-, 146025

,_I~I• .--!ill.!.-__ }Five-Year Review Report

Rowe Industries Superfund Site ,Suffolk County

Sag Harbor, New York

Prepared by: , '

United Stat~ Environmental Protection Agency . Region 2

New York, New York

February 2013

..2-!V->d/.?Waiter E. Mugdan, Director nate Emergency and Remedial Response Division

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Table of Contents

Acronyms Used in this Docwnent iii Executive Summary iv Five-Year Review Summary Fonn v

I. Introduction - :............................................................................ I II. . Site Chronology I

Ill. Background :........................................... I Site Location I

Land and Resource Use : 2

Initial Response , , ,. 3 Basis/or Taking Action , , 3

Physical Characteristics .. ,.. , , , , ,.. , 1 Site Geology/Hydrogeology.................................... ................................... 2

History o/Contamination 3

IV. Remedial Actions .­ ............. 4 Remedy Selection ,; 4 Remedy Implementation ,....................... 5

Contaminated Soils and Dry Wells .5 Groundwater Remediation ......... ........................•..............7

Institutional Controls Implementation........................................ ............... 7 System Operations/Operations and Maintenance 8

V. Five-Year Review Process : 9

Data Review....................................................................•.......................... 9.

Other Comments on Operation, Maintenance, Monitoring, and

Administrative Components 9 Community Involvement 9 Document Review ....................................•.: 9

Site Inspection ; 11 Interviews ;................................................. ........................... 11 Institutional Controls Verification.......................................................... II

Institutional Controls II VI. Technical Assessment. ~ : , 11

Question A: Is the remedy functioning as intended by the decision documents? 11

Question B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action oDjectives used at the time ofthe remedy

Question C: Has any other information come to light that could call into

Technical Assessment Summary ]3

still valid? 12

question the protectiveness ofthe remedy? 13

VII. R~mmendations and FoUow:'Up Actions :.. :· ]3 VIII. Protectiveness Statement : 13

IX. Next Review : : 14

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Figure 1: Figure 2:

Table 1: Table2: Table 3a: Table 3b: Table 3c: Table 4:

FIGURES

Site Plan . Plume Map

TABLES

Chronology of Site EventS Documents, Data, and Information Reviewed in Completing the Five·Year Review Current and Historic Concentrations ofpeE Current and Historic Concentrations of TCE Current and Historic Concentrations 'of TeA Other Comments on Operation,_ Maintenance, Monitoring, and. Institutional Controls

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Acronyms Used in tbis Document

CIC Community Involvement Coordinator

DCA Dichloroeth~e

DCE Dichloroethylene

EPA United States Environmental Protection Agency

FRW Focused Recovery Well

MCL Maximum Contaminant Leyel

mglkg Milligrams per Kilogram

~gIkg Micrograms per Kilogram

~gIl Micrograms per Liter

NYSDEC New York State Department of Environmental Protection

O&M Operation and Maintenance

PCOR Preliminary Close-Out Report

PCE Tetrachloroethylene

PRPs Potentially Responsible Parties

RA Remedial Action

RAO Remedial Action Objective

RD Remedial Design

ROD Record of Decision

RPM Remedial Project Manager

TAGM Technical and Administrative Guidance Memorandum

TCA Trichloroethane

VOCs Volatile Organic Compounds

III

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EXECUTIVE SUMMARY·

This is the second five-year review for the Rowe Industries Superfund site, located in Sag Harbor; Suffolk County, New York. The assessment of this five;.year review is that. the implemented actions at the site protect human health and the envirorunent.

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Five·Year Review Summary Fann

SITE IDENTIFICATION

Site Name: Rowe Industries

EPA 10: NYD981486954

NPL Status: Final.

Multiple OUo?

No

Has the site achieved construction completion?. .

Yes

REVIEW STATUS

Lead agency: EPA If "Other Federal Agency" was selected above, enter Agency name: N/A

Author name (Federal or State Project Manager): Pamela Tames

Author affiliation: EPA

Review period: 0212212008 to 0212212013

Date of site inspection: 10102112

.Type of review: Policy

Review number: 2

Triggering action date: 02/22/2008

Due date (five years after triggering action date): 212212013

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OUts) witho~t ~;ss~,e"RecolTllt'I!:nd!~ons,I~.e.ritif.i~ i':1.·jtI_~:§ly~~~e~~ R.Yi;;r~~ OU 1

Protectiveness Statement

Operable Unit: Protectiveness Detennination: Addendum Due Date OU 1 Protective (if applicable):

N/A

Protectiveness Statement: The implemented actions at the Rowe Industries site protect human health and the environment. The unsaturated soil (above the water table) has been remediated and allows for unlimited 'use. ".The groundwater remedy has been construc;ted and is operational. The affected residents have all been connected to a public water supply.

Sltewlde Protectiveness Statement

Protectiveness Determination: . Addendum Due Dele (if applicable): Protective . N/A

.Protectiveness Statement: The implemented actions at the Rowe Industries site protect human health and the environment. The unsaturated soil has been remediated and allows for unlimited use. The groundwater remedy has been constructed and is operational. The affected residents have all been connected to a public water supply..

VI

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I. Introduction

This second five-year. review for the Rowe Industries Superfund site, located in Sag Harbor, Suffolk County, New York, was conducted by United States Environmental Protection Agency (EPA) Remedial Project 'Manager (RPM) Pamela Tames. The review was conducted in accordance with the Comprehensive Five-Year Review Guidance,· OSWER Directive 9355.7-03B-P (June 2001). The purpose of five-year reviews is to ensure that implemented remedies protect public health and the environment and that they f\mction as intended by the site decision documents, . This report will become part of the site file.

This five-year review is being prepared in accordance'with a provision in Section 1.2.2 of the fiv,e-year review guidance, that requires a paljey five-year review be conducted for a pre- or post-Superfund Amendments and Reauthorization Act remedial action that, upOn completion, will not leave hazardous substances, pollutants, or contaminants on~site above levels that allow for unlimited use. ~d unrestricted exposure, but requires five years or more -to complete. The trigger for this second five-year review is'February 22. 2008, the approval date of the first five-year review. This five-year review provides background information, covers the site history, discusses past data-collection efforts along with information colle.cted in the past five years, re-evaluates risk 'and remedy protectiveness based on updated assumptions, and makes suggestions for follow-up actions.

This five-year review covers the entire site and has determined that the implemented remedy is functioning as intended and continues to protect human health and the environment.

II. Site Chronology

Table 1 summarizes the site-related events from discovery to construction completion,

III. Background

Site Location

The Rowe Industries site is situated on"Sag Harbor-Bridgehampton Turnpike in the Village of Sag Harbor, Suffolk County, New York. -It is located on the south fork of eastern Long Island, approximately 75 miles east of New York City. The-major roadways. in this area include Sag Harbor-Bridgehampton Turnpike and Noyack Road (see FigUre 1).

Physical Characteristics

The property is comprised of an eight-acre industrial facility. The most prominent feature of the property is a small factory covering one acre of the site with the remainder containing a small lawn area, parking lot,-several acres of oak forest, a rech~ge basin, and a small pond', .The oak forest and pond are part of the Long Pond Greenbelt, a protected ecological sanctuary. Residences are located on the' northern and so.uthl:;rn sides of the facility.

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Sag Harbor Cove is located about 3,000 feet n~rthwest of the site. Ugonee Brook., which flows into Sag Harbor Cove, is to the east and north of the site.

Site Geology/Hydrogeology

The site's geology is typical ,of the regional geology. The site is underlain by the Upper Glacial aquifer, which mostly consists of sand and gravel, with some silt and clay. The upper sediments ahove the water table consist ofmedium to fine sand with a trace amount ofmedium to fine gravel. The lower sediments below the water· table consist of medium to very fme sand, alternating with. intervals of silty clay, silt and clay.

