REMEDIAL ACTI01~ REPORT 

GROUNDWATER REMEDY 

FULTON TERMINALS SITE 

Prepared by: 

de mnximis, inc. 

1125 South Cedar Crest Blvd. 

Suite 202 

Allentown, Pennsylvania 18103 

September 24, 1999 

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REMEDIAL ACTION REPORT 

GROUNDWATER REMEDY 

FULTON TERMINALS SITE 

Table of Contents 

Section Numbers and Headings Page No. 

I. INTRODUCTION ....................................................... 1 

II. SITE DESCRIPTION AND HISTORY ...................................... 1 

A. Site Description 

B. Initial and Supplemental Remedial Investigation/Feasibility Studies 

C. Record of Decision 

D. Consent Decree 

K Pre-Remedial Site Investigations 

-F. Focused Feasibility Study 

G. EPA Explanation of Significant Differences 

III. SOIL REMEDY COMPLETION SUMMARY .. · ... ·: :. ~.: . .............. · ....... : .. 4 -- · 

IV. GROUNDcWATER REMEDY OVERVIEW .- >.:-:;, . : : . :; ; .......... ; .< .< ..... 4 

v. 

VI. 

VII. 

VIII. 

IX. 

A. Rationale for the Expedited Pumping Program' · 

B. ExpeditedPumping Pro gram Activities·· 

L Groundwater Extraction 

2. Groundwater Investigation · 

3. Monitoring Well/Piezometer Installation _,, _ 

4. Groundwater Monitoring Prior to Termination of Groundwater Extraction 

5. Groundwater Monitoring Following Termination of Groundwater Extraction 

PERFORMANCE STANDARDS AND CLEANUP GOALS MET/QUALITY 

ASSURANCE (QA), QUALITY CONTROL (QC) ............................. 9 

A. Extraction System Installation 

B. Treatment System Mobilization/Operation 

C. Post Remedy Groundwater Investigation 

FINAL INSPECTION DOCUMENTATION . , .. ; ............................ 11 -· 

CERTIFICATION ... : ...................... ;:,.,,.; :-;; ..................... 11· 

LONG TERM MONITORING ................... · ......................... 11 

REFERENCES ............................. : . ......................... 12·-

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I. INTRODUCTION 

Remedial Action Report, Groundwater Remedy 

Fulton Terminals Site 

September 24, 1999 

Page 1 of12 

This document presents the Final Remedial Action (RA) Report for the grOlmdwater remedy at the 

Fulton Terminals Superfund Site (the Site) in Fulton, New York. This Final RA Report was 

prepared on behalf of the Fulton Terminals Site Remedial Action Trust and under the direction of 

the Site Management Committee (Committee), a group of potentially responsible parties (PRPs), 

who represent the "Settling Defendants" as defined in the Remedial Design (RD) Remedial Actions 

(RA) Consent Decree (Consent Decree) for the Fulton Terminals Site, which was approved by the 

U.S. District Court for the Northern District ofNew York (the Court) on December 13, 1991. This 

Report was prepared consistently with the requirements of the United States Environmental 

Protection Agency (EPA) guidance entitled Remedial Action Report Documentation for Operable 

Unit Completion (June 1992). 

This Report has 'been based on the remedial action work completed at the Site by Clemi Harbors 

. Environmental Services, Inc.(Clean Harbors) and 'Raux Associates, Inc. (Raux) pursuai1ttotheRPA . 

· approved Expe.dited Pumping Program. The remedial action-was consistent with the· September 

·1989 Rec()rcl ofi)ecisioi1 (ROD) and the EPA approved GrDlindwater RemedyFinal Design 

Submittal (Blasland, Bouck & Lee, Inc. (BB&L), 1·994). The work was performed in accordance 

.with the Expedited Groundwater Remediation WorlcPlan (Clean Harhors, 1997) and the El?A 

· ' · , :a,pproved PostSo·il Remedy Groundwaterlnvestigation Work Plan{Rou~v\ssociatess.l997).·~··· .·.· 

II. SITE DESCRIPTION AND HISTORY 

A. Site Description 

The Site is located .in an industrial section of the City of Fulton in Oswego County,:New York. 

