FINAL CLOSE-OUT REPORT FOR 

FEDERAL CREOSOTE SUPERFUND SITE 

SOMERSET COUNTY, NEW JERSEY 

Prepared by 

U.S. Environmental Protection Agency 

Region 2 

New York, New York 
Table of Contents 

I. Introduction 1 

II. Summary of Site Conditions 1 

Site Location and Description 1 

Background 2 

Removal Action 3 

Engineering Evaluation/Cost Analysis and Remedial Investigation/Feasibility Studies...3 

Remedy Selection 4 

Design Criteria 6 

Remedial Construction Activities 6 

Institutional Controls 8 

Community Relations Activities 9 

Site Redevelopment 10 

III. Monitoring Results 10 

IV. Summary of Operation and Maintenance 11 

V. Demonstration of Cleanup Activity QA/QC 12 

VI. Five-Year Review 12 

VII. Site Completion Criteria 13 

Bibliography 14 

Figure: Area of Technical Impracticability Determination 16 
SUPERFUND FINAL CLOSE-OUT REPORT 

FEDERAL CREOSOTE SUPERFUND SITE 

BOROUGH OF MANVILLE 

SOMERSET COUNTY, NEW JERSEY 

I. Introduction 

This Final Close-Out Report documents the United States Environmental Protection 

Agency's (EPA's) completion of all response actions for the Federal Creosote Superfund 

Site in accordance with Close-Out Procedures for National Priorities List Sites (OSWER 

Directive 9320.2-22, May 2011). 

All appropriate response actions at the Federal Creosote Superfund Site have been 

successfully implemented. Specifically, based upon' field observations associated with 

EPA and the U.S. Army Corps of Engineers (USACE) oversight and the results of a final 

inspection of the Site on March 19, 2008, and the results of the five-year reviews 

completed on June 7, 2007, and May 3, 2012, it has been determined that the remedy has 

been constructed in accordance with the 1999, 2000, and 2002 Records of Decision 

(RODs), as modified by the 2006 and 2008 Explanations of Significant Differences 

(ESDs). 

The 2000 and 2002 RODs and the 2008 ESD required the implementation of institutional 

controls to restrict activities that could compromise the integrity of protective covers, 

prevent exposure to residual soils contamination at depth, and prevent unacceptable use 

of contaminated groundwater. These institutional controls are all in place. It has been 

determined that no further response, other than long-term monitoring and five-year 

reviews, is anticipated. Human exposures and contaminated groundwater releases are 

under control. 

The Site is divided into three operable units. Operable unit 1 (OU1) consisted of creosote 

source areas in the residential portion of the Site, operable unit 2 (OU2) consisted of 

residually contaminated soils in the residential area of the Site, and operable unit 3 (OU3) 

consisted of source areas and residually contaminated soils in the commercial property 

and contaminated groundwater. 

II. Summary of Site Conditions 

Site Location and Description 

The Federal Creosote Site (Site) is located in the Borough of Manville in Somerset 

County, New Jersey. The 50-acre Site is bordered to the west by commercial properties 

that line the east side of Main Street. To the north, on the opposite side of the Norfolk 
Southern railroad tracks, is the former Johns-Manville company property. The JohnsManville property has been redeveloped for a variety of commercial and retail uses, 

including automobile storage, warehousing, and large retail stores. To the south, on the 

opposite side of the CSX Transportation tracks, is a primarily residential area known as 

Lost Valley. Approximately 5,000 people live within a one-mile radius of the Site. 

Currently, drinking water for the surrounding area is provided by a public water supply 

and no private drinking water wells are used. 

The Site is divided into two land uses: residential (the Claremont Development, 35 acres) 

and commercial (the Rustic Mall, 15 acres). The Claremont Development consists of 129 

single-family residential houses, which are home to approximately 350 residents. The 

Rustic Mall portion of the Site is zoned commercial. The Borough of Manville and the 

property owner are planning revitalization of the Rustic Mall, which includes a 

combination of commercial and residential use. 

Background 

The 50-acre Site was used to treat rail road ties with coal tar creosote, prior to 

development into the current land uses described above. Beginning in approximately 

1910, the Site was operated by a company known as the Federal Creosoting Company. 