Although no major clay layers were observed downgradient of the site, a local, continuous clay bed was 'observed beneath the former drum storage area, at a depth ofabout 30 to 40 feet below the land surface. The clay layer is about two feet thick aud it extends about 40 feet by 40 feet laterally. The top of the clay layer is about 5 to 10 feet below the water table. The depth to groundwater beneath the fonner drum storage area is about. 20 to 25 feet; groundwater levels in this area were observed to fluctuate by about 5 feet.

Groundwater flow direction is north-northwest and discharges into Sag Harbor Cove. Groundwater velocity averages about 1 foot per day.

Land and Resource Use

A manufacturer ofelectronic devices (Sag Harbor Industries), an ice c~eam company. a landscaping company; and an awning manufacturer currently occupy the building on the property.

The area surrounding the site is largely undeveloped to the east and west. Several designated ­wetlands in the vicinity of the site are considered to be significant habitats. The Nation Wetlands Inventory classifies the area where Ligonee Brook enters Sag Harbor Cove as a, mixture of palustrine forested, broadleaf deciduous wetlands and intertidal emergent estuarine wetlands communities. The on-site pond is classified as a palustrine, open water, intermittently exposed wetland community. One other significant habitat, a tern nesting area, is listed as occurring within two miles of the site along Noyack Bay. The tiger salamander is the only en-dangered animal known to live within two mifes of the site. It is listed as· endangered in the New York State Department of Environmental Conservation's (NYSDEC's) database. .

With respect to water use, groUndwater is. used as a potable water source by some local residents within a three-mile radius and as a source of irrigation water by- fanners. The residences located in the vicinity of the groundwater plume are connected to a public water supply.

History ofContamination

The Rowe Industries facility .was constructed in 1953 to manufacture small electric _motors and transformers. Chlorinated solvents were used to degrease oil-coated metals during the manufacturing process. Waste solvents were discharged into on-site dry wells andl9r stored

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• behind the facility, where they leaked into the soils below. The original building was completely destroyed by a fLTe in 1962, and was rebuilt that same year to twice the size of the original facility.

In November 1965, Aurora Plastics p~hased the plant and its equipment from Rowe lndustries.. The manufacture of the motors continued and Nabisco acquired Aurora Plastics in the early 1970's. The facility remained active until 1974, when Nabisco relocated- its operations and the building was closed.

The building remained empty until it was sold to Sag Harbor Industries in 1980. Solvents_are no longer used in the manufacturing process.

In/fiat Response

GroWldwater contamination was first discovered by the Suffolk County Department of Health in 1983. Water. from a private well near the site revealed contamination by three volatile organic compounds (VOCs). l.l.l-trichloroethane (TCA); trichlorethylene (TCE),. and tetrachloroethylene (peE). Further investigations determined that a groundwater contaminant plume extended from the fonner Rowe Industries facility northwest to Ligonee Brook. In 1985, twenty-five residences in the vicinity of the groundwater plume were hooked up to the public water supply. Based on the extent ofgroundwater contamination. the Rowe Industries site was placed on the National Priorities List on July 7,1987.

Basis for Ta/dng Action

During the remedial investigation (RJ), 32 wells were sampled to evaluate groundwater conditions. The highest concentration ofpeE found in the groundwater at that time was 12,000 micrograms per liter (Jlgll). TeA and TeE were also found in the groundwater. Their highest concentrations were 690 ~gIl and 530 ~gIl, respectively. The Maximum Contaminant Level (MCL) exceedances of these VOCs in groundwater and the conclusion of the risk assessment indicated that an unacceptable risk existed for on-site residents based on ingesting untreated groundv.:ater containing PCE from the Upper Glacial aquifer in the vicinity of the site. Soils in the fonner drum storage area exhibited levels ofPCE as high as 67 milligrams per kilogram. Three of the six dry ~ells had elevated levels of VOCs. The risk assessment concluded that soils on the site did not pose an

. unacceptable risk to human receptors, however, contamination in these areas, if not addressed, would likely continue to contribute -to further contamination of groundwater at the site.

IV. Remedial Actions

Remedy Selection

Based upon the results of the RI and feasibility study, in September 1992, EPA signed a Record of Deci~ion (ROD) selecting a remedy for the site. The remedial action objectives (RAOs) identified in the ROD include:

• the excavation of all con~inated soils which act as a contributor to the groundwater

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contamination; and • the restoration of groundwater quality to drinking water standards.

The remedy includes:

• .excavating and disposing of 365 cubic yards of soil at a Resource Conservation and Recovery Act-pennitted facility (soil will be treated to meet land disposal resuictions, if necessary);

• monitoring to confinn that soils with concentrations above site cleanup objectives have been exc3.vated;

• extraction and treatment of contaminated groundwater to meet federal and stale drinking water MCLs in the aquifer (groundwater will be treate<;l with air stripping with subsequent discharge to Sag Harbor Cove);

• long-tenn groundwater mo~toring to track the migration and concentrations of the contaminants of concern; and

• re-evaluation of the site at least once every five years to detennine if a modification to the selected alternative is necessary as long as contaminants remain on-site above health-based levels.

Subsequently, Nabisco, Inc. 1 and Sag Harbor Industries,Jnc. signed a Consent Decree with EPA .agreeing tq design and implement the selecied remedy for the site. A Notice 'of Lodging of the Consent Decree was published in the Federal Register on December 28, 1993. The Consent Decree was entered in U.S. District Court on April 21, 1994.

As part of the remedial design effort, the Potentially Responsible Pailies' (PRPs') contractor collected numerous soil and groundwater samples and performed a nUmber of groundwater tests necessary to prepare the design of the selected remedy. As a result of this sampling effort, the estimated volume of contaminated soil requiring excavation increased from the ROD estimate of 360 cubic yards to approximately 1,700 cubic yards. It was also.determined that approximately half of the excavated soils were more highly contaminated than originally believed, which would necessitate on-site pretreatment prior to off-site disposal in order to comply with the requirements of Resource Conservation and Recovery Act Land Disposal Restrictions. The selected remedy was modified yia· a July 1997 Explanation of Significant Differences (ESO) to include a partial excavation of the former drum storage area, the installation of in-situ Soil Vapor Extraction (SVE) wells to remediate the remaining. unsaturated contaminated soil"s and air sparging wells to assist in the remediation ·of the saturated contaminated soils during extraction and' treatment of the· groundwater. In addition, the ESD called for the pretreatment of the excavated soils using ex-situ SVE.

The ROD also called for the treated groundwater to be discharged in Ligonee Creek/Inner Sag' Harbor Cove. However, in response to public concerns about potential impacts resulting from the discharge of fresh water into a saline environment, the remedy was modified so as to allow for the discharge of the treated groundwater to a recharge basin (the Town of Southampton granted the

Kraft acquired Nabisco Inc. in 2000.

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PRPs access to the Town's property for the construction of a rec~arge basin)2.

Remedy Implementation

In late 1997, Leggette, Brashears & Graham, Inc., the PRPs' contractor, hired a local well driller to install the SVE wells. A contract was awarded by the PRPs to Handex Inc. in April 1998 for the implementation of the remaining portions of the soil remedy.

In February 2000~ a well-drilling contract and a groundwater extraction and treatment system contract were awarded by the PRPs to Earth Technology LLC for the implementation of the groWldwater remedy.

