13, 1994Feb. 1, 1995Aug. 3, 1995
Sept. 18, 1995Oct. 2, 1995
Nov. 30, 1995May 13, 1998
Oct. 27-28, 1998Aug. 29, 2000Nov. 20, 2000February 2000August 2000
February 200 1August 2001
February 2002Feb. 25, 2002August 2002
February 2003August 2003
February 2004August 2004
February 2005Mar. 16,2005May 18,2005Jun. 24 2005Jun. 27, 2005Aug. 1,2005
Aug. 29, 2005
III. Background
Physical Characteristics
The Midwest Manufacturing/North Farm Superfund site consists of two non-contiguouspieces of property. The North Farm Operable Unit is located two miles north and one-half mileeast of Kellogg, Iowa. This North Farm Operable Unit was used for sludge disposal during the1977 and 1978 time period. The first five-year review for the Midwest Manufacturing/NorthFarm Superfund site indicated that no additional ground water monitoring was needed for theNorth Farm Operable Unit. None have been conducted during the past five-year review period.The EPA did verify that the land use restrictions remain in place for this operable unit. Propertyuse remains unchanged.
This review primarily focuses on the ongoing RA at the Midwest ManufacturingOperable Unit in Kellogg, Iowa, where the Midwest Manufacturing Company operates on aneight-acre facility and manufactures small engine parts. The site is surrounded by farmland withapproximately 3,000 residents living within a three-mile radius of the site, including the town ofKellogg, Iowa. Prior to the RA, contaminants of concern at the site included zinc, nickel,chromium, and volatile organic compounds (VOCs), including cis-l,2-dichloroethylene (cis-1,2-DCE), vinyl chloride (VC), 1,1,1- trichloroethane (TCA), tetrachloroethylene (PCE), andtrichloroethylene (TCE). People could have been exposed to contaminants by drinking waterfrom contaminated private wells, by direct contact with contaminated water or soil, by inhalingcontaminants released during water use, or by eating food in which contaminants bioaccumulated.
Land and Resource Use
The Midwest Manufacturing/North Farm Superfund site consists of two noncontiguouspieces of property known as the North Farm Operable Unit and the Midwest ManufacturingOperable Unit. As previously stated, the North Farm Operable Unit is located two miles northand one-half mile east of Kellogg, Iowa. Kellogg, population 700, is located in Jasper County,which is approximately 42 miles east of Des Moines. The physical characteristics of the NorthFarm Operable Unit remain unchanged from the Record of Decision (ROD). No new familieshave moved into the area, and the site remains rural in nature. The area is used for pasture landfor grazing cattle. The nearby residence was torn down and the deed restriction states that theowner shall not obstruct the performance of the work as required under the Consent Decree, theowner shall not install nor allow others to install any drinking water well within the affectedarea, and that the owner shall not use or allow others to use the disposal area for a vegetablegarden. The Midwest Manufacturing Operable Unit is owned and operated by Smith Jones, Inc.and is located at 101 High Street in the city of Kellogg, Iowa. The Midwest ManufacturingOperable Unit occupies eight acres within the North Skunk River flood plain. The physicalcharacteristics of the Midwest Manufacturing Operable Unit have changed from the time of theROD Amendment. The manufacturing facility has expanded into areas which previously wereunoccupied although within the boundaries of the plant site. The plant site is located adjacent toa city park and the North Skunk River.
History of Contamination
Smith Jones, Inc. engaged in electroplating and painting operations of manufacturedproducts at the Midwest Manufacturing Operable Unit from 1973 until 1981. The electroplatingprocess involved the use of TCE to clean a product before it was coated with a metal. Cadmiumwas used as the metal coating prior to 1979, nickel was used unt i l 1980, and from 1980-1981zinc was used. Prior to 1977, electroplating wastes containing TCE, heavy metals, and paintresidues generated from onsite painting operations were disposed directly into the North SkunkRiver. In 1977, a wastewater treatment system was constructed. Sludges generated from thetreatment process were pumped to a storage tank where they were periodically removed andplaced into one of two disposal areas located at the plant site. In addition, from 1977 to 1978,the sludge resulting from this wastewater treatment process was periodically transported to theNorth Farm Operable Unit for disposal. At the Midwest Manufacturing Operable Unit, thesludge was placed in an unlined trench excavated to a depth of approximately five feet belowground surface. A berm was in i t ia l ly placed around the perimeter of the trench to divert surfacewater away from the disposed material. The trench was covered with native soils in 1978.Electroplating operations ceased in June of 1981.
The ini t ial ROD for the North Farm Operable Unit selected excavation of thecontaminated soil, chemical stabilization of the soil and disposal in a Resource Conservation andRecovery Act (RCRA) Subtitle C landfill. The initial ROD for the Midwest ManufacturingOperable Unit selected installing a RCRA Subtitle C landfill cap on the disposal area and groundwater extraction and treatment. On September 23, 1993, the Acting Regional Administrator-signed a ROD Amendment which changed the remedy to institutional controls and ground watermonitoring for both the North Farm Operable Unit and the Midwest Manufacturing OperableUnit.
Initial Response
From 1987 to 1990, EPA conducted sampling of the municipal wells and a series ofinvestigations on the extent of soil and ground water contamination. The site was proposed forthe National Priorities List (NPL) on October 26, 1989, and finalized on the NPL in August1990. In March 1993, the combined Remedial Investigation/Feasibility Study (RI/FS) reportwas made available to the public.
Basis for Taking Action
Hazardous substances that have been identified in the soils at the facilities include PCE,TCE, cis-1,2-DCE, TCA, VC, and arsenic. Ground water beneath the site contains PCE, TCE,1,2-TCA, 1,2-DCE, VC, and arsenic. Arsenic is naturally occurring in the area, however, arsenicwas retained in risk calculations to obtain the maximum exposure scenarios. People could beexposed to contaminants in drinking water by direct contact with contaminated water and byinhaling contaminants during water use.
IV. Remedial Actions
North Farm Operable Unit
A. Remedy Selection
For the contaminated soils at the North Farm Operable Unit, the selected remedy, asamended, included deed restrictions to prevent using the disposal area as a vegetablegarden which could lead to accidental exposure to hazardous substances. For the groundwater, the selected remedy, as amended, included deed restrictions to prevent installationof ground water supply wells to restrict human consumption of contaminated groundwater. Ground water monitoring was conducted to verify that the remedy remainsprotective of human health and the environment.
B. Remedy Implementation
The RA for both of the operable units is being conducted under a Consent Decree. TheConsent Decree is Civil No. 4-92-CV-80417 which was entered into by the United StatesDistrict Court for the Southern District of Iowa, Central Division, on December 12, 1994.For the North Farm Operable Unit, deed restrictions were recorded in the Jasper CountyCourthouse, Newton, Iowa, on August 3, 1994. The ground water was monitored fromthe three existing ground water wells for nickel, cadmium, and zinc in November 1995,February 1996, May 1996, August 1996, May 1997, and November 1997. The levels ofcontamination present in the ground water were less than the levels of concern for thesecompounds'. The North Farm monitoring wells were closed in April 1999.
C. System Operations
The physical characteristics of the North Farm Operable Unit remain unchanged from theROD. No new families have moved into the area, and the site remains rural in nature.The area is used for pasture land for grazing cattle. The nearby residence was torn down.The deed restriction states that the owner shall not obstruct the performance of the workas required under the Consent Decree, the owner shall not install nor allow others toinstall any drinking water well within the affected area, and that the owner shall not useor allow others to use the disposal area for a vegetable garden. On August 29, 2000, EPAtraveled to Kellogg, Iowa, and verified that the deed restriction is on record at the JasperCounty Courthouse in Newton, Iowa; and EPA traveled to the site and verified that noground water supply wells were installed within the affected area. The site has only beenused as pasture land or for grazing. Ground water monitoring utilizing the existing
The May 1993 drinking water standards and health advisories for the contamination at the NorthFarm site are: cadmium, 5 micrograms per liter (ug/l); nickel, 100 ug/1; and zinc, 500 ug/l. The standardsfor cadmium and nickel are maximum contaminant levels (MCLs). The standard for zinc is a secondaryMCL, which means that it is for taste and odor reasons not directly related to health.
monitoring wells was conducted as part of the RA. On August 29, 2000, EPA verifiedthat the photos contained in Appendix C of the Monitoring Well Closure Report, datedMay 1999, accurately depicted the North Farm conditions. On May 18, 2005, EPA, theIowa Department of Natural Resources (1DNR), and representatives of Smith-Jonesvisited the site and determined that conditions at the North Farm Operable Unit wereunchanged from our visit in August 2000.
