Corrective Measures Implementation at Pharmacia & Upjohn ...€¦ · Pharmacia & Upjohn, who is the Respondent to the Order. During 2012, the Corrective Measure Implementation (CMI)

Golder, Golder Associates and the GA globe design are trademarks of Golder Associates Corporation

A world ofcapabilities

delivered locally

2012 ANNUAL PROGRESS REPORT

Corrective Measures Implementation at

Pharmacia & Upjohn Company LLC Site

North Haven, Connecticut

RCRA I.D. No. CTD001168533 Submitted To: Pfizer Inc Submitted By: Golder Associates Inc. 200 Century Parkway, Suite C Mt. Laurel, NJ 08054 Distribution: USEPA – Region I CTDEEP Mabbit & Associates, Inc. Booz Allen Hamilton Town of North Haven Pfizer Inc Quantum Management Group, Inc. Woodard & Curran, Inc. Robinson & Cole, LLP WRScompass URS Corporation Brown and Caldwell TerraTherm, Inc. Vita Nuova, LLC Amy S. Greene Environmental Consultants, Inc. Golder Associates Inc. January 2013 Project No. 033-6231-002

REPO

RT

January 2013 ES-1 033-6231-002

g:\projects\2003 projects\033-6231-002 nhaven\annualrpt\2012\2012 annual report - final (nh 25jan13).doc

EXECUTIVE SUMMARY The 2012 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

Resource Conservation Recovery Act (RCRA) identification number for the site is RCRA ID

CTD001168533.

Pfizer Inc (Pfizer) acquired the Site on April 16, 2003 as a result of its acquisition of the Pharmacia

Corporation. Pharmacia Corporation is a wholly owned subsidiary of Pfizer and remains the parent

company of Pharmacia & Upjohn Company LLC, which owns and operates the Site. Current Site use

includes the operation and maintenance of the existing interim remedial systems, including a groundwater

extraction system and a groundwater treatment facility, along with initial activities to design and construct

the Corrective Measures (CM) selected by USEPA for the Site with the concurrence of the Connecticut

Department of Energy and Environmental Protection (CTDEEP).

Although Pfizer Inc (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 measure 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 measure. In all cases, representatives of Pfizer are acting on behalf of

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

During 2012, the Corrective Measure Implementation (CMI) Team of contractors and consultants

assembled by Pfizer continued designing and implementing the requirements of the Order. Major

activities included:

Completed treatment of DNAPL Subarea C which involved the construction and operation of the In-Situ Thermal Remediation (ISTR) Pilot System, including supporting activities such as completing two stack testing events to collect engineering data and verify that the Performance Standards for air emissions were met and operation of the perimeter air monitoring stations in accordance with the Community Air Monitoring Plan.

Completed construction of two 115,000 gallon equalization tanks and associated secondary containment structures necessary to upgrade the Groundwater Treatment Facility (GWTF) to manage CMI wastewater streams.

January 2013 ES-2 033-6231-002


Advanced the design of the East Side Remedial Components (ESRC), including submission of several Pre-Design Investigation (PDI) reports and Preliminary Design Proposals (PDP) to USEPA and CTDEEP to solicit feedback on specific design concepts, including the alignment of the hydraulic barrier wall, the horizontal extent of sediment remediation activities, and the proposed measures to be implemented in the vicinity of Unit 3 well SEC-7D.

Collected groundwater monitoring samples and monitored the performance of interim remedial measures previously installed at the Site, including the performance of the interim groundwater extraction system to hydraulically control Unit 1 groundwater to prevent it from entering the Quinnipiac River.

As part of the progress towards implementation of the corrective measures, during 2012 the CMI Team

has achieved, ahead of schedule, the following Major Milestones and Progress Goal specifically defined

in the Order:

Activity Milestone Type Milestone Date

Date Achieved

Complete ISTR Pilot System Construction Progress Goal 1/22/2013 4/16/2012

Submit Sediment PDI Report and Sediment Remediation PDP Progress Goal 6/28/2013 8/28/2012

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

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

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

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

quarterly basis. In addition, Pfizer has involved the Town community during the project, including

regularly meeting with the Citizens’ Advisory Panel (CAP).

In accordance with the Order, the 2012 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 (CM) selected by USEPA with concurrence from CTDEEP

Section 2 summarizes the principal Corrective Measures Implementation (CMI) activities completed during 2012

Section 3 provides the hydrogeologic and chemical data collected in 2012 as part of the CMI Groundwater Monitoring Program, the GWTF Operations, Monitoring & Maintenance (OM&M), and the data obtained as part of the design for the GWTF upgrades

Sections 4 assesses the performance of the existing interim corrective measures at the Site

Section 5 describes the institutional control monitoring activities conducted during 2012

Section 6 discusses the OM&M monitoring and major CMI activities planned for 2013

January 2013 ES-3 033-6231-002


A list of acronyms and abbreviations is provided immediately after the Table of Contents. Please note

that there are minimal changes in the information provided in Section 1 from the 2011 Annual Report

(Golder 2012a).

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 space constraints the appendices have not been provided in the website copy.

Interested readers can review the complete report through the document repository established at the

North Haven Memorial Library, or by contacting Pfizer or USEPA.

http://www.upjohnnorthhaven.com/

February 2012 i 033-6231-002


Table of Contents EXECUTIVE SUMMARY ........................................................................................................................ ES-1 1.0 INTRODUCTION .............................................................................................................................. 1

1.1 Overview ...................................................................................................................................... 1 1.2 CMI Progress Reporting ............................................................................................................... 1

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 ......................................................................................... 8 2.1 Communications with USEPA and CTDEEP ............................................................................... 8 2.2 Corrective Measures Implementation Work Plan (CMI Work Plan) ............................................. 9 2.3 CMI Groundwater Monitoring and Monitoring Well O&M ............................................................. 9 2.4 In-Situ Thermal Remediation Pilot Study ................................................................................... 11

2.4.1 ISTR Pilot Study Work Plan ................................................................................................... 11 2.4.2 ISTR Pilot Study System Installation and Operation ............................................................. 11 2.4.3 Stack Testing ......................................................................................................................... 13 2.4.4 Thermal Treatment Zone Sampling ....................................................................................... 15

2.5 East Side Remedial Components (ESRC) ................................................................................. 15 2.5.1 Design of the ESRC ............................................................................................................... 15 2.5.2 Permitting of ESRC ................................................................................................................ 16

2.6 Pre-Design Investigations for other CM Components ............................................................... 17 2.6.1 Sediment (Tidal Flat Nos. 1 and 2 and North Creek)............................................................. 17 2.6.2 Unit 3 Well SEC-7D ............................................................................................................... 18 2.6.3 Groundwater Extraction System (GWES) PDI ....................................................................... 18

2.7 Groundwater Treatment Facility Permitting, Operation and Upgrades ...................................... 18 2.8 Town of North Haven Permitting ................................................................................................ 21 2.9 Community Outreach ................................................................................................................. 22

3.0 DATA SUMMARY AND CONCLUSIONS ...................................................................................... 24 3.1 Assessment of Performance of Interim Groundwater Extraction and Treatment System ......... 24

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

3.2 Groundwater Quality Monitoring ................................................................................................ 27 3.2.1 Groundwater Data Collection and Review Activities .............................................................. 27

February 2012 ii 033-6231-002


3.2.2 Unit 1 Groundwater Sample Results...................................................................................... 30 3.2.3 Unit 3 Baseline and ISTR Pilot Monitoring Results ................................................................ 31

3.3 Other Data Generated ................................................................................................................ 33 4.0 ASSESSMENT OF PERFORMANCE OF CORRECTIVE MEASURE .......................................... 35 5.0 INSTITUTIONAL CONTROL MONITORING ACTIVITIES ............................................................ 37 6.0 PROJECTED 2013 MONITORING ACTIVITIES AND MASTER PLAN SCHEDULE ................... 39

6.1 Schedule of OM&M Sampling and Proposed Modifications To The Annual OM&M Activities .. 39 6.2 Master Plan Schedule ................................................................................................................ 41

7.0 REFERENCES ............................................................................................................................... 42

List of Tables Table 1 Summary of Well Completion Information Table 2 CMI Groundwater Monitoring Scope Table 3 Target Analytes and Comparative Criteria Table 4 Summary of Detected Compounds in Unit 1 Groundwater Data – 2012 CMI Groundwater

Monitoring Table 5 Summary of Detected Compounds in Unit 3 Groundwater Data – 2012 CMI Groundwater

Monitoring

List of Figures Figure 1 Site Location Map Figure 2 Base Map and Groundwater Monitoring Points Figure 3 Master Plan Schedule (December 31, 2012) Figure 4 Piezometric Contour Map Unit 1 at High-Tide (March 19, 2012 ) Figure 5 Piezometric Contour Map Unit 1 at Low-Mid-Tide (March 19, 2012) Figure 6 Piezometric Contour Map Unit 1 at High-Tide (September 25, 2012) Figure 7 Piezometric Contour Map Unit 1 at Low-Mid-Tide (September 25, 2012) Figure 8 Unit 1 Groundwater Concentration Summary (September 2012) Figure 9 Units 3 and 4 Organic Exceedances (2012)

List of Appendices Appendix A Key Agency Correspondence Appendix B GWES/GWTF OM&M Data Appendix C Groundwater Elevation Data (March & September 2012) Appendix D Data Quality Assessment Appendix E Laboratory Data Packages E-1 CMI Monitoring Data E-2 Unit 4 Groundwater Sample Data E-3 South Pile Pore Water Data Appendix F Time-Versus-Concentration Graphs with Regression Analyses Appendix G Other data

G-1 GD-8BR Groundwater Sample Data G-2 Units 3 & 4 Biodegradation Indicator Data

G-3 GW-U404 Sample Data G-4 South Pile Pore-water Field Sampling Report

February 2012 iii 033-6231-002


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

Community Air Monitoring Program Citizens’ Advisory Panel

CM Corrective Measure 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 ECV Engineered Control Variances ELURs Environmental Land Use Restrictions ESRC East Side Remedial Components FBR Fluidized Bed Reactor FIR Final Investigation Report FPL Former Polishing Lagoon GAC Granular Activated Carbon GWES Groundwater Extraction System GWTF Groundwater Treatment Facility HBW Hydraulic Barrier Wall ICVC Industrial/Commercial Volatilization Criteria IMER/RGMR Interim Measures Evaluation Report & RCRA Groundwater Monitoring Reports IRMs Interim Remedial Measures ISTR In-Situ Thermal Remediation IWC Inland Wetlands Commission IWP MASC

Implementation Work Plan Maximum Allowable Stack Concentrations

MIP Membrane Interface Probe MPS MSL NDDB

Media Protection Standards Mean Sea Level National Diversity Database

NPDES National Pollutant Discharge Elimination System OLISP CTDEEP Office of Long Island Sound Programs OM&M ORCR

Operation, Monitoring, and Maintenance Office of Resource Conservation and Recovery

P&ZC Planning and Zoning Commission PAH PCBs

Polycyclic Aromatic Hydrocarbon 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

February 2012 iv 033-6231-002


ACRONYM DEFINITION RCSA RSRs SHPO

Regulations of Connecticut State Agencies Remediation Standard Regulations State Historic Preservation Office

SIM SPLP

Selective Ion Monitoring Synthetic Precipitation Leaching Procedure

SRS Solids Removal System SVOCs Semivolatile Organic Compounds SWPC Surface Water Protection Criteria TSCA Toxic Substances Control Act TTZ USACE

Thermal Treatment Zone US Army Corps of Engineers

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

January 2013 1 033-6231-002


1.0 INTRODUCTION

1.1 Overview This 2012 Annual Progress Report (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 RCRA ID

number for the Facility is CTD001168533. The location of the Site is shown on Figure 1 and a Base Map

showing Site features and monitoring points is provided as Figure 2. 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 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.

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, 1996). 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) acquired the Site on April 16, 2003 through its acquisition of the Pharmacia

Corporation. As a result, the Pharmacia Corporation is a wholly owned subsidiary of Pfizer and remains

the parent company of Pharmacia & Upjohn Company LLC, which owns and operates the Site. 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.

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.