Contaminated Soils and Dry Wells

The contaminated soils associated with the former drum storage area spanned a portion of the parking lot behind the facility and two adjacent residential properties. Site construction work commenced in late 1997, with the installation of six SVE wells (IO-foot-Iong screens starting at depths ranging from 4-17 feet below the surface) into the Wlsaturated soils and associated piping beneath the parking lot. In April 1998,230 cubic yards ofVOe-contaminated soils located on the adjacent residential properties were excavated to a depth of four feet. In May 1998, 9 SVE wells and associated piping were installed on the adjacent residential properties within the former drum storage areal. Subsequently, a 40-mil high density polyethylene vapor barrier was installed at the bottom of the four-foot excavation, followed by clean fill and top soil. Disturbed areas of the site were subsequently seeded and a number of pine trees were planted to provide a privacy hedge between the two affected residents' properties and the plant groUJ!.ds.

An ex-situ treatment system, consisting of a soil impoWldment containing SVE-piping Wlderlain with a 40-mil high density polyethylene liner was constructed adjacent to the excavation area behind the facility. The excavated soil was placed within the treatment system and sealed with high density polyethylene. Soil vapors were extracted from the system and piped through two l,250-pound carbon units in series. The SVE system in the soil impoundment operated from January 28, 1999 to March 11, 1999. On April 8, 1999,22 soil samples were collected from the excavated soils within the soil impoundment and analyzed to determine if sufficient vacs had been removed prior to off-site disposal. The soils were disposed of at an off-site landfill in

2 This modification to the remedy was effected via two ESDs. In response to the public's concern regarding discharging the treated effluent into a saltwater environment, in May 200 I, EPA issued an ESD documenting a decision to split the discharge between surface water and a recharge basin. However, since the public objected to having any surface water discharges, in December 2001, EPA issued another ESD documenting a decision to discharge all of-the treated groundwater into a recharge basin.

3 Air sparge wells to assist the removal of the VOCs from the contaminant plume were installed into the saturated soils under the parking lot behind the facility and the two adjacent residential properties concurrently with the installation of the SVE wells in the unsaturated soils. Details related to this effort are discussed in the "Groundwater Remediation" section, below.

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mid-1999 and the soil impoundment was subsequently dismantled.

The three dry wells were pumped out in June 1998 and their contents were disposed of off-site. Approximately. 120 cubic yards of contaminated soil in the vicini~y of a broken pipe leading to' a fourth. dry well (the contents were not contaminated) were excavated in February 2003 and disposed of off-site.

The in-situ SVE system Was started up in December 1998. Various pairs ofSVE wells were run in cycles so that the VOC vapors in the unsaturated soils were extracted from all directions and ' pumped through the two carbon units. In October 2000, twenty-eight soil borings were drilled to collect 38 soil samples from the treated soils. Soil analyses revealed that while the majority of the soil had been remediated, seven samples within a 300-square-foot section of the former drum storage area remained contaminated above the New York State technical and Administrative Guidance Memorandum (TAGM) objectives ranging from 3,100 micrograms per kilogram (~gIkg)

to 4,200,000 ~gIkg for PCE. ,The SVE'system was restarted using a single SVE well which was run in a pulsed' fashion (two weeks on and one week oft) from mid-December 2000 to April 2002 in order to address the remaining hot spot. A second round of soil confirmation samples was collected in April 2002. Analyses of twenty-three. soil samples revealed that the SVE system continued to remediate the unsaturated soils, with only five samples containing VOC concentrations that exceeded the TAGM objectives, ranging from 3,400 ~gIkg to 5,300 ~gIkg PCE. ' The SVE system was restarted in June 2002 to complete the remediation'of the unsaturated soils within the former drum storage area. A third round of corifirmation samples was collected in January 2003. Analyses ofnine soil samples revealed that the SVE system continued to reme4iate the Unsaturated soils, with only thre,e samples containing VOC concentrations exceeding the TAGM objectives, ranging from 1,800 ~gIkg to 21,000 ~gIkg PCE. It was determined that these three soil samples were located within the saturated zone much of the year due to the seasonal fluctuation of the groundwater table. A bioremediation pilot (see .the "System Operations/Operation and Miuntenance" section, below) was used 'in an attempt to address the contamination in this area in November 2004. ,This area is being addressed by the continued operation of the full-scale groundwater extraction and treatment system. Following the conclusion that all of the soils within the unsaturated zone had been successfully remediated by the SVE system (approximately 690 pounds of VOCs were removed), a Remedial Action (RA) Report for the soil was approved in March 2005. '

Gr.oundwater Remediation

The groundwater extraction and treatment system construction began in 1996. The groundwater extraction system consists of nine recovery wells. The groundwater treatment system consists of influent equalization, pre-filtration using a series of three stations of eight bag filters, and air stripping with discharge of the treated effluent to two 50- by ISO-foot recharge ,basins. The VOC-con~inated air stream' generated by the air stripping is being treated with activated carbon before being released to the atmosphere. The air stripper tower has been equipped with an acid backwash system for maintenance associated with tower fouling. The design' flow is 535 gallons per minute. The system became operational on December 17, 2002.

Eleven air sparge wells to assist the removal o(the VOCs from the contaminant plume were

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, installed in the fonner drum storage area; two on the plant grounds and nine on the adjacent residential yards. The air sparge wells, which had two-foot screens, ranged in depth from 30 to 50 feet into the saturated soils. The air sparge wells .were activated in February _2003 and decommissioned in December 2004.

Prior to the ipstallation of the SVE and air sparge wells within the former drum storage area, fOUf

ge9probe borings were drilled to determine the bottom elevation of the plume for proper placement of the air sparge wells. This investigation revealed the· existence of a clay lens located approximately seven feet below the water table. The clay locally impedes vertical groundwater flow and contaminant transport. An order-of-magnitude difference between the analytical results of groundwater samples collected above and below the clay lens near the top of the saturated soils indicated that the clay lens was retaining VOCs, P9ssibly due to its concave shape. In October 2000, four small focused recovery wells (FRWs) and below grade piping were installed in this area in order to perform "focused remediation" of the groundwater within the former drum storage area. The four wells were designed to pump at a variable flow rate averaging about 47 gallons per

-minute. The groundwater was pumped into a 425-gallon equalization tank before being sent through two I ,OOO-pound carbon units placed in series. The treated water was then piped into an existing on-site pond. The system began operation in March 2001 and operated until December 2003.

A Preliminary Closeout Report (PCOR) was approved in February 2003. An interim RA Report for the grolUldwater was approved in September 2003.

Institutional Controls Implementation

Since the contaminated soils have been remediated to levels that prot~ct human health and the groundwater, they are suitable for unlimited use. The monitoring and recovery wells are protected from invasive activities on -the adjacent residential properties with access/use agreements. The recharge basins were constructed on Town-owned property that is protected with· a conservation easement.

The affected residents have all been connected to the public water supply. Since Town of Southampton regulations prohibit the construction and use ofdrinking water wells unless tested and certified as clean by the Suffolk County Department of Health, Office of Drinking Water, no further controls are necessary to safeguard public health with respect to the site.

System Operations/Operation and Maintenance

The Operation and Maintenance (O&M) Manual for the site contains the procedures for operating, inspecting, and evaluating the grolUldwater extraction and treatment system along with the long-term monitoring of groundwater. Repairs are to be made, as necessary, to control the effect of any event that might interfere with the performance" of the remedy.

Scheduled O&M activities include weekly inspections of the overall site and the groundwater extraction, and treatment system (checking the bag filter for "!,lolids loading, gauging air flow through the stripper, and npting flow rates and totalized flow). Preventive maintenance items

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include monthly inspections of the air stripper- blower and the well pumps for mineral deposits. The recovery wells, effluent water quality and pre-, mid-, and post-carbon air are sampled monthly. Sl,Jrface water elevations are taken in the nearby ponds of the Long Pond,Greenbelt, and salinity and temperature measurements are taken 'at various points in Ligonee Brook. Surface water piezOmeter data is collected during the months of June. July, AUgU:St and September and compared to historical data collected from 1993 to ZOO7, a period prior to any remedial activiti~.

