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2014 ANNUAL PROGRESS REPORT

Corrective Measures Implementation at Pharmacia & Upjohn Company LLC Site North Haven, Connecticut RCRA I.D. No. CTD001168533 Submitted To: Pfizer Inc on behalf of Pharmacia & Upjohn Company LLC Submitted By: Golder Associates Inc. 200 Century Parkway, Suite C Mt. Laurel, NJ 08054 Distribution: USEPA – Region I CTDEEP Mabbett & Associates, Inc. Booz Allen Hamilton Town of North Haven Pfizer Inc Quantum Management Group, Inc. Woodard & Curran, Inc. Robinson & Cole, LLP NorthStar URS Corporation Brown and Caldwell TerraTherm, Inc. Vita Nuova, LLC Golder Associates Inc. January 2015 Project No. 033-6231-002

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January 2015 ES-1 033-6231-002

EXECUTIVE SUMMARY The 2014 Annual Progress Report (Annual Report) for the Pharmacia & Upjohn Company LLC Site has

been prepared on behalf of Pharmacia & Upjohn Company LLC, (Pharmacia & Upjohn) for the Pharmacia

& Upjohn Facility located at 41 Stiles Lane in North Haven, Connecticut (Site). The Annual Report was

prepared in accordance with the Administrative Order on Consent (Order) issued to Pharmacia & Upjohn

by the United States Environmental Protection Agency (USEPA) pursuant to Section 3008(h) of the

Resource Conservation and Recovery Act (RCRA). The Order (Docket Number RCRA-01-2011-0027)

was executed on March 31, 2011 and covers Corrective Measures Implementation (CMI) at the Site. The

RCRA identification number for the Site is CTD001168533.

Pfizer Inc (Pfizer) assumed responsibility for the Site on April 16, 2003 as a result of its acquisition of the

Pharmacia Corporation. Pharmacia Corporation was converted to a limited liability company (LLC) on or

about November 30, 2012 and is now known as Pharmacia LLC. Pharmacia & Upjohn Company LLC,

which owns and operates the Site, continues to be a subsidiary of Pharmacia LLC, and both are indirect

wholly-owned subsidiaries of Pfizer. There are no active commercial or industrial activities at the site,

however, current Site use includes the operation and maintenance of the existing interim remedial

systems, including a groundwater extraction system and a groundwater treatment facility, along with

activities to design and construct the final Site-wide Corrective Measures selected for the Site on

September 10, 2010 by USEPA with the concurrence of the Connecticut Department of Energy and

Environmental Protection (CTDEEP) and as specified in the Order.

Although Pfizer never operated on the property, Pfizer takes seriously its responsibility to address the

conditions at the Site in order to protect human health and the environment. Pfizer will direct activities

associated with the implementation of the Corrective Measures and compliance with the Order, including

primary interaction with USEPA, CTDEEP and the Town of North Haven. Pfizer will also build upon past

and present community outreach activities to ensure appropriate public engagement during the

implementation of the Corrective Measures. In all cases, representatives of Pfizer are acting on behalf of

Pharmacia & Upjohn, who is the Respondent to the Order.

During 2014, the CMI Team of contractors and consultants assembled by Pharmacia & Upjohn continued

designing and implementing the Corrective Measures in accordance with the Order. Major activities and

achievements included:

CTDEEP approved the Engineered Control Fact Sheets associated with the ESRC cover systems on April 11, 2014 and USEPA approved the revised East Side Remedial Components (ESRC) Corrective Measures Design Report (CMDR) and the Groundwater Extraction System (GWES) Final Design (FD) on August 5, 2014.

By the end of 2014, the GWES configuration described in the GWES FD was operating; the sediment removal activities were completed; the low permeability cover systems on

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the North Pile, South Pile, and Former Aeration Lagoons had been constructed; and the protective barrier covers had been placed over the remainder of the ESRC area. The ecological enhancements had been planted in the northern portion of the Site and the major ESRC task remaining for 2015 was the installation of the ecological enhancements on the southern portion of the ESRC.

USEPA approved the In-Situ Thermal Remediation (ISTR) Pilot Study Report and Preliminary Design Proposal (PDP) on August 21, 2014, concurring with the proposal that the full-scale ISTR treatment system to be constructed in Dense Non-Aqueous Phase Liquid (DNAPL) Subareas A and B be designed to provide a subsurface treatment temperature of 100 oC. The submission of the Full Scale In Situ Thermal Remediation Draft Final Design Report (Full-Scale ISTR DFD) was completed on December 11, 2014.

The CMI Team obtained a Town of North Haven Site Plan Approval for the full-scale ISTR system and began construction in August 2014. During 2014, TerraTherm installed the imported fill layer to create a vadose zone for vapor collection, installed the ISTR operational wells, and constructed the lightweight concrete vapor cover system over the target treatment zone (TTZ). Upgrades to the Site electrical and gas utilities were also completed in preparation for full-scale ISTR operations.

Continued to operate and monitor the GWES. Based on the monitoring data collected, the GWES continued to maintain hydraulic control of Unit 1 groundwater throughout 2014. The extracted groundwater continued to be treated at the Groundwater Treatment Facility (GWTF) in accordance with the Site National Pollutant Discharge Elimination System (NPDES) permit issued by CTDEEP.

Collected groundwater monitoring samples, which continued to show that Unit 1 groundwater being extracted by the GWES and managed at the GWTF exceeds comparative criteria before treatment. The groundwater samples also confirmed that samples of Unit 3 groundwater from locations along the Site perimeter remain below the comparative criteria and provided additional data concerning groundwater conditions in the vicinity of Unit 3 well SEC-7D.

As part of the progress towards implementation of the corrective measures, during 2014 the CMI Team

has achieved, ahead of schedule, the following Major Milestones and Progress Goals specifically defined

in the Order:

Activity Milestone Type Milestone Date

Date Achieved

Submit Full-Scale ISTR Draft Final Design Progress Goal 9/25/2015 12/11/2014

Pfizer and the CMI Team have worked closely with USEPA and CTDEEP and the Town of North Haven

(Town) throughout the year. Progress reports were provided to USEPA, CTDEEP, and the Town on a

quarterly basis. Monthly teleconferences were held with USEPA and CTDEEP to keep the agencies

apprised of project progress, to obtain agency input and conduct technical reviews, and coordinate

focused teleconferences to discuss specific technical matters. In addition, Pfizer has involved the Town

community during the project, including regularly meeting with the Citizens’ Advisory Panel (CAP).


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In general accordance with the Order, the 2014 Annual Report is divided into the following six Sections:

Section 1 describes the requirements of the Order in relation to the Annual Report and provides a brief summary of background information regarding the Site and the Corrective Measure selected by USEPA with concurrence from CTDEEP

Section 2 summarizes the principal CMI activities completed during 2014

Section 3 provides the hydrogeologic and chemical data collected in 2014 as part of the CMI Groundwater Monitoring Program, the GWTF Operations, Monitoring & Maintenance (OM&M), and other sampling efforts.

Section 4 assesses the performance of the existing interim corrective measures and the final Corrective Measures being installed at the Site

Section 5 describes the institutional control monitoring activities conducted during 2014

Section 6 discusses the OM&M monitoring and major CMI activities planned for 2015

A list of acronyms and abbreviations is provided immediately after the Table of Contents. The Annual

Progress report also includes supporting appendices that provide graphical or tabular presentations of

key operational and monitoring data, technical analysis of the data, and copies of the laboratory reports.

In accordance with the Order, copies of this Annual Report are being made available on

the www.upjohnnorthhaven.com website that provides information to the public concerning CMI progress.