D. Progress Since the Last Five-Year Review
During this past five-year period, no ground water monitoring occurred at the North FarmOperable Unit. During the first five-year review for the Midwest Manufacturing/NorthFarm site, the ground water at the North Farm Operable Unit was found to comply withthe cleanup goals selected in the ROD as amended. This second five-year review verifiedthat the deed restrictions remain on the site for the disposal cell and that site conditionsremained the same.
Midwest Manufacturing Operable Unit
A. Remedy Selection
For the contaminated soils at the Midwest Manufacturing Operable Unit, the selectedremedy, as amended, includes installation of a perimeter fence to control access to thesite and deed restrictions to prevent any change on the property, i.e., changing the use ofthe property from industrial to residential use, which could lead to accidental exposure tohazardous substances. For the ground water, the selected remedy, as amended, includedthe following elements: 1) deed restrictions to prevent installation of ground water supplywells to prevent human consumption of contaminated ground water; 2) performance of asurvey within one mile of the plant site to identify all water supply wells, both publ ic andprivate, prior to the initiation of the ground water monitoring program; 3) installation oftwo monitoring wells close to the existing public water supply wells; and 4) ground watermonitoring to verify that the remedy is protective of human health and the environmentand to ensure that no future unacceptable exposures to contaminants at the MidwestManufacturing Operable Unit occur.
B. Remedy Implementation
As previously mentioned, the RA at this operable unit was conducted pursuant to aConsent Decree. As required, deed restrictions were recorded in the Jasper CountyCourthouse, Newton, Iowa, on January 12, 1995. The RA work plan was approved byEPA in August 1995. The EPA agreed that one existing monitoring well could serve asan early warning well for the municipal supply well system and that only one additionalmonitoring well was needed. Installation of the new monitoring well was initiated inOctober 1995. The first ground water monitoring event was completed in November1995 with IDNR collecting split samples for EPA. The water well survey was completedon November 2, 1995, the perimeter fence was installed on November 27, 1995, and the
final inspection of the site was completed on December 6, 1995. Ground water samplescollected from selected monitoring wells were analyzed for selected metals and VOCs.The ground water monitoring also included sampling of the three municipal supply wellsto determine if the Midwest Manufacturing Operable Unit impacted the quality of waterwithin the municipal water supply system.
C. System Operation/Operation and Maintenance
Ground water monitoring was initiated at the Midwest Manufacturing Operable Uni t inNovember 1995. The three municipal supply wells (city well 1, 2, and 3) were sampledfor the following metals: aluminum, antimony, barium, cadmium, chromium, iron, lead,manganese, mercury, and nickel. These wells were also sampled for cyanide. Theinorganic parameters were analyzed for the total fraction only. The municipal supplywells were also analyzed for the following VOCs: TCA, 2-butanone, carbon disulfide, cis1,2-DCE, PCE, toluene, trans 1,2-dichloroethylene, TCE, VC, and total xylenes. NoVOCs were present above detection limits. Limited inorganics were present althoughnone were present above Maximum Contaminant Levels (MCLs) or SecondaryMaximum Contaminant Levels. The municipal water supply wells were sampled inNovember 1995, February 1996, May 1996, August 1996, November 1996, February1997, May 1997, August 1997, and November 1997. Ground water monitoring wellswere sampled during the same time as the municipal supply wells were sampled and werefurther sampled in August 1998, February 1999, August 1999, February 2000, August2000, February 2001, August 2001, February 2002, August 2002, February 2003, August2003, February 2004, August 2004, February 2005, and August 2005. A summary of theground water data collected since the last five-year review (2000-2005) is contained inAttachment 2.
A review of the most current ground water data indicates that the contamination presentin the ground water at the site is undergoing biodegradation as shown by the presence ofcis 1,2-DCE and VC in the ground water from monitoring wells PAMW-2A and PAMW-2B although cis 1,2-DCE is not present above the MCL. For PAMW-2B, only VCremains above the MCL. All other VOCs present in PAMW-2A and PAMW-9A arebelow their respective MCL. Ground water samples will be collected from these selectwells on a semi-annual basis.
The perimeter security fence has been damaged several times. Midwest Manufacturinghas maintained a photographic record of the damages to the fence and the repair of thefence. On May 18, 2005, during EPA's five-year review of the site, the perimeter fencewas inspected by EPA and IDNR and determined to be functioning as required as anaccess barrier.
The physical characteristics of the Midwest Manufacturing Operable Unit have changedfrom the time of the ROD Amendment. The manufacturing facility has expanded intoareas which previously were unoccupied although within the boundaries of the plant site.
There are no "environmentally" sensitive areas located within the eight-acre plant site.The plant site is located adjacent to a city park and the North Skunk River.
Restrictions were placed on the property deed on January 12, 1995, which: 1) l imi t anyuse of the property where children would be exposed to hazardous substances; 2) prohibi tusing the property for residents; 3) prohibit using the property for educational,recreational, daycare, or rehabilitative use in .any areas except where such uses areconducted on areas where clean fill was installed or within buildings on the property; 4)prohibit the installation of drinking water wells on the property; 5) restrict access by theinstallation of a security fence; 6) provide access to the federal government includingEPA; 7) require a written notice to EPA at least 30 days prior to conveyance of anyinterest in the premises; 8) provide notice to the deed, title, or other instalment ofconveyance for the premises stating that the premise is subject to the Consent Decree; 9)state that both parties have the right to sue to enforce the provisions of the ConsentDecree and the deed Declaration; and 10) provide that if Midwest Manufacturing wishesto change the institutional controls or deed restrictions, Midwest Manufacturing shallconsider this request as additional work and shall be wil l ing to pay for the EPA's effortsto perform the risk assessment and any additional work to change the restrictions. OnMay 18, 2005, EPA traveled to the Jasper County Courthouse in Newton, Iowa, andverified that the deed restrictions are still in place for the Midwest Manufacturing Plantsite.
During the final RA inspection, a survey of the area within a one-mile radius of .the plantsite was conducted by EDNR, EPA, and the potentially responsible parties' (PRPs)contractor. All residences located within the surveyed area were known to be on ruralwater, and therefore, no additional supply wells were identified for sampling andmonitoring. Conditions surrounding the plant site have remained unchanged since theEPA 2000 visit.
In February 2002, the IDNR issued a letter removing the Midwest Plant site from thestate's Registry ofHazardous Sites. Pursuant to Iowa Code Section 455B.431, when thedirector finds that a site on the Registry has been properly closed under section 455B.427,subsection 3, paragraph "e", with no evidence of potential adverse impact, the site shallbe defined as "properly closed" and removed from the Registry. This removes the sitefrom the requirement to file annual reports with IDNR.
Table 2 - Response Action Costs
From 10-01-2000 to 9-15-2005
Contract Support Costs
EPA's Oversight Costs
Total Costs
Total Cost rounded to nearest $1,000
$23,000
mm$37,000
D. Progress Since the Last Five-Year Review
This is the second five-year review for the Midwest Manufacturing/North Farmsite. The institutional controls are functioning to prevent exposure to thecontaminants present at the Midwest Manufacturing Operable Unit. The groundwater at the Midwest Manufacturing Operable Unit is approaching theremediation goals as shown by the levels of VOCs present within the groundwater samples collected from selected monitoring locations. Semi-annual groundwater monitoring will continue until MCLs are attained and verified for at leasttwo years (four sampling rounds). Future five-year reviews will need to verifythat the VOCs present in the aquifer continue to decline and that the institutionalcontrols for the Midwest Manufacturing Operable Unit remain effective inpreventing the exposure to hazardous substances.
v. Five-Year Review Process
Administrative Components
The Midwest Manufacturing/North Farm site team was notified of the initiation ofthe five-year review on February 2, 2005. The Midwest Manufacturing Review team wasled by Diane Easley, Remedial Project Manager for the Midwest Manufacturing/NorthFarm site. Bob Drustrup of the state of Iowa assisted in the review as the IDNRrepresentative, the support agency.
From March 1, 2005, to March 16, 2005, the review team established the reviewschedule whose components included:
Community InvolvementDocument ReviewData ReviewSite InspectionLocal interviewsFive-Year Review Report Development and Review
The schedule extended through October 31, 2005.
