FIFTH FIVE-YEAR REVIEW REPORT FOR

BIG D CAMPGROUND SUPERFUND SITE

ASHTABULA COUNTY, OHIO

Prepared by

U.S. Environmental Protection Agency

Region 5

Chicago, Illinois

XDouglas Ballotti, Director

Superfund Emergency & Management Division

Signed by: DOUGLAS BALLOTTI

9/30/2019

950945

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Table of Contents LIST OF ABBREVIATIONS & ACRONYMS ........................................................................................ 3 I. INTRODUCTION .................................................................................................................................. 4

Site Background ..................................................................................................................................... 4

Five-Year Review Summary Form ........................................................................................................ 5 II. RESPONSE ACTION SUMMARY ..................................................................................................... 5

Basis for Taking Action ......................................................................................................................... 5 Response Actions ................................................................................................................................... 6 Status of Implementation ....................................................................................................................... 7

Institutional Controls ............................................................................................................................. 8 Systems Operations/Operation & Maintenance ................................................................................... 10

III. PROGRESS SINCE THE LAST REVIEW ...................................................................................... 10

IV. FIVE-YEAR REVIEW PROCESS ................................................................................................... 12 Community Notification, Involvement & Site Interviews ................................................................... 12 Data Review ......................................................................................................................................... 12 Site Inspection ...................................................................................................................................... 13

V. TECHNICAL ASSESSMENT ........................................................................................................... 16 QUESTION A: Is the remedy functioning as intended by the decision documents? ......................... 16

QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action

objectives (RAOs) used at the time of the remedy selection still valid? ............................................. 16 QUESTION C: Has any other information come to light that could call into question the

protectiveness of the remedy? .............................................................................................................. 17 VI. ISSUES/RECOMMENDATIONS .................................................................................................... 17

VII. PROTECTIVENESS STATEMENT ............................................................................................... 18

VIII. NEXT REVIEW .............................................................................................................................. 19

REFERENCE LIST ................................................................................................................................. 20 APPENDIX A…………………………………………………………………………………………...21

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LIST OF ABBREVIATIONS & ACRONYMS

AOC Administrative Order on Consent

ARAR Applicable or Relevant and Appropriate Requirement

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act

CFR Code of Federal Regulations

COCs Contaminants of Concern

DAT 2,4 diaminotoluene

DCA Dichloroethane

DCB Dichlorobenzene

DCE Dichloroethene

EPA United States Environmental Protection Agency

ESD Explanation of Significant Differences

FS Feasibility Study

FYR Five-Year Review

ICs Institutional Controls

MCB Monochlorobenzene

MCLs Maximum Contaminant Limits

MEA Monoethanolamine

MNA Monitored Natural Attenuation

NCP National Contingency Plan

NCP National Oil and Hazardous Substances Pollution Contingency Plan

NPL National Priorities List

O&M Operation and Maintenance

OEPA Ohio Environmental Protection Agency

ORP Oxidation Reduction Potential

OSWER Office of Solid Waste and Emergency Response

PCE Perchloroethylene or perchloroethene or tetrachloroethene

QAPP Quality Assurance Project Plan

RAS Remedial Action Standard

RI Remedial Investigation

RI/FS Remedial Investigation/Feasibility Study

PRP Potentially Responsible Party

RAO Remedial Action Objectives

ROD Record of Decision

RPM Remedial Project Manager

Site Big D Campground Superfund Site

TBC To be considereds

UU/UE Unlimited Use and Unrestricted Exposure

VC Vinyl Chloride

VOC Volatile Organic Compound

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I. INTRODUCTION

The purpose of a Five-Year Review (FYR) is to evaluate the implementation and performance of a

remedy in order to determine if the remedy is and will continue to be protective of human health and the

environment. The methods, findings, and conclusions of reviews are documented in FYR reports such as

this one. In addition, FYR reports identify issues found during the review, if any, and document

recommendations to address them.

The United States Environmental Protection Agency (EPA) is preparing this FYR pursuant to the

Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Section 121,

consistent with the National Contingency Plan (NCP)(40 CFR Section 300.430(f)(4)(ii)) and considering

EPA policy.

This is the fifth FYR for the Big D Campground Superfund Site (Big D Site or Site). The triggering

action for this statutory review is the completion date of the previous FYR. The FYR has been prepared

due to the fact that hazardous substances, pollutants, or contaminants remain at the site above levels that

allow for unlimited use and unrestricted exposure (UU/UE).

The Site consists of two Operable Units (OUs). Both are addressed in this FYR. The remedy for OU1

addresses groundwater at the site, and the remedy for OU2 addresses the source material.

The Big D Site FYR was led by Bill Ryan and Dion Novak, Remedial Project Managers (RPM) for

EPA. Regan Williams and Scott Aschenbrenner, Project Managers for the Ohio Environmental

Protection Agency (OEPA), provided support in the review of monitoring data and site conditions.

A notice sent to OEPA and the Potentially Responsible Parties (PRPs) on 4/2/2018 officially initiated

this review.

Site Background

The Big D Site is a former sand and gravel quarry located in Kingsville, Ohio, approximately 2.5 miles

south of Lake Erie and 50 miles northeast of Cleveland, Ohio. The Site lies between Creek Road and

Conneaut Creek, with residential areas and the former Big D Campground nearby. The southern portion

of the site contains a small, capped landfill that accepted hazardous and non-hazardous waste for

disposal when the quarry was operating. Known hazardous waste disposed in the landfill at the site

included residues from toluene diisocyanate (TDI) production, toluene diisocyanate, chlorobenzene, and

diaminotoluene. In addition to the known hazardous wastes, other wastes of undocumented type and

quantity were disposed of in the landfill. Available information suggests that these wastes included

drummed halogenated and non-halogenated solvents, caustics, and oily substances. Waste in the landfill

contaminated surrounding soil and groundwater with volatile organic compounds (VOCs) and heavy

metals including barium, chromium, and lead.