January 2013 2 033-6231-002


1.2.1 Annual Progress Reports The specific requirements for Annual Reports as presented in Attachment 3.11.D.2 of the Order, along

with the section of this Annual Report where each requirement is addressed (shown in parenthesis), are

as follows:

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 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 and have not yet been

installed. Therefore, Section 4 of this Annual Report focuses on the effectiveness of existing interim

remedial measures in place at the Site. A description of the Interim Remedial Measures is presented in

Section 1.3 of this Annual Report. As corrective measures design and construction progress, future

Annual Reports will cover final corrective measure 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 2012, Pfizer

submitted quarterly progress reports to USEPA and CTDEEP for the following reporting periods

(submittals dates are in parenthesis):

January through March 2012 (April 27, 2012)

April through June 2012 (July 30, 2012)

July through September 2012 (October 29, 2012)

October through December 2012 (January 25, 2013)

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. As requested by USEPA, a brief executive summary of CMI progress was

also provided for the 3rd and 4th Quarter reports. This Annual Report presents an overview of the CMI

January 2013 3 033-6231-002


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 Circuit Wise facility; Precision Combustion (on Lake A Property)), former

off-site landfill, and South Creek (southwest and south sides); the State Route 40 highway and

embankment, inactive industrial sites (e.g., the Humphrey Chemical Site), and North Creek (north side);

and, the Quinnipiac River and Interstate 91 (east 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

operated a clay mine and brick yard 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 chemicals (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).

Several Interim Remedial Measures (IRMs) 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 IRMs include limiting

access to and securing the Site, construction of 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, and installation and continued operation of a state-of-the-art groundwater extraction and treatment

system. A more complete description of the IRMs completed at the Site can be found in the Statement of

January 2013 4 033-6231-002


Basis (USEPA, 2010a) and the Final Revised CMS. These IRMs will be maintained by Pfizer until the final

corrective measures are installed.

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

groundwater extraction system (GWES) and a groundwater treatment facility (GWTF)1, along with CMI

design and construction activities. For much of 2012, the In-Situ Thermal Remediation (ISTR) Pilot Study

was in operation, and two 115,000 gallon equalization tanks to manage construction wastewaters and,

which are anticipated to be incorporated into the final remedy, were commissioned. Woodard & Curran,

on behalf of Pfizer, manages and maintains the Site and provides 24-hour per day presence, controls

access to the Site through locked chain-link fenced gates, posted and 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.

The majority of groundwater contamination occurs within Unit 1, and Unit 1 is hydraulically separated from

Units 3 and 4 by the Unit 2 silty clay/clayey silt layer. 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. Groundwater elevations at the Site are tidally influenced with the greatest

influence on groundwater closest to the river. During high tide, the natural gradients are inward toward

the Site and Unit 1 receives groundwater from the Quinnipiac River and its tributaries (North Creek and

South Creek). Portions of the Unit 1 aquifer have been mostly 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 and treated prior to its discharge to adjacent surface waters.

1 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.

January 2013 5 033-6231-002


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

relatively minimal and do not discharge 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.

1.4 Description of Selected Corrective Measure (Remedy) The corrective measure (CM) 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 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, 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;

January 2013 6 033-6231-002


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 residential2 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.

The Order also includes the CMI “Master Plan Schedule,” 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,

Pfizer has accelerated the CMI schedule and, as to date, has completed the scheduled Major Milestones

and Progress Goals ahead of the Master Plan Schedule. Pfizer will strive to continue this accelerated

pace throughout the CMI.

2 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.

January 2013 7 033-6231-002


Activity Milestone Type Milestone Date Date Achieved Status as of

December 31, 2012 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 Approved by USEPA and CTDEEP after

revisions. Submit ESRC Component Implementation Work Plan

(including PDI Sampling and Analysis Plan)

Major Milestone 1/13/2012 9/30/2011 Approved by USEPA and CTDEEP after

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 Report and PDP Progress Goal 3/21/2013 9/14/2012

USEPA comments received; CTDEEP comments pending.

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

January 2013 8 033-6231-002


2.0 PRINCIPAL ACTIVITIES CONDUCTED Given its scope and magnitude, Pfizer has divided the corrective measure selected by USEPA into

separate components (CM 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

URS Corporation (URS) - Construction Manager and Health and Safety oversight

Woodard & Curran – Site management, operation and maintenance of the existing groundwater extraction system / groundwater treatment facility, and groundwater treatment facility upgrades

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

WRScompass Team [WRScompass, Brown and Caldwell, and Amy S. Greene Environmental Consultants, Inc. (ASGECI)] – Design and construction of the East Side Remedial Components which is a major CM component

TerraTherm, Inc. (TerraTherm) - In-Situ Thermal Remediation (ISTR) pilot study and preliminary design of the full-scale In-Situ Thermal Remediation system

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 2012.

2.1 Communications with USEPA and CTDEEP Representatives from USEPA, CTDEEP, Pfizer, and their associated consultants met in Boston, MA on

June 21, 2012. The purpose of the meeting was to provide an overview of CMI progress to date, review

the Master Plan Schedule, discuss key activities planned for the remainder of 2012 by the CMI Team, and

address technical aspects of CMI design, among other topics.

Representatives of USEPA, CTDEEP, and Pfizer along with their respective consultants participated in a

teleconference on September 13, 2012 to discuss CMI progress and to present early concepts related to

the design of the GWES. This teleconference was one in a series of routine calls, intended to discuss key

aspects of CMI progress and any questions or comments USEPA or CTDEEP may have on the quarterly

reports.

Pfizer maintains regular contact with USEPA and CTDEEP to discuss project status and specific technical

issues as they arise on the project. These contacts are described in the appropriate section below as part

January 2013 9 033-6231-002


of the discussion of specific aspects of CMI progress. Pfizer also regularly communicates with the Town

of North Haven with respect to permitting construction activities (see Section 2.8 below) and with respect

to community involvement (see Section 2.9 below).

2.2 Corrective Measures Implementation Work Plan (CMI Work Plan) A complete Draft CMI Work Plan (Golder 2011b) was submitted to USEPA and CTDEEP on September

30, 2011, which included the Draft East-Side Remedial Components Implementation Work Plan (ESRC

IWP; Appendix B of CMI Work Plan) along with the material provided as advanced drafts of selected

portions of the Draft CMI Work Plan containing the rationale and scope of Preliminary Design

Investigation (PDI) activities to USEPA and CTDEEP on August 12, 2011 and August 15 2011. The

submittal of the Draft CMI Work Plan fulfilled Task 1 of the Order Scope of Work (Attachment 3 of the

Order) and achieved two Major Milestones of the Master Plan Schedule (Attachment 6 of the Order). As

shown on Figure 3, the Draft CMI Work Plan and the Draft ESRC IWP were submitted well in advance of

the Major Milestone dates, which were November 18, 2011 and January 22, 2012 respectively.

USEPA approved the CMI Work Plan via a letter dated January 13, 2012, which is provided in Appendix

A of this Annual Report. The letter stated that the Draft CMI Work Plan was thorough and well developed

and that the plan presented detailed management and technical approaches which appeared adequate to

meet the requirements of the March 2011 Order. USEPA stated that apart from the October 3, 2011

technical review comments concerning the PDI programs that they had no additional technical issues or

concerns. USEPA provided approval of the TSCA-PCB aspects of the CMI Work Plan via email on

January 30, 2012 (also provided in Appendix A). CTDEEP has notified Pfizer that no specific comments

will be forthcoming on the CMI Work Plan.

Pfizer submitted a revised CMI Work Plan to USEPA and CTDEEP on February 29, 2012, which

addressed the technical review comments provided by USEPA via letter dated October 3, 2011 and

introduced a small number of revisions regarding recent updates to personnel and procedures. Pfizer

received email acknowledgements from the USEPA Project Manager and USEPA Region 1 TSCA-PCB

Coordinator on May 3, 2012 and June 8, 2012, respectively, stating that they had no further comments on

the CMI Work Plan and that Pfizer should consider the CMI Work Plan approved (copies provided in

Appendix A). Therefore, Task 1 of the Scope of Work (Order Attachment 3) to prepare the CMI Work

Plan has been completed and approved in accordance with Section IX of the Order.

2.3 CMI Groundwater Monitoring and Monitoring Well O&M Golder implemented the CMI Groundwater Monitoring Plan, which is contained in Appendix A of the CMI

Work Plan. The activities conducted, including measurement of water levels and collection of

groundwater samples, are in part a continuation of the groundwater monitoring activities previously

reported to USEPA and CTDEEP on a semi-annual basis in the consolidated Interim Measures

January 2013 10 033-6231-002


Evaluation Report & RCRA Groundwater Monitoring Reports (IMER/RGMR). Various non-routine

sampling and well maintenance activities were integrated into the monitoring events to collect data for

CMI design. Principal activities performed during 2012 are summarized below. The data obtained from

these activities are presented and evaluated in Section 3.0.

On January 19, 2012 the 2nd baseline round of groundwater samples were collected from five Unit 3 wells located near ISTR pilot study. An additional sample was also collected from well GD-8BR to confirm the December 2011 results from this well.

Synoptic groundwater elevation measurements were collected on March 19, 2012 as part of the verification that discharge of Unit 1 groundwater to surrounding surface water is being sufficiently controlled. In conjunction with this event, and as discussed in the 2011 Annual Progress Report, Golder also collected samples between March 20, 2012 and March 22, 2012 from selected Unit 3 and Unit 4 wells for analysis of methane, ethane, ethene and ferrous iron to remedy the omission of these parameters from the December 2011 site-wide sampling event. Additional samples for VOCs and SVOCs were collected from wells GD-3D, GD-4D, and SEC-7D in support of the SEC-7D PDI. Golder also utilized a down-hole video camera on March 20, 2012 to assess the conditions at well GD-8BR and several other wells.

Groundwater samples were collected from the five Unit 3 wells surrounding the ISTR pilot study area on June 20, 2012 in accordance with the CMI Groundwater Monitoring Plan. These samples were collected approximately 60 days after initiation of sub-surface heating of the ISTR Pilot System in accordance with the estimate travel time of 50 – 100 days between the perimeter of the Thermal Treatment Zone (TTZ) and well GW-U307.

The December 2011 CMI monitoring identified non-representative groundwater conditions at Unit 4 monitoring well GD-8BR, which were confirmed via resampling in January 2012. As discussed in the 2011 Annual Report, Pfizer planned to assess the condition of the well, and then implement an appropriate repair or action to address the existing conditions at GD-8BR. On March 20, 2012, Golder utilized a down-hole video camera to assess sub-surface conditions at well GD-8BR and several other wells. Based on the evidence of infiltration of impacted, shallow Unit 1 groundwater into the well, on June 7, 2012 and June 8, 2012, Glacier Drilling abandoned Unit 4 well GD-8BR. Glacier Drilling also revised the surface completion of Unit 3 well GD-8D and Unit 1 well GD-8S to prevent infiltration of shallow groundwater into the well casings and redeveloped an number of groundwater monitoring wells, including GW-U404, to reduce particulates and improve communication of the well with the surrounding groundwater formation.

A groundwater sample was collected from Unit 3 well GW-U307 on August 14, 2012, approximately 120 days after initiation of sub-surface heating of the ISTR Pilot System. In addition to the sample from Unit 3 well GW-U307 described in the CMI Groundwater Monitoring Plan, a sample was collected from Unit 3 well GW-U304 to provide additional information prior to the estimated travel time from the ISTR pilot study area of 150 – 300 days and from Unit 4 well GW-U404 to evaluate the effectiveness of the redevelopment performed in June 2012.

In accordance with the CMI Groundwater Monitoring Plan synoptic groundwater level measurements and collection of samples associated with the annual groundwater monitoring event occurred between September 25, 2012 and September 27, 2012. In addition to the samples described in the CMI Groundwater Monitoring Plan, and in accordance with the recommendations presented in the SEC-7D PDI Report and Preliminary Design Proposal (PDP) (Golder 2012b), samples were also collected from wells GD-3D and GD-4D to monitor groundwater chemistry at the northern property

January 2013 11 033-6231-002


perimeter downgradient to SEC-7D. A sample was also collected from Unit 3 well GD-8D to confirm the effectiveness of the repaired surface completion.

A groundwater sample was collected from Unit 3 well GW-U307 on December 6, 2012, approximately 40 days after cessation of sub-surface heating of the ISTR Pilot System.

