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-OutProcedures 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), asmodified by aJune 1994 Explanation ofSignificant Differences(ESD). The remedy was implementedin accordance with thesoil 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-acresite is located in an industrial sectionofthe City ofFulton, 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.

277335 liliillllllllllllllllllServices site in Oswego,New York. From 1981 to 1983, Fulton Terminals, Inc., removed several

tanks aspart ofa voluntary cleanup program. These activitiesceased in 1983 afterthe facility was fined by theNew YorkState Department ofEnvironmental Conservation(NYSDEC) for improper disposal ofpolychlorinated biphenyls. The sitewas listed on the NationalPriorities List (NPL) in 1982.
Initial actionsconducted in 1986 by EPA andthe PRPsconsisted ofconstructing a 7-foot perimeter fence aroundthe site,posting warning signs,removingtwo aboveground tanks and twounderground tanks,removing approximately 300 cubicyardsofvisibly-contaminated soil and tar-likewastes, and excavating storm drains that were acting asa conduit forcontaminated runoffentering theOswego River during storm events. An additional removal action in 1990 involved the construction of earthen barriers for the prevention ofsurface runoff from the contaminated portion ofthe 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 wasdeclared invalid by NYSDECdue to problems associatedwith 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 withthe existing site conditions. However, the Supplemental RI/FSdetermined thatthe leaching of VOCs from the contaminated on-site soil into the groundwater posed a risk to the environment.
Remedial Construction Activities
On September29,1989, aRODto control the source ofthe contaminationwas 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 thecontaminated groundwater. The goal ofthe soil remedy in theROD was to reduce concentrations ofVOCs in the fill soils to levelswhich would not causethe groundwater quality to exceedstandardsduetopercolation ofprecipitationthroughtheunsaturated soils. The soil cleanup levels specified in the ROD, which were based on NewYork State groundwater standards and site-specific criteria, were determined through the application ofa 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 inthe 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 andspecifications 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 additionalcontamination in the deep soil (from the water table down to bedrock). Since the contaminated soil below the water table would continue to leach contaminants tothe 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 addressthe area ofimpacted 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 inJanuary 1994). TheFFS also determinedthat specialized methods for stabilising the deep excavation areawould be required forremoval ofthe impacted silt and clay soilsbecause ofthe excavation depth,the need for control ofgroundwater infiltration intothe excavation area, and the close proximityto the Oswego River.
Based on the results ofthe 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 ofthe soil remedy in April 1995and 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 whichwould not cause groundwater quality standards to be exceeded due to leaching from both the unsaturated and saturated soils.
On September24,1996, a final site inspection wasconducted by EPAat thesite withrespect tothe soil remedy. No deficiencies were identified. EPA approved an RA Report, documenting the completion ofthe 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) andNewYork State'sgroundwater quality standards. The action levels established for all VOCs found atthe siteare 5jug/1(proposed MCL and NewYork State'sgroundwater quality standard atthe time of ROD issuance)with the exception of vinyl chloride,which has an action level of 2/zg/1.groundwater from the saturated sandarid gravel zoneunderlying the site, treatingthe groundwater

by air stripping and carbon adsorption, andreinjecting the water into the saturatedsand and gravel zone. The groundwater remediation RD wasinitiated byBlasland, Bouck & Lee, Inc., (BBL) in late 1991. The plansand specificationsrelated tothe groundwater extraction and treatment werecompleted 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 ifthe groundwater extractioncould beeffected immediately. Utilizing amobiletreatment system withcomponentsthat were consistent with the groundwater RD {i.e., air stripping and carbon adsorption), an expedited pumping ofthe contaminated groundwatertook place between February and May 1997. Duringthis 12-week period, 8.8 million gallons of groundwater were extracted and treated. Subsequently, a groundwatermonitoringprogramwasimplementedto assesstheeffectivenessofthe soilremediation 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 infiltrationduring theexcavation andtreatment of the contaminated deepsoil, precluded an accurate evaluation of the groundwater remedy performance. Therefore, the groundwatermonitoring continued through the spring and summer of1999, 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 hasbeen concluded thatthe ROD requirements for the groundwaterremedy have been substantially met4.
EPA's approval of

the RA Report, documenting thecompletion of thegroundwater remediation, is anticipated by September 30,1999. Constructionfor Entire Site Based on the results of the final inspection for the soil remedy and the review of the groundwater monitoring data following theexpedited groundwaterremediation program,it has beendetermined that the construction for the entire site has been completed, the remedy that hasbeen 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 bythe Expedited Groundwater Remediation Work Plan, andno furtherresponse (other than long-term groundwater monitoring) is anticipated.

For example, inthe three on-site sand and gravel aquifer wells RX-3, RX-4, and RX7,vinyl chloride was detected at lessthan 1//g/1(versus an ARAR of2/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/1respectively (versus an ARAR of 5 //g/1).ID. DEMONSTRATION OF CLEANUP ACTIVITY QUALITY ASSURANCE AND

QUALITY CONTROL
RA activities at the site were undertakenin a manner consistent withthe 1989 ROD, as modified by the ESD, and with theRD plans and specifications, as modified by the as-built documentation and by the site. Allapplicable EPA and State quality assuranceand quality control (QA/QC) procedures and protocols wereincorporated intothe RDs. EPA analytical methodswere used for all validation and monitoring samples during all RA activities. All procedures and protocols followed for groundwater, soil, and air sample collectionand analyses during theRA are documented in theRD 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 bytheExpedited GroundwaterRemediation WorkPlan.

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 aClose-Out Report, and deletingthe 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 GroundwaterMonitoring Plan PRP Contractor 11/99 Long-Term Groundwater Monitoring PRP Contractor 12/99-12/02 Determine Whether GroundwaterARARs Have Been Maintained at End of Monitoring EPA 6/03 Complete Decommissioning ofMonitoring 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 9/04V. 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 atthe site have, substantially, met the ROD cleanup levels. The soil and groundwaterremedies implemented at this site are protective of human health and the environment. Although institutional controls are not required as aresult of the implementation ofthese remedies, local authorities may wish to restrict theuse of groundwater in this area due to naturally-occurring metalsor contaminants released from 2upgradient, non-NPL sites. Since groundwater monitoring activities will be performed for an estimated 3 years to ensure the continued effectiveness ofthe 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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