Residences; city and county offices, and several businesses are located within a 1 ,500-foot radius of 

the Site. The Site .consists of an approximately 2-acre former storage facility that was used for the 

storage of raw materials used in the manufacture of asphalt roofing from the 1920s through the 

1960s. The storage facility, which formerly contained several above and underground storage tanks, 

was also used in the 1970s and early 1980s for storage of solvents and other materials that were 

originally scheduled for incineration at the Pollution Abatement Services facility in Oswego, 

New York. The Site was listed on the National Priorities List (NPL) in 1982. All aboveground 

tanks and underground tanks, drums, and approximately 300 cubic yards of contaminated soil were 

removed during removal action activities in the mid-1980s. 
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Fulton Terminals Site 

September 24, 1999 

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B. Initial and Supplemental Remedial Investigation/Feasibility Studies 

The initial Remedial Investigation/Feasibility Study (RI/FS) activities were conducted by New York 

State Department ofEnviro1m1ental Conservation (NYSDEC) contractors during 1985 to 1987. The 

EPA and several PRPs conducted the removal action addressing the storage tank, drums and visibly 

contaminated surface soil removal prior to the initial RI/FS activities. The results ofthe initial RI/FS 

activities were declared invalid by NYSDEC due to problems associated with the laboratory 

analyses. A revised RI/FS was prepared by a NYSDEC contractor based on additional sampling 

performed in 1988. The EPA concluded that the revised RI/FS did not fully characterize the Site so 

an EPA contractor conducted a Supplemental Rl/FS. The Supplemental RI/FS was completed in 

1989 and indicated that various volatile organic compounds (VOCs) were detected in unsaturated 

fill soil samples and in groundwater samples from the Site. In 1989, the EPA completed an 

Endangerment Assessment (CDM, 1989) for the Site and concluded that minimal risks were 

associated with current site conditions based on the Supplemental RI data. However, the 

Supplem~ntal R:I/FS identified that the on-site soils were a potentialfuture source ofVOCs leaching 

into groundwater.·· 

C. Record of Decision 

; . The EPA issued the ROD in September 1989followii1g completion of the SupplementalRIAFS;Jfhe 

ROD specified a remedial action consisting ofboth soil and groundwater remedies to address VOCs 

detected in the respective media. The soil remedy required excavation and low temperature thermal 

desorption (LTTD) of unsaturated soil located above the water table (also referred to as "fill soil"), 

within a localized area of the Site as defined by soil borings surrounding the former location of a 

1 ,000,000-gallon.tank used for storage of solvents. The goal of the soil remedy was to reduce 

concentrations~ofVOCs in the fill soils to levels which would not cause an exceedance of applicable 

or relevant and appropriate requirements (ARARs) for groundwater due to percolation of 

precipitation through the unsaturated soils. The soil cleanup levels in the ROD were based on 

New York State groundwater standards and site-specific criteria. 

The groundwater remedy specified in the ROD required the reduction ofVOC concentrations to 

established ARARs in the shallow groundwater by pumping groundwater from a saturated sand and 

gravel zone underlying the Site, treating the groundwater by air stripping and carbon adsorption, and 

reinjecting the water into the saturated sand and gravel zone. 
D. Consent Decree 

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Fulton Terminals Site 

September 24, 1999 

Page 3 of 12 

The United States subsequently entered into a Consent Decree with the Settling Defendants for the 

Site that was approved by the Court on December 13, 1991. The Consent Decree required the 

implementation of the remedial action described in the ROD and specified that a number of work 

plans, design documents, and other deliverables be prepared by the Settling Defendants prior to Site 

remediation. 

E. Pre-Remedial Site Investigations 

Pre-remedial Site investigations conducted during the period December 1992 to January 1993 

resulted in the identification of a new area ofVOC impacted soil in a layer of saturated silt and clay 

belowth.e impacted fill soils and above the sand and gravel zone. The V OCs detected in the silt and 

clay·Jayer, which were not identified during ptevious RI/FS activities, represented a potential 

continuing source of VOCs to the sand and gravel groundwater unit. ·During this period, a preremedial grotmdwater investigation was also conducted, including the installatiOn of additional 

·monitoring wells, monitoring well sampling, and an aquifer pump test. Pump testing of the sand and 

·;gravel groundwater unit indicated that the permeability of the sand and gravel unit was significantly 

higher than anticipated in the Supplemental Rl/FS; The grmmdwater sampling confirmed that VOC 

impacted groundwater in the sand and gravel zone correlated with the same general area ofVOC soil 

impacts in the silt and clay layer. 