Due to space constraints the appendices have not been provided in the website copy. Interested readers

can review the complete report through the digital document repository that can be accessed from the

North Haven Memorial Library, or by contacting Pfizer or USEPA.


http://www.upjohnnorthhaven.com/

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Table of Contents EXECUTIVE SUMMARY ........................................................................................................................ ES-1

LIST OF ACRONYMS ................................................................................................................................... iii

1.0 INTRODUCTION .............................................................................................................................. 1 1.1 Overview ............................................................................................................................. 1 1.2 CMI Progress Reporting ..................................................................................................... 2

1.2.1 Annual Progress Reports ....................................................................................... 2 1.2.2 Quarterly Progress Reports ................................................................................... 2

1.3 Site Description ................................................................................................................... 3 1.3.1 Site History and Current Use ................................................................................. 3 1.3.2 Site Geology and Hydrogeology ............................................................................ 4

1.4 Description of Selected Corrective Measure (Remedy) ...................................................... 5 1.5 Performance Standards and Master Plan Schedule ........................................................... 6

2.0 PRINCIPAL ACTIVITIES CONDUCTED ......................................................................................... 9 2.1 Communications with USEPA and CTDEEP ...................................................................... 9 2.2 Groundwater Treatment Facility Permitting and Operation .............................................. 10 2.3 CMI Groundwater Monitoring ............................................................................................ 11 2.4 Non-Routine Sampling and Monitoring ............................................................................. 12

2.4.1 Unit 3 Well SEC-7D ............................................................................................. 12 2.4.2 Full-Scale ISTR PDI ............................................................................................. 14

2.5 East Side Remedial Components ..................................................................................... 14 2.5.1 Agency Review of the ESRC CMDR and GWES DFD ........................................ 14 2.5.2 ESRC Design and Permit Modifications .............................................................. 15 2.5.3 ESRC Remedial Construction .............................................................................. 16

2.6 In-Situ Thermal Remediation ............................................................................................ 24 2.6.1 In-Situ Thermal Remediation Pilot Study ............................................................. 24 2.6.2 In-Situ Thermal Remediation Draft Final Design ................................................. 24 2.6.3 Town of North Haven Approvals for Full-Scale ISTR .......................................... 25 2.6.4 Utility Upgrades .................................................................................................... 26 2.6.5 Full-Scale In-Situ Thermal Remediation System Construction ............................ 26

2.7 Community Outreach ........................................................................................................ 28

3.0 DATA SUMMARY AND CONCLUSIONS ...................................................................................... 31 3.1 Assessment of Performance of the Groundwater Extraction Systems and Groundwater

Treatment System ............................................................................................................. 31 3.1.1 Summary of GWES Operations, Monitoring and Maintenance ........................... 31 3.1.2 Treatment System Monitoring .............................................................................. 32 3.1.3 GWES Hydraulic Control Monitoring ................................................................... 32

3.2 Groundwater Quality Monitoring ....................................................................................... 35 3.2.1 Groundwater Data Collection and Review Activities ............................................ 35 3.2.2 Unit 1 Groundwater Sample Results.................................................................... 37 3.2.3 Unit 3 Groundwater Sample Results.................................................................... 38

3.3 Other Data Generated ...................................................................................................... 39 3.3.1 SEC-7D PDI/PDP................................................................................................. 39 3.3.2 ISTR Thermal Treatment Zone Monitoring .......................................................... 40 3.3.3 ESRC Construction Quality Assurance Sampling ............................................... 40 3.3.4 ISTR Construction Quality Assurance ................................................................. 40

4.0 ASSESSMENT OF PERFORMANCE OF CORRECTIVE MEASURE .......................................... 41

5.0 INSTITUTIONAL CONTROL MONITORING ACTIVITIES ............................................................ 44

6.0 PROJECTED 2015 MONITORING ACTIVITIES AND MASTER PLAN SCHEDULE ................... 47 6.1 Schedule of OM&M Sampling ........................................................................................... 47


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6.1.1 Objective 1: Unit 1 Groundwater Hydraulic Control Monitoring .......................... 48 6.1.2 Objective 2: Evaluation of Post-ESRC Groundwater Flow Directions ................ 50 6.1.3 Objective 3: Unit 1 Groundwater Quality Outside HBW...................................... 51 6.1.4 Objective 4: Demonstrate Compliance with Unit 3 Performance Standards at

Downgradient Property Boundary ........................................................................ 52 6.1.5 Objective 5: Groundwater Chemistry and Hydraulic Gradients in the Vicinity of

Unit 3 Well SEC-7D ............................................................................................. 52 6.1.6 Objective 6: Confirm Groundwater Quality Data Collected at Unit 4 Well

GW-U402A ........................................................................................................... 53 6.1.7 Objective 7: Monitor Changes in Unit 3 Groundwater Quality During Full-Scale

ISTR ..................................................................................................................... 54 6.2 Proposed Modifications To The Annual OM&M Activities ................................................ 54 6.3 Master Plan Schedule ....................................................................................................... 54

7.0 REFERENCES ............................................................................................................................... 57

List of Tables Table 1 Summary of Well Completion Information Table 2 CMI Groundwater Monitoring Scope Table 3 Target Analytes and Comparative Criteria Table 4 Summary of Detected Compounds in Unit 1 Groundwater Data – 2014 CMI Groundwater

Monitoring Table 5 Summary of Detected Compounds in Unit 3 Groundwater Data – 2014 CMI Groundwater

Monitoring Table 6 2015 Groundwater Elevation Monitoring Locations Table 7 2015 Groundwater Sampling Locations

List of Figures Figure 1 Site Location Map Figure 2 Base Map and Groundwater Monitoring Points Figure 3 Master Plan Schedule (December 31, 2014) Figure 4 Piezometric Contour Map Unit 1 at High-Tide (March 25, 2014) Figure 5 Piezometric Contour Map Unit 1 at Low-Mid-Tide (March 25, 2014) Figure 6 Piezometric Contour Map Unit 1 at High-Tide (August 5, 2014) Figure 7 Piezometric Contour Map Unit 1 at Low-Mid-Tide (August 5, 2014) Figure 8 Unit 1 Groundwater Concentration Summary (September 2014) Figure 9 Units 3 CMI Exceedance Summary (2014) Figure 10 2015 Unit 1 Monitoring Locations Figure 11 2015 Unit 3 and Unit 4 Monitoring Locations

List of Appendices Appendix A Key Agency Correspondence Appendix B Well Completion and Abandonment Reports Appendix B-1 Well Completion Report Appendix B-2 ISTR Area Well Abandonment Report Appendix C GWES/GWTF OM&M Data Appendix D Groundwater Elevation Monitoring Appendix D-1 Groundwater Elevation Monitoring and Piezometric Contours Appendix D-2 Continuous Groundwater Elevation Monitoring Appendix E Data Quality Assessment Appendix F Laboratory Data Packages Appendix F-1 CMI Monitoring Data


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Appendix F-2 SEC-7D Area Monitoring Data Appendix F-3 ISTR Thermal Treatment Zone Monitoring Data Appendix G Time-Versus-Concentration Graphs with Regression Analyses Appendix H Other Data Appendix H-1 SEC-7D Area Monitoring Appendix H-2 ISTR Thermal Treatment Zone Monitoring Appendix H-3 ESRC Cover System CQA Appendix H-4 ISTR CQA


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ACRONYM DEFINITION

APS Additional Polluting Substances ASGECI Amy S. Greene Environmental Consultants, Inc. CAMP CAP