In November 2004. the former drum storage area was treated using a bioremediation pilot. Several injections ofEHC™. which contains zero-valent iron and an enriched carbon nutrient source, were. performed at the site. Gro~dwater samples taken from the FRWs showed that while some degradation took place as a result of the injection, the main benefit of the treatment was accelerated loosening and partitioning ofVOCs from the soil to the groundwater. Due to a lack of significant decrease in the concentration ofVOCs in the groundwater in the viCinity of the former drum storage area, the "focused remediation" of this· area was restarted in May 2006. The "focused remediation" system ran intennittently until April 2007, when it was shut down due to clogging of the system with mobilized EHC™. The system was restarted in'September 2008 and it ran witil July 2012. The groundwater in this area is currently being monitored to evaluate groundwater quality within the fonner drum storage area under nori·pumping ·conditions. An assessment of rebound of contaminant conce~trations during static conditions and an evaluation of alternative technologies to ex~ite the cleanup of the remaining contaminants is being perfonned.

One recovery well was shut down in July 2005 with EPA's-perrnission after exhibiting non..<fetect levels of contaminants for several years. In the 2010 Annual Summary Report for the site (dated November 2011). LBO requested permission to discontinue extracting groundwater from four. additional" recovery wells which had exhibited "non detect" levels of VOCs for over one year. EPA, after a review of the 'data and with the concurrence·ofNYSDEC, approved this request In a lenerdated May 1,2012..Recovery wells RW·2, RW-4, RW-6, and RW-7 are currently operating.

To date, more than 1.3 billion gallons of grouo.dwater have been treated and ,approximately 225 pounds ofVOCs'have been removed from the groundwater plume via this system.

When the groUndwater extraction and treatment system automatically shut down 'due to power failures or operational difficuliies, repairs and manual restarting of the system previously awaited the scheduled weekly visit of the operator. To improve the overall operational·efficiency of the system, Ii Sag Harbor Industries' employee was recently trained to restart the system.

The PRPs were not required by the tenos of the Consent Decree to make cost infonnation available. The inspections. maintenance, sampling, monitoring, data evaluation and reporting costs are· estimated to be $300,000 on an annual basis.

V. Five-Year Review Process

Administrative Components

The five-year review team consisted of Pamela Tames (RPM), Michael Scorea (hydrogeologist),

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Charles Nace (human health and ecological risk assessor),

Community Involvement

Following the completion of the five-year review, the EPA Community Involvement Coordinator (CIe) for the Rowe Industries site, Cecelia Echols, will publish a notice in the Sag Harbor Express; , a local newspap'er, notifying the conununity of the findings of the five-year review. The notice will also indicate'that the five-year review will be made available in the local site repository. In addition, the notice will include the addresses and telephone numbers for the RPM and CIC for questions related to the five-year review process or the. Rowe Industries site..

Document Review

The documents, data, and infonnation which were reviewed in completing the five-year review are summarized in Table 2.

Data Review

The primary compounds of concern detected in the groundwater at the site are PCE, TCE, and TCA. The Maximum Contaminant Level (MCL) for all three compounds is 5 ~gn. Based upon a

. review and trend analysis ofthe data collected from the monitoring and extraction wells. it has been· concluded that the downgradient groundwater VOC plume has decreased significantly in size and magnitude since remedial activities began.

Monitoring well cluster MW-49, whicb consists of monitoring wells MW-49B (68 feet deep}·and MW-49C (100 feet deep), is near the farthest downgradient extraction well RW·9 (see Figure I). The monitoring wells and the extraction well originally had elevated PCE cpncentrations, but PCE concentrations in al~ of these wells have bee.n less than 5 ~g/l since 2007. TCE and TeA concentrations in these wells have been less than 5 ~gIl since 2003.

Extraction wells RW-8 and RW-7 are the second and third most downgradient extraction wells, respectively. Both.have shown declines in their PCE concentrations from over 100 ~g11 to less than 5 Jlgll since 2010. The TCE concentrations in extraction wells RW~7 and RW-8 have been less than 5 ~gIl since 2003 and 2006. respectively. The TCA concentrations in extraction wells RW-7 and RW-8 have been less than 5 ~g/1 since 2007 and 2002, respectively.

Monitoring well cluster MW43 is just upgradient of extraction well RW-6. Monitoring well MW-43B (74 feet deep) was the most affected well ill the cluster. Its PCE concentrations have been below 5 ~gIL since 2010. TCA and TCE concentrations in the well cluster have been below 5 ~g/1

since 2002 with the exception of the TCA concentrations in monitoring well MW-43A (29 feet deep) which were between 5. and 7.6 ~g/1 in2011 arid 2012. PCE concentrations in extraction well RW·6 have shown a steady decline and have also been below 5 ~g/I since 2010. TCE and TCA concentrations in extraction well RW-6 have been below 5 ~g/1 since 2002 and 2010, respectively. Water'levels at RW-6 are anomalously low and could result from localized conditions in soil type or well construction. .

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Just downgradient of the source area, PCE concentrations at monitoring well cluster MW-44 have also greatly declined and have remained below 5 ~gll in all three wells since 2003. TCE and TCA concentrations in all three wells have remained below 5 Ilg/1 sinc~ 2002 and 2008, respectively.

In addition to the four extraction wells noted above, none of the three on-property (RW-I, RW-2, RW-3) or two other off-property extraction wells (RW-4 and RW-5) have had levels ofPCE, TCE, or TCA above their respective MeL since December 2010. As previously noted; EPA agreed to the PRP request to discontinue extracting groundwater from five of the extraction wells. Extraction wells RW-2, RW~4, RW-6, and RW-7 are currently operating. Groundwater continues to be monitored in all of the recovery wells for any: changes in chemical conditions that could result

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"from the shutdown. Figure 2 shows plume maps from 2002..2007 and 2012.

During the most recent sampling round in September 2012. the level ofPCE ,in the monitoring wells and FRWs in the fonner dnim storage area ranged from 6.1 ~gI1 to 130 ~gll. TCA concentrations were below the MCL in all wells except for monitoring well MW-43A (5.7 ~gI1) and FRW-I (5.8 Ilg/I) in the former drum storage area. TCE concentrations were below the MCL in all wells except for FRW-I (39 ~gI1) and FRW-2 (13" ~gI1). Since groundwater samples from monitoring wells in the former drum. storage area still contain -elevated levels of VOCs, the injection of the EHCTM in this area has not yet completely removed .the source contamination. Additional peE, TCE, and TCA concentration data can be found in Tables 3a, 3b, and 3c.

A review of the salinity, surface water, and piezometer data indicate that the pumping of the aquifer. does not adversely affect the nearby ponds of the Long Pond 'Greenbelt, Ligonee Brook, and Ligonee Creek. .

Site Inspection

On October 2,2012, a five-year review;.related site inspection was conducted by Pamela Tames,' Michael Scorca, and Charles Nace. Paul Jobmann (PRP consultant LBG, Inc.) and Lisa Krogman (Kraft) were also present at the site inspection.

There were no visible signs of trespassing or vandalism- at the site. All of the well casings were found to be properly secured and locked. The treatment system building was found to be properly secured and locked. - The fence surrounding the recharge. basins was intact and its gate was secured.

Interviews

An interview was conducted on October 2, 2012 with Paul Jobmann ofLBG Inc. and Lisa KrogmaJ.1 of Kraft for this review.

Institutional Controls Verification

As was noted above, since the contaminated soils have heen remediated, soil-related restrictions are' not needed. The affected residents have all heen connected to the public water supply and cannot reconnect to a private well 'without Department of Health approval.

