2015 ANNUAL PROGRESS · 2016-02-10 · 2015 ANNUAL PROGRESS REPORT. Corrective Measures Implementation at the . Pharmacia & Upjohn Company LLC Site . North Haven, Connecticut . RCRA

2015 ANNUAL PROGRESS REPORT

Corrective Measures Implementation at the Pharmacia & Upjohn Company LLC Site North Haven, Connecticut RCRA I.D. No. CTD001168533 Submitted To: Pfizer Inc on behalf of Pharmacia & Upjohn Company LLC Submitted By: Golder Associates Inc. 200 Century Parkway, Suite C Mt. Laurel, NJ 08054 Distribution: USEPA – Region I CTDEEP Mabbett & Associates, Inc. Booz Allen Hamilton Town of North Haven Pfizer Inc Quantum Management Group, Inc. Woodard & Curran, Inc. Robinson & Cole, LLP NorthStar AECOM Brown and Caldwell TerraTherm, Inc. Vita Nuova, LLC Golder Associates Inc. February 2016 Project No. 033-6231-002

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EXECUTIVE SUMMARY The 2015 Annual Progress Report (Annual Report) for the Pharmacia & Upjohn Company LLC Site has

been prepared on behalf of Pharmacia & Upjohn Company LLC, (Pharmacia & Upjohn) for the Pharmacia

& Upjohn Facility located at 41 Stiles Lane in North Haven, Connecticut (Site). The Annual Report was

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

by the United States Environmental Protection Agency (USEPA) pursuant to Section 3008(h) of the

Resource Conservation and Recovery Act (RCRA). The Order (Docket Number RCRA-01-2011-0027)

was executed on March 31, 2011 and covers Corrective Measures Implementation (CMI) at the Site. The

RCRA identification number for the Site is CTD001168533.

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

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

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

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

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

industrial activities at the site, however, current Site use includes the operation and maintenance of the

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

construction and maintenance of the final Site-wide Corrective Measures selected for the Site on

September 10, 2010 by USEPA with the concurrence of the Connecticut Department of Energy and

Environmental Protection (CTDEEP) and as specified in the Order.

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

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

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

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

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

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

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

During 2015, the CMI Team of contractors and consultants assembled by Pharmacia & Upjohn continued

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

achievements included:

The CMI Team responded to USEPA’s comments regarding the Full Scale In Situ Thermal Remediation (ISTR) Draft Final Design Report. On June 4, 2015, USEPA approved the Full-Scale ISTR System Final Design Report, which incorporated the comment responses.

TerraTherm completed construction of the full-scale ISTR system in May 2015 and started subsurface heating on June 15, 2015. USEPA approved the completion of

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treatment in dense non-aqueous phase liquid (DNAPL) Subarea B on November 5, 2015. As of December 31, 2015, treatment in DNAPL Subarea A was near complete.1

The East Side Remedial Components (ESRC) Team led by NorthStar completed construction of the ecological enhancements and tidal wetlands mitigation areas on the eastern side of the Site in July 2015. Monitoring and maintenance of the plantings continued throughout the year. On October 1, 2015, USEPA and CTDEEP performed a post-construction inspection of the completed ESRC.

Woodard & Curran operated and monitored the post-ESRC groundwater extraction system (GWES), which is a final corrective measure. Based on the monitoring data collected by Golder Associates Inc., the GWES maintained hydraulic control of Unit 1 groundwater during 2015. The extracted groundwater continued to be treated at the GWTF in accordance with the Site National Pollutant Discharge Elimination System (NPDES) permit issued by CTDEEP.

Golder Associates collected groundwater monitoring samples from outside the hydraulic barrier wall to establish a baseline for the post-ESRC monitoring in July and October 2015. The groundwater samples collected during the Annual Monitoring Event in October 2015 confirmed that samples of Unit 3 groundwater from locations along the Site perimeter remain below the comparative criteria and provided additional data concerning groundwater conditions in the vicinity of Unit 3 well SEC-7D and Unit 4 well GW-U402A.

As part of the progress towards implementation of the corrective measures, during 2015 the CMI Team

has achieved, ahead of schedule, the following Progress Goals specifically defined in the Order:

Activity Milestone Type Milestone Date

Date Achieved

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

Progress Goal 10/30/2015 3/3/2015

Complete Full-Scale ISTR System Construction Progress Goal 10/26/2017 5/29/2015

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

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

quarterly basis. Teleconferences were held with USEPA and CTDEEP at least monthly to keep the

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

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

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

(CAP).

In general accordance with the Order, the 2015 Annual Report is divided into the following six Sections:

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

1 USEPA approved the completion of DNAPL Subarea A treatment on January 14, 2016.


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Section 2 summarizes the principal CMI activities and CM maintenance activities

completed during 2015

Section 3 provides the hydrogeologic and chemical data collected in 2015 as part of the CMI Groundwater Monitoring Program, the GWTF Operations, Monitoring & Maintenance (OM&M), and other sampling efforts.

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

Section 5 describes the institutional control monitoring activities conducted during 2015

Section 6 discusses the OM&M monitoring and major CMI activities planned for 2016

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

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

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

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

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

Due to the size of the report, not all sections of the 2015 Annual Report have been provided in the

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

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


http://www.upjohnnorthhaven.com/

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Table of Contents EXECUTIVE SUMMARY ........................................................................................................................ ES-1

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

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

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

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

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

2.0 PRINCIPAL ACTIVITIES CONDUCTED ......................................................................................... 9 2.1 Communications with USEPA and CTDEEP ...................................................................... 9 2.2 Groundwater Treatment Facility Permitting and Operation .............................................. 10 2.3 Groundwater Monitoring ................................................................................................... 12

2.3.1 Post-ESRC Groundwater Monitoring ................................................................... 12 2.3.2 Non-Routine Sampling and Monitoring ................................................................ 13

2.4 In-Situ Thermal Remediation ............................................................................................ 13 2.4.1 ISTR Design ......................................................................................................... 13 2.4.2 ISTR System Construction ................................................................................... 15 2.4.3 ISTR System Operation and Design Modifications .............................................. 16

2.5 East Side Remedial Components ..................................................................................... 17 2.5.1 ESRC Construction and Design Modifications .................................................... 17 2.5.2 ESRC Reporting................................................................................................... 21

2.6 Community Outreach ........................................................................................................ 21

3.0 DATA SUMMARY AND CONCLUSIONS ...................................................................................... 23 3.1 Assessment of Performance of the Groundwater Extraction Systems and Groundwater

Treatment System ............................................................................................................. 24 3.1.1 Summary of GWES Operations, Monitoring, and Maintenance .......................... 24 3.1.2 Treatment System Monitoring .............................................................................. 25 3.1.3 GWES Hydraulic Control Monitoring ................................................................... 26

3.2 Groundwater Quality Monitoring ....................................................................................... 27 3.2.1 Groundwater Data Collection and Review Activities ............................................ 27 3.2.2 Unit 1 Groundwater Sample Results.................................................................... 29 3.2.3 Unit 3 Groundwater Sample Results.................................................................... 31

3.3 Other Data Generated ...................................................................................................... 31 3.3.1 Additional Unit 3 Groundwater Monitoring ........................................................... 32 3.3.2 Unit 4 Groundwater Monitoring ............................................................................ 32 3.3.3 GW-LP01 Monitoring ........................................................................................... 32

4.0 ASSESSMENT OF PERFORMANCE OF CORRECTIVE MEASURE .......................................... 33

5.0 INSTITUTIONAL CONTROL MONITORING ACTIVITIES ............................................................ 36

6.0 PROJECTED 2016 MONITORING ACTIVITIES AND MASTER PLAN SCHEDULE ................... 38 6.1 Schedule of OM&M Sampling ........................................................................................... 38

6.1.1 Objective 1: Unit 1 Groundwater Hydraulic Control Monitoring .......................... 39 6.1.2 Objective 2: Evaluation of Post-ESRC Unit 1 Groundwater Flow Directions ..... 40 6.1.3 Objective 3: Monitor Unit 1 Groundwater Quality Outside HBW ........................ 41 6.1.4 Objective 4: Monitor Unit 3 and Unit 4 Groundwater Flow Directions and Vertical

Gradients .............................................................................................................. 42


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

Downgradient Property Boundary ........................................................................ 42 6.1.6 Objective 6: Monitor Groundwater Chemistry in the Vicinity of Unit 3 Well

SEC-7D ................................................................................................................ 43 6.1.7 Objective 7: Monitor Changes in Unit 3 Groundwater Quality During Full-Scale

ISTR ..................................................................................................................... 44 6.1.8 Objective 8: Post-ESRC Unit 3 Synoptic Monitoring ........................................... 44 6.1.9 Objective 9: GW-U402B and Post-ESRC Unit 4 Monitoring ................................ 45 6.1.10 Objective 10: Monitor Well GW-LP01 .................................................................. 46

6.2 Proposed Modifications To The Annual OM&M Activities ................................................ 46 6.2.1 Master Plan Schedule .......................................................................................... 47

7.0 REFERENCES ............................................................................................................................... 48

List of Tables Table 1 Summary of Well Completion Information Table 2 Post-ESRC Groundwater Monitoring Scope Table 3 Target Analytes and Comparative Criteria Table 4 Summary of Detected Compounds in Unit 1 Groundwater Data – 2015 Post-ESRC

Groundwater Monitoring Table 5 Summary of Detected Compounds in Unit 3 Groundwater Data – 2015 Post-ESRC

Groundwater Monitoring Table 6 2016 Unit 1 Monitoring Locations Table 7 2017 Units 3 & 4 Monitoring Locations

List of Figures Figure 1 Site Location Map Figure 2 Base Map and Groundwater Monitoring Points Figure 3 Master Plan Schedule (December 31, 2015) Figure 4 Piezometric Contour Map Unit 1 (April 8, 2015) Figure 5 Piezometric Contour Map Unit 1 (July 22, 2015) Figure 6 Piezometric Contour Map Unit 1 (October 30, 2015) Figure 7 Piezometric Contour Map Unit 1 (December 7, 2015) Figure 8 Post-ESRC Unit 1 Monitoring - 2015 Figure 9 Post-ESRC Unit 3 Monitoring - 2015 Figure 10 2016 Unit 1 Monitoring Locations Figure 11 2016 Unit 3 and Unit 4 Monitoring Locations

List of Appendices Appendix A Key Agency Correspondence Appendix B Well Completion and Abandonment Reports Appendix B-1 Unit 3 Well Completion Report Appendix B-2 Unit 4 Well Investigation and Well Installation Report Appendix C GWES/GWTF OM&M Data Appendix D Groundwater Elevation Monitoring Appendix D-1 Groundwater Elevation Monitoring Appendix D-2 Continuous Groundwater Elevation Monitoring Appendix D-3 Datalogger Temperature Surveys Appendix E Data Quality Assessment Appendix F Laboratory Data Packages Appendix G Other Data Appendix G-1 Additional Unit 3 Groundwater Monitoring


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Appendix G-2 Unit 4 Groundwater Monitoring Appendix G-3 GW-LP01


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ACRONYM DEFINITION

APS Additional Polluting Substances ASGECI Amy S. Greene Environmental Consultants, Inc. CAMP CAP

Community Air Monitoring Program Citizens’ Advisory Panel

CMDR Corrective Measures Design Report CMI Corrective Measures Implementation CMS Corrective Measures Study CTDEEP Connecticut Department of Energy and Environmental Protection DNAPL Dense Non-Aqueous Phase Liquid E&S Erosion & Sedimentation EC Engineered Control ELUR Environmental Land Use Restrictions ESRC East Side Remedial Components FBR Fluidized Bed Reactor FIR Final Investigation Report GAC Granular Activated Carbon GWES Groundwater Extraction System GWTF Groundwater Treatment Facility HBW Hydraulic Barrier Wall ICVC Industrial/Commercial Volatilization Criteria IRM Interim Remedial Measure(s) ISTR In-Situ Thermal Remediation LNAPL Light Non-aqueous Phase Liquid MPS MSL

Media Protection Standards Mean Sea Level

NPDES National Pollutant Discharge Elimination System OLISP CTDEEP Office of Long Island Sound Programs OM&M Operation, Monitoring, and Maintenance PCBs Polychlorinated Biphenyls PDI Preliminary Design Investigation PDP Preliminary Design Proposal QA QC

Quality Assurance Quality Control

QMG Quantum Management Group RCRA Resource Conservation and Recovery Act SIM Selective Ion Monitoring SRS Solids Removal System SVOCs Semivolatile Organic Compounds SWPC Surface Water Protection Criteria TSCA Toxic Substances Control Act TTZ USACE

Target Treatment Zone US Army Corps of Engineers


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ACRONYM DEFINITION

USEPA United States Environmental Protection Agency UV/Oxidation Ultra Violet Light/Hydrogen Peroxide VOCs Volatile Organic Compounds WWTR Wastewater Treatment Residuals


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1.0 INTRODUCTION

1.1 Overview This 2015 Annual Progress Report (2015 Annual Report) has been prepared by Golder Associates Inc.

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

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

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

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

Components (ESRC), are shown on the base map provided as Figure 22. This Annual Report was

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

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

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

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

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

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

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

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

Plan. In addition, the implementation of the corrective measure is intended to satisfy CTDEEP’s

requirements for final closure of the RCRA units identified at the Site and to satisfy the CTDEEP

Remediation Standard Regulations (RSRs) (CTDEEP, amended June 27, 2013). Approvals from other

regulatory agencies, such as the US Army Corps of Engineers (USACE) and CTDEEP Office of Long

Island Sound Programs (OLISP) and from the Town of North Haven will also be obtained as appropriate

for the implementation of the corrective measures.

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

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

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

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

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

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

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

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

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

the Order.

2 This base map contains a snapshot of the monitoring wells present at the Site as of December 31, 2015 and reflects well installations and abandonments completed throughout 2015. As a result, monitoring points appearing as abandoned on Figure 2 may have been used in for a portion of 2015 and discussed in this Annual Report but abandoned at some point later in the year.


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

Reports to USEPA, as discussed below.

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

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

parenthesis:

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

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

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

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

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

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

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

in Section 2 of this 2015 Annual Report. A description of the Interim Remedial Measures (IRM) is

presented in Section 1.3 and updates to the status of the IRM have been provided to USEPA and

CTDEEP on a quarterly basis throughout 2015. The effectiveness of existing interim remedial measures,

the corrective measures components installed and other controls put in place during CMI in 2015 is

summarized in Section 4. As corrective measures design and construction progress, future Annual

Reports will cover final corrective measures effectiveness. Similarly, several of the institutional controls

required by the Order, such as Environmental Land Use Restrictions (ELURs), will not be in place until

the corrective measures are completed, therefore Section 5 of this report focuses on confirming the

monitoring of the institutional controls currently in place.

1.2.2 Quarterly Progress Reports The Order also requires reporting of CMI progress to USEPA on a quarterly basis. During 2015,

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

reporting periods (submittals dates are in parenthesis):

January through March 2015 (April 30, 2015)

April through June 2015 (July 30, 2015)


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July through September 2015 (October 29, 2015)

October through December 2015 (January 25, 2016)

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

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

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

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

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

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

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

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

Spectrix)), former off-site landfill, and South Creek (southwest and south sides); the Quinnipiac River and

Interstate 91 (east side); and the State Route 40 highway and embankment, inactive industrial sites (e.g.,

the Humphrey Chemical Site), and North Creek (north side). The small parcel of predominantly tidal

wetlands adjacent to the northeast corner of the Site is referred to as the North Haven Land Trust

property. The surrounding properties have been used for a variety of industrial activities since the early

1800s.

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

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

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

Corporation for electrical component manufacturing from circa 1963 to 1975. Beginning in 1962, Upjohn

produced specialty and industrial chemicals including pharmaceutical, dye, pigment, and photographic

intermediates, agricultural treatment chemicals, ultraviolet curing initiators, coating and adhesive

additives, and flavor and fragrance components. Chemical manufacturing continued until 1993, when the

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

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

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

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

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

description, including a detailed conceptual Site model, can be found in the Final Investigation Report

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


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

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

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

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

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

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

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

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

maintained by Pharmacia & Upjohn until the final corrective measures are installed. In several portions of

the Site existing IRM will be incorporated into the final remedy.

Current Site use includes operation and maintenance of the existing interim and final remedial systems,

including a groundwater extraction system (GWES) and a groundwater treatment facility (GWTF)3, along

with CMI construction activities. Woodard & Curran, on behalf of Pharmacia & Upjohn, manages and

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

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

Site.

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

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

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

bedrock (Unit 4) and include:

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

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

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

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

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

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

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

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

3 The on-site GWTF is operated by Woodard & Curran in accordance with National Pollutant Discharge Elimination System (NPDES) Permit CT0001341, issued by CTDEEP on January 8, 2010.


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

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

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

combination of the hydraulic barrier wall (HBW) and the GWES. The collected Unit 1 groundwater is

treated by the GWTF prior to its discharge to adjacent surface waters.

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

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

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

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

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

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

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

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

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

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

Pharmacia & Upjohn updated the Site conceptual hydrogeologic and chemical transport model for Unit 3

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

northern portion of the Site were presented in the revised SEC-7D Pre-Design Investigation Report and

Preliminary Design Proposal (SEC-7D PDI/PDP), which was submitted to USEPA and CTDEEP in

February 2014 (Golder, 2014b). The conceptual Site model continues to evolve as new hydrogeologic

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

1.4 Description of Selected Corrective Measure (Remedy) The Corrective Measure selected by USEPA for the Site is presented in the USEPA Final Decision and

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

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

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

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


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

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

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

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

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

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

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

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

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

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

1.5 Performance Standards and Master Plan Schedule The Order includes “Performance Standards” which define the performance requirements for the

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

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

specific Sections of the CTDEEP RSRs.

4 Section VII.B.5.b.i of the new RCRA 3008(h) Order excludes ‘controlled community access via guided interpretive trails on the east side’ from ‘outdoor recreational use,’ which is included in the definition of ‘residential use’ under the CT RSRs at Section 22a-133q-1.


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

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

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

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

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

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

Sections below, Pharmacia & Upjohn has accelerated the CMI schedule and has completed all of the

scheduled Major Milestones and Progress Goals ahead of the Master Plan Schedule. Pharmacia &

Upjohn will strive to continue this accelerated pace throughout the CMI.

Activity Milestone Type

Milestone Date

Date Achieved

Status as of December 31, 2015

2011 Submit Draft ISTR Pilot System

Design and Pilot-Study Work Plan

Major Milestone 6/16/2011 6/3/2011

Approved by USEPA and CTDEEP after

revisions. Submit NPDES Request for Determination Concerning

Wastewaters from ISTR Pilot System Operation

Progress Goal 8/26/2011 6/1/2011

Approved by CTDEEP. No USEPA approval

required.

Submit CMI Work Plan Major Milestone 11/18/2011 9/30/2011


revisions. Submit ESRC Component Implementation Work Plan

(including PDI Sampling and Analysis Plan)



revisions.

2012 Complete ISTR Pilot System

Construction Progress

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

Submit Sediment PDI Report and Sediment Remediation PDP

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

and CTDEEP.

Submit SEC-7D PDI/PDP Progress Goal 3/21/2013 9/14/2012

Approved by USEPA after revisions;

CTDEEP deferred review to USEPA.

Complete ISTR Pilot Study Progress Goal 3/18/2013 11/14/2012 Completed.

2013 Submit NPDES Request for Determination Concerning Wastewaters from ESRC

Construction Activities

Progress Goal 7/3/2014 2/19/2013


required.

Submit Unit 1 Groundwater Hydraulic Controls Draft final

Design Package



revisions.

5 The Groundwater Extraction System (GWES) Hydrogeologic Design Draft Final Design (DFD), Appendix H of the ESRC CMDR, was submitted on May 6, 2013 (Golder, 2013c).


February 2016 8 033-6231-002

Activity Milestone Type

Milestone Date

Date Achieved

Status as of December 31, 2015

Submit Draft Final Design Package for Remaining ESRCs



revisions.

Submit ISTR Pilot Study Report and PDP

Major Milestone 11/13/2014 8/30/2013



2014

Submit Full-Scale ISTR Draft Final Design

Progress Goal 9/25/2015 12/11/2014



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

Progress Goal 10/30/2015 3/3/2015


required.

Complete Full-Scale ISTR System Construction

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

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

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

Goal “Submit Draft Final Design of West Side Remedial Components (WSRC)” was revised from August

28, 2015 to November 16, 2016. USEPA was notified of the intent to change the target completion for this

Progress goal in Second Quarter 2015 Progress Report. This change will allow Pharmacia & Upjohn and

its subcontractors to complete full-scale ISTR operations and decommissioning, and collect additional

data on the existing west side conditions prior to designing the remedy. This additional time will also allow

for additional discussions with the Town of North Haven and potential developers. Revising the Progress

Goal date associated with the submittal of the Draft Final Design of the WSRC from August 28, 2015 to

November 16, 2016 is not anticipated to impact the ability to achieve the May 29, 2020 Major Milestone

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


February 2016 9 033-6231-002

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

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

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

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

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

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

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

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

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

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

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

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

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

activities performed by the CMI Team during 2015.

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

teleconferences on an approximately monthly basis throughout 2015. Progress teleconferences were

held on January 21, February 25, March 18, April 14, May 20, June 10, July 15, August 19, September

16, October 21, November 18, and December 16, 2015. A variety of topics were discussed during the

progress teleconferences including the progress of USEPA and CTDEEP technical reviews of CMI Team

submittals, community air monitoring related to the full-scale ISTR, full-scale ISTR system construction

and operation, ESRC construction activities, groundwater monitoring results, and various technical

matters. Once ISTR operation began, representatives of USEPA, CTDEEP, and a smaller selection of

CMI Team Members also participated in focused teleconferences to review the progress of ISTR

operations on July 1, August 5, September 2, October 6, November 4, and December 2, 2015.

On April 14, 2015, Representatives of USEPA, CTDEEP visited the Site to perform the Pre-Construction

Inspection and Meeting related to the full-scale ISTR treatment of DNAPL and DNAPL-impacted soil and

WWTR within Subareas A and B. During the meeting, participants also discussed groundwater conditions


February 2016 10 033-6231-002

at the Site, and the monthly CMI progress update. Representatives of USEPA and CTDEEP also visited

the Site on October 1, 2015 and performed the post-construction inspection of the ESRC as well as

observing portions of the Air Emissions Compliance Monitoring (aka Stack Test) Event.

The CMI Team remained in regular communication with the USEPA and CTDEEP during 2015 through

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

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

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

CMI Team is provided in Appendix A.

2.2 Groundwater Treatment Facility Permitting and Operation Throughout 2015, Woodard & Curran continued to operate the GWTF in accordance with NPDES Permit

CT0001341, issued by CTDEEP on January 8, 2010. NPDES permits issued by CTDEEP typically have

an effective duration of 5 years, and accordingly the Site’s NPDES permit was scheduled to expire on

January 7, 2015. On behalf of Pharmacia & Upjohn, Woodard & Curran submitted a draft of the NPDES

permit renewal application to CTDEEP on May 15, 2014 for preliminary review in accordance with the

CTDEEP Pre-Application Assistance Program. CTDEEP provided comments on the draft application on

May 19, 2014, which were addressed prior to the formal submission of the NPDES permit renewal

application on July 3, 2014. The CTDEEP review of the revised permit renewal application was not

completed by January 7, 2015. CTDEEP communicated to Pharmacia & Upjohn that, as provided by the

State of Connecticut regulations, by the timely and administratively complete submittal to CTDEEP of the

permit renewal application, the GWTF should continue to operate in accordance with existing NPDES

permit CT0001341 until such time as the new permit is issued.

