COMBINED FIRST AND SECONDFIVE-YEAR REVIEW REPORTS

HAYFORD BRIDGE ROAD GROUNDWATER SITEST. CHARLES, MISSOURI

Prepared by:

U.S. Environmental Protection AgencyRegion 7

Kansas City, Kansas

September 2000

Combined First and Second Five-Year Review ReportsHayford Bridge Road Groundwater Site

St. Charles, Missouri

Approved:

TABLE OF CONTENTS

1.0 INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

2.0 SITE BACKGROUND . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

2.1 Site Location . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

2.2 Site History . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

2.3 Selected Remedy . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

2.4 Remedial Design and Construction . . . . . . . . . . . . . . . . . . . . . . . . . . 6

3.0 SUMMARY OF LONG-TERM REMEDIAL ACTIONS . . . . . . . . . . . . . .

3.1 Summary of Operation and Maintenance . . . . . . . . . . . . . . . . . . . . . 8

3.2 Site Visits, Inspections and Meetings . . . . . . . . . . . . . . . . . . . . . . . . 10

3.3 Areas of Non-Compliance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

3.4 Additional Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

4.0 ARARS REVIEW . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

5.0 RECOMMENDATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

6.0 STATEMENT OF PROTECTIVENESS . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

7.0 NEXT REVIEW . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

FIGURE 1. SITE VICINITY MAP . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

FIGURE 2. SITE LOCATION MAP . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

FIGURE 3. BIOTREATMENT MAP . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

APPENDIX A. FIGURES 4 THROUGH 8

APPENDIX B. FIGURES 9 THROUGH 21

1.0 INTRODUCTION

This report documents two reviews conducted by the U.S. Environmental ProtectionAgency (EPA), the lead agency, for the Hayford Bridge Road Groundwater site (HBR site),located in St. Charles, Missouri, to determine if the remedy is still protective of human health,welfare, and the environment. For reference purposes, the HBR site is listed as the Findett site in the Superfund computer system. Section 121(c) of the Comprehensive EnvironmentalResponse, Compensation, and Liability Act (CERCLA), as amended, and Section300.430(f)(4)(ii) of the National Oil and Hazardous Substances Pollution Contingency Plan(NCP) require that periodic reviews (at least once every five years) be conducted for sites wherehazardous substances, pollutants, or contaminants remain at the site above levels that allow forunlimited use or unrestricted exposure following the completion of all remedial actions for thesite. This type of five-year review is referred to as a statutory review.

The five-year timetable typically begins with mobilization of contractors to start remedialaction construction. For the HBR site, the construction started October 22, 1990, on the concretesupport pad used for the air stripper unit. Formally, a five-year review report was not writtenduring 1995. However, many of the substantive elements of the five-year review process wereconducted in the development of the 1995 Amendment to the Record of Decision (ROD) and the1995 Removal Action Engineering Evaluation and Cost Analysis (EE/CA), and associatedDecision Document. This report will combine a review of the results for the first five years witha review of the results for the second five years.

The EPA has closely monitored the remedial action at the HBR site through: 1) fieldoversight of the multiple construction activities; 2) review of design and remedial actionsubmittals including the design documents and monthly reports; and 3) visits to the siteaveraging several per year.

2

2.0 SITE BACKGROUND

2.1 Site Location

The HBR site is located in St. Charles County, in east-central Missouri. The HBR site isjust north of the city of St. Charles, approximately 25 miles northwest of St. Louis (see Figure1). The HBR site is in the flood plain of the Mississippi River, which is approximately 3.2 milesto the north.

Land uses surrounding the HBR site are primarily agricultural. A small industrial park(Gardnerville) on Elm Point Road and Governor Drive contains the Findett Corporation (Findett)and former Cadmus Corporation (Cadmus) facilities and several other light commercial orindustrial establishments (see Figure 2). Residences in the area are limited to: a) a few farmhomes on Huster Road approximately 1,000 feet northeast of the HBR site; b) a residentialsubdivision located on the bluff approximately 1,500 feet south of the site; and c) a residentialsubdivision located approximately one-half mile due east on Elm Point Road. The Elm Pointwell field, which is the primary drinking water supply for St. Charles, is located 1,800 feetnortheast of the Findett property.