2.4 In-Situ Thermal Remediation Pilot Study

2.4.1 ISTR Pilot Study Work Plan On behalf of Pfizer, CMI Team members TerraTherm and Golder, prepared the ISTR Pilot Study Work

Plan which was initially submitted to USEPA and CTDEEP on June 3, 2011 (TerraTherm and Golder,

2011). The submittal of the ISTR Pilot Study Work Plan satisfied the Master Plan schedule Major

Milestone of Submit Draft ISTR Pilot System Design and Pilot Study Work Plan (milestone date June 16,

2011) as shown on Figure 3. After several exchanges of USEPA and CTDEEP comments and CMI Team

responses, described in detail in the 2011 Annual Report and the quarterly progress reports, TerraTherm

and Golder prepared a revised ISTR Pilot Study Work Plan. The revised ISTR Pilot Study Work Plan

which addressed the USEPA and CTDEEP comments and incorporated additional information concerning

the proposed stack testing events and Quality Assurance/Quality Control (QA/QC) information from the

selected laboratories was submitted to USEPA and CTDEEP on January 13, 2012 (TerraTherm and

Golder, 2012).

After a series of emails discussing specific aspects of the thermal oxidizer settings and the previous

Response to Comments documents, Pfizer received email acknowledgement from the USEPA Project

Manager and USEPA Region 1 TSCA-PCB Coordinator on May 3, 2012 and June 8, 2012, respectively,

stating that they had no further comments on the ISTR Work Plan and that Pfizer should consider it

approved (copies of the emails provided in Appendix A). Therefore, the requirement described in Order

Section VII.B.3 to prepare an ISTR Pilot System Design and Pilot-Study Work Plan is deemed to be

complete and approved in accordance with Section IX of the Order.

2.4.2 ISTR Pilot Study System Installation and Operation Following the notification provided to USEPA/CTDEEP in the second and third quarter 2011 progress

reports, TerraTherm began construction of the ISTR Pilot System in accordance with the draft ISTR Pilot

Study Work Plan and USEPA’s technical comments on the Work Plan. The location of the ISTR pilot

study system is shown on Figure 2. Construction was essentially complete in early March 2012 and

USEPA confirmed via email on March 9, 2012 that Pfizer should proceed with implementing the ISTR

Pilot Test without waiting for USEPA comments (if any) on the revised ISTR Pilot Study Work Plan. After

completion of the shakedown activities, TerraTherm initiated soil heating on Monday, April 16, 2012,

thereby achieving the Order Progress Goal “Complete ISTR Pilot System Construction” (Progress Goal

date: January 22, 2013) in advance of the Master Plan Schedule.

January 2013 12 033-6231-002


Concurrent with the start of soil heating activities, TerraTherm implemented the perimeter air monitor

described in the Community Air Monitoring Plan (CAMP). The CAMP monitoring was continued until

December 20, 2012 (as discussed below, the pilot study was completed and the ISTR pilot system was

turned off on November 14, 2012) and then was performed again from January 3, 2013 through January

14, 2013 when TerraTherm personnel remobilized to the Site for pilot system decommissioning activities.

While there were a number of false alarms due to humidity and on-site water sprays (for construction-

related dust control purposes), there were no documented exceedances of CAMP associated with

emissions of volatile organic compounds from ISTR operations.

Completed ISTR Pilot Study Well Field and Air Pollution Controls

During the evening of May 18, 2012, when subsurface temperatures were approximately 95 oC, the ISTR

Pilot System automatically shut down due to a malfunction in the thermal oxidizer. In accordance with the

contingency measures described in the ISTR Pilot Study Work Plan, the well-field vapors were redirected

to the backup Granular Activated Carbon (GAC) system and sub-surface heating was discontinued. No

well-field vapors were released to the atmosphere as the system was under vacuum. USEPA and

January 2013 13 033-6231-002


CTDEEP were informed of the shut-down via email on May 19, 2012. TerraTherm, with assistance from

the thermal oxidizer vendor, inspected the system on May 19, 2012 and by May 21, 2012 had determined

the root cause of the malfunction to be temperatures in the thermal oxidizer chamber exceeding the rating

of the ceramic fiber insulation modules due to the placement of the controlling thermocouple. Repairs,

including installation of insulation modules with a higher temperature rating, repairing the hole in the steel

thermal oxidizer shell, moving the controlling thermocouple to upstream of the thermal relief valve, and

installing additional thermocouples to monitor chamber and shell temperatures were completed by June

6, 2012. After satisfactory restart of the thermal oxidizer, the well-field vapors were directed from the

GAC back to the thermal oxidizer on June 7, 2012 and subsurface heating was re-started on June 8,

2012.

The subsurface Thermal Treatment Zone reached an average temperature of 100 oC on or around June

15, 2012, drying of subsurface soils to allow treatment at higher temperatures continued until the end of

July 2012, and subsurface heating to higher temperatures continued until October 24, 2012.

Representatives from several USEPA and CTDEEP divisions, including the USEPA Office of Resource

Conservation and Recovery (ORCR), the USEPA Emergency Response Team, and the CTDEEP Bureau

of Water Protection & Land Reuse, visited the Site on September 11, 2012 for an overview of the Pilot

Study and to observe the ISTR pilot system in operation.

A proposal to cease subsurface heating was provided to USEPA and CTDEEP via email on October 21,

2012. After verbal concurrence from the USEPA Project manager and email concurrence from the

USEPA Region 1 TSCA-PCB Coordinator and CTDEEP, subsurface heating ceased on October 24,

2012. The air pollution controls were operated through November 14, 2012 during the initial cool-down

period as described in the ISTR Study Work Plan. Following the cool-down period, TerraTherm began

decontaminating and decommissioning the ISTR Pilot System. The Master Plan Progress Goal “Complete

ISTR Pilot Study” was achieved on November 14, 2012, when the Pilot System was turned off.

The findings of the Pilot Study will be presented in detail in the ISTR Pilot Study Report and PDP for Full-

Scale ISTR System, which is projected to be submitted to USEPA and CTDEEP in mid-2013.

2.4.3 Stack Testing As described in the ISTR Pilot Study Work Plan and discussed below, stack testing was conducted at two

phases of the ISTR Pilot Study to assess compliance with the Performance Standards described in the

Order:

The first stack testing event, which occurred on June 26, 2012 and June 27, 2012, was conducted to assess compliance under typical Pilot Study operating conditions associated with the 100 oC subsurface operating temperature. CK Environmental collected triplicate stack samples under standard thermal oxidizer operating conditions (approximately 2200°F and 2 second residence time) in accordance with the Stack Test

January 2013 14 033-6231-002


Protocol (Appendix F of the Revised ISTR Study Work Plan) the results of which will be provided as part of the ISTR Pilot Study Report and PDP for Full-Scale ISTR System. Golder completed preliminary evaluation of the data and the data demonstrated compliance with the Performance Standards as they were below the CTDEEP Maximum Allowable Stack Concentrations (MASC) for the operating conditions at the time of testing.

On May 11, 2012 via email to USEPA and CTDEEP, Pfizer proposed conducting a short-term test of the thermal oxidizer at a decreased treatment chamber temperature (approximately 1800°F) and residence time (approximately 1.5 seconds) immediately following the formal compliance stack testing event. The purpose of the additional samples collected during the short-term thermal oxidizer test was to collect engineering information for design of the full scale ISTR vapor treatment system. Representatives of Pfizer, USEPA TSCA-PCB staff, and the CMI team participated in a conference call to discuss the short-term test proposal on June 14, 2012. Pfizer provided additional information requested by USEPA during the conference call, specifically concerning the thermal oxidizer low temperature set-points and the rationale for collecting duplicate samples, via email on June 18, 2012 and June 19, 2012. USEPA acknowledged the receipt of the information and that the responses to their concerns were reasonable via email on June 19, 2012. Therefore, immediately following the formal compliance stack test, the thermal oxidizer operating conditions were adjusted on June 28, 2012, and the short-term stack test was conducted. The thermal oxidizer was returned to standard operating configuration immediately following the short-term stack test. The results of the short-term stack test also demonstrated compliance with the Performance Standards as they were below the CTDEEP MASC for the operating conditions at the time of testing.

CK Environmental collected triplicate stack samples in accordance with the Stack Test Protocol (Appendix F of the Revised ISTR Study Work Plan) to assess compliance with the Performance Standards described in the Order under typical Pilot Study operating conditions between September 11, 2012 and September 13, 2012. As described in the ISTR Pilot Study Work Plan, the second round of stack testing was performed to assess compliance of the emissions with the Performance Standards during the period with subsurface temperature heating above 100°C. A representative from the Permits Branch of ORCR, with a focus on PCB incineration, remained on site as an observer throughout the stack test, and verbally reported that he was satisfied with the performance of the stack testing procedures.

On September 21, 2012, CK Environmental informed Pfizer that the VOST samples and the aqueous condensate fraction associated with the SVOC/Polycyclic Aromatic Hydrocarbon (PAH)/PCB analysis from the September 11-13 stack testing activities were received at the laboratory at 22°C (room temperature) rather than at the less than 10°C specified by the analytical method. Pfizer sent a Technical Memorandum explaining the sample temperature deviation and the expected minor impact on the overall stack test results to USEPA and CTDEEP via email on September 27, 2012. Pfizer held a teleconference to discuss the potential impact on data usability with USEPA and CTDEEP on October 4, 2012. Following the teleconference on October 4, 2012, and with concurrence from USEPA and CTDEEP that retesting was not necessary, Pfizer released the affected samples for completion of the laboratory analysis. The results from these samples, along with a discussion of data usability will be provided as part of the ISTR Pilot Study Report and PDP for Full-Scale ISTR System, which is anticipated to be submitted to USEPA and CTDEEP in mid-2013. Golder completed preliminary evaluation of the data and the data demonstrated compliance with the Performance Standards as they were below the CTDEEP MASC for the operating conditions at the time of testing.

January 2013 15 033-6231-002


2.4.4 Thermal Treatment Zone Sampling In accordance with the revised ISTR Pilot Study Work Plan, soil and groundwater samples were collected

from within the TTZ during 2012. Golder collected samples of Unit 1 groundwater from within the TTZ:

On April 3, 2012 in accordance with the ISTR Pilot Study Work Plan, prior to the initiation of subsurface heating.

On May 14, 2012, when the average in-ground temperature was approximately 80 oC.

Golder and TerraTherm attempted to collect Unit 1 groundwater samples from within the TTZ in late July 2012 near the end of 100 oC treatment, however samples could not be collected as the bulk groundwater had evaporated and both the pressure monitoring points and the multiphase extraction wells were dry.

An additional groundwater sample is planned during 2013 once groundwater has recharged the area within the TTZ.

Golder and TerraTherm collected soil samples from within the TTZ. In addition to the Synthetic

Precipitation Leaching Procedure (SPLP) analyses specified in the Revised ISTR Study Work Plan,

samples were submitted for total VOC, SVOC, and PCB analyses as requested by USEPA during the

June 21, 2012 meeting.

Samples were collected from one location with the TTZ on August 2, 2012 at the completion of 100°C subsurface temperature treatment. A second planned sample could not be obtained due to soil conditions.

Soil samples were collected from two locations within the TTZ on November 15, 2012 and November 16, 2012 at the completion of subsurface heating.

The results from these soil and groundwater samples will be reported to USEPA as part of the ISTR Pilot

Study Report and PDP for Full-Scale ISTR System, which is anticipated to be submitted to USEPA and

CTDEEP in 2013.

2.5 East Side Remedial Components (ESRC)

2.5.1 Design of the ESRC In the fourth quarter of 2011, the WRScompass Team installed 116 soil borings and eight temporary

piezometers as part of the PDI activities described in the ESRC Investigation Work Plan (IWP) which is

Appendix B of the CMI Work Plan. During 2012, the WRScompass Team utilized the data from the

borings and subsequent information gathered from soil samples submitted for analytical and geotechnical

testing, as well as soil and groundwater samples for use in a treatability/compatibility study to formulate a

backfill mixture for the hydraulic barrier wall. ASGECI conducted field delineation of vegetation

communities and soil characterization of tidal wetlands on November 14, 2012 and installed two

temporary tide gauges within tidal wetlands on November 16, 2012 to collect information needed for

design of the ecological enhancements.

The Preliminary Design Proposal and Pre-Design Investigation Report, Unit 1 Hydraulic Controls –

Horizontal Alignment of Low Permeability, Vertical Barrier Wall, (PDP and PDI Report – Unit 1 Hydraulic

January 2013 16 033-6231-002


Barrier Wall), prepared by Brown and Caldwell, was submitted to USEPA and CTDEEP on April 27, 2012.

