# 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 sz de maximis

### de maximis

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 ofDecision D. Consent Decree K Pre-Remedial Site Investigations -F. Focused Feasibility Study G. EPA Explanation ofSignificant Differences 

### III. SOIL REMEDY COMPLETION SUMMARY
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### IV. GROUNDcWATER REMEDY OVERVIEW .- 

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VI. VII. VIII. IX. A. Rationale

### for the Expedited Pumping Program' · B. ExpeditedPumping ProgramActivities·· L Groundwater Extraction 2. Groundwater Investigation · 3. Monitoring Well/Piezometer Installation _,, _ 4. Groundwater Monitoring Prior to Termination ofGroundwater Extraction 5. Groundwater Monitoring Following Termination ofGroundwater 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
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### 11 REFERENCES
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### 12·-

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I. INTRODUCTION Remedial Action Report, Groundwater Remedy Fulton Terminals Site September 24, 1999 Page 1 of12

This documentpresents 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 behalfofthe Fulton Terminals Site Remedial Action Trust andunder the direction of the Site Management Committee (Committee), a group ofpotentially responsible parties (PRPs), who represent the "SettlingDefendants" 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 ofNewYork (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 Reporthas 'been based on the remedial actionworkcompleted at the Site by Clemi Harbors

.EnvironmentalServices, Inc.(CleanHarbors)and'RauxAssociates, 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 GroundwaterlnvestigationWork**Plan{Rou~v\ssociatess.l997).·~···** .·.· II. SITE DESCRIPTION AND HISTORY A. Site Description The Site is located.in an industrial section of the City ofFulton in Oswego County,:New York. Residences; city and county offices, and severalbusinesses are located within a 1,500-foot radius of the Site. The Site .consists ofan approximately 2-acre former storage facility that was used for the storage ofrawmaterials used in the manufacture of asphaltroofing from the 1920s through the 1960s. The storage facility, whichformerly contained several above andunderground storagetanks, 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 ofcontaminated soil were removed during removal action activities in the mid-1980s.

### demaximis Remedial Action Report, Groundwater Remedy Fulton Terminals Site September 24, 1999 Page 2 of12 B. Initial and Supplemental Remedial Investigation/Feasibility Studies Theinitial RemedialInvestigation/Feasibility Study (RI/FS) activities were conductedby NewYork State DepartmentofEnviro1m1ental Conservation (NYSDEC) contractors during 1985to 1987. The EPA and several PRPs conducted the removal action addressing the storage tank, drums and visibly contaminated surface soilremovalpriorto the initial RI/FS activities. Theresults oftheinitial 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 thatthe 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/FSidentifiedthatthe on-site soils wereapotentialfuture source ofVOCsleaching into groundwater.·· C. Record ofDecision ; . The EPAissuedthe ROD in September 1989followii1g completion ofthe SupplementalRIAFS;Jfhe ROD specifieda remedial action consisting ofboth soil and groundwaterremedies to address VOCs detected intherespective media. The soil remedy required excavation and lowtemperaturethermal desorption (LTTD) ofunsaturated soil located above the watertable (also referred to as "fill soil"), within a localized area ofthe Site as defined by soil borings surrounding the former location ofa 1,000,000-gallon.tank used for storage of solvents. The goal ofthe soil remedy was toreduce**concentrations~ofVOCs** inthe fill soils to levels which wouldnotcause an exceedance ofapplicable 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 inthe shallow groundwaterby pumping groundwater from a saturated sand and gravel zoneunderlyingthe Site, treatingthe groundwaterby air stripping and carbon adsorption, and reinjecting the water into the saturated sand and gravel zone.D. Consent Decree 

### de maximis Remedial Action Report, Groundwater Remedy Fulton Terminals Site September 24, 1999 Page 3 of 12

TheUnited 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 ofthe remedial action described in the ROD and specified that a number ofwork plans, design documents, and other deliverables be prepared bythe Settling Defendants priorto Site remediation. E. Pre-Remedial Site Investigations Pre-remedial Site investigations conducted during the period December 1992 to January 1993 resulted inthe identification ofa new area ofVOC impacted soil in a layer ofsaturated silt and clay belowth.e impactedfill soils and above the sandandgravel zone. The VOCs detected in the silt and clay·Jayer, which were not identified during ptevious RI/FS activities, represented a potential continuing source ofVOCs to the sand and gravel groundwater unit. ·During this period, a preremedial grotmdwater investigation was also conducted, including the installatiOn of additional ·monitoringwells, monitoringwell sampling, and an aquiferpumptest. Pumptesting ofthe sandand ·;gravelgroundwaterunit indicated thatthe permeability ofthe sand and gravel unitwas significantly

higherthan anticipatedinthe Supplemental Rl/FS; Thegrmmdwater sampling confirmedthatVOC impactedgroundwaterinthe sand and gravel zone correlated withthe same general area ofVOC soil impacts in the silt and clay layer. Additional field activities were conducted inJuly 1993 to complete the delineation ofVOC impacts inthe silt andclay soils, as well as to further characterize groundwaterimpactsinthe sand andgravel
· unit.Subsequentgroundwaterinvestigations were conducted duringthe periodAugust 1994to May

1995. These investigations confirmed that the upper portion ofthe 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 ofimpacted soils contained in the silt and clay layerwere evaluated in a Focused Feasibility Study (FFS) (BB&L, October 1993, as addended January 1994). The FFS results providedthe basis for the EPAto conclude thatthe soilremedy shouldbe expanded ·beyond the area offill 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 stabilizingthe deep excavation areawouldberequiredfor removal ofthe impactedsiltand clay soils because ofthe excavation depth, the need for control ofgroundwaterinfiltration into the excavation area and the close proximity to the Oswego River.