Community Air Monitoring Program Citizens’ Advisory Panel

CMDR Corrective Measures Design Report CMI Corrective Measures Implementation CMS Corrective Measures Study CQA Construction Quality Assurance CQC Construction Quality Control CTDEEP Connecticut Department of Energy and Environmental Protection DNAPL Dense Non-Aqueous Phase Liquid E&S Erosion & Sedimentation EC Engineered Control ELUR Environmental Land Use Restrictions ESRC East Side Remedial Components FBR Fluidized Bed Reactor FIR Final Investigation Report FPL Former Polishing Lagoon GAC Granular Activated Carbon GWES Groundwater Extraction System GWES FD Groundwater Extraction System Final Design GWTF Groundwater Treatment Facility HBW Hydraulic Barrier Wall ICVC Industrial/Commercial Volatilization Criteria IRMs Interim Remedial Measures ISTR In-Situ Thermal Remediation IWC Inland Wetlands Commission MPS MSL

Media Protection Standards Mean Sea Level

NPDES National Pollutant Discharge Elimination System OLISP CTDEEP Office of Long Island Sound Programs OM&M Operation, Monitoring, and Maintenance P&ZC Planning and Zoning Commission PCBs Polychlorinated Biphenyls PDI Preliminary Design Investigation PDP Preliminary Design Proposal QA/QC Quality Assurance/Quality Control QMG Quantum Management Group RCRA Resource Conservation and Recovery Act SIM

Selective Ion Monitoring


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ACRONYM DEFINITION

SRS Solids Removal System SVOCs Semivolatile Organic Compounds SWPC Surface Water Protection Criteria TSCA Toxic Substances Control Act TTZ USACE

Target Treatment Zone US Army Corps of Engineers

USEPA United States Environmental Protection Agency UV/Oxidation Ultra Violet Light/Hydrogen Peroxide VOCs Volatile Organic Compounds WWTR Wastewater Treatment Residuals


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1.0 INTRODUCTION

1.1 Overview This 2014 Annual Progress Report (Annual Report) has been prepared by Golder Associates Inc.

(Golder) on behalf of Pharmacia & Upjohn Company LLC (Pharmacia & Upjohn) for the Pharmacia &

Upjohn Facility located at 41 Stiles Lane in North Haven, Connecticut (Facility or Site). The Resource

Conservation and Recovery Act (RCRA) ID number for the Facility is CTD001168533. The location of the

Site is shown on Figure 1. Site features, the conceptual layout of East Side Remedial Components

(ESRC), and monitoring points are shown on the base map provided as Figure 21. This Annual Report

was prepared in accordance with the Administrative Order on Consent (Order) issued to Pharmacia &

Upjohn by the United States Environmental Protection Agency (USEPA) pursuant to Section 3008(h) of

RCRA. The Order (Docket Number RCRA-01-2011-0027) was executed on March 31, 2011 and covers

Corrective Measures Implementation (CMI) at the Site (USEPA, 2011).

USEPA retains lead regulatory oversight and jurisdiction for the CMI phase of work under the Order. The

Connecticut Department of Energy and Environmental Protection (CTDEEP) also provides regulatory

oversight in support of the USEPA. The implementation of the corrective measure is intended to satisfy

the Connecticut Transfer Act requirements and be accepted by the CTDEEP as the Site Remedial Action

Plan. In addition, the implementation of the corrective measure is intended to satisfy CTDEEP’s

requirements for final closure of the RCRA units identified at the Site and to satisfy the CTDEEP

Remediation Standard Regulations (RSRs) (CTDEEP, amended June 27, 2013). Approvals from other

regulatory agencies, such as the US Army Corps of Engineers (USACE) and CTDEEP Office of Long

Island Sound Programs (OLISP) and from the Town of North Haven will also be obtained as appropriate

for the implementation of the corrective measures.

Pfizer Inc (Pfizer) assumed responsibility for the Site on April 16, 2003 as a result of its acquisition of the

Pharmacia Corporation. Pharmacia Corporation was converted to a limited liability company (LLC) on or

about November 30, 2012 and is now known as Pharmacia LLC. Pharmacia & Upjohn Company LLC,

which owns and operates the Site, continues to be a subsidiary of Pharmacia LLC, and both are indirect

wholly-owned subsidiaries of Pfizer. Pfizer, the parent company of Pharmacia & Upjohn, has assembled

a team of consultants and contractors (CMI Team) and directs activities associated with the

implementation of the final Site-wide corrective measure (or remedy) and compliance with the RCRA

3008(h) Order, including primary interaction with USEPA and CTDEEP. In all cases, representatives of

Pfizer are acting on behalf of Pharmacia & Upjohn, who is the Respondent to the Order.

1 This base map contains a snapshot of the monitoring wells present at the Site as of December 31, 2014 and reflects well installations and abandonments completed throughout 2014. As a result, monitoring points appearing as abandoned on Figure 2 may have been used in for a portion of 2014 and discussed in this Annual Report but abandoned at some point later in.


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1.2 CMI Progress Reporting Section VII.C of the Order describes the general requirements to provide Annual and Quarterly Progress

Reports to USEPA, as discussed below.

1.2.1 Annual Progress Reports The specific requirements for Annual Reports, as presented in Attachment 3.II.D.2 of the Order, are listed

below and the Section of this Annual Report where each requirement is addressed as shown in

parenthesis:

a. A narrative summary of principal activities conducted; (Section 2)

b. Graphical or tabular presentations of key operational and monitoring data and copies of the analytical data; (Section 3)

c. An assessment of the performance of the Corrective Measure during the previous year: (Section 4)

d. A schedule of sampling and field activities to be performed and reported in the following year and any proposed modifications to the annual Operations, Monitoring and Maintenance (OM&M) activities. (Section 6)

e. Confirmation that the institutional control monitoring activities required by Section VII.B.5 have occurred. (Section 5)

“Corrective Measures” as defined by the Order are currently being designed or are in the process of being

installed. Progress updates on Corrective Measures installed during this reporting period are

summarized in Section 2 of this Annual Report. A description of the Interim Remedial Measures (IRMs) is

presented in Section 1.3 and updates to the status of the IRMs have been provided to USEPA and

CTDEEP on a quarterly basis throughout 2014. The effectiveness of existing interim remedial measures,

the corrective measures components installed, and other controls put in place during CMI in 2014 is

summarized in Section 4. As corrective measures design and construction progress, future Annual

Reports will cover final corrective measures effectiveness. Similarly, several of the institutional controls

required by the Order, such as Environmental Land Use Restrictions (ELURs), will not be in place until

the corrective measures are completed, therefore Section 5 of this report focuses on confirming the

monitoring of the institutional controls currently in place.

1.2.2 Quarterly Progress Reports The Order also requires reporting of CMI progress to USEPA on a quarterly basis. During 2014,

Pharmacia & Upjohn submitted quarterly progress reports to USEPA and CTDEEP for the following

reporting periods (submittals dates are in parenthesis):

January through March 2014 (April 30, 2014)

April through June 2014 (July 30, 2014)


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July through September 2014 (October 30, 2014)

October through December 2014 (January 26, 2015)

These quarterly progress reports provide a detailed account of CMI progress, list the data collection

activities throughout the year, and provide a short-term projection of work to be completed during the

upcoming reporting period. This Annual Report presents an overview of the CMI activities completed

throughout the year and focuses on the presentation and the evaluation of data collected during the year.

1.3 Site Description The Site consists of an approximately 80-acre parcel of land located within a commercial/industrial area

of North Haven, Connecticut, as shown on Figure 1. The Site lies within an area of North Haven,

Connecticut that is isolated from residential communities by active rail lines (west side); inactive and

active industrial sites (e.g., the Circuit Wise facility; Precision Combustion and SK PT LLC (i.e. Spectrix,

formerly Lake A)), former off-site landfill, and South Creek (southwest and south sides); the State Route

40 highway and embankment, inactive industrial sites (e.g., the Humphrey Chemical Site), and North

Creek (north side); and, the Quinnipiac River and Interstate 91 (east side). The small parcel of

predominantly tidal wetlands adjacent to the northeast corner of the Site is referred to as the North Haven

Land Trust property. The surrounding properties have been used for a variety of industrial activities since

the early 1800s.

