September 1999 

SUPERFUND PRELIMINARY SITE CLOSE-OUT REPORT 

Fulton Terminals Site 

Oswego County, New York 

I. INTRODUCTION 

This Preliminary Close-Out Report documents that the United States Environmental Protection 

Agency (EPA) has determined that construction activities at the Fulton Terminals site have been 

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

Directive 9320.2-09). 

\ 

A final inspection was conducted by EPA on September 24,1996, following the completion of the 

soil remedy. Expedited pumping of contaminated groundwater took place from February to May 

1997. Groundwater monitoring conducted from June 1997 to August 1999 has indicated that no 

further construction is necessary. This decision is consistent with the 1989 source control Record 

of Decision (ROD), as modified by a June 1994 Explanation of Significant Differences (ESD). The 

remedy was implemented in accordance with the soil remedial design (RD) plans and specifications, 

as modified by the as-built documentation1, and the groundwater RD, as modified by the Expedited 

Groundwater Remediation Work Plan2. No further response (other than long-term groundwater 

monitoring) is anticipated. 

II. SUMMARY OF SITE CONDITIONS 

Background 

The 1.5-acre site is located in an industrial section of the City of Fulton, Oswego County, New York, 

within 50 feet of the Oswego River, which is used for recreation. Residences, city and county 

offices, and several businesses are located within a 1,500-foot radius of the site. Approximately 

13,000 people live within 3 miles of the site. 

From 1936 to 1960, the primary activity at the site was the manufacturing of roofing materials, 

which-involved the storage of asphalt in aboveground tanks and fuel oil storage in underground 

tanks. From 1972 to 1977, the site was used by Fulton Terminals, Inc., as a staging and storage area 

for solvents and other materials that were scheduled for incineration at the Pollution Abatement 

The certified October 1996 as-built drawings prepared by Blasland, Bouck & Lee, Inc. 

(BBL), the Potentially Responsible Parties' (PRPs') contractor, constitute the as-built 

documentation for the soil remediation. 

The Expedited Groundwater Remediation Work Plan (January 1997) was prepared by 

Clean Harbors Environmental Services, Inc., a PRP contractor. 

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Services site in Oswego, New York. From 1981 to 1983, Fulton Terminals, Inc., removed several 

tanks as part of a voluntary cleanup program. These activities ceased in 1983 after the facility was 

fined by the New York State Department of Environmental Conservation (NYSDEC) for improper 

disposal of polychlorinated biphenyls. The site was listed on the National Priorities List (NPL) in 

1982. 

Initial actions conducted in 1986 by EPA and the PRPs consisted of constructing a 7-foot perimeter 

fence around the site, posting warning signs, removing two abo veground tanks and two underground 

tanks, removing approximately 300 cubic yards of visibly-contaminated soil and tar-like wastes, and 

excavating storm drains that were acting as a conduit for contaminated runoff entering the Oswego 

River during storm events. An additional removal action in 1990 involved the construction of 

earthen barriers for the prevention of surface runoff from the contaminated portion of the site. 

The initial remedial investigation/feasibility study (RI/FS) activities at the site were conducted by 

NYSDEC's contractor, URS Company, Inc., from 1985 to 1987. The RI/FS report that was 

generated from these efforts was declared invalid by NYSDEC due to problems associated with the 

laboratory analyses. A revised RI/FS report, based on additional sampling, was prepared by 

NYSDEC's contractor in February 1988. EPA concluded, however, that the revised RI/FS report 

did not fully characterize the site. Accordingly, EPA initiated a Supplemental RI/FS. The 

Supplemental RI/FS, completed by EPA's contractor, Ebasco Services, Inc., in July 1989, indicated 

that various volatile organic compounds (VOCs) were detected in the unsaturated soil and in the 

groundwater at the site. An Endangerment Assessment for the site, which was also completed in 

1989, concluded that, based on the Supplemental RI data, minimal human health risks were 

associated with the existing site conditions. However, the Supplemental RI/FS determined that the 

leaching of VOCs from the contaminated on-site soil into the groundwater posed a risk to the 

environment. 