2.2 Site History

Findett currently operates and Cadmus formerly operated independent companies onadjacent properties. Findett was founded in 1962 and is a resource recovery/custommanufacturing facility. Prior to 1973, Cadmus did not exist and Findett owned both properties.In 1973, the two owners/founders of Findett agreed to separate the properties and operationswhich led to the formation of Cadmus. Business operations at Findett initially focused onrecycling of heat transfer fluids, hydraulic fluids, solvents, and catalysts. Many of the heattransfer and hydraulic fluids contained polychlorinated biphenyls (PCBs). The recyclingoperations, occasional spills, and common industrial practices for that time period led to releasesof various hazardous substances containing contaminants including PCBs and volatile organiccompounds (VOCs). The Cadmus business was based on one catalyst recycling process which,to date, has not been connected to the PCB and chlorinated VOC contaminants found at the HBRsite. Cadmus ceased operating on the property within the last year.

Findett was the original facility addressed by EPA at the HBR site because Findett self-reported its handling of PCBs. A 1976 EPA investigation, conducted pursuant to the CleanWater Act, identified PCB contamination in sediments and surface water samples taken fromdrainage ditches and a quench pond both near and on the Findett property. Findett conducted twosoil excavations of the quench pond in 1977 and 1981, respectively. From 1982 to 1984, Findettconducted a PCB investigation of its property.

5

In 1984, EPA nominated the HBR site for the National Priorities List (NPL) of hazardous waste sites because of the potential for groundwater contamination and the threat tothe nearby municipal well field. From that time on, the HBR site has been managed by EPA as aremedial site. Over five years later, the HBR site was withdrawn as a proposed NPL site whenEPA Headquarters decided to withdraw all sites proposed for the NPL for which the authority ofthe Resource Conservation and Recovery Act (RCRA) could potentially be used to require cleanup. However, by that time, EPA Region VII had already signed a ROD and entered into aConsent Decree for implementation at the HBR site. For these reasons, EPA has continued tomanage the HBR site using Superfund authorities.

From 1984 to 1986, EPA negotiated with Findett to conduct a Remedial Investigation/Feasibility Study (RI/FS), but an agreement could not be reached on the scope of the work. Thus, EPA conducted the RI/FS from 1987 to 1988. The investigation was focused on thegroundwater route due to the nearby municipal water supply. Following public notice and apublic hearing, a ROD was signed on December 28, 1988, by the Regional Administratorselecting the remedy for an operable unit of the HBR site involving the shallow, contaminatedgroundwater.

The HBR site was divided into three operable units (OUs): 1) the shallow, contaminatedgroundwater on Findett (Findett OU); 2) the contaminated soils on Cadmus (Cadmus OU); and,3) the area-wide contaminated shallow and deep groundwaters (Area Groundwater OU). For theCadmus OU, an EE/CA was conducted which led to a Decision Document completed by EPA onMay 10, 1995. Regarding the Area Groundwater OU, negotiations to implement a RI/FS arecurrently underway to reach a settlement with the potentially responsible parties (PRPs).

Where appropriate, sections of this report will address the three OUs individually.

2.3 Selected Remedies

FINDETT OU

Based upon the evaluation of the remedial alternatives described in the ROD and inconsideration of the applicable or relevant and appropriate legal requirements (ARARs)described in the ROD, an active groundwater containment system and soil excavation with off-site disposal were selected as the remedial actions for this OU. These alternatives wereconsistent with the general requirements of Section 121 (b) of CERCLA that a remedial actionshall be selected which is “protective of human health and the environment, that is cost effective,and that utilizes permanent solutions and alternative treatment technologies or resource recoverytechnologies to the maximum extent practicable.”