1.3.1 Site History and Current Use The Site was used for industrial manufacturing beginning in the mid-1800s, when I.L. Stiles & Sons

operated a clay mine and brick yard into the 1930s. The Site was then used by Carwin Chemical

Company for chemical manufacturing from the mid-1940s to 1962 and by the Burndy Corporation for

electrical component manufacturing from circa 1963 to 1975. Beginning in 1962, Upjohn produced

specialty and industrial chemicals including pharmaceutical, dye, pigment, and photographic

intermediates, agricultural treatment chemicals, ultraviolet curing initiators, coating and adhesive

additives, and flavor and fragrance components. Chemical manufacturing continued until 1993, when the

manufacturing facilities (buildings, tanks, and pipelines) were dismantled and demolished to grade.

Wastes generated at the Site during historical operations primarily included chemical manufacturing

process wastes and wastewater treatment residuals (WWTR) consisting of several different types of

organic chemicals and metals, including, among others, volatile organic chemicals (VOCs), semivolatile

organic compounds (SVOCs), polychlorinated biphenyls (PCBs), and lead. A more detailed Site

description, including a detailed conceptual Site model, can be found in the Final Investigation Report

(FIR) (Golder, 2006) and the Final Revised Corrective Measures Study (CMS) (Golder, 2010).


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Several IRMs have been put in place over the past 20-plus years to protect human health and the

environment while the site investigations and risk assessments were completed and while the corrective

measures are being designed and constructed. These IRMs include limiting access to and securing the

Site, construction of interim covers over impacted soils, consolidation and isolation of WWTR, removal

and off-site disposal of some impacted soil and sediment, management of storm water runoff, and

installation and continued operation of a state-of-the-art groundwater extraction and treatment system. A

more complete description of the IRMs completed at the Site can be found in the Statement of Basis

(USEPA, 2010a) and the Final Revised CMS. These IRMs will be maintained by Pharmacia & Upjohn

until the final corrective measures are installed, and in several portions of the Site will be incorporated into

the final remedy.

Current Site use includes operation and maintenance of the existing interim remedial systems, including a

groundwater extraction system (GWES) and a groundwater treatment facility (GWTF)2, along with CMI

design and construction activities. Woodard & Curran, on behalf of Pharmacia & Upjohn, manages and

maintains the Site and provides 24-hour per day presence, controls access to the Site through locked

chain-link fenced gates, maintains signage warning trespassers to keep out, and regularly inspects the

Site.

1.3.2 Site Geology and Hydrogeology Geologic units underlying the Site have been correlated with published geologic unit designations and

have then been assigned informal designations, from the youngest (Unit 1) to the oldest geologic unit

(Unit 4). Unit 1, Unit 2 and Unit 3 together comprise the unconsolidated geologic units that overlie

bedrock (Unit 4) and include:

Unit 1 – Undifferentiated, surficial man-made fill, Alluvial Sands, marine estuarine deposits and peat;

Unit 2 – Silty Clay, occasionally varved, assigned to the New Haven Clay or more informally the “Quinnipiac Silt-Clay”. This unit acts as an aquitard, which isolates groundwater in Unit 1 from Unit 3 and Unit 4;

Unit 3 – Deltaic Sand of Muddy River Delta Deposits (Unit 3b) or “lower sand” outwash- of the Quinnipiac River valley (Unit 3a); and,

Unit 4 – New Haven Arkose, bedrock assigned to the Newark Group of the Hartford Basin.

Unit 1 is generally separated hydraulically from Units 3 and 4 by the Unit 2 silty clay/clayey silt layer, with

the exception of a small area where Unit 2 is thinned or absent at the north side of the Site. The surficial

groundwater-bearing unit at the Site is developed within the materials of Unit 1. The groundwater flow in

Unit 1 generally trends eastward towards the Quinnipiac River. Portions of the Site Unit 1 aquifer have

2 The on-site GWTF is operated by Woodard & Curran in accordance with National Pollutant Discharge Elimination System (NPDES) Permit CT0001341, issued by CTDEEP on January 8, 2010.


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been impacted by compounds diffusing from the Dense Non-Aqueous Phase Liquid (DNAPL) present in

the Former Production Area on the western side of the site and, to a lesser extent, from the WWTR

present on the eastern side of the Site. Unit 1 groundwater is currently being contained by the

combination of the hydraulic barrier wall (HBW) and the GWES. The extracted groundwater is treated by

the GWTF prior to its discharge to adjacent surface waters.

Deeper groundwater circulation enters the Upland Terrace west of the Site (elevation about 20 ft. above

mean sea level (MSL)) and flows easterly through Unit 3 and Unit 4 that underlie the silty clay/clayey-silt

aquitard (Unit 2). Vertical hydraulic gradients are generally downward in the western portion of the Site

and upward in the eastern portion near the river. Chemical impacts to Units 3 and 4 groundwater are

significantly less than chemical impacts to Unit 1 groundwater. Units 3 and 4 groundwater do not flow

directly into surface water. Rather, a component of Unit 3 and Unit 4 groundwater in the eastern portion of

the Site slowly seeps upward through the Unit 2 silty clay/clayey silt into Unit 1 prior to discharge into the

Quinnipiac River and a component of groundwater from Unit 3 and Unit 4 flows southerly along the river.

A complete conceptual Site model, including detailed discussion of the Unit 3 and 4 groundwater to

surface water discharge pathway is discussed in more detail in the FIR and the CMS.

During 2014, Pharmacia & Upjohn updated the Site conceptual hydrogeologic and chemical transport

model for Unit 3 groundwater in the vicinity of Unit 3 monitoring well SEC-7D. The refinements to this

model in the northern portion of the Site were presented in the revised SEC-7D Pre-Design Investigation

Report and Preliminary Design Proposal (SEC-7D PDI/PDP), which was submitted to USEPA and

CTDEEP in February 2014 (Golder, 2014b). Additional monitoring performed during 2014 in the vicinity of

SEC-7D is discussed in Section 2.4.1

1.4 Description of Selected Corrective Measure (Remedy) The Corrective Measure selected by USEPA for the Site is presented in the USEPA Final Decision and

Response to Comments Document (USEPA, 2010b) and is described in the Order as follows:

Construction of a hydraulic control system for shallow groundwater (hydrogeologic Unit 1) consisting of a perimeter sub-grade low-permeability vertical barrier and a groundwater extraction system that will intercept contaminated groundwater, thus preventing impacts to the Quinnipiac River and to the adjacent North Creek and South Creek. Collected groundwater will be treated in the existing on-site Groundwater Treatment Facility prior to discharge in accordance with a CTDEEP National Pollutant Discharge Elimination System (NPDES) Permit;

Construction, regular sampling and evaluation of data from monitoring wells and piezometers both inside and outside the hydraulic barrier wall to verify long-term performance of the Unit 1 hydraulic control system;

Monitoring of deep groundwater (in hydrogeologic Units 3 and 4) to assess continued compliance with the groundwater Performance Standards. This component of the


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remedy includes further investigation of well SEC-7D and implementation of focused remedial measures, if determined necessary by USEPA;

Treatment of the most highly contaminated area on the Site, which contains Dense Non-Aqueous Phase Liquid (DNAPL), using in-situ thermal remediation (ISTR), including operation of appropriate air pollution controls, thereby eliminating this area as the most highly contaminated area of the Site;

On-site management of polychlorinated biphenyl (PCB)-impacted materials below protective barrier cover systems and low permeability cover systems under a Determination of Toxic Substances Control Act (TSCA) PCB Risk-Based Disposal Approval (40 C.F.R. § 761.61(c));