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

collected surface water samples from the Quinnipiac River on an approximately monthly basis between

April and December 2015. This data will be submitted to CTDEEP for CTDEEP’s possible use while

developing the discharge limits for the new NPDES permit.

A request for approval of modifications to the GWTF associated with managing the aqueous streams from

full-scale ISTR under RCSA 22a-430-3(i) was prepared by Woodard & Curran and submitted to CTDEEP

on March 3, 2015. On March 18, 2015, CTDEEP approved the treatment of the aqueous waste streams

associated with the full-scale ISTR and the modifications, which included the installation of two 10,000

pound granular activated carbon (GAC) vessels, upgrading the impellers for the pumps that feed the GAC

vessels, installing in-line ultraviolet transmittance sensors downstream of the GAC vessels. A copy of the

approval is included in Appendix A. Installation of the pre-treatment components began on April 9, 2015

and the system was commissioned and operational on May 15, 2015, shortly before the full-scale ISTR

system began operating.


February 2016 11 033-6231-002

Granular Activated Carbon Vessels installed to pre-treat ISTR Wastewaters

In response to operational needs, a Facility and Wastewater Treatment System Modification Notification

and Request for Approval under RCSA 22a-430-3(i) was submitted to CTDEEP on July 27, 2015

proposing the installation of a 21,000 gallon frac tank and a 18,000 gallon weir tank at the front end of the

ISTR liquid treatment process equipment to increase the residence time for the liquid treatment system.

The 3(i) request also included the potential introduction of citric acid (iron sequestration), biocide,

defoamer, and a biocide inhibitor to enhance the pretreatment system. The ISTR related design change

was communicated to USEPA via email on July 31, 2015 and discussed during the August 5, 2015 ISTR

Progress Update teleconference. CTDEEP approved the 3(i) request on August 5, 2015 (See Appendix

A). While the modifications were made to the process operated by TerraTherm prior to delivering the

ISTR wastewaters to the GWTF, they were considered a change to the wastewater treatment process,

thus requiring the CTDEEP 3(i) approval.

On December 22, 2014 the construction of the GWES and the associated controls were sufficiently

complete to transfer primary responsibility for operation of the GWES from the ESRC contractor,

NorthStar, to Woodard & Curran as the Site Operator. Woodard & Curran operated, monitored and

maintained the GWES throughout 2015. Golder monitored the hydrogeologic performance of the GWES

throughout the year. The operation, monitoring, and hydrogeologic performance of the GWES are

discussed in Section 3.0.


February 2016 12 033-6231-002

2.3 Groundwater Monitoring The data from the actions implemented by Golder in 2015 to fulfill the Order requirement to conduct

groundwater monitoring during the CMI period and to monitor the performance of installed final remedy

components are presented and evaluated in Section 3.0 of this 2015 Annual Report. The monitoring

activities that were anticipated to be performed in 2015 were described in Section 6.1 of the 2014 Annual

Progress Report. Additional refinements to the 2015 monitoring program were discussed with USEPA

and CTDEEP during the April 14, 2015 Site meeting. USEPA reviewed Section 6.1 of the 2014 Annual

Report and on June 4, 2015 confirmed that they had no comments on the proposed 2015 monitoring

program as modified by the additional activities discussed on April 14, 2015. The groundwater activities

conducted in 2015 are in part a continuation of the groundwater monitoring activities previously reported

to USEPA and CTDEEP in the 2011, 2012, 2013 and 2014 Annual Reports (Golder, 2012a, 2013a,

2014a and 2015a).

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

Groundwater Monitoring Plan, approved as Appendix D of the ESRC CMDR,6 were implemented in 2015:

Synoptic ground water level measurements were collected from selected Unit 1, Unit 3 and Unit 4 wells on March 25, July 22, October 30, and December 7, 2015.

The data from the continuous water level measurement devices (dataloggers) installed along the periphery of the Site were analyzed and used to recommend changes to the GWES operation to maintain Unit 1 hydraulic control. The dataloggers were downloaded on an approximately monthly basis throughout 2015.

Electronic dataloggers were installed in ten wells located outside the HBW from June 30, 2015 through July 15, 2015 and in three wells located outside the HBW between September 16, 2015 and September 29, 2015 to verify the relationship between water temperature and water level in the well to the tidal cycle and to confirm the timeframes to collect representative Unit 1 samples.

Groundwater samples were collected from ten selected Unit 1 wells between July 22, 2015 and July 24, 2015 and between October 19 and 23, 2015 to provide baseline data regarding Unit 1 groundwater quality outside the HBW.

Groundwater samples were collected from seven Unit 3 wells between October 19, 2015 and October 23, 2015. These samples verified that VOC and SVOC concentrations in Unit 3 groundwater at the Site perimeter continue to be below the comparative criteria.

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


February 2016 13 033-6231-002

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

implemented in 2015 to collect information related to monitoring CMI activities and the performance of the

Corrective Measures. These non-routine sampling and monitoring activities included:

Unit 3 wells GW-U312, GW-U313 and GW-U308 were installed between March 23, 2015 and April 1, 2015, Unit 4 well GW-U402A was abandoned on September 2, 2015, and Unit 4 well GW-U402B was installed between September 10, 2015 and September 17, 2015.

Groundwater samples were collected from selected Unit 1, deep unconfined groundwater, and Unit 3 monitoring wells in the vicinity of Unit 3 Well SEC-7D between April 8, 2015 and April 10, 2015 and between October 19, 2015 and October 22, 2015.

Groundwater samples were collected between April 8, 2015 and April 10, 2015, on June 9, 2015, on August 19, 2015, between October 19, 2015 and October 22, 2015, and on December 7, 2015 related to monitoring Unit 3 during full-scale ISTR operations

Geophysical studies were conducted on March 12, 2015 and September 9, 2015 and groundwater samples were collected on December 22, 2014, February 6, 2015, March 12, 2015, April 9, 2015, October 21 2015, and December 12, 2015, from Unit 4 wells GW-U402A and/or GW-U402B.

A Light Non-aqueous Phase Liquid (LNAPL) sample was collected from Unit 1 well GW-LP01 on November 2, 2015.

Documentation of USEPA and CTDEEP concurrence with the non-routine sampling activities is included

in Appendix A. Boring logs for the wells installed in support of these non-routine monitoring activities and

the geophysical studies in wells GW-U402A and GW-U402B are provided in Appendix B. Groundwater

data generated from these activities are discussed in Section 3.3 and are being provided to USEPA and

CTDEEP in the Appendices to this 2015 Annual Report.

2.4 In-Situ Thermal Remediation

2.4.1 ISTR Design The In Situ Thermal Remediation Draft Final Design (ISTR DFD) was submitted to USEPA and CTDEEP

in several stages to facilitate construction of the full-scale ISTR system in DNAPL Subareas A and B in

parallel with the Agency review of the ISTR DFD. The majority of the ISTR DFD, including the basis of

design (main text), engineering drawings (Appendix A) and air regulatory compliance demonstration

(Appendix B), was submitted to USEPA and CTDEEP on October 31, 2014. The remaining portions of the

ISTR DFD, namely the Sampling and Analysis Plan (SAP; Appendix D), the Quality Assurance Project

Plan (QAPP; Appendix F), and the ISTR Unit 3 Groundwater Monitoring Plan (ISTR Unit 3 GWMP;

Appendix G), were submitted to USEPA and CTDEEP on December 11, 2014. The submission of the

final appendices to the ISTR DFD on December 11, 2014 achieved the Order Progress Goal “Submit Full-

Scale ISTR Draft Final Design” in advance of the Master Plan Schedule (Progress Goal date: September

25, 2015). Pharmacia & Upjohn authorized the accelerated construction schedule based on USEPA’s


February 2016 14 033-6231-002

August 21, 2014 concurrence with the fundamental design components for full-scale ISTR treatment of

Subareas A and B, including metrics such as the proposed target treatment temperature and duration,

system specifications, treatment system monitoring requirements, and shut-down criteria presented in the

Full-scale ISTR Preliminary Design Proposal (TerraTherm and Golder, 2014).

On January 30, 2015, USEPA and CTDEEP were notified via email of minor revisions to the Community

Air Monitoring Plan (CAMP), including relocating the weather station by approximately 100 feet and

shifting monitoring station #3 to accommodate field conditions, along with a change in the perimeter

monitoring computer system to the Emilcott Greenlight™ system which utilizes cellular instead line of

sight communication to transmit the data collected at the monitoring stations to the central data

repository. These changes to the CAMP were approved by USEPA on February 9, 2015 and by CTDEEP

on February 10, 2015 (See Appendix A). These approvals authorized the operation of the CAMP system

during ISTR construction activities.

USEPA comments regarding all sections of the ISTR DFD were received by February 18, 2015.

Responses to the comments on the SAP, QAPP, and Unit 3 Groundwater Monitoring Plan for Full-Scale

ISTR (along with red-line/strike-out versions of the proposed revisions that would be included in the Full-

Scale ISTR Final Design (ISTR FD) were submitted to USEPA and CTDEEP on April 1, 2015. USEPA

approval of the comment responses and the ISTR FD was received on June 4, 2015. A copy of the

approval letter is provided in Appendix A. In the letter dated June 4, 2015, USEPA requested additional

clarifications of a few items related to RCRA characterization of wastes and Unit 3 groundwater

monitoring. The CMI team provided responses to USEPA on July 8, 2015 via email and held a brief

teleconference with USEPA on July 9, 2015 to discuss the responses. The CMI Team provided a copy of

the partially executed signature/approval page for the ISTR Quality Assurance Project Plan (QAPP) to

USEPA on July 17, 2015 and received the fully executed signature page from USEPA August 18, 2015.

Hard copies of the Final ISTR Design Report were distributed to USEPA and CTDEEP in August 2015.

The ISTR DFD discussed the intended parameters for the Air Emissions Compliance Test (aka the Stack

Test) and established that the associated sampling and analysis plan and the QC information for the

stack testing would be provided in a stand-alone submission. The Air Emissions Test Protocol for the Full-

Scale ISTR system and the associated QAPP Addendum (Gammie and Golder, 2015) were submitted to

USEPA and CTDEEP on July 29, 2015. USEPA requested clarification of a number of items in the Air

Emissions Test Protocol via teleconference and email on September 16, 2015. The requested

clarifications were provided to USEPA via email on September 29, 2015 in preparation for the stack

testing event conducted on October 1 and 2, 2015. On October 28, 2015, USEPA confirmed that the

comments on the stack test report were adequately addressed, which completes the review and revision

cycle for the Air Emissions Test Protocol and Full-Scale ISTR QAPP Addendum (See Appendix A).


February 2016 15 033-6231-002

2.4.2 ISTR System Construction TerraTherm implemented the CAMP throughout ISTR construction activities, including operation of the

real-time Photoionization Detectors (PID) as part of the Emilcott Greenlight™ system and collection of

monthly discrete samples for analysis of VOCs by an off-site laboratory by method TO-15. No verified

exceedances were reported during the construction period. The TO-15 data continued to indicate the

presence of various VOCs at concentrations consistent with background conditions.

During the second half of 2014, a number of improvements were made to the Site utilities to prepare for

full-scale ISTR, including relocating natural gas feeds and portions of the main electrical supply for the

GWTF, installation of secondary gas feeds to service the ISTR air emissions equipment, and installation

of a new emergency generator for the GWTF. Woodard & Curran oversaw additional modifications to the

Site utility infrastructure during 2015 in order to prepare for the operation of the ISTR system.

New electrical transformers and switchgear were installed in January 2015 and activated in March 2015.

The main power feed into the property was also upgraded by the local electricity provider (United

Illuminating) during the first quarter of 2015 in preparation for full-scale ISTR operations. These

modifications did not require CTDEEP approval, since they did not directly affect the GWTF process.

TerraTherm completed construction of the full-scale ISTR system during 2015. Major construction

activities completed in 2015 included the following:

ISTD heater well liner and heating rod installation

Well development and multi-phase extraction (MPE) pump installation

Construction of the liquid and compressed air manifolds in the wellfield

Installation and electrical connection of temperature and pressure monitoring point instrumentation

Delivery and installation the air pollution controls including the thermal oxidizer, scrubber, and quench system along with other vapor and liquid treatment system equipment

Installation of the piping for the aboveground vapor and liquid treatment system equipment, including piping to bring caustic from the storage tank inside the GWTF to the ISTR process equipment pad

Completion of the connections to the GWTF equalization tanks for the process wastewater discharge and to the GWTF surge tank for the non-contact cooling water discharge from the ISTR system

Completion of the electrical and natural gas infrastructure for the ISTR system

Completion of the ISTR system electrical wiring and the programming of the associated interlocks and alarms

Completion of the ISTR system construction on May 29, 2015 achieved the Order Master Plan Progress

Goal “Complete Full-Scale ISTR System Construction”.


February 2016 16 033-6231-002

2.4.3 ISTR System Operation and Design Modifications TerraTherm continued operation of the continuous-monitoring, perimeter PID monitoring stations

associated with the CAMP on a 24-hour basis during ISTR operation and collection of discrete samples

for TO-15 analysis of VOCs on an approximately monthly basis. No verified exceedances were identified

at any of the perimeter monitoring stations during 2015.

Vapor and liquid extraction from the Subarea A and Subarea B treatment zones began on June 5, 2015,

after USEPA authorized the operation of the full-scale ISTR system by approval of the comment

responses and the ISTR Full Scale Final Design Report on June 4, 2015. Subsurface heating began on

June 15, 2015. During the second half of June, power input to the ISTD heaters was slowly ramped up to

design levels and near the end of the month, TerraTherm initiated a heater cycling test to evaluate

whether they could shift a portion of the power demand to off-peak hours (and thereby “greener” power

sources). The heater cycling tests were successful, therefore during the remainder of ISTR operation, a

portion of the power demand was shifted to off-peak hours, where feasible. Also during operation of the

system in 2015, TerraTherm conducted energy injection and process monitoring, with vapor and liquid

extraction rates and heater inputs adjusted, as needed, based on the process monitoring data.

Panoramic view of the constructed full-scale ISTR System showing the well fields in DNAPL

Subareas A and B and the process treatment equipment

The ISTR liquid handling process equipment includes an organoclay vessel, which is designed to remove

any non-aqueous phase liquid (NAPL) droplets from the liquid stream conveyed to the GWTF. As

discussed in Section 2.2, in response to operational issues, including premature organoclay vessel and

filter clogging, TerraTherm modified the liquid treatment system to increase the residence time and allow

additional opportunities to separate NAPL from the aqueous wastes. The system modification authorized

by the 3(i) request approved by CTDEEP on August 5, 2015, including the frac tank, weir tank, and

chemical injection system, along with larger organoclay vessels and additional filtration capacity, was

installed and operational by August 21, 2015.


February 2016 17 033-6231-002

The air emissions compliance test event was conducted on October 1 and 2, 2015 and was observed by

representatives of USEPA and CTDEEP. The stack test samples were collected at near the peak

emission rates for the ISTR system, with the peak emission rate from Subarea A of approximately 2274

pounds/per day reached on October 6, 2015. Preliminary evaluation of the stack test data indicates that

the observed concentrations were below the performance standards. The data from the stack testing will

be provided as part of the DNAPL construction completion report.

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

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

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

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

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

USEPA notified Pharmacia & Upjohn that it had determined that the operation of Subarea B had

successfully attained the completion criteria (See Appendix A). Power input to Subarea B was ramped

down beginning on November 5, 2015. Vapor and liquid extraction continued from Subarea B until

November 30 and December 4, 2015, respectively. The liquid and vapor lines from Subarea B were

subsequently isolated from the main process while treatment of DNAPL Subarea A continued. The

completion of treatment in Subarea B more quickly than the completion of treatment in Subarea A was

expected based on the modelling performed during the ISTR system design process.

In mid-November, a target treatment temperature of approximately 100°C had been reached at 90% of

the individual temperature sensors located at centroid locations throughout the Subarea A treatment

zone, however the mass removal rate remained more than approximately 10% of the peak mass removal

rate. The performance monitoring indicated that as of December 31, 2015, treatment of Subarea A was

nearing completion.7

2.5 East Side Remedial Components

2.5.1 ESRC Construction and Design Modifications USEPA written approval of the ESRC Corrective Measures Design Report (CMDR) was issued on August

5, 2014. Clean record copies of the final ESRC CMDR were distributed to USEPA and other project

stakeholders on August 29, 2014, which completed the review and revision cycle for the documents

associated with Order Major Milestones: “Submit Unit 1 Hydraulic Controls Draft Final Design” and

“Submit Draft Final Design Package for the Remaining ESRC”. On April 11, 2014, the CMI team received

conditional approval from the CTDEEP of the EC Variance requests for all of the ESRC except for the

North Pile, which had previously been approved on July 12, 2013. By the end of the fourth quarter of

7 The completion of treatment in Subarea A was approved by USEPA on January 14, 2016.


February 2016 18 033-6231-002

2014, the ESRC construction had progressed to the point that impacted soils were no longer exposed

(i.e. clean cover systems had been placed) protecting site workers from potential contact with impacted

soils and eliminating the generation of potentially impacted stormwater. The locations of the major

components of the ESRC, and the locations of specific groundwater monitoring wells and Site features

are shown on Figure 2.

Limited ESRC construction occurred during the first quarter of 2015 due to frozen and snow covered

ground conditions. NorthStar completed a few minor tasks begun during the fourth quarter of 2014, then

in January 2015 demobilized from the Site except for a limited presence to monitor and maintain the pore

water extraction sumps on the South Pile and the erosion controls. NorthStar returned to the Site from

early May 2015 to July 2015 (referred to below as the “summer mobilization”) and again in late August

and September 2015 (referred to below as the “fall mobilization”) to substantially complete the remaining

ESRC construction activities, which are discussed thematically below.

Groundwater Extraction System

While the GWES controls and operations were transferred from NorthStar to Woodard & Curran in

December 2014, in January 2015, NorthStar completed minor items related to the GWES controls and

aboveground extraction infrastructure (e.g. installed heaters in well enclosures, labeled piping and

instrumentation, etc.). Additional minor items related to the GWES infrastructure were constructed during

the summer mobilization including extending existing site groundwater header clean-outs and valve stem

manholes to match the surrounding finish grade, and repairing monitoring wells that had been damaged

during winter snow plowing activities.

Constructed Inland Wetlands and Stormwater BMP in CMS Areas E-1, E-2 and E-3

Placement of the remainder of the soil in the South BMP was completed in early January 2015.

Ecological enhancements were installed between May and July 2015 in all of the inland wetland areas not

planted in 2014.

Tidal Wetlands Mitigation

A portion of the eastern stream bank of South Creek was damaged during significant summer rainstorms

in 2014. In response, the ESRC Team revised the design for the wetland mitigation area adjacent to

South Creek. On November 14, 2014, CTDEEP OLISP approved a Certificate of Permission (COP) to

construct the re-designed South Creek bank restoration and protection measures. Copies of the approved

COP were provided to USACE on November 17, 2014. On November 25, 2014, the CMI Team received

the USACE approval of the de minimis modification to the existing permit (permit number NAE-2012-

1039) to incorporate the additional South Creek bank restoration and protection activities into the


February 2016 19 033-6231-002

permitted work within wetlands under USACE jurisdiction. The following activities were completed in 2015

in accordance with the COP and USACE permit modification:

The South Creek bank adjacent to the new south Tidal Wetland (Creation Area C) was restored following storm-related damage in January and again in late March 2015.

Further restoration of the berm separating the South Creek from the new South Tidal Wetland area was completed in the second quarter of 2015, though sand bags were left in place to maintain the hydraulic separation until the new wetland plants fully established to protect the berm from potential storm erosion.

The sand bags were removed from the South Creek berm in early August 2015 and the area was stabilized with erosion matting, loam and seed. By September the new seed had germinated and permanent stabilization was achieved.

In addition, the plantings were completed in Tidal Wetland Mitigation Areas A and B during second

quarter of 2015. The remainder of the final grading and installation of plantings were completed in the

new South Tidal Wetland (Creation Area C) in July 2015.

South Pile

The following activities were completed on the South Pile in 2015:

The northern pore-water extraction sump was decommissioned during the second quarter of 2015 after reviewing the South Pile consolidation and pore-water generation data.

Ecological enhancements on the South Pile were completed in July 2015.

Pumping pore-water from the southern sump was discontinued in April 2015 and the stabilization of groundwater levels in that area of the South Pile was monitored. In August 2015, the southern pore-water extraction sump on the South Pile was decommissioned after confirming the stabilization of the water levels in this area. Following the abandonment, the ecological enhancements were restored.

Miscellaneous

The following miscellaneous ESRC activities were completed in 2015:

The cover system transition markers were installed in September 2015

Several “punch-list” items, including minor grading to improve the transitions between the various portions of the ESRC were completed during the summer and fall mobilizations.

A pedestrian bridge was placed to improve walkability of the trail system in the where it crosses the outlet of the North BMP in September 2015.

At the completion of construction, NorthStar removed its construction trailers and the remaining staged materials and equipment.

Erosion and Sedimentation Controls

NorthStar continued to maintain the erosion and sedimentation (E&S) controls surrounding the ESRC

through the first three quarters of 2015, inspecting them after storm events and repairing them as

conditions warranted. In August 2015, representatives of the USACE and the Town reviewed site


February 2016 20 033-6231-002

conditions with respect to growth of vegetation and stabilization of ground conditions. Approvals were

granted to remove the temporary erosion control measures from the majority of the Site. The remaining

erosion controls, namely a small length of silt fence along the northern edge of the North Pile side slope

downchute to the tidal wetlands and the perimeter coir logs downslope from the South Pile will be

removed upon Town approval.

Ecological Enhancement Maintenance and Monitoring

After NorthStar and their subcontractors completed the ecological enhancement plantings in July 2015,

the new plantings were irrigated in upland areas throughout the Site on an approximately weekly basis

into the fall. ASGECI monitored the plant growth and collected data related to the tidal wetlands mitigation

reporting. Maintenance and monitoring of the new plantings will continue over the next several in

accordance with USACE and CTDEEP permit requirements.

Photographs of the completed ESRC and the October 1, 2015 Post-Construction Inspection

\\mtlaurel\mtl data\data\projects\2003 projects\033-6231-002 nhaven\annualrpt\2015\p20.docx

February 2016 21 033-6231-002

2.5.2 ESRC Reporting On January 26, 2015, ASGECI submitted an annual update concerning the status of the activities

associated with the Wetland Mitigation Plan and Permit NAE-2012-1039 to the USACE, and copying the

CTDEEP OLISP. On June 24, 2015, ASGECI submitted a letter to USACE, copying CTDEEP OLISP,

notifying them of the Completion of Mitigation Activities and the start of the post-construction monitoring in

the tidal wetlands mitigation areas associated with USACE Permit number NAE-2012-1039.

As the ESRC work is substantially complete, including all cover systems, GWES construction, hydraulic

barrier wall, roads, paths, and initial plantings, representatives of USEPA and CTDEEP conducted a post-

construction inspection of the ESRC areas on October 1, 2015. On October 28, 2015, USEPA notified the

CMI Team that they had no comments regarding the observed conditions in the ESRC.

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

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

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

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

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

Team requested and CTDEEP approved a further extension until February 15, 2016 (See Appendix A).