6

The objectives of the ROD required that the remedial action include:

• Hydraulic control of the shallow, contaminated plume consisting ofgroundwater extraction wells near the suspected contaminant source(s),and screened in the upper granular unit;

• Groundwater treatment to remove organic contaminants using airstripping. An option for further treatment of groundwater using granularactivated carbon was retained;

• Groundwater discharge after treatment to the local publicly ownedtreatment works (POTW); and,

• Contaminated soil excavation and off-site disposal or treatment to addressthe direct contact threat.

CADMUS OU

The objective of the Decision Document required that the removal action include:

• The excavation and off-site disposal of all soils, excluding the Findettproperty, contaminated with PCBs above 25 parts per million (ppm) andlocated above the water table.

AREA-WIDE GROUNDWATER OU

The objective will be to protect human health and the environment as related to the area-wide groundwater. The tentative schedule for this operable unit projects completion of the RI/FSand signing of the ROD during 2003.

2.4 Remedial Designs and Constructions

FINDETT OU

Findett and EPA entered into a Consent Decree on May 14, 1990, requiring Findett toconduct the remedial actions for this OU. Due to the concerns with the nearby Elm Point wellfield, the remedial actions were divided into a shallow groundwater phase and a soils phase, withpriority assigned to the groundwater phase. As a result, the design and construction activities forthe two phases were implemented separately.

7

The EPA approved Findett’s final design for the groundwater phase on September 19,1990. By October 1991, the EPA and the city of St. Charles approved the construction andoperation of the groundwater extraction and treatment system. November 21, 1991, was theformal date for full operation of the pump and treatment system. Originally, the groundwaterextraction system was designed to use one extraction well, EW-1. However, due to lowpumping rates from EW-1 [approximately 1-2 gallons per minute (gpm)], Findett modified thedesign to utilize a second extraction well which was formerly monitoring well MW-6. Themodification was completed during April 1992 and increased the total extraction rate to 12-14gpm. In 1994, chemical analysis identified low levels of PCBs in the extracted groundwater fromEW-1. With EPA’s approval, Findett added a granular activated carbon (GAC) treatment step toremove the PCBs.

Following startup of the groundwater system, Findett submitted a remedial design planfor the soils phase in May 1992. Findett proposed investigating soil remedial actions utilizingmore permanent treatment processes than excavation and off-site disposal. The EPA andMissouri Department of Natural Resources ( MDNR) accepted the plan. Findett’s investigationsled to a treatability study using in-situ bioremediation for the PCB-contaminated soils. On June28, 1994, Findett submitted the results for the bioremediation field trial and recommendedchanging the ROD to allow implementation of the technology. Discussions with Findett, EPA,and MDNR culminated in a September 25, 1995, ROD Amendment for the soils remedy only.Specifically, the ROD Amendment states that biological treatment of the PCB-contaminatedsoils will be implemented in an effort to reach the 25 ppm clean-up goal for PCBs. However, thebioremediation will achieve a 50 percent reduction in PCB concentrations within 2 years, andwill achieve the 25 ppm clean-up goal within 5 years. Otherwise, the original excavation andoff-site disposal remedy will be implemented.

Findett’s design for the biotreatment process was approved by EPA on July 23, 1997.Construction activities were completed, and biotreatment was initiated by August 1999.

CADMUS OU

Currently, negotiations are underway to reach a settlement for the PRPs to implement theremoval action. Negotiations will be completed by September 2000, and completion of theremoval action is scheduled for September 2001.

AREA-WIDE GROUNDWATER OU

If needed, the tentative schedule projects completion of the remedial design by 2007 andcompletion of the remedial action construction by 2008.

8

3.0 SUMMARY OF LONG-TERM REMEDIAL ACTIONS

In this five- and ten-year review, this section is not applicable to the CADMUS OU andthe AREA-WIDE Groundwater OU due to the early stages of those clean-up activities. As aresult, the summaries presented in this section are for the Findett OU only.

3.1 Summary of Operation and Maintenance

Pursuant to the Consent Decree, Findett is required to operate and maintain the remedialactions. As a result, operation and maintenance (O&M) plans were developed by Findett andapproved by EPA for both the groundwater and soils remedial activities. The O&M plans aredocuments to oversee the remedial actions; the scope of the O&M plans include the groundwaterextraction system, treatment facility, and monitoring well network, and the soils biotreatmentand monitoring processes.