The current land use for the surrounding area is both residential and recreational, and Conneaut Creek is

used for fishing and swimming. EPA anticipates that these land uses will continue into the foreseeable

future. The Site is currently fenced, and the incinerated waste and soils are contained within the fenced

area under a landfill cap. Groundwater at the Site is currently not used as a source of drinking water, and

the PRP for the Site, Olin Corporation (Olin), has acquired the groundwater rights of the surrounding

property owners. Olin has also placed deed restrictions on these nearby properties to prohibit the future

use of groundwater.

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FIVE-YEAR REVIEW SUMMARY FORM

SITE IDENTIFICATION

Site Name: Big D Campground

EPA ID: OHD 980611735

Region: 5 State: OH City/County: Kingsville/Ashtabula

SITE STATUS

NPL Status: Final

Multiple OUs? Yes Has the site achieved construction completion? Yes

REVIEW STATUS

Lead agency: EPA, Region 5

Author name: Bill Ryan and Dion Novak

Author affiliation: EPA Region 5

Review period: 4/2/2018 – 8/10/2019

Date of site inspection: 5/23/2018, 8/13/2019

Type of review: Statutory

Review number: 5

Triggering action date: 4/16/2014

Due date (five years after triggering action date): 4/16/2019

II. RESPONSE ACTION SUMMARY

Basis for Taking Action

Hazardous substances have been released at the Big D Site. As recorded in the 1989 Record of Decision

(ROD), these substances included:

Source Area Soil Groundwater Surface Water

barium barium barium barium

lead beryllium beryllium beryllium

nickel lead lead lead

chlorobenzene nickel nickel nickel

1,2-dichlorobenzene chlorobenzene chlorobenzene chlorobenzene

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1,4-dichlorobenzene 1,2-dichlorobenzene 1,2-dichlorobenzene

trichloroethene 1,4-dichlorobenzene 1,4-dichlorobenzene

tetrachloroethene trichloroethene trans-1,2 dichloroethene

vinyl chloride tetrachloroethene diaminotoluene

vinyl chloride trichloroethene

tetrachloroethene

vinyl chloride

The primary risks at the Site were from ingestion of contaminated groundwater. VOCs were detected in

shallow wells screened in the water table aquifer and in wells screened in the alluvial over bank deposits

along Conneaut Creek. No contamination was found in the confined bedrock aquifer. No VOCs

attributable to site activities were detected in the residential wells sampled. Surface water samples from

Conneaut Creek indicated that no contaminants of concern (COCs) were present above Remedial Action

Standards (RASs). Chlorobenzene was the only organic compound detected in surface water samples

from Conneaut Creek; however, all detections were below RASs. No sediment contamination

attributable to site activities was detected. Groundwater monitoring continues at the site and is focused

on residual VOCs.

Response Actions

Big D was proposed for the National Priorities List (NPL) in December 1982 and it became final on

the NPL in September 1983. EPA subsequently conducted a fund-financed Remedial Investigation (RI)

from November 1986 to October 1988 to: 1) determine the nature and extent of contamination at the

Site, 2) determine whether substances migrating from the Site endangered public health, welfare, or

the environment, and 3) gather the data necessary to support a feasibility study. EPA concluded in the

RI report that the waste buried in the former landfill had contaminated soil and groundwater.

EPA subsequently completed a fund-financed Feasibility Study (FS) of cleanup alternatives to address

the contaminated media.

The Big D site was divided into two OUs: groundwater (OU1) and source area material (OU2).

Both organic compounds and certain heavy metals were initially identified as COCs in the RI/FS report,

but in 1993 EPA issued an Explanation of Significant Differences (ESD) removing metals as COCs. The

current COCs include perchloroethene (PCE), trichloroethene (TCE), trans-1,2-dichloroethene (tDCE),

vinyl chloride (VC), diaminotoluene (2,4-DAT), and monochlorobenzene (MCB). These COCs are

found in the water table aquifer that flows northward from the former landfill. The water table aquifer is

underlain by a glacial till aquitard and is not hydraulically connected to the underlying bedrock aquifer.

EPA issued a ROD in 1989 to clean up both OUs. The selected remedy required the following:

• Site fencing

• Excavation and on-site incineration of source area material

• On-site disposal of treated residuals and backfilling

• Groundwater extraction and treatment

• Discharge of treated groundwater to Conneaut Creek

• Groundwater and surface water monitoring

• Deed restrictions

The groundwater extraction and treatment remedy was modified in an ESD to include an interceptor

trench that was installed adjacent to Conneaut Creek.

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EPA also issued a Unilateral Administrative Order (UAO) in 1989, requiring Olin to conduct the

selected cleanup actions. Olin excavated and incinerated waste materials on-site, placed a clay cap

over the former landfill, and began operating the groundwater extraction and treatment system in 1994.

Olin also connected nearby residences to municipal water and placed deed restrictions on the

surrounding properties to prohibit the current and future use of groundwater as well as limiting

excavation in specific Site areas. EPA approved the Remedial Action Implementation Report

documenting compliance with remedy requirements in March 1995.

Remedial Action Objectives (RAOs) for the Site were established to address risk and comply with

Applicable or Relevant and Appropriate Requirements (ARARs). They include the following:

• Adequately protect the environment and public health from ingestion or direct contact with

contaminated groundwater at the Site, and

• Reduce the concentrations of Site COCs in groundwater to their respective cleanup goals.

RASs for the Site for groundwater are as follows:

Contaminant of Concern Cleanup Goal (μg/L) PCE 5 TCE 5 tDCE 100 VC 2

MCB 100 2,4-DAT 50

Status of Implementation

Source Area Excavation

A total of 93,219 tons of material were excavated from the former landfill and incinerated. This resulted

in an excavated area of approximately 2.7 acres with dimensions of 230 feet wide by 510 feet long and

18 feet deep. The excavated area was backfilled with ash and covered with clean fill and vegetated

topsoil.

On-site incineration

The incinerator trial burn was conducted in September 1992 under the terms of an EPA interim burn

approval. The interim burn continued until February 1993, when EPA approved the trial burn report,

from which full burn production commenced. During the trial burn, ash was tested in accordance with

the Confirmation of Incinerator Ash Delistability Plan. The combination of the trial burn and the

periodic ash sampling analysis confirmed that the ash was eligible for delisting and EPA allowed the ash

to be placed into the landfill. Wastes excavated from the former landfill were incinerated and the ash

was sampled prior to being placed back into the landfill.