As the wetlands mitigation work is complete, an Annual Mitigation Monitoring Report is due to the US

Army Corps of Engineers (USACE) by December 15th each year. On December 3, 2015 the ESRC Team

requested and USACE approved an extension until January 31, 2016 to prepare and submit the first

Mitigation Monitoring Report8.

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

implementing the Community Relations Plan (Appendix H of the CMI Work Plan). Key community

outreach activities during 2015 included:

The CMI Team maintained regular contact with the Town of North Haven throughout the year to inform them of construction activities and work hours.

Meetings with the North Haven Citizens’ Advisory Panel were held in May and November 2015 to provide progress updates and obtain input from the members.

Representatives of the CMI Team attended the biannual North Haven Economic Development Breakfast held in April and October of 2015 to interact with local stakeholders.

8 The due date for the mitigation monitoring report was further extended to February 15, 2016 in late January 2016.


February 2016 22 033-6231-002

The CMI Team hosted a booth at the North Haven Community Earth Day celebration on

April 4, 2015 at the North Haven High School. The team displayed graphics depicting the site, answered questions, and promoted the project website.

Representatives of the CMI Team presented a project update at the North Haven Rotary Club on April 28, 2015.

A Site Safety Briefing was held on April 28, 2015 with North Haven Emergency Response personnel. Fire and rescue, police and public works departments were represented at this briefing. The CMI Team provided a detailed briefing about the anticipated 2015 work schedule, construction activities, and reviewed site safety protocols and emergency procedures.

News articles reporting on progress and activities at the PUC site appeared in The North Haven Citizen on May 15 and November 23, 2015. An article appeared in the New Haven Register on May 6, 2015. Articles were published in the North Haven Courier on November 17, 2015 and in the Meriden Record Journal on November 29, 2015.

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

Pharmacia & Upjohn commissioned a study of the Site remediation practices under the ASTM Standard Guide for Greener Cleanups (E2893-13). The completed study identifying the greener cleanup best management practices (BMPs), which included the quantitative analysis of the carbon footprint of remedial activities during the remedy selection, the onsite reuse of impacted soils, the use of recycled ground/granulated blast furnace slag in place of virgin bentonite for the HBW construction, and the ISTR energy conservation efforts, was posted on the CLU-IN website in July 20159 and highlighted in the September 1, 2015 edition of the USEPA Technology Innovation and Field Services Division’s TechDirect electronic newsletter.

On October 23, 2015, a delegation of scientists and professionals from the Socialist Republic of Vietnam and representatives of USEPA and the US Agency for International Development (USAID) visited the Site to observe the ongoing work and learn about the site investigation, risk assessment and remedial action process implemented at the site. The operation of the ISTR system was of particular interest to the delegation members, as this technology is potentially applicable to several contaminated sites in Vietnam.

9 To view the project profile, including the ASTM greener cleanup technical summary, visit https://clu-in.org/greenremediation/profiles/pharmaciaupjohn.


https://clu-in.org/greenremediation/profiles/pharmaciaupjohn

https://clu-in.org/greenremediation/profiles/pharmaciaupjohn

February 2016 23 033-6231-002

3.0 DATA SUMMARY AND CONCLUSIONS The Order includes a requirement to conduct groundwater monitoring both during corrective measures

implementation (CMI groundwater monitoring) and during long-term post-construction OM&M (post-CMI

groundwater monitoring) and to monitor the performance of the final remedy. Both the CMI Groundwater

Monitoring Plan, approved as Appendix of A of the CMI Work Plan, and Post-CMI Groundwater

Monitoring Plan, approved as Appendix D of the ESRC CMDR, made provisions to adapt the

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

modifications to the groundwater monitoring program to USEPA and CTDEEP to the Annual Reports.

Accordingly, the intended groundwater monitoring to be implemented in 2015 was described in Section

6.1 of the 2014 Annual Report. USEPA reviewed Section 6.1 of the 2014 Annual Report and on June 4,

2015 confirmed that they had no comments on the proposed 2015 monitoring program (see Appendix A).

Section 6.1 of the 2014 Annual Report laid out seven objectives for the groundwater data collection

activities to be conducted during 2015. The routine monitoring objectives, and the associated monitoring

activities, were drawn from the monitoring programs described in the CMI Groundwater Monitoring Plan,

the Transition GWES monitoring plan, and the Post-CMI Groundwater Monitoring Plan. The Full-Scale

ISTR FD and the SEC-7D PDI/PDP also describe other proposed CMI groundwater monitoring activities,

which are captured in these objectives. The objectives for groundwater monitoring in 2015 were as

follows:

Objective 1: Monitor Unit 1 Groundwater Hydraulic Control

Objective 2: Evaluate Post-ESRC Groundwater Flow Directions in Units 1, 3, and 4

Objective 3: Establish Baseline Unit 1 Groundwater Quality Outside the HBW

Objective 4: Demonstrate Compliance with Unit 3 Performance Standards at Downgradient Property Boundary

Objective 5: Monitor Groundwater Chemistry and Hydraulic Gradients in the Vicinity of Unit 3 Well SEC-7D

Objective 6: Confirm Groundwater Quality Data Collected at Unit 4 Well GW-U402A

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

Section 3 of the 2015 Annual Report summarizes the data collected to monitor operations of the GWES

and GWTF, groundwater monitoring data collected in accordance with the objectives described above,

and the other data collected in 2015 during the activities described in Section 2.0.


February 2016 24 033-6231-002

3.1 Assessment of Performance of the Groundwater Extraction Systems and

Groundwater Treatment System During the 2015 monitoring period Pharmacia & Upjohn operated the Post-ESRC GWES consisting of

extraction wells PW-1R, PW-2RA, PW-4R, PW-5R10, PW-9, PW-10, PW-16A, TPW-1N, and the

extraction sumps within both the north and the south groundwater collection trenches (S1S, S2S, S2N,

and S1N). The locations of the GWES wells and sumps are shown on Figure 2. Table 1 summarizes the

screen length and placement for the extraction wells and the surrounding monitoring wells. Pharmacia &

Upjohn also continued to operate, monitor, and maintain the GWTF to treat the extracted groundwater

and the CMI wastewater flows.

Since the post-ESRC GWES was not fully functioning until late 2014 and final shakedown of the GWES

operation and controls did not occur until February 2015, the groundwater monitoring in 2015 as they

relate to Objectives 1 and 2 is a hybrid of the programs from the CMI Groundwater Monitoring Plan, the

Transition GWES monitoring plan, and the Post-CMI Groundwater Monitoring Plan, with the transition to

the post-ESRC monitoring described in the Post-CMI Groundwater Monitoring Plan occurring in July

2015.

3.1.1 Summary of GWES Operations, Monitoring, and Maintenance During the 2015 monitoring period, the GWES extraction wells and sumps included the following wellhead

and downhole equipment at each location:

Ball valves to allow isolation of appurtenances and instruments for maintenance;

Magnetic flow meter for continuous measurement of pumped flow rate and pump control;

Globe valve for flow throttling (for flow turndown at post-CMI pumping rates);

Check valve for backflow prevention;

Air relief valve for potentially entrained air;

Butterfly valves for flow diversion to the conveyance lines;

Sample port for groundwater sampling;

Grundfos submersible pumps, model 10S07-12 (extraction wells);

Blackhawk piston pumps, model 103E (collection sumps); and

Submersible level transducer.

Flow rates from each extraction well were varied by changing pump speed via variable frequency drives

(VFD) to maintain target water levels in the extraction well. Daily averages of instantaneous pumping

rates are summarized in Table C-1 in Appendix C.

10 Well PW-5R was taken offline in February 2015 due to operational issues. As hydraulic control in this portion of the Site was sufficiently maintained by PW-1R and PW-4R, PW-5R is not being operated at this time. The well is being maintained as part of the GWES as a contingency pumping location.


February 2016 25 033-6231-002

The extraction wells were maintained on an as-needed basis as part of the preventative maintenance

program to help achieve consistent performance and as needed based on observed increases in VFD

speed and decreased pumping rate. During the 2015 reporting period there were numerous maintenance

and redevelopment activities conducted at the Site to improve extraction efficiency and/or repair well

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

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

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

part of Site improvements. Appendix C summarizes the maintenance activities performed and significant

events occurring during the 2015 monitoring period.

3.1.2 Treatment System Monitoring The GWTF at the Site consists of a Fluidized Bed Reactor (FBR) Unit (installed in 1995), a Solids

Removal System (SRS) (installed in 2001), and an Ultraviolet Light/Hydrogen Peroxide (UV/Oxidation)

System (installed in 2001). The FBR Unit degrades organic compounds with activated biological growth

attached to suspended carbon media. The SRS removes suspended solids, metals, and some organics

adhered to the solids from the FBR effluent. The UV/Oxidation System further degrades the organic

compounds by using ultraviolet light in conjunction with hydrogen peroxide to oxidize and destroy the

compounds. The GWTF operates and is monitored under a NPDES permit (CT0001341) issued by

CTDEEP that regulates the treatment of groundwater and stormwater and the subsequent discharge of

the treated water to the Quinnipiac River.

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

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

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

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

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

The pre-treatment system was operated in a batch mode beginning in May 2015.

A summary of the performance of the GWTF is provided in Table C-3 in Appendix C. The data include

average influent and effluent chemical concentrations, percent removal and mass removal during 2015.

The total mass of volatile and semivolatile organic chemicals listed in Table C-3 that was removed during

the 2015 reporting period is estimated to be approximately 3,085 pounds. The total volume treated by the

GWTF during the 2015 reporting period is estimated to be approximately 50,071,870 gallons. The

material treated by the GWTF included groundwater extracted from the perimeter of the Site by the

GWES, and wastewater generated by full-scale ISTR operations which included groundwater extracted

from DNAPL Subareas A and B, condensate and scrubber blowdown. Approximately 3,924,000 gallons of

groundwater extracted from DNAPL Subareas A and B and condensate from the ISTR process were

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


February 2016 26 033-6231-002

3.1.3 GWES Hydraulic Control Monitoring During 2015, GWES monitoring included the collection of manual and continuous water level monitoring

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

accordance with Objectives 1 and 2 in Section 6.1 of the 2014 Annual Report, to evaluate changes in Unit

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

assess post-ESRC Units 1, 3 and 4 groundwater flow patterns, elevations, and vertical gradients. Once

these evaluations were completed, recommendations were made to adjust groundwater extraction rates

(if needed). Manual groundwater elevation readings are included in Appendix D-1 and continuous

groundwater elevation data are presented in Appendix D-2.

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

measurement with tides is no longer required following installation of the HBW; however, during 2015

groundwater elevation measurements were targeted toward low-mid-tide11 to allow for Site groundwater

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

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

groundwater flows from west to east, toward the GWES as shown on Figures 4, 5, 6, and 7, from a high

elevation of approximately 10 to 12 feet National Geodetic Vertical Datum of 1929 (NGVD29) on the west

side of the Site to less than 0 feet NGVD29 on the east side of the Site where groundwater is collected by

the GWES. Unit 1 groundwater hydraulic control is shown on Figures 4, 5, 6 and 7 by the depressions in

the groundwater surface depicted between the Site and the Quinnipiac River. The piezometric contours

for the October 2015 and December 2015 monitoring events show the effects of the groundwater

extraction on the western side of the Site related to full-scale ISTR operations.

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

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

exterior monitoring points (monitoring wells or the Quinnipiac River) during the 2015 monitoring period.

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

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

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

was changed (or extraction well rehabilitated) to reestablish an inward gradient. These instances are

discussed in full in Appendix D-2.

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

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

hydraulic control analyses (see previous Annual Reports).

11 Low tide is defined to be five hours after high groundwater elevation occurs at MP-22S One hour is added to the high groundwater elevation in MP-22 to approximate the time frame required for the high tide conditions to extend into the entire Site.


February 2016 27 033-6231-002

3.2 Groundwater Quality Monitoring

3.2.1 Groundwater Data Collection and Review Activities The approved Post-CMI Groundwater Monitoring Plan, included as Appendix D of the ESRC CMDR,

described the intended monitoring network, procedures for groundwater monitoring, and associated

Quality Assurance (QA) protocols for groundwater sampling and analyses at the Site during the first two

years following completion of ESRC construction, and concurrent with the implementation of the

remaining Corrective Measures. As the ESRC construction was considered complete in July 2015,

groundwater monitoring to achieve Objectives 3 and 4 was conducted as part of the first year of post-

ESRC monitoring. The results of this sampling are provided in this Section of the 2015 Annual Report.

The results of the non-routine groundwater monitoring that was conducted during 2015 in support of

monitoring objectives 5, 6 and 7 are described in Section 3.3.

Post-ESRC Groundwater Sampling and Analyses

The first year of the post-ESRC groundwater monitoring program was conducted 2015. Samples were

collected from ten Unit 1 wells located outside the HBW in April and October 2015 (GW-NFPA07,

GW-HBW03, GW-HBW11, GD-5S, DM-5S, DM-7S, GW-HBW12, GW-HBW06, GW-HBW13, and

GW-HBW07) and seven perimeter Unit 3 wells in October 2015 (GD-3D, GD-4D, MP-20DR, DM-5D,

DM-7D, DM-9D, MW-35D).

Prior to collection of the 2015 groundwater quality samples from the wells located outside the HBW,

electronic dataloggers were used to record temperature and water level data from a selection of these

wells for a two-week period to verify the relationships between water level and temperature in the well

and the tidal cycle to confirm the timeframes for collecting representative Unit 1 groundwater samples

outside the HBW. The results of the datalogger study are provided in Appendix D-3.

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

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

dates and parameters for analysis are summarized in Table 2. The primary objective of the Unit 1

samples was to establish baseline conditions in the wells outside the HBW. The primary objective of the

Unit 3 samples was to assess whether chemical concentrations in Unit 3 groundwater at the Site

perimeter remain below the comparative criteria and thereby meet the Unit 3 Performance Standards

presented in the Order.

Comparative Criteria

This Annual Report evaluates the groundwater analytical data in relation to two sets of comparative

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


February 2016 28 033-6231-002

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

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

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

2007) and subsequently withdrawn in May 2009, as well as 2) RSR values for Additional Polluting

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

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

revisions to the RSRs, among other factors. The promulgated RSRs or approved Site-specific RSRs for

APS at the time of remedy implementation are the applicable MPS.”

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

2015 Annual Report have changed from those used in the 2014 Annual Report to reflect the changes in

the RSRs. These RSR criteria include the RSRs for APS criteria approved by CTDEEP for Site-specific

use in December 2008 (CTDEEP, 2008) and March 2012 (CTDEEP, 2012a)12. The RSR criteria are

currently in transition while CTDEEP implements a multi-year transformation in the statues and

regulations underlying the Site cleanup program in accordance with the requirements of Public Act 12-

196 (CTDEEP, 2012b). In June 2013, CTDEEP promulgated the first wave of revisions to the RSRs.

However, with the exception of revisions to the criteria for Total Petroleum Hydrocarbons (TPH) and lead,

did not revise the SWPC and the Industrial/Commercial Volatilization Criteria (ICVC) criteria from those

originally published in 1996. The June 2013 revisions to the RSRs also formalized the withdrawal of

certain of the interim criteria previously used for comparative purposes in previous Annual Reports.

On December 10, 2015, CTDEEP released new APS and alternative criteria13 that could be requested for

expedited Site-Specific approval (CTDEEP, 2015). These criteria are based on recent toxicological

information for these chemicals, provide updated criteria for many common chemicals, but do not include

criteria for all the chemicals for which site-specific APS were developed and approved. After discussion

with CTDEEP, the hierarchy of RSR criteria used for comparative purposes in the 2015 Annual Report is

as follows:

Surface Water Protection Criteria

The SWPC promulgated in Appendix D of the June 2013 RSRs

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

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

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


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

February 2016 29 033-6231-002

Industrial/Commercial Volatilization Criteria

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

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

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

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

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

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

within 15 feet of the ground surface or a building. While these criteria are being used informally for

comparative purposes in this Annual Report, Pharmacia & Upjohn is discussing the possibility of

requesting approval of additional Site-specific criteria with CTDEEP.

Data Quality Review

In accordance with the Post-CMI Groundwater Monitoring Plan, the data generated by the groundwater

monitoring program underwent a data quality assessment to identify quality issues which could affect the

use of the data. After completion of the data quality review, 99.3 percent of the groundwater sample data

reported by Alpha associated with the groundwater monitoring program were found to be acceptable for

project use, which met the project completeness goal of 85 percent. The data quality review and the

detailed findings of the data quality assessment are presented in Appendix E along with tables

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

Chains-of-Custody, are provided on CD-ROM in Appendix F. In many cases, the samples from the routine

post-ESRC Groundwater Monitoring were collected concurrently with samples related to other monitoring

objectives. Therefore, Appendices E and F address all of the groundwater sample data collected in 2015.

3.2.2 Unit 1 Groundwater Sample Results While the primary intent of the Unit 1 groundwater sample data collected in 2015 is to meet Objective 3

and to establish baseline conditions outside the HBW, the sample results have been compared to the

SWPC and ICVC criteria discussed above. The compounds detected in the Unit 1 monitoring

groundwater samples are summarized in Table 4, with concentrations exceeding one or more of the

comparative criteria indicated. Complete results for the Unit 1 sample analyses (which include non-

detected compounds) are provided in Appendix E.

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

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

15 Chloroethane and 1-methylnaphthalene have both a site-specific and a 2015 Alternative ICVC criteria.


February 2016 30 033-6231-002

Benzene

2-Chloroaniline

3,3’-Dichlorobenzidine

3,3’-Dimethylbenzidine

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

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

Benzene

Vinyl Chloride

The five primary organic compounds identified in Unit 1 groundwater at the Site, based on frequency

and/or magnitude of detection, are benzene, chlorobenzene, 1,4-dioxane, 2-chloroaniline, and

3,3’-dichlorobenzidine16. The concentration of these five compounds in Unit 1 groundwater along with the

additional chemicals that exceed one or more of the comparative criteria are summarized on Figure 8.

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

NFPA07, GW-HBW03, GW-HBW11, GD-5S, DM-5S, and DM-7S) are below the comparative criteria. The

exceptions are:

The concentration of vinyl chloride in the October sample from GW-NPFA07 (54 ug/L) is above the ICVC RSR (52 ug/L). This detection is consistent with previous samples from well GW-NFPA07, collected both before and after the installation of the HBW. Concentrations of vinyl chloride in GW-NFPA07 have decreased from 190 ug/L in December 2005 and 110 ug/L in October 2013 to the 54 ug/L detected during the most recent sampling event. Well GW-NFPA07 is not located within 15 feet of any currently existing occupied buildings and, due to the location on the Site perimeter, is unlikely to be within 30 feet of future buildings; therefore, the presence of vinyl chloride at concentrations above the ICVC comparative criteria are not of concern.

The concentrations of 3,3’-dichlorobenzidine in the July and October samples from DM-5S (2.0 and 2.7 ug/L, respectively) and in the July sample from DM-7S (1.2 J ug/L) are between the SWPC MPS (0.850 ug/L) and the approved site-specific SWPC (12.19 ug/L). These results are consistent with historical results from groundwater samples collected before ESRC construction. The highest concentration of 3,3’-dichlorobenzidine in well DM-5S (12 ug/L) was detected in March 2002. Concentrations between 5 ug/L and non-detect have been reported in DM-5S in the eight samples collected between September 2003 and March 2007. The highest concentration of 3,3’-dichlorobenzidine in well DM-7S (9 ug/L) was detected in September 2001. Concentrations between 2 ug/L and non-detect have been reported in DM-5S in the nine samples collected between September 2003 and March 2007. As the results are below the approved site-specific SWPC, they are not of concern.

The remainder of the sample results above the comparative criteria are from groundwater samples

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

concentration of 2-chloroaniline in groundwater from wells GW-HBW06 (340 ug/L, October 2015) and

GW-HBW07 (400 ug/L, July 2015) are above the Site-specific SWPC (53 ug/L), these concentration are

16 These five compounds were previously identified as compounds of concern (COCs).


February 2016 31 033-6231-002

orders of magnitude below recent concentrations detected in South Pile wells now located interior to the

HBW (36,000 ug/L in well MW-35SR in September 2013; 6,400 ug/L in well PW-11 in September 2014).

Similarly, the concentration of benzene in groundwater from well GW-HBW13 (580 ug/L, July 2015) is

below the maximum historical concentration for benzene (6,500 ug/L detected in well MW-35SR in

December 2011) and the concentration of 3,3’-dimethylbenzidine in groundwater from well GW-HBW06

(76 ug/L in October 2015) is below the maximum historical concentration for 3,3’-dichlorobenzidine (370

ug/L detected well PW-11 in September 2005). As specified in the Post-CMI Groundwater Monitoring

Plan, the remnant impacts in groundwater from these wells will continue to be monitored.

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

MP-20DR, and MW-35D) to monitor conditions at the downgradient perimeter during October 2015. The

chemicals detected in Unit 3 in these routine post-ESRC monitoring samples are summarized in Table 5,

where they are compared to the SWPC criteria described above. As shown on Figure 9 and discussed

below, all results from the Unit 3 perimeter monitoring samples collected as part of the routine post-ESRC

monitoring were below the comparative criteria. Complete results for the Unit 3 sample analyses (which

include non-detected results) are provided in Appendix E.

Perimeter Unit 3 Wells

Consistent with the evaluation of Unit 3 groundwater presented in Appendix L of the CMS, provisions of

the June 27, 2013 CTDEEP RSRs promulgated under 22a-133k-3(g)(2)(c) were considered to evaluate

compliance with the SWPC (the only groundwater protection criteria applicable to Unit 3 and 4

groundwater). Specifically, compliance with the SWPC for a substance in groundwater is achieved when

the sampling locations are representative of the subject groundwater plume and:

(i) the ninety-five percent upper confidence level of the arithmetic mean of all sample results representative of the subject groundwater plume is equal to or less than such criterion; or (ii) the concentration of a substance in the portion of the plume which is immediately upgradient of the point of discharge to groundwater is less than or equal to the SWPC.

The chemistry results for organic compounds in the downgradient perimeter wells sampled as part of the

2015 CMI Groundwater Monitoring are all below the MPS and the RSR and APS-based SWPC criteria.

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

of various CMI activities, including the collection and analysis of Unit 3 samples located interior to the

Site. The results from the analysis of these samples are provided in appendices to this Annual Report.


February 2016 32 033-6231-002

3.3.1 Additional Unit 3 Groundwater Monitoring Two new Unit 3 monitoring wells (GW-U312 and GW-U313) were installed and Unit 3 groundwater

monitoring was conducted in the interior of the Site to gather data relevant to monitoring Objectives 5 and

7. While these objectives were independently derived from the SEC-7D PDI/PDP and the Full-Scale ISTR

FD, due to the proximity of the wells, all Unit 3 data collected from the northeastern and central portions

of the Site during 2015 are discussed in an integrated fashion in Appendix G-1. The Unit 3 well

installation is documented in Appendix B-1. The results of the groundwater samples collected between

April 8, 2015 and April 10, 2015, on June 9, 2015, on August 19, 2015, between October 19, 2015 and

October 22, 2015, and on December 7, 2015 are provided in Appendix G-1. The data quality assessment

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

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

3.3.2 Unit 4 Groundwater Monitoring During ESRC construction, Unit 4 monitoring well GW-U402 was replaced with monitoring well GW-

U402A, located approximately 40 feet to the South, due to the construction of Tiers 2 and 3 of the

Northern Inland Wetlands. Initial groundwater sample results from well GW-U402A in October 2014 were

not consistent with historical results from well GW-U402. The work performed in 2015 related to

monitoring Objective 6 to confirm the October 2014 data from GW-U402A is provided in Appendix G-2.