Remedial Construction Activities 

On September 29,1989, aROD to control the source of the contamination was signed, selecting low 

temperature thermal desorption (LTTD) to treat the contaminated unsaturated soils located above 

the v\£ater table (also referred to as "fill soil"), and pumping, air stripping, carbon adsorption, and 

reinjection for treating the contaminated groundwater. The goal of the soil remedy in the ROD was 

to reduce concentrations of VOCs in the fill soils to levels which would not cause the groundwater 

quality to exceed standards due to percolation of precipitation through the unsaturated soils. The soil 

cleanup levels specified in the ROD, which were based on New York State groundwater standards 

and site-specific criteria, were determined through the application of a model. 

A Consent Decree was signed by the PRPs in 1990, in which they agreed to design and implement 

the site cleanup as called for in the ROD. The Consent Decree became effective (was entered as a 

final judgement by the Court) in December 1991. 

Soil Remediation 

The soil excavation and treatment RD was initiated by BBL in late 1991. The plans and 
specifications related to the soil treatment were completed in March 1995. 

The ROD specified that approximately 4,000 cubic yards (CY) of soil above the water table 

exceeding the cleanup standards for VOCs were to be excavated and thermally treated by LTTD. 

Pre-RD sampling, however, revealed additional contamination in the deep soil (from the water table 

down to bedrock). Since the contaminated soil below the water table would continue to leach 

contaminants to the groundwater, EPA concluded that remediating this soil would be beneficial to 

the long-term groundwater cleanup. Based on the pre-RD sampling, the estimated volume of 

contaminated soil increased to 13,000 CY. 

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

the water table were evaluated in a focused feasibility study (FFS) completed by BBL in October 

1993 (addended in January 1994). The FFS also determined that specialized methods for stabilising 

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. 

Based on the results of the pre-RD sampling effort and the findings of the FFS, EPA modified the 

soil remedy in an ESD dated June 1994. The ESD called for the excavation of the VOCcontaminated soils below the water table, followed by treatment by LTTD. 

BBL initiated construction of the soil remedy in April 1995 and completed all thermal treatment and 

backfill work by April 1996. The total amount of contaminated source material remediated was 

10,200 CY. 

The analytical results from post-excavation soil samples collected from the excavation limits 

indicated that the residual levels of VOCs were well below the target levels. Therefore, the 

remediation of the source of contamination has reduced contamination of site soils in both the 

unsaturated and saturated zones to levels which would not cause groundwater quality standards to 

be exceeded due to leaching from both the unsaturated and saturated soils. 

On September 24,1996, a final site inspection was conducted by EPA at the site with respect to the 

soil remedy. No deficiencies were identified. EPA approved an RA Report, documenting the 

completion of the soil remediation, on September 30,1996. 

Groundwater Remediation 

The groundwater remedy called for in the September 1989 ROD required the reduction of VOC 

concentrations to Applicable or Relevant and Appropriate Requirements (ARARs)3 by pumping 

The ARARs for groundwater cleanup include EPA's Maximum Contaminant Levels 

(MCLs) and New York State's groundwater quality standards. The action levels established 

for all VOCs found at the site are 5 jug/1 (proposed MCL and New York State's groundwater 

quality standard at the time of ROD issuance) with the exception of vinyl chloride, which 

has an action level of 2 /zg/1. 
groundwater from the saturated sand arid 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. 

The groundwater remediation RD was initiated by Blasland, Bouck & Lee, Inc., (BBL) in late 1991. 

The plans and specifications related to the groundwater extraction and treatment were completed in 

September 1994. Initiation of the groundwater RA was, however, postponed until all soil RA 

activities at the site were completed. 

Given the overall effectiveness of the soil remedy, it was determined that groundwater standards 

could be achieved within a shorter time frame than that identified in the ROD if the groundwater 

extraction could be effected immediately. Utilizing a mobile treatment system with components that 

were consistent with the groundwater RD {i.e., air stripping and carbon adsorption), an expedited 

pumping of the contaminated groundwater took place between February and May 1997. During this 

12-week period, 8.8 million gallons of groundwater were extracted and treated. Subsequently, a 

groundwater monitoring program was implemented to assess the effectiveness of the soil remediation 

in combination with the expedited groundwater remedy. This monitoring indicated that residual 

subsurface ice from the temporary ground-freezing system, or "freezewall," which was used to 

control groundwater infiltration during the excavation and treatment of the contaminated deep soil, 

precluded an accurate evaluation of the groundwater remedy performance. Therefore, the 

groundwater monitoring continued through the spring and summer of 1999, when it was determined 

that the ice formations in the subsurface had completely thawed and natural groundwater flow 

conditions had been re-established. Based upon a review of the groundwater monitoring data by 

EPA and NYSDEC, it has been concluded that the ROD requirements for the groundwater remedy 

have been substantially met4. 