Additional field activities were conducted in July 1993 to complete the delineation ofVOC impacts 

in the silt and clay soils, as well as to further characterize groundwater impactsin the sand and gravel 

· unit. Subsequent groundwater investigations were conducted during the period August 1994 to May 

1995. These investigations confirmed that the upper portion of the sand and gravel unit was being 

impacted by VOCs contained in the silt and clay layer. 

F. Focused Feasibility Study 

Remedial alternatives to address the area of impacted soils contained in the silt and clay layer were 

evaluated in a Focused Feasibility Study (FFS) (BB&L, October 1993, as addended January 1994). 

The FFS results provided the basis for the EPA to conclude that the soil remedy should be expanded 

·beyond the area of fill soils identified for remediation in the ROD to include the impacted silt and 

clay soils located beneath the fill soils. The FFS also determined that specialized methods for 

stabilizing the deep excavation area would be required for removal of the impacted silt and clay soils 

because of the excavation depth, the need for control of groundwater infiltration into the excavation 

area and the close proximity to the Oswego River. 

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September 24, 1999 

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G. EPA Explanation of Significant Differences 

Based on the results of the pre-remedial investigations at the Site and the FFS described above? the 

EPA modified the soil remedy in an Explanation of Significant Differences (ESD) dated June 1994. 

This ESD required the excavation and treatment by L TTD technology of soils impacted by VOCs, 

including the impacted silt and clay soils located beneath the fill soils. 

III. SOIL REMEDY COMPLETION SUMMARY 

A temporary ground-freezing system, or "freezewall" was used to control groundwater infiltration 

during excavation facilitating the successful excavation and treatment of approximately 10,200 cubic 

yards of impacted soil. A temporary groundwater treatment system was used to treat over 100,000 

gallons of impacted groundwater. during installation of the freeze piping. A horizontal extraction .· .. ·· 

. well$ystem consisting of a. gallery Qfperforated piping and a collectionmanhole was installed at the • · ·. 

base.oftheArea 1 excavation to facilitate performance of the groundwaterremedy. Final inspection 

of the· soil remedy was conducted in July and September 1996. · A Remedial Action Report 

(de maximis, inc., 1996) for soil was submitted to the EPA on September 24, 1996. The EPA 

approved completion of the soil remedy by letter dated April16, 1997. A Project Closeout Report 

(BBL, 1996) for soil remedy was submitted in October 1996. 

IV. GROUNDWATER REMEDY OVERVIEW 

A. Rationale for the Expedited Pumping Program 

The soil remedy implemented at the Site in 1995 and 1996 employed freezewall technology to isolate 

contaminated soil so that the removal of VOCs below the water table could be effectuated. This 

facilitated a more complete remediation of VOCs in Site soil, and provided for a more timely 

remediationof groundwater. The •. s.uccess of the soil remedy, which has been documented by BB&L · 

in previous submittals (e.g., BB&L, 1996), is summarized as follows: 

• Approximately 99% of the VOC mass contributing to groundwater impacts at the Site was 

successfully removed. 

• Treated soils analyses indicate that VOC concentrations in backfilled soils were significantly 

below the cleanup levels specified in the ROD. 

• Groundwater modeling suggested that the minor volume of impacted Site soil which could 

not be addressed by the soil remedy (due to overgrowth of the freezewall) would not 

· significantly impact groundwater quality or the overall grol.lndwater remedy.· 
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Given the overall effectiveness of the soil remedy and the more favorable hydrogeologic conditions 

in the sand and gravel unit, the PRPs and EPA explored the possibility of expediting the 

groundwater remediation by utilizing a mobile treatment system in place of the design and 

construction of a permanent system. The goal was to complete the groundwater remediation in an 

accelerated and more cost effective manner. The PRPs ultimately proposed an Expedited Pumping 

Program for the Site utilizing mobile treatment components which were consistent with the ROD 

(EPA, 1989) and the Groundwater Remedy Final Design Submittal (BB&L, 1994). By employing 

the mobile system, the PRPs and EPA believed that VOCs could be rapidly removed from the sand 

and gravel groundwater unit and that the groundwater cleanup standards or ARARs could be 

achieved within a shorter time frame than that identified in the ROD. 