The following team members assisted in the review:
° Donn L. Stone, P.E., Stone Consulting, Project Manager for the siteemployed by the Midwest Manufacturing Company, the site'sresponsible party (515-433-2164)
° Jerry McCann, Midwest Manufacturing Company Representative (641-526-8106)
° Daniel Shiel, EPA Regional Counsel, responsible for the legal review ofthe document (913-551-7278)
Glenn Curtis, Chief, Iowa/Nebraska Remedial Branch of SuperfundDivision, Region VII, EPA (913-551-7726)
Becky Himes, EPA Community Involvement Coordinator (913-551 -7253)
Community Involvement
The EPA conducted an onsite visit on May 18, 2005. The review teamconsisted of EPA (Diane Easley), IDNR (Bob Druestrup), Stone Consulting(Donn Stone), Midwest Manufacturing (Jerry McCann), and communityrepresentative (Mr. Jay Stevenson). A site tour was completed by EPA, IDNR,and Stone Consulting representatives. The team met with representatives ofMidwest Manufacturing and the city of Kellogg. The EPA explained the five-year review process to these representatives and asked if there were anycommunity concerns regarding the Superfund site work at MidwestManufacturing. The only concerns expressed were regarding the costs for thiswork that were expended by both EPA and Midwest Manufacturing. Mr.Stevenson pointed out that many of the Kellogg residents were employed byMidwest Manufacturing and wanted to retain the plant in Kellogg along with thejobs Midwest provides. Mr. Stevenson serves as the public works director for thecity of Kellogg (population 622), overseeing activities of the police, fire, roads,etc. He is aware of any building or changes in residents in the city. There is noelementary school in Kellogg, and the former school was converted into smallapartments. On June 24, 2005, the EPA posted a Fact Sheet announcing theinitiation of the five-year review on EPA's web site. On June 27, 2005, a publicnotice was printed in the Newton Iowa Newspaper.
Document Review
This five-year review consisted of a review of relevant documents includingoperation and maintenance (O&M) records and monitoring data (see AttachmentI). Applicable ground water cleanup standards, as listed in the ROD, werereviewed. No changes were found in any of the applicable cleanup standards.
Data Review
As stated in the previous section, ground water monitoring has continued on asemi-annual basis. The state of Iowa collects split samples of the ground waterfrequently. The EPA reviews the ground water data from both sources (PRP andstate) and determines the accuracy of the information. The EPA review indicatedthat one ground water monitoring well remains above the MCL for VC. Semi-annual sampling will continue until all remaining wells remain below the MCLfor two years (four samples). The EPA anticipates this will be achieved withinthe next five years. Stone Consulting prepares semi-annual reports once dataresults have been verified. The August 2005 report is included as Attachment 3 tothis document.
Site Inspection
In preparation of the onsite inspection, the following work was completed: 1)coordinating with Stone Consulting for conducting the site inspection; 2)requesting contact information from Midwest Manufacturing Company todetermine a point of contact with the company for the site inspection and relatedfive-year review activities; 3) involvement in the assembly of the ground waterinformation from the ground water sampling effort for the plant site operable unit(Attachment 1); 4) interviews with IDNR technical staff; 5) a site visit confirmingcurrent site conditions; and 6) arranging for onsite interviews with localgovernmental official(s).
On May 18, 2005, the EPA and Stone Consulting met at the plant site to conduct asite inspection. We drove to the North Farm site and saw that no site conditionshad changed (no one living at the site, no vegetable garden, and land use remainsas pasture land). The IDNR representative met us at the Midwest ManufacturingPlant site, and we conducted an inspection of the perimeter fence and monitoringwells. No changes were noted at the plant site since EPA's 2000 inspection. Wetraveled back to the North Farm site so the IDNR person could also verify theexisting site conditions.
Interviews
The EPA, IDNR, and Stone Consulting met with representatives of MidwestManufacturing and the city of Kellogg, Iowa, to discuss the five-year reviewprocess and asked if there were questions concerning this effort. The onlyconcern expressed by the city of Kellogg was the cost which Midwest incursperforming this work and EPA's oversight costs. The Midwest Manufacturingrepresentative had no questions concerning this process. No other interviewswere conducted in relation to this five-year review.
Both operable units have deed restrictions, and EPA visited the Jasper CountyCourthouse in Newton, Iowa, to verify that the deed restrictions on the propertiesare still on file. The completed five-year review report will be available in theinformation repository at the Newton Public Library, Newton, Iowa. Notice ofthis report completion will be placed in the local newspaper, and local contactswill be notified by letter or phone. A brief summary of this report will also beincluded in EPA's website information.
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VI. Technical Assessment
The following conclusions support the determination that the remedy at theMidwest Manufacturing/North Farm site is expected to continue to be protective ofhuman health and the environment.
Question A: Is the remedy functioning as intended by the decision documents?
- The Health and Safety Plan - The Health and Safety Plan is in place, advisingground water monitoring personnel of the risks and measures to follow to avoidexposure to site contamination.
- Implementation of Institutional Controls and Other Measures - The PRPscontinue to own the site property, and there are no current or planned changes inland use at either operable unit which comprises the site.
- RA Performance - The remedy of institutional controls and ground watermonitoring has been shown to be effective. The contaminant concentrations havebeen decreasing as shown in the attached tables. Based on the data gatheredduring sampling events, the EPA and the IDNR approved the recommendation todiscontinue ground water monitoring at the North Farm Operable Unit and tomonitor the ground water at the Midwest Manufacturing Operable Unit on a semi-annual basis, and to continue the semi-annual sampling of monitoring wellsPAMW-02A, PAMW-02B, and PAMW-06 for the following selected volatileorganics: TCA, TCE, cis-1, 2-DCE, PCE, and VC.
- System Operations/O&M - System operations procedures are consistent withrequirements.
- Cost of System Operations/O&M - Total costs of the RA to June 30, 2000, were$131,802.98. Costs from July 1, 2000, to September 15, 2005, were $37,000 andhave been within an acceptable range.
- Opportunities for Optimization - The initial ground water sampling program hasbeen reduced. When contaminant concentration levels were determined to bebelow standards, the EPA and the IDNR approved a recommendation todiscontinue sampling and agreed with the abandonment of several monitoringwells.
- Early Indicators of Potential Remedy Failure - No early indicators of potentialremedy failure were noted during the review. Costs and maintenance activitieshave been consistent with expectations.
12
Question B: Are the assumptions used at the time of remedy selection still valid?
- Changes in Standards and To Be Considered - No new standards have beenintroduced which would be more stringent or which would affect protectiveness atthe site.
- Changes in Exposure Pathways - No changes in the site conditions that affectexposure pathways were identified as part of this five-year review. There are nocurrent or planned changes in land use. No new contaminants, sources, or routesof exposure were identified as part of this five-year review. There is no indicationthat hydrologic/hydrogeologic conditions are not adequately characterized. Therate of decrease of contaminant levels in ground water is consistent withexpectations at the time of the ROD.
- Changes in Toxicity and Other Contaminant Characteristics - Toxicity and otherfactors for contaminants of concern have not changed.
- Changes in Risk Assessment Methodologies - Since the time of the ROD, thereare no changes in risk assessment methodologies which call into question theprotectiveness of the remedy.
- Expected Progress Towards Meeting Remedial Action Objectives (RAOs) - Theground water monitoring data indicate that progress towards meeting the RAOscontinues and is anticipated to be achieved and verified within the next five-yearreporting period. The analytical results from one monitoring well indicate thatVC remains above the MCL. The August 2005 data indicate that VC was presentin the well at 2.2 ug/1. The MCL for VC is 2.0 ug/1.
Question C: Has any other information come to light that could call into questionthe protectiveness of the remedy?
- No additional information has been identified that would call into question theprotectiveness of the remedy.
Technical Assessment Summary
According to the data reviewed, the site inspection, and the interviews, the remedy isfunctioning as intended by the Amended ROD. There have been no changes in thephysical conditions of the site that would affect the protectiveness of the remedy. MostApplicable or Relevant and Appropriate Requirements (ARARs) for ground watercontamination have been met. There have been no changes in the toxicity factors for thecontaminants of concern that were used in the baseline risk assessment, and there havebeen no changes to the standardized risk assessment methodology that could affect theprotectiveness of the remedy. There is no other information that calls into question theprotectiveness of the remedy.