The scope of the Unit 4 monitoring in 2015 expanded from that originally proposed in the 2014 Annual

Report and led to the abandonment of well GW-U402A and the installation of well GW-U402B. The

additional response actions, including geophysical studies of the GW-U402A borehole, the subsequent

abandonment of well GW-U402A, the installation of well GW-U402B approximately 25 feet east of well

GW-U402A and 45 southeast of former well GW-U402, and the geophysical studies in new well GW-

U402B are documented in Appendix B-2. The results of the Unit 4 groundwater samples collected on

December 22, 2014, February 6, 2015, April 9, 2015, October 21 2015, and December 12, 2015, along

with results from adjacent Unit 3 well GW-U305 are provided in Appendix G-2 along with a brief overview

of the Unit 4 sampling history. The data quality assessment for the 2015 Unit 4 data was integrated with

the data quality assessment for the post-ESRC monitoring data and is provided in Appendix E. The

laboratory data packages are provided in Appendix F.

3.3.3 GW-LP01 Monitoring Residual LNAPL was observed in monitoring well GW-LP01 on September 17, 2015 during water level

measurement as part of ISTR Subarea A hydraulic control monitoring. On November 2, 2015, Golder

Associates staff removed as much LNAPL as possible from the well with a bailer and submitted a sample

of the LNAPL material for laboratory analysis. A full summary of the sample results is provided in

Appendix G-3. The laboratory data package is provided in Appendix F.


February 2016 33 033-6231-002

4.0 ASSESSMENT OF PERFORMANCE OF CORRECTIVE MEASURE The Order requires that the Annual Report provide an assessment of the performance of the Corrective

Measure during the previous year. Construction of the Unit 1 groundwater hydraulic controls, construction

of the ESRC, and the focused remediation of sediment in Tidal Flat No. 1 and 2 and the South Creek was

substantially completed in 2015. The remaining final “Corrective Measures” as defined by the Order, are

in process of design, construction, or operation and have not been completed to date. Therefore, this

Section of the 2015 Annual Report discusses the effectiveness of the Corrective Measure components

that have been constructed to date, namely the Unit 1 groundwater hydraulic controls and final cover

systems constructed on the eastern portion of the Site as part of the ESRC, along with the remaining IRM

and interim covers remaining in place on the west side of the Site. Subsequent Annual Reports will

provide specific assessments of the performance of the final Corrective Measures once they are fully

constructed at the Site and when appropriate, will discuss progress toward achievement of the Order

Performance Standards. The groundwater migration controls and direct exposure controls described

below, along with the ongoing Site management procedures and institutional controls (as discussed in

Section 5.0) will continue to mitigate and provide protection of human and environmental exposures to

impacted media throughout the CMI period until final Corrective Measures are fully implemented at Site

Groundwater Migration Controls

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

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

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

and South Creek) by providing effective containment and treatment of impacted groundwater. Prior to

June 2013, groundwater hydraulic control was provided by the interim GWES, which in 1999 allowed

USEPA to approve stabilization measures under the Environmental Indicators Migration of Contaminated

Groundwater Under Control (CA-750), and provided the necessary hydraulic controls over impacted Unit

1 groundwater for over 15 years.

In November 2013, the ESRC Team completed the installation of the HBW, providing physical isolation of

impacted Unit 1 groundwater from the adjacent surface water. The construction of the GWES and the

associated controls were sufficiently complete as of December 22, 2014 to transfer primary responsibility

for operation of the GWES from the ESRC contractor, NorthStar, to the Site Operator, Woodard & Curran.

Between January and July 2015, NorthStar completed the remaining tasks to bring the GWES to the

post-ESRC configuration. The performance of the GWES and GWTF during 2015 is discussed in Section

3.1 of this Annual Report. Consistent with the findings of previous hydraulic control analyses, in 2015 the

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

prior to its reaching the Quinnipiac River.


February 2016 34 033-6231-002

Direct Exposure Controls

Prior to the start of CMI in 2011, Pharmacia & Upjohn had also previously installed IRM and various

RCRA and non-RCRA covers to mitigate human and ecological direct contact with impacted soil and

WWTR and institutional controls such as perimeter fencing to prevent unauthorized entry. Based on these

IRM covers and institutional controls, USEPA approved stabilization measures under the Environmental

Indicators for Current Human Exposures Under Control (CA-725) in 1999. In essence, this means that

there were no unacceptable human exposures to soil/WWTR at the Site, based on current use.

After decontaminating, decommissioning and removing former manufacturing buildings and storage tanks

in 1993, Pharmacia & Upjohn paved the majority of the western portion of the Site (including the Former

Production Area) to mitigate direct exposures. Pharmacia & Upjohn installed a chain-link fence and

locking gates around the north, west, and south property boundaries, installed warning signs, and

provided 24-hour per day Site security to minimize unauthorized entry to impacted areas of the Site. Also

in the western portion of the Site, Pharmacia & Upjohn constructed an IRM for the Relic Firewater Pond,

which provides a geosynthetic membrane and soil cover to prevent human and ecological exposures.

These IRM continue to effectively protect against direct contact exposures to impacted media on the

western side of the site in 2015 in those areas where CMI is not currently occurring.

During 2013 and 2014, a portion of the interim asphalt cover along the northwestern and southwestern

property boundaries was disturbed to install the groundwater extraction trenches and the other

infrastructure related to the post-ESRC GWES. The disturbed areas were repaired with asphalt pavement

(in the south) or asphalt millings (in the north) that prevent direct contact to underlying impacted media.

In August 2014, the interim asphalt cover in a portion of the Former Production Area was disturbed as

part of constructing the full-scale ISTR system in Subareas A and B. The clean fill and concrete thermal

covers placed over Subareas A and B during construction of the Target Treatment Zone (TTZ), and the

concrete and gravel equipment pads that hold the process treatment equipment prevent direct contact to

underlying contaminated media during the ISTR operations in 2015. The ISTR TTZ has also been

surrounded by physical barriers to deter entry and warning signs regarding both the subsurface

contamination and the electrical and thermal hazards associated with the operating ISTR system.

As described in Section 2.0, construction of the ESRC was substantially completed in 2015, and as of

July 2015 all impacted media located on the east side of the Site was covered by the approved low

permeability and protective barrier covers. While work remains to monitor and maintain the ecological

enhancements, that will among other purposes provide long-term stabilization of the cover systems

against erosion, the existing conditions prevent both human and ecological direct contact exposures. In


February 2016 35 033-6231-002

addition, the low permeability geosynthetic cover systems placed over the North Pile, FAL and South Pile

in 2014 will reduce infiltration of precipitation through WWTR.


February 2016 36 033-6231-002

5.0 INSTITUTIONAL CONTROL MONITORING ACTIVITIES The Order defines institutional controls as “(a) the prohibitions of various land and water use activities set

forth by Section VII.B.5.d and e of this Order to limit human exposure to the contaminants at the Facility

and ensure the protectiveness of the Corrective Measures as well as (b) the Environmental Land Use

Restrictions (ELURs) that Respondent shall put into place pursuant to Section VII.B.5.b of this Order.”

Section V.B.5.c of the Order requires that as part of the Annual Report, the Respondent shall confirm that

it has conducted long-term institutional control monitoring activities. The majority of the institutional

controls identified in the Order, in particular the ELURs, will not be implemented until after completion of

Corrective Measures construction. However, several institutional controls have been implemented at the

Site, are incorporated into Site OM&M, and have been monitored during the 2015 CMI reporting period as

summarized below.

Site-Wide Controls

Unauthorized entry into the accessible portions of the western side of the Site is restricted by a chain link

fence installed around the western boundary and portions of the northern and southern boundary.

Woodard & Curran is the contractor hired by Pharmacia & Upjohn to maintain a 24-hour per day on-site

presence, control the automatic locking Site entrance gate, and to operate and maintain the GWES and

GWTF. Access through the fenced area is controlled by three gates which are locked 24 hours a day

when not in use. A key card entry lock system and a surveillance camera is installed at the front gate (41

Stiles Lane). All Site visitors are required to sign in upon entry to the Site and to obey Site health and

safety requirements. The primary visitor sign-in area is located in the GWTF entrance and managed by

Woodard & Curran. Supplemental sign-in sheets for the consultants, contractors, and visitors associated

with CMI are also maintained by AECOM, NorthStar and TerraTherm.

Entry to the eastern side of the Site is controlled by natural features which render the area inaccessible.

Access to these portions of the Site is controlled by the following:

Eastern Portions of the North Side: The Highway 40 corridor’s steep embankment, North Creek waterway, dense vegetation, and tidal marsh;

Eastern Portion of the South Side: Neighboring industrial/commercial facilities, South Creek Waterway, and tidal marsh, and;

East Side: Quinnipiac River and tidal marsh.

The warning signs previously located within the tidal marsh under a Certificate of Permission from

CTDEEP OLISP were removed in 2014 and 2015 as part of the completion of the ESRC. While the

primary purpose is to protect the ecological enhancements during the initial establishment period, the

deer fencing installed along the site perimeter as part of ESRC will also deter unauthorized human entry

to the Site from the east.


February 2016 37 033-6231-002

All fences, gates, and security measures are checked periodically for vandalism or other evidence of

trespassing. Woodard & Curran staff is present on-site 24 hours per day and security checks of controlled

areas are made several times a day. There were no documented trespassing incidents in 2015.

Woodard & Curran staff performs a weekly perimeter sign inspection and maintenance program to

confirm that warning signs are present and remain clear of obstructions. The perimeter fencing is

inspected for damage and the gates are checked to ensure they are locked and locks are in working

order. Institutional control inspection checklists (for such items as signs, fences, and gates) are

maintained on-site. During 2015, Woodard & Curran staff would also periodically inspect the interim

covers on the west side of the Site and the final covers on the east side of the site to assess damage,

thereby fulfilling the requirement to at least annually verify that cover systems and engineered controls

are in good order.

During 2015, TerraTherm regularly inspected the concrete thermal covers constructed over Subareas A

and B in the Former Production Area and the warning signs surrounding the TTZ.

Current Land Use Restrictions

While the Environmental Land Use Restrictions (ELUR) described in the Order will not be implemented

until final CMs are installed, Site use restrictions are currently recorded on the existing property deed,

stating that the Site shall not be used in any manner that the USEPA determines would adversely affect

the integrity of any containment system, treatment system, or monitoring system. It is likely that at least

two separate ELURs will be implemented: (1) an ELUR allowing passive recreational use on the East

Side where ecological habitat will be restored, created and/or maintained, and (2) an ELUR allowing

commercial or light industrial use on the West Side. Pharmacia & Upjohn has verified that through its

oversight that current Site use is consistent with the conditions of the existing deed restriction.

Summary

As Site Owner, Pharmacia & Upjohn remains in control and maintains the Site in accordance with current

land use requirements, therefore institutional control provisions related to site ownership/property deed

transfer are not relevant. The Site continues to be used for remediation activities in accordance with

USEPA and CTDEEP approved work plans. While CMI activities, in particular the full-scale ISTR system,

have disturbed previously existing IRM, these activities are being performed with the knowledge and

consent of USEPA and CTDEEP and in accordance with the CMI Work Plan, temporary concrete thermal

covers have been constructed over disturbed portions of Subareas A and B, and no uncontrolled

exposure to Site contaminants has occurred or is currently. Prohibited uses of the Site, such as the

potable use of groundwater and the use for residential activities, are not occurring.


February 2016 38 033-6231-002

6.0 PROJECTED 2016 MONITORING ACTIVITIES AND MASTER PLAN

SCHEDULE The following Sections fulfill the Order requirement for the Annual Report to provide a schedule of

sampling and field activities to be performed and reported in the following year, along with any proposed

modifications to the OM&M activities. This Section also summarizes milestones and progress goals that

Pharmacia & Upjohn anticipates will be fulfilled in the upcoming year. There are no proposed changes to

the Master Plan Schedule.

6.1 Schedule of OM&M Sampling This Section summarizes the groundwater monitoring activities to be conducted in 2016. It includes

monitoring activities that have been described in previous technical submittals to USEPA and CTDEEP

and presents proposed monitoring activities. The approved Post-CMI Groundwater Monitoring Plan,

included as Appendix D of the ESRC CMDR, described the intended monitoring network, procedures for

groundwater monitoring, and associated QA protocols for groundwater sampling and analyses at the Site

during the first two years following completion of ESRC construction, and concurrent with the

implementation of the remaining Corrective Measures. The ESRC construction was considered

essentially complete in July 2015, when the NorthStar Team demobilized, and the transition to the

post-ESRC monitoring described in the Post-CMI Groundwater Monitoring Plan occurred in mid-2015.

Therefore the second year of post-ESRC monitoring begins in 2016. The Full-Scale ISTR FD and the

SEC-7D PDI/PDP also describe other proposed groundwater monitoring activities that will be

implemented in 2016. In addition, as described below, Pharmacia & Upjohn is planning to gather

groundwater samples from wells within Units 3 and 4 to collect data that will be considered when

developing the longer-term, post-CMI monitoring program.

As has been discussed on the progress teleconferences, a holistic view is valuable when considering

groundwater monitoring efforts and there is a benefit to consolidating monitoring activities to provide more

complete data sets. In support of this, the majority of the 2016 monitoring activities are being consolidated

into spring and fall 2016 monitoring events. Pharmacia & Upjohn anticipates that groundwater monitoring

in 2016 will continue to be a dynamic process as the Site moves towards post-CMI conditions. While it is

anticipated that the spring monitoring event will occur in March or April 2016 and the fall monitoring event

will occur in September or October 2016, the scope and the schedule of the groundwater monitoring

activities discussed below may be adjusted to accommodate the methods, locations and schedule of

specific construction activities planned for 2016 (e.g. Full-Scale ISTR decommissioning and WSRC-

related activities), access limitations, health and safety considerations, and the data obtained from the

spring event. USEPA and CTDEEP will be kept informed of the progress of these activities via the

quarterly progress reports and teleconferences, or by less formal means, such as email, as these

activities develop throughout the year.


February 2016 39 033-6231-002

The objectives, scope and schedule of the planned 2016 monitoring activities are described in the

sections that follow. The groundwater monitoring activities described below will be collected in general

accordance with the approved monitoring procedures and data quality objectives included in the

Post-CMI Groundwater Monitoring Plan, therefore detailed sampling procedures are not provided.

6.1.1 Objective 1: Unit 1 Groundwater Hydraulic Control Monitoring Objective

Verify hydraulic control of Unit 1 groundwater, evaluate changes in Unit 1 groundwater elevations as a

result of CMI and equilibration of the Site to post-ESRC conditions, and recommend adjustment to

groundwater extraction rates, if needed.

Scope and Schedule

To achieve this objective, Unit 1 groundwater elevation measurements will be taken along the Site

perimeter and the HBW alignment on a continuous basis using portable electronic datalogger devices. As

described in both the GWES Final Design (Golder, and the Post-CMI Groundwater Monitoring Plan,

periodic manual water level measurements will also be taken at the locations where the dataloggers are

installed that will be used to verify the accuracy of the datalogger devices and allow for correction, if

necessary. These continuous groundwater elevation measurements will be supplemented by periodic

manual groundwater elevation measurements at selected perimeter wells between the continuous

monitoring locations.

During 2016, the portable dataloggers will be deployed at the locations indicated in Table 6 and shown on Figure 10. This configuration is similar to the configuration described in the Post-CMI Groundwater Monitoring Plan; however, it incorporates changes in response to ESRC as-built conditions (e.g. the use of replacement wells when those referenced in the Post-CMI Groundwater Monitoring Plan were damaged by construction, and the changes to which wells will be used for extraction on the South Pile) and adjustments to the monitoring locations based on the data collected during the 2015 monitoring period. The datalogger configuration for 2016 will be similar to that used during the 4th Quarter of 2015 with two modifications.

The dataloggers will be removed from several redundant continuous monitoring locations (GD-6SR and MW-35SR) and locations exhibiting 100% inward gradients during the 2015 monitoring period (GW-HBW04A/GW-HBW03 pair and GW-HBW08/GW-HBW09 pair). These locations (GD-6SR, MW-35SR, GW-HBW04A, GW-HBW03, GW-HBW08, and GW-HBW09) will be monitored manually at the same time that the dataloggers are downloaded and readings verified.

Groundwater elevations in the Groundwater Collection Trenches will be monitored by the addition of datalogger monitoring pairs in each collection trench segment (STP-01/GW-NFPA06 and STP-05/GW-NFPA01 in the North Groundwater Collection Trench and STP-10/GW-HBW18 and STP-07/GW-HBW10 in the South Groundwater Collection Trench).


February 2016 40 033-6231-002

The continuous water level monitoring in the groundwater collection trenches is being added, in part, due

to the difficulty of accessing the monitoring points to collect manual measurements in these areas under

winter conditions. Therefore, Pharmacia & Upjohn moved the dataloggers to the configuration shown on

Table 6 in January 2016.

As specified in the Post-CMI Groundwater Monitoring Plan, the information collected by the dataloggers

was evaluated approximately monthly during the first six months following the completion of the ESRC

construction (July through December 2015). The Post-CMI Groundwater Monitoring Plan anticipated that

after the initial 6-month period, the datalogger downloads and manual elevation verification would be

performed semiannually for the first two years following ESRC CMI completion. As proposed in the

Post-CMI Groundwater Monitoring Plan, the frequency of the manual verification of the water levels, and

the collection of the supplemental manual groundwater elevations was evaluated following the initial

6-month period. Based on the data collected in 2015, the intent is to download and evaluate the

continuous monitoring data from the dataloggers on an approximately quarterly basis in 2016 (spring,

summer, fall, and winter) and to manually verify the accuracy of the dataloggers and collect manual

groundwater levels from the supplemental monitoring points on a semiannual basis (spring and fall).

The frequency of the evaluation of the continuous water level monitoring data and the locations used for

continuous water level monitoring will be further evaluated near the end of 2016. Based on additional

observations of the correlation between pumping well set point elevations, monitoring point groundwater

elevations, and the Quinnipiac River elevation as recorded by the SCADA system, the monitoring network

for 2017 may be further refined, including changes from continuous to periodic manual monitoring at

additional monitoring locations. Proposed revisions to the scope and schedule of the 2017 monitoring will

be provided in the 2016 Annual Report.

6.1.2 Objective 2: Evaluation of Post-ESRC Unit 1 Groundwater Flow Directions Objective

Assess post-ESRC Unit 1 groundwater elevations, flow patterns, and vertical gradients.

Scope and Schedule

This objective will be achieved by the collection of periodic manual water level measurements at wells

screened in Unit 1. The perimeter and interior Unit 1 wells to be included during the manual water level

monitoring program in 2016 are shown on Figure 10 and listed on Table 6. To fulfill the objective to

evaluate and assess groundwater flow directions, manual water level measurements will be collected

approximately semiannually. These synoptic water level monitoring events are anticipated in spring and

fall 2016. Manual measurements will target low-mid tide only. High tide measurements were discontinued


February 2016 41 033-6231-002

in 2015 since the average tidal fluctuation in wells along the eastern perimeter (MP-21S, GD-6SR,

DM-9SR, OH-13, OH-14, etc.) has been greatly muted by installation of the HBW.

The schedule for the 2016 monitoring events is consistent with the Post-CMI Groundwater Monitoring

Plan, which anticipated that after an initial period of quarterly monitoring (completed in 2015), the

verification of the interior water level elevations would be performed semiannually for the first two years

following ESRC construction completion. Any proposed revisions to the scope and schedule for the 2017

monitoring will be provided in the 2016 Annual Report.

6.1.3 Objective 3: Monitor Unit 1 Groundwater Quality Outside HBW Objective

Monitor Unit 1 groundwater quality outside the HBW to allow the future assessment of attenuation of

residual Unit 1 groundwater impacts outside the HBW.

Scope and Schedule

This objective will be achieved by the collection of groundwater samples for VOC and SVOC analysis

from 10 Unit 1 monitoring wells located outside the HBW (GW-NFPA07, GW-HBW03, GW-HBW11,

GD-5S, DM-5S, DM-7S, GW-HBW12, GW-HBW06, GW-HBW13 and GW-HBW07). These samples will

be collected during the consolidated Annual Groundwater Monitoring event in fall 2016. The wells to be

sampled are listed in Table 6 and shown on Figure 10.

The datalogger studies performed during 2015, and discussed in Appendix D-3, confirmed the

relationship between the tidal cycle and the water level and temperature in the well, as well as the

timeframes for collecting representative Unit 1 groundwater samples outside the HBW. As discussed in

the Post-CMI Groundwater Monitoring Plan, during the summer and fall months, when the air and river

temperatures are higher than the groundwater temperature, the incoming tide raises the groundwater

temperature. During this time period, the groundwater is least affected by the river water when the

temperature is at its lowest. This occurs between two and six hours following low tide. During the 2016

sampling, it is anticipated that wells DM-5S, DM-7S, GD-5S, GW-HBW03, GW-HBW06, GW-HBW07,

GW-HBW11, GW-HBW12, and GW-HBW13, which show tidal influence, will be sampled between

approximately two and six hours following low tide. Wells GW-HBW12 and GW-HBW13, which show little

temperature variation with tidal changes will be sampled during the four hour period following low tide.

The schedule for the 2016 monitoring is consistent with the Post-CMI Groundwater Monitoring Plan,

which anticipated that after an initial baseline was established by collecting samples quarterly for a period

of six months following completion of the ESRC (completed in 2015) that groundwater samples would be

collected annually for the first two years following ESRC construction completion at a time that generally


February 2016 42 033-6231-002

coincided with the low river stage. Low river stage typically occurs between mid-September and early

October. Therefore, the annual monitoring event in 2016 will target this low river stage timeframe. In

addition, to the extent practical, the groundwater sampling events will be scheduled to avoid periods of

abnormally high river discharge (e.g., due to significant storm events). Any proposed revisions to the

scope and schedule for the 2017 monitoring will be provided in the 2016 Annual Report.

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

Objective

Monitor post-ESRC groundwater elevations, flow patterns, and vertical gradients within Units 3 and 4 and

the area of deep unconfined groundwater in the northern part of the Site.

Scope and Schedule

This objective will be achieved by collecting manual water level measurements semiannually at wells

screened in Units 3 and 4 and at wells screened within the deep unconfined groundwater in the northern

part of the Site. The perimeter and interior Unit 3 and 4 wells to be included during the manual water level

monitoring program in 2016 are shown on Figure 11 and listed on Table 7. These synoptic water level

monitoring events are anticipated in spring and fall 2016. This groundwater elevation data will also be

used to assess the effectiveness of TPW-1N at hydraulically controlling the impacts seen at SEC-7D and

GW-HBW17.

The schedule for the 2016 groundwater level monitoring events is consistent with the Post-CMI

Groundwater Monitoring Plan, which anticipated that, after an initial period of quarterly monitoring

(completed in 2015), verification of the interior water level elevations would be performed semiannually

for the first two years following ESRC construction completion. Any proposed revisions to the scope and

schedule for the 2017 monitoring will be provided in the 2016 Annual Report.

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

Objective

Demonstrate compliance with the Unit 3 Performance Standards established in the Order at wells along

the downgradient property boundary.