Stabilization and installation of low-permeability cover systems for both the North and South Piles on the east side of the Site to safely contain contaminated materials, prevent future contact with the materials, reduce infiltration into these areas, and reduce groundwater impacts from the Piles;

Construction of protective barrier and low-permeability cover systems over remaining portions of the east side of the Site to allow it to be safely used by maintenance workers and visitors;

Construction of protective barrier covers over the west side of the Site to allow safe commercial/light industrial redevelopment of this portion of the Site;

Focused remediation of Quinnipiac River sediment in two areas of the tidal mud flats (portions of Tidal Flat Nos. 1 and 2) and in a small stretch of South Creek, in a manner that will balance ecological benefits derived from the removal of the highest concentrations of key contaminants while minimizing the damage to ecological habitat that would result from sediment removal;

Enhancement of the east side ecological habitat, including creation of higher ecological value uplands and freshwater wetlands habitat. Construction of walking trails for interpretative environmental education and guided viewing of the enhanced habitats, which habitats will be maintained as an ecological preserve overlaying the constructed protective remedy;

Placement of institutional controls, including CTDEEP Environmental Land Use Restrictions, to prohibit residential3 development and other residential uses (e.g., schools, hospitals, day care centers), restrict groundwater use, and prevent disturbance to or demolition of engineered controls constructed on the Site; and

Long-term operation, monitoring, and maintenance (OM&M) of the Site to verify continued protection of human health and the environment and compliance with Performance Standards.

1.5 Performance Standards and Master Plan Schedule The Order includes “Performance Standards” which define the performance requirements for the

corrective measure. The Performance Standards are provided in Attachment 2 of the Order, and contain

both numerical criteria and narrative requirements, such as references to meeting the requirements of

specific Sections of the CTDEEP RSRs.

3 Section VII.B.5.b.i of the new RCRA 3008(h) Order excludes ‘controlled community access via guided interpretive trails on the east side’ from ‘outdoor recreational use,’ which is included in the definition of ‘residential use’ under the CT RSRs at Section 22a-133q-1.


January 2015 7 033-6231-002

The Order also includes the CMI “Master Plan Schedule,” (Order Attachment 6) which contains projected

completion dates (Major Milestones and Project Goals) for major work plans, design documents, field

work, construction work, and reports necessary to comply with the Order and implement the Corrective

Measures. A copy of the Master Plan Schedule is provided as Figure 3. Completion symbols and dates

have been added to this schedule indicating when the Major Milestones and Progress Goals have been

achieved to date. A table summarizing the status of the milestones is provided below. As discussed in

the Sections below, Pharmacia & Upjohn has accelerated the CMI schedule and has completed all of the

scheduled Major Milestones and Progress Goals ahead of the Master Plan Schedule. Pharmacia &

Upjohn will strive to continue this accelerated pace throughout the CMI.

Activity Milestone Type

Milestone Date

Date Achieved

Status as of December 31, 2014

2011 Submit Draft ISTR Pilot System

Design and Pilot-Study Work Plan

Major Milestone 6/16/2011 6/3/2011

Approved by USEPA and CTDEEP after

revisions. Submit NPDES Request for Determination Concerning

Wastewaters from ISTR Pilot System Operation

Progress Goal 8/26/2011 6/1/2011

Approved by CTDEEP. No USEPA approval

required.

Submit CMI Work Plan Major Milestone 11/18/2011 9/30/2011


revisions. Submit ESRC Component Implementation Work Plan

(including PDI Sampling and Analysis Plan)



revisions.

2012 Complete ISTR Pilot System

Construction Progress

Goal 1/22/2013 4/16/2012 Completed.

Submit Sediment PDI Report and Sediment Remediation PDP

Progress Goal 6/28/2013 8/28/2012 Approved by USEPA

and CTDEEP.

Submit SEC-7D PDI/PDP Progress Goal 3/21/2013 9/14/2012

Approved by USEPA after revisions;

CTDEEP deferred review to USEPA.

Complete ISTR Pilot Study Progress

Goal 3/18/2013 11/14/2012 Completed.

2013 Submit NPDES Request for Determination Concerning Wastewaters from ESRC

Construction Activities

Progress Goal 7/3/2014 2/19/2013

Approved by CTDEEP. No USEPA approval

required.

Submit Unit 1 Groundwater Hydraulic Controls Draft final

Design Package



revisions.

4 The Groundwater Extraction System (GWES) Hydrogeologic Design Draft Final Design (DFD), Appendix H of the ESRC CMDR, was submitted on May 6, 2013 (Golder, 2013c).


January 2015 8 033-6231-002

Activity Milestone Type

Milestone Date

Date Achieved

Status as of December 31, 2014

Submit Draft Final Design Package for Remaining ESRCs



revisions.

Submit ISTR Pilot Study Report and PDP

Major Milestone 11/13/2014 8/30/2013


revisions. 2014

Submit Full-Scale ISTR Draft Final Design

Progress Goal 9/25/2015 12/11/2014

USEPA and CTDEEP are currently reviewing

this submission.


January 2015 9 033-6231-002

2.0 PRINCIPAL ACTIVITIES CONDUCTED Given its scope and magnitude, Pharmacia & Upjohn has divided the corrective measure selected by

USEPA into separate components and has assembled the CMI Team to design and construct them. The

CMI Team is comprised of several entities with various roles and responsibilities as summarized below.

Pharmacia & Upjohn Company LLC (Site Owner and Operator) – Overall project direction and management provided by Pfizer on behalf of Pharmacia & Upjohn

Quantum Management Group, Inc. (QMG) - Assists Pfizer with project management

URS Corporation (URS)5 - Construction Manager and Health and Safety oversight

Woodard & Curran – Site management, operation and maintenance of the existing groundwater extraction system / groundwater treatment facility, and groundwater treatment facility upgrades

Golder Associates Inc. (Golder) – Environmental Consultant and Construction Quality Assurance

East Side Remedial Components (ESRC) Team [WRS6, Brown and Caldwell, and Amy S. Greene Environmental Consultants, Inc. (ASGECI)] – Design and construction of the East Side Remedial Components which is a major Corrective Measure component

TerraTherm, Inc. (TerraTherm) – Design and Operation of the full-scale In-Situ Thermal Remediation system to address DNAPL Subareas A and B, which is a major Corrective Measure component

Vita Nuova, LLC (Vita Nuova) - Ecological Enhancement, West Side redevelopment, and Community Relations consultant

This Section addresses the Annual Report requirements to provide a narrative summary of principal

activities completed in the reporting year. As such, this Section provides a summary of the principal CMI

activities performed by the CMI Team during 2014.

2.1 Communications with USEPA and CTDEEP The USEPA, CTDEEP and the CMI Team participated in progress update teleconferences on an

approximately monthly basis throughout 2014. Teleconferences were held on January 15, February 26,

March 19, April 10, May 28, June 18, July 23, August 20, September 17, October 15, November 19, and

December 17, 2014. A variety of topics were discussed during the progress teleconferences including:

USEPA and CTDEEP review of the Draft Final ESRC Corrective Measures Design Report (CMDR) (WRS and Brown and Caldwell, 2013), the ISTR Pilot Study Report and Preliminary Design Proposal (PDP) (TerraTherm and Golder Associates, 2013), the revised SEC-7D PDI/PDP (Golder, 2014b), the Full Scale In Situ Thermal Remediation

5 URS Corporation was acquired by AECOM on October 17, 2014, however the merger was not complete and corporate name did not change until January 5, 2015. Therefore they will be referred to as URS throughout this report. 6 In 2013 and in the beginning of 2014, the lead ESRC contractor operated as WRScompass. WRScompass changed names to WRS Infrastructure & Environment in March 2014. WRS Infrastructure & Environment was subsequently purchased by NorthStar Group Services, Inc (NorthStar) effective November 14, 2014. Since they operated under the name WRS for the majority of 2014, the lead ESRC contractor will be referred to as such for the remainder of this 2014 Annual Report.