13
Issues
The only issue identified during this five-year review is whether the existing deedrestrictions are an appropriate long-term mechanism to control land and ground wateruse. Other possible mechanisms, such as an environmental covenant as provided for inthe Uniform Environmental Covenants Act (UECA), passed as 2005 Iowa Acts SF 375,might provide more effective land use controls over the long-term.
VIII. Recommendations and Follow-up Actions
The only follow-up action is to review the existing land use restrictions andevaluate other possible mechanisms, such as UECA.
IX. Protectiveness Statements
The remedy is expected to be protective of human health and the environmentupon attainment of the ground water cleanup goals which is expected to be completedwithin the next five years. In the interim, exposure pathways that could result inunacceptable risks are being controlled; and institutional controls are preventing exposureto, or the ingestion of, contaminated ground water. All threats at the site have beenaddressed through installation of fencing, ground water monitoring, and institutionalcontrols.
Long-term protectiveness of the RA. will be verified by obtaining additionalground water samples to verify the completion of the RA. Current data indicate that theplume remains very localized, and the remedy is functioning as required to achieveground water cleanup goals. The ground water at the Midwest Manufacturing OperableUnit does contain site contaminants above MCLs, but the levels are decreasing; and EPAand IDNR believe that the site contaminants will be reduced to levels below MCLswith in a reasonable period of time. The site has not been shown to cause any significantadverse impact on the environment.
X. Mext Review
This is a statutory five-year review. The next five-year review will be conductedwithin five years of the completion of this five-year review report in the year 2010.
The PRP will continue to conduct semi-annual ground water monitoring andmaintain all of the institutional controls (deed restrictions and security fencing) at the sitein accordance with the Consent Decree No. 4-94-CV-80417.
14
ATTACHMENT 1
Documents Reviewed
"Amended Record of Decision for the Midwest Manufacturing/North Farm Site - NorthFarm Operable Unit and Midwest Manufacturing Operable Unit" dated September 29,1993, EPA, Region VII
"Consent Decree Number 4-92-CV-80417" dated December 12, 1994
"Draft Five-Year Review - Midwest Manufacturing Co., Kellogg, Iowa" by FoxEngineering Associates Inc., dated July 2000
"Semi-Annual Sampling, Second Half 2005 - Midwest Manufacturing, Kellogg, Iowa''dated August 29, 2005
15
ATTACHMENT 2
Applicable or Relevant and Appropriate Requirements (ARARs)
North Farm Operable Unit (per September 1993 ROD)
Medium/Authority
Soils
Federal,State, Local,
etc.
State
ARAR
Iowa Code Section455B.426-identifies and listssites where disposalof "hazardouswaste" occurred
Status
Applicable
Requirement Synopsis
State registry of sites wherethe disposal of "hazardous"waste occurred prior toregulation under Chapter 455B.
Action to beTaken to Attain
ARAR
Midwest Manufacturing Operable Unit
Medium/Authority
Waste/RCRA
GroundWater/SafeDrinkingWater Act
Soils
GroundWater
FederalState,
Local, etc.
Federal
Federal
State
State
ARAR
ResourceConservation andRecovery Act, 40CFR Part 257.
MaximumContaminantLevels (MCLs) (40CFR Parts 141 and143) and non-zeroMaximumContaminant LevelGoals (MCLGs)
Iowa Code Section455B.426-identifies and listssites wheredisposal of"hazardous waste"occurredState of Iowa'sChapter 133
Status
Applicable
RelevantandAppropriate
Applicable
Applicable
RequirementSynopsis
Requirements forproper disposal ofsolid or hazardouswaste.
Standards (MCLs)have been adopted asenforceable standardsfor public drinkingwater systems; goals(MCLGs) are non-enforceable levels forsuch systems.
State registry of siteswhere the disposal of"hazardous waste"prior to regulationunder Chapter 455B.
State ground waterquality standardshave beenpromulgated. Whenstate levels are morestringent than federal,the state levels areused. Establishesprocedure fordetermining neededaction for groundwater pollutionoccurrences.
Actions Being Taken toAttain ARAR
Disposal of solid wastesgenerated as a result of theremedial action have been inaccordance with theserequirements.In 1993, the state of Iowaexpressed to EPA its positionregarding Chapter 133 ofIowa's Code tha t "passivecleanup" satisfies the state'sARAR. Passive cleanupentails leaving the contamin-ation in the ground water andallowing natural processes toremediate the site
In 1993, the state of Iowaexpressed to EPA its positionregarding its positionregarding Chapter 133 andstated that "passive" c leanupwould satisfy the state'sARAR.
16
ATTACHMENT 3
Figures & Semi-Annual Report
18
NORTH FARM SITE•^im
MIDWEST OPERABLE SITE.M - - /'
NORTH
NO SCALE
ENGINEERINGAUCS. OHM
S/7e LocationMidwest Manufacturing, Inc.
Kellogg, Iowa
FIGURE:
REVISION
DRAWN
BPM
PROJECT NO.S076-95A
DATE2/96
N50* PAMW 2 A&BPAMW 3 A&B
—— PAMW 4 A&B-p — PAMW 9 A&B
i J
ENGINEERINGAHES, IOWA
Monitoring Well LocationsMidwest Manufacturing, Inc.
Kellogg, Iowa
NORTH
HO SCALE
FIGURE: 4REVISION
DFJAWNBPM
NO.
PROJECT NO5076-95A
DATE
DATE2/96
1. ; 1
: • '. , i1t
l/J •»! JO TJ
< S £ §
« RMo ^
Czm
r*momz0
°rr
,
!•i^
ij ~~\\^? FOX Engineering Aisocialas. Inc.
&-&K^'( 1531 Airpori Rood/-/ v-^y\\ *m«». lowo 50010
ENGINEERING fr™ l\l lll~-™l•acs. am
PLOT PLAN
MIDWEST MANUFACTURING
KELLOGG. IOWA
FIGURE: 5REVISION
DRAWNKAG
NO.
PROJECT NO.4042-OOA
DATE
DATEB/2/OOj
TONE Consulting DONN L STONE, P.E.
D D
August 19, 2005
Ms. Diane EasleyUS EPA Region VII901 North 5lh StreetKansas City, Kansas 66101
RECEIVED
AUG 2 9 2005
SUFERFUND DIVISION
Re: Semi-annual Sampling, 2nd Half 2005Midwest Manufacturing, Kellogg, Iowa
Dear Ms. Easley:
Attached is a summary of the semi-annual sampling episode for Midwest Manufacturing,Kellogg, Iowa, addressing activities for the second half of the 2005 calendar year. Thissampling event notes vinyl chloride concentrations at non detectable levels in wells PMAW2A and PAMW 9A. Monitoring well PMAW 2B noted a vinyl chloride concentration of 2.2ppb.
Very truly yours,Stone Consulting
Donn L Stone, P.E.
cc: J. McCann, Midwest Man.R. Drustrup, IDNR
604 Redbud Drive ° Boone, Iowa 50036 ° 515-433-2164 phone/fax ° 515-689-7701 cell ° [email protected]
REPORT OF SEMI-ANNUAL SAMPLING
SECOND HALF 2005
IOWA CONSENT DECREE:
CIVBL NO, 4-92-CV-80417
KELLOGG, IOWA
August 2005
Stone Consulting4 Redbud DriBoone, Bowa
AIJG 2 9 2005
REPORT OF SEMI-ANNUAL SAMPLING
SECOND HALF 2005
IOWA CONSENT DECREE:
CIVIL NO. 4-92-CV-80417
PREPARED FOR
MIDWEST MANUFACTURING COMPANY
KELLOGG, IOWA
August 2005
I hereby certify that this engineering document wasprepared by me or under my direct personalsupervision and that I am a duly LicensedProfessional Engineer under the laws of the State of
Date
License Number: 11461My license renewal date is December 31, 2006
August 2005 SC003-05-391
TABLE OF CONTENTS
INTRODUCTION 1
CHRONOLOGY OF EVENTS 1
PERFORMANCE STANDARDS AND CONSTRUCTION QUALITY CONTROL 2
GROUNDWATER SAMPLING 3
CHEMICAL ANALYSIS 4
OPERATION AND MAINTENANCE 5
LIST OF APPENDICES
APPENDIX A - CHEMICAL ANALYSIS, GROUNDWATER SAMPLES, August 2005
APPENDIX B - INSPECTION REPORTS
APPENDIX C - HISTORIC DATA
August 2005 SC003-05-391
INTRODUCTION
The intent of this report is to identify and detail site activities and chemical analysis of
groundwater samples that have been performed to comply with the Consent Decree
(CD) for civil action 4-92-8041 7.