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# sz demaximis Remedial Action Report, Groundwater Remedy Fulton Terminals Site September 24, 1999

. Page 4 of12
G. EPA Explanation ofSignificant Differences Based on the results ofthe pre-remedial investigations at the Site and the FFS described above? the EPAmodifiedthe soil remedy in an Explanation ofSignificantDifferences (ESD) dated June 1994. This ESD required the excavation and treatment by LTTD technology ofsoils 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 duringexcavationfacilitating the successful excavationand treatmentofapproximately 10,200cubic yards ofimpacted soil. A temporary groundwatertreatment system was used to treat over 100,000 gallons ofimpacted groundwater.during installation ofthe freeze piping. A horizontal extraction .·.. ··

. well$ystemconsisting of

### a.gallery Qfperforatedpiping and a collectionmanholewas installed atthe •··.

base.oftheArea 1excavationto facilitate performance ofthe 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 ofthe 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 soilremedyimplementedatthe Site in 1995 and 1996 employedfreezewall technologyto isolate contaminated soil so that the removal ofVOCs below the water table couldbe effectuated. This facilitated a more complete remediation of VOCs in Site soil, and provided for a more timely remediationofgroundwater. The •.s.uccess ofthe soil remedy, which has been documentedby BB&L · inprevious submittals (e.g., BB&L, 1996), is summarized as follows:

• Approximately 99% ofthe VOC mass contributing to groundwater impacts at the Site was successfully removed. • Treatedsoils analyses indicatethatVOC concentrations inbackfilled soils were significantly belowthe cleanup levels specified in the ROD. • Groundwater modeling suggested that the minor volume ofimpacted 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.·

## sz demaximis Remedial Action Report, Groundwater Remedy Fulton Terminals Site September 24, 1999 Page 5 of12 Given the overall effectiveness ofthe 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 ofa 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. Theproposed systemwas discussedwiththe EPA during an October22, 1996 meeting inNewYork City, andthe EPAgave approval forperformance ofthe ExpeditedPumpingProgram. Thisprogram was to include agroundwater investigation to evaluate the effectiveness ofthe Expedited Pumping Program and the ability to ·achieve groundwaterdean 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 ofapproximately 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 ofinfluent· and effluent water. • Performance ofa groundwater investigation to evaluate the effectiveness ofthe 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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### demaximis Remedial Action Report, Groundwater Remedy Fulton Terminals Site September 24, 1999 Page 6 of 12 Work Plan (Raux Associates, 1997) and associated plans. 2. Groundwater Extraction The groundwatertreatmentsystem consistedofaclarifiergroundwaterheadtank,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 onMarch 7, 1997. Influent/effluent sampling was performed weekly from March 13 through May 26, 1997, and monthly progress reports detailing the quality and quantity ofextracted ground water were submittedto 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 pumpingprogram. The system was shut down on May 30, 1997, once influent data indicated that the objectives ofthe Expedited Pumping Programhad been achieved and it was determined that
·. pnmping would no longerprovide an efficient means ofVOC mass removal. All equipment was drained, decontaminated, secured and demobilized from the Site during the period ofMay 30 through June 4, 1997. 3. Groundwater Investigation The ExpeditedPumping Program groundwater investigation was implemented by RauxAssociates between April and October 1997, and included the following five tasks:

• Task 1 -monitoring well/piezometer installation; • Task 2 - groundwater monitoring prior to termination ofgroundwater extraction; • Task 3 - groundwater monitoring following termination ofgroundwater extraction; • Task 4 - data evaluation/modeling; and • Task 5 - supplemental groundwater monitoring.4. Monitoring Well/Piezometer Installation 

### demaximis Remedial Action Report, Groundwater Remedy Fulton Terminals Site September 24, 1999

. Page 7 of12

Seven new monitoring wells were installed to monitor water levels and groundwater quality inthe sand and gravel unit beneath the southwest portion ofthe Site. Each new monitoring well installed during the groundwater investigation was constructed ofstainless steel casing and screen, and was set to screen the entire thickness ofthe 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 lowermostportions ofthe sand and gravel groundwaterunit. 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 ofGroundwater 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, 1997fromeachnewwell, existing downgradientwell FBW-3, and existing upgradientwells FBWIS, EBMW-6S, and EBMW-6D. All data developed during the May7 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 inthe sand and gravel groundwater unit prior to and following a temporary shutdown of the pumping system. Once it was determined that groundwater andriver water levels were stable, the pumping systemwas shutdown, andwaterlevels were recorded continuously (i.e., every 15 seconds) for four hours. The groundwaterrecovery data were usedto confirm that ve1iical capture ofthe plume was achieved by pumping ofthe horizontal groundwater extraction wells. OnMay 23, 1997, afterpumpingresumed and equilibriumpumping conditions werere-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.