January 2015 10 033-6231-002

Draft Final Design Report (Full-Scale ISTR DFD) (TerraTherm and Golder Associates, 2014), and other CMI Team submissions.

Proposed CMI Team responses to specific Agency comments concerning aspects of the ESRC CMDR, ISTR Pilot Study Report and PDP, and other submissions.

The progress of construction activities, and status of construction permits.

Design modifications and clarifications based on field conditions, and other technical items as they arose during the project (such as the location of new and replacement groundwater monitoring points).

Progress on other aspects of the project including ongoing investigations in the vicinity of Unit 3 well SEC-7D, upgrades to the Site infrastructure and GWTF, and public outreach activities.

The April 10, 2014 teleconference was hosted at the Site and representatives of CTDEEP toured the

ESRC construction after completion of the progress update agenda items.

The CMI Team also remained in regular communication with the USEPA and CTDEEP during 2014

through email correspondence and telephone conversations between Pfizer and various Agency staff.

Teleconferences to address specific technical matters were also conducted, and are detailed below as

part of the discussion of specific aspects of the CMI. Key correspondence between the Agencies and the

CMI Team is provided in Appendix A.

2.2 Groundwater Treatment Facility Permitting and Operation Throughout 2014, Woodard & Curran continued to operate the GWTF in accordance with NPDES Permit

CT0001341, issued by CTDEEP on January 8, 2010; the June 9, 2011 Regulations of Connecticut State

Agencies (RCSA) Section 22a-430-3(i) approval authorizing installation of two 115,000 gallon

equalization tanks; and, the March 19, 2013, RSCA Section 22a-430-3(i) approval to manage the ESRC

construction waters.

During 2014, the GWES was cooperatively managed by Woodard & Curran, for the portions of the

previous extraction system still being operated, and the ESRC Team, for newly installed extraction wells

and components. GWES construction progress is further discussed along with other aspects of ESRC

construction in Section 2.5. On December 22, 2014 the construction of the GWES and the associated

controls were sufficiently complete to transfer primary responsibility for operation of the GWES back to

Woodard & Curran. Golder monitored the hydrogeologic performance of the GWES throughout the year.

The operation, monitoring, and hydrogeologic performance of the GWES are discussed in Section 3.

NPDES permits issued by CTDEEP typically have an effective duration of 5 years, and accordingly the

Site’s NPDES permit was scheduled to expire on January 7, 2015. Woodard & Curran submitted a draft

of the NPDES permit renewal application to CTDEEP on May 15, 2014 for preliminary review in

accordance with the CTDEEP Pre-Application Assistance Program. CTDEEP provided comments on the

draft application on May 19, 2014, which were addressed prior to the formal submission of the NPDES


January 2015 11 033-6231-002

permit renewal application on July 3, 2014. CTDEEP has communicated to Pharmacia & Upjohn that the

review process for the revised permit will not be completed by January 7, 2015 and that, as provided by

the State of Connecticut regulations by the timely and administratively complete submittal to CTDEEP of

the permit renewal application, the GWTF should continue to operate in accordance with existing permit

CT0001341 until such time as the new permit is issued.

To provide information requested by CTDEEP to support the NPDES permit renewal application, dye

study mappings were completed during spring tides on Sunday, August 10th and Monday, August 11th

and during neap tides on Tuesday, August 19th and Wednesday, August 20th. The Effluent Mixing Zone

Dye Study Report, prepared by Hydrodata, Inc., under subcontract to Woodard & Curran, was submitted

to CTDEEP on November 6, 2014 (Hydrodata, 2014).

During 2014, Woodard & Curran evaluated potential options for managing the aqueous streams

anticipated from full-scale ISTR operations. Representatives of CTDEEP, Pfizer and the CMI Team met

at the Site on December 11, 2014 to discuss CTDEEP’s review of the NPDES permit renewal application,

the preliminary results of the dye study mapping conducted in August 2014, and regulatory options for

managing the water generated during full-scale ISTR operations. Subsequent to the meeting, Woodard &

Curran has begun to prepare a request for approval of modifications to the GWTF associated with

managing the aqueous streams from full-scale ISTR under RCSA 22a-430-3(i). It is anticipated that the

letter describing the proposed modifications to the GWTF will be submitted to CTDEEP during the first

quarter of 2015.

2.3 CMI Groundwater Monitoring During 2014, Golder continued implementing the CMI Groundwater Monitoring Plan, which is contained in

Appendix A of the CMI Work Plan (Golder, 2012b). The activities conducted in 2014, including

measurement of water levels and collection of groundwater samples, are in part a continuation of the

groundwater monitoring activities previously reported to USEPA and CTDEEP in the 2011, 2012 and

2013 Annual Reports (Golder, 2012a, 2013a and 2014a). The CMI Groundwater Monitoring Plan

anticipated that the Site conditions would change during the CMI period and included mechanisms to

adapt the monitoring to the changes in Site conditions. The CMI Groundwater Monitoring Plan

established a process of communicating the modifications the CMI monitoring program to USEPA and

CTDEEP via the Annual Reports. Accordingly, the groundwater monitoring implemented in 2014 was

described in Section 6.1 of the 2013 Annual Progress Report. USEPA reviewed Section 6.1 of the 2013

Annual Report and on July 8, 2014 confirmed that they had no comments on the proposed 2014

monitoring program.

A summary of principal groundwater monitoring activities performed during 2014 is provided below. The

data obtained from these activities are presented and evaluated in Section 3.0.


January 2015 12 033-6231-002

Golder collected synoptic water level measurements from selected Unit 1 and Unit 3

wells on March 25, 2014 and August 5, 2014. The second synoptic round was conducted in August, rather than the more typical September timeframe, to allow it to include the monitoring locations on the western side of the Site that would be subsequently abandoned as part of ISTR construction (see Section 3.1)

Golder continued monitoring the continuous water level measurement devices (dataloggers) installed as described in the GWES Draft Final Design (DFD) (Golder, 2013b), submitted to USEPA and CTDEEP on May 6, 2013. As described in Section 6.1 of the 2013 Annual Report, the dataloggers were deployed in several different configurations over the course of the 2014. These data were used in conjunction with manual water level measurements to evaluate hydraulic control during the ESRC construction activities (see Section 3.1).

Golder collected samples from select perimeter Unit 1 and Unit 3 monitoring wells between September 16 and 18, 2014 and on October 24, 2014 (see Section 3.2). Additional samples were collected from wells GW-U305 and GW-U402A on December 22, 2014; however, the data from these samples was not received in time to incorporate the results into this report.

2.4 Non-Routine Sampling and Monitoring Various non-routine well installation, sampling and water level monitoring activities were implemented in

2014 to collect information required for design and monitoring of the Corrective Measure. These data are

being provided to USEPA and CTDEEP in the Appendices to this Annual Report.