10

Other Comments on Operation, Maintenance, Monitoring, and Institutional Controls

Table 4 presents an observation and offers a suggestion to resolve an outstanding issue.

VI. Technical Assessment

Question A: Is the remed)' functioning as intended by the decision ,-,ocument5?

The remedy identified in the ROD consisted of soil excavation' with off-site disposal and installation ofa groundwater extraction system.with on-site treatment and discharge to local surface water. The SOli excavation remedy was modified in the 1997 ESD to include the additional volume of soil and on-site treatment ofsoils prior to off-site disposal. The groundwater extraction remedy was modified in the May 2001 and December 2001 ESDs to change the discharge location from Ligonee Creek to a recharge basin. The imple~ented actions for the soils have effectively eliminated the exposure pathway for contact with contaminated soils. Post-excavation and SVE· sampling indicate that vadose zone sources of contamination have been effectively remediated. The soils remedy has been completed.

The groundwater extraction and treatment system has greatly reduced the extent and magnitude of the downgradient groundwater plume. Groundwater sampling results indjcate that saturated soils in the vicinity of the drum storage ar~ are still contaminated. Adqitional groundwater data is being collected in this area to assess the impact of the residual source areas on the groundwater and evaluate alternative· technologies to addres.s the source.

All residents in the area are served by municipal water. The property is owned by Sag Harbor Industries and fencing around the property prevents trespassing.

Question B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action objectives used at the time ofthe remedy stU! valid? .

The ROD'summarized the human health risk assessment that was conducted to support the RA for the site. - .

There were seven" exposure pathways that were evaluated including, residential exposure to groundwater through ingestion and inhalation. ingestioQ of sUrface soil by residents. ingestion of. subsurface soil by excavation workers and utility workers, ingestion of sediments from Ligonee Brook by residents, and ingestion of dry well sediments by utility workers. Although the groundwater has not attained the goals set in the ROD, the groundwater pathway is not complete due to municipal water ~ing supplied to the community; the exposure pathways for the soil are no longer complete as the soils have been remediated; and the exposure pathway for the sediment is no longer complete since the contaminant plwne no longer extends to Sag Harbor Cove. The vapor intrusion path-",ay was previously evaluated; no further action was required (see the discussion, below).

11

.' The toxicity data that were used in the humari health risk assessment have changed since the risk assessment was completed. However, using.current toxicity values in the risk assessment would result in the same risk management deci~ion for the soil and groundwater; therefore, the toxicity data is still valid.

The cleanup levels for groundwater identified in the ROD were the Safe Drinking Water Act Max'imum Contaminant Levels and the NYCRR Groundwater Quality Regulations. These regulations still apply.

The RAOs identified in the ROD include restoration of groundwater quality to its intended use of ,potential drinking water by _reducing- contaminant levels to state and federal drinking water standards and remediation of the contaminated soil to the. recommended soil cleanup objectives in

, order for the soil not to be a contributor to groundwater contamination. The remedial action objectives used at the time of the remedy selection are still valid.

Vapor intrusion was not evaluated in the ROD; however, in 1997 prior to any remedial activities, indoor air monitoring was' performed in six residences located over the plume. That study, concluded that voes were not found in affected residences above'background levels. A subslab vapor intrusion investigation was perfonned in mid-February 2008. The data collected during the. subslab vapor intrusion investigation was evaluated and determined that no additional actions are required. Future monitoring is also not required due to the greatly reduced size ofthe groundwater plume.

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

No information has come to light that could call into question' the protectiveness of the remedy.

Technical Assessment Summary

Based upon the results of the five-year review, it has been concluded that:

• Groundwater extraction and treatni.ent has greatly reduced the extent and magnitude of the downgradient groundwater plume;

• . The monitoring and recovery wells are securely locked and,functional; and • ,No additional measures are needed to protect public health.

Although the groundwater management system appears to be effectively' addressing the contaminated groundwater plume, it will need to continue to operate as long as there is source material in the saturated zone in the vicinity of the fonner drum storage area. Despite efforts to remediate this source material in-situ, the levels of contaminants are still elevated. If the focused remediation system does not prove to be effective in addressing the source material, consideration should be given to alternative source remedial approaches.

12

VII. Issues, Recommendations, and Follow-Up Actions

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

VIII. Protectiveness Statement

The implemented actions at the Rowe Industries site protect human health and the environment. The unsaturated soil (above the water table) has been remediated and allows for unlimited use. The groundwater remedy has been constructed and is operational. The affected residents have all been connected to a public water supply. -

IX. Next Review

The next review for the Rowe Industries site should be completed within five years of the date of this review.

13

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SEPTEMBER 2012 PCE PLUME MAP

~

~ o 500 I

:>\;ALL IN fEU

GROUNDWATER REMEDIAL ACTION FORMER ROWE INDUSTRIES SUPERFUND SITE

SAG HARBOR, NEW YORK ----------tl

PIl.F,REMr:DlATION AND OCTOBER 2007 AND SEmMBER 2\'12 reI: PLUMH MAl'S

Iamrm: 15_ fW) I 00l: 01/'0/13 I /lGUlC :2,

•

Table 1: Chronology of Site Events

Event Date(s)

Discovery of Contaminated Groundwater 1983

EPA Action to Connect Residences to Public Water Supply 1985

Site Added to the NPL 1987

Administrative Order on Consent to Potentially Responsible Parties by EPA 1988

Remedial Investigation and Feasibility Study 1988~1992

Record of Decision 1992

Consent Decree supersedes Administrative Order on Consent 1994

Remedial Design 1994-2001

Explanation of Significant Differences 1997

Explanation ofSignificant Differences (May) 2001

Explanation of Significant Differences (December) 2001

Groundwater Remedial Action Commences 2000

Soil Remedial Action 1997-2003

Preliminary Close-Out Report 2003

Groundwater Remedial Action Report 2003

Soil Remedial ~ction Report 2005

First Five-Year Review 2008

.

.

Table 2: Documents, Data, and Information Reviewed in Completing tbe FivewYear Review

Document Title Author

Remedial Inv~stigationJFeasibility Study, Leggette, Brashears & Graham, Inc.

Record'ofDecision. EPA

Final Design Reports for Soil and Groundwater, Leggette, Brashears & Graham Inc.

Occurrence and Significance of a Clay Lens Beneath the Water Table in the Vicinityofthe Former Drum Storage Area, Leggette, Brashears & Graham, Inc. Recovery Well Installation Report, Leggette, Brashears & Graham, Inc.

Submittal Date

1992

1992

1997 & 2001

1999

2000

Operation and Maintenance Monitori~g -Manual, Leggette, Brashears & Graham, Inc. Focused Pump & Treat Operation S.ummary, Leggette. Brashears & Graham, Inc.

Drywells A and G Investigation, Leggette, Brashears & Graham, Inc.

2001

2001

2002

Focused Ground-Water Remediation System Operation Summary (January 1,2002 - June 17,2002), Leggette, Brashears & Graham, Inc.· .

2002

Preliminary Close-Out Report, EPA

Post-Closure Monthly Groundwater Quality Monitoring Reports, Leggette, Brashears & Graham, Inc.

Draft. EHC Moni~oring Report, March 2005 to September 2005, Ground-Water Remedial Ac~ion. Leggette, Brashears & Graham, Inc.

2003

2008-2012

2005

2011 Annual Summary Report, Leggette, Brashears & Graham, Inc. 2011

Groundwater sample Results (September 2012), Leggette, Brashears & Graham, Inc.

EPA guidance for conducting five~year reviews and other guidance and regulations to detennine ifany new Applicable or Relevant and Appropriate Requirements relating to the protectiveness of the remedy have been developed since EPA issued the ROD..