Scope and Schedule

This objective will be achieved by the collection of Unit 3 groundwater samples for VOC and SVOC

analysis from seven Unit 3 monitoring locations (DM-5D, DM-7D, DM-9D, MP-20DR, MW-35D, GD-3D,


February 2016 43 033-6231-002

and GD-4D) during the annual monitoring event in fall 2016. The Unit 3 wells that will be sampled are

listed in Table 7 and shown on Figure 11. The data from several of these wells will also be used to

evaluate conditions in the vicinity of Unit 3 well SEC-7D.

The schedule for the 2016 monitoring events is consistent with the Post-CMI Groundwater Monitoring

Plan, which continued the annual CMI monitoring schedule for perimeter Unit 3 groundwater. Any

proposed revisions to the scope and schedule for the 2017 monitoring will be provided in the 2016 Annual

Report.

Pharmacia & Upjohn will continue to communicate with CTDEEP about the applicable Performance

Standards as the RSR revision process continues. Changes to the comparative criteria will be discussed

in the 2016 Annual Report.

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

Continued monitoring of groundwater chemistry in the vicinity of Unit 3 well SEC-7D.

Scope and Schedule

The SEC-7D PDI/PDP proposed collecting samples from a refined group of Unit 3 and other select wells

in the vicinity of SEC-7D semiannually in spring and fall of each year during 2015 and 2016. The data

collected during 2015 does not suggest a benefit to changing this monitoring program. Continuing this

monitoring through 2016 will allow time for completion of full scale ISTR and additional time for operation

of the post-ESRC Unit 1 hydraulic control system. Accordingly, groundwater samples will be collected for

VOC and SVOC analysis from five Unit 3 wells (GD-3D, GD-4D, SEC-7D, GW-U311 and GW-U305) and

two deep unconfined wells (GW-HBW17 and GW-U309) in the spring of 2016 and from four shallow Unit

1 wells (GW-HBW16, GW-HBW19, GW-U103, and TPW-1N), three deep unconfined wells (GW-HBW17,

GW-U303, and GW-U309), and five Unit 3 wells (GD-2D, GW-U310, SEC-7D, GW-U305, and GW-U311)

in fall 2016. The data collected during the annual monitoring event from Unit 1 well GW-NFPA07 and Unit

3 wells GD-3D, and GD-4D as part of the post-ESRC monitoring, and from Unit 3 well GW-U312 as part

of the full-scale ISTR monitoring, will also be evaluated as part of the SEC-7D Area data set. The Unit 3

wells that will be sampled are listed in Table 7 and shown on Figure 11.


February 2016 44 033-6231-002

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

ISTR Objective

Continued monitoring of Unit 3 groundwater conditions downgradient of Subareas A and B, to monitor

changes, if any, to groundwater quality and groundwater elevations during and immediately after the

full-scale ISTR operations.

Scope and Schedule

The monitoring schedule approved in the Unit 3 ISTR Groundwater Monitoring Plan specifies that

samples would be collected approximately every 60 days during operation of the full-scale ISTR system

and that the last round of ISTR monitoring samples would be collected from wells GW-U305, GW-U311,

GW-U312, GW-U313 in February 2016. However, as discussed in Appendix G-1, based on the lack of

observed impacts attributable to full-scale ISTR to date, and the understanding of the slower movement

of groundwater in Unit 3, there would be little benefit to two rounds of sampling at wells GW-U305 and

GW-U311 during the spring of 2016 (e.g. sampling both in February and April of 2016). The September 9,

2015 communication with USEPA and CTDEEP indicated that, based on the variations in the updated

travel time estimates, Pharmacia & Upjohn intends to move away from using groundwater travel time as

the primary determinant of when to collect groundwater quality samples in Unit 3 and to align the ISTR

monitoring sampling to the overall Site groundwater monitoring program. Due to the overlap between the

ISTR and SEC-7D area monitoring programs, there would be benefit to conducting a combined

groundwater monitoring event in the spring of 2016.

Accordingly, Pharmacia & Upjohn intends to collect groundwater samples from wells GW-U305,

GW-U311, GW-U312, and GW-U313 for VOC, SVOC, and PCB analysis at the same time as the spring

SEC-7D area monitoring event. Wells GW-U312 and GW-U313 will also be sampled in fall 2016, at the

same time as the wells specified for SEC-7D area monitoring, to provide a more complete Unit 3

groundwater data set as part of a comprehensive Unit 3 monitoring event. The Unit 3 wells that will be

sampled are listed in Table 7 and shown on Figure 11. The need for continued sampling of Unit 3 wells

GW-U305, GW-U311, GW-U312, and GW-U313 in 2017 will be reviewed at the end of 2016 and

discussed in the 2016 Annual Report.

6.1.8 Objective 8: Post-ESRC Unit 3 Synoptic Monitoring Objective

Collect additional Unit 3 groundwater data to assess changes in groundwater quality since the pre-ESRC

baseline monitoring in 2011.


February 2016 45 033-6231-002

Scope and Schedule

The last synoptic groundwater monitoring of the deeper water bearing units was conducted in December

2011, immediately prior to the start of CMI. The ESRC construction and ISTR treatment of DNAPL

Subareas A, B and C, which comprise the bulk of the CMI activities, will be complete by the fall of 2016.

Based on the refined understanding of groundwater impacts in Units 3 and 4, Pharmacia & Upjohn will

collect an expanded Site-wide round of Unit 3 groundwater samples in the fall of 2016. This will provide

data to compare to the 2011 pre-ESRC baseline monitoring, and to develop the long-term post-CMI

monitoring program that would potentially be included in a future Stewardship Permit Application. As part

of this expanded Unit 3 monitoring program, samples will be collected for VOCs and SVOCs in the fall of

2016 from wells GD-5D, GD-6D, GW-U306, GW-U308, MP-28DR, SEC-1D, and SEC-2D, which when

combined with the Unit 3 groundwater data collected in support of Objectives 6 and 7 will provide a

comprehensive Unit 3 data set. All Unit 3 wells shown on Figure 11 will be sampled and the data

considered as part of fulfilling Objective 8.

Following the completion of the 2016 monitoring, Pharmacia & Upjohn will be evaluating the longer-term

monitoring scope for the deeper water-bearing units. It is anticipated that the data collected under

Objectives 4, 6, 7, 8 and 9 will be used to develop the scope of longer-term monitoring activities. This

longer-term monitoring scope may be provided to USEPA and CTDEEP for discussion separately from

the discussion of the 2017 monitoring to be included in the 2016 Annual Report.

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

Collect Unit 4 groundwater data to assess changes since the pre-ESRC baseline monitoring in 2011 and

to monitor groundwater in the vicinity of well GW-U402B

Scope and Schedule

As discussed in Appendix G-2, while recent Unit 4 data is available from selected Unit 4 wells in the

northern portion of the Site, a full Unit 4 synoptic sampling event was last conducted in 2011 as part of

the CMI baseline monitoring event. By the fall of 2016, the ESRC construction and the ISTR treatment of

DNAPL Subareas A, B and C, which comprise the bulk of the CMI activities, will be complete. Based on

the refined understanding of groundwater impacts in Units 3 and 4 and the installation of two new Unit 4

wells, GW-U402B and GW-U405, Pharmacia & Upjohn will voluntarily collect an expanded Site-wide

round of Unit 3 and 4 samples in the fall of 2016. This will provide baseline data to develop the long-term

post-CMI monitoring program that would potentially be included in a future Stewardship Permit

Application.


February 2016 46 033-6231-002

As part of this expanded Unit 4 monitoring program, groundwater samples will be collected for VOC and

SVOC analysis in the fall of 2016 from wells GD-1BR, GD-2BR, GD-4BR, GD-5BR, GD-6BR, GD-9BR,

GW-U402B, GW-U403, GW-U404, and GW-U405. The wells that will be sampled are listed on Table 7

and all Unit 4 wells shown on Figure 11 will be sampled. Due to the limited groundwater flow in Unit 4,

collecting samples in Unit 4 earlier in 2016 would not be beneficial, since insufficient time would have

elapsed to allow for meaningful changes in groundwater quality.

Following the completion of the 2016 monitoring, Pharmacia & Upjohn will be evaluating the longer-term

monitoring scope for the deeper water-bearing units. It is anticipated that the data collected under

Objectives 4, 6, 7, 8 and 9 will be used to develop the scope of longer-term monitoring activities. This

longer-term monitoring scope may be provided to USEPA and CTDEEP for discussion separately from

the discussion of the 2017 monitoring to be included in the 2016 Annual Report.

6.1.10 Objective 10: Monitor Well GW-LP01 Objective

Unit 1 Monitoring well GW-LP01 will be monitored for the presence of recoverable LNAPL.

Scope and Schedule

Per Connecticut regulation RCSA 22a-449(d)-106(f), LNAPL must be removed to the extent recoverable.

Pharmacia & Upjohn intends to continue gauging the LNAPL thickness in GW-LP01 on an approximately

quarterly basis throughout 2016, as the Site re-equilibrates after the cessation of ISTR pumping, to

confirm that LNAPL is not re-accumulating in the well and has been removed to the extent recoverable.

6.2 Proposed Modifications To The Annual OM&M Activities Woodard & Curran will continue to operate the GWTF in accordance with the Site NPDES Permit and will

continue the NPDES permit renewal process with CTDEEP. Woodard & Curran will continue to operate,

monitor and maintain the post-ESRC GWES, inspect the ESRC cover systems, inspect the interim west

side covers, and monitor existing institutional controls at the Site. Golder Associates will continue to

monitor water levels, assess the performance of the Unit 1 hydraulic controls, and collect the groundwater

quality monitoring samples. No changes to routine OM&M activities, such as redevelopment and

maintenance of extraction wells (as needed) and inspection of the fences and signs at the Site are

anticipated. While daily operating parameters may be adjusted to accommodate the CMI wastewater

streams, including those generated by ISTR operation and decommissioning, these changes will be

implemented in accordance with the NPDES permit and CTDEEP approvals.


February 2016 47 033-6231-002

6.2.1 Master Plan Schedule As shown on Figure 3 and discussed in Section 1.5, Pharmacia & Upjohn has met all of the Major

Milestones or Progress Goals included on the Master Plan Schedule for 2015, including:

Submit Full-Scale ISTR Draft Final Design

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

The CMI Team achieved the June 5, 2015 Major Milestone associated with “Submit Draft Final Design for

Remaining ESRCs (including EC Variance Application Part 2)” in 2013.

The Master Plan Schedule includes one Progress Goal in 2016, namely the revised Progress Goal date

of November 16, 2016 related to “Submit Draft Final Design of the West Side Remedial Components

(WSRC).” Pharmacia & Upjohn will communicate progress towards this Progress Goal and the

associated process toward assessing future development needs in the Town of North Haven through

discussions with potential developers and Town officials, and the selection of a West Side redevelopment

concept that will be compatible with WSRC remedial action objectives with USEPA and CTDEEP during

the progress teleconferences and other communication channels.

To date, the CMI Team has not encountered any delays or technical difficulties that would negatively

impact the ability to meet the Master Plan Schedule. The CMI Team, on behalf of Pharmacia & Upjohn, is

striving to accelerate the design and construction schedule to efficiently implement the Corrective

Measures. In particular, Pharmacia & Upjohn anticipates achieving the Major Milestones “Submit

Construction Completion Report for East Side Areas” and “Submit DNAPL Component Completion

Report” during 2016 through the submission of the ESRC Construction Completion Report and the Full-

Scale ISTR Construction Completion Report to USEPA and CTDEEP for review.

Section IV of the quarterly progress reports describes and provides more detail on specific CMI activities

planned for 2016, including details of Corrective Measure implementation that lead to the Order Major

Milestones and Progress Goals highlighted above. USEPA and CTDEEP will be kept informed of any

schedule changes through the quarterly progress reports and routinely scheduled teleconferences.

USEPA and CTDEEP will also continue to be consulted, regarding technical and regulatory matters (e.g.

to solicit input on the ISTR implementation and WSRC design), as necessary during 2016.


February 2016 48 033-6231-002

7.0 REFERENCES

CTDEEP, 2003. Connecticut’s Remediation Standard Regulations Volatilization Criteria, Proposed Revisions. March 2003.

CTDEEP, 2007. Draft Proposed Revisions to the Remediation Standard Regulations, October 2007.

CTDEEP, 2008. Letter from Patrick F. Bowe (CTDEEP) to Russ Downey (Pharmacia & Upjohn) “Request for Criteria for Additional Polluting Substances” dated December 22, 2008.

CTDEEP, 2010. NPDES Permit Issued to Pharmacia & Upjohn Company LLC (Permit ID CT0001341), January 2010.

CTDEEP, 2011, Ms. Kim Hudak, “Approval of Facility Modification Treatment System Modification Approval”. Letter to Mr. Russell Downey, June 11, 2011.

CTDEEP, 2012a. Letter from Patrick F. Bowe (CTDEEP) to Tim Carr (GeoDesign) “Request for Criteria for Additional Polluting Substances” dated March 23, 2012.

CTDEEP, 2012b. June 2012, Substitute House Bill No. 5343 Public Act No. 12-196: An Act Concerning Economic Development Through Streamlined And Improved Brownfield Remediation Programs, Exempting Certain Airport Conveyances From The Department Of Transportation To The Connecticut Airport Authority From The Hazardous Waste Establishment Transfer Act, And Holding Harmless And Indemnifying The Connecticut Airport Authority And Its Employees And Directors.

CTDEEP 2013b, Remediation Standard, RCSA 22a-133k-1 through 22a-133k-1, July 2013.

CTDEEP, 2015. Request for Fast-track Approval of Criteria for Additional Polluting Substances and Certain Alternative Criteria. December 10, 2015.

Gammie Air Monitoring LLC and Golder Associates Inc., 2015. Air Emissions Test Protocol for the Full-Scale ISTR System, Pharmacia & Upjohn Company LLC Site, North Haven, Connecticut, July 2015.

Golder Associates Inc., 2006. Final Investigation Report, Pharmacia & Upjohn Company LLC Site, North Haven, Connecticut, August 2006.

Golder Associates Inc. (Golder), 2007. Proposed RSR Criteria for Additional Polluting Substances (Revision 1), June 2007.

Golder Associates Inc., 2010. Final Revised Corrective Measures Study, Pharmacia & Upjohn Company LLC Site and Lake A LLC Site, North Haven, Connecticut, Golder Associates Inc., June 2010.

Golder Associates, 2012a. 2011 Annual Progress Report, Pharmacia & Upjohn Company LLC Site, North Haven, Connecticut, February 2012.

Golder Associates, 2012b. Corrective Measures Implementation Work Plan, Pharmacia & Upjohn Company LLC Site, North Haven, Connecticut, February 2012.

Golder Associates, 2013. 2012 Annual Progress Report, Pharmacia & Upjohn Company LLC Site, North Haven, Connecticut, January 2013.


February 2016 49 033-6231-002

Golder Associates, 2013b. Groundwater Extraction System Hydrogeologic Draft Final Design (Appendix

H of the Draft Final East Side Remedial Components Design Report) Pharmacia & Upjohn Company LLC Site, North Haven, Connecticut, May 2013.

Golder Associates, 2014a. 2013 Annual Progress Report, Pharmacia & Upjohn Company LLC Site, North Haven, Connecticut, January 2014.

Golder Associates, 2014b. SEC-7D Pre-Design Investigation Report and Preliminary Design Proposal, Pharmacia & Upjohn Company LLC Site, North Haven, Connecticut, revised February 2014.

Golder Associates, 2014c. Groundwater Extraction System Hydrogeologic Final Design (Appendix H of the East Side Remedial Components Design Report) Pharmacia & Upjohn Company LLC Site, North Haven, Connecticut, July 2014.

Golder Associates, 2014d. Post-CMI Groundwater Monitoring Plan (Attachment A to Appendix D of the East Side Remedial Components Design Report) Pharmacia & Upjohn Company LLC Site, North Haven, Connecticut, July 2014.

Golder Associates, 2015a. 2014 Annual Progress Report, Pharmacia & Upjohn Company LLC Site, North Haven, Connecticut, January 2015. .

TerraTherm and Golder Associates, 2013. Draft In-Situ Thermal Remediation Pilot Study Final Report and Full-Scale Preliminary Design Proposal, Pharmacia and Upjohn Company LLC, North Haven, Connecticut, August 2013.

TerraTherm and Golder Associates, 2014. Full Scale In Situ Thermal Remediation Draft Final Design Report, Pharmacia and Upjohn Company LLC, North Haven, Connecticut, December 2014.

TerraTherm and Golder Associates, 2015. Full Scale In Situ Thermal Remediation Final Design Report, Pharmacia and Upjohn Company LLC, North Haven, Connecticut, July 2015.

USEPA, 2010a. Statement of Basis for Pharmacia & Upjohn Company LLC Site, North Haven, Connecticut, June 2010.

USEPA, 2010b. Final Decision and Response to Comments for Pharmacia & Upjohn Company LLC Site, North Haven, Connecticut, September 2010.

USEPA, 2011. Administrative Order on Consent in the Matter of the Pharmacia & Upjohn Company LLC, 41 Stiles Lane, North Haven, CT, (USEPA Docket Number RCRA-01-2011-0027), March 2011.

WRS and Brown and Caldwell, 2013a. Final Draft Corrective Measures Design Report East Side Remedial Components, Pharmacia & Upjohn Company LLC Site, North Haven, Connecticut, March 2013.

WRS, Brown and Caldwell, and Golder, 2013b. Engineered Control Fact Sheets for the Remaining ESRC, Pharmacia & Upjohn Company LLC Site, North Haven, Connecticut, October 2013. Revised March 2014.

WRS, Brown and Caldwell, and Golder, 2014. Corrective Measures Design Report East Side Remedial Components, Pharmacia & Upjohn Company LLC Site, North Haven, Connecticut. August 2014.


TABLES

February 2016 033-6231-002

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Well No.

Top of Casing Elevation (NGVD)

Top of Screen Elevation (NGVD)

Screen Length (ft)

Total Well Depth (ft bgs) Reason for Monitoring

PW-1R 17.05 -4.5 8.5 20.2 Replacement extraction well located north of North PilePW-2RA 12.89 0.5 10.0 22.4 Replacement extraction well located northwest of North PilePW-4R 17.59 -10 6.0 29.0 Replacement extraction well located southeast of North PilePW-5R 18.72 -1 10.0 26.0 Replacement extraction well located northeast of North PilePW-9 17.23 -8.9 5.0 29.8 Extraction well located between the North and South PilesPW-10 23.44 -8.2 5.0 35.5 Extraction well located at northeast corner of South PilePW-16A 24.65 -8.82 5.0 38.5 Extraction well located on the eastern side of the South Pile

S1N 19.67 NA NA NM Northern Groundwater Collection Trench Sump located northeast of the Former Building 22S2N 14.42 NA NA NM Northern Groundwater Collection Trench Sump located northeast of the Former Building 22S1S 14.05 NA NA 7.07 Southern Groundwater Collection Trench Sump located southwest of the Former Relic Firewater PondS2S 12.41 NA NA 16.9 Southern Groundwater Collection Trench Sump located southeast of the Former Relic Firewater Pond

TPW-1N 14.80 -4.0 10 27 Unit 1 temporary groundwater extraction well located south of the headwaters of North Creek (outside HBW)

DM-7S 10.95 -5.7 5.0 22.6 Transition GWES continous water level monitoring well; located east of Former Enclosed Aeration Lagoon (outside HBW)DM-9SR 25.7 -2.4 5.0 31.7 Transition GWES continous water level monitoring well; located on the north-eastern edge of South Pile (inside HBW)GD-6SR 14.96 6.0 5.0 12.1 Transition GWES continous water level monitoring well; located southeast of Former Aeration Lagoon (inside HBW)GW-HBW01 14.54 -4.0 5.0 20.0 Located in the northwestern area of the North Inland Wetland (outside HBW)GW-HBW02 12.83 -8.0 5.0 22.7 Located in the northwestern area of the North Inland Wetland (inside HBW)GW-HBW03 8.82 -4.0 5.0 15.0 Located in the northeastern area of the North Inland Wetland (outside HBW)GW-HBW04A 11.34 -1.8 6.0 16.9 Transition GWES continous water level monitoring well; located in the northeastern area of the North Inland Wetland (inside HBW)GW-HBW05 15.24 -8.0 5.0 26.3 Located east of Former Aeration Lagoon (inside HBW)GW-HBW06 9.91 -16.2 5.0 26.0 Located east of South Pile (outside HBW)GW-HBW07 8.66 -8.0 4.0 16.0 Located on south of South Pile (outside HBW)GW-HBW08 9.65 -0.9 10.0 18.0 Transition GWES continous water level monitoring well; located in the Southern Inland Wetland (inside HBW)GW-HBW09 9.01 -5.1 5.0 20.0 Transition GWES continous water level monitoring well; located in the Southern Inland Wetland (outside HBW)GW-HBW10 17.96 1.5 2.5 8.0 Located southwest of the Former Relic Firewater Pond (outside HBW)GW-HBW11 16.03 -3.47 5.0 24.5 Located northeast of North Pile (outside HBW)GW-HBW12 10.28 -8.8 5.0 18.0 Located northeast of South Pile (outside HBW)GW-HBW13 9.41 -10.2 4.0 18.0 Located southeast of South Pile (outside HBW)GW-HBW14A 10.50 -2.9 5.0 15.3 Transition GWES continous water level monitoring well; located in the eastern area of the North Inland Wetland (inside HBW)GW-HBW15 16.21 -7.5 5.0 19.2 Located northeast of North Pile (inside HBW)GW-HBW16 13.67 7.0 13.0 18.5 Monitoring well in the northern area of thinned/absent Unit 2; located east of former Building 22 (outside HBW)GW-HBW18 13.97 -6.23 5.0 25.2 Located south of the Former Relic Firewater Pond (outside HBW)GW-HBW19 13.01 6.51 5.0 11.5 Located north of Former Building 22 (outside HBW)GW-HBW20 16.53 -4.47 5.0 26.0 Replacement transition GWES continous water level monitoring well for MP-21S; located east of the North Pile (inside HBW)GW-U102 16.20 -2.54 10.0 25.5 Monitoring well located north of the South Inland Wetland (inside HBW)GW-U103 15.14 -2.36 8.0 25.5 Monitoring well in the northern area of thinned/absent Unit 2; located east of former Building 22 (inside HBW)GW-NFPA07 11.44 -6.1 10.0 28.0 Transition GWES continous water level monitoring well; located west the headwaters of North Creek (outside HBW)MW-35SR 23.22 -6.3 3.0 34.5 Transition GWES continous water level monitoring well; located on southern edge of South Pile (inside HBW)PW-111 24.51 -14.0 5.0 43.0 Former extraction well located east of South Pile; now a monitoring wellPW-14B1 25.15 -9.99 5.0 40.0 Former extraction well located east of South Pile; now a monitoring wellPW-20 24.51 -0.9 5.0 34.0 Transition GWES continous water level monitoring well; located on southern edge of South Pile (inside HBW)PW-61 16.41 -8.5 5.0 29.0 Former groundwater recovery well located southeast of the Former Polishing Lagoon; now a monitoring wellPW-211 17.55 0.6 5.0 22.0 Former groundwater recovery well located north of Former Relic Firewater Pond in center of black top area on the western portion of the

Site

Groundwater Extraction Wells - Unit 1

Shallow Groundwater Monitoring Wells - Unit 1

TABLE 1SUMMARY OF WELL COMPLETION INFORMATION

PHARMACIA & UPJOHN COMPANY LLC SITENORTH HAVEN, CONNECTICUT

Shallow Groundwater Collection Sumps - Unit 1

Temporary Groundwater Extraction Wells - Unit 1

February 2016 033-6231-002

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Well No.