CHRONOLOGY OF EVENTS
A RAWP for the Midwest Manufacturing Facility was prepared and submitted by Donn
L Stone, PE, FOX Engineering Associates, Inc., Ames, Iowa in February 1995.
Subsequent revisions were made during April 1995, and July 1995. Acceptance of the
RAWP by EPA was received on August 3, 1995. The field activities were scheduled
upon acceptance of the RAWP.. The initial field activity to be completed was the
installation of the monitoring well on October 2,1995. The first sampling event for the
RAWP was performed on November 14, 1995, with samples being split with IDNR.
The water well survey was completed on November 2, 1995 and the perimeter fence
was installed on November 27, 1995. The final site inspection was completed on
December 6,1995. Quarterly sampling and reporting was performed from November
14,1995 to November 6,1997. Sampling frequency and parameters were reevaluated
at the end of the last forth quarter sampling episode performed on November 6, 1997.
It was determined by EPA and IDNR in a letter dated May 13, 1998 that sampling
events be performed on a semi-annual basis. Another condition of the May 13th letter
was to limit sampling to five monitoring wells and limit parameters of analysis to
substances noted as present during previous sampling events. After the August 2001
sampling event, Midwest requested that sampling of monitoring wells PAMW 4A and
PAMW 6A be discontinued. EPA reviewed the chemical analysis and confirmed by
letter dated November 30, 2001, that sampling and analysis of PAMW 4A and PAMW
6A could be discontinued. The most recent semi-annual sampling episode was
performed on August 1, 2005. A summary of recent and historic chemical analyses are
presented in the Appendix
Three monitoring wells were located at the North Farm site, NF MW 1, NF MW 2, and
1August 2005 SC003-04-391
NF MW 3. Sampling at this site was discontinued in accordance with Section I.C.4. of
Appendix B of the consent decree: Civil No. 4-92-CV-80417. These wells were
abandoned during 1999 according to the Operation and Maintenance Plan approved
by EPA. IDNR rules and regulations on well abandonment were followed.
Sampling at the three City of Kellogg municipal water supply wells was discontinued in
accordance with Section I.C.4. of Appendix B of the consent decree and EPAand IDNR
approval. These wells are city supply wells; therefore they are not required to be
abandoned.
Sampling for this event was performed August 1, 2005, at three (3) of the Midwest
Operable site monitoring wells, PAMW 2A, PAMW 2B, and PAMW9A. The remaining
wells at this site required no further sampling in accordance to Section I.C.4 of
Appendix B of the Consent Decree and the approval of EPA and IDNR. These wells
were abandoned during 1999 according to IDNR rules and regulations. The closed
wells are as follows: PAMW 1A, PAMW IB, PAMW 1C, PAMW 3A, PAMW 3B,
PAMW 4B, PAMW 5, PAMW 7A, PAMW 7B, PAMW 8A, PAMW 8B, PAMW 9B,
PAMW 10A, PAMW 10B, PAMW 11A, PAMW 11 B, MW95A. Well closure
documentation was submitted to EPA. Monitoring wells PAMW 4A and PAMW 6A,
which were approved to be abandoned in the November 30, 2001, EPA letter have yet
to be abandoned.
PERFORMANCE STANDARDS AND CONSTRUCTION QUALITY CONTROL
Groundwater sampling was performed as a one-phase sampling event August 1, 2005,
with groundwater depth measurements and well purging for all wells being performed
as an initial task, and sample collection for all wells being performed as a final
sampling task. The field activities initiated with the purging of wells PAMW 2A,
PAMW 2B, and PAMW 9A at the Midwest Operable site and then collection of the
samples. The Quality Assurance and Quality Control of the chemical analysis of the
2August 2005 SC003-04-391
groundwater samples were performed using methods noted in the RAWP to be
consistent with the EPA's Quality Assurance/Quality Control (QA/QC) requirements.
The purpose of the QA\QC samples is to identify the impact or lack of impact of
outside parameters on the collected samples. Analysis of a field sample was performed
to indicate the integrity of the sampling procedures. Inconsistencies were not noted
with the field sample. Copies of the chemical analyses of the recent sampling event
are included in Appendix A.
GROUNDWATER SAMPLING
Pre-sampling activities for all wells at the Midwest Operable site, included observation
of the condition of the well, specifically: the protective cover, the concrete plug, the
well casing, and the lock. None of the wells were noted to have conditions that
warranted correction at this time. Prior to sampling each well, the depth of water was
determined. Measurements of water levels in the monitoring wells were performed
with an electronic measuring tape graduated in 1/100-foot increments. After
determination of the water level, the monitoring well was purged by bailing a
minimum of three well volumes of water. No well was bailed dry during the purging
process.
Sample collection and preservation was accomplished in accordance with the accepted
RAWP, which noted following EPA guidance documents for sampling/analysis
activities. Water samples for the parameters were collected in PVC bailers. Water
collected for chemical analysis was distributed immediately upon removal from the
well into the sample containers. The chemical analyses required were performed by
Keystone Laboratory, Newton, Iowa. Keystone Laboratory is located approximately 10
miles from the project. The Iowa Department of Natural Resources was not present at
this sampling event to split collected samples for analysis.
August 2005 SC003-04-391
CHEMICAL ANALYSIS
Chemical analysis of groundwater samples was performed in a manner consistent with
the RAWP. Groundwater was sampled for five (5) VOC's as determined by EPA.
These VOC's include 1,1,1-trichloroethane, cis-1,2-dichloroethylene,
tetrachloroethylene, trichloroethane, and vinyl chloride. Table 1 summarizes the
chemical analyses of the current sampling episode. Table 2 summarizes the historic
data for the wells that are currently required to be sampled.
Discussions in spring 2001, between EPA, IDNR and Midwest Manufacturing lead to
agreement that reduction of the persistence of vinyl chloride to below action levels for
three future consecutive sampling events would most likely qualify the site for a no
further action status. It was noted that because of three conditions, the location of the
site with respect to the adjacent river, site access controls limit the potential for
persons to enter the site, and the minimal concentrations of regulated chemicals,
suggested that the site was a minor risk if any to the public.
The August 2005 sampling event noted organic compounds in all three monitoring
wells near the Midwest Operable disposal area. The concentrations of the compounds
were generally noted as less than MCLs. Historically, vinyl chloride has been
persistent in PAMW 2B at concentrations slightly above the action level, while vinyl
chloride has been non-detectable at PAMW 2A, a well in the same cluster. During this
monitoring event the concentration of vinyl chloride at PAMW 2B was noted as 2.2
ppm. No vinyl chloride was noted in wells PAMW2A or PAMW 9A as determined by
the samples delivered to the laboratory by Stone Consulting. .
Wells PAMW 2A, 2B, and 9A noted a detectable concentration of cis-1,2-
dichloroethylene (16.1, 41.0, and 23.2 ppb respectively) however all are below the
MCL. Previous sampling events have noted cis-1,2-dichloroethylene within the range
noted at this event. Although these chemicals are present at detectable levels, historic
4August 2005 SC003-04-391
data suggests that they will continue to decrease with time.
Trichioroethylene has been historically noted in PAMW 9A during all but one of the
sampling periods. This chemical continues to be present at a concentration (1.6 ppb)
less than the action level (5 ppb) in PAMW 9A. This concentration is consistent with
recent sampling events.
The blind sampje was a duplicate of PAMW 2A. The concentrations noted in
comparison reflect consistency within the laboratory procedures. The trip and field
samples both noted no presence of volatiles.
Chemical analysis was not available at the time of the preparation of this report.
Copies of that analysis will be forwarded upon receipt with a discussion of the
relevance of those analyses.
Chemical analysis of the groundwater, from the three (3) monitoring wells sampled at
the Midwest Operable site, generally shows a reduction in concentration from historic
to present data. While reduction in degree of concentration of volatiles is anticipated,
the rate of degradation is presently insignificant. This suggests that continual reduction
is not probable on a short term and concentrations may or may not decrease to the
non-detectable range or stabilize at lower levels in the near future. The reported
concentrations of cis-1, 2-dichloroethylene, trichloroethylene and vinyl chloride do not
suggest a highly contaminated area. The chemical analyses appear consistent with
former site activities and are in the range of expected concentrations.