The Remedial Action Implementation Report was approved by EPA in March 1995.

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Water Table Aquifer Groundwater Collection System

The selected remedy for the water table aquifer was two interceptor trenches: one at the downgradient

edge of the contaminant plume and one at the north end of the source area. Olin designed a modified

groundwater extraction system to include the use of active groundwater pumping using wells in the

water table aquifer and an approximately 500-foot-long artificial recharge trench. This design change

was approved by EPA in a 1993 ESD.

Eight extraction wells were installed. Ten monitoring wells were installed to be sampled quarterly to

determine the extent of the groundwater plume. The potable water recharge system, supplied by city

water, was installed at the north end of the excavation.

The groundwater extraction system was shut down in 1999 in order to complete a pilot study evaluating

monitored natural attenuation (MNA) as a Site remedy for groundwater. The system has remained shut

down as additional groundwater monitoring information has been collected. A Focused Feasibility Study

was submitted to EPA in 2018, in which the PRPs were asked to summarize existing groundwater data

and to present information to support a potential remedy change to MNA. EPA has asked the PRPs to

update the contaminant trend analyses to more fully depict current conditions.

Confined Bedrock Aquifer Groundwater Collection System

The selected ROD remedy called for groundwater extraction in the bedrock aquifer. However,

information collected during the remedy design indicated that the bedrock aquifer was not impacted by

the Site. As memorialized in the 1993 ESD, groundwater extraction from the bedrock aquifer was

replaced by annual monitoring of the bedrock aquifer.

On-site groundwater treatment

All groundwater was processed through the existing treatment plant and effluent sampling was

conducted. A treatability study was performed to demonstrate compliance with treatment requirements

prior to full treatment plant design. The initial treatment included metals removal, air stripping, and

GAC polish treatment. In November 1997, EPA approved a change in treatment, eliminating the metals

removal requirement.

An 8-inch PVC pipe conveyed treated water to a discharge point north of Conneaut Creek when the

treatment plant was in operation. All water discharged from the treatment plant complied with

applicable regulations.

Institutional Controls

Institutional controls (ICs) are required at the Site to ensure the protectiveness of the remedy. ICs are

non-engineered instruments, such as administrative and/or legal controls, that help minimize the

potential for exposure to contamination and protect the integrity of the remedy. Compliance with ICs is

required to assure long-term protectiveness for any areas which do not allow for UU/UE.

A summary of the implemented and planned ICs for the Site is listed in Table 1 and are further

discussed below. A map showing the area in which the ICs apply can be found in the 2010 Institutional

Control Communication Plan for the Site.

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Table 1: Summary of Planned and/or Implemented ICs

Media,

engineered

controls, and

areas that do

not support

UU/UE based

on current

conditions

ICs

Nee

ded

ICs Called

for in the

Decision

Documents

Impacted

Parcel(s)

IC

Objective

Title of IC

Instrument

Implemented

and Date (or

planned)

Landfill

Cover Yes Yes

270060004803

270060004800

Olin to have full and unrestricted

access; prohibited from making any

changes to surface contours;

prohibited from conducting interfering

activities;

prohibited from drilling wells or

extracting groundwater;

prohibited from excavating the former

Olin project site (270060004800);

prohibited from any excavation on the

exclusion area at the northwest corner

of the property;

prohibited from excavating below 12

feet on the remainder of parcel

270060004803, except that there shall

be no limit on excavating on the

property south of Conneuaut Creek;

commercial development or residential

development on the property north of

Conneaut Creek is prohibited;

owner of parcel 270060004803 may

construct for his personal use or

residential dwelling at the area of

highest elevation along Creek Road;

existing fences on parcel

270060004800 are to be maintained by

the owner as is in order to restrict the

presence of anyone not involved in

administering the administrative order

or CERLCA remedy;

prohibited from erecting any building

or structure unless approved by Olin

or

EPA as a necessary component of the

administrative order or CERCLA

remedy

Grandfathered

deed

restriction

under Ohio's

UECA, June

11, 2009

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Residential

properties

Yes Yes Numerous

properties

Residential properties are required to

have no use of well water and are

prohibited from excavating below an

agreed upon depth

Grandfathered

deed

restriction

under Ohio's

UECA, June

11, 2009

Status of Access Restrictions and ICs: Restrictive easements were placed on the properties overlying

the source area and contaminant plume, as required in the ROD, to prohibit installation or use of

drinking water wells in any of the three aquifers present at the Site.

In 2009, EPA conducted an evaluation of ICs and determined that the existing deed restrictions at the

site were legally enforceable and to be grandfathered under Ohio's Uniform Environmental Covenant

Act (UECA), Ohio Revised Code Section 5301.85(c). This determination was based upon information

Olin provided to EPA in November 2008. Upon EPA request, Olin provided additional site ICs

information for review in March 2010 including the 2010 Institutional Control Communication Plan,

which contains information on governmental controls, a communications plan, mapping, title work for

individual parcels, and planned development.

Current Compliance: Based on current inspections of the Site, EPA is not aware of Site or media uses

which are inconsistent with the stated objectives to be achieved by the ICs. No Site uses which are

inconsistent with the implemented ICs or remedy IC objectives have been noted during Site inspections.

IC Follow up Actions Needed: There are no IC follow up actions needed.

Long-Term Stewardship: As stated in the EPA approved 2010 Institutional Control Communication

Plan for the Site, Olin conducts an annual deed review to determine if any of the properties with Olin

imparted restrictive covenants have changed ownership. If a change has occurred, Olin mails a

description of the covenants placed on the property deeds to the new owner. Olin also provides a contact

phone number to the affected residents for any follow-up questions. Olin has completed this process

several times since the plan was approved, as was discussed during the recent Site inspection.

Systems Operations/Operation & Maintenance

Olin periodically conducts site operation and maintenance (O&M) on the landfill cap (e.g., repairing

animal holes, maintaining the vegetative cover) and ensures site security by inspecting the site and

maintaining the site fence. Additionally, groundwater and surface water monitoring is conducted

annually. Since the last FYR, the building housing the treatment system was vandalized and the

treatment system was damaged beyond repair, as documented during the recent Site inspection

(the system hasn’t been in operation since 1999).