Top of Casing Elevation (NGVD)

Top of Screen Elevation (NGVD)

Screen Length (ft)

Total Well Depth (ft bgs) Reason for Monitoring

TABLE 1SUMMARY OF WELL COMPLETION INFORMATION


SEC-1D 20.43 -17.3 5.0 39.8 Upgradient Unit 3 monitoring well; not monitored in 2015DM-5D 10.83 -33.9 7.0 49.4 Perimeter Unit 3 well DM-7D 11.35 -54.8 5.0 69.9 Perimeter Unit 3 well DM-9D 23.17 -64.8 5.0 92.3 Perimeter Unit 3 well GD-3D 14.28 -38.1 2.0 49.0 Perimeter Unit 3 well; Monitor downgradient of SEC-7D GD-4D 11.82 -74.3 5.0 89.0 Perimeter Unit 3; Monitor downgradient of SEC-7D GD-5D 9.02 -54.1 5.0 67.0 Perimeter Unit 3 well; not monitored in 2015GD-6D 14.99 -70.2 5.0 87.1 Perimeter Unit 3 well; not monitored in 2015GD-8D 14.26 -28.4 2.0 42.0 Interior Unit 3 well; not monitored in 2015GW-HBW17 14.14 -12.5 13.0 37.5 Interior monitoring well in the northern area of thinned/absent Unit 2; located east of former Building 22 (outside HBW)

GW-U303 11.52 -14.48 7.0 33.0Perimeter deep monitoring well – located in the Unconfined Materials within the Area of Thinned/Absent Unit 2; located northeast of former Building 22

GW-U305 14.87 -61.3 5.0 77.8 Interior Unit 3 well; monitor side gradient of SEC-7D AreaGW-U306 17.62 -46.3 1.0 63.3 Interior Unit 3 well; not monitored in 2015GW-U308 13.98 -40.0 5.0 59.0 Interior Unit 3 well; not monitored in 2015

GW-U309 14.13 -19.9 5.0 39.0Perimeter deep monitoring well – located in the Unconfined Materials within the Area of Thinned/Absent Unit 2; located east of former Building 22

GW-U310 15.06 -38.1 5.0 58.0 Interior Unit 3 well; monitor upgradient of SEC-7D Area and Northern area of thinned Unit 2; located east of former Building 22GW-U311 13.07 -32.9 5.0 51.0 Interior Unit 3 well; monitor upgradient of SEC-7D Area and Northern area of thinned Unit 2GW-U312 12.36 -39.5 5.0 57.0 Interior Unit 3 well; monitor downgradient of ISTR subarea A and upgradient of SEC-7DGW-U313 15.32 -30.0 5.0 51.0 Interior Unit 3 well; monitor downgradient of ISTR subarea BMP-20DR 11.77 -102.8 5.0 120.6 Perimeter Unit 3 well MP-28DR 17.62 -96.8 10.0 124.4 Interior Unit 3 well; located on the south slope of the North Pile MW-35D 25.13 -64.7 5.0 93.0 Perimeter Unit 3 well ; located on the south side of the South PileSEC-2D 16.95 -59.4 5.0 95.0 Upgradient Unit 3 monitoring well; not monitored in 2015SEC-7D 14.79 -24.6 5.0 87.0 Interior Unit 3 well; Monitoring Local Impacts in Unit 3

GD-1BR* 19.25 -30.5 8.0 55.0 Upgradient Unit 4 groundwater monitoringGD-4BR* 11.18 -83.7 10.2 102.4 Unit 4 groundwater monitoringGD-5BR* 8.32 -59.0 15.2 80.2 Unit 4 groundwater monitoringGD-6BR* 14.87 -82.0 10.0 104.6 Unit 4 groundwater monitoringGD-9BR* 16.76 -90.4 9.2 113.8 Unit 4 groundwater monitoringGW-U402A* 15.46 -71.5 10.0 94.0 Unit 4 groundwater monitoring, abandoned in 2015GW-U402B* 19.24 -74.8 19.0 109.0 Unit 4 groundwater monitoringGW-U403* 13.48 -44.4 25.0 80.0 Unit 4 groundwater monitoringGW-U404* 17.37 -80.6 15.0 110.1 Unit 4 groundwater monitoringGW-U405* 16 -16.5 12.5 45.0 Unit 4 groundwater monitoring

NOTES:1 PW-21, PW-6, PW-11, and PW-14B are former groundwater extraction wells used for groundwater elevation monitoring.NGVD = National Geodetic Vertical Datum (1929) HBW - hydraulic barrier wallNS = Well Survey not completed. CMI - corrective measures implementationNM = Not measured. ISTR - in-situ thermal remediationNA = No data available. * - In Unit 4 wells, screen interval is open borehole.

Prepared by: RMW 1/7/2016Checked by: JTS 1/11/2016

Deep Groundwater Monitoring Wells - Unit 4

Deep Groundwater Monitoring Wells - Unit 3 and Deep Unconfined Wells

February 2016 033-6231-002

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Field Identification Matrix QC SamplesCollection

Date VOC

s

SVO

Cs

TSS

Unit 1DM-5S Ground Water -- 7/22/2015 X XDM-5S Ground Water -- 10/23/2015 X XDM-7S Ground Water -- 7/22/2015 X XDM-7S Ground Water -- 10/20/2015 X XGD-5S Ground Water -- 7/23/2015 X XGD-5S Ground Water -- 10/20/2015 X XGW-HBW11 Ground Water -- 10/22/2015 X XGW-HBW03 Ground Water -- 7/24/2015 X XGW-HBW03 Ground Water -- 10/20/2015 X XGW-HBW06 Ground Water -- 7/24/2015 X XGW-HBW06 Ground Water -- 10/20/2015 X XGW-HBW07 Ground Water -- 7/23/2015 X XGW-HBW07 Ground Water -- 10/19/2015 X XGW-HBW11 Ground Water -- 7/22/2015 X XGW-HBW12 Ground Water -- 7/22/2015 X XGW-HBW12 Ground Water -- 10/19/2015 X XGW-HBW13 Ground Water -- 7/23/2015 X XGW-HBW13 Ground Water -- 10/21/2015 X XGW-NFPA07 Ground Water MS/MSD 7/23/2015 X XGW-NFPA07 Ground Water -- 10/21/2015 X XUnit 3DM-5D Ground Water -- 10/19/2015 X XDM-7D Ground Water -- 10/19/2015 X XDM-9D Ground Water MS/MSD (VOCs only) 10/22/2015 X XGD-3D Ground Water 10/19/2015 X XGD-4D Ground Water 10/22/2015 X X XMP-20DR Ground Water -- 10/21/2015 X XMW-35D Ground Water -- 10/19/2015 X XQuality Control Samples TBGW_072215 Water TB 7/22/2015 XFDGW_072215 Ground Water FD (GW-HBW11) 7/22/2015 X XTBGW_072315 Water TB 7/23/2015 XRBGW_072315 Water RB 7/23/2015 X XTBGW_072415 Water TB 7/24/2015 XTBGW_101915 Water TB 10/19/2015 XTBGW_102015 Water TB 10/20/2015 XRBGW_102015 Water RB 10/20/2015 X XTBGW_102115 Water TB 10/21/2015 XTBGW_102215 Water TB 10/22/2015 XTBGW_102315 Water TB 10/23/2015 X

Notes:All samples were analyzed by Alpha Analytical.FD - Field DuplicateMS/MSD - Matrix Spike/Matrix Spike DuplicateQC - Quality ControlRB - Rinsate BlankSVOCs - Semivolatile Organic CompoundsTB - Trip BlankTSS - Total Suspended SolidsVOCs - Volatile Organic Compounds

TABLE 2POST-ESRC SAMPLE COLLECTION AND ANALYSIS SUMMARY


Analysis/Parameters

February 2016 TABLE 3COMPARATIVE CRITERIA FOR THE 2015 ANNUAL REPORT

PHARMACIA UPJOHN COMPANY LLC SITENORTH HAVEN, CONNECTICUT

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Parameter CAS Units SWPC MPS CT RSR APPD SITE SWPC APSCT 2015 SWPC

APSVolatile Organic CompoundsAcetone 67-64-1 ug/L 10,000 - - 10,000Benzene 71-43-2 ug/L 231 710 - -Bromodichloromethane 75-27-4 ug/L 516 - - 510Bromomethane 74-83-9 ug/L - - - 1602-Butanone (MEK) 78-93-3 ug/L 10,000 - - 10,000tert-Butyl Alcohol 75-65-0 ug/L 10,000 - 10,000 -n-Butylbenzene 104-51-8 ug/L 10 - - 10,000sec-Butylbenzene 135-98-8 ug/L - - - 10,000Carbon disulfide 75-15-0 ug/L - - - 150Carbon tetrachloride 56-23-5 ug/L - 132 - -Chlorobenzene 108-90-7 ug/L 640 420,000 - -Chloroethane 75-00-3 ug/L 10,000 - 10,000 -Chloroform 67-66-3 ug/L 280 14,100 - -1,1-Dichloroethane 75-34-3 ug/L 470 - 10,000 -1,2-Dichloroethane 107-06-2 ug/L 1,099 2,970 - -1,1-Dichloroethene 75-35-4 ug/L 250 96 - -cis-1,2-Dichloroethene 156-59-2 ug/L 5,900 - 10,000 -trans-1,2-Dichloroethene 156-60-5 ug/L 5,900 - 10,000 -1,2-Dichloropropane 78-87-5 ug/L 813 - - 150cis-1,3-Dichloropropene 10061-01-5 ug/L - 34,000 - -trans-1,3-Dichloropropene 10061-02-6 ug/L - 34,000 - -Ethylbenzene 100-41-4 ug/L 73 580,000 - -Isopropanol 67-63-0 ug/L 10,000 - 10,000 -Isopropylbenzene 98-82-8 ug/L 210 - - 210p-Isopropyltoluene (Cymene) 99-87-6 ug/L 165 - - 200Methyl t-butyl ether (MTBE) 1634-04-4 ug/L 10,000 - 10,000 -4-Methyl-2-pentanone (MIBK) 108-10-1 ug/L 10,000 - - -Methylene Chloride 75-09-2 ug/L 9,524 48,000 - -n-Propylbenzene 103-65-1 ug/L - - - 10,000Styrene 100-42-5 ug/L 240 - - 3201,1,2,2-Tetrachloroethane 79-34-5 ug/L 120 110 - -Tetrachloroethene 127-18-4 ug/L 187 88 - -Toluene 108-88-3 ug/L 98 4,000,000 - -1,1,1-Trichloroethane 71-55-6 ug/L 110 62,000 - -1,1,2-Trichloroethane 79-00-5 ug/L - 1,260 - -Trichloroethene 79-01-6 ug/L 127 2,340 - -Trichlorofluoromethane 75-69-4 ug/L 10,000 - - 10,0001,2,4-Trimethylbenzene 95-63-6 ug/L 160 - - 1501,3,5-Trimethylbenzene 108-67-8 ug/L 260 - - 260Vinyl chloride 75-01-4 ug/L 142 15,750 - -Xylenes, total 1330-20-7 ug/L 130 - 1,431 -Semivolatile Organic CompoundsAcenaphthene 83-32-9 ug/L - - - 150Acenaphthylene 208-96-8 ug/L 6,667 0.3 - -Aniline 62-53-3 ug/L 13 - 68.9 -Anthracene 120-12-7 ug/L 7 1,100,000 - -Azobenzene 103-33-3 ug/L 345 - 345 -Benzidine 92-87-5 ug/L 1 - 26.5 -Benzo(a)anthracene 56-55-3 ug/L 0.27 0.3 - -Benzo(ghi)perylene 191-24-2 ug/L - - - 150Benzo(k)fluoranthene 207-08-9 ug/L 10 0.3 - -Benzo(a)pyrene 50-32-8 ug/L 0.14 0.3 - -Benzo(b)fluoranthene 205-99-2 ug/L 3.3 0.3 - -Benzoic acid 65-85-0 ug/L - - - 9,000Bis(2-chloroethyl)ether 111-44-4 ug/L 7 42 - -Bis(2-ethylhexyl)Phthalate 117-81-7 ug/L 30 59 - -Butylbenzyl phthalate 85-68-7 ug/L - - - 230Carbazole 86-74-8 ug/L 53 - 281 -2-Chloroaniline 95-51-2 ug/L 134 - 53 -



033-6231-002



Parameter CAS Units SWPC MPS CT RSR APPD SITE SWPC APSCT 2015 SWPC

APS3-Chloroaniline 108-42-9 ug/L 52 - 53 -4-Chloroaniline 106-47-8 ug/L 10 - 53 -1-Chloro-2-nitrobenzene 88-73-3 ug/L - - - -2-Chlorophenol 95-57-8 ug/L 124 - 1,696 -Chrysene 218-01-9 ug/L - - - 0.54Dibenzo(ah)anthracene 53-70-3 ug/L - - - 0.3Dibenzofuran 132-64-9 ug/L - - - 401,2-Dichlorobenzene 95-50-1 ug/L 140 170,000 - -1,3-Dichlorobenzene 541-73-1 ug/L 180 26,000 - -1,4-Dichlorobenzene 106-46-7 ug/L 150 26,000 - -3,3'-Dichlorobenzidine 91-94-1 ug/L 0.85 - 12.19 -2,6-dichloro-4-nitroaniline (Dichloran) 99-30-9 ug/L - - 649 -2,4-Dichlorophenol 120-83-2 ug/L 82 15,800 - -Diethyl phthalate 84-66-2 ug/L - - - 2,200Dimethyl phthalate 131-11-3 ug/L - - - 10,0003,3'-Dimethylbenzidine 119-93-7 ug/L 20 - 58.83 -2,4-Dimethylphenol 105-67-9 ug/L - - - 1502,4-Dinitrophenol 51-28-5 ug/L - - - 7102,4-Dinitrotoluene 121-14-2 ug/L - - - 100Di-n-Butylphthalate 84-74-2 ug/L 40 120,000 - -Di-n-Octyl phthalate 117-84-0 ug/L - - - -1,4-Dioxane 123-91-1 ug/L 8,000 - 5,300 -Diphenamid 957-51-7 ug/L 23,169 - 10,000 -Fluoranthene 206-44-0 ug/L 62 3,700 - -Fluorene 86-73-7 ug/L 39 140,000 - -Indeno(1,2,3-cd)pyrene 193-39-5 ug/L - - - 0.54Isophorone 78-59-1 ug/L - - - 9,2001-Methylnaphthalene 90-12-0 ug/L - - 249.1 -2-Methylnaphthalene 91-57-6 ug/L - - - 622-Methylphenol (o-cresol) 95-48-7 ug/L - - - 6704-Methylphenol/3-Methylphenol 65794-96-9 ug/L 555 - 2,941.5Naphthalene 91-20-3 ug/L 120 - 1,113 -4-Nitroaniline 100-01-6 ug/L - - - 1,200Nitrobenzene 98-95-3 ug/L - - - 2,3004-Nitrophenol 100-02-7 ug/L - - - -N-Nitrosodiphenylamine 86-30-6 ug/L - - - 180Pentachlorophenol 87-86-5 ug/L - - - 30Phenanthrene 85-01-8 ug/L 63 - 121.9 -Phenol 108-95-2 ug/L 1,100 92,000,000 - -Pyrene 129-00-0 ug/L 10 110,000 243.8 -1,2,4,5-Tetrachlorobenzene 95-94-3 ug/L - - - 111,2,4-Trichlorobenzene 120-82-1 ug/L - - 265.0 -2,4,6-Trichlorophenol 88-06-2 ug/L - - - 49m-Toluidine 108-44-1 ug/L 98 - 98.05 -Polychlorinated BiphenylsTotal PCBs TPCBs ug/L 0.25 0.5 - -

Key to Criteria on last page



033-6231-002



Parameter CAS UnitsVolatile Organic CompoundsAcetone 67-64-1 ug/LBenzene 71-43-2 ug/LBromodichloromethane 75-27-4 ug/LBromomethane 74-83-9 ug/L2-Butanone (MEK) 78-93-3 ug/Ltert-Butyl Alcohol 75-65-0 ug/Ln-Butylbenzene 104-51-8 ug/Lsec-Butylbenzene 135-98-8 ug/LCarbon disulfide 75-15-0 ug/LCarbon tetrachloride 56-23-5 ug/LChlorobenzene 108-90-7 ug/LChloroethane 75-00-3 ug/LChloroform 67-66-3 ug/L1,1-Dichloroethane 75-34-3 ug/L1,2-Dichloroethane 107-06-2 ug/L1,1-Dichloroethene 75-35-4 ug/Lcis-1,2-Dichloroethene 156-59-2 ug/Ltrans-1,2-Dichloroethene 156-60-5 ug/L1,2-Dichloropropane 78-87-5 ug/Lcis-1,3-Dichloropropene 10061-01-5 ug/Ltrans-1,3-Dichloropropene 10061-02-6 ug/LEthylbenzene 100-41-4 ug/LIsopropanol 67-63-0 ug/LIsopropylbenzene 98-82-8 ug/Lp-Isopropyltoluene (Cymene) 99-87-6 ug/LMethyl t-butyl ether (MTBE) 1634-04-4 ug/L4-Methyl-2-pentanone (MIBK) 108-10-1 ug/LMethylene Chloride 75-09-2 ug/Ln-Propylbenzene 103-65-1 ug/LStyrene 100-42-5 ug/L1,1,2,2-Tetrachloroethane 79-34-5 ug/LTetrachloroethene 127-18-4 ug/LToluene 108-88-3 ug/L1,1,1-Trichloroethane 71-55-6 ug/L1,1,2-Trichloroethane 79-00-5 ug/LTrichloroethene 79-01-6 ug/LTrichlorofluoromethane 75-69-4 ug/L1,2,4-Trimethylbenzene 95-63-6 ug/L1,3,5-Trimethylbenzene 108-67-8 ug/LVinyl chloride 75-01-4 ug/LXylenes, total 1330-20-7 ug/LSemivolatile Organic CompoundsAcenaphthene 83-32-9 ug/LAcenaphthylene 208-96-8 ug/LAniline 62-53-3 ug/LAnthracene 120-12-7 ug/LAzobenzene 103-33-3 ug/LBenzidine 92-87-5 ug/LBenzo(a)anthracene 56-55-3 ug/LBenzo(ghi)perylene 191-24-2 ug/LBenzo(k)fluoranthene 207-08-9 ug/LBenzo(a)pyrene 50-32-8 ug/LBenzo(b)fluoranthene 205-99-2 ug/LBenzoic acid 65-85-0 ug/LBis(2-chloroethyl)ether 111-44-4 ug/LBis(2-ethylhexyl)Phthalate 117-81-7 ug/LButylbenzyl phthalate 85-68-7 ug/LCarbazole 86-74-8 ug/L2-Chloroaniline 95-51-2 ug/L

ICVC MPSCT 2003

REVGWVC IC SITE ICVC APS CT 2015 ICVC APS

50,000 50,000 - -308 310 - -73 - - 35- - - 1,100

50,000 50,000 - -50,000 - 50,000 -21,000 - - 21,80020,000 - - 20,100

- - - 5,200- 14 - -

26,736 23,000 - -17,118 - 11,828 -

60 62 - -9,470 - 9,452 -

65 68 - -1,467 920 - -11,494 - 11,472 -13,372 - 6,673 -

110 58 - -- 360 - -- 360 - -

21,916 36,000 - -- - - -

6,747 - - 2,2006,978 - - 2,10050,000 - 50,000 -50,000 50,000 - -1,045 2,200 - -

- - - 2,90012,270 42,000 - -

55 54 - -200 810 - -

41,584 41,000 - -20,439 16,000 - -

- 2,900 - -63 67 - -

4,263 - - 4,3001,518 - - 12,8001,193 - - 10,000

52 52 - -25,525 - 25,558 -

- - - 50,00050,000 - - -

- - - -50,000 - - -37,829 - 37,829 -

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

51 - - -- - - -- - - -- - - -- - - -



033-6231-002



Parameter CAS Units3-Chloroaniline 108-42-9 ug/L4-Chloroaniline 106-47-8 ug/L1-Chloro-2-nitrobenzene 88-73-3 ug/L2-Chlorophenol 95-57-8 ug/LChrysene 218-01-9 ug/LDibenzo(ah)anthracene 53-70-3 ug/LDibenzofuran 132-64-9 ug/L1,2-Dichlorobenzene 95-50-1 ug/L1,3-Dichlorobenzene 541-73-1 ug/L1,4-Dichlorobenzene 106-46-7 ug/L3,3'-Dichlorobenzidine 91-94-1 ug/L2,6-dichloro-4-nitroaniline (Dichloran) 99-30-9 ug/L2,4-Dichlorophenol 120-83-2 ug/LDiethyl phthalate 84-66-2 ug/LDimethyl phthalate 131-11-3 ug/L3,3'-Dimethylbenzidine 119-93-7 ug/L2,4-Dimethylphenol 105-67-9 ug/L2,4-Dinitrophenol 51-28-5 ug/L2,4-Dinitrotoluene 121-14-2 ug/LDi-n-Butylphthalate 84-74-2 ug/LDi-n-Octyl phthalate 117-84-0 ug/L1,4-Dioxane 123-91-1 ug/LDiphenamid 957-51-7 ug/LFluoranthene 206-44-0 ug/LFluorene 86-73-7 ug/LIndeno(1,2,3-cd)pyrene 193-39-5 ug/LIsophorone 78-59-1 ug/L1-Methylnaphthalene 90-12-0 ug/L2-Methylnaphthalene 91-57-6 ug/L2-Methylphenol (o-cresol) 95-48-7 ug/L4-Methylphenol/3-Methylphenol 65794-96-9 ug/LNaphthalene 91-20-3 ug/L4-Nitroaniline 100-01-6 ug/LNitrobenzene 98-95-3 ug/L4-Nitrophenol 100-02-7 ug/LN-Nitrosodiphenylamine 86-30-6 ug/LPentachlorophenol 87-86-5 ug/LPhenanthrene 85-01-8 ug/LPhenol 108-95-2 ug/LPyrene 129-00-0 ug/L1,2,4,5-Tetrachlorobenzene 95-94-3 ug/L1,2,4-Trichlorobenzene 120-82-1 ug/L2,4,6-Trichlorophenol 88-06-2 ug/Lm-Toluidine 108-44-1 ug/LPolychlorinated BiphenylsTotal PCBs TPCBs ug/L

Key to Criteria on last page

ICVC MPSCT 2003

REVGWVC IC SITE ICVC APS CT 2015 ICVC APS- - - -- - - -- - - -

50,000 - - -- - - -- - - -- - - 5,800

50,000 50,000 - -4,380 50,000 - -1,120 3,400 - -

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

50,000 - - -- - - -- - - -- - 2,888 -- - - 13,100- - - -- - - -

3,095 - 3,099 -- - - -- - - 750- - - -- - - -- - - -

50,000 - 50,000 -- - - -

50,000 - - -- - - -- - - 660- - - -- - - -

- - - -

February 2016 TABLE 4SUMMARY OF DETECTED COMPOUNDS IN UNIT 1 GROUNDWATER DATA – 2015 POST-ESRC GROUNDWATER MONITORING


033-6231-002

G:\PROJECTS\2003 Projects\033-6231-002 NHaven\AnnualRpt\2015\tables\Tbl4 Unit1_detects_012916.xlsx Page 1 of 3