OPERATION AND MAINTENANCE
Operation and Maintenance with respect to the Midwest consent decree is, for the
most part, limited to ensuring the integrity of the monitoring wells at the Midwest
Operable Unit. O&M procedures also include the periodic inspection of the perimeter
fence at the Midwest Operable Unit.
5August 2005 SC003-04-391
Routine sampling of the monitoring wells provides an opportunity to inspect each well
for integrity of construction. The wells that required no further sampling at the North
Farm site and Midwest Operable site were properly abandoned and closed. The
remaining monitoring wells at the Midwest Operable site will be examined each
sampling period to determine the condition of the wells. Items to be reviewed will be
the condition of the surface seals, outer well casing, inner well casing, casing cap and
protective posts. The condition of the monitoring wells was noted as satisfactory
during the recent sampling episode.
A review of the condition of the perimeter fence was made at the time of the final
inspection and will be continued with each sampling event. The current condition of
the fence is excellent.
August 2005 SC003-04-391
APPENDIX A
CHEMICAL ANALYSIS
GROUNDWATER SAMPLES
TABLE 1
Ayg us'l 2005
!:':!v. :":': :.::. •' ': "' : '.......' . . : • • • • • : • ' • " ; l!" ^ '•
Vinyl ChlorideCarbon Bisulfidetrans-1 ,2-Dichloroethylenecis-1 ,2-Dichloroethylene2-Butanone (MEK)1,1,1-TrichloroethaneTrichloroethyleneTolueneTetrachloroethyleneXylene, total
£re
o>
'2c
Q
O
.' ': :,::.-;'• v-".V2-
100705
2005
10005
10000
<CM
S
Q.
' . ' : • ' • '• '
<1<1<1
16.1<5<1<1<1<1<2
mN
§<tf0.
•V • . : '..• ."..I.'..'..:-.:
2.2<1<1
41.0<5<1<1<1<1<2
<o>
EQ̂.
. : . .;: :; : : :. • . • :. : -:-:. -:
<1
<1
<1
23.2<5<11.6<1<1<2
^0.coozcc."ZQ
..••:::••:•.;•:.•:•••.;.•:•:.•*::::•:;::
Q_JIUu.
••:--'-::'::-:-':---:":":::
<1
<1
<1
<1
<5<1<1<1<1<12
Analyses are noted in ug/l (ppb)
LfeystoneL A B O R A T O R I E S , INC,
M E M B E R
Accreditations:Iowa DNR; 095New Jersey DEP IAOO!Kansas DHE: E-10287
Work Order: 15H0017
ANALYTICAL REPORTAugust 11,2005
Page 1 of 4
Report To
Dorm StoneStone Consulting604 Redbud DriveBoone,lA 50036
\Vdrfc0rderrInformation
Date Received: 08/01/2005 1:45PMCollector:
Phone: (515^) 689-7701PO Number:
Project: SC 003 Midwest ManufacturingProject Number: SC003
( Analyte15H0017-01 MW2A
Result
Determination of Volatile Organic CompoundsVinyl Chloride <1.0 ug/lCarbon Disulfidetrans- 1 ,2-Dichloroethy lenecis-1 ,2-Dichloroethylene2-Butanone (MEK)1,1,1 -TrichloroethaneTrichloroethyleneTolueneTetrachloroethyleneXylenes, totalSurrogate: DibromofluoromethaneSurrogate: J, 2-Dichloroethane-d4Surrogate: Toluene-d8Surrogate: 4-Bromofluorobenzene
<1.0 ug/l<1.0 ug/l16.1 ug/l<5.0 ug/l<1.0 ug/l<I.O ug/l<1.0 ug/l<1.0 ug/l<2.0 ug/l
114%104%102%
98.7%
MRL
1.01.01.01.05.01.01.01.01.02.0
MethodMatrix: Water
EPA 8260BEPA 8260BEPA 8260BEPA 8260BEPA 8260BEPA 8260BEPA 8260BEPA 8260BEPA 8260BEPA 8260B83-12379-12883-11481-114
Analyst Analyzed QualifierCollected: 08/01/05 11:59
TVKTVKTVKTVKTVKTVKTVKTVKTVKTVKTVKTVKTVKTVK
08/09/05 22:2908/09/05 22:2908/09/05 22:2908/09/05 22:2908/09/05 22:2908/09/05 22:2908/09/05 22:2908/09/05 22:2908/09/05 22:2908/09/05 22:2908/09/05 22:2908/09/05 22:2908/09/05 22:2908/09/05 22:29
15H0017-02 MW2BDetermination of Volatile Organic CompoundsVinyl Chloride 2.2 ug/l 1.0Carbon Disulfide <1.0 ug/l ].Qtrans-1,2-Dichloroethylene <1.0 ug/l i.ocis-1,2-Dichloroethylene 41.0 ug/l 1.02-Butanone (MEK) <5.0 ug/l 5.01,1,1-Trichloroethane <1.0 ug/l i.oTrichloroethylene <1.0 ug/l i.oToluene <1.0 ug/l i.oTetrachloroethylene <I.O ug/l i.oXylenes, total <2.0 ug/l 2.0Surrogate: Dibromofluoromethane 113%Surrogate: 1,2-Dichloroethane-d4 102 %Surrogate: Toluene-d8 103%
Matrix: Water Collected: 08/01/05 11:16
EPA 8260BEPA 8260BEPA 8260BEPA 8260BEPA 8260BEPA 8260BEPA 8260BEPA 8260BEPA 8260BEPA 8260B83-12379-12883-114
TVKTVKTVKTVKTVKTVKTVKTVKTVKTVKTVKTVKTVK
08/09/0508/09/0508/09/0508/09/0508/09/0508/09/0508/09/0508/09/0508/09/0508/09/0508/09/0508/09/0508/09/05
23:0823:0823:0823:0823:0823:0823:0823:0823:0823:0823:0823:0823:08
The results in this report applv to the samples analyzed in accordance with the chain of custody document. This analytical reportmust be reproduced in its entirety. Samples were preserved in accordance -with 40 CFRfor pH adjustment unless otherwise noted.MRL= Method Reporting Limit.
Phone 641-792-8451 600 East 17th street SouthNewton, IA 50208
Fax 641-792-7989
\ L^cy stoneL A B O R A T O R I E S , INC.
M E M B E R
ACILStone Consulting604 Redbud DriveBooneJA 50036
Work Order: 15H0017August 11,2005
Page 2 of 4
| Analyte15HOOI7-02 MW2B
Result MRL MethodMatrix:Water
Analyst Analyzed QualifierCollected: 08/01/05 11:16
Determination of Volatile Organic CompoundsSurrogate: 4-Bromofluorobenzene
15HOOI7-03 MW9A
98.4% 81-114
Matrix:Water
TVK 08/09/05 23:08
Collected: 08/01/05 11:30Determination of Volatile Organic CompoundsVinyl ChlorideCarbon Disulfidetrans- 1 ,2-Dichloroethy lenecis-l,2-DichIoroethylene2-Butanone (MEK)1,1,1-TrichloroethaneTrichloroethyleneTolueneTetrachloroethyleneXylenes, totalSurrogate: DibromojluoromethaneSurrogate: 1 ,2-Dichloroethane-d4Surrogate: Tolvene-d8Surrogate: 4-Bromofluorobenzene
15H0017-04 Blind"
<1.0 ug/1<1.0 ug/1<1.0 ug/123.2 ug/1<5.0 ug/1<1.0 ug/1
1.6 ug/1<1.0 ug/i<1.0 ug/1<2.0 ug/1
114%101%103%
96.6%
.0
.0
.0.