The proposed system was discussed with the EPA during an October 22, 1996 meeting in New York 

City, and the EPA gave approval for performance of the Expedited Pumping Program. This program 

was to include agroundwater investigation to evaluate the effectiveness of the Expedited Pumping 

Program and the ability to ·achieve groundwater dean up standards in the sand and gravel unit 

B. Expedited Pumping Program Activities 

1. General 

The Expedited Pumping Program was implemented between February and October 1997, and 

included the following work elements: 

• Pumping of approximately 100 g. p.m. from the existing on-site horizontal groundwater 

extraction well network for a period of approximately 12 weeks. 

• Treatment of approximately 8.8 million gallons of ground water using air stripping and 

carbon polishing techniques. · 

• Reinjection or discharge (to surface water).oftreated ground water. 

• Weeldy sampling and monitoring of influent· and effluent water. 

• Performance of a groundwater investigation to evaluate the effectiveness of the Expedited 

Pumping Program and the ability to achieve groundwater cleanup standards in the sand 

and gravel unit. 

The operation of the groundwater extraction/treatment system (including groundwater 

reinjection/surface water discharge) as well as the weekly influent/effluent monitoring, were 

performed by Clean Harbors. These elements were performed in accordance with the Expedited 

Groundwater Remediation Work Plan (Clean Harbors, 1997). Roux Associates conducted the 

groundwater investigation element of the .Expedited Pumping Program. The groundwater 

investigation was performed in accordance with the Post-Soil Remedy Groundwater Investigation 

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Fulton Terminals Site 

September 24, 1999 

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Work Plan (Raux Associates, 1997) and associated plans. 

2. Groundwater Extraction 

The groundwater treatment system consisted of a clarifier groundwater head tank, chemical addition, 

two primary bag filters, two air strippers, four secondary bag filters, two liquid granular activated 

carbon (GAS) vessels, two vapor GAS vessels, solids collection tank and two temporary storage 

tanks. The treatment system components were consistent with the ROD and the Groundwater 

Remedy Final Design Submittal (BB&L, 1994). 

The system was mobilized to the Site in February 1997, activated on February 11, 1997, and 

operated intermittently during a 3-week initial test period to ensure that the system could meet the 

performance standards. The system was activated continuously on March 7, 1997. Influent/effluent 

sampling was performed weekly from March 13 through May 26, 1997, and monthly progress 

reports detailing the quality and quantity of extracted ground water were submitted to the EPA and 

NYSDEC by Clean Harbors. Concentratio.ns of trichloroethene, vinyl chloride; and 1,1-

dichloroethene were also monitored in the extraction manhole over the course of the 12-week 

pumping program. The system was shut down on May 30, 1997, once influent data indicated that 

the objectives of the Expedited Pumping Program had been achieved and it was determined that 

·. pnmping would no longer provide an efficient means ofVOC mass removal. 

All equipment was drained, decontaminated, secured and demobilized from the Site during the 

period of May 30 through June 4, 1997. 

3. Groundwater Investigation 

The Expedited Pumping Program groundwater investigation was implemented by Raux Associates 

between April and October 1997, and included the following five tasks: 

• Task 1 -monitoring well/piezometer installation; 

• Task 2 - groundwater monitoring prior to termination of groundwater extraction; 

• Task 3 - groundwater monitoring following termination of groundwater extraction; 

• Task 4 - data evaluation/modeling; and 

• Task 5 - supplemental groundwater monitoring. 
4. Monitoring Well/Piezometer Installation 

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September 24, 1999 

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Seven new monitoring wells were installed to monitor water levels and groundwater quality in the 

sand and gravel unit beneath the southwest portion of the Site. Each new monitoring well installed 

during the groundwater investigation was constructed of stainless steel casing and screen, and was 

set to screen the entire thickness of the sand and gravel groundwater unit. 