Monthly operating reports have been prepared by Findett since entry of the ConsentDecree in 1990. It is an effective means of advising and informing the EPA and the state of thestatus of the remedial action. The monthly reports include data to show the effectiveness oftreatment, maintenance issues, and other items that may have a bearing on the remedial actions.

Groundwater Monitoring Results

In Appendix A, Figures 4 through 8 summarize the historic concentrations and trends forthe Total, Chlorinated and Non-chlorinated VOC contaminants (TVOCs, CVOCs and NCVOCs)for each of the public water supply wells sampled as part of the monitoring program for the site.As shown in Figures 4, 5, and 8, acetone has been detected twice and cis-1,2-dichloroethylene(cis-DCE) once during the ten years of monitoring. The two acetone detections were identifiedin public water supply wells EP-3 and EP-7 and followed by sampling events with no acetonedetected. Acetone is suspected to be a laboratory artifact from the analytical procedure. The onecis-DCE detection was identified in public water supply well EP-4, and it was in the most recentsampling event. The concentrations detected were far below the health-based standards for bothcontaminants. Through the years of monitoring, several public supply wells have been sampledat least on one occasion. For example, Figures 6 and 7 present the data for one duplicatesampling event in 1990 for EP-5 and EP-6, respectively. Based on the historic results and thepotential contaminant migration, the sampling program was designed to focus on the nearestwell, EP-3, to the site. Since EP-3 was taken out of service as a supply well, EP-4 replaced EP-3in the monitoring program because EP-4 was the next closest well to the site.

In Appendix B, Figures 9 and 10 summarize the historic concentrations and trends for theTVOC, CVOC, and NCVOC contaminants for each of the two extraction wells. Figure 9presents the data for MW-6 which is located in the eastern-central side of the Findett property(refer to Figure 2 as needed for locations). MW-6 was originally a monitoring well which wasconverted into the second extraction well in 1991. As a monitoring well, the TVOC

9

concentrations ranged from 50,000 to 80,000 parts per billion (ppb) which then dropped to10,000 ppb when converted to an extraction well. During the 8 or 9 years of pumping, the MW-6 TVOC concentrations have decreased to approximately 7,000 ppb which is a decrease ofapproximately 30 percent for the TVOCs. TVOCs is simply the sum of the CVOCs andNCVOCs. Interestingly, the NCVOC concentrations increased from less than 100 ppb as amonitoring well to almost 2,000 ppb as an extraction well. Certainly, extraction well MW-6 isdrawing in a plume of NCVOCs. This NCVOC increase actually hides the true decrease inCVOC concentrations. Specifically, the MW-6 CVOC concentrations have decreased 45 percentfrom approximately 10,000 ppb to 5,500 ppb.

Figure 10 presents the data for monitoring well UA-12 which is located very close toextraction well #1 in the southern area of the Findett property. UA-12 is not an extraction well;instead, it is a monitoring well. However, the contaminant concentrations for UA-12 areexpected to reflect the concentrations in extraction well #1. UA-12 is the most contaminated wellat the site. The TVOC and CVOC concentrations in UA-12 are essentially the same atapproximately 100,000 ppb and have remained level through the years. At the same time, theNCVOC concentrations in UA-12 have increased from approximately 500 ppb to over 10,000ppb. Again, similar to MW-6, extraction well #1 appears to be drawing in a NVOC plume.

Figures 11 through 21 in Appendix B summarize the historic concentrations and trendsfor the TVOC, CVOC, and NCVOC contaminants for 11 monitoring wells. The monitoring wellscan be categorized into two types - shallow and deep. The type of well can be identified by thenaming system with the prefixes MW and UA designating shallow wells and the prefix LAdesignating deep wells. Five observations are found when the monitoring wells results areanalyzed.