III. PROGRESS SINCE THE LAST REVIEW

This section includes the protectiveness determinations and statements from the last FYR as well as the

recommendations from the last FYR and the current status of those recommendations.

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Table 2: Protectiveness Determinations/Statements from the 2014 FYR

OU # Protectiveness

Determination Protectiveness Statement

1 Protective in the short term The OU l remedy is protective of human health and the

environment in the short-term because no one is drinking

contaminated groundwater and institutional controls (ICs) are

in place to prevent groundwater use. However, in order for the

remedy to be protective in the long term, the following actions

need to be taken: complete the evaluation of MNA as a

treatment option. If EPA determines that MNA is a viable

remedy for reaching the groundwater cleanup standards, a

decision document to alter the originally-selected groundwater

remedial action to MNA will be completed. If EPA determines

that MNA is not a viable remedy, then the groundwater

treatment system will be reactivated and operated to achieve

the groundwater cleanup goals. 2 Protective The OU2 remedy is protective of human health and the

environment because the source materials have been

incinerated and residual contaminants are contained in the

landfill, thus, no unacceptable exposures exist. ICs are in place

to prevent disturbance of the landfill cap. Site-wide Protective in the short

term

The remedial actions are protective of human health and the

environment in the short-term. However, in order for the

remedy to be protective in the long term, a decision must be

made by EPA as to the most viable remedy for reaching the

groundwater cleanup standards within a reasonable time period

and the operation of that remedy to achieve the groundwater

cleanup goals.

Table 3: Status of Recommendations from the 2014 FYR

OU # Issue Recommendations

Current

Status

Current Implementation Status

Description

Completion

Date (if

applicable) Complete the

evaluation of MNA

as a viable option for

groundwater cleanup

EPA, in consultation

with OEPA, should

make a determination

whether MNA is a

viable option based

on the information

provided by Olin*

*If EPA determines

that MNA is a viable

remedy for reaching

the groundwater

cleanup standards, it

will issue a decision

document to alter the

originally-selected

groundwater remedial

action to MNA. If

EPA determines that

MNA is not a viable

Ongoing EPA has requested additional

information regarding the MNA

assessment, which was included in a

focused FS report submitted in 2018.

EPA will provide comments on this

report when the Site PRP amends the

assessment to include additional

aquifer trend analyses.

NA

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groundwater remedial

action to meet the

groundwater cleanup

goals in a reasonable

amount of time, then

Olin will reactivate

the groundwater

treatment system

with appropriate

operation and

maintenance

In addition, the following activity was identified during the 2014 FYR to be completed that does not

affect current nor future protectiveness:

Olin submitted a long-term monitoring plan to EPA in July 2012. The plan calls for a reduction in the

number of monitoring wells and the number of analytes. EPA has not commented on the long-term

monitoring plan to date but plans to do so after it makes its determination concerning the viability of

MNA at the Big D Campground site. This plan will be updated as necessary based on current

groundwater conditions and EPA’s determination regarding the viability of MNA for the groundwater

remedy.

IV. FIVE-YEAR REVIEW PROCESS

Community Notification, Involvement & Site Interviews

A public notice was made available by publishing a notice in a local newspaper, the Star Beacon, on

4/28/2018, stating that there was a FYR and inviting the public to submit any comments to EPA.

The results of the review and the report will be made available to the public at the following locations:

Kingsville Public Library

6006 Academy Street

Kingsville, OH 44048

EPA’s Chicago office

Superfund Records Center, 7th Floor

77 W Jackson Blvd.

Chicago, IL 60604

Data Review

Olin collects groundwater monitoring samples on a semi-annual basis. Water samples are collected from

19 monitoring wells during the spring sampling event and from 25 monitoring wells during the fall

sampling event. The samples are collected using low-flow sampling techniques and then analyzed for

Site COCs and for natural attenuation parameters. The field sampling parameters are: dissolved oxygen,

iron (II), oxidation reduction potential (ORP), pH, specific conductance, temperature, and turbidity.

The laboratory sampling parameters are VOCs, carbon dioxide, chloride, total organic carbon, ethylene,

methane, nitrate, sulfate, sulfide total alkalinity and hydrogen. Groundwater level measurements are also

performed. Sampling is conducted in accordance with the EPA approved quality assurance project plan

(January 2000).

Groundwater data from this review period indicates that chlorobenzene and vinyl chloride were detected

above regulatory standards at a number of on-site well locations. Other contaminants, such as

tetrachloroethane, cis 1,2-dichloroethylene, and 1,1-dichloroethylene, have been detected sporadically at

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levels above MCLs. Detected concentrations for chlorobenzene range to 14,000 parts per billion (ppb)

(the cleanup goal is the federal maximum contaminant level (MCL) established under the Safe Drinking

Water Act of 100 ppb), although results trended downward in more recent sampling. The detected

concentrations for vinyl chloride ranged to 140 ppb (the MCL for vinyl chloride is 2 ppb) again with

downward trends throughout the review period. A more complete summary of groundwater data during

the last five years is included in Appendix A.

EPA has requested sampling of several residential wells located south of Conneaut Creek to assist in

determining whether the deeper shale aquifer is being impacted by the Site. This information will be

used for the overall MNA determination for the site. Previous monitoring does not show impacts in this

lower aquifer where these wells are located. The current groundwater plume remains stable according to

existing groundwater monitoring information, but this additional sampling will help to supplement

previous data and is expected to confirm the existing understanding of the groundwater plume.

The groundwater treatment system that was constructed remains shut down while EPA continues to

evaluate the viability of MNA as a cleanup option for groundwater. The Site inspection noted that the

inside of the water treatment building had been vandalized. If EPA requires the restart of the

groundwater pump and treat system, the treatment infrastructure will have to be completely rebuilt.

Groundwater monitoring data collected within the last five years has indicated that the contaminant

plumes remain within the deed restricted area. Residents in the area of the Site are connected to the

municipal water supply and, as such, there is no current exposure based on available monitoring data.

However, additional data will be used to review the previous determination and ultimately will be used

to make a decision for MNA.