Two piezometer clusters were installed at the Site: one adjacent to monitoring well RX-3 and one 

at a location approximately halfway between monitoring well RX-3 and the Oswego River. Each 

piezometer cluster consists of three l-inch diameter piezometers screening two feet of the 

uppermost, middle and lowermost portions of the sand and gravel groundwater unit. A stream gauge 

was installed in the Oswego River immediately adjacent to the Site so that water level fluctuations 

in the river could be appropriately considered in the evaluation of observed groundwater level 

changes in the sand and gravel unit beneath the Site. 

5. Groundwater Monitoring Prior to Termination of Groundwater Extraction 

Prior to ·termination of pumping, a groundwater sampling event was conducted to· evaluate 

groundwater quality in the sand and gravel· unit. Groundwater samples were collected on May 7, 

1997 from each new well, existing downgradient well FBW-3, and existing up gradient wells FB WIS, EBMW-6S, and EBMW-6D. All data developed during the May 7 groundwater sampling event 

as well as certain subsequent monitoring events were validated by Trillium, Inc. in accordance with 

the EPA Region II guidelines. 

Immediately following the May 7 sampling event, pressure transducers were installed in selected 

wells and at the stream gauge to monitor water levels in the sand and gravel groundwater unit prior 

to and following a temporary shutdown of the pumping system. Once it was determined that 

groundwater and river water levels were stable, the pumping system was shutdown, and water levels 

were recorded continuously (i.e., every 15 seconds) for four hours. The groundwater recovery data 

were used to confirm that ve1iical capture of the plume was achieved by pumping of the horizontal 

groundwater extraction wells. 

On May 23, 1997, after pumping resumed and equilibrium pumping conditions were re-established, 

water levels were again measured at the new wells and piezometers, at the stream gauge, and at all 

existing Site wells screened in the sand and gravel groundwater unit that were determined to be 

useable. These water level data were used to verify the horizontal and vertical groundwater flow 

directions under pumping conditions. 
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Remedial Action Report, Groundwater Remedy 

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September 24, 1999 

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6. Groundwater Monitoring Following Termination of Groundwater Extraction 

The pumping system was permanently shutdown on May 3 0, 1997 when it was determined that the 

objectives of the Expedited Pumping Program had been achieved. On June 20, 1997, three weeks 

after Expedited Pumping Program groundwater extraction was terminated (sufficient time for the 

groundwater to stabilize), a second groundwater sampling/water level gauging event was conducted 

to evaluate post pumping groundwater quality and flow directions. The primary objective of this 

post pumping sampling event was to confirm that VOC concentrations in the sand and gravel 

groundwater unit had not rebounded following the cessation of pumping. 

Roux Associates conducted two additional groundwater sampling rounds, one in August 1997 and 

one in October 1997. These sampling events were also used to confirm that VOC concentrations 

in the former VOC plume "core" area (i.e., in the vicinity of well RX-3) were not rebounding and 

to continue to assess post pumping conditions in the sand and gravel groundwater unit. This 

monitoring indicated that residual subsurface ice from the former free:;1:ewall precluded an accurate 

evaluation of the groundwater remedy performance. 

A geophysical investigation was performed by HydEng Consultants, Inc. in February 1998 in an 

effort to delineate the extent of residual subsurface ice in the downgradient area of the Site. 

Although the results of the survey were inconclusive, physical observations made during 

performance of the geophysical survey indicated that significant thawing had occurred in some of 

the downgradient wells. 

A work plan to perform monthly groundwater temperature monitoring and quarterly water quality 

sampling on an interim basis pending complete thawing of the residual subsurface ice was 

conditionally approved by EPA on May 16, 1998. This Plan also included temporary thawing of the 

downgradient monitoring wells using high pressure steam. The results of the interim monitoring 

were discussed in a letter repmi, Interim Groundwater Temperature/Quality Monitoring (Roux, 

1998). Temperature and water quality monitoring was performed on a quarterly basis after the 

August 1998 monitoring event in accordance with EPA's November 24, 1998 response letter. 