EPA's approval of the RA Report, documenting the completion of the groundwater remediation, is 

anticipated by September 30,1999. 

Construction for Entire Site 

Based on the results of the final inspection for the soil remedy and the review of the groundwater 

monitoring data following the expedited groundwater remediation program, it has been determined 

that the construction for the entire site has been completed, the remedy that has been implemented 

is consistent with the 1989 ROD, as modified by the ESD, the contractors have constructed the 

remedy in accordance with the RD plans and specifications, as modified by the as-built 

documentation and by the Expedited Groundwater Remediation Work Plan, and no further response 

(other than long-term groundwater monitoring) is anticipated. 

For example, in the three on-site sand and gravel aquifer wells RX-3, RX-4, and RX7, vinyl chloride was detected at less than 1 //g/1 (versus an ARAR of 2 /zg/1), cis-1,2-

dichloroethylene was detected at less than 1 //g/1, 2 //g/1, and less than 1 //g/1 

respectively (versus an ARAR of 5 //g/1), and trichloethylene was detected at less 

than 1 fj.g/1, at 3 //g/1, and at 8 //g/1 respectively (versus an ARAR of 5 //g/1). 
ID. DEMONSTRATION OF CLEANUP ACTIVITY QUALITY ASSURANCE AND 

QUALITY CONTROL 

RA activities at the site were undertaken in a manner consistent with the 1989 ROD, as modified by 

the ESD, and with the RD plans and specifications, as modified by the as-built documentation and 

by the site. All applicable EPA and State quality assurance and quality control (QA/QC) procedures 

and protocols were incorporated into the RDs. EPA analytical methods were used for all validation 

and monitoring samples during all RA activities. All procedures and protocols followed for 

groundwater, soil, and air sample collection and analyses during the RA are documented in the RD 

reports, and the sample analyses were performed at state-certified laboratories. 

The QA/QC program used throughout the soil and groundwater RAs was rigorous and in 

conformance with EPA and State standards; therefore, EPA and the State determined that all 

analytical results are accurate to the degree needed to assure satisfactory execution of the RAs, 

consistent with the 1989 ROD, as modified by the ESD, and the RD plans and specifications, as 

modified by the as-built documentation and by the Expedited Groundwater Remediation Work Plan. 

IV. ACTIVITIES AND SCHEDULE FOR COMPLETION 

The activities that remain to be completed for the site include approving the groundwater RA report, 

preparing the long-term groundwater monitoring plan, determining Whether groundwater cleanup 

standards continue to be maintained at the end of the 3-year monitoring period, decommissioning 

the monitoring Wells, conducting a final inspection, preparing a Close-Out Report, and deleting the 

site from the NPL. These activities will be completed according to the following schedule. 

Activity Responsibility Date 

Approve RA Report EPA 9/99 

Finalize Long-Term Groundwater Monitoring Plan PRP Contractor 11/99 

Long-Term Groundwater Monitoring PRP Contractor 12/99-12/02 

Determine Whether Groundwater ARARs Have Been 

Maintained at End of Monitoring 

EPA 6/03 

Complete Decommissioning of Monitoring Wells PRP Contractor 8/03 

Final Inspection EPA/State 9/03 

Approve Final Close-Out Report EPA 9/03 

Five Year Review EPA 9/04 

Deletion From NPL EPA 9/04 
V. FIVE-YEAR REVIEW 

The soil remedies implemented at this site provide for unlimited use of the site and unrestricted 

exposure. The soil and groundwater remedies implemented at the site have, substantially, met the 

ROD cleanup levels. The soil and groundwater remedies implemented at this site are protective of 

human health and the environment. Although institutional controls are not required as a result of 

the implementation of these remedies, local authorities may wish to restrict the use of groundwater 

in this area due to naturally-occurring metals or contaminants released from 2 upgradient, non-NPL 

sites. 

Since groundwater monitoring activities will be performed for an estimated 3 years to ensure the 

continued effectiveness of the remedy, a five-year review will be conducted as a matter of policy. 

The first 5-year review of the groundwater remedy will be performed before September 2004. 

Approved: 

Richard L. Caspe, P.E., Director 

Emergency and Remedial Response Division 

Date 

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