2.4.1 Unit 3 Well SEC-7D The SEC-7D PDI/PDP (Golder 2012c) was initially submitted to USEPA and CTDEEP for review on

September 14, 2012, which achieved the Order Progress Goal “Submit SEC-7D PDI Report and PDP”

(Progress Goal date: March 21, 2013) in advance of the Master Plan Schedule. In response to technical

review comments provided by USEPA on December 12, 2012 and discussions during various

teleconferences between the CMI Team and USEPA in 2013, in October 2013 the CMI team installed two

groundwater monitoring wells (GW-HBW16 and GW-HBW17) northwest of well SEC-7D in the area

outside the HBW where Unit 2 is thinned or absent. As communicated in the 2013 Annual Report,

elevated concentrations of 2-chloroaniline (up to 62,000 ug/L) were detected in well GW-HBW17, which is

the deeper of the new wells in the unconfined aquifer and screened in the lower portion of the

unconsolidated deposits immediately above bedrock. However samples from GW-HBW17 did not contain

all of the chemicals of interest at concentrations consistent with identifying the area around GW-HBW17

as the primary source of impacts to the Unit 3 groundwater near SEC-7D. The new data collected from

GW-HBW17, SEC-7D, and other wells in the vicinity during the fourth quarter of 2013 were initially

communicated to USEPA and CTDEEP in the 2013 Annual Report. The data collected in 2013 in the

vicinity of SEC-7D was used to provide responses to USEPA’s technical comments and were

incorporated into a revised SEC-7D PDI/PDP, which was submitted to USEPA and CTDEEP on February

28, 2014.


January 2015 13 033-6231-002

As proposed in the revised SEC-7D PDI/PDP, a new groundwater monitoring well, GW-U309, was

installed along the northern border of the Site near where the culvert conveying off-site storm water

discharges into North Creek on June 4, 2014. A copy of the well construction log is provided in Appendix

B-1. After installation and development of the new well, groundwater monitoring samples were collected

from SEC-7D, GW-U309, and a number of other wells in the area where Unit 2 is thinned/absent, during

the week of June 23, 2014. The data collected during this event are discussed in Section 3.3.

USEPA completed their review of the revised SEC-7D PDI/PDP and associated Response to Comments

in July 2014. On July 8, 2014 USEPA communicated via email that the revisions to the SEC-7D PDI/PDP

adequately addressed their concerns (See Appendix A). This approval of the revised SEC-7D PDI/PDP

completes the review and revision cycle for the documents associated with the Order Progress Goal

“Submit SEC-7D PDI Report and PDP”.

While the SEC-7D PDI/PDP Report has been approved, discussions between USEPA and the CMI Team

regarding several topics concerning groundwater in the northern portion of the site and in the vicinity of

SEC-7D continued throughout the remainder of 2014. On August 15, 2014 USEPA and CTDEEP were

provided a letter describing the proposed installation of one shallow monitoring well (GW-U103) within the

zone of thinned/absent Unit 2, collocated with recently installed deep monitoring well GW-U309, and two

groundwater wells screened within Unit 3 (GW-U310 and GW-U311) located upgradient of the zone of

thinned/absent Unit 2, along with a datalogger study to obtain additional information about vertical

gradients in the vicinity of SEC-7D. Representatives of USEPA, Pfizer and their respective consultants

held a teleconference on October 9, 2014 to discuss the proposed path forward and the USEPA

comments provided via email on July 8, 2014. During the October 9, 2014 teleconference, it was agreed

that the CMI Team would collect the additional data described in Section 6 of the revised SEC-7D

PDI/PDP, install the wells proposed in the August 15, 2014 letter, collect samples from the newly installed

wells, complete the datalogger study and then prepare a formal response to USEPA’s comments.

Accordingly, Cascade Drilling, with oversight from Golder, installed shallow well GW-U103, and Unit 3

wells GW-U310 and GW-U311 between September 29, 2014 and October 10, 2014 (See Appendix B-1

for the well completion report). Groundwater samples were collected from the newly installed wells along

with selected other Unit 1, Unit 3 and Unit 4 wells in the northern portion of the Site between October 22,

2014 and October 24, 2014. The data collected during this event are discussed in Section 3.3.

Dataloggers were installed in 18 wells in the vicinity of SEC-7D on December 18 and 19, 2014. Following

the completion of the datalogger study in January 2015, the CMI Team is planning to present the

continuous water level monitoring data to USEPA and CTDEEP along with responses to USEPA’s July 8,

2014 comments. The response to comments is anticipated to be submitted to USEPA and CTDEEP

during the first quarter of 2015.


January 2015 14 033-6231-002

2.4.2 Full-Scale ISTR PDI During the week of June 23, 2014, Golder collected samples of DNAPL and groundwater from within the

footprint of the full-scale ISTR target treatment zone (TTZ) to provide updated and additional data for the

design of the full-scale ISTR system and for the evaluation of pre-treatment processes to manage the

aqueous streams generated by full-scale ISTR in the on-site GWTF pre-treatment process. The results of

this investigation are further discussed in Section 3.3. Following the sampling and in preparation for the

construction of the full-scale ISTR system, Golder abandoned the existing wells within the full-scale ISTR

TTZ footprint. A well abandonment report is provided in Appendix B-2.

2.5 East Side Remedial Components

2.5.1 Agency Review of the ESRC CMDR and GWES DFD The Final Draft Corrective Measures Design Report (CMDR) for the ESRC was submitted to USEPA and

CTDEEP on March 22, 2013 and the Groundwater Extraction System Draft Final Design (GWES DFD)

(Golder, 2013b), which was an Appendix to the ESRC CMDR (specifically Appendix H), was submitted to

USEPA and CTDEEP on May 6, 2013. The submission of the Draft Final ESRC CMDR along with the

GWES DFD achieved two Major Milestones of the Master Plan Schedule (Attachment 6 of the Order):

Submit Unit 1 Hydraulic Controls Draft Final Design Package (milestone date June 4, 2014) and Submit

Draft Final Design Package for the Remaining ESRC (milestone date June 5, 2015). The ESRC CMDR

also included a Part 2 Engineered Control (EC) Variance request for CTDEEP review and approval

(ESRC CMDR Appendix C). As described in the 2013 Annual Report, at the request of Pharmacia &

Upjohn USEPA performed a phased review of the ESRC CMDR. During the course of 2013, USEPA and

CTDEEP provided several sets of technical review comments, which were addressed by interim

submittals by the CMI Team, and provided multiple targeted approvals to facilitate construction of certain

aspects of the ESRC concurrent with the Agency review period. On January 24, 2014, USEPA notified

the CMI Team that they had completed their review of the Final Draft ESRC CMDR and would not be

providing additional technical review comments.

A formal Response to Comments (RTC) letter was submitted on October 23, 2013 to address the

technical review comments related to the GWES DFD and the Post-CMI GWES Groundwater Monitoring

Plan provided by USEPA on July 12, 2013. USEPA provided a letter on December 20, 2013 that

generally accepted the RTC, and provided several minor comments that were addressed in the drafts of

the revised GWES Final Design (FD) (Golder, 2014c) and the revised Post-CMI Groundwater Monitoring

Plan (Golder, 2014d) submitted to USEPA and CTDEEP on June 11, 2014. USEPA provided verbal

concurrence to the revisions to the GWES FD and Post-CMI Groundwater Monitoring Plan on July 23,

2014 and via email on July 29, 2014 (see Appendix A). USEPA written approval of the ESRC Corrective

Measures Design Report (CMDR) was issued on August 5, 2014 (See Appendix A). Clean record copies

of the final ESRC CMDR were distributed to USEPA and other project stakeholders on August 29, 2014,


January 2015 15 033-6231-002

which completes the review and revision cycle for the documents associated with Order Major Milestones:

“Submit Unit 1 Hydraulic Controls Draft Final Design” and “Submit Draft Final Design Package for the

Remaining ESRC”.

CTDEEP also performed a phased review of the EC Variance request, to allow certain ECs, particularly

the low permeability cover for the North Pile to be constructed in 2013. Pharmacia & Upjohn received

written conditional approval of the EC Variance Request for the North Pile from CTDEEP dated July 12,

2013. USEPA provided email confirmation that they delegated the technical review of the EC Variance

Request for the North Pile cover system to CTDEEP on July 17, 2013, which authorized the CMI Team to

proceed with construction of the planned low permeability cover for the North Pile during 2013.