2012

TABLE 3 a

2012 ANNUAL SUMMARY REPORT FORMER ROWE INDUSTRIES SUPERFUND SITE

1668 SAG HARBOR TURNPIKE SAG HARBOR, NEW YORK

CURREI\'T AND mSTORIC CONCENTRATIONS OF PCE DETECTED IN GROUNDWATER FROM MONITOR AND RECOVERY WELLS, ugll

Sam Ie Dates Monitor or

RKo\'ery'Vells 9/02**

Mar-OJ Sep-03 ~1ar-04 Jul--04 Sep-04 Jau-OS Mar-O May-OS Jun-OS Aug-OS """IS D~"" Mar--O(j Sep-06 Mar-O Oct-07 l\hr-O Sep-O' l\hr-09 Sep-09 Mar-l0 Sep-l0 Mar-ll Sep-ll Mar-12 Jun-12 Sep-12• MW-B1 ND ND ND ND ND ND ND ND ND ND ND ND ND ND MW-B2 ND ND ND ND

W-B3 ND ND MW-B4 ND ND ND ND ND FRW-I 300 8S 110 36 18 210 ISO 32 24 II 670 110 310 41 380 600 6~ 110 IS 160 180 6. 37 37 52 130 FRW-2 0.7 24 51 28 150 130 200 380 420 190 10 450 450 2.5 5.7 ND 27 n 24 20 33 ISO 39 24 25 48 69

W­ 94 98 ISO 230 67 1500 480 no 110 63 1000 920 480 110 .9 62 16 270 110 190 110 19 16 Il 65 IS

FRW-4 Il Il 10 4.2 2.5 36 34 4.8 ND 4.5 2.3 18 17 53 53 ND 4.5 22 22 21 6.1 RW-1 ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND RW-2 110 26 7.9 4.9 Il 20 16 6.5 2.8 ND 1.4 3.4 4.0 1.8 1.0 ND 0.91 J 0.96 J 0.81 0.57 0.52 RW-3 30 2.4 2. l.2 2.7 3 .1 ND ND ND ND ND ND ND ND ND ND 0.19 ND ND RW-4 590 150 210 170 110 45 22 9 73 9.4 6~ 3.8 3.3 4.5 2.1 ND 0.82 J 1.1J 1.4 0.13 J 0.95 RW-5 ND 19 IS 14 24 14 8 2.6 ND ND ND ND ND ND ND ND ND ND ND 0.16 ND ND RW-6 146 130 140 110 130 110 100 65 46 29 14 19 13 10 II 7.0 4.3 1.9 3.6 J 3.2 3.1 2.8

W-7 350 160 110 100 " 42 39 38 36 23 25 II 5.4 5.5 9.5 .6 ND .8 -­ 2.2 .0 0.7 RW-8 100 70 30 22 9 2.9 1.3 ND ND ND ND ND ND ND ND ND ND ND 0.11 J 0.10 J RW-9 II 23 25 ND 3.7 ND 1.2 1.3 ND ND ND ND ND ND ND ND ND ND ND ND ND ND

MW-28A

MW-28B

MW-28A ~ 1.3 13 8.9 ND 2.7 ND ND ND ND 21 ND ND ND ND ND ND ND MW-28B (New 1.2 ND ND ND ND ND ND ND ND ND ND ND ND ND ND

MW-42A ND MW-42B ND ND ND ND ND ND ND ND ND ND ND ND ND MW-42C ND ND ND MW-43A ND ND ND ND ND ND 2.3 1.2 MW-43B 180 110 200 ND ND ND 7.6 1.5 ND ND ND ND ND ND Il 2.7 1.0 4.5 J 3.4 ND

-43 ND ND ND 52 ND 20 ND 27 ND ND ND ND ND ND ND ND ND ND ND MW-44A 8.7 ND 1.2 ND ND ND ND ND ND ND ND 1.1 0.66 J ND ND ND ND 0.11 J MW-44B ND ND 1.5 ND ND ND ND 5.0 ND ND ND ND 3.1 ND ND ND 0.16 J 0.30 J MW-44C ND ND ND ND ND ND ND ND ND ND

-4 .0 32.0 ND ND ND ND ND ND ND ND ND ND O.

MW-45B ND 34 ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND MW-46A 14 ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND MW-46B ND ND ND ND ND ND ND ND ND ND

-47 .3 21 16 .7 .8 .5 .2 .77 .27 MW-47B ND ND ND ND ND ND ND ND ND ND ND MW-48A ND ND ND ND ND ND ND ND MW-48B ND ND ND ND ND ND ND ND ND ND ND ND ND MW-49A ND ND ND 29 ND 25 2.2 ND ND ND ND 5 ND ND ND ND ND ND O. J

MW-49B 230 ISO IS ND 53 35 26 7.6 6.8 2.1 3 4.6 3.6 2.3 1.4 ND ND ND 0.60 0.89 0.43J ND

K-~Foods GkJl*, IncV«JWE In<kJolries\Grc ~SP&T\GW~121Sept20121 T_ PCE_TeE_TCA 2012.x1u 1 of 2 LOG ENGINEERING SERVICES, P.C.

2012 ANNUAL SUMMARY REPORT FORMER ROWE INDUSTRIES SUPERFUND SITE

1668 SAG HARBOR TURNPIKE SAG HARBOR, NEW YORK

CURREI\'T AND mSTORIC CONCENTRATIONS OF PCE DETECTED IN GROUNDWATER FROM MONITOR AND RECOVERY WELLS, ugll

Sam Ie Dates Monitor or

RKo\'ery'Vells 9/02**

Mar-OJ Sep-03 ~1ar-04 Jul-04 Sep-04 Jau-OS Mar-O May-OS Jun-OS Aug-OS """IS D~"" Mar--O(j Sep-06 Mar-O Oct-07 l\hr-O 5ep-OS l\hr-09 5ep-09 Mar-tO Sep-tO Mar-ll Sep-ll Mar-12 Jun-12 Sep-12• MW-50A ND ND ND ND ND ND ND ND ND MW-50B ND ND ND ND ND ND ND ND ND ND ND ND MW-50C ND ND ND ND ND ND ND ND ND

• 2A ND ND ND ND ND ND ND O. 2 MW-53 3.2 3.0 ND ND ND 0.71 J 0.4 J ND ND 0.72 0.31 J MW·54 2.0 4.6 1.2 1.2 1.5 5.1 0.32 J ND 0.80 J 0.42 J 0.44 J MW-55 ND ND ND ND ND ND ND ND

• 6A MW-56B ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND MW-56C ND ND ND ND ND ND ND ND ND ND ND ND ND ND MW-57A ND ND ND ND ND ND MW- 7B ND ND ND ND ND ND ND ND ND MW-57C ND ND ND ND ND ND ND ND ND

. .