A full analysis of collected groundwater data will be conducted that will build on the previously

submitted monitoring results reports, the MNA demonstration report submitted in 2010, the focused

feasibility for MNA submitted in 2018, and the additional residential well sampling to be completed by

the end of 2019. The FFS was determined to be incomplete because a complete site-wide analysis of

contaminant trends was not included to help make a complete determination on the viability of MNA for

groundwater. The MNA evaluation will include full trend analyses for all collected data and EPA will

use this information to ultimately determine whether the ongoing shutdown of the groundwater

extraction system remains appropriate, or if groundwater conditions warrant restart of the system to

achieve the groundwater cleanup goals.

Site Inspection

There were two inspections of the Site. The first was conducted by Bill Ryan on May 23, 2018.

The second was conducted by Dion Novak on August 13, 2019. For the August 13, 2019 inspection, in

attendance were Dion Novak, EPA RPM, Scott Aschenbrenner, OEPA, and James Cashwell

representing Olin Corporation. The purpose of the inspections was to assess the protectiveness of the

remedy.

EPA and OEPA inspected the water treatment building, the landfill cover, monitoring wells and

piezometers, and Conneaut Creek. The inspection discovered that the inside of the water treatment

building had been vandalized with most of the infrastructure damaged beyond repair. Mr. Cashwell

indicated that a police report had been filed and the decision was made not to press charges against the

perpetrators. The vegetation on the cover was in good condition and all observed monitoring wells were

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also in good condition. The monitoring wells near the Creek were also in good condition and locked.

Signs were present on the site fencing prohibiting trespassing. All fencing was in good condition.

Mr. Cashwell indicated that if EPA ultimately requires the restart of the groundwater pump and treat, the

treatment infrastructure will have to be completely rebuilt. This determination will be made following

the completion of the evaluation for MNA.

The following photographs were taken during the site inspection:

Southern site boundary on bluff

facing Conneaut Creek

Landfill cover and perimeter fence along

creek looking north

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Landfill cover

looking north

Front gate to site

Vandalized groundwater

treatment system

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V. TECHNICAL ASSESSMENT

QUESTION A: Is the remedy functioning as intended by the decision documents?

Question A Summary:

Yes. A review of the relevant documents and the results of the FYR site inspection indicate that the

remedy is functioning as intended by the ROD. Major remedy construction (source area excavation,

incineration on-site, disposal of treated material and backfilling on-site) was successfully completed in

1995. Materials consolidated on-site, including incineration treatment residuals, are adequately

contained beneath the vegetated cover. Access controls and ICs are currently effective in preventing

exposure to on-site covered materials and contaminated groundwater.

The groundwater treatment system that was constructed remains shut down while EPA continues to

evaluate the viability of MNA as a cleanup option for groundwater. The Site inspection noted that the

inside of the water treatment building had been vandalized. If EPA requires the restart of the

groundwater pump and treat, the treatment infrastructure will have to be completely rebuilt.

Groundwater monitoring data collected within the last five years has indicated that the contaminant

plumes remain within the deed restricted area. However, additional groundwater monitoring including

residential well sampling of wells south of Conneaut Creek, will be used to update the previous data.

Previous monitoring does not show impacts in the lower aquifer where these wells are located.

The current groundwater plume remains stable according to existing groundwater monitoring

information. This additional sampling will help to supplement previous data and is expected to confirm

the existing understanding of the groundwater plume. Residents in the area of the Site are connected to

the municipal water supply and, as such, there is no current exposure based on available monitoring

data.

An IC Study was performed by Olin and EPA has found that adequate and enforceable ICs are in place,

including prohibitions on: (1) use of groundwater; (2) excavation activities; (3) disturbance of the cap;

and (4) any other activities or actions that might interfere with the implemented remedy. No activities

were observed that would have violated the ICs, except for the vandalism of the treatment building and

destruction of the treatment system. If the results of the MNA analysis indicate that the groundwater

treatment system should be reactivated, Olin will have to rebuild or repair the existing system to ensure

proper groundwater treatment operations. The cap and the surrounding area were undisturbed, and no

new uses of groundwater were observed at the Site during the Site inspection.

QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action

objectives (RAOs) used at the time of the remedy selection still valid?

Question B Summary:

Yes. There have been no changes in the physical conditions of the site that would affect the

protectiveness of the selected remedy. There have been no changes in the ARARs requirements that

would affect the protectiveness of the remedy. There have not been any changes in the use of the

property during the last five years. There have been no changes in land use near the site, nor are changes

expected in the near future. There have been no newly observed species or ecological settings.

There have been no changes in most of the human and ecological exposure assumptions or the toxicity

17

data that were used in the risk assessment at the time of the remedy selection that would affect the

protectiveness of the remedy. EPA has released revised Vapor Intrusion screening and risk assessment

guidance since the time of the remedy selection. While not expected to be an issue affecting the

protectiveness of the remedy, in an abundance of caution, EPA and OEPA have requested vapor

intrusion sampling to the south of the Site to determine if this is a potential exposure pathway.

There have been no other changes in the standardized risk assessment methodology that would affect

the protectiveness of the remedy. The RAOs used at the time of remedy selection are still valid.

QUESTION C: Has any other information come to light that could call into question the protectiveness

of the remedy?

No. There is no other information that calls into question the protectiveness of the remedy.

VI. ISSUES/RECOMMENDATIONS

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

2

Issues and Recommendations Identified in the Five-Year Review:

OU(s): 1 Issue Category: Remedy Performance

Issue: Complete the evaluation of MNA as a viable option for groundwater

cleanup.

Recommendation: EPA, in consultation with OEPA, should finalize a

determination on whether MNA is a viable option based on the information

provided by Olin*.

Affect Current

Protectiveness

Affect Future

Protectiveness

Party

Responsible

Oversight Party Milestone Date

No Yes PRP EPA/State 9/30/2020

*EPA must complete a determination on whether MNA is a viable remedy for reaching the

groundwater cleanup standards in a reasonable timeframe. If EPA determines that MNA is not a

viable groundwater remedial action to meet the groundwater cleanup goals in a reasonable

amount of time, then EPA will direct Olin to immediately reactivate the groundwater treatment

system, with associated operation and maintenance.