During operations, untreated railroad ties were delivered to the Site by rail and were 

processed in a treatment plant located on the southwest western portion of the Site. Coaltar creosote was applied to the railroad ties in this area. Treatment residuals from the 

plant were discharged into two unlined canals. One canal conveyed the flow of the 

treatment residuals to the northern portion of the property for a distance of approximately 

375 feet, where the canal contents entered an unlined lagoon. The other canal directed the 

flow of treatment residuals toward the southern portion of the property, where the 

contents of this canal spilled into another unlined lagoon located approximately 1,500 

feet from the treatment plant. After treatment, railroad ties were moved from the plant to 

the central portion of the property, referred to as the drip area, where the excess creosote 

dripped from the treated wood onto the ground. Creosoting material and contaminated 

soil associated with the wood treating facility were not removed prior to construction of 

the Claremont Development and Rustic Mall. 

Land use patterns on the Federal Creosoting Company property remained the same until 

the mid-1950s, when the wood treatment plant ceased operations and was dismantled. 

During the early through mid-1960s the property was re-developed. The area that 

formerly housed the treatment plant was developed into the 15-acre commercial and retail 

property known as the Rustic Mall. The remaining 35 acres of the former Federal 

Creosoting Company property, including the drip area, canals and lagoons, were 

developed into the Claremont Development. 

In April 1996, the New Jersey Department of Environmental Protection (NJDEP) 

responded to an incident involving the discharge of an unknown liquid from a sump 

located at one of the Claremont Development residences on Valerie Drive. A thick, tarry 

substance was observed flowing from the sump to the street. In January 1997, the 

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Borough of Manville responded to a complaint that a sinkhole had developed around a 

sewer pipe in the Claremont Development along East Camplain Road. Excavation of the 

soil around the pipe identified a black tar-like material in the soil. Subsequent 

investigations of these areas revealed elevated levels of contaminants consistent with 

creosote. 

Following the discovery of this material, NJDEP, with technical assistance from EPA, 

began an investigation of the Site. In April and May 1997, air samples were collected 

inside the majority of homes in the Claremont Development. With the exception of one 

house, the analysis of these samples indicated that the Site-related contaminants were not 

present in indoor air at elevated levels. 

In October 1997, EPA's Environmental Response Team initiated a Site investigation on 

properties believed to contain creosote contamination based on analysis of historical 

aerial photographs, as well as input from residents. Over 100 surface and subsurface soil 

samples were collected. These sampling results indicated that the canals and lagoons still 

existed beneath the Claremont Development, and that the contamination was extensive. 

NPL Listing 

The Site was proposed for the National Priorities List (NPL) on July 27, 1998, and was 

formally placed on the NPL on January 19, 1999. 

Removal Action 

In January 1998, responsibility for the Site was transferred from NJDEP to EPA. In July 

1998, EPA initiated a removal action at 11 residential properties to temporarily cover 

areas that contained higher surface soil levels of carcinogenic polycyclic aromatic 

hydrocarbons (PAHs) in exposed surface soils. As an interim action, sod was placed over 

bare areas in lawns and mulch was placed over exposed soils in garden beds. 

Engineering Evaluation/Cost Analysis and Remedial Investigation/Feasibility Studies 

EPA conducted an Engineering Evaluation/Cost Analysis (EE/CA) for OU1 utilizing the 

results of sampling initiated in October 1997. The EE/CA evaluated options for the 

removal of creosote source areas (subsurface canals and lagoons) located in the 

residential development. The EE/CA was completed in April 1999. EPA concluded that 

the EE/CA was sufficient documentation to proceed to selecting a remedy for this portion 

of the site and, after release of a Proposed Plan and receiving public comment, a Record 

of Decision (ROD) for OU1 was signed on September 28, 1999. 

Under the remedial investigation/feasibility study (RI/FS) process, EPA conducted a 

focused feasiblity study (FFS) for OU2 to determine the nature and extent of residual 

levels of creosote contamination associated with surface and subsurface soil within the 

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residential development and to identify remedial alternatives to address contaminated 

soil. The FFS found that soils contained residual levels of creosote components, PAHs, in 

the majority of the residential properties. The RI/FS was completed in April 2000 and a 

ROD for OU2 was signed on September 29, 2000. 

For OU3, EPA conducted a FFS for the Rustic Mall soils and an RI/FS for the 

groundwater, to determine the extent of subsurface soil contamination on the commercial 

portion of the Site, the nature and extent of Site-wide groundwater contamination, and to 

provide remedial alternatives to address these media. The RI/FS for groundwater was 

completed in June 2001, and the FFS for the commercial property soils was completed in 

August 2001. A ROD for OU3 was signed on September 30, 2002. 