1) Significant Decreases in Downgradient, TVOC Concentrations: The TVOCconcentrations in MW-2, MW-3, MW-4, UA-2, and UA-4 have decreased byapproximately 99+ percent, 75 percent, 85 percent, 90 percent, and 100 percent,respectively. One exception to this observation is MW-5. However, MW-5 is located onthe west side of the Findett property, which is not downgradient.

2) Significant Decreases in Downgradient, CVOC Concentrations: The CVOCconcentrations in MW-2, MW-3, MW-4, and UA-2 have decreased by approximately99+ percent, 75 percent, 90+ percent, and 99+ percent, respectively. Essentially, theCVOCs have been removed from the downgradient wells.

3) Clean Downgradient, Deep Wells: LA-2 and LA-5 are clean. The NCVOC contaminantbenzene has been detected in three of ten sampling events in LA-4 over the ten years.LA-3 has proven clean until the most recent sampling event when cis-DCE wasidentified. However, LA-3 is located on the east side of the Findett property which is notdirectly downgradient.

10

4) Downgradient Benzene Contamination: The remaining NCVOC contamination isprimarily benzene in downgradient monitoring wells MW-2, MW-3, MW-4, and UA-2.

5) CVOC is not Decreasing in West: As noted earlier, MW-5 is located on the west side ofthe Findett property, which is not downgradient from the extraction wells. Figure 14clearly shows that the contamination in MW-5 is almost totally CVOC, and it is notdecreasing after ten years. Obviously, the extraction system is not impacting thecontamination on the west side of the site.

Soils Monitoring Results

The in-situ biotreatment process to degrade PCBs in soils began in August 1999. Thetreatment area is located in the southern portion of the Findett property (see Figure 3) and isdivided into five sections: CS1, CS2, CS3, CS4, and CS5. Composite samples will be collectedsemi-annually and will be used to track the treatment progress. Thus far, three sampling eventshave occurred - August 1999, November 1999, and May 2000. The results are presented belowin ppm concentrations.

SAMPLE AREA AUGUST 1999 NOVEMBER 1999 MAY 2000

CS1 1920 1630 3000

CS2 1830 1290 3600

CS3 2070 1780 2600

CS4 1850 1990 2400

CS5 600 1270 96

CS5 DUPLICATE 470

AVERAGE 1654 1592 2339

Findett’s consultants have explained the results by stating that the November 1999 datashow a modest reduction over a very short process time. Then, they believe the May 2000 datacould be the result of the process which modified the soils resulting in breaking down the claysand releasing the PCBs. The previously “bound” PCBs are then available for sampling andanalysis. Finally, they stated that the increase in PCB concentrations can be attributed to a fasterrate of release of PCBs from the soils compared to the rate of degradation by the microbes. Theresults from the next couple sampling events will be critical to determine if the process ismeeting the degradation goals specified in the ROD Amendment.

12

3.2 Site Visits, Inspections, and Meetings

Throughout the construction and operation phases, EPA representatives have conductedinspections of the site, averaging several per year. The MDNR representatives have alsoconducted inspections of the site.

3.3 Areas of Non-Compliance

There has been only one area of non-compliance during implementation of the ROD andcorresponding Consent Decree for the Findett OU - groundwater monitoring. Between 1994 and1997, Findett did not sample the public water supply wells and the monitoring wells on schedule.As a result, EPA notified Findett in 1997 that resuming implementation of the monitoringprogram was a high priority. At the same time, EPA proposed certain changes to the monitoringprogram which were implemented by Findett within one year. Subsequently, Findett hasimplemented the monitoring program on schedule.

3.4 Additional Activities

The site was flooded by the Mississippi River beginning in July 1993. The flood reached13 feet at the Findett property. Flood conditions continued at the site until October 1993.Reconditioning of the air stripper and blower was required. Also, monitoring well pumps wererepaired or replaced, as necessary. The groundwater system was ready to resume in the spring of1994. In 1997, monitoring wells MW-3 and MW-4 were found damaged and not repairable as aresult of the flood. At EPA’s request, MW-4 was replaced.