The interim monitoring has been performed on a quarterly basis since December 1998. Ice is no 

longer present in any of the downgradient monitoring wells. While groundwater temperatures in 

select downgradient wells still exhibit slight temperature anomalies, the sand and gravel groundwater 

unit appears to be nearing equilibrium conditions. 
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Fulton Terminals Site 

September 24, 1999 

Page 9 of 12 

V. PERFORMANCE STANDARDS AND CLEANUP GOALS MET/QUALITY 

ASSURANCE (QA), QUALITY CONTROL (QC) 

A. Extraction System Installation 

The horizontal weJl groundwater extraction system was installed during the 1996 soil remedy 

construction. Documentation concerning construction of the extraction system is found in the final 

Project Closeout Report, Soil Remedy (BB&L, 1996). 

B. Treatment System Mobilization/Operation 

Mobile treatment system components utilized in the Expedited Pumping Program were consistent 

with the September 1989 Record of Decision (ROD) and the Groundwater Remedy Final Design 

(BB&L, Inc., 1994). Prior to continuous operation an initial system start-up test was performed to< 

ensure that the effluent met the performance standards for groundwater re-injection (19 8 9 ROD) and 

surface water discharge (SPDES permit). The treatment system was operated and maintained in 

accordance with the Expedited Groundwater Remediation Work Plan (Clean Harbors, 1997). 

Weekly effluent and continuous flow monitoring was performed by Clean Harbors in accordance 

with the SPDES permit requirements outlined in a January 7, 1997 letter from NYSDEC. Clean 

Harbors also provided monthly reporting to EPA and NYSDEC regarding operation, maintenance 

ahd effluent sampling results for the system. 

The system was operated for a period of approximately three months. Operation was terminated on 

May 30, 1997 once groundwater concentrations in the sand and gravel unit had been substantially 

reduced and pumping was no longer providing an effective means of contaminant mass removal. 

All equipment was drained, decontaminated, secured and demobilized from the Site during the 

period of May 30 through June 4, 1997. Decontamination liquids, treatment sludges, and spent 

carbon were appropriately labeled, manifested and disposed by Clean Harbors in accordance with 

applicable state federal and local laws and regulations. 

Due to capacity limitations for the on-site injection well PW -1, a substantial volume of the effluent 

was discharged to the catch basin. A total of approximately 8,780,648 gallons of ground water was 

treated by the system, with 7,532,948 gallons discharged to the catch basin and the remaining 

1,247,700 discharged to PW-1. 
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C. Post Remedy Groundwater Investigation 

All well installations, groundwater sampling/monitoring and analytical work were performed in 

accordance with the Post-Soil Remedy Groundwater Investigation Work Plan (Roux Associates, 

1997) and subsequent plans approved by EPA. Data validation was performed by Trillium, Inc. in 

accordance with the EPA Region II guidelines. These activities have been appropriately documented 

and reported. Purge water and drill cuttings generated during the field investigation were 

appropriately labeled, manifested and disposed of by Clean Harbors and Parratt Wolf, Inc. in 

accordance with applicable federal, state and local laws and regulations. 

The ROD identified groundwater cleanup standards (ARARs) have been achieved throughout the 

core of the former plume area as monitored by well RX-3. Several downgradient monitoring wells 

located at the downgradient Site boundary and adjacent to the Oswego River exhibit residual 

concentrations of select VOC' s which marginally exceed, but substantially comply with the ROD 

identified ARARs for cis 1,2-dichloroethene (cis 1,2-DCE), trichloroethene (TCE) and/or vinyl 

chloride. With equilibrium conditions nearly re-established in the sand and gravel grotmdwater unit, 

V OC concentrations in the downgradient wells are expected to continue to decline over time. Even 

prior to implementation of the groundwater remedy, no material health, ecological or environmental 

risks were identified at the Site based on historical groundwater quality data. Since performance of 

the groundwater remedy, VOC concentrations remaining in the groundwater in this limited area of 

the Site have been reduced by greater than or order of magnitude. 