Remedy Selection 

The OU1 ROD, signed in September 1999, established the following remedial action 

objectives (RAOs) for OU1: 

• clean up the canal and lagoon source areas to levels that will allow for 

unrestricted land use; 

• remove as much source material as possible in order to minimize a potential 

source of groundwater contamination. 

The remedy included: 

• permanent relocation of residents from certain properties within the canal and 

lagoon source areas, and temporary relocation where necessary to implement the 

remedy; 

• excavation of source material from the canal and lagoon source areas, backfilling 

with clean fill, and property restoration as necessary; and 

• transportation of the source material for off-site thermal treatment and disposal. 

The OU2 ROD, signed in September 2000, established the following RAOs: 

• prevent human exposure, via direct contact, with contaminated soils, considering 

the current and future residential site use; 

• prevent future impacts to underlying groundwater quality by contaminated soils; 

• prevent exposure and minimize disturbance to the Claremont Development 

residents, and the surrounding community of Manville, during implementation of 

the remedial action. 

The remedy included: 

• excavation of soils containing PAHs in excess of site-specific remediation goals 

from an estimated 82 properties, backfilling with clean fill, and property 

restoration as necessary, and 

• transportation of the contaminated soil off site for disposal, with treatment as 

necessary. 

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The 0U3 ROD, signed in September 2002, established the following RAOs for soils and 

groundwater: 

• prevent human exposure via direct contact, inhalation, and ingestion of 

contaminated soils, considering the future potential residential site use; 

• prevent future impacts to underlying groundwater quality by contaminated soils 

that can act as a continuing source of groundwater contamination; and 

• prevent exposure and minimize disturbance to the Rustic Mall occupants and 

consumers, and the surrounding community of Manville, during implementation 

of the remedial action. 

• prevent ingestion and direct contact with groundwater that has contaminant 

concentrations greater than the Applicable or Relevant and Appropriate 

Requirements (ARARs); 

• minimize the potential for additional off-site migration of groundwater with 

contaminant concentrations that exceed the ARARs; 

• minimize the potential for transfer of groundwater contamination to the other 

media (e.g. ,surface water) at concentrations in excess of ARARs. 

The soil remedy included: 

• Excavation of soils containing PAHs in excess of site-specific remediation goals 

on the Rustic Mall, backfilling with clean fill, and property restoration as 

necessary; and, 

• Transportation of the contaminated soil off site for disposal, with treatment as 

necessary. 

As described in more detail in the Decision Summaries of the OU2 and OU3 RODs, the 

Selected Remedy would leave residual levels of PAHs (but not source material as defined 

by the September 1999 Record of Decision) at depths greater than approximately 14 feet 

below the ground surface in the Rustic Mall. The backfilled clean fill would act as a 

barrier or "engineering control" to prevent contact with any residual contamination. In 

addition, a deed notice would be required to prevent direct contact with any remaining 

residual soil contamination. 

The groundwater remedy included: 

• Implementation of a.long-term groundwater sampling and analysis program to 

monitor the concentrations of creosote components in the groundwater at the site, 

to assess the migration and attenuation of the creosote in groundwater over time; 

and, 

• Institutional controls to restrict the installation of wells and the use of 

groundwater in the vicinity of the contaminated groundwater. 

The evaluation of remedial alternatives for remediation of the dense nonaqueous phase 

liquid creosote contamination, including contamination found in the fractured bedrock 

aquifer, concluded that no practicable alternatives could be implemented. As a result, 

EPA invoked an ARAR waiver for the groundwater at this site due to technical 

impracticability (TI). The area for the TI waiver covers approximately 119 acres. The 

5 
area includes three distinct subareas: the north off-site subarea, the on-site subarea, and 

the south off-site subarea (see Figure 1). The TI waiver includes both the overburden 

aquifer and the bedrock aquifer within the area. The contaminants for which the ARAR 

apply include: acenaphthene, benzene, naphthalene, 2,4-dimethyl phenol, benzo(a) 

anthracene, benzo(a)pyrene, benzo(k) fluoranthene, fluorine, chrysene, 

benzo(b)fluoranthene, and indeno(l,2,3-cd)pyrene. 