USEPA provided comments via email on June 19, 2012. The comments stated that Pfizer’s proposal to

locate the hydraulic barrier wall (HBW) at the toe of the berm surrounding the eastern and southern sides

of the South Pile would be an acceptable approach if the wetlands intrusion resulting from this

configuration of the HBW was agreed to by CTDEEP and if suitable measures were included to monitor

groundwater east of the hydraulic barrier to confirm that contamination is not escaping the hydraulic

controls. The USEPA comments on the PDP and PDI Report – Unit 1 Hydraulic Barrier Wall, were

discussed with USEPA and CTDEEP during the June 21, 2012 meeting. As a result of this feedback,

Pfizer pursued further discussions with CTDEEP and with the US Army Corps of Engineers (USACE)

concerning permits to implement the HBW along the alignment presented in the PDP and PDI Report –

Unit 1 Hydraulic Barrier Wall. The USEPA comments will be addressed in the Draft Final Design of the

Unit 1 Hydraulic Controls and Remaining ESRC.

Pfizer and the CMI Team also held a meeting with CTDEEP on October 24, 2012 to discuss ESRC

construction disturbance of existing interim and final RCRA covers along with submittal of Part 2 of the

Engineered Control Variance request.

While the Order has separate Major Milestones for the Draft Final Design of the Unit 1 Hydraulic Controls

and the Draft Final Design of the Remaining ESRC, as discussed with USEPA and CTDEEP during the

September 14, 2012 teleconference, due to refinements in the design/construction sequence and

schedule, a single Draft Final Design pertaining to all ESRC is envisioned at this time. It is anticipated

that this single design submittal will be made in the first quarter of 2013 prior to both of the milestone

dates in the Master Plan Schedule.

2.5.2 Permitting of ESRC In addition to advancing the detailed design, the WRScompass Team has been in frequent

communication with representatives of the USACE and CTDEEP OLISP in relation to obtaining permits

related to construction of portions of the ESRC within regulated tidal wetlands and initiated other activities

to support preparation of the upcoming permit applications. Notable activities during 2012 include:

On June 22, 2012, representatives of the CTDEEP OLISP and USACE held a pre-application meeting with Pfizer and the CMI Team at the Site to discuss obtaining permits for the HBW installation, sediment remediation, and associated tidal wetlands restoration activities. Due to the anticipated time required to obtain the necessary permits, permit applications to implement the Unit 1 Hydraulic Controls are expected to be submitted to OLISP and USACE prior to the submission of the Draft Final Design of the Unit 1 Hydraulic Controls and Remaining ESRC to USEPA and CTDEEP.

Pfizer received guidance concerning the consultation process to fulfill the historical preservation requirements associated with the OLISP and USACE permits during the June 22, 2012 pre-application meeting between representatives of OLISP, USACE, Pfizer, and the CMI Team. As a result, the Phase 1A Archeological Assessment Survey

January 2013 17 033-6231-002


prepared by the WRScompass Team was provided to the Mashantucket and Mohegan Tribes, CT State Historical Preservation Office (SHPO), and USACE, on July 27, 2012. Concurrence with the findings of the Phase 1A Archeological Assessment Survey was received from the Mashantucket Pequot Tribal Nation on August 2, 2012. The USACE and CT SHPO have informally indicated that they have no comments and will provide a formal response as part of the review of the full permit application.

In support of the upcoming permit applications, the WRScompass Team also submitted:

A consultation request to USACE on December 4, 2012 and the response was received on December 14, 2012.

A consultation request to the Department of Agriculture on December 10, 2012 and the response was received on December 18, 2012.

A Natural Diversity Database (NDDB) Request related to the potential presence of threatened or endangered species at the Site to CTDEEP on December 13, 2012 and the response was received on January 18, 2013. The permit applications are expected to be submitted to USACE and OLISP by late January 2013.

2.6 Pre-Design Investigations for other CM Components The CMI Team implemented a number of other PDI activities in the 4th quarter of 2011 and the first half of

2012 to collect information required for design of the CM Components. The results of these PDI activities

have been reported to USEPA and CTDEEP in a number of PDPs to solicit feedback prior to advancing

the detailed design of these components.

2.6.1 Sediment (Tidal Flat Nos. 1 and 2 and North Creek) Golder continued sediment PDI activities in accordance with the Revised Sediment PDI Work Plan

(Golder 2011a), which was approved by USEPA and CTDEEP on July 22, 2011 and August 1, 2011,

respectively. Golder utilized the results from the additional samples collected from Tidal Flat No. 2 on

April 2, 2012 to complete the delineation of the proposed remediation area. A summary of the sediment

PDI and the proposed remediation areas was presented to USEPA and CTDEEP during the June 21,

2012 meeting.

The Sediment PDI Report and PDP (Golder 2012b) was submitted to USEPA and CTDEEP for review on

August 28, 2012, which achieved the Order Progress Goal “Submit Sediment PDI Report and Sediment

Remediation PDP” (Progress Goal date: June 28, 2013) in advance of the Master Plan Schedule. Pfizer

received a letter from USEPA dated September 24, 2012 approving the sediment remediation boundaries

proposed in the Sediment PDI Report and PDP, with the caveat that potential TSCA issues will be

addressed separately (copy provided in Appendix A). On December 15, 2012, the USEPA Region I

TSCA Coordinator confirmed that no TSCA comments would be forthcoming.

Pfizer discussed preliminary comments on the Sediment PDI Report and PDP with CTDEEP via

teleconference on October 4, 2012 and continued discussions when at CTDEEP on October 24, 2012.

Subsequently, Pfizer received a letter from CTDEEP dated November 28, 2012 concurring with the

January 2013 18 033-6231-002


USEPA’s approval of the Sediment PDI Report and PDP(copy provided in Appendix A). The sediment

remediation extent described in the Sediment PDI Report and PDP will be incorporated into the ESRC

design being prepared by the WRScompass Team.

2.6.2 Unit 3 Well SEC-7D Golder conducted a Membrane Interface Probe (MIP) investigation in the vicinity of Unit 3 monitoring well

SEC-7D in accordance with CMI Work Plan Appendix E – SEC-7D IWP between November 28, 2011 and

December 3, 2011. The SEC-7D PDI Report and PDP (Golder 2012c) was submitted to USEPA and

CTDEEP for review on September 14, 2012, which achieved the Order Progress Goal “Submit SEC-7D

PDI Report and PDP” (Progress Goal date: March 21, 2013) in advance of the Master Plan Schedule.

USEPA provided technical review comments concerning the SEC-7D PDI Report and PDP on December

12, 2012. Pfizer will prepare responses to USEPA’s comments in 2013.

2.6.3 Groundwater Extraction System (GWES) PDI Golder conducted a site-wide well condition survey between April 16, 2012 and April 19, 2012 to provide

information to be used in the design of the Site-wide post-CMI groundwater monitoring network and the

abandonment plan for wells not proposed for use post-CMI. The information from the survey is

anticipated to be provided to USEPA and CTDEEP as part of the basis for the post-CMI OM&M Plan,

which is expected to be submitted to USEPA and CTDEEP as part of the Draft Final Design for the

GWES in the first quarter of 2013.

2.7 Groundwater Treatment Facility Permitting, Operation and Upgrades Woodard & Curran continues to operate the GWTF in accordance with NPDES Permit CT0001341,

issued by CTDEEP on January 8, 2010, and expiring on January 7, 2015, and the June 9, 2011

Regulations of Connecticut State Agencies (RCSA) Section 22a-430-3(i) approval authorizing GWTF

upgrades, specifically installation of two 115,000 gallon equalization tanks to manage the CMI waste

streams, and the treatment of the ISTR Pilot Study wastewaters, including the use of GAC.

As described in the GWTF IWP (Appendix D of the CMI Work Plan), design, permitting, and

implementation of GWTF upgrades to store and treat water streams generated during CMI are being

reviewed by CTDEEP and permitted through the CTDEEP NPDES regulatory process. As part of this

process, Pfizer and Woodard & Curran met with CTDEEP on October 24, 2012 to discuss whether the

anticipated water streams from implementation of the ESRC could be addressed by a Request for

Determination [Section 3i waiver, per RSCA Section 22a-430-3(i)] or whether they would require a major

NPDES Permit Modification. Based on the discussion with CTDEEP, Woodard & Curran has begun

preparation of a 22a-430-3(i) waiver request, which is anticipated to be submitted to CTDEEP in the first

quarter of 2013, along with preparing the GWTF to accept the CMI construction waters..

January 2013 19 033-6231-002


GWES OM&M

Throughout 2012, Woodard & Curran continued to operate, monitor and maintain the performance of the

interim GWES to achieve Unit 1 groundwater hydraulic control. Specific noteworthy activities included:

Extraction well PW-9, which is approximately 40 feet from the Quinnipiac River, was temporarily out of service from January 23, 2012 until January 29, 2012 (seven days) due to electrical issues. The extended repair time was due to obtaining parts not typically required for routine maintenance and not available locally. As a corrective action, Woodard & Curran now maintains spares of these components on Site. Consistent with the downtime analyses provided as attachments to the 4th Quarter 2011 Progress Report, there was no loss of hydraulic capture from the seven day down-time at PW-9.

Between May 22, 2012 and May 24, 2012, a total of six extraction wells with reduced specific capacities (PW-1, PW-2, PW-4, PW-17, PW-18, and PW-19) were redeveloped using Aquafreed techniques (i.e., injection of carbon dioxide), which provides additional rehabilitation over traditional brushing and surging methods.

Following the redevelopment, extraction well PW-18 was temporarily taken out of service on May 24, 2012 due to a hole in the casing that was discovered during the redevelopment. On June 1, 2012, American Environmental Assessment Corp pumped out sediment that accumulated in the well and installed a new casing, screen and sand pack. Well PW-18 was returned to service on June 1, 2012 after the completion of the repairs. Well PW-18 is located more than 40 feet from the Quinnipiac River. Consistent with the downtime analyses provided as attachments to the 4th Quarter 2011 Progress Report, there was no loss of hydraulic capture since PW-18 was out of service for eight days. As a contingency for a potential extended down time period for PW-18 (which did not occur), the hours of operation of adjacent wells PW-19 and PW-4 were extended so that they operated on a 24 hour per day basis rather than the typical approximately 18 hours per day based on tidal fluctuation to provide additional hydraulic capture in the vicinity of PW-18. Wells PW-19 and PW-4 were returned to standard operation on June 1, 2012 when well PW-18 was placed back in service.

Additional routine maintenance activities are described in Appendix B and further discussed in Section

3.1.

Equalization Tanks

Construction of two equalization tanks to equalize flow and chemical loading from the ISTR pilot system

dewatering water (and possibly from other CMI streams) prior to treatment in the GWTF began in the 4th

Quarter of 2011 and was completed in the 3rd Quarter of 2012. The equalization tanks were installed on

the Former Polishing Lagoon (FPL) at the location as shown on Figure 2. The equalization tank

foundations and secondary containment system consist of the installation of over 150 crushed stone piers

that extend from the ground surface to the top of Unit 2 and more than 2 feet of reinforced concrete and

crushed stone that rests on top of the stone piers and existing soils. This foundation and containment

system will be integrated into the protective barrier cover for CMS Area E-3 in accordance with Order

Section VII.B.4.b.1 and will serve as an engineered control to mitigate human and ecological exposures to

January 2013 20 033-6231-002


soils/WWTR in accordance with the Order Performance Standards and will render the underlying soils

inaccessible in accordance with CTDEEP RSRs.

Completed Equalization Tanks

Former Polishing Lagoon (FPL) Soil Placement Area

As described in the 2011 Annual Report, Woodard & Curran and their subcontractors constructed soil

placement areas in the FPL and the South Pile in accordance with the Soil Management Plan, including

the installation of soil erosion and sedimentation (E & S) controls in accordance with the Town of North

Haven requirements. All soils, including incidental intermixed WWTR, brought to the ground surface

during stone pier installation and generated during 2012 from construction of the equalization tanks were

placed in the FPL placement area.