Groundwater modeling confirmed that the remaining low level concentrations ofVOCs will degrade 

naturally and that ARARs will be achieved throughout the sand and gravel groundwater unit .within 

a "reasonable" time frame (Roux Associates, 1999). In determining the reasonableness of the model 

predicted remedial time frame, the following site-specific factors were considered: 

• The sand and gravel groundwater unit in this area is a non-potable source of groundwater due 

to naturally occurring and upgradient groundwater impacts. 

• No human health, ecological, or environmental risks are associated with the Site or these 

residual low level concentrations ofVOCs. 

• The Site is located in an industrialized area immediately adjacent to the Oswego River (i.e. 

no downgradient receptors). 

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September 24, 1999 

. Page 11 of 12 

VI. FINAL INSPECTION DOCUMENTATION 

The activities associated with the groundwater remedy did not require emih moving or regrading of 

the Site. Therefore, Site conditions are the same as those observed during the 1996 final inspection 

ofthe soil remedy. 

The Expedited Pumping Program involved tempormy pumping/treatment and discharge of treated 

groundwater. Routine inspections were performed by de maximis as part of the oversight activities 

during the tlu·ee-month program. Site inspections have also been performed by Raux Associates 

during performance of monthly and quarterly groundwater monitoring events. 

VII. CERTIFICATION 

Based on observations during de ma.x:imis' field oversight and the results of the post pumping 

groundwater monitoring, it has been determined that the groundwater remedy has been completed 

consistent with the approved plans and conforms with the substantive requirements ofthe remedy 

selected in the 1989 ROD for the Site. Final groundwater remedy documentation (Project Closeout 

Report) is being prepared by Raux Associates. This certification is contingent upon submission and 

subsequent approval by the Committee and agencies of Raux Associates Project Closeout Report 

for the groundwater remedy. 

VIII. LONG TERM MONITORING 

A plan for sampling and analysis to assess the effectiveness of the groundwater remedy will be 

developed for review and approval by the EPA. The plan will include three (3) years of post remedy 

groundwater monitoring to verify successful performance of the groundwater remedy. The plan will 

also include provisions for performing periodic site inspections to confirm the integrity of the 

groundwater monitoring wells and other site controls and to assess the general condition of the 

property. This plan will also include provisions to perform necessary Site maintenance (i.e., 

vegetation control, fence repairs, etc.) based on the results of the periodic inspections. 

FILE: 3024/finalfultonrareport.wpd 
IX. REFERENCES 

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Remedial Action Report, Groundwater Remedy 

Fulton Terminals Site 

September 24, 1999 

: Page 12 of 12 

Blasland, Bouck & Lee, Inc., Focused Feasibility Study, 'Fulton Terminals Site, Fulton, New York, 

October 1993, As Addended January 1994. 

Blasland, Bouck & Lee, Inc., Groundwater Remedy Final Design Submittal, Fulton Terminals Site, 

Fulton, New York, August 1994, Revised September 1994. 

Blasland, Bouck & Lee, Inc., Environmental Services, Inc., Final Design Submittal- Soil Remedy, 

Fulton Terminals Site, Fulton, New York, March 31, 1995. 

Blasland, Bouck & Lee, Inc., Project Closeout Report, Fulton Terminals Site, Soil Remedy, October 

1996. 

Clean Harbors Environment Service, Inc., Expedited Groundwater Remediation Work Plan, 

Groundwater Treatment System, Fulton Terminals Site, Fulton, New York, January 1997. 

de maximis, inc. Final Remedial Action Report, Soil Remedy, September 1996. 

Focus Environmental, Inc., Perfonnance Test Report, Fulton Terminals Site, Fulton, New York, 

August 199 5. 

Roux Associates, Inc., Post-Soil Remedy Groundwater Investigation Work Plan, Fulton Terminals 

Site, Fulton, New York, November1996, revised April1997. 

Roux Associates, Inc., Draft Expedited Pumping Program Report, Fulton Terminals Site, Fulton, 

New York, November 1997. 

Roux Associates, Inc., Results oflnterim Ground-Water Temperature /Quality Monitoring, Fulton 

Terminals Site, October 1998. 

U.S. Environmental Protection Agency, Office of Emergency and Remedial Response, Rerp_edial 

Action Report Documentation for Operable Unit Completion, June 1992. 

FILE: 3024/finalfultonrareport.wpd