Two ESDs were prepared to document significant changes to components of the selected 

remedies. The first ESD provided an explanation of the increase in the estimated costs for 

the OU1, OU2 and OU3 remedies. A second ESD provided an explanation of the 

application of institutional controls, in some circumstances, at depths shallower than 

anticipated in the OU2 ROD. 

Design Criteria 

The design criteria consisted of the removal of creosote waste that was a source of 

groundwater contamination. In addition, design criteria also specified that residually 

contaminated soils exceeding the Site-specific remediation goals would be removed to a 

depth of approximately 14 feet and transported off-site for treatment and/or disposal 

according to the RCRA Land Disposal Requirements. These Site-specific remediation 

goals consisted of seven PAHs, which are the primary contaminants of concern found in 

creosote-contaminated soils. 

Remedial Construction Activities 

As noted above, the site was divided into three OUs. 

The OU1 remedial action included removal of source material from 29 residential 

properties and required the permanent relocation of 21 OU1 property owners, and the 

demolition of 18 homes. 

The remedy was implemented as a fund-lead. In October 1999, EPA entered into an 

interagency agreement with the Baltimore District Real Estate Division of the USACE to 

perform acquisition and relocation activities at the Site. In July 2000, EPA entered into an 

interagency agreement with the Kansas City District USACE to perform the remedial 

action at the Site. The contracts for the remedial action were awarded by the Kansas City 

District USACE and then transferred to the New York District USACE for management 

of the construction work. In October 2000, USACE's selected demolition contractor, 

Cape Environmental, Inc., mobilized equipment at the Federal Creosote Site to begin 

demolition of residential houses located above or adjoining creosote waste lagoons and 

canals. In December 2000 USACE's remediation contractor, Sevenson Environmental 

Services, Inc., mobilized on Site. 

6 
The cleanup of OU1 was divided into three phases. Phase 1 focused on the cleanup of the 

southern lagoon; Phase 2 focused on the cleanup of the northern lagoon and canal; and 

Phase 3 cleanup efforts were focused on the southern canal. 

The OU1 Phase 1 remedial action involved temporary relocation of one family, the 

purchase of eight residential properties and permanent relocation of the residents, 

demolition of eight single-family homes, and excavation and removal of 64,000 tons of 

soil from the southern lagoon area to off-site treatment and disposal facilities. Soil 

requiring treatment was sent to the Bennett Environmental, Inc., hazardous waste 

incinerator in Saint Ambrose, Quebec, Canada; soils requiring subtitle C disposal were 

sent to the Chemical Waste Management hazardous waste landfill located in Model City, 

New York. Remediation of Phase 1 was completed in June 2002. Ownership of these 

eight properties was transferred from EPA to NJDEP in July 2003. NJDEP sold these 

properties through public auction in the spring of 2008, and these properties were 

subsequently redeveloped into single-family residences. 

s 

The OU1 Phase 2 remedial action included the acquisition of eight residential properties 

and the permanent relocation of residents from the eight properties located over the 

northern lagoon and canal. The houses on the eight lots were demolished and excavation 

of creosote-contaminated soil from this northern lagoon and canal started in April 2002. 

Excavation on this phase reached a depth of 35 feet below the ground surface. 

Approximately 115,600 tons of soil have been excavated and shipped off Site to 

treatment and disposal facilities previously mentioned. These properties have been 

backfilled with clean soil and have been restored. The United States government 

currently owns the eight lots and, through the USACE, has placed the properties up for 

sale. 

OU1 Phase 3 remedial action included the excavation and off-site disposal of 30,605 tons 

of contaminated soil from 13 residential properties and roadways located on the buried 

southern creosote canal. OU1 Phase 3 included the temporary relocation of three families, 

permanent relocation of residents from five properties built over a portion of the buried 

southern creosote waste canal, and the demolition of two of these properties. After 

remediation and restoration, all of the OU1 Phase 3 properties were sold by EPA and 

returned to residential use. The two properties that were demolished were redeveloped 

into single-family residences. 

The remediation of OU2 was divided into two phases. The OU2 Phase 1 remedial action 

consisted of soil removal at 14 residential properties that surrounded the southern lagoon 

area (OU1 Phase 1). The OU2 Phase 1 remedial action involved no permanent relocations 

and no demolitions. The remedial action of this phase started in February 2002. By June 

2002, 8,957 tons of soil had been excavated, treated and/or disposed off Site; the 14 

properties were completely restored; and temporarily relocated residents returned to their 

homes. 