Golder collected samples for PCB analysis of the material placed in the FPL soil placement area on June

4, 2012, June 5, 2012, and June 11, 2012. Partial results of these samples were presented and

discussed during the June 21, 2012 meeting between representatives of Pfizer, USEPA, CTDEEP, and

January 2013 21 033-6231-002


their respective consultants. As decided during the meeting, Golder prepared a letter documenting the

PCB analysis of the soil placed in FPL placement area and a formal proposal for reuse of these soils in

the South Pile, which was submitted to USEPA on July 30, 2012 as an attachment to the 2nd Quarterly

Report for 2012. As the total PCB concentrations in the soils are below 50 mg/kg, Pfizer proposed to

reuse the materials currently in the FPL soil placement area as preload and subgrade grading fill within

the South Pile, which will ultimately be completed by a low-permeability cover.

During the September 13, 2012 teleconference, USEPA indicated general agreement with this reuse

proposal. Based on USEPA’s verbal concurrence, Pfizer is incorporating reuse of the soil in the FPL

placement area as part of the South Pile consolidation and subgrade fill into the Draft Final Design of the

Unit 1 Hydraulic Controls and Remaining ESRC. Pfizer continues to communicate with USEPA TSCA

personnel concerning their review of the letter and the mechanism for approval of the proposal, including

whether it needs to be approved separately from the TSCA concurrence with the ESRC design as

presented in the Draft Final Design of the Unit 1 Hydraulic Controls and Remaining ESRC.

2.8 Town of North Haven Permitting Pfizer and CMI Team representatives completed the following activities toward obtaining the Town’s

approval of the ESRC and remedial construction activities:

The CMI Team met with the North Haven Town Land Use Administrator and Town Engineer on June 7, 2012 and September 12, 2012, to discuss CMI progress and pre-application planning for the first phase of ESRC implementation, including the Unit 1 Hydraulic Barrier Wall construction.

The CMI Team held a pre-application meeting with the North Haven Town Land Use Administrator and Town Engineer on October 16, 2012 in preparation for submission of the applications to the Inland Wetlands Commission (IWC) and Planning and Zoning Commissions (P&ZC) for permits to implement the ESRC.

Applications to implement the ESRC were submitted to the Town of North Haven IWC and P&ZC along with material for Coastal Area Management review and a Fill Permit on October 29, 2012. The application was given number I12-11 by the Town. The CMI Team received comments from the North Haven Town Land Use Administrator and Town Engineer on November 27, 2012.

Notification of the IWC Commission Hearing on the permit application was provided to adjacent property owners on November 14, 2012. The IWC discussed Application I12-11 at the November 28, 2012 meeting, following which a positive referral was provided to the P&ZC.

On December 26, 2012, adjacent property owners were provided notification that a public hearing was to be held concerning the fill permit during the upcoming P&ZC meeting scheduled for January 7, 2013. The CMI Team presented the planned ESRC construction to the P&ZC during the January 7, 2013 meeting and the P&ZC provided their approval for the project.

January 2013 22 033-6231-002


Pfizer and CMI Team will address the questions and comments provided by the Town of North Haven and

apply for electrical and building permits to implement specific construction activities, as needed

throughout 2013.

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

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

outreach activities included the following in 2012:

Meetings with the North Haven First Selectman in February, July and September 2012 to provide progress updates to town leadership.

Pfizer and the CMI Team participated in a moderated television program which was recorded on February 22, 2012 and broadcast on North Haven Community Television. The program was opened by Michael Freda, First Selectman of North Haven and moderated by David Monz, Chair of the North Haven Citizens’ Advisory Panel (CAP). The content of the program focused on the components of the approved remedy, and the status of the CMI. The program was broadcast on NHTV Cable 18 public access station approximately 20 times during the month of March 2012. NHTV Cable 18 is available to residents of North Haven. In addition, the program was available to state-wide subscribers of AT&T U-Verse via channel 99.

Meetings with news media representatives of the New Haven Register and the North Haven Citizen in March 2012 to provide an update on the CMI. An article on CMI activities appeared in the Citizen on March 2, 2012 and in the New Haven Register on March 4, 2012. The CMI Team also communicated with local media representatives during the week of July 16, 2012 to provide an update on site activities. Articles reporting on CMI progress appeared in the New Haven Register and the North Haven Citizen on July 21, 2012 and August 3, 2012 respectively.

A meeting of the North Haven CAP was held on July 19, 2012 at the North Haven Recreation Building. Pfizer and the CMI Team provided an update on the progress and achievements at the site. The next CAP meeting is planned for early in the second quarter of 2013.

Pfizer and the CMI Team hosted a site tour and information session for invited guests on Saturday, September 29, 2012. Town leaders, emergency response coordinators, key staff and commissioners, members of the North Haven CAP, North Haven Trail Association, North Haven Land Trust, and local media were invited to attend the program. Approximately 25 people attended, including news media representatives of the New Haven Register and North Haven Patch. News articles and photos appeared in the Register on September 29 and in the Patch on October 1, 2012.

A stakeholder workshop, planned for November 3, 2012, was postponed due to community impacts from Hurricane Sandy. This workshop, rescheduled for March 23, 2013, seeks to engage key community members in the planning and design of the post-remediation ecological restoration. Representatives of the North Haven CAP, North Haven Trail Association, North Haven Land Trust, Open Space Advisory Committee, Conservation Commission, the local high school environmental program and University of New Haven will be invited to participate in this program. Following this workshop, community representatives will help conduct a baseline study of the ecological features on the property.

January 2013 23 033-6231-002


As part of the Community Outreach activities being conducted in accordance with the Community Relations Plan, Pfizer has also updated the www.upjohnnorthhaven.com website and maintained an information repository at the North Haven Memorial Library, where selected Site reports are being made available through an electronic database.

http://www.upjohnnorthhaven.com/

January 2013 24 033-6231-002


3.0 DATA SUMMARY AND CONCLUSIONS The following section summarizes the data collected to monitor operations at the interim GWES and

GWTF, groundwater monitoring data collected in accordance with the CMI Groundwater Monitoring Plan,

and the data collected as part of the GWTF upgrades and as described in Section 2.0.

3.1 Assessment of Performance of Interim Groundwater Extraction and Treatment System

Pharmacia & Upjohn operates and maintains a Unit 1 GWES consisting of a network of 16 interceptor

wells (PW-1, PW-2, PW-3, PW-4, PW-5, PW-8, PW-9, PW-10, PW-11, PW-14B, PW-16A, PW-17,

PW-18, PW-19, PW-23, and PW-24) and 2 recovery wells (PW-6, PW-15), as listed in Table 1. The Base

Map (Figure 2) shows the locations of all extraction wells (both the interceptor and recovery wells), and

monitoring wells along with Site topography. The pumping cycle for 12 extraction wells (PW-3, PW-4,

PW-8, PW-9, PW-10, PW-11, PW-14B, PW-15, PW-16A, PW-17, PW-18, and PW-19) is coordinated with

Quinnipiac River tidal cycles. Water levels at monitoring well MP-22S, which is the well located closest to

the Quinnipiac River, trigger the pumping cycles for these 12 extraction wells. These 12 extraction wells

pump on a cyclical schedule based on tidal fluctuations to maintain inward hydraulic gradients. The

current pumping cycles start after high tide in the Quinnipiac River and continue for 3 hours after low tide

for an average pumping duration of 8 to 9 hours per tidal cycle (approximately 16 to 18 hours per day).

The pumping cycle for three of the extraction wells (PW-1, PW-2, and PW-5) along the north eastern

perimeter of the Site where there is larger spacing between wells operate continuously. The pumping

cycle for three extraction wells (PW-6, PW-23, and PW-24) are controlled by water levels in the wells.

Pumping shuts off when the water level inside the well casing is below the pump intake screen. The

pump in PW-6 activates again after 45 minutes. The pumps in PW-23 and PW-24 activate again when

the water levels in these wells have recharged to a set elevation.

3.1.1 Summary of GWES Operations, Monitoring and Maintenance The extraction wells are fitted with pressure gauges and paddle wheel style electronic flow meters. The

operation of each extraction well is inspected daily and the flow rates and discharge pipe pressures for

each well are recorded. The daily average and accumulated volume of groundwater pumped from the

extraction wells for this reporting period is tabulated in Table B-1 (Appendix B). The benchmarks for

comparison of the groundwater extraction rates is discussed further in Section 3.1.3. Monthly monitoring

of well specific capacities is performed, and the resulting data are summarized in Table B-2 (Appendix B).

The extraction wells are redeveloped on an as-needed basis as part of the preventative maintenance

program to help achieve consistent performance. Each well has a specific preventative maintenance

program based on past performance and historical degradation of specific capacity (e.g., hydraulic

performance). Redevelopment is performed in 1 or 2-day periods to minimize downtime of the extraction

January 2013 25 033-6231-002


well and is intended to maintain an adequate specific capacity until the next redevelopment event.

Redevelopment activities that occurred during this reporting period are summarized in Table B-3

(Appendix B). Between May 22, 2012 and May 24, 2012, a total of six extraction wells with reduced

specific capacities (PW-1, PW-2, PW-4, PW-17, PW-18, and PW-19) were redeveloped using Aquafreed

techniques (i.e., injection of carbon dioxide).

Pharmacia & Upjohn maintains an emergency spare parts inventory on-site to maintain operation of the

system. 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 B summarizes the preventative maintenance

activities performed and significant events occurring during the 2012 monitoring period.

To evaluate the impact of redevelopment and other scheduled or unscheduled well downtimes, in 2011

Golder prepared an analysis of the amount of time an extraction well(s) could be out of service and not

significantly impact hydraulic capture. Site-specific hydrogeological data indicate that, in general,

groundwater from an extraction well would travel ten feet in approximately 60 days after pumping had

ceased. For wells closest to the river, (e.g., PW-19, which lies approximately 30 feet from the river) this

analysis indicates that groundwater would not have traveled closer than 20 feet upgradient from the river

after this 60 day period. Applying a factor of safety of 10 resulted in a conservative recommendation that

PW-19 or wells equally close to the river not be out of operation for more than six days. This general

analysis utilized conservative assumptions and is evaluated on a case by case basis, if necessary, to

ascertain specific well conditions. For instance, wells located further from the river could be out of service

for longer periods without impacting hydraulic capture, and will be evaluated on an as-needed basis.

Extraction well PW-9, which is approximately 40 feet from the Quinnipiac river, was temporarily out of

service from January 23, 2012 until January 29, 2012 (seven days) due to electrical issues. The repair

time was due to obtaining parts not typically required for routine maintenance and not available locally.

As a corrective action, Woodard & Curran now maintains spares of these components on Site.

Consistent with the downtime analyses provided as attachments to the 4th Quarter 2011 Progress

Report, there was no loss of hydraulic capture from the seven day period PW-9 was out of service.

Following the redevelopment activities in May 2012, extraction well PW-18 was temporarily taken out of

service on May 24, 2012 due to a hole in the casing that was discovered during the redevelopment. On

June 1, 2012, American Environmental Assessment Corp pumped out sediment that accumulated in the

well and installed a new casing, screen and sand pack. Well PW-18 was returned to service on June 1,

2012 after the completion of the repairs. Well PW-18 is located greater than 40 feet from the Quinnipiac

River. Consistent with the downtime analyses provided as attachments to the 4th Quarter 2011 Progress

Report, there was no loss of hydraulic capture from the eight day period PW-18 was out of service. As a

January 2013 26 033-6231-002


contingency for a potential extended down time period for PW-18 (which did not occur), the hours of

operation of adjacent wells PW-19 and PW-4 were extended so that they operated on a 24 hour per day

basis rather than the typical approximately 18 hours per day based on tidal fluctuation to provide

additional hydraulic capture in the vicinity of PW-18. Wells PW-19 and PW-4 were returned to standard

operation on June 1, 2012 when well PW-18 was placed back in service.

3.1.2 Treatment System Monitoring The groundwater treatment system at the Site consists of a Fluidized Bed Reactor (FBR) Unit (1995), a

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

(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 under a NPDES permit (CT0001341) issued by CTDEEP that regulates the treatment of

contaminated groundwater and storm-water and the subsequent discharge of the treated water to the

Quinnipiac River.

A summary of the performance of the existing groundwater treatment system is provided in Table B-4

(Appendix B). The data include average influent and effluent chemical concentrations, percent removal

and mass removal during 2012. The total mass of volatile and semivolatile organic chemicals listed in

Table B-4 that was removed during the 2012 reporting period is estimated to be 3,294 pounds.