OTHER FINDINGS

In addition, the following are recommendations that were identified during the FYR and (may improve

performance of the remedy, reduce costs, improve management of O&M, accelerate site close out,

conserve energy, promote sustainability, etc.), but do not affect current nor future protectiveness:

• sampling of several residential wells located south of Conneaut Creek to assist in determining if

the deeper shale aquifer is being impacted by the Site; and

18

• vapor intrusion sampling to the south of the Site to determine whether this is a potential pathway

of concern.

VII. PROTECTIVENESS STATEMENT

Protectiveness Statement(s)

Operable Unit:

1

Protectiveness Determination:

Short-term protective

Protectiveness Statement:

The OU1 remedy is currently protective of human health and the environment because no one is drinking

contaminated groundwater and ICs are in place to prevent groundwater use. However, in order for the

remedy to be protective in the long term, the following actions need to be taken to ensure protectiveness:

EPA will complete the evaluation of MNA and determine if MNA is a viable remedy for reaching the

groundwater cleanup standards in a reasonable timeframe. If EPA determines that MNA is not a viable

remedy, then the groundwater treatment system will be immediately reactivated and operated to achieve

the groundwater cleanup goals.

Protectiveness Statement(s)

Operable Unit:

2

Protectiveness Determination:

Protective

Protectiveness Statement:

The OU2 remedy is protective of human health and the environment because the source materials have

been incinerated, residual contaminants are contained in the landfill, and no unacceptable exposures

exist. Effective ICs are in place to prevent disturbance of the landfill cap.

Sitewide Protectiveness Statement

Protectiveness Determination:

Short-term protective

Protectiveness Statement:

The remedy at the Big D Campground site is currently protective of human health and the environment

because source materials have been incinerated, residual contaminants are contained in the landfill, no

one is drinking the groundwater, and no unacceptable exposures exist. Effective ICs are in place to

prevent disturbance of the landfill cap and to prevent groundwater use. However, in order for the remedy

to be protective in the long term, the following action needs to be taken to ensure protectiveness: EPA

needs to finalize a determination on whether MNA is a viable option for reaching the groundwater

cleanup standards within a reasonable time period and, if not, direct the immediate reactivation of the

groundwater treatment system, with associated operation and maintenance.

19

VIII. NEXT REVIEW

The next FYR report for the Big D Campground Superfund Site is required five years from EPA’s

signature date of this review.

20

REFERENCE LIST

• 4th Five Year Review April 16, 2014

• Record of Decision September 29, 1989

• Institutional Control Communication Plan-2010

• Focused Feasibility Study – 2018

21

APPENDIX A: Groundwater Data Summary

Result Qualifier Result Qualifier Result Qualifier Result Qualifier Result Qualifier Result Qualifier Result Qualifier Result Qualifier Result Qualifierug/l 5/8/14 0.8 U 590 0.8 U 1.6 0.8 U 0.8 U 0.5 JQ 3.7ug/l 10/2/14 2 U 1800 2 U 2 U 2 U 2 U 2 U 2 Uug/l 5/7/15 2 U 760 2 U 2.5 2 U 2 U 2 U 0.9 JQug/l 10/7/15 2 U 1900 2 U 6 2 U 3.1 2 U 2 Uug/l 10/2/14 1 U 50 U 2.4 1 U 1 U 1 U 1 U 1 U 1 UJug/l 10/8/15 1 U 50 UJ 0.36 JQ 1 U 1 U 1 U 1 U 1 U 1 Uug/l 10/4/16 50 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 11/7/17 50 UJ 1 U 1 U 1 U 1 U 1 U 1 Uug/l 10/30/18 170 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 10/2/14 10 U 100 5500 10 U 10 U 10 U 10 U 10 U 10 Uug/l 10/8/15 20 U 59 J 12000 20 U 20 U 20 U 20 U 20 U 20 Uug/l 10/4/16 160 10000 50 U 50 U 50 U 50 U 50 Uug/l 11/7/17 30 JQ 6200 20 U 20 U 20 U 20 U 20 Uug/l 10/30/18 110 JQ 14000 25 U 25 U 25 U 25 U 25 Uug/l 5/8/14 1 U 1 U 1 U 1.9 1 U 1 U 8.2 1 Uug/l 10/1/14 1 U 50 UJ 1 U 1 U 2 1 U 1 U 7.2 1 Uug/l 5/6/15 1 U 1 U 1 U 1 U 1 U 1 U 11 1 Uug/l 10/7/15 1 U 50 UJ 1 U 1 U 2.4 1 U 1 U 7.1 1 Uug/l 5/8/14 1 U 1 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 10/1/14 1 U 50 UJ 1 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 5/6/15 1 U 1 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 10/7/15 1 U 50 UJ 1 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 5/9/14 5 U 1900 5 U 36 36 0.95 JQ 65 3.8 JQug/l 10/2/14 4 U 5400 J 4 U 53 J 92 4 U 140 4 Uug/l 5/7/15 20 U 5400 20 U 71 130 20 U 190 20 Uug/l 10/8/15 20 U 9000 20 U 78 J 110 J 20 U 290 20 Uug/l 5/6/14 1 U 1 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 9/30/14 1 U 1 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 5/5/15 1 U 1 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 10/6/15 1 U 1 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 10/5/16 1 U 1 U 1 U 1 U 1 U 1 Uug/l 11/7/17 1 U 1 U 1 U 1 U 1 U 1 Uug/l 10/30/18 1 U 1 U 1 U 1 U 1 U 1 Uug/l 5/7/14 1 U 1 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 9/30/14 1 U 1 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 5/5/15 1 U 1 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 10/6/15 1 U 1 U 1 U 1 U 1 U 1 U 1 U 1 U