The OU2 Phase 2 remediation began in June 2003. Cleanup activities occurred on 50 

residential properties and portions of residential roadways. The OU2 Phase 2 remedial 

7 
action involved two permanent relocations and no building demolitions. The remediation 

of a day care center was included in this phase. In August 2001, the day care center 

playground was remediated and in 2006 the day care center parking lot was remediated., 

The remedial action of OU2 Phase 2 resulted in the excavation and off-site disposal (with 

treatment as necessary) of 58,984 tons of soil. 

Remediation of OU3 soils began in August 2005. After excavation was started by EPA, 

the Rustic Mall owner demolished all buildings on their property except for a bowling 

alley. The property owner agreed to demolish the buildings above the foundations, which 

were not contaminated, to serve the dual purpose of clearing the area for the remedial 

action and initiating property redevelopment. EPA excavated creosote waste in 

accordance with design documents, including source material found below the footprints 

of the former Rustic Mall buildings. Source material and residual levels of creosote were 

excavated from the Mall property. Approximately 176,000 tons of soil were excavated 

and shipped off site for treatment and/or disposal. The excavation of the OU3 soils was 

completed in November 2007. 

The first round of long-term monitoring of Site groundwater was started in November 

2005, as required by the OU3 ROD. Levels of PAHs in groundwater have, in general, 

declined when compared to the initial groundwater sampling performed prior to the 

remediation of the source areas. 

On March 19, 2008, a pre-fmal inspection of the soil remedy was conducted by EPA, 

USACE and the NJDEP. No major deficiencies were identified during the inspection, a 

punch list of minor items was developed. As the items on the punch list were minor in 

nature, the pre-final inspection served as the final inspection. 

Based upon the results of the final inspection, EPA has determined that the construction 

activity for the entire Site has been completed, the remedy has been implemented 

consistent with each of the RODs, as modified by the ESDs, and the contractors have 

constructed the remedy in accordance with the remedial design plans and specifications. 

Institutional Controls 

Institutional controls have been established for the groundwater and, where appropriate, 

soils at the Site. 

The OU3 ROD required the establishment of a Classification Exception Area (CEA) for 

the area of groundwater contamination. The CEA was established to provide notice that 

the constituent standards for a class IIA aquifer classification are not or will not be met in 

the area of the Federal Creosote Site and that designated aquifer uses are suspended in the 

affected area for the term of the CEA. Additional monitoring wells were installed to 

delineate the CEA, and the CEA was established in January 2010. 

Deed notices were applied at the Site to prevent exposure to residual contaminants in 

soils that were not excavated as part of the remediation. The OU2 ROD anticipated the 

8 
use of deed notices on 23 properties where residual contamination (not source material) 

was left at depths greater than approximately 14 feet. As documented in the 2008 ESD, 

the implemented remedy differed from the ROD by use of deed notices at a number of 

properties where residual contamination remained between two feet and 14 feet in depth. 

Residual contamination was not removed between these depths in order to preserve the 

structural integrity of houses. 

During the implementation of the remedy, all source material encountered in the 

residential development was removed and residual contamination above cleanup goals 

was left beneath 21 properties. All 21 residential property owners applied deed notices to 

their properties where residual contamination remained at levels exceeding the remedial 

goals established for the Site. Consistent with the expectations of the ROD, deed notices 

were applied to six properties where residual contamination remains below 

approximately 14 feet. The remaining 15 properties requiring deed notices have residual 

contamination shallower than 14 feet. The residual contamination remains at depths that 

are inaccessible through normal residential activities. Property owners are required to 

maintain the property in a manner that ensures the deed notice continues to be protective. 

NJDEP is to conduct biennial inspections and certify the continued protectiveness of all 

residential properties containing deed notices. 

In addition to residential properties, on September 2, 2010, the Borough of Manville 

applied deed notices to portions of Borough roads that contained residual levels of 

creosote above remediation goals pursuant to the 2008 ESD. 

A deed, notice was also required on the Rustic Mall commercial property. The owners 

applied a deed notice to this property on December 22, 2011, in accordance with the 

remedy selected in the OU3 ROD. The commercial property owner is responsible to 

conduct biennial inspections and provide certification to NJDEP that specifications of the 

deed notice continue to be protective. 