. . MW-98-02A

I 'iiF·~2B ~ "'

, -98-05 070 600 260 79 760 190 200 ,., 0' 37 190 4.' 14

MW-98-05B ND ND ND 66 78 .. ND ND ND ND ND ND ND -98-06A

MW-98-06B ND MW-98-07 ND

I ~98-08 • 7

N-IA ND ND ND ND ND ND N-1B ND ND ND ND ND ND ND ND ND ND ND N-2A ND ND ND ND ND ND

·28 ND ND ND ND ND ND ND ND ND ND ND N·6

N·' ND ND ND ND ND ND N-ll

· 6 ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND N-17 ND ND ND ND ND ND ND ND ND ND ND ND N-32 ND ND ND ND ND ND ND ND ND N-37 ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND

· .8 ND ND ND ND ND ND ND ND ND ND N-39 0.7 10 3.2 6.0 6.8 ND ND ND ND I., ND ND ND ND ND ND ND ND ND

• EffillC1lt sample: from focus pmnp and trc:al •• DBS - Sample: colle:cted using diffusive: bag sample: mc:thod

••• Collccte:d after 4 hours of pumpiug during e:Xe:CUtiOll of Initial Te:stiug Plan

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2012 ANNUAL SUMMARY REPORT FORMER ROWE INDUSTRIES SUPERFUND SITE

1668 SAG HARBOR TURNPIKE SAG HARBOR, NEW YORK

CURRENT AND HISTORIC CONCENTRATIONS OF TCE DETECTED IN GROUNDWATER FROM MONITOR WELLS AND RECOVERY WELLS, ugll

Sample Dates Monitor or

Reoonry \Vells 9/02·". Mar-03 Sl'p-03 Mar-04 Jul-04 Sep-04 Jan-05 Mar-05 #####. Jun-06 Aug-06 ")HIS Dec-05 Mar-06 ")HI6 Mar-07 Oct-07 Mar-08 Sep-08 Mar-09 Sep-09 Mar-lO Sep-lO Mar-II Sl'p-1I Mar-12 Jun-12 Sep-12

MW81 ND ND ND ND ND ND ND ND ND ND ND ND ND ND MW ND MW83 ND ND ND ND ND MW84 ND ND ND ND ND FRW I ND ND ND ND ND 1.6 ND ND ND ND ND ND ND ND 7.' no ND 2.4 ND 1.2 3.1 ND ND LO 3.7 " FRW ND ND ND ND 14 7.4 15 6.2 12 12 ND " 13 ND ND ND 10 19 ND ND 1.7 18 ND 4 , 0.83 13

W ND ND ND ND 1.' 31 '.2 28 13 1.7 77 41 4.5 16 20 " 6.6 10 12 3.2 12 6 4 FRW-4 ND ND ND ND ND ND 2.4 ND ND ND 0.99} ND ND ND ND 4.5 ND 0.99 } 1.2 L6 0.33 }

RW I ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND RW 1.4 1.' ND ND ND 1.1 1.' 3.5 ND ND ND ND ND ND ND ND ND ND O. 6} 0.21 02 J

W D 3.6 5.' 5.0 2 13 3.6 3.4 ND 2.2 ND 2.5 ND 1.4 3 D 0.' ND ND RW-4 '.5 3.6 5.7 5.' 3.7 ND ND ND ND l.l 0.57} ND ND ND ND ND ND ND 0.18 0.13 } 0.15 J RW5 ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND

W l.l 1 2.2 2.7 3.3 2.3 1.6 .2 ND ND ND ND ND ND ND ND D ND 0 J RW7 5.2 " 2.3 3.0 2.2 1.5 N N 0.73 ND N ND RW' 6.6 2.' 1.7 2.7 , ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND RW' 3 2.2 1.2 2.2 1.0 1.4 ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND

A

MW-288

MW28A ~ ND ND ND ND 3.2 ND ND ND ND 13 ND ND ND ND ND ND ND MW- 88 'w ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND

MW42A ND MW-428 ND ND ND ND ND ND ND ND ND ND ND ND ND MW-42C ND ND ND

~43A ND ND ND ND ND ND O. 6 J 0.22 J -48 1.' ND ND ND ND ND ND ND ND ND ND 2.' ND D ND ND ND

MW-43C ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND

44A ND ND ND ND ND ND ND ND ND ND ND ND ND D ND ND ND -448 N N ND N ND

MW-44C ND ND ND ND ND ND ND ND ND ND ND

MW-45A ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND

MW-458 ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND

MW46A 5.6 ND ND ND ND ND ND 0.59 ND ND ND ND ND ND ND ND 0.24 J ND MW-468 ND ND ND ND ND ND ND ND ND ND ND MW47 16 3.' ND ND ND ND 0.97 14 ND ND 2.' ND ND 7 0.77

MW-478 ND ND ND ND ND ND ND ND ND ND

MW-48A ND ND ND ND ND ND ND ND

MW-488 ND ND ND ND ND ND ND ND ND ND ND ND

MW-49A ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND

MW-498 6.4 31ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND

MW-49C ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND

K:UobslKrall Foods Global, Inc\ROWE IndustriesIGround Water\O&M\FSP&T\GW salflllingl2012\Sept 201 ZI Table PCE-TCE-TCA 2012.xtsx LOG ENGINEERING SERVICES, P.C.","

2012 ANNUAL SUMMARY REPORT FORMER ROWE INDUSTRIES SUPERFUND SITE

1668 SAG HARBOR TURNPIKE SAG HARBOR, NEW YORK

CURRENT AND HISTORIC CONCENTRATIONS OF TCE DETECTED IN GROUNDWATER FROM MONITOR WELLS AND RECOVERY WELLS, ugll

Monitor or Reoonry \Vells

Sample Dates

9/02·". Mar-03 Sl'p-03 Mar-04 Jul-04 Sep-04 Jan-OS Mar-OS #####. Jun-06 Aug-06 ")HIS Dec-OS Mar-06 ")HI6 Mar-07 Oct-07 Mar-08 Sep-08 Mar-09 Sep-09 Mar-lO Sep-lO Mar-II Sl'p-1I Mar-12 Jun-12 Sep-12

MW-SOA NO NO NO NO NO NO NO NO NO

MW-S08 NO NO NO NO NO NO NO NO NO NO NO NO

MW-SOC NO NO NO NO NO NO NO NO NO

MW S2A NO NO NO NO NO NO NO NO NO NO NO MW~ NO NO NO NO NO NO NO NO NO NO NO

NO NO NO NO NO '.6 NO NO NO NO NO MW-SS NO NO NO NO NO NO NO NO

MW S6A NO NO NO NO NO NO NO NO NO NO

~68 NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO

MW S~A NO NO NO NO NO NO NO NO NO NO NO NO NO

NONONO NO NO NO

MWS78 NO NO NO NO NO NO NO NO NO

~~ NO NO ::: NO NO NO NO

NO ::: NO NO NO NO

NO NO NO

NO NO 0 NO NO

NO NO

MW 8 8 NO ~O

MW 98 028

MW 98-03 NO NO

MW-98-04 NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO 0.13 J

MW- 8-0S " NO 1.6 NO NO 11 '~8 ,~, 6~' NO 8 0.48 4 MW 98 OS8 NO NO NO NO 15 26 9~S NO NO NO NO NO NO 0.21 J MW-98-06A NO

MW 8068 NO

7 NO

MW 98-08 MW-0718

NO NO NO NO NO NO 8 NO N NO

N 2A

NO

NO

NO

9

NO

NO

NO ~,

NO

NO

NO NO

NO NO NO

NO

NO NO NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO NO NO NO

NO

NO

NO

NO NO NO NO

NO

NO

NO NO NO

0

NO NO NON-28

N-II N-16

7

N-37 N-38

9

NO

NO

NO

,

NO

NO

NO

NO

NO

NO

NO

NO

NO ~,

NO

NO

NO

NO

NO

NO

NO

NO

NO NO NO

NO NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO NO NO NO NO NO

NO

NO

NO

NO

NO

NO

.Effiuenl sample from focus pump and treat ••DBS - Samples collected using diffusive bag sample method ... Collected after 4 hours ofpumping during execution of Initial Tesling Plan

K:Uobs\Krall Foods Global, Inc\ROWE IndustriesIGround Waler\O&M\FSP&T\GW salflllingl2012\Sept 201 ZI Table PCE-TCE-TCA 2012.xtsx ,"', LOG ENGINEERING SERVICES, P.C.