MW

-27-

SM

W-0

7-D

RM

W-0

7-SR

MW

-17-

SM

W-1

8-S

MW

-20-

SM

W-3

2-S

Vinyl Chloride

MW

-03-

S

Well Sample Date 1,1-Dichloroethene Chlorobenzene Chloroethane cis-1,2-

DichloroetheneTetrachloroethene

(PCE)trans-1,2-

DichloroetheneTrichloroethene

(TCE)Unit 2,4 and/or 2,6-Diaminotoluene

Result Qualifier Result Qualifier Result Qualifier Result Qualifier Result Qualifier Result Qualifier Result Qualifier Result Qualifier Result Qualifierug/l 5/8/14 2.8 2100 2 U 140 2 U 3.6 52 19ug/l 10/1/14 2 U 2400 2 U 150 2 U 2 U 43 14ug/l 5/7/15 20 U 2500 20 U 180 20 U 20 U 57 17 JQug/l 10/7/15 1 U 1900 1 U 85 1 U 2 9.9 8.5ug/l 10/5/16 1 U 4.6 1 U 1 U 1 U 1 Uug/l 10/30/18 890 52 5 U 5 U 2.2 JQ 5.4

MW

-34S

-D

ug/l 11/7/17 690 83 1 U 1 U 1 U 11

MW

-34S

-I

ug/l 11/7/17 84 1 U 1 U 1 U 1 U 1 U

MW

-34S

-S

ug/l 11/7/17 36 5.4 36 1 U 1 U 1 U

ug/l 5/6/14 1 U 1 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 9/30/14 1 U 1 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 5/5/15 1 U 1 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 10/6/15 1 U 1 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 5/7/14 1 U 1 U 1 U 98 1 U 1 U 1 U 7.2ug/l 9/30/14 1 U 1 U 1 U 120 1 U 1 U 1 U 7.8ug/l 5/6/15 1 U 1 U 1 U 130 1 U 1 U 1 U 8.5ug/l 10/6/15 1 U 1 U 1 U 120 1 U 1 U 1 U 6ug/l 10/5/16 1 U 1 U 1 U 1 U 1 U 1 Uug/l 11/7/17 1 U 4.8 J 1 U 1 U 1 U 1.6 Jug/l 10/30/18 1 U 42 1 U 1 U 1 U 1.8

MW

-39S

-D

ug/l 12/21/16 1 U 76 1 U 1 U 1 U 3.5

Well

MW

-34-

SM

W-3

7-S

Sample Date 1,1-Dichloroethene

MW

-39-

S

2,4 and/or 2,6-Diaminotoluene Vinyl ChlorideTetrachloroethene

(PCE)trans-1,2-

DichloroetheneTrichloroethene

(TCE)Unit Chloroethane cis-1,2-DichloroetheneChlorobenzene

Result Qualifier Result Qualifier Result Qualifier Result Qualifier Result Qualifier Result Qualifier Result Qualifier Result Qualifier Result Qualifier

MW

-39S

-I

ug/l 12/21/16 1 U 1.6 1 U 1 U 1 U 1.5

MW

-39S

-S

ug/l 12/21/16 1 U 1 U 1 U 1 U 1 U 1 U

ug/l 5/7/14 1 U 1 U 1 U 1 U 1 U 1 U 1 U 9.6ug/l 9/30/14 1 U 1 U 1 U 1 U 1 U 1 U 1 U 11ug/l 5/5/15 1 U 1 U 1 U 1 U 1 U 1 U 1 U 7.3ug/l 10/6/15 1 U 1 U 1 U 1 U 1 U 1 U 1 U 8.4ug/l 10/5/16 1 U 1 U 1 U 1 U 1 U 1 Uug/l 10/30/18 1 U 1 U 1 U 1 U 1 U 3

MW

-43S

-D

ug/l 11/7/17 1 U 1 U 1 U 1 U 1 U 3.7

MW

-43S

-I

ug/l 11/7/17 1 U 1 U 1 U 1 U 1 U 1 U

MW

-43S

-S

ug/l 11/7/17 1 U 1 U 1 U 1 U 1 U 1 U

ug/l 5/5/14 1 U 1 U 1 U 1 U 1 U 1 U 1 U 6.4ug/l 9/29/14 1 U 1 U 1 U 1 U 1 U 1 U 1 U 9.7ug/l 5/4/15 1 U 1 U 1 U 1 U 1 U 1 U 1 U 9.9ug/l 10/5/15 1 U 1 U 1 U 1 U 1 U 1 U 1 U 16ug/l 10/5/16 1 U 1 U 1 U 1 U 1 U 11ug/l 11/7/17 1 U 1 U 1 U 1 U 1 U 12ug/l 10/30/18 1 U 1 U 1 U 1 U 1 U 1 U

MW

-43-

S

Well

MW

-45-

S

Chlorobenzene2,4 and/or 2,6-Diaminotoluene

Sample Date 1,1-Dichloroethene Trichloroethene

(TCE) Vinyl ChlorideTetrachloroethene (PCE)

trans-1,2-DichloroetheneUnit Chloroethane cis-1,2-

Dichloroethene

Result Qualifier Result Qualifier Result Qualifier Result Qualifier Result Qualifier Result Qualifier Result Qualifier Result Qualifier Result Qualifierug/l 5/6/14 1 U 1 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 9/29/14 1 U 1 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 5/4/15 1 U 1 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 10/5/15 1 U 1 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 10/5/16 1 U 1 U 1 U 1 U 1 U 1 Uug/l 11/7/17 1 U 1 U 1 U 1 U 1 U 1 Uug/l 10/30/18 1 U 1 U 1 U 1 U 1 U 1 Uug/l 5/7/14 1 U 1 U 1 U 1 U 1 U 1 U 1 U 5.9ug/l 10/1/14 1 U 1 U 1 U 1 U 1 U 1 U 1 U 5.6ug/l 5/6/15 1 U 1 U 1 U 1 U 1 U 1 U 1 U 5.1ug/l 10/7/15 1 U 1 U 1 U 1 U 1 U 1 U 1 U 5.5ug/l 10/5/16 1 U 1 U 1 U 1 U 1 U 1 Uug/l 10/30/18 1 U 1 U 1 U 1 U 1 U 1 U

MW

-49-

D

ug/l 11/7/17 1 U 1 U 1 U 1 U 1 U 1 U

MW

-49S

-I

ug/l 11/7/17 1 U 1 U 1 U 1 U 1 U 4.5

MW

-49S

-S

ug/l 11/7/17 1 U 1 U 1 U 1 U 1 U 1.4

ug/l 5/14/14 1 U 1 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 9/29/14 1 U 1 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 5/4/15 1 U 1 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 10/5/15 1 U 1 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 10/5/16 1 U 1 U 1 U 1 U 1 U 1 Uug/l 11/7/17 1 U 1 U 1 U 1 U 1 U 1 Uug/l 10/30/18 1 U 1 U 1 U 1 U 1 U 1 U