Community Relations Activities 

A very high level of community concern was demonstrated by residents, commercial 

property owners, business owners, and borough officials at the time the Site was 

discovered in 1997. This level of community concern extended to the completion of 

cleanup activities in 2008. EPA used a number of public outreach tools to interact with 

community members. 

Initially, public meetings were used to convey information to the community. At these 

meetings, residents were informed of plans for indoor air sampling and soil sampling on 

their properties. As results of the sampling events were produced, EPA held public 

availability sessions in which EPA representatives met with residents one-on-one to 

discuss the sampling results. As with the public meetings, these public availability 

sessions were well attended and preferred by many members of the community. A 

Community Advisory Group (CAG) comprised of residents from the Claremont 

Development was formed early in the project. The CAG obtained information from EPA 

9 
and provided community input on the implementation of field activities associated with 

investigations, design and remedial construction. As the project moved through the 

remedial investigation to the remedial design and remedial action, the on-site presence of 

equipment and contractor personnel associated with these activities gained higher 

visibility and became more intrusive to the community. EPA recognized the need to 

increase community relations activities, and provided frequent fact sheets to residents and 

business owners. Informational fact sheets were distributed immediately before field 

activities were to take place in an area of the community. The fact sheets informed the 

community of Site activities such as utility mark-offs, road closures, equipment to be 

used for upcoming work, number of personnel involved in the work and the duration of 

the work as well as upcoming meetings. Since the fact sheets could be produced quickly 

and delivered door-to-door, they were used to convey valued information to community 

members on short notice. In addition, EPA distributed periodic newsletters informing the 

community of cleanup progress and plans for future cleanup activities. EPA held multiple 

interviews with different media (newspaper, television and radio news) to report on 

progress of the Site investigation and cleanup activities. Press events were also held on 

occasion to announce major milestones of the project. Meeting one-on-one with residents 

at their homes was a critical component of community relations activities at this Site. A 

wide range of issues were addressed at these meetings such as access agreements, 

property-specific plans for upcoming environmental testing and remediation, 

interpretation of sampling results, permanent and temporary relocation assistance, and 

residents' concerns regarding intrusive remediation of their properties. 

Site Redevelopment 

To implement the remedy, EPA purchased and demolished houses on 18 residential 

properties. Ten of these properties have been sold and have been redeveloped as singlefamily residences. The remaining eight residential properties have been placed up for sale 

by EPA. All residential properties have been cleaned up to residential standards to allow 

for residential reuse. 

The 15-acre commercial property has been included in the Borough of Manville's 

redevelopment zone. All buildings on the 15-acre commercial property at the Site, except 

for a bowling alley, were razed by the commercial property owners to accommodate 

redevelopment plans. EPA's remedial action of the commercial property immediately 

followed the building demolition conducted by the property owners. The Rustic Mall's 

redevelopment plan calls for mixed commercial and residential reuse of the property, and 

the implemented remedy supports this land use. 

III. Monitoring Results 

The remedial action provided for a rigorous sampling and analysis program. Specifically, 

sampling was required and implemented to protect on-site residents and on-site workers, 

and to confirm compliance with RAOs. Daily real-time air monitoring was conducted 

within the perimeter of the remediation area to detect and quantify total volatile organic 

10 
compounds and respirable particulates. In addition, confirmatory soil samples were taken 

for Site contaminants wherever additional contamination was suspected or known to 

occur. Samples of backfill were analyzed to ensure the NJDEP's soil quality 

requirements were met. 

In addition to air and soil sampling conducted during all phases of the remediation, the 

OU3 ROD called for long-term groundwater monitoring. The objective of the long-term 

groundwater monitoring is to assess the migration and attenuation of creosote in 

groundwater over time. 

IV. Summary of Operation and Maintenance 

Operation, maintenance and monitoring activities at the site include: maintenance of eight 

EPA-acquired residential properties; sale of the eight remaining EPA-acquired residential 

properties; maintenance of the institutional controls; long-term, on-site and off-site 

groundwater monitoring; and adjustments and/or modifications to the groundwater 

monitoring systems. 

As part of the monitoring program, groundwater will continue to be sampled to monitor 

plume properties, including its extent over time to verify that the plume will not expand 

or pose an unacceptable risk to human health and the environment. 