Parameter CAS SWPC MPSCT RSR APPD

SITE SWPC APS

CT 2015 SWPC APS ICVC MPS

CT 2003 REVGWVC

ICSITE ICVC

APSCT 2015

ICVC APS Units Result Qual MDL QL Result Qual MDL QL Result Qual MDL QL Result Qual MDL QL Result Qual MDLVolatile Organic CompoundsAcetone 67-64-1 10000 10000 50000 50000 ug/L < 1.5 U 1.5 5 < 1.5 U 1.5 5 < 1.5 U 1.5 5 < 1.5 U 1.5 5 < 1.5 U 1.5Benzene 71-43-2 231 710 308 310 ug/L < 0.16 U 0.16 0.5 < 0.16 U 0.16 0.5 1.6 0.16 0.5 1.1 0.16 0.5 < 0.16 U 0.162-Butanone (MEK) 78-93-3 10000 10000 50000 50000 ug/L < 1.9 U 1.9 5 < 1.9 U 1.9 5 < 1.9 U 1.9 5 < 1.9 U 1.9 5 < 1.9 U 1.9tert-Butyl Alcohol 75-65-0 10000 10000 10000 50000 50000 ug/L < 0.9 U 0.9 10 < 0.9 U 0.9 10 < 0.9 U 0.9 10 < 0.9 U 0.9 10 < 0.9 U 0.9Chlorobenzene 108-90-7 640 420000 26736 23000 ug/L 2.9 0.18 0.5 1.4 0.18 0.5 2.1 0.18 0.5 1.5 0.18 0.5 1.8 0.18Chloroethane 75-00-3 10000 10000 10000 17118 11828 ug/L < 0.13 U 0.13 1 < 0.13 U 0.13 1 < 0.13 U 0.13 1 < 0.13 U 0.13 1 < 0.13 U 0.131,1-Dichloroethane 75-34-3 470 10000 4100 9470 9452 ug/L < 0.21 U 0.21 0.8 < 0.21 U 0.21 0.8 < 0.21 U 0.21 0.8 < 0.21 U 0.21 0.8 < 0.21 U 0.211,2-Dichloroethane 107-06-2 1099 2970 65 68 ug/L < 0.13 U 0.13 0.5 < 0.13 U 0.13 0.5 < 0.13 U 0.13 0.5 < 0.13 U 0.13 0.5 < 0.13 U 0.131,1-Dichloroethene 75-35-4 250 96 1467 920 ug/L < 0.14 U 0.14 0.5 < 0.14 U 0.14 0.5 < 0.14 U 0.14 0.5 < 0.14 U 0.14 0.5 < 0.14 U 0.14cis-1,2-Dichloroethene 156-59-2 5900 10000 6200 11494 11472 ug/L 0.37 J 0.19 0.5 0.45 J 0.19 0.5 < 0.19 U 0.19 0.5 < 0.19 U 0.19 0.5 0.3 J 0.19trans-1,2-Dichloroethene 156-60-5 5900 10000 10000 13372 6673 ug/L < 0.16 U 0.16 0.8 < 0.16 U 0.16 0.8 < 0.16 U 0.16 0.8 < 0.16 U 0.16 0.8 < 0.16 U 0.16Methyl t-butyl ether (MTBE) 1634-04-4 10000 10000 10000 50000 50000 ug/L < 0.16 U 0.16 1 < 0.16 U 0.16 1 < 0.16 U 0.16 1 < 0.16 U 0.16 1 < 0.16 U 0.16Toluene 108-88-3 98 4000000 41584 41000 ug/L < 0.16 U 0.16 0.8 < 0.16 U 0.16 0.8 < 0.16 U 0.16 0.8 < 0.16 U 0.16 0.8 < 0.16 U 0.16Trichloroethene 79-01-6 127 2340 63 67 ug/L < 0.18 U 0.18 0.5 < 0.18 U 0.18 0.5 < 0.18 U 0.18 0.5 < 0.18 U 0.18 0.5 < 0.18 U 0.18Vinyl chloride 75-01-4 142 15750 52 52 ug/L < 0.07 U 0.07 1 0.12 J 0.07 1 < 0.07 U 0.07 1 < 0.07 U 0.07 1 < 0.07 U 0.07Semivolatile Organic CompoundsAniline 62-53-3 13 68.9 41 ug/L < 0.55 U 0.55 5 < 0.55 U 0.55 5 1.3 J 0.55 5 0.72 J 0.55 5 < 0.55 U 0.55Benzidine 92-87-5 1 26.5 5 ug/L < 0.45 U 0.45 2 < 0.45 U 0.45 2 < 0.45 U 0.45 2 0.82 J 0.45 2 < 0.45 U 0.45Benzo(a)anthracene 56-55-3 0.27 0.3 ug/L < 0.016 U 0.02 0.2 0.024 J 0.02 0.2 < 0.016 U 0.02 0.2 < 0.016 U 0.02 0.2 < 0.016 U 0.02Benzoic acid 65-85-0 9000 ug/L < 1 U 1 50 < 1 U 1 50 < 1 U 1 50 < 1 R 1 50 < 1 U 1Bis(2-chloroethyl)ether 111-44-4 7 42 51 ug/L < 0.41 U 0.41 5 < 0.41 U 0.41 5 < 0.41 U 0.41 5 < 0.41 U 0.41 5 < 0.41 U 0.41Bis(2-ethylhexyl)Phthalate 117-81-7 30 59 ug/L < 0.93 U 0.93 5 < 5 U 5 5 < 0.93 U 0.93 5 < 0.93 U 0.93 5 < 0.93 U 0.932-Chloroaniline 95-51-2 134 53 ug/L 0.59 J 0.28 2 < 0.28 U 0.28 2 37 0.28 2 35 J 0.28 2 12 0.283-Chloroaniline 108-42-9 52 53 ug/L < 0.84 U 0.84 10 < 0.84 U 0.84 10 < 0.84 U 0.84 10 < 0.84 U 0.84 10 < 0.84 U 0.844-Chloroaniline 106-47-8 10 53 9.9 ug/L < 0.84 U 0.84 5 < 0.84 U 0.84 5 < 0.84 U 0.84 5 < 0.84 U 0.84 5 < 0.84 U 0.841,2-Dichlorobenzene 95-50-1 140 170000 50000 50000 ug/L < 0.3 U 0.3 5 < 0.3 U 0.3 5 < 0.3 U 0.3 5 < 5 U 5 5 < 0.3 U 0.31,3-Dichlorobenzene 541-73-1 180 26000 4380 50000 ug/L < 0.35 U 0.35 5 < 0.35 U 0.35 5 < 0.35 U 0.35 5 < 0.35 U 0.35 5 < 0.35 U 0.353,3'-Dichlorobenzidine 91-94-1 0.85 12.19 5 ug/L 2 0.48 2 2.7 0.48 2 1.2 J 0.48 2 < 0.48 U 0.48 2 < 0.48 U 0.483,3'-Dimethylbenzidine 119-93-7 20 58.83 ug/L 5.1 1.2 4 16 1.2 4 4.3 1.2 4 4.9 1.2 4 < 1.2 U 1.21,4-Dioxane 123-91-1 8000 5300 960 ug/L 14.4 7.08 14 < 15.6 U 15.6 31 76.8 6.82 14 59.4 16.3 33 420 7.21Diphenamid 957-51-7 23169 10000 ug/L 2.1 J 0.67 5 5.6 0.67 5 17 0.67 5 14 0.67 5 5.3 0.67Phenol 108-95-2 1100 92000000 ug/L < 0.27 U 0.27 7 < 0.27 U 0.27 7 < 0.27 U 0.27 7 < 0.27 U 0.27 7 < 0.27 U 0.27Inorganics and General ChemistryDissolved Oxygen DO mg/L 0 0 0 0 0Oxidation-Reduction Potential ORP millivolts -64 -57 -27 -30 -21pH pH SU 6.51 6.26 6.04 6.34 6.52Specific Conductance SC ms/cm 0.882 0.882 1.08 1.08 1.38Temperature TEMP C 13.09 20.51 11.74 16.71 16.4Turbidity TURB ntu 0 1.6 0 1.3 0

GD-5S7/23/2015

N

DM-7S7/22/2015

N

DM-7S10/20/2015

N

DM-5S7/22/2015

N

DM-5S10/23/2015

N

See "Abbreviations and Definitions" sheet for an explanation of the abbreviations used on this table.Blank spaces indicate that there is not a comparative criteria.

Sample ID:Sample Date:Sample Type:



033-6231-002



Parameter CASVolatile Organic CompoundsAcetone 67-64-1Benzene 71-43-22-Butanone (MEK) 78-93-3tert-Butyl Alcohol 75-65-0Chlorobenzene 108-90-7Chloroethane 75-00-31,1-Dichloroethane 75-34-31,2-Dichloroethane 107-06-21,1-Dichloroethene 75-35-4cis-1,2-Dichloroethene 156-59-2trans-1,2-Dichloroethene 156-60-5Methyl t-butyl ether (MTBE) 1634-04-4Toluene 108-88-3Trichloroethene 79-01-6Vinyl chloride 75-01-4Semivolatile Organic CompoundsAniline 62-53-3Benzidine 92-87-5Benzo(a)anthracene 56-55-3Benzoic acid 65-85-0Bis(2-chloroethyl)ether 111-44-4Bis(2-ethylhexyl)Phthalate 117-81-72-Chloroaniline 95-51-23-Chloroaniline 108-42-94-Chloroaniline 106-47-81,2-Dichlorobenzene 95-50-11,3-Dichlorobenzene 541-73-13,3'-Dichlorobenzidine 91-94-13,3'-Dimethylbenzidine 119-93-71,4-Dioxane 123-91-1Diphenamid 957-51-7Phenol 108-95-2Inorganics and General ChemistryDissolved Oxygen DOOxidation-Reduction Potential ORPpH pHSpecific Conductance SCTemperature TEMPTurbidity TURB


QL Result Qual MDL QL Result Qual MDL QL Result Qual MDL QL Result Qual MDL QL Result Qual MDL QL Result Qual MDL QL Result Qual MDL QL Result Qual MDL QL Result Qual MDL

5 < 5 U 5 5 < 1.5 U 1.5 5 < 1.5 U 1.5 5 < 1.5 U 1.5 5 < 1.5 U 1.5 5 < 1.5 U 1.5 5 < 1.5 U 1.5 5 < 1.5 U 1.5 5 < 1.5 U 1.50.5 < 0.16 U 0.16 0.5 0.43 J 0.16 0.5 < 0.16 U 0.16 0.5 38 0.16 0.5 38 0.16 0.5 37 0.16 0.5 23 0.16 0.5 1.9 0.16 0.5 2 0.165 < 1.9 U 1.9 5 < 1.9 U 1.9 5 < 1.9 U 1.9 5 < 1.9 U 1.9 5 < 1.9 U 1.9 5 < 1.9 U 1.9 5 < 1.9 U 1.9 5 < 1.9 U 1.9 5 < 1.9 U 1.910 0.92 J 0.9 10 < 0.9 U 0.9 10 < 0.9 U 0.9 10 < 0.9 U 0.9 10 < 0.9 U 0.9 10 < 0.9 U 0.9 10 < 0.9 U 0.9 10 < 0.9 U 0.9 10 < 0.9 U 0.90.5 1.2 0.18 0.5 11 0.18 0.5 2.3 0.18 0.5 23 0.18 0.5 22 0.18 0.5 41 0.18 0.5 24 0.18 0.5 39 0.18 0.5 38 0.181 < 0.13 U 0.13 1 < 0.13 U 0.13 1 < 0.13 U 0.13 1 < 0.13 U 0.13 1 < 0.13 U 0.13 1 < 0.13 U 0.13 1 < 0.13 U 0.13 1 < 0.13 U 0.13 1 < 0.13 U 0.13

0.8 < 0.21 U 0.21 0.8 < 0.21 U 0.21 0.8 < 0.21 U 0.21 0.8 < 0.21 U 0.21 0.8 < 0.21 U 0.21 0.8 < 0.21 U 0.21 0.8 < 0.21 U 0.21 0.8 < 0.21 U 0.21 0.8 < 0.21 U 0.210.5 < 0.13 U 0.13 0.5 < 0.13 U 0.13 0.5 < 0.13 U 0.13 0.5 < 0.13 U 0.13 0.5 < 0.13 U 0.13 0.5 < 0.13 U 0.13 0.5 < 0.13 U 0.13 0.5 < 0.13 U 0.13 0.5 < 0.13 U 0.130.5 < 0.14 U 0.14 0.5 < 0.14 U 0.14 0.5 < 0.14 U 0.14 0.5 < 0.14 U 0.14 0.5 < 0.14 U 0.14 0.5 < 0.14 U 0.14 0.5 < 0.14 U 0.14 0.5 < 0.14 U 0.14 0.5 < 0.14 U 0.140.5 < 0.19 U 0.19 0.5 0.23 J 0.19 0.5 < 0.19 U 0.19 0.5 < 0.19 U 0.19 0.5 < 0.19 U 0.19 0.5 < 0.19 U 0.19 0.5 < 0.19 U 0.19 0.5 < 0.19 U 0.19 0.5 < 0.19 U 0.190.8 < 0.16 U 0.16 0.8 < 0.16 U 0.16 0.8 < 0.16 U 0.16 0.8 < 0.16 U 0.16 0.8 < 0.16 U 0.16 0.8 < 0.16 U 0.16 0.8 < 0.16 U 0.16 0.8 < 0.16 U 0.16 0.8 < 0.16 U 0.161 < 0.16 U 0.16 1 < 0.16 U 0.16 1 < 0.16 U 0.16 1 < 0.16 U 0.16 1 < 0.16 U 0.16 1 < 0.16 U 0.16 1 < 0.16 U 0.16 1 < 0.16 U 0.16 1 < 0.16 U 0.16

0.8 < 0.16 U 0.16 0.8 < 0.16 U 0.16 0.8 < 0.16 U 0.16 0.8 < 0.16 U 0.16 0.8 < 0.16 U 0.16 0.8 < 0.16 U 0.16 0.8 < 0.16 U 0.16 0.8 < 0.16 U 0.16 0.8 < 0.16 U 0.160.5 < 0.18 U 0.18 0.5 < 0.18 U 0.18 0.5 < 0.18 U 0.18 0.5 < 0.18 U 0.18 0.5 < 0.18 U 0.18 0.5 < 0.18 U 0.18 0.5 < 0.18 U 0.18 0.5 < 0.18 U 0.18 0.5 < 0.18 U 0.181 < 0.07 U 0.07 1 < 0.07 U 0.07 1 < 0.07 U 0.07 1 < 0.07 U 0.07 1 < 0.07 U 0.07 1 < 0.07 U 0.07 1 < 0.07 U 0.07 1 0.11 J 0.07 1 0.12 J 0.07

5 < 0.55 U 0.55 5 < 0.55 U 0.55 5 < 0.55 U 0.55 5 < 0.55 U 0.55 5 < 0.55 U 0.55 5 < 1.1 U 1.1 10 < 0.55 U 0.55 5 < 0.55 U 0.55 5 < 0.55 U 0.552 < 0.45 U 0.45 2 < 0.45 U 0.45 2 < 0.45 U 0.45 2 < 0.45 U 0.45 2 < 0.45 U 0.45 2 < 0.45 U 0.45 2 < 0.45 U 0.45 2 < 0.45 U 0.45 2 < 0.45 U 0.45

0.2 < 0.016 U 0.02 0.2 < 0.016 U 0.02 0.2 < 0.016 U 0.02 0.2 < 0.016 U 0.02 0.2 < 0.016 U 0.02 0.2 < 0.016 U 0.02 0.2 < 0.016 U 0.02 0.2 < 0.016 U 0.02 0.2 < 0.016 U 0.0250 < 1 R 1 50 6.4 J 1 50 < 1 R 1 50 < 1 U 1 50 < 1 R 1 50 < 2 U 2 100 < 1 R 1 50 < 1 U 1 50 6.7 J 15 < 0.41 U 0.41 5 < 0.41 U 0.41 5 < 0.41 U 0.41 5 < 0.41 U 0.41 5 < 0.41 U 0.41 5 < 0.82 U 0.82 10 < 0.41 U 0.41 5 < 0.41 U 0.41 5 < 0.41 U 0.415 < 0.93 U 0.93 5 < 0.93 U 0.93 5 < 0.93 U 0.93 5 < 0.93 U 0.93 5 < 0.93 U 0.93 5 < 1.8 U 1.8 10 < 0.93 U 0.93 5 < 0.93 U 0.93 5 5.1 0.932 13 J 0.28 2 0.95 J 0.28 2 0.63 J 0.28 2 260 1.4 10 340 1.1 8 400 0.56 4 260 1.1 8 3.8 0.28 2 3.6 0.28

10 < 0.84 U 0.84 10 < 0.84 U 0.84 10 < 0.84 U 0.84 10 < 0.84 U 0.84 10 1.3 J 0.84 10 < 1.7 U 1.7 20 < 0.84 U 0.84 10 3.3 J 0.84 10 < 0.84 U 0.845 < 0.84 U 0.84 5 < 0.84 U 0.84 5 < 0.84 U 0.84 5 < 0.84 U 0.84 5 2.4 J 0.84 5 < 1.7 U 1.7 10 1.2 J 0.84 5 0.88 J 0.84 5 < 0.84 U 0.845 0.36 J 0.3 5 < 0.3 U 0.3 5 < 0.3 U 0.3 5 < 0.3 U 0.3 5 < 0.3 U 0.3 5 < 0.6 U 0.6 10 < 0.3 U 0.3 5 0.78 J 0.3 5 0.86 J 0.35 < 0.35 U 0.35 5 < 0.35 U 0.35 5 < 0.35 U 0.35 5 < 0.35 U 0.35 5 < 0.35 U 0.35 5 < 0.7 U 0.7 10 < 0.35 U 0.35 5 < 0.35 U 0.35 5 < 0.35 U 0.352 < 0.48 U 0.48 2 < 0.48 U 0.48 2 < 0.48 U 0.48 2 0.66 J 0.48 2 < 0.48 U 0.48 2 0.52 J 0.48 2 < 0.48 U 0.48 2 < 0.48 U 0.48 2 < 0.48 U 0.484 < 1.2 U 1.2 4 < 1.2 U 1.2 4 < 1.2 U 1.2 4 25 1.2 4 76 1.2 4 14 1.2 4 40 1.2 4 < 1.2 U 1.2 4 < 1.2 U 1.214 369 15.6 31 183 7.21 14 107 15 30 260 7.08 14 233 14.4 29 110 7.65 15 54.9 13.4 27 139 7.21 14 151 7.55 4 J 0.67 5 4.5 J 0.67 5 5.7 0.67 5 48 0.67 5 60 0.67 5 18 1.3 10 9.9 0.67 5 28 0.67 5 32 0.677 < 0.27 U 0.27 7 < 0.27 U 0.27 7 < 0.27 U 0.27 7 < 0.27 U 0.27 7 < 0.27 U 0.27 7 < 0.54 U 0.54 14 < 0.27 U 0.27 7 < 0.27 U 0.27 7 < 0.27 U 0.27

0.23 0 0 0 0 1.42 0 5.71 5.71-39 -76 -101 -238 -146 -109 -158 -104 -1046.41 5.93 6.62 6.21 7.49 8.19 7.36 7.5 7.51.38 0.782 0.782 1.62 1.62 1.19 1.19 1.03 1.0320.1 14.32 22.12 12.45 18.02 14.22 20.47 13.96 13.968.9 17.7 12.8 34.9 40.8 4.1 1 38 38

GW-HBW117/22/2015

FD

GW-HBW117/22/2015

N

GW-HBW077/23/2015

N

GW-HBW0710/19/2015

N

GW-HBW067/24/2015

N

GW-HBW0610/20/2015

N

GW-HBW037/24/2015

N

GW-HBW0310/20/2015

N

GD-5S10/20/2015

N



033-6231-002



Parameter CASVolatile Organic CompoundsAcetone 67-64-1Benzene 71-43-22-Butanone (MEK) 78-93-3tert-Butyl Alcohol 75-65-0Chlorobenzene 108-90-7Chloroethane 75-00-31,1-Dichloroethane 75-34-31,2-Dichloroethane 107-06-21,1-Dichloroethene 75-35-4cis-1,2-Dichloroethene 156-59-2trans-1,2-Dichloroethene 156-60-5Methyl t-butyl ether (MTBE) 1634-04-4Toluene 108-88-3Trichloroethene 79-01-6Vinyl chloride 75-01-4Semivolatile Organic CompoundsAniline 62-53-3Benzidine 92-87-5Benzo(a)anthracene 56-55-3Benzoic acid 65-85-0Bis(2-chloroethyl)ether 111-44-4Bis(2-ethylhexyl)Phthalate 117-81-72-Chloroaniline 95-51-23-Chloroaniline 108-42-94-Chloroaniline 106-47-81,2-Dichlorobenzene 95-50-11,3-Dichlorobenzene 541-73-13,3'-Dichlorobenzidine 91-94-13,3'-Dimethylbenzidine 119-93-71,4-Dioxane 123-91-1Diphenamid 957-51-7Phenol 108-95-2Inorganics and General ChemistryDissolved Oxygen DOOxidation-Reduction Potential ORPpH pHSpecific Conductance SCTemperature TEMPTurbidity TURB


QL Result Qual MDL QL Result Qual MDL QL Result Qual MDL QL Result Qual MDL QL Result Qual MDL QL Result Qual MDL QL Result Qual MDL QL

5 < 1.5 U 1.5 5 < 1.5 U 1.5 5 < 1.5 U 1.5 5 < 15 U 15 50 21 J 15 50 < 1.5 U 1.5 5 < 1.5 U 1.5 50.5 0.99 0.16 0.5 1.4 0.16 0.5 0.92 0.16 0.5 580 1.6 5 380 1.6 5 5.8 0.16 0.5 6.3 0.16 0.55 < 1.9 U 1.9 5 < 1.9 U 1.9 5 < 1.9 U 1.9 5 < 19 U 19 50 22 J 19 50 < 1.9 U 1.9 5 < 1.9 U 1.9 510 5 J 0.9 10 < 0.9 U 0.9 10 < 0.9 U 0.9 10 < 9 U 9 100 23 J 9 100 < 0.9 U 0.9 10 < 0.9 U 0.9 100.5 33 0.18 0.5 15 0.18 0.5 9.5 0.18 0.5 26 1.8 5 16 1.8 5 19 0.18 0.5 20 0.18 0.51 < 0.13 U 0.13 1 < 0.13 U 0.13 1 < 0.13 U 0.13 1 < 1.3 U 1.3 10 < 1.3 U 1.3 10 0.45 J 0.13 1 0.29 J 0.13 1

0.8 < 0.21 U 0.21 0.8 < 0.21 U 0.21 0.8 < 0.21 U 0.21 0.8 < 2.1 U 2.1 7.5 < 2.1 U 2.1 7.5 23 0.21 0.8 25 0.21 0.80.5 < 0.13 U 0.13 0.5 < 0.13 U 0.13 0.5 < 0.13 U 0.13 0.5 < 1.3 U 1.3 5 < 1.3 U 1.3 5 < 0.13 U 0.13 0.5 0.28 J 0.13 0.50.5 < 0.14 U 0.14 0.5 < 0.14 U 0.14 0.5 < 0.14 U 0.14 0.5 < 1.4 U 1.4 5 < 1.4 U 1.4 5 1.8 0.14 0.5 1.6 0.14 0.50.5 0.3 J 0.19 0.5 < 0.19 U 0.19 0.5 < 0.19 U 0.19 0.5 < 1.9 U 1.9 5 < 1.9 U 1.9 5 59 0.19 0.5 64 0.19 0.50.8 < 0.16 U 0.16 0.8 < 0.16 U 0.16 0.8 < 0.16 U 0.16 0.8 < 1.6 U 1.6 7.5 < 1.6 U 1.6 7.5 0.9 0.16 0.8 0.85 0.16 0.81 < 0.16 U 0.16 1 < 0.16 U 0.16 1 < 0.16 U 0.16 1 < 1.6 U 1.6 10 < 1.6 U 1.6 10 0.28 J 0.16 1 2.8 0.16 1