MW

-47-

SM

W-4

9-S

MW

-50-

S

Well Sample Date 1,1-Dichloroethene 2,4 and/or 2,6-

Diaminotoluene Chlorobenzene Tetrachloroethene (PCE)

trans-1,2-Dichloroethene

Trichloroethene (TCE) Vinyl ChlorideUnit Chloroethane cis-1,2-

Dichloroethene

Result Qualifier Result Qualifier Result Qualifier Result Qualifier Result Qualifier Result Qualifier Result Qualifier Result Qualifier Result Qualifierug/l 10/2/14 8 U 240 8200 8 U 8 U 8 U 8 U 81 J 8 Uug/l 10/8/15 200 U 82 J 18000 200 U 200 U 200 U 200 U 200 U 200 Uug/l 10/4/16 170 13000 50 U 50 U 50 U 50 U 50 Uug/l 11/7/17 120 J 10000 J 50 U 50 U 50 U 50 U 50 Uug/l 10/30/18 120 JQ 6600 J 20 UJ 20 U 20 U 20 U 20 U

ug/l 11/7/17 50 UJ 1 U 1 U 1 U 1 U 1 U 1 U

ug/l 10/30/18 170 U 1.2 1 U 0.35 JQ 1 U 1 U 1 U

ug/l 10/2/14 1 U 50 U 2.1 1 U 1 U 1 U 1 U 1 U 1 U

ug/l 10/8/15 1 U 50 UJ 1.3 1 U 1 U 1 U 1 U 1 U 1 U

ug/l 5/5/14 1 U 1 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 9/29/14 1 U 1 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 5/4/15 1 U 1 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 10/5/15 1 U 1 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 10/5/16 1 U 1 U 1 U 1 U 1 U 1 Uug/l 11/7/17 1 U 1 U 1 U 1 U 1 U 1 Uug/l 10/30/18 1 U 1 U 1 U 1 U 1 U 1 Uug/l 5/8/14 1 U 1 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 10/1/14 1.4 450 1 U 240 1 U 400 8.2 86ug/l 5/7/15 1 U 0.39 JQ 1 U 6.8 1 U 10 1 U 1.3ug/l 10/7/15 1 U 370 1 U 330 1 U 490 12 140ug/l 10/5/16 130 200 1 U 400 1.3 120ug/l 10/30/18 55 57 1 U 82 1 U 55 J

PW03

-D

ug/l 11/7/17 260 140 1 U 250 1 U 79

PW03

-I

ug/l 11/7/17 19 34 1 U 59 1 U 13

PW03

-S

ug/l 11/7/17 1 U 1 U 1 U 1 U 1 U 1.4

PW-0

3M

W-5

2-D

MW

-52-

SM

W-5

3-D

MW

-54-

SRX

UnitWell Sample Date 1,1-Dichloroethene Tetrachloroethene

(PCE)trans-1,2-

DichloroetheneTrichloroethene

(TCE) Vinyl Chloridecis-1,2-Dichloroethene

2,4 and/or 2,6-Diaminotoluene Chlorobenzene Chloroethane

Result Qualifier Result Qualifier Result Qualifier Result Qualifier Result Qualifier Result Qualifier Result Qualifier Result Qualifier Result Qualifierug/l 5/6/14 1 U 1 U 1 U 9.4 1 U 1 U 1 U 1 Uug/l 9/30/14 1 U 1 U 1 U 75 1 U 3.7 1 U 21ug/l 5/5/15 1 U 1 U 1 U 5.5 1 U 1 U 1 U 1 Uug/l 10/6/15 1 U 1 U 1 U 48 1 U 5.6 1 U 22ug/l 5/6/14 1 U 1 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 9/29/14 1 U 1 U 1 U 1 U 1 U 1 U 1 U 24ug/l 5/5/15 1 U 1 U 1 U 1 U 1 U 1 U 1 U 3.8ug/l 10/6/15 1 U 1 U 1 U 1 U 1 U 1 U 1 U 16ug/l 5/5/14 1 U 1 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 9/29/14 1 U 1 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 5/4/15 1 U 1 U 1 U 1 U 1 U 1 U 1 U 4.2ug/l 10/5/15 1 U 1 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 10/2/14 1 U 50 U 1.7 1 U 1 U 1 U 1 U 1 U 1 Uug/l 10/8/15 1 U 50 UJ 2 1 U 1 U 1 U 1 U 1 U 1 Uug/l 10/4/16 50 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 11/7/17 50 UJ 1 U 1 U 1 U 1 U 1 U 1 Uug/l 10/30/18 170 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 10/2/14 1 U 50 U 1 1 U 1 U 1 U 1 U 1 U 1 Uug/l 10/8/15 1 U 50 UJ 1.9 1 U 1 U 1 U 1 U 1 U 1 Uug/l 10/4/16 50 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 11/7/17 50 UJ 1 U 1 U 1 U 1 U 1 U 1 Uug/l 10/30/18 170 U 0.49 JQ 1 U 1 U 1 U 1 U 1 Uug/l 10/2/14 1 U 50 U 1 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 10/8/15 1 U 50 UJ 1 U 1 U 1 U 1 U 1 U 1 U 1 Uug/l 10/4/16 50 U 1.2 1 U 1 U 1 U 1 U 1 Uug/l 11/7/17 50 UJ 1 U 1 U 1 U 1 U 1 U 1 Uug/l 10/30/18 170 U 1 U 1 U 1 U 1 U 1 U 1 U

SW-0

2SW

-03

PW-0

4PW

-05

PW-0

8SW

-01

Well Tetrachloroethene (PCE)

trans-1,2-Dichloroethene

Trichloroethene (TCE) Vinyl ChlorideSample

Date 1,1-Dichloroethene 2,4 and/or 2,6-Diaminotoluene Chlorobenzene ChloroethaneUnit cis-1,2-

Dichloroethene