.0
.0
.0
.01.01.02.0
EPA 8260BEPA 8260BEPA 8260BEPA 8260BEPA 8260BEPA 8260BEPA 8260BEPA 8260BEPA 8260BEPA 8260B83-12379-12883-11481-114
Matrix: Water
TVKTVKTVKTVKTVKTVKTVKTVKTVKTVKTVKTVKTVKTVK
08/09/05 23:4808/09/05 23:4808/09/05 23:4808/09/05 23:4808/09/05 23:4808/09/05 23:4808/09/05 23:4808/09/05 23:4808/09/05 23:4808/09/05 23:4808/09/05 23:4808/09/05 23:4808/09/05 23:4808/09/05 23:48
Collected: 08/01/05 11:59Determination of Volatile Organic CompoundsVinyl ChlorideCarbon Disulfidetrans- 1 ,2-Dichloroethylenecis-l,2-Dichloroethylene2-Butanone (MEK)1,1,1 -TrichloroethaneTrichloroethyleneTolueneTetrachloroethyleneXylenes, totalSurrogate: DibromofluoromethaneSurrogate: l,2-Dichloroethane-d4Surrogate: Toluene-d8Surrogate: 4-Bromofluorobenzene
<1.0 ug/1<1.0 ug/1<1.0 ug/115.8 ug/1<5.0 ug/1<1.0 ug/1<1.0 ug/1<1.0 ug/1<1.0 ug/1<2.0 ug/1
112%10] %104%
98.0%
1.01.01.01.05.01.01.01.01.02.0
EPA 8260BEPA 8260BEPA 8260BEPA 8260BEPA 8260BEPA 8260BEPA 8260BEPA 8260BEPA 8260BEPA 8260B83-12379-12883-11481-114
TVKTVKTVKTVKTVKTVKTVKTVKTVKTVKTVKTVKTVKTVK
08/10/05 0:2708/10/05 0:2708/10/05 0:2708/10/05 0:2708/10/05 0:2708/10/05 0:2708/10/05 0:2708/10/05 0:2708/10/05 0:2708/10/05 0:2708/10/05 0:2708/10/05 0:2708/10/05 0:2708/10/05 0:27
1 SHOO 17-05 TripDetermination of Volatile Organic CompoundsVinyl Chloride <1.0 ug/1
Matrix:Water Collected: 08/01/05 12:05
1.0 EPA8260B TVK 08/09/0521:49
The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical reportmust be reproduced .in its entirety. Samples were preserved in accordance -with 40 CFRfor pH adjustment unless otherwise noted.MRL= Method Reporting Limit.
Phone 641-792-8451 600 East 17*h Street SouthNewton, IA 50208
Fax 641-792-7989
L A B O R A T O R I E S , INC.
M E M B E R
Stone Consulting604 Redbud DriveBoone, IA 50036
Work Order: 15H0017August 11, 2005
Page 3 of 4
| Analyte1SH0017-05 Trip
Result MRL MethodMatrix: Water
Analyst Analyzed QualifierCollected: 08/01/05 12:05
Determination of Volatile Organic CompoundsCarbon Disulfidetrans- 1 ,2-Dichloroethy lenecis- 1 ,2-Dichloroethylene2-Butanone (MEK)1 , 1 , 1 -TrichloroethaneTrichloroethyleneTolueneTetrachloroethyleneXylenes, totalSurrogate: DibromofluoromethaneSurrogate: 1, 2-Dichloroethane-d4Surrogate: Toluene-d8Surrogate: 4-Bromqfluorobenzene
15H0017-06 Field
<1.0 ug/1<1.0 ug/1<1.0 ug/1<5.0 ug/1<1.0 ug/1<1.0 ug/1<1.0 ug/1<1.0 ug/1<2.0 ug/1
109%102%102%
98.7%
1.01.01.05.01.01.01.01.02.0
EPA 8260BEPA 8260BEPA 8260BEPA 8260BEPA 8260BEPA 8260BEPA 8260BEPA 8260BEPA 8260B83-12379-12883-11481-114
Matrix:Water
TVKTVKTVKTVKTVKTVKTVKTVKTVKTVKTVKTVKTVK
08/09/05 21:4908/09/05 21:4908/09/05 21:4908/09/05 21:4908/09/05 21:4908/09/05 21:4908/09/05 21:4908/09/05 21:4908/09/05 21:4908/09/05 21:4908/09/05 21:4908/09/05 21:4908/09/05 21:49
Collected: 08/01/05 12:05Determination of Volatile Organic CompoundsVinyl ChlorideCarbon Disulfidetrans- 1,2-Dichloroethy lenecis- 1,2-Dichloroethy lene2-Butanone (MEK)1,1,1 -TrichloroethaneTrichloroethyleneTolueneTetrachloroethyleneXylenes, totalSurrogate: DibromofluoromethaneSurrogate: 1 , 2-Dichloroethane-d4Surrogate: Toluene-d8Surrogate: 4-Bromofluorobenzene
<1.0 ug/1<1.0 ug/1<1.0 ug/1<1.0 ug/1<5.0 ug/1<1.0 ug/1<1.0 ug/1<1.0 ug/1<I.O ug/I<2.0 ug/1
109%102%103%
98.4%
1.01.01.01.05.01.01.01.01.02.0
EPA 8260BEPA 8260BEPA 8260BEPA 8260BEPA S260BEPA 3260BEPA 8260BEPA 8260BEPA 8260BEPA 8260B83-12379-12883-11481-114
TVKTVKTVKTVKTVK
•TVKTVKTVKTVKTVKTVKTVKTVKTVK
08/09/05 21:0908/09/05 21:0908/09/05 21:0908/09/05 21:0908/09/05 21:0908/09/05 21:0908/09/05 21:0908/09/05 21:0908/09/05 21:0908/09/05 21:0908/09/05 21:0908/09/05 21:0908/09/05 21:0908/09/05 21:09
The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical reportmust be reproduced in its entirety. Samples were preserved in accordance with 40 CFRfor pH adjustment unless otherwise noted.MRL= Method Reporting Limit.
Phone 641-792-8451 600 East 17th Street SouthNewton, IA 50208
Fax 641-792-7989
APPENDIX B
INSPECTION REPORTS
MONITORING WELLS
AND
PERIMETER FENCE
CHECK LIST
MONITORING WELL CONDITION
Inspected By: Donn StoneDate of inspection: August 1, 2005
Monitoring well identification: PAMW-2ALocation: See figureDiameter: 2 inchesDepth: 26 feet
Condition of:Casing: okProtective cover: okConcrete seal: Starting to crackProtective posts: okOther comments: None
Monitoring well identification: PAMW-2BLocation: See figureDiameter: 2 inchesDepth: 26 feet
Condition of:Casing: okProtective cover: okConcrete seal: Starting to crackProtective posts: okOther comments: None
Monitoring well identification: PAMW-9ALocation: See figureDiameter: 2 inchesDepth: 26 feet
Condition of:Casing: okProtective cover: okConcrete seal: okProtective posts: okOther comments: None
CHECK LIST
PERIMETER FENCE CONDITION
Inspected By: Donn StoneDate of inspection: August 1, 2005
Fence identification: Perimeter fence extensionsLocation: Midwest Manufacturing, Kellogg
Condition of:
Structure, poles: Good
Fence fabric: Good
Barbed wire: Good
Other comments: No apparent problems.
APPENDIX C
HISTORIC DATA
CHEMICAL ANALYSIS SUMMARY
TABLE 2
CHEMICAL ANALYSISMIDWEST OPERABLE SIT
'•' "•• ., ;••- -^ ;.••:'»• .:i-:';J.:::.;/.:?:--i-'.: ••::.:••:;•: :':•:;/ '•:MCL Drinking Water
PAMW 2 APAMW 2 APAMW 2 APAMW 2 APAMW 2 APAMW 2 APAMW 2 APAMW 2 APAMW 2 APAMW 2 APAMW 2 APAMW 2 APAMW 2 APAMW 2 APAMW 2 APAMW 2 APAMW 2 APAMW 2 APAMW 2 APAMW 2 APAMW 2 A
PAMW 2 APAMW 2 A
0*0̂3Q
•'.'. •;.'.- :!..•:.:•;:•••:;::.•
Nov95May 96Aug96Nov96Feb97May 97May 97Nov97Aug 98Feb-99Aug-99Feb-00Aug-00Feb-01Aug-01Feb-02Aug-02Feb-03Aug-03Feb-04Aug-04Feb-05Aug-05
1,1,
1- T
richl
oroe
than
e
I:.:! !:•::• \:; I:-::-;'/:::
200
<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1
<1<1<1<1
cis-
1 .2
-Dic
hlor
oeth
ylen
e
'.''.;'.:",?:: .::::F
70
22.719.5
•:•-,.„ .73.725.730.6
1719
16.220.728.9
|_ 23.3.22.418.615.426.714.522.2
2125.722.617.917.116.1
Tet
rach
olro
ethy
lene
•&3$£&'?.?.