## sz de maximis Remedial Action Report, Groundwater Remedy Fulton Terminals Site September 24, 1999 : Page 8 of12 6. Groundwater Monitoring Following Termination ofGroundwater Extraction The pumping system was permanently shutdown on May 30, 1997 when it was determined that the objectives ofthe Expedited Pumping Program had been achieved. On June 20, 1997, three weeks after Expedited Pumping Program groundwater extraction was terminated (sufficient time for the groundwaterto stabilize), a second groundwater sampling/waterlevel gauging event was conducted to evaluate post pumping groundwater quality and flow directions. The primary objective ofthis post pumping sampling event was to confirm that VOC concentrations in the sand and gravel groundwater unit had not rebounded following the cessation ofpumping. Roux Associates conducted two additional groundwater sampling rounds, one inAugust 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 ofwell 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 ofthe 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 ofthe 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 ofthe downgradient monitoring wells using high pressure steam. The results ofthe 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 ofthe downgradient monitoring wells. While groundwater temperatures in selectdowngradientwells still exhibit slighttemperature anomalies, the sand and gravelgroundwater unit appears to be nearing equilibrium conditions.

### de maximis Remedial Action Report, Groundwater Remedy 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 ofthe 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 ofDecision (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 thatthe effluentmetthe performance standards for groundwaterre-injection (198 9ROD) 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 aperiod ofapproximately 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 ofcontaminant mass removal. All equipment was drained, decontaminated, secured and demobilized from the Site during the period ofMay 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 ofthe effluent was discharged to the catchbasin. A total ofapproximately 8,780,648 gallons ofground 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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Remedial Action Report, Groundwater Remedy Fulton Terminals Site September 24, 1999

, Page 10 of 12 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 accordancewiththe EPARegionII guidelines. These activities havebeenappropriately 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 ofthe 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 ofselect 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. Withequilibrium conditionsnearlyre-establishedinthe sand andgravel grotmdwaterunit, VOC concentrations inthe downgradient wells are expected to continue to decline overtime. Even priorto implementation ofthe groundwaterremedy, no materialhealth, ecological orenvironmental risks were identified at the Site based onhistorical groundwater quality data. Sinceperformance of the groundwater remedy, VOC concentrations remaining in the groundwater inthis limited area of the Site have been reduced by greater than or order ofmagnitude. Groundwatermodeling confirmedthatthe remaining lowlevel concentrations ofVOCswill degrade naturally and that ARARs will be achieved throughoutthe sand and gravel groundwaterunit.within a "reasonable"timeframe (Roux Associates, 1999). In determiningthe reasonableness of themodel predicted remedial time frame, the following site-specific factors were considered:

• The sand and gravel groundwaterunitinthis areais anon-potable source ofgroundwaterdue 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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### de maximis Remedial Action Report, Groundwater Remedy Fulton Terminals Site September 24, 1999

. Page 11 of 12 VI. FINAL INSPECTION DOCUMENTATION The activities associated with the groundwaterremedy did notrequire emihmoving 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 oftreated groundwater. Routine inspections were performedby de maximisas part ofthe oversight activities during the tlu·ee-month program. Site inspections have also been performed by Raux Associates during performance ofmonthly and quarterly groundwater monitoring events. VII. CERTIFICATION Based on observations during de ma.x:imis' field oversight and the results ofthe 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 selectedinthe 1989 ROD for the Site. Final groundwaterremedy documentation (Project Closeout Report) is beingpreparedby RauxAssociates. This certificationis contingentupon submissionand subsequent approval by the Committee and agencies ofRaux Associates Project Closeout Report for the groundwater remedy. VIII. LONG TERM MONITORING A plan for sampling and analysis to assess the effectiveness ofthe groundwater remedy will be developed for review and approval by the EPA. Theplan will include three (3) years ofpostremedy groundwatermonitoringto verify successfulperformance ofthe groundwaterremedy. Theplanwill 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 ofthe property. This plan will also include provisions to perform necessary Site maintenance (i.e., vegetation control, fence repairs, etc.) based onthe results ofthe periodic inspections.

FILE: 3024/finalfultonrareport.wpd

### IX. REFERENCES 

### de maximis
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, FultonTerminals 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 CloseoutReport, FultonTerminals 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 1995. Roux Associates, Inc., Post-Soil Remedy Groundwater Investigation Work Plan, FultonTerminals 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 ofEmergency and Remedial Response, Rerp_edial Action Report Documentation for Operable Unit Completion, June 1992.

FILE: 3024/finalfultonrareport.wpd