4.0 ARARS REVIEW

The five-year review includes a review of newly promulgated or modified requirementsof federal and state environmental laws. These new laws are evaluated to determine whether theyare ARARs and whether they call into question the protectiveness of the response action selectedin the ROD. The intent of the review is to evaluate whether the selected remedy remainsprotective of human health and the environment. Although ARARs are usually considered frozenas of the date of the ROD, if an evaluation in the light of the new laws concludes that the remedyis no longer protective of human health and the environment, it would be necessary to change theremedy to meet the new ARAR standards. The NCP provides:

Requirements that are promulgated or modified after ROD signature must be attained (orwaived) only when determined to be applicable or relevant and appropriate and necessaryto ensure that the remedy is protective of human health and the environment. NCP 40 C.F.R. § 300.430(f)(1)(ii)(B)(1).

The EPA did not identify any new ARARs which require changing the remedy.

13

5.0 RECOMMENDATIONS

FINDETT OU

Clearly, the groundwater remedy for this OU is a containment remedy which will requiregroundwater extraction and treatment for many years into the future. With that in mind, tworecommendations have been identified: 1) investigate operating the system year round; and, 2)address the groundwater contamination on the west side of the Findett property. Currently, thegroundwater system operates only during the months when the air temperature stays above 40degrees because the air stripper will freeze at lower temperatures. As a result, the systemoperates from approximately April through October. Although the monitoring well resultsdocument significant reductions in contaminant concentrations, benzene continues tocontaminate downgradient monitoring wells MW-3 and UA-2 at concentrations of 500 and 1,000ppb, respectively. In addition, extraction well results document increasing concentrations ofnon-chlorinated VOCs. Operating the system during the entire year could accelerate thewithdrawal of the non-chlorinated VOC plume which could result in more significant decreasesin the benzene concentrations in the downgradient wells. The EPA will initiate discussions withFindett to address this issue in 2001.

Regarding the west side groundwater contamination, MW-5 documents a chlorinatedVOC plume which appears unaffected by the current extraction system. The EPA will initiatediscussions with Findett to address this issue in 2001.

The soils biotreatment process started operation in the fall of 1999. The RODAmendment requires that the process reduce the PCB levels in the soils by 50 percent within twoyears. The fall of 2001 will mark the two-year decision point. If the 50 percent criteria is notreached, EPA will immediately initiate discussions with Findett to conduct the excavation andoff-site disposal action specified in the ROD Amendment.

CADMUS OU

The negotiations will be completed in the fall of 2000 for the responsible parties toconduct the soils removal as specified in the Decision Document. The removal will be scheduledfor completion by the fall of 2001.

AREA-WIDE GROUNDWATER OU

The negotiations will be completed in late 2000 for the responsible parties to conduct thegroundwater investigation of the area-wide groundwater contamination. The investigation willbegin in 2001 and be completed before the next five-year review.

14

6.0 STATEMENT OF PROTECTIVENESS

The EPA has reviewed the adequacy of the response actions both completed at theFindett OU and scheduled, following negotiations, at the Cadmus OU and for the Area-WideGroundwater OU. Based on that review, the EPA has determined for the Findett OU that: 1) theresponse actions implemented by Findett have complied with the requirements of the ROD andthe Consent Decree; and, 2) the remedy is expected to be protective of human health and theenvironment upon completion, and immediate threats are currently being addressed. For theCadmus OU, the removal action is expected to be protective of human health and theenvironment upon completion, and the immediate threat will be addressed. For the Area-WideGroundwater OU, the upcoming investigations will identify if unacceptable risks exist and willidentify, if necessary, the required remedial actions to be protective of human health and theenvironment. The state of Missouri was consulted as part of this review process.

7.0 NEXT REVIEW

Since hazardous substances, pollutants, or contaminants remain at the site at levels whichwill not allow for unlimited use or restricted exposure, the EPA will conduct additional five-yearreviews at the Hayford Bridge Road Groundwater site. The EPA Region VII will follow theguidance for the schedule of the next review which should be completed within five years afterOctober 2000. Therefore, the next five-year review will be due by October 2005.

APPENDIX A

APPENDIX B