To date, nine rounds of groundwater sampling events have been completed in the 

overburden and the intermediate and deep bedrock zones.. The first two rounds occurred 

in 1999 prior to the excavation of source material and contaminated soil at the former 

lagoons and canals. The long-term monitoring of groundwater was initiated in 2005 by 

sampling 30 monitoring wells and has continued on an annual basis. In 2007, 18 new 

wells were added to the monitoring well network to replace monitoring wells abandoned 

during soil remediation and to further refine groundwater quality monitoring. In 2008, 

based on historical analytical results, contaminant distribution, and monitoring well 

location, 28 wells were designated to be sampled on an annual basis. 

Contaminant concentrations have decreased in the majority of monitoring wells sampled 

since 1999 within the TI zone. The removal of source material through the remedial 

action, and the aging of creosote (being released for more than 60 years) may result in the 

remaining fraction of contaminants to be less soluble and less mobile. This is consistent 

with the limited detections of creosote-related contaminants from monitoring wells 

downgradient of the sources. In addition, monitoring wells outside of the TI zone do not 

show contaminant concentrations above federal, state or risk-based levels. Therefore, 

data evaluation supports that the plume is stable and concludes that it is not migrating 

outside the footprint of the TI zone. Based on the evaluation of natural attenuation 

parameters, the geochemical characteristics of the groundwater in the vicinity of the 

remaining creosote source areas indicate the occurrence of natural attenuation via the 

anaerobic pathway, though not to a degree that would likely result in the aquifer reaching 

ARARs in the foreseeable future. 

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V. Demonstration of Cleanup Activity QA/QC 

The Remedial Action Reports for OU1 Phase 1 dated July 2005, OU1 Phase 2 dated 

August 2008, OU1 Phase 3 dated August 2006, OU2 Phase 1 dated July 2005, OU2 

Phase 2 dated August 2008, and OU3 dated August 2008, found that the construction 

activities at the Site were consistent with the approved construction plans (Design 

Reports, Site Management Plan, Sampling Analysis and Monitoring Plan, Perimeter Air 

Monitoring Plan, De-watering Plan, Waste Management Plan, Excavation and Handling 

Plan, Health and Safety Plan, and Quality Assurance Project Plan). 

The construction contractor adhered to the approved Contractor Quality Control Plan. 

The construction Quality Assurance Project Plan (QAPP) incorporated all USACE and 

EPA requirements. All confirmatory inspections, independent testing, and evaluations of 

materials and workmanship were performed in accordance with the construction 

drawings, technical specifications and QAPP. Construction quality assurance was 

performed by the USACE. The EPA remedial project manager visited the Site on a 

weekly basis, and various state regulators visited the Site approximately once every three 

months during construction activities to review construction progress and evaluate quality 

assurance/quality control (QA/QC) activities. 

Groundwater monitoring has been conducted in accordance with the EPA-approved 

Groundwater Monitoring Program. The long-term groundwater monitoring called for in 

the OU3 ROD, was instituted to collect data on contaminant concentrations and plume 

properties at the Site. A Sampling and Analysis Plan, Field Sampling Plan, and a QAPP 

have been developed to execute the long-term groundwater monitoring. 

The QA/QC program used throughout the remedial actions was rigorous and in 

conformance with EPA standards; therefore, EPA has determined that all analytical 

results are accurate to the degree needed to assure satisfactory execution of the remedial 

actions, and that they are consistent with the ROD and the remedial design plans and 

specifications. 

VI. Five-Year Review 

Hazardous substances, pollutants, or contaminants will remain at the Site above levels 

that allow for unlimited use and unrestricted exposure. In accordance with CERCLA 

Section 121 (c), the remedies at the Site will be reviewed no less than every five years. 

The first five-year review was completed in June 2007. A second five-year review was 

completed on May 3, 2012. This second five-year review determined that the 

implemented actions at the site currently protect human health and the environment 

because soil excavation activities and institutional controls prevent direct exposure to 

contaminated soils. The next five-year review will be completed by May 2017. 

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VTI. Site Completion Criteria 

This Site meets all the site completion requirements as specified in OSWER Directive 

9320.2-22, Close Out Procedures for National Priorities List Sites. The implemented 

remedies achieve the degree of cleanup and protection specified in the RODs for all 

pathways of exposure. Specifically, all actions specified in the 1999, 2000, and 2002 

RODs have been implemented. Excavations of source material and soils exceeding the 

Site-specific cleanup goals have been completed and have been backfilled with clean fill. 