3.1.3 Hydraulic Control Monitoring Table B-1 presented in Appendix B presents the average daily pumping rate for each extraction well

during this reporting period. On average, all extraction wells met or exceeded the conservatively derived

design capture rate being used as a conservative target for GWES operation during 2012. However, as

discussed below, the evaluation of whether the GWES is achieving hydraulic control is based on the

evaluation of groundwater elevations within the perimeter extraction and monitoring system.

For purposes of evaluating the groundwater elevation trends and associated hydraulic control,

groundwater elevation measurements were conducted at low-mid-tide, which is defined to be five hours

after high groundwater elevation occurs at MP-22S3. This time allows for Site groundwater levels to be

influenced by an approximately one hour slack high tide followed by four hours of ebbing tide prior to

water level collection. Groundwater elevation measurements were also conducted on the same day at

high tide at the Site, which is defined as one hour following the time at which high groundwater elevation

3 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 Site.

January 2013 27 033-6231-002


occurs at monitoring well MP-22S. The resulting data allow comparison of Unit 1 water levels as affected

by changes in tidal cycles and extraction of groundwater.

The groundwater elevation data collected as part of the 2012 annual groundwater elevation monitoring on

March 19, 2012 and September 25, 2012 is provided in Tables C-1 and C-2 respectively. Unit 1

groundwater piezometric surface maps were developed based on the standard March 2012 and

September 2012 groundwater monitoring events, as shown on Figures 3 through 6.

In general, Unit 1 groundwater flows from west to east, toward the interceptor system as shown on

Figures 3 through 6, from a high elevation of more than 10 feet above the National Geodetic Vertical

Datum of 1929 (NGVD29) on the west side of the side of the Site to less than 0 feet NGVD29 (equivalent

to MSL) on the east side of the Site where groundwater is extracted for treatment to prevent groundwater

from discharging to the Quinnipiac River. Groundwater flow directions and elevation contours interpreted

from the March 19, 2012 and September 25, 2012 water level data are consistent with groundwater flow

directions presented in past groundwater elevation and capture evaluations (previous IMER/RGMR and

Annual Reports).

Elevations lower than 0 feet NGVD29 or MSL that exist along the perimeter of the Site are the result of

the influences of the groundwater extraction wells that depress the water table surface in the vicinity of

the Quinnipiac River. Unit 1 groundwater capture is shown on Figures 3 through 6 by the groundwater

surface depression depicted between the Site and the Quinnipiac River. In conclusion, the extraction

system operation in 2012 continues to provide hydraulic capture of Unit 1 groundwater prior to its

reaching the Quinnipiac River. This conclusion is consistent with the findings of previous hydraulic

capture analyses.

3.2 Groundwater Quality Monitoring

3.2.1 Groundwater Data Collection and Review Activities 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). The objectives and scope for the CMI groundwater monitoring were described

in the CMI Groundwater Monitoring Plan (Appendix A of the CMI Work Plan) and Table A-3 of Appendix A

of the CMI Work Plan summarizes the locations to be sampled along with the rationale for monitoring

each location.

Groundwater Sampling and Analyses

Historically, groundwater samples have been collected from the Site on a semi-annual basis, typically

during March and September and reported to USEPA and CTDEEP in the IMER/RGMRs. The year 2011

January 2013 28 033-6231-002


served as the transition between the previous monitoring program and the CMI Groundwater Monitoring

Program, as was described in the 2011 Annual Report. The CMI Groundwater Monitoring Program

continued in 2012, with groundwater monitoring being performed during six sampling events in January,

March, June, August, September, and December 2012. Samples from a total of 21 distinct wells were

collected by Golder over the course of these events, with several wells sampled multiple times. The

samples were submitted to Alpha Analytical, who utilized both their Mansfield and Westborough, MA

facilities to perform the requested analyses. The following groundwater sampling and analyses

conducted during these events are summarized in Table 2.

Six Unit 1 wells (two monitoring wells and four extraction wells) were sampled to assess groundwater conditions downgradient of the FPL, which has undergone final RCRA closure, the North Pile, which has undergone interim RCRA closure, and the Former Enclosed Aeration Basin, which was addressed by an interim remedial measure. In addition, as requested by USEPA in their comments on CMI Work Plan Appendix A, samples were also collected downgradient of the South Pile. The Unit 1 groundwater samples were submitted for analysis of VOCs, SVOCs and total lead.

Fifteen Unit 3 wells were sampled to obtain data to verify that Unit 3 groundwater remains in compliance with the Performance Standards, and to monitor Unit 3 groundwater downgradient of the ISTR pilot study. All samples from Unit 3 wells were submitted for analysis of VOCs and SVOCs. Downgradient perimeter wells and wells in the vicinity of SEC-7D were also analyzed for lead. The five Unit 3 wells downgradient of the ISTR pilot study were additionally analyzed for PCB Homologs during selected events.

Groundwater samples associated with monitoring the ISTR Pilot Study were scheduled to be collected from well GW-U307 on an approximately bimonthly basis, and from wells GW-U301, GW-U304, GW-U305, and GW-U307 approximately every 4 months. While this schedule was generally followed, samples related to the monitoring Unit 3 in the vicinity of the ISTR Pilot Study were collected in late September rather than mid-October so that they were collected concurrently with the Annual CMI Monitoring Event.

Non-routine groundwater samples were also collected at several points during 2012 as described in

Section 3.3 below.

Comparative Criteria

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

comparative criteria. The first set of comparative criteria are the groundwater Media Protection Standards

(MPS) defined 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 Pfizer in June 2007 (Golder, 2007a). As noted in Attachment 2

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 criterion that are used

January 2013 29 033-6231-002


include 1) the current Surface Water Protection Criteria (SWPC) RSR criteria promulgated by CTDEEP

for state-wide use as of December 31, 2011 (CTDEEP, 1996 & 20054), 2) the Industrial Commercial

Volatilization Criteria (I/C VC) from the CTDEEP Remedial Standard Regulations Volatilization Criteria,

Proposed Revisions, (CTDEEP, 2003), which can be approved by CTDEEP for use on a site-specific

basis, and 3) the RSRs for APS criteria approved by CTDEEP for Site-specific use in December 2008

(CTDEEP, 2008).

On March 5, 2012, GeoDesign submitted a request to CTDEEP on behalf of Pharmacia & Upjohn, for

site-specific approval of revised criteria for naphthalene5. The request covered both the Site and the

adjacent Lake A property Site at 410 Sackett Point Road. CTDEEP approved the proposed I/C VC for

naphthalene of 3099 ug/l in a letter dated March 23, 2012. The approval of this new criterion is not

expected to cause any changes to the design of the corrective measures for the Site as the newly

approved criteria is nearly identical to the Interim I/C VC for naphthalene of 3,095 ug/l provided as a

Media Protection Standard (MPS) in Attachment 2, Table 3 of the Order.

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

summarized on Table 3 of this Annual Report. The SWPC MPS and RSRs apply to all water bearing

units at the Site, while the Industrial-Commercial Volatilization Criteria (ICVC) MPS and RSRs only apply

to Unit 1 groundwater.

Data Quality Review

In accordance with the CMI Groundwater Monitoring Plan, the data generated by the CMI 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, 99.5% of the groundwater sample data

reported by Alpha were found to be acceptable for project use, which met the project completeness goal

of 85%. The data quality review and the detailed findings of the data quality assessment are presented in

Appendix D 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 E.

Notable observations from the data quality review are presented below:

As discussed in the 2011 Annual Report, the data quality assessment identified minor changes between the analytical methods described in the CMI Groundwater Monitoring Plan and the analytical methods used by Alpha Analytical to generate the groundwater sample data. In particular, the laboratory re-evaluated the analytical sensitivity

4 CTDEEP withdrew blanket approval to utilize the 2005 Criteria for APS on March 16, 2011 as they are in the process of reviewing and revising the RSRs. While the Site has not formally petitioned to continue using these criteria, they are being presented for comparative purposes for consistency with previous reports. 5 The Site-specific I/C VC criteria for naphthalene of 12 ug/l, which CTDEEP approved on December 22, 2008, was believed to be a transcription error.

January 2013 30 033-6231-002


achievable for aniline, benzidine, 3,3’-dichlorobenzidine, and 3,3’-dimethylbenzidine between the submission of the CMI Groundwater Monitoring Plan in September 2011 and receipt of the groundwater monitoring samples in December 2011. Following method optimization, they were able to improve the detection limits for aniline, benzidine, 3,3’-dichlorobenzidine, and 3,3’-dimethylbenzidine using full-scan SVOC full analysis. As the sample analyses met the sensitivity goals, the change from SVOC Selective Ion Monitoring (SIM) to SVOC full-scan analysis for these compounds did not affect the data quality. A comparison of the laboratory detection limits to the comparative criteria is provided in Appendix D. Future samples will continue to be analyzed using full-scale SVOC analysis.

The CMI Groundwater Monitoring Plan stated that 1,4-dioxane would be included in the full-scan SVOC analysis. During the 2011 monitoring and the January 2012 sampling event, Alpha elected to quantitate for 1,4-dioxane in a low-level, compound-specific analysis that utilized SVOC SIM along with isotope dilution to compensate for the poor recoveries of 1,4-dioxane from the aqueous matrix. This method is calibrated to achieve the high analytical sensitivity required to meet low-level comparative criteria such as the Massachusetts criterion for 1,4-dioxane in drinking water (0.3 ug/L). The SWPC MPS for 1,4-dioxane is 8,000 ug/L, therefore, this low-level SVOC-SIM analysis is not necessary to meet project sensitivity objectives and high dilutions were needed to accommodate the elevated 1,4-dioxane concentrations present in certain samples. To streamline the sample analyses and to avoid high dilutions, Alpha incorporated 1,4-dioxane in the full-scan SVOC analysis for the March, June, August, and September 2012 sampling events.

3.2.2 Unit 1 Groundwater Sample Results The compounds detected in the Unit 1 groundwater samples are summarized in Table 4, where they are

compared to the criteria discussed above (SWPC and ICVC MPS along with the SWPC and ICVC RSRs).

Concentrations exceeding one or more of the comparative criteria are indicated. Complete results for the

Unit 1 sample analyses (which include non-detected compounds) are provided in Appendix D.

As indicated in Table 4, the following compounds were detected above the comparative criteria in one or

more Unit 1 monitoring locations. These compounds include:

Benzene

Chlorobenzene

Aniline

Benzidine

Carbazole

2-Chloroaniline

3-Chloroaniline

4-Chloroaniline

3,3’-Dichlorobenzidine

3,3’-Dimethylbenzidine

1,4-Dioxane

m-Toluidine

January 2013 31 033-6231-002


All of the Unit 1 exceedances are within the hydraulic capture zone of the groundwater extraction well

system and thus are being contained and removed via the groundwater extraction and treatment system.

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’-dichlorobenzidine6. The concentration of these five compounds in Unit 1 groundwater is summarized

on Figure 8.

Time versus concentration graphs covering the last ten years of data are presented in Appendix G for the

Unit 1 wells. The Unit 1 data collected during 2012 are consistent with the historical concentration trends

for the wells monitored. The groundwater sample analyses verify that conditions in Unit 1 groundwater

have not significantly changed since the previous sampling and meet the objectives of the CMI

Groundwater Monitoring Program.

3.2.3 Unit 3 Baseline and ISTR Pilot Monitoring Results The chemicals detected in Unit 3 are summarized on Table 5, where they are compared to the criteria

described above (SWPC MPS along with the SWPC RSRs). Although concentrations exceeding the

comparative criteria were observed in 3 interior Unit 3 monitoring wells, all results from perimeter

monitoring wells were below the comparative criteria as discussed below. Complete results for the Unit 3

sample analyses (which include non-detected results) are provided in Appendix D.

Organic Compounds – Unit 3

As indicated in Table 5, there were no exceedances of the comparative criteria for any organic compound

in 17 of the 19 Unit 3 wells, including all downgradient perimeter wells. Concentrations of organic

compounds above the MPS and/or the RSRs were observed only at two interior wells (SEC-7D and GW-

U304).