0.8 < 0.16 U 0.16 0.8 < 0.16 U 0.16 0.8 < 0.16 U 0.16 0.8 < 7.5 U 7.5 7.5 < 1.6 U 1.6 7.5 < 0.75 U 0.75 0.8 0.26 J 0.16 0.80.5 < 0.18 U 0.18 0.5 < 0.18 U 0.18 0.5 < 0.18 U 0.18 0.5 < 1.8 U 1.8 5 < 1.8 U 1.8 5 0.26 J 0.18 0.5 0.22 J 0.18 0.51 0.14 J 0.07 1 < 0.07 U 0.07 1 < 0.07 U 0.07 1 < 0.7 U 0.7 10 < 0.7 U 0.7 10 50 0.07 1 54 0.07 1

5 < 0.55 U 0.55 5 < 0.55 U 0.55 5 < 0.55 U 0.55 5 < 0.55 U 0.55 5 < 0.55 U 0.55 5 < 0.55 U 0.55 5 < 0.55 U 0.55 52 < 0.45 U 0.45 2 < 0.45 U 0.45 2 0.8 J 0.45 2 < 0.45 U 0.45 2 < 0.45 U 0.45 2 < 0.45 U 0.45 2 < 0.45 U 0.45 2

0.2 < 0.016 U 0.02 0.2 < 0.016 U 0.02 0.2 < 0.016 U 0.02 0.2 < 0.016 U 0.02 0.2 < 0.016 U 0.02 0.2 < 0.016 U 0.02 0.2 0.02 J 0.02 0.250 < 1 U 1 50 < 1 U 1 50 < 1 R 1 50 7.1 J 1 50 8.4 J 1 50 < 1 U 1 50 < 1 R 1 505 < 0.41 U 0.41 5 < 0.41 U 0.41 5 < 0.41 U 0.41 5 0.89 J 0.41 5 < 0.41 U 0.41 5 < 0.41 U 0.41 5 < 0.41 U 0.41 55 < 0.93 U 0.93 5 < 0.93 U 0.93 5 3.9 J 0.93 5 < 0.93 U 0.93 5 < 0.93 U 0.93 5 < 0.93 U 0.93 5 < 0.93 U 0.93 52 2.8 0.28 2 70 0.28 2 72 J 0.28 2 46 0.28 2 55 J 0.28 2 0.62 J 0.28 2 0.34 J 0.28 210 < 0.84 U 0.84 10 < 0.84 U 0.84 10 < 0.84 U 0.84 10 < 0.84 U 0.84 10 < 0.84 U 0.84 10 < 0.84 U 0.84 10 < 0.84 U 0.84 105 < 0.84 U 0.84 5 < 0.84 U 0.84 5 < 0.84 U 0.84 5 < 0.84 U 0.84 5 < 0.84 U 0.84 5 < 0.84 U 0.84 5 < 0.84 U 0.84 55 < 0.3 U 0.3 5 < 0.3 U 0.3 5 28 J 0.3 5 0.62 J 0.3 5 < 5 U 5 5 4.4 J 0.3 5 4.2 J 0.3 55 < 0.35 U 0.35 5 < 0.35 U 0.35 5 0.43 J 0.35 5 < 0.35 U 0.35 5 < 0.35 U 0.35 5 < 0.35 U 0.35 5 < 0.35 U 0.35 52 < 0.48 U 0.48 2 0.54 J 0.48 2 < 0.48 U 0.48 2 < 0.48 U 0.48 2 < 0.48 U 0.48 2 < 0.48 U 0.48 2 < 0.48 U 0.48 24 < 1.2 U 1.2 4 7.8 1.2 4 20 1.2 4 < 1.2 U 1.2 4 < 1.2 U 1.2 4 < 1.2 U 1.2 4 < 1.2 U 1.2 4

15 94.6 13.9 28 68.8 6.82 14 72.2 14.4 29 786 7.35 15 844 14.4 29 13.7 J 7.08 14 < 15 U 15 305 26 0.67 5 32 0.67 5 18 0.67 5 34 0.67 5 28 0.67 5 < 0.67 U 0.67 5 4 J 0.67 57 < 0.27 U 0.27 7 < 0.27 U 0.27 7 < 0.27 U 0.27 7 3.6 J 0.27 7 4.6 J 0.27 7 < 0.27 U 0.27 7 < 0.27 U 0.27 7

0 5.48 0 1.31 0 0 0-109 -72 -72 -177 -104 -72 -746.52 7.41 6.61 6.7 6.7 6.62 6.351.03 1.37 1.37 2.1 2.1 0.625 0.62518.9 13.16 20.09 16.76 21.42 16.58 22.947.7 11.2 25.8 136 66.2 0 0.9

GW-HBW1310/21/2015

N10/21/2015

N

GW-NFPA077/23/2015

N

GW-NFPA07GW-HBW1210/19/2015

N

GW-HBW137/23/2015

N

GW-HBW1110/22/2015

N

GW-HBW127/22/2015

N

February 2016 TABLE 5SUMMARY OF DETECTED COMPOUNDS UNIT 3 GROUNDWATER DATA - 2015 GROUNDWATER MONITORING


033-6231-002



Parameter CAS UnitsSWPC MPS

CT RSR APPD

SITE SWPC APS

CT 2015 SWPC APS Result Qual MDL QL Result Qual MDL QL Result Qual MDL QL Result Qual MDL QL Result Qual MDL QL Result Qual MDL QL Result Qual MDL QL

Volatile Organic CompoundsBenzene 71-43-2 ug/L 231 710 < 0.16 U 0.16 0.5 < 0.16 U 0.16 0.5 < 0.16 U 0.16 0.5 0.62 0.16 0.5 2 0.16 0.5 < 0.16 U 0.16 0.5 < 0.16 U 0.16 0.5Chlorobenzene 108-90-7 ug/L 640 420000 < 0.18 U 0.18 0.5 < 0.18 U 0.18 0.5 < 0.18 U 0.18 0.5 60 0.18 0.5 200 0.18 0.5 < 0.18 U 0.18 0.5 < 0.18 U 0.18 0.5Chloroform 67-66-3 ug/L 280 14100 < 0.16 U 0.16 0.8 < 0.16 U 0.16 0.8 < 0.16 U 0.16 0.8 1.2 0.16 0.8 0.84 0.16 0.8 < 0.16 U 0.16 0.8 < 0.16 U 0.16 0.81,1-Dichloroethane 75-34-3 ug/L 470 10000 4100 < 0.21 U 0.21 0.8 < 0.21 U 0.21 0.8 < 0.21 U 0.21 0.8 5.6 0.21 0.8 < 0.21 U 0.21 0.8 < 0.21 U 0.21 0.8 < 0.21 U 0.21 0.81,2-Dichloroethane 107-06-2 ug/L 1099 2970 < 0.13 U 0.13 0.5 < 0.13 U 0.13 0.5 < 0.13 U 0.13 0.5 0.42 J 0.13 0.5 0.29 J 0.13 0.5 < 0.13 U 0.13 0.5 < 0.13 U 0.13 0.51,1-Dichloroethene 75-35-4 ug/L 250 96 < 0.14 U 0.14 0.5 < 0.14 U 0.14 0.5 < 0.14 U 0.14 0.5 1.5 0.14 0.5 8.3 0.14 0.5 < 0.14 U 0.14 0.5 < 0.14 U 0.14 0.5cis-1,2-Dichloroethene 156-59-2 ug/L 5900 10000 < 0.19 U 0.19 0.5 < 0.19 U 0.19 0.5 < 0.19 U 0.19 0.5 8.8 0.19 0.5 16 0.19 0.5 < 0.19 U 0.19 0.5 < 0.19 U 0.19 0.5trans-1,2-Dichloroethene 156-60-5 ug/L 10000 < 0.16 U 0.16 0.8 < 0.16 U 0.16 0.8 < 0.16 U 0.16 0.8 0.26 J 0.16 0.8 0.77 0.16 0.8 < 0.16 U 0.16 0.8 < 0.16 U 0.16 0.8Isopropanol 67-63-0 ug/L 10000 < 8.5 U 8.5 25 < 25 U 25 25 22 R 8.5 25 < 25 U 25 25 < 25 U 25 25 < 8.5 U 8.5 25 < 25 U 25 25Isopropylbenzene 98-82-8 ug/L 210 210 < 0.19 U 0.19 0.5 < 0.19 U 0.19 0.5 < 0.19 U 0.19 0.5 < 0.19 U 0.19 0.5 0.24 J 0.19 0.5 < 0.19 U 0.19 0.5 < 0.19 U 0.19 0.5Methyl t-butyl ether (MTBE) 1634-04-4 ug/L 10000 10000 < 0.16 U 0.16 1 < 0.16 U 0.16 1 < 0.16 U 0.16 1 7.9 0.16 1 < 0.16 U 0.16 1 < 0.16 U 0.16 1 < 0.16 U 0.16 1Tetrachloroethene 127-18-4 ug/L 187 88 < 0.18 U 0.18 0.5 < 0.18 U 0.18 0.5 < 0.18 U 0.18 0.5 4.7 0.18 0.5 4 0.18 0.5 < 0.18 U 0.18 0.5 < 0.18 U 0.18 0.51,1,1-Trichloroethane 71-55-6 ug/L 110 62000 < 0.16 U 0.16 0.5 < 0.16 U 0.16 0.5 < 0.16 U 0.16 0.5 0.24 J 0.16 0.5 < 0.16 U 0.16 0.5 < 0.16 U 0.16 0.5 < 0.16 U 0.16 0.5Trichloroethene 79-01-6 ug/L 127 2340 < 0.18 U 0.18 0.5 < 0.18 U 0.18 0.5 < 0.18 U 0.18 0.5 12 0.18 0.5 14 0.18 0.5 < 0.18 U 0.18 0.5 < 0.18 U 0.18 0.5Vinyl chloride 75-01-4 ug/L 142 15750 < 0.07 U 0.07 1 < 0.07 U 0.07 1 < 0.07 U 0.07 1 0.44 J 0.07 1 1.5 0.07 1 0.16 J 0.07 1 < 0.07 U 0.07 1Xylenes, total 1330-20-7 ug/L 130 1431 < 0.33 U 0.33 1 < 0.33 U 0.33 1 < 0.33 U 0.33 1 < 0.33 U 0.33 1 0.33 J 0.33 1 < 0.33 U 0.33 1 < 0.33 U 0.33 1Semivolatile Organic CompoundsBis(2-ethylhexyl)Phthalate 117-81-7 ug/L 30 59 < 0.93 U 0.93 5 < 0.93 U 0.93 5 < 0.93 U 0.93 5 < 0.93 U 0.93 5 < 0.93 U 0.93 5 2.9 J 0.93 5 < 0.93 U 0.93 52-Chloroaniline 95-51-2 ug/L 134 53 < 0.28 U 0.28 2 0.7 J 0.28 2 1.6 J 0.28 2 0.61 J 0.28 2 4 0.28 2 4.8 J 0.28 2 < 0.28 U 0.28 21,2-Dichlorobenzene 95-50-1 ug/L 140 170000 < 0.3 U 0.3 5 < 0.3 U 0.3 5 < 0.3 U 0.3 5 52 J 0.3 5 120 0.3 5 < 5 U 5 5 < 0.3 U 0.3 51,4-Dichlorobenzene 106-46-7 ug/L 150 26000 < 0.32 U 0.32 5 < 0.32 U 0.32 5 < 0.32 U 0.32 5 < 5 U 5 5 5.3 0.32 5 < 0.32 U 0.32 5 < 0.32 U 0.32 51,4-Dioxane 123-91-1 ug/L 8000 5300 < 15 U 15 30 < 13.4 U 13.4 27 < 13.9 U 13.9 28 359 15 30 865 14.4 29 < 15.6 U 15.6 31 < 15 U 15 30Diphenamid 957-51-7 ug/L 23169 10000 < 0.67 U 0.67 5 < 0.67 U 0.67 5 < 0.67 U 0.67 5 0.78 J 0.67 5 11 0.67 5 < 0.67 U 0.67 5 < 0.67 U 0.67 5Inorganics and General ChemistryDissolved Oxygen DO mg/L 0.06 0 0 0.04 0 0 0Oxidation-Reduction Potential ORP millivolts -40 -41 -157 27 -9 -198 -153pH pH SU 9.28 8.68 7.92 7.71 7.47 8.45 8.69Specific conductance SC ms/cm 0.161 0.226 0.213 2.210 3.140 0.414 0.226Temperature TEMP C 18.44 16.84 17.48 17.57 17.54 16.3 15.31Turbidity TURB ntu 122 4 0 1.5 1000 62.9 0

See "Abbreviations and Definitions" sheet for an explanation of the abbreviations used on this table.

Blank spaces indicate that there is not a criteria for a specific target analyte

Sample ID:Sample Date:Sample Type:

DM-5D10/19/2015

N

DM-7D10/19/2015

N

DM-9D10/22/2015

N

GD-3D10/19/2015

N

GD-4D10/22/2015

N

MP-20DR10/21/2015

N

MW-35D10/19/2015

N

February 2016 033-6231-002

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TABLE 62016 UNIT 1 MONITORING LOCATIONS


Well No. Elevation of Measuring Point (NGVD)

Objective 1: Unit 1

Hydraulic Control

Objective 2: Unit 1 GW Flow Direction

Objective 3: Monitor Unit 1 Outside HBW

Objective 6: SEC-7D Area

Unit 1 Monitoring

Comments

DM-5S 10.43 X XDM-7S 10.95 X XGD-5S 8.68 X X

GD-6SR 14.96 X X Changed from continuous to manual monitoring for 2016GD-8S 13.52 X

GW-DPLX01 17.36 XGW-DPLX08 13.03 XGW-DPLX13 13.23 XGW-HBW01 14.50 X XGW-HBW02 12.83 X XGW-HBW03 8.82 X X X Changed from continuous to manual monitoring for 2016

GW-HBW04A 11.34 X X Changed from continuous to manual monitoring for 2016GW-HBW05 15.24 X XGW-HBW06 9.91 X XGW-HBW07 8.66 X X XGW-HBW08 9.65 X X Changed from continuous to manual monitoring for 2016GW-HBW09 9.01 X X Changed from continuous to manual monitoring for 2016GW-HBW10 17.96 X X Changed from manual to continuous monitoring for 2016GW-HBW11 16.03 X XGW-HBW12 10.28 X XGW-HBW13 9.41 X X

GW-HBW14A 10.50 X XGW-HBW15 16.21 X XGW-HBW16 13.67 X XGW-HBW18 13.97 X X Changed from manual to continuous monitoring for 2016GW-HBW19 13.01 X X XGW-HBW20 16.53 X XGW-NFPA01 12.13 X X Changed from manual to continuous monitoring for 2016GW-NFPA04 13.54 XGW-NFPA06 16.95 X X Changed from manual to continuous monitoring for 2016GW-NFPA07 11.44 X X X X

GW-U102 15.99 X XGW-U103 14.53 X XMP-22S NA X X Correlated with surface water elevationMP-24S 12.88 XMP-27S 15.71 XMP-28S 13.87 X

MW-107S 19.57 XMW-33 26.69 XMW-34 24.17 X

MW-35SR 22.58 X X Changed from continuous to manual monitoring for 2016PA-52 12.95 X XPA-55 20.49 XPW-1R 17.91 X

PW-2RA 10.46 XPW-4R 17.59 XPW-5R 14.83 XPW-6 12.30 XPW-9 10.44 X

PW-10 23.95 XPW-11 24.51 X X

PW-14B 25.15 X XPW-16A 25.18 XPW-20 24.51 X X

S1N 19.67 XS1S 16.18 XS2N 14.42 XS2S 14.22 X

SEC-1S 20.63 XSEC-2S 16.78 XSTP-01 17.72 X X Changed from manual to continuous monitoring for 2016STP-02 18.67 X XSTP-03 17.71 X XSTP-04 14.70 X XSTP-05 13.51 X X Changed from manual to continuous monitoring for 2016STP-06 12.30 X XSTP-07 20.67 X X Changed from manual to continuous monitoring for 2016STP-08 16.93 X XSTP-09 15.02 X XSTP-10 17.74 X X Changed from manual to continuous monitoring for 2016STP-11 17.01 X XTPW-1N 16.06 X X

Notes:Bold and Underlined - Indicates continuous monitoring location NGVD - National Geodetic Vertical DatumNM - Not measuredft-btoc - feet below top of casingNA - Not applicable

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TABLE 72016 UNITS 3 & 4 MONITORING LOCATIONSPHARMACIA & UPJOHN COMPANY LLC SITE

NORTH HAVEN, CONNECTICUT

Well No.Elevation of

Measuring Point (NGVD)

Objective 4: Unit 3 & 4 GW

Flow Direction

Objective 5: Unit 3 Performance

Standard Comparison

Objective 6: Unit 3

Monitoring near SEC-7D

Objective 7: Unit 3 Full-Scale ISTR Monitoring

Objective 8: Unit 3 Post-

ESRC Monitoring

Objective 9: GW-U402B and

Post-ESRC Monitoring

Unit 3 and Deep Unconfined Groundwater Monitoring WellsDM-5D 10.83 X X XDM-7D 11.35 X X XDM-9D 23.17 X X XGD-2D 21.37 X X XGD-3D 14.28 X X X XGD-4D 11.82 X X X XGD-5D 9.02 X XGD-6D 14.99 X XGD-8D 14.26 X X

GW-HBW17 14.14 X X XGW-U303 11.52 X X XGW-U305 14.87 X X X XGW-U306 17.62 X XGW-U308 13.98 X XGW-U309 14.13 X X XGW-U310 14.95 X X XGW-U311 13.07 X X X XGW-U312 12.36 X X X XGW-U313 15.32 X X XMP-20DR 11.77 X X XMP-28DR 17.62 X XMW-35D 25.13 X X XSEC-1D 20.43 X XSEC-2D 16.95 X XSEC-7D 14.79 X X X

Unit 4 Monitoring WellsGD-1BR 19.25 X XGD-2BR 21.30 X XGD-4BR 11.18 X XGD-5BR 8.32 X XGD-6BR 14.87 X XGD-9BR 16.76 X X

GW-U402B 18.41 X XGW-U403 13.48 X XGW-U404 17.37 X XGW-U405 12.68 X X

Wells which will be sampled in spring 2016 indicated by bold and underlining

Notes:NGVD - National Geodetic Vertical DatumNM - Not measuredft-btoc - feet below top of casingNA - Not applicable

033-6231-002February 2016

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NotesBlank spaces indicate that the sample was not analyzed for a specific constituentSample results exceeding the MPS and/or the RSRs are highlighted as described below

Abbreviations- - Not Applicable QC - Quality ControlAPS - Additional Polluting Substances QL - Quantitation LimitFD - Field Duplicate RB - Rinsate BlankGW - Groundwater RPD - Relative Percent DifferenceICVC - Industrial/Commercial Volatilization Criteria RSRs - Remedial Standard Regulations LCS/LCSD - Laboratory Control Sample / Laboratory Control Sample Duplicate SVOCs - Semivolatile Organic CompoundsMDL - Method Detection Limit SWPC - Surface Water Protection CriteriaMPS - Media Protection Standards TB - Trip BlankMS/MSD - Matrix Spike/Matrix Spike Duplicate TSS - Total Suspended SolidsNA - Not Applicable VOCs - Volatile Organic CompoundsNC - No Comparative Criteria WQ - Water, Quality ControlND - Not Detected SDG - Sample Delivery GroupPAHs - Polycyclic Aromatic Hydrocarbons

DefinitionsValidation Qualifiers

Laboratory Qualifiers

Comparative Criteria

CT 2003 REVGWVC IC - Proposed Revisions Industrial/Commercial Volatilization Criteria from the CTDEEP Remedial Standard Regulations Volatilization Criteria, March 2003. Results exceeding the CT 2003 REVGWVC IC criteria are shaded.

SITE IC VC APS - ICVC Criteria approved for use at the Pharmacia & Upjohn Company LLC Site in December 2008, and the ICVC criterion for naphthalene approved March 23, 2012.CT 2015 ICVC APS - Industrial/Commercial Volatilization Criteria for Additional Polluting Substances default values available for "fast-track" approval on a Site-Specific Basis released December 11, 2015.

G - The concentration may be biased high due to matrix interferences (i.e, co-elution) with non-target compound(s). The result should be considered estimated.J - Estimated value. The target analyte concentration is below the quantitation limit (QL), but above the Method Detection Limit (MDL).

SWPC MPS - Surface Water Protection Criteria Media Media Protection Standard as defined in Attachment 2, Tables 3 & 4 of the March 31, 2011 RCRA 3008(h) Order (Docket Number RCRA-01-2011-0027) issued to Pharmacia & Upjohn Company LLC by USEPA. Sample results exceeding the SWPC MPS are shown in bold.CT RSR APPD - Surface Water Protection Criteria from Appendix D of the CTDEEP Remedial Standard Regulations, June 2013. SITE SWPC APS - Surface Water Protection Criteria approved for use at the Pharmacia & Upjohn Company LLC Site in December 2008. Includes the assumption that the Dilution Factor is 53. Sample results exceding the SITE SWPC APS criteria are shaded.

CT 2015 SWPC APS - Surface Water Protection Criteria for Additional Polluting Substances default values available for "fast-track" approval on a Site-Specific Basis released December 11, 2015. Sample results exceeding the CT 2015 SWPC APS criteria are shaded.

ICVC MPS - Industrial/Commercial Volatilization Criteria Media Protection Standard as defined in Attachment 2, Table 3 of the March 31, 2011 RCRA 3008(h) Order (Docket Number RCRA-01-2011-0027) issued to Pharmacia & Upjohn Company LLC by USEPA. Sample results exceeding the ICVC MPS are shown in italics .

UJ - The analyte was not detected above the reported sample detection limit. However, the reported detection limit is approximate and may or may not represent the actual limit of quantitation necessary to accurately and precisely measure the analyte in the sample.

R - The sample results are rejected due to serious deficiencies in meeting QC criteria. The data are unusable. The analyte may or may not be present in the sample.

B - The analyte was detected above the reporting limit in the associated method blank.E - Concentration of analyte exceeds the range of the calibration curve and/or linear range of the instrument.

ABBREVIATIONS AND DEFINITIONSPHARMACIA & UPJOHN COMPANY LLC SITE

NORTH HAVEN, CONNECTICUT

U - The analyte was analyzed for, but not detected above the reported sample detection limit.

J - The analyte was positively identified; the associated numerical value is the approximate concentration of the analyte in the sample.

Documents

2015 ANNUAL PROGRESS · 2016-02-10 · 2015 ANNUAL PROGRESS REPORT. Corrective Measures Implementation at the . Pharmacia & Upjohn Company LLC Site . North Haven, Connecticut . RCRA