2012 ANNUAL SUMMARY REPORT FORMER ROWE INDUSTRIES SUPERFUND SITE

1668 SAG HARBOR TURNPIKE SAG HARBOR, NEW YORK

CURRENT AND mSTORIC CONCENTRATIONS OF TCA DETECTED IN GROUNDWATER FROM MONITOR WELLS AND RECOVERY WELL, ugll

Monitor or Sample Dates

Recovery Well 9/02** Mar-03 """13 l\hr-04 Jul-04 5ep-04 Jau-OS Mar-OS May-05 Jun-OS Aug-OS Sep-OS Dec-OS Mar-06 Sep-06 l\tar-O Oc.-07 Mar-OS """IS l\hr-09 Sep-09 Mar-tO Sep-tO l\hr-ll Sep-ll Mar-12 Juu-12 Sep-12•

MW-BI ND ND ND ND ND ND ND ND ND ND ND ND ND ND ;V-B2 ND ND ND ND

MW-B3 ND ND ND ND ND MW·B4 ND ND ND ND ND FRW-I ND ND ND 2.8 ND 3.2 ND ND ND ND 6.3 ND 11 :;:~

13 ND ND ND 4.6 5.7 0.58 J ND O.24J 1.0 5.ll W· 23 5.6

FRW-3 ND ND ND ND 2.6 61 28 54 5.1 ND 28 44 ND ND 1.3 ND ND ND ND 1.8 ND ND ND 0.30 J 0.29 J FRW-4 ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND 0.14 J 0.16 J ND RW-I ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND RW-2 ND ND ND ND ND ND ND ND 200 31 1.2 2.4 .9 ND 1.7 ND ND ND O. 1 J 0.26 J 0.2 J RW-3 ND 1.1 2.9 2.3 8.7 5.0 1.2 ND ND ND 0.8 J ND 1.3 ND ND ND ND ND 0.27 ND ND RW-4 1.6 ND 1.1 4.5 18 6 7 7~ 2.1 10 3 6 ND ND 4.2 1.9 ND 2.7 J 3.6 3.6 2.2 RW-5 ND ND ND ND 6.5 4.3 3.8 3 ND ND ND ND 2.6 2.0 ND 2.6 ND ND l.lJ 0.12 J ND ND

W-6 ND ND ND ND 2.2 6.6 2 17 27 8.4 1 6.1 6.S 6.S 4. 4.2 2.8 0.9 2.7 J 2.7 2.0 .5 RW-7 ND ND ND ND ND 1.7 3.4 4.1 7~ 2.7 2.8 1.1 ND ND ND 0.77 J 0.67 J ND .. 0.29 J 0.21 J 0.21 J RW-8 ND 2.7 3.6 4.3 4.2 4.2 2.8 3 2 1.2 ND ND ND ND ND ND ND ND ND ND RW-9 3.5 2.8 3.5 12 6 5.9 2 ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND

·28 MW-28B

MW-28AlNew) ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND MW-28 ow ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND

·42 MW-42B ND ND ND ND ND ND ND ND ND ND ND ND ND MW-42C ND ND ND MW-43A ND ND ND ND ND 5.3 7.6 5.7 MW-43B ND ND ND ND ND ND ND ND ND ND ND ND ND ND .8 0.69 J ND l.lJ .2 ND MW-43C ND ND ND ND ND 4.1 ND ND ND ND ND ND ND ND ND ND ND ND ND MW-44A ND ND ND ND ND 5.1 4.8 1.9 41 ND ND ND ND ND ND ND ND ND MW-44B ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND

W-44 ND ND ND ND ND ND ND ND ND ND ND MW-45A ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND MW-45B ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND MW-46A ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND

-46B ND ND ND ND ND ND MW-47A 7~ ND ND ND ND ND ND ND 6.7 ND ND ND ND ND ND 0.15 J MW-47B ND ND ND ND ND ND ND ND ND ND

~48A ND ND ND ND ND ND ND -48B

MW-49A ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND MW-49B 2.9 2.8/ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND

K:UobslKran Foods Global. Inc\ROWE IndustrieslGround Waler\O&MlFSp&nGW Silrnplillgl2012lSept 20121 Table PCE-TCE-TCA 2012.xlsx 1012 LBG ENGINERING SERVICES, P.C.

2012 ANNUAL SUMMARY REPORT FORMER ROWE INDUSTRIES SUPERFUND SITE

1668 SAG HARBOR TURNPIKE SAG HARBOR, NEW YORK

CURRENT AND mSTORIC CONCENTRATIONS OF TCA DETECTED IN GROUNDWATER FROM MONITOR WELLS AND RECOVERY WELL, ugll

Monitor or Sample Dates

Recovery Well 9/02** Mar-03 """13 l\hr-04 Jul-04 Sep-04 Jau-OS Mar-OS May-05 Jun-OS Aug-OS Sep-OS Dec-OS Mar-06 Sep-06 l\tar-O Oc.-07 Mar-OS """IS l\hr-09 Sep-09 Mar-tO Sep-tO l\hr-ll Sep-ll Mar-12 Juu-12 Sep-12•

MW-50A ND ND ND ND ND ND ND ND ND MW-50B ND ND ND ND ND ND ND ND ND ND ND ND

W- ND ND ND ND ND ND MW-51A MW-52A ND ND ND ND ND ND ND ND ND ND ND MW-53 IS 16 24 20 5.S 18 ••• 2.0 73 4.2 3.5

- 4 5.1 .4 .4 4 . 4 . .77 .7 MW-55 ND ND ND ND ND ND ND ND

MW-56A ND ND ND ND ND ND ND ND ND ND ND MW-56B 10 18 1.5 ND 2.1 ND ND ND ND ND ND ND ND ND ND ND ND ND MW­ 2.2 .7 ND ND ND ND ND ND ND ND ND ND ND ND MW-57A ND ND ND ND ND ND MW-57B ND ND ND ND ND ND ND ND ND MW-57C ND ND ND ND ND ND ND ND ND

-98-0 ND ND ND ND ND ND ND .3 ND ND ND ND ND ND ND ND MW-98-01B ND MW-98-02A MW-98-02B

-9 -0 ND MW-98-04 ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND

MW-98-05A ND ND ND 1.8 39 ND ND ND ND 3.4 ND ND ND ND ND

IMW~8-05A-MS -98- B 6.6 4.4

MW-98-06A ND MW-98-06B ND MW-98-07 ND MW-98-08 MW-0718

N-IA ND ND ND ND ND ND N-IB 1.1 ND ND ND ND ND ND ND ND ND ND

-2 ND ND ND ND ND ND N-2B ND ND ND ND ND ND ND ND ND ND ND

N-' N-' ND ND ND ND ND

- ND 5.3 7.1 7 2.S ND ND 2. 4. ND ND ND N-17 ND ND ND ND ND ND ND ND ND ND ND ND N-32 ND ND ND ND ND ND ND ND ND N-37

::Bii ND ND ND ND

~ ~ ND ND ND

~ ND ND ND

-- 4.

• "DBS - Sample: colle:cted using diffiJsive: bag sample: method ••• Colle:cte:d after 4 hours of pmnping during execution of Initial Te:sting Plan

K:UobslKran Foods Global. Inc\ROWE IndustrieslGround Waler\O&MlFSp&nGW sarnplillgl2012lSept 20121 Table PCE-TCE-TCA 2012.xlsx 2012 LBG ENGINERING SERVICES, P.C.

'...... • Table 4: Other Comments on Operation, Maintenance, Monitoring, and Institutional Controls

- Comment

Although the groundwater management system appears to· be effectively addressing the contaminated groundwater plume, it will need to continue to operate as long as there is source material in the saturated zone in the vicinity of the fonner drum storage area. Despite efforts to remediate this source material in-situ, the levels of contaminants are still elevated.

Suggestion

Ifthe focused remediation system does not prove to be effective ill addressing the source material, consideration should be given to alternative source remedial approaches.