The compounds that exceeded the comparative criteria in well SEC-7D are chlorobenzene,

tetrachloroethene, trichloroethene, 2-chloroaniline, 1,2-dichlorobenzene, and 3,3’-dichlorobenzidine. Time

versus concentration graphs covering the last ten years of data at SEC-7D for benzene, chlorobenzene,

2-chloroaniline and 1,4-dioxane in SEC-7D are included in Appendix F. The analytical results for the

samples collected from SEC-7D during the March and September 2012 monitoring events are consistent

with the trends in concentrations at this well over the past 10 years. As discussed in Section 2.6.2, Pfizer

conducted a PDI to identify potential sources for these detections at well SEC-7D, which is located

approximately 680 feet from the downgradient perimeter of the Site, and submitted the SEC-7D PDI

Report and PDP to USEPA and CTDEEP for review on September 14, 2012. Pfizer will respond to

6 These five compounds were identified as compounds of concern (COCs) in previous IMER/RGMRs.

January 2013 32 033-6231-002


USEPA’s technical review comments concerning the SEC-7D PDI Report and PDP provided on

December 12, 2012, revise and resubmit the report along with continuing to monitor and evaluate

conditions in the vicinity of this well during 2013.

At newly installed interior monitoring well GW-U304, chemical concentrations for 2-chloroaniline and

3,3’-dichlorobenzidine were detected above the comparative criteria. Well GW-U304 is located in the

interior of the Site, between the Former Polishing Lagoon and North Pile, approximately 525 feet from the

downgradient perimeter of the Site, and was installed to assess potential ISTR Pilot Study impacts to

groundwater. The increase in 2-chloroaniline concentrations in well GW-U304 between January 2012

and June 2012 is not believed to be related to the ISTR pilot study, as the sample was collected

approximately 65 days after the initiation of subsurface heating and the increase in concentration

occurred well before the estimated travel time of 150 – 300 days between the ISTR pilot area and GW-

U304 and concentrations in subsequent samples demonstrate a decreasing trend. Pfizer will continue to

monitor GW-U304 during 2013 as discussed further in Section 6.1.

As described in the 2011 Annual Report, the results for total PCBs in the field duplicate sample from

GW-U304 were above the comparative criteria in December 2011, while the results from the primary

sample were below the comparative criteria. The total PCBs results from the primary and field duplicate

samples collected from well GW-U304 during the September 2012 sampling event were below the

comparative criteria.

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

the CTDEEP RSRs promulgated under 22a-133k-3(f)(2) 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:

(A) the average concentration of a substance in such plume is equal to or less than the SWPC for four consecutive quarterly monitoring periods or (B) 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, provided the areal extent of the plume is not increasing and the chemical concentration is not increasing, except as the result of natural attenuation, at any point in time.

The chemistry results for organic compounds in the downgradient perimeter wells sampled during the

2012 CMI Groundwater Monitoring (GD-3D, GD-4D, GD-5D, DM-5D, DM-7D, GD-6D, DM-9D, and

MW-35D) are all below the MPS and the promulgated RSR-based SWPC criteria. While there are no

exceedances of the comparative criteria in perimeter Unit 3 wells, the sample results show that the extent

of the plume in the vicinity of SEC-7D may be increasing, as demonstrated by the increasing

concentrations of trichloroethene, tetrachloroethene and chlorobenzene detected in Unit 3 groundwater

January 2013 33 033-6231-002


wells GD-3D, GD-4D, and GW-U305. Impacts to Unit 3 groundwater in the vicinity of SEC-7D and

downgradient wells GD-3D, GD-4D, and GW-U305 will be addressed as part of the Site-wide CMI, as

described in the SEC-7D PDI Report and PDP that was submitted to USEPA and CTDEEP for review on

September 14, 2012,as previously discussed in Section 2.6.2.

As mentioned in Section 1.3, Unit 3 and 4 groundwater do not discharge directly into surface water, rather

these deeper units seep slowly upward through the Unit 2 silty clay/clayey silt and then discharge to Unit

1 groundwater, which in time may discharge to surface water. Consequently, there are only relatively

minor amounts of Unit 3 (and Unit 4) groundwater that discharges to Unit 1 relative to the amount of Unit

1 groundwater that could potentially discharge to surface water and Unit 1 discharges to surface water

are currently being controlled. Furthermore, attenuation of Unit 3 and Unit 4 chemicals would occur within

the Unit 2 silty-clay/clayey-silt prior to discharge to Unit 1. Therefore, considering that concentrations of

organic compounds in the downgradient perimeter wells sampled during the 2012 CMI Groundwater

Monitoring are all below the MPS and the promulgated RSR-based SWPC criteria, any potential

discharges of Unit 3 groundwater to surface water would be expected to be well below the SWPC despite

the potential increasing chemical concentrations in downgradient perimeter wells GD-3D and GD-4D.

Metals – Unit 3

Consistent with historical data, the concentration of total (unfiltered) lead in Unit 3 well MP-28DR (0.0209

mg/L) was above both the SWPC MPS (0.012 mg/L) and the SWPC RSR (0.013 mg/L). This well is

located between the North Pile and Former Enclosed Aeration Basin, approximately 350 ft from the

downgradient perimeter of the Site. Samples collected from MP-28DR indicated moderate turbidity in the

sample, which may be a cause of the exceedances. The association of the lead with particulates in the

sample is supported by the dissolved (filtered) lead result in MP-28DR (0.003 mg/L), which is well below

the SWPC MPS. Lead is not a concern in Unit 3 groundwater in regards to compliance with the SWPC

RSRs as all other lead results from wells at the down-gradient perimeter of the Site are below the

comparative criteria. Therefore, Unit 3 groundwater remains in overall compliance with the CTDEEP

RSRs for metals.

3.3 Other Data Generated As discussed in Section 2, a number of non-routine groundwater samples were collected in support of

various CMI activities. The results from these samples are summarized below and are provided in

Appendices to this Annual Report.

Unit 4 Well GD-8BR Abandonment

As discussed in the 2011 Annual Report, the results from the 2011 sampling of GD-8BR were inconsistent with historical results for VOCs and SVOCs. Furthermore, adjacent

January 2013 34 033-6231-002


Unit 3 monitoring well GD-8D does not exhibit similar elevated VOCs and SVOCs even though GD-8D is screened just above the bedrock screened interval of GD-8BR. Golder collected confirmation samples in January and March 2012 to verify whether the anomalous results at this well were representative of current groundwater chemistry in this area. On March 20, 2012, Golder utilized a down-hole video camera to assess sub-surface conditions at well GD-8BR and several other wells. Based on the evidence of infiltration of impacted, shallow Unit 1 groundwater into the well, on June 7, 2012 and June 8, 2012, Glacier Drilling abandoned Unit 4 well GD-8BR. Glacier Drilling also revised the surface completion of Unit 3 well GD-8D and Unit 1 well GD-8S to prevent infiltration of shallow groundwater into the well casings. The results of the samples from GD-8BR are provided in Appendix G-1.

Unit 3 and 4 Indicator Gases

As discussed in the 2011 Annual Report, biodegradation indicator gases methane, ethane and ethene and field parameter ferrous iron were not analyzed as part of the natural attenuation parameters for the samples in Unit 3 and 4 groundwater collected during the December 2011 sampling event. Golder re-collected samples for methane, ethane, ethene and ferrous iron analysis in March 2012 and the results are presented in Appendix G-2.

Unit 4 Well GW-U404 Redevelopment

As discussed in the 2011 Annual Report, well GW-U404 exhibited concentrations of iron and zinc in excess of the comparative criteria. It was noted the sample was discolored when collected and the well had not been developed since its installation in 2005. Thus the metals detected do not appear to be site related. As proposed, well GW-U404 was redeveloped on June 8, 2012 and resampled for metals (iron, zinc) on August 14, 2012. The results from the 2012 sample were below the comparative criteria. A table comparing the result from the pre-development sample in 2011 to the post-development sample in 2012 are provided in Appendix G-3.

South Pile Samples

Golder collected individual aqueous samples from existing shallow wells and piezometers screened within the South Pile WWTR in August 2012 to provide gross chemical analyses of pore water that would be generated during WWTR consolidation. Individual aqueous samples were field composited and submitted for laboratory analysis. The rationale, methodology, and results of this investigation is summarized in Appendix G-4. The data were provided to Pfizer and Woodard & Curran (the GWTF OM&M consultant) to help assess pre-treatment and/or treatment requirements for this ESRC construction water stream.

January 2013 35 033-6231-002


4.0 ASSESSMENT OF PERFORMANCE OF CORRECTIVE MEASURE The Order requires the Annual Report to include a section assessing the performance of the Corrective

Measure during the previous year. Final “Corrective Measures” as defined by Order are in process of

design and have not as yet been installed. This section of the 2012 Annual Report discusses the

effectiveness of existing IRMs in place at the Site. Subsequent Annual Reports will provide specific

assessments of the performance of the final Corrective Measures once they are constructed at the Site.

Pharmacia and Upjohn installed, operates, and maintains a Site perimeter GWES and state-of-the-art

GWTF that controls 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 capture and

treatment of impacted groundwater. The performance of these interim Unit 1 hydraulic controls is

discussed in Section 3.1 of this Annual Report. Consistent with the findings of previous hydraulic control

analyses, the extraction system operation in 2012 continues to effectively provide hydraulic control of Unit

1 groundwater prior to its reaching the Quinnipiac River.

Pharmacia & Upjohn has also installed IRMs to mitigate human and ecological direct contact with

impacted soil and WWTR. 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 Manufacturing Area) to mitigate direct exposures. Pharmacia & Upjohn also

installed a chain-link fence and locking gates around the north, west, and south property boundaries,

installed warning signs, and provides 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 IRMs continue to effectively protect against direct contact

exposures to contaminated media on the western side of the site.

Various stages of closure also were completed at each of the impacted soil and WWTR management

areas located on the eastern portion of the Site. For instance, final RCRA closure of the FPL was

achieved by excavating WWTR above the water table, backfilling the excavation and, installing a

compacted soil and vegetated cover. Interim RCRA closure activities at the North Pile included

construction of a geosynthetic membrane cover over the crown of the pile, covering and regrading side

slopes, and collection and treatment of surface water runoff. Interim closure of the Former Enclosed

Aeration Lagoon included covering the WWTR with geosynthetic membrane and soil covers. The South

Pile is partially covered by a soil cover, is surrounded by a soil berm, and accumulated surface water

within the berm is pumped to and treated at the GWTF. The low permeability covers over the crown of the

North Pile and the Former Enclosed Aeration Lagoon and surface water management systems also

reduce infiltration and thereby impacts to the underlying groundwater.

January 2013 36 033-6231-002


Based on these IRMs and RCRA unit closures, USEPA approved stabilization measures under the

Environmental Indicators for Current Human Exposures Under Control (CA-725) and Migration of

Contaminated Groundwater Under Control (CA-750) in 1999. In essence, this means that there are no

unacceptable human exposures to soil/WWTR at the Site, based on current use, and that potential

discharges of impacted groundwater to the Quinnipiac River are being controlled. Ongoing Site

management procedures and institutional controls (as discussed in Section 5.0) will help mitigate and

provide protection of human and environmental exposures to impacted media throughout the CMI period

until final Corrective Measures are implemented at the Site.

January 2013 37 033-6231-002


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 these institutional controls identified in the Order, most particularly the ELURs, will not be

implemented until after completion of CM construction. However, several institutional controls have been

implemented at the Site, are incorporated into Site OM&M, and have been monitored during the 2012

CMI reporting period as discussed below.

Unauthorized entry into the accessible portions of the Site is restricted by a chain link fence with signage

(24 inches by 36 inches reading "Warning, No Trespassing, Environmental Contamination Beyond This

Point") installed around the perimeter of the Site at approximately 200-foot intervals. Additional “Warning"

and "No Trespassing" signs are posted in the least accessible areas of the Site, which are not fenced.

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.

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 groundwater

extraction and treatment system. 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 was

installed at the front gate (41 Stiles Lane). All Site visitors are required to sign in at the GWTF and to

obey Site health and safety requirements. A map of the Site is posted in the sign-in area that shows

visitors where significant exposure hazards may exist in accordance with CTDEEP requirements.

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 have been no reported incidents of trespassing on

the North Haven Site property during 2012.