5
<1
<1<1<1<1<1
<1<1<1<1<1<1<1<1<1<1<1<1<1
<1<1<1<1
Tric
hlor
oeth
ylen
e
w^"-:.5
3.2
-:>i5.6;2.82.5
• '^":1t:3:
4.24.93.8<1<1<11.3<1<1
:'7'.T8v7j'•Vrs.B
•- ";•:• 9:2;••:<•• 14.1
2.4
-..11.65.92.1<1
Vin
yl C
hlor
ide
. . ,:' '. •• . •• -.-' '..: : ..:.y.: :•
2<1<1
j--;? .'.5.2<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1
TABLE 3
MIDWEST OPERABLE SITE
i-'^f!'^;;--::$tys^:;'&>^\">:::-i;dMCL Drinking Water
PAMW 2 BPAMW 2 BPAMW 2 BPAMW 2 BPAMW 2 BPAMW 2 BPAMW 2 BPAMW 2 BPAMW 2 BPAMW 2 BPAMW 2 BPAMW 2 BPAMW 2 BPAMW 2 BPAMW 2 BPAMW 2 B
5coO
• •. . .'.' . .' ' •- •' .- -.' • '. :' :- :
Feb-96Aug-98Feb-99Aug-99Feb-00Aug-00Feb-01Aug-01Feb-02Aug-02Feb-03Aug-03Feb-04Aug-04Feb-05Aug-05
1,1,
1- T
richl
oroe
than
e
•.;.::.;-;':::: •.•:;;;•;.:.;
200<1<1<1<1<1<1<1<1<1'<1<1<1<1<1<1<1
cis-
1 .2
-Dic
hlor
oeth
ylen
e
: ' '-: i '--: '-"--hi! '--::
70
:,,; .••.•>.- 102•.-•^r-72.1
••-* :::74.5:;;: ;-; 84.2
60.153.662.827.852.550.243.416.145.348.750.841.0
Tet
rach
olro
ethy
lene
f'S^j^v^5<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1
Tric
hlor
oeth
ylen
e
' : : • ' . ;: •• :'•' ' '-: ''.-..•
54.3
2<1<1<1<1<15.9<1<1<1
4.6<1<1<1<1
Vin
yl C
hlor
ide
. • • . ;.;. . .; • • •
2
^i.,-.'-i.6:-5-4>D
:::• <':5.7
<1
:'. \ ::'.4.4•••';?: u-2.6.•:.-. ••-, 3J
• 1-1. - . . : - -3.2i- •.,;.: 3..0:-:.;vVl.,; . 2
<1
-.•:: .2.6/•'-• > 2.6
•f--'%--3v4^•r;:'.^2
TABLE 4
CHEMICAL ANALYSIS SUMMARYMIDWEST OPERABLE
• •. • • '.• • • . ' • . . . " . •• . ' . ; . • •'.:'.:. • • . .• •.•• • • • • • • • • • . • : • •
MCL Drinking WaterPAMW 9 APAMW 9 BPAMW 9 APAMW 9 APAMW 9 APAMW 9 APAMW 9 APAMW 9 APAMW 9 APAMW 9 APAMW 9 APAMW 9 APAMW 9APAMW 9APAMW 9APAMW 9APAMW 9APAMW 9APAMW 9APAMW 9APAMW 9APAMW 9APAMW 9APAMW 9A
30
: . •• '-'.:;..:j :-!:.:.:'.::. '."'.:
Nov-95Feb-96May-96Aug-96Nov-96Feb-97May-97Aug-97Nov-97Aug-98Feb-99Aug-99Feb-00Aug-00Feb-01Aug-01Feb-02Aug-02Feb-03Aug-03Feb-04Aug-04Feb-05Aug-05
1,1,
1- T
richl
oroe
than
e
;::;;:-:f:" :;.:•:!.;:.:'•:
200<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1
cis-
1 .2
-Dic
hlor
oeth
ylen
e
::;.•:•,'; -:X;,:-v
7050.8
<135.740.954.447.337.845.637.627.234.3
2732.534.641.834.133.542.4
3631.247.829.421.123.2
Tet
rach
olro
ethy
lene
v^-vS:-^
5<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1
Tric
hlor
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5.-: / 26.2
<1; :-*:• 22
20.37-.C31 .1
. :24v9
. 20.-1
: :.20'.9- . 1 7 . 8
:vn.9- 9.6
•: -1: 5.8:
':.:•• '̂ 7:3'4.94.44.44.44.33.32.03.03.02.71.6
Vin
yl C
hlor
ide
!• :i.:':" •':':•' ••••;:-.::'-..
2
••_;.-,;£2-:3<1
-:.:.^-i2.3-••-V-2.1'H:'sr;^3:5
1.91.5<1<1<1<1<11.21.61.91.71.9<1<1<11.6<1<1<1
TABLE 5
.,.v::::-:::'Vi:::-:\-:|:': ;.::;/;::•.; •;:;:.•:•;•;;:;.;.:,;;...
MCL Drinking WaterPAMW 4 APAMW 4 BPAMW 4 APAMW 4 APAMW 4 APAMW 4 APAMW 4 APAMW 4 APAMW 4 APAMW 4 APAMW 4 APAMW 4 APAMW 4 APAMW 4APAMW 4APAMW 4APAMW 4APAMW 6 APAMW 6 APAMW 6 APAMW 6 APAMW 6 APAMW 6 APAMW 6 APAMW 6 APAMW 6 APAMW 6 APAMW 6 APAMW 6 APAMW 6 APAMW 6 APAMW 6 APAMW 6 A
0)15D
•'. '. . ." . '. .'. . '.:'•:.••: "
1,1,
1- T
richl
oroe
than
e
::•:••- "•<•* •<:•;•:
1 200Nov95Feb96May 96Aug 96Nov96Feb97May 97Aug 97Nov97Aug 98Feb-99Feb-99Aug-99Feb-00Aug-00Feb-01Aug-01Nov95Feb96May 96Aug 96Nov96Feb97May 97Aug 97Nov97Aug 98Feb-99Aug-99Feb-00Aug-00Feb-01Aug-01
<1<1<1
<1
<1
<1
<1<1<1
<1
<1
<1
<1
<1<1<1
<1<1
11.74
1.37.1<1
2.3<1
6.11.4<1<11.5<1
2.1<1
0)cV
+- t0)oj5obiCNj
i
'o:..,.,-::, :.:;.;:::..
70<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1
Tet
rach
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ethy
lene
• S-:-::̂ :' •:•
5<1<1<1<1<1<1<11.5<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1
<1
Tric
hlor
oeth
ylen
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^:;:-.:--:::yv ;5
3.43.43.91.64.3
3.02.51.51.7
<1<1<1<11.71.71.4<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1
Vin
yl C
hlor
ide
..:;.:';' :. . : . • . •.! •
2<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1<1
TABLE 6
(U-i— •roQ 1,
1,1-
Tric
hlor
oeth
ane
• ::- •*;; ::::::::V..; ;,. it '{^ ;̂™": i i:-:: • :-:--'::
: i •::: •%; :.; -.:::'- &$&.?-• -rt-.l
MCL Drinking WaterFIELDFIELDFIELDFIELDFIELDFIELDFIELDFIELDFIELDFIELDFIELDFIELDFIELDFIELDFIELDFIELDFIELDFIELDFIELDFIELDFIELDFIELDFIELD
Feb96May 96Aug96Nov96Feb97May 97Aug 97Nov97Aug 98Feb-99Aug-99Feb-00Aug-00Feb-01Aug-01Feb-02Aug-02Feb-03Aug-03Feb-04Aug-04Feb-05Feb-05
200
<1<1<1
<1
000000000
<1<1<1<1<1<1
cis-
1 .2
-Dic
hlor
oeth
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....... . ..;. . : : :;.'•-.: '
70
<1<1<1
<1
000000000
<1<1<1<1<1<1
Tet
rach
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ethy
lene
Tric
hlor
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mm^m^->5
<1<1<1
<1
000000000
<1<1<1<1<1<1
5
<1<1<1
<1
000000000
2.52.5<1<1<1<1
Vin
yl C
hlor
ide
'•':'...•...:'.•:••.•.'•:•:.••'.
2
<1<1<1
<1
000000000
<1<1<1<1<1<1