Confirmatory sampling verifies that the remedial activities have achieved the ROD 

cleanup objectives outside the deed restricted areas. Institutional controls are in place to 

further prevent potential exposures to the public. Groundwater ARARs were waived 

through a TI waiver within the overburden and bedrock zones of the 119-acre TI area. 

The plume is stable and contaminants are not detected above federal, state or risk-based 

levels outside of the TI zone. All selected remedial and removal actions, RAOs and 

associated cleanup goals are consistent with agency policy and guidance. 

The continuing efforts at the Site are the annual long-term groundwater monitoring 

activities, biennial inspections and certifications for deed-noticed properties, and 

conducting future five-year reviews. A bibliography of all documents relevant to the 

completion of the work at the Site under the Superfund program is attached. 

13 
Bibliography 

Roy F. Weston, Inc., Focused Engineering Evaluation/Cost Analysis for the Subsurface 

Soils Associated with the Historic Canals and Lagoons at the Federal Creosote Site, 

April 6, 1999. 

Roy F. Weston, Inc., Engineering Evaluation/Cost Analysis for the Subsurface Soils 

Associated with the Historic Canals and Lagoons at the Federal Creosote Site, April 6, 

1999. 

Environmental Protection Agency, Record of Decision Federal Creosote Superfund Site, 

September 28, 1999. 

CDM Federal Programs Corporation, Draft'Final Focused Feasibility Study Report, 

Federal Creosote Superfund Site, Remedial Investigation/Feasibility Study, April 7, 

2000. 

Environmental Protection Agency, Record of Decision Federal Creosote Superfund Site, 

September 29, 2000. 

CDM Federal Programs Corporation, Draft Final Focused Feasibility Study Report, 

Addendum for Operable Unit 3, Rustic Mall Investigation, Federal Creosote Superfund 

Site, June 15, 2001. 

CDM Federal Programs Corporation, Draft Final Feasibility Study Report, Operable 

Unit 3, Groundwater, Surface Water, and Sediment, Remedial Investigation/Feasibility, 

Federal Creosote Superfund Site, August 10, 2001. 

CDM Federal Programs Corporation, Draft Final Remedial Investigation Report for 

Operable Unit 3, Groundwater, Surface Water, and Sediment, Federal Creosote 

Superfund Site, Remedial Investigation/Feasibility Study, July 10, 2001. 

Environmental Protection Agency, Record of Decision Federal Creosote Superfund Site, 

September 29, 2002. 

CDM Federal Programs Corporation, Addendum to Draft Final Feasibility Study Report, 

Operable Unit 3, Groundwater. Surface Water and Sediment, Remedial 

Investigation/Feasibility Study Federal Creosote Superfund Site, June 28, 2002. 

CDM Federal Programs Corporation, Remedial Action Report Federal Creosote 

Superfund Site OU1 Phase 1-Lagoon B, July 2005. 

CDM Federal Programs Corporation, Remedial Action Report Federal Creosote 

Superfund Site OU2 Phase I , July 2005. 

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Environmental Protection Agency, Explanation of Significant Differences Federal 

Creosote Superfund Site, April 17, 2006. 

CDM Federal Programs Corporation, Remedial Action Report Federal Creosote 

Superfund Site OU1 Phase 3, August 2006. 

CDM Federal Programs Corporation, Remedial Action Report Federal Creosote 

Superfund Site OU2 Phase 2, August 2006. 

Environmental Protection Agency, Five-Year Review Report Federal Creosote Superfund 

Site, June 7, 2007. 

Environmental Protection Agency, Relocation Remedial Action Report Federal Creosote 

Superfund Site, September 28, 2007. 

Environmental Protection Agency, Superfund Preliminary Close-Out Report Federal 

Creosote Superfund Site, March 31, 2008. 

Environmental Protection Agency, Explanation of Significant Differences Federal 

Creosote Superfund Site, August 21, 2008. 

CDM Federal Programs Corporation, Remedial Action Report Federal Creosote 

Superfund Site OU1 Phase 2, August 2008. 

CDM Federal Programs Corporation, Remedial Action Report Federal Creosote 

Superfund Site OU3, August 2008. 

CDM, Final Groundwater Monitoring Report Long-Term Groundwater Monitoring -

Year 7, April 2012. 

Environmental Protection Agency, Five-Year Review Report Federal Creosote Superfund 

Site, May 3, 2012. 

15