January 2013 38 033-6231-002


Woodard & Curran staff perform 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. Weekly

institutional control inspection checklists (for such items as signs, fences, and gates) are maintained on-

site consistent with provisions of RCRA interim status. Woodard & Curran staff inspect the IRM covers on

a monthly basis for erosion of slopes, depressions, and other signs of damage. The regular inspections

also include examination of active extraction and monitoring wellheads to determine if wellhead locks are

in place and if repairs to the wellheads are required. The regular OM&M inspections performed by

Woodard & Curran staff assess damage to IRM covers and operating wells, thereby fulfilling the

requirement to at least annually verify that cover systems and engineered controls are in good order and

the requirement to verify that monitoring wellheads are in good repair.

While the 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. Pfizer has verified that through its oversight that current Site use

is consistent with the conditions of the existing deed restriction.

Pharmacia & Upjohn remains the Site Owner, 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 certain CMI activities

have disturbed the RCRA cover over the FPL, these activities are being performed with the knowledge

and consent of CTDEEP and in accordance with the CMI Work Plan and no uncontrolled exposure to Site

contaminants has occurred or is currently present (i.e. RCRA cover is currently serving its purpose to

prevent direct contact exposure). Prohibited uses of the Site, such as the potable use of groundwater and

the use for residential activities, are not occurring.

January 2013 39 033-6231-002


6.0 PROJECTED 2013 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 annual OM&M activities. This section also summarizes milestones and progress

goals that Pfizer 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 and Proposed Modifications To The Annual OM&M Activities

This section consolidates and summarizes the groundwater monitoring activities that will be conducted in

2013 that have been described in previous technical submittals to USEPA and CTDEEP. Objectives of

the 2013 monitoring include:

Routine monitoring of groundwater chemistry in Units 1 and 3 and water levels collected from Units 1, 3, and 4

Unit 3 groundwater monitoring associated with the ISTR Pilot Study

Unit 3 groundwater sampling associated with monitoring groundwater chemistry in the vicinity of SEC-7D

Unit 1 water level monitoring associated with ESRC construction activities, particularly the transition from the existing GWES to the Post-CMI GWES

With the initiation of ESRC construction activities, Pfizer anticipates that the CMI Groundwater monitoring

will be a dynamic process during 2013. The CMI Groundwater Monitoring Plan will continue to be

implemented during ESRC construction, though the scope and the schedule of the groundwater

monitoring activities may be adjusted to accommodate the methods, locations and schedule of specific

ESRC construction activities planned for 2013 (e.g. Health and Safety and access limitations). 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

course of the year.

Pfizer is planning the following field activities during 2013, the scope and schedule of which are :

Collection of groundwater monitoring samples from Unit 1 Monitoring Wells MP-20S, MW-35SR, PW-4, PW-5, PW-11, and PW-19 and Unit 3 monitoring wells DM-5D, DM-7D, DM-9D, MP-20DR, MP-28DR, and MW-35D, as part of the Annual CMI Groundwater Monitoring Event described in the CMI Groundwater Monitoring Plan (planned for September 2013). All wells will be sampled for VOCs, SVOCs, and lead.

Collection of site-wide semi-annual groundwater elevation measurements (projected to occur in March and September 2013) as described in the CMI Groundwater Monitoring Plan.

January 2013 40 033-6231-002


Collection of post-ISTR Pilot Study samples of Unit 1 groundwater within the ISTR Pilot Treatment Area as specified in Section 6.6 of the ISTR Pilot Study Work Plan (Revised) and analyzed in the field for pH and conductivity and in the laboratory for chemical oxygen demand, total organic carbon, and metals (Pb, Zn, Cu, As). Groundwater elevations within the TTZ are being monitored, and these samples will be collected if sufficient water accumulates within the TTZ to allow sampling.

Collection of groundwater monitoring samples from Unit 3 monitoring wells GW-U301, GW-U304, GW-U305, GW-U306, and GW-U307 as part of the continued monitoring of Unit 3 groundwater downgradient from the ISTR Pilot Study TTZ. The CMI Groundwater Monitoring Plan established a schedule where Unit 3 monitoring well GW-U307 (approximately 50 – 100 days downgradient of the TTZ) was to be sampled on a bi-monthly basis and ISTR monitoring wells GW-U301, GW-U304, GW-U305, and GW-U306 (approximately 150 – 300 days downgradient of the TTZ) were to be sampled every four months after ISTR pilot study operations begin and for approximately 6-12 months after completion of the ISTR Pilot Study. The CMI Groundwater Monitoring Plan also provided the flexibility to vary the wells to be sampled and sampling frequency as monitoring proceeds and data is obtained. As the data collected during 2012 shows no changes to Unit 3 groundwater chemistry attributable to the ISTR Pilot Study, Pfizer is planning to reduce the sampling frequency in GW-U307 and to align the ISTR Pilot Study monitoring with the schedule for the routine CMI monitoring discussed above. Accordingly, samples will be collected from Unit 3 wells GW-U301, GW-U304, GW-U305, GW-U306, and GW-U307 on an approximately quarterly basis for the first 3 quarters of 2013 (projected to occur in March, June and September 2013) for VOCs and SVOCs. Samples will also be analyzed for PCB homologs concurrent with the Annual CMI Groundwater Monitoring event (anticipated for September 2013). Should the data collected during the first 3 quarters of 2013 continue to demonstrate that Unit 3 groundwater was not affected by the ISTR Pilot Study, then collection of quarterly samples from Unit 3 wells GW-U301, GW-U304, GW-U305, GW-U306, and GW-U307 will end with the 2013 Annual CMI Groundwater Monitoring event currently planned for September 2013.

Collection of groundwater monitoring samples from Unit 3 Monitoring wells SEC-7D, GD-3D, and GD-4D as recommended by the SEC-7D PDI Report and PDP. These wells will be sampled VOCs and SVOCs concurrent with the Annual CMI Groundwater Monitoring event (anticipated in September 2013).

Collection of Unit 1 groundwater elevation measurements both on a continuous basis using portable datalogger devices and manually on an approximately monthly basis until the Hydraulic Barrier Wall is constructed and approximately semi-annually through the remainder of 2013. These data will be used to adjust the pumping rates to maintain hydraulic control during the ESRC construction, if necessary. The locations, durations, and frequency of water level measurements will be determined by a variety of factors, including, but not limited to, weather, safe access to the monitoring locations during construction activities, and variability of datalogger readings. The scope and schedule of the water level monitoring during ESRC construction are presented in Section 5.3 of the GWES Hydrogeologic Design PDI Report and PDP, which was submitted to USEPA and CTDEEP in January 2013.

Woodard & Curran will continue to operate, monitor and maintain the interim GWES, GWTF, and

institutional controls at the Site. No changes to routine OM&M activities, such as redevelopment 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

January 2013 41 033-6231-002


those generated by ESRC construction activities, these changes will be implemented in accordance with

the NPDES permit and CTDEEP approvals for the ESRC construction waste streams.

6.2 Master Plan Schedule As shown on Figure 3 and discussed in Section 1.5, Pfizer has already met the Major Milestones or

Progress Goals included on the Master Plan Schedule for 2013, including Complete ISTR Pilot System

Construction, Submit Sediment PDI Report and Sediment Remediation PDP, and Submit SEC-7D PDI

Report and PDP. The CMI Team anticipates reaching the following Major Milestones and Progress Goals

identified on the Master Plan Schedule during 2013:

Activity Milestone Type Milestone Date Target

Completion Date

Submit Unit 1 Hydraulic Controls Draft Final Design Package7 Major Milestone 6/2/2014 1st Quarter

2013 Submit Draft Final Design for Remaining

ESRC’s (including CTDEEP ECV Application Part 2)6

Major Milestone 6/5/2015 1st Quarter 2013

Submit GWTF NPDES Request for Determination of Permit Modification to

CTDEEP, as necessary Progress Goal 7/25/2014 1st Quarter

2013

Submit Pilot Study Report and Preliminary Design Proposal for Full-

Scale ISTR Major Milestone 11/13/2014 3rd Quarter

2013

Submit Full-Scale ISTR Draft Final Design Progress Goal 9/25/2015 1st Quarter

2014

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. Therefore, Pfizer does not request any modification

to the Master Plan Schedule at this time. The CMI Team, on behalf of Pfizer, is striving to accelerate the

design and construction schedule to efficiently implement the CM and efficiently complete the CMI period.

Section IV of the quarterly progress reports describes and provides more detail on specific CMI activities

planned for 2013, including details of CM implementation that lead to the Order Major Milestones and

Progress Goals highlighted above, and formal notification of activities that may disturb the existing RCRA

covers at the Site. 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

ontinue to be consulted, regarding technical and regulatory matters (e.g. to solicit input on the GWES

Hydrogeologic Design, ESRC Design, and ISTR Full-Scale Design), as necessary during 2013.

7 While the Order has separate Major Milestones for Submit Unit 1 Hydraulic Controls Draft Final Design Package and Submit Draft Final Design for Remaining ESRC’s (including CTDEEP ECV Application Part 2), due to refinements in the ESRC design process, a single integrated Draft Final Design submittal is anticipated.

January 2013 42 033-6231-002


7.0 REFERENCES CTDEEP, 1996. Remediation Standard, RCSA 22a-133k-1 through 22a-133k-1, January 1996.

CTDEEP, 2003. Connecticut’s Remediation Standard Regulations Volatilization Criteria, Proposed Revisions. March 2003.

CTDEEP, 2005. Comprehensive List of Approved Additional and Alternative Criteria, October 2005.

CTDEEP, 2007. Draft Proposed Revisions to the Remediation Standard Regulations, October 2007.

CTDEEP, 2008. Letter from Patrick F. Bowe (CTDEEP) to Russ Downey (Pfizer) “Request for Criteria for Additional Polluting Substances” dated December 22, 2008.

CTDEEP, 2012. Letter from Patrick F. Bowe (CTDEEP) to Tim Carr (GeoDesign) “Request for Criteria for Additional Polluting Substances” dated March 23, 2012

CTDEEP, 2010. NPDES Permit Issued to Pharmacia & Upjohn Company LLC (Permit ID CT0001341), January 2010.

EarthTech, Inc., 1999. Response to USEPA May 12, 1999 Technical Review of Documents, July 1999.

EPA, 2010a. Statement of Basis for Pharmacia & Upjohn Company LLC Site, North Haven, Connecticut, June 2010.

EPA, 2010b. Final Decision and Response to Comments for Pharmacia & Upjohn Company LLC Site, North Haven, Connecticut, September 2010.

EPA, 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.

Golder Associates Inc., 2006. Final Investigation Report, Pharmacia & Upjohn Company LLC Site, North Haven, Connecticut, August 2006.

Golder Associates Inc. (Golder), 2007a. 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 Inc., 2011a. Sediment Pre-Design Investigation Work Plan, Corrective Measures Implementation, Pharmacia & Upjohn Company LLC Site, North Haven, Connecticut, (Revised) July 2011.

Golder Associates, 2011b. Draft Corrective Measures Implementation Work Plan, Pharmacia & Upjohn Company LLC Site, North Haven, Connecticut, September 2011.

Golder Associates, 2012a. 2011 Annual Progress Report, Pharmacia & Upjohn Company LLC Site, North Haven, Connecticut, February 2012.

Golder Associates, 2012b. Sediment Pre-Design Investigation Report and Preliminary Design Proposal, Pharmacia & Upjohn Company LLC Site, North Haven, Connecticut, August 2012.

January 2013 43 033-6231-002


Golder Associates, 2012c. SEC-7D Pre-Design Investigation Report and Preliminary Design Proposal, Pharmacia & Upjohn Company LLC Site, North Haven, Connecticut, September 2012.

Pharmacia & Upjohn Company, LLC, 2007. Letter to USEPA dated August 2, 2007.

TerraTherm and Golder Associates, Inc, 2011. Pilot Study Work Plan, In Situ Thermal Remediation Pharmacia and Upjohn Company LLC, North Haven, Connecticut June 2011.

TerraTherm and Golder Associates, Inc, 2012. Pilot Study Work Plan, In Situ Thermal Remediation Pharmacia and Upjohn Company LLC, North Haven, Connecticut (Revised) January 2012.

Rust, 1994. RCRA 3008 (h) Corrective Measures Program Interim Measures Study Report, The Upjohn Company, North Haven, Connecticut. Rust Environment & Infrastructure, August 30, 1994.

Golder, Golder Associates and the GA globe design are trademarks of Golder Associates Corporation

Golder Associates Inc. 200 Century Parkway, Suite C

Mt. Laurel, NJ 08054 USA Tel: (856) 793-2005 Fax: (856) 793-2006