Draft Fact Sheets for the remaining ESRC ECs, with the exception of the North Pile, were provided to the

CTDEEP for comment on October 1, 2013. CTDEEP provided comments on the draft Fact Sheets on

December 26, 2013. Representatives of CTDEEP, Pfizer, Brown and Caldwell, and Golder participated

in a teleconference on January 23, 2014 to clarify CTDEEP’s December 26, 2013 technical review

comments. Revised EC Fact Sheets were submitted to CTDEEP for review on March 12, 2014. On April

11, 2014, the CMI team received conditional approval from the CTDEEP of the EC Variance requests for

the remainder of the ESRC (see Appendix A). The CMI Team communicated concerns with the phrasing

of the conditional approval letter to CTDEEP in May 2014 and communicated with CTDEEP concerning

the clarification of which CMS Areas would receive protective barrier cover systems and which would

receive low permeability cover systems. On June 10, 2014 CTDEEP provided two emails concurring with

the clarifications of the areas to receive low permeability cover systems (see Appendix A).

2.5.2 ESRC Design and Permit Modifications Throughout 2014, the ESRC Team continued frequent communication with USEPA and CTDEEP

representatives about modifications to the design presented in the ESRC CMDR due to refined

understanding of the field conditions. The primary venue for discussion of these changes was the

monthly progress teleconferences, however in certain situations, additional information was provided to

USEPA and/or CTDEEP via email. When the design change was to be implemented in the tidal wetlands

areas, the ESRC Team consulted with representatives of CTDEEP OLISP concerning whether the

proposed changes required modifications to the Tidal Wetlands, Structures, Dredging and Fill Permit

(application number 201300533) and USACE regarding changes to the Section 404 Permit (File Number

NAE-2012-1039) or other permits.

Specific design and permit modifications related to the extraction wells to be used as part of the GWES in

the vicinity of the South Pile, the protective barrier covers for several small areas around the GWTF and

the main electrical switchgear for the Site, and the design for the wetland mitigation area adjacent to

South Creek are discussed in the sections below that discuss the ESRC construction progress during


January 2015 16 033-6231-002

2014. As described below, CTDEEP OLISP approved a Certificate of Permission (COP) related to the

additional stream bank protection measures to be installed in South Creek.

In June and September 2014, the CMI Team requested approval from USEPA and CTDEEP for the use

of soils from two alternate off-site sources as clean fill for the construction of the cover system and in

wetlands areas. After review of the sample data, and comparison of the results both to the comparative

criteria and typical anthropogenic background concentrations, both USEPA and CTDEEP provided their

concurrence with the use of the clean soil from the proposed off-site sources (see Appendix A). Since

there was sufficient material available from the previously approved clean soil sources these two

additional sources were not used on the project in 2014.

2.5.3 ESRC Remedial Construction The following Sections discuss progress towards constructing the major elements of the ESRC during

2014. The discussion is arranged thematically rather than chronologically, as the ESRC Team

successfully progressed many concurrent construction activities throughout the year. The locations of the

major components of the ESRC, and the locations of specific groundwater monitoring wells and Site

features are shown on Figure 2.

Erosion and Sedimentation Controls, Stormwater Management, and General Site Maintenance

WRS conducted activities to maintain the erosion and sedimentation (E&S) controls surrounding the

ESRC throughout 2014, expanding and improving them as conditions warranted. The ESRC Team

monitored the weather and proactively improved the E&S controls several times during the year in

advance of anticipated storms, particularly the E&S controls in the areas surrounding the North and South

Pile.

As part of the implementation of the ESRC, stormwater that may have contacted exposed chemically-

impacted soil, was collected rather than being allowed to directly run-off to surrounding surface water.

During 2013 and most of 2014, the areas that would become the stormwater BMPs and constructed

wetlands were used as interim stormwater collection basins. To maximize the containment capacity of

these basins, the collected water was pumped through a pre-treatment system, then conveyed to the

GWTF for further treatment prior to discharge to the Quinnipiac under the Site NPDES permit.

Approximately 13,400,000 gallons of stormwater were pre-treated and conveyed to the GWTF during the

first, second and third quarters of 2014.

As described in the sections below, by early in the fourth quarter of 2014, impacted soils were no longer

exposed (i.e. clean cover systems had been placed) eliminating the generation of potentially impacted


January 2015 17 033-6231-002

stormwater. At that point, stormwater collection and pre-treatment was discontinued and the

pre-treatment system was disassembled, decontaminated, and removed from the Site.

WRS also conducted a variety of site maintenance activities including: use of water trucks for dust control,

utility clearance in new areas to be disturbed, clearing and grubbing areas targeted for future construction

activities, and maintenance of decontamination pads. By mid-October 2014 essentially all of the ESRC

area was covered with clean material. At that point, the dedicated decontamination pads near the

entrances to the ESRC areas were removed to permit completion of the access roadways in the areas

where they had been located. Late in the fourth quarter of 2014, WRS also prepared the site for winter

conditions, including frost-protection for the GWES components (e.g., heat tracing exposed elements of

the GWES), and making provisions for snow removal, as necessary.

ESRC Perimeter Air Monitoring

Perimeter air monitoring associated with ESRC construction was conducted by URS in accordance with

the USEPA and CTDEEP approved Perimeter Air Monitoring Program (PAMP) included as Appendix M of

the ESRC CMDR. The PAMP addresses community health and safety and identified actions and/or

measures to ensure that the public living and working near the site as well as employees or visitors to any

facility located on the Site are protected from exposure to site contaminants. As described in the PAMP,

the chemicals of concern for air monitoring during ESRC construction were PCBs and lead and these

chemicals are anticipated to be associated with dust from the disturbance of impacted shallow soils.

In accordance with the PAMP, two continuous air monitoring stations that measure meteorological

conditions and particulates (PM10) were operated while impacted soils on the eastern side of the Site

were exposed. Monthly particulate samples were submitted for PCB and lead analysis by an off-site

laboratory. The results from these samples collected between January and October 2014 confirmed that

the dust control measures implemented by the ESRC Team were effective as concentrations of PCBs,

lead, and particulates remained well below project action levels throughout the year. With the completion

of the placement of clean cover materials over the ESRC work area in October 2014, a request was

submitted via email to the USEPA and CTDEEP on November 18, 2014 to terminate the ESRC perimeter

air monitoring program. USEPA and CTDEEP approved the termination of the ESRC perimeter air

monitoring program on November 21, 2014 and November 24, 2014, respectively. Copies of these

approvals are provided in Appendix A. Community air monitoring associated with the ISTR construction

began in August 2014 and remains in operation.

Hydraulic Control System Construction

WRS completed construction of the HBW utilizing the mix design of 15% recycled ground granulated

blast furnace slag (GGBFS) and 5% Portland cement in late November 2013, which resulted in the


January 2015 18 033-6231-002

hydraulic isolation of the Site Unit 1 groundwater from the surface water of the Quinnipiac River and its

tributaries. As described in the 2013 Annual Report, by the end of 2013, the majority of the extraction

and monitoring wells described in the ESRC CMDR along with the south groundwater collection trench

had been installed and were being operated, though the location of several elements of the GWES were

modified based on field conditions. The installation of the remaining elements of the GWES was

completed in 2014, including, but not limited to the following major components:

Well PW-2RA was installed on January 10, 2014 at the location shown on Figure 2, and has been incorporated into the GWES.

Construction of the North Groundwater Collection Trench was completed between January 7, 2014 and March 3, 2014. The design of the trench was slightly modified in the field due to the presence of a buried concrete slab. The modification was presented to USEPA and CTDEEP during the February 26, 2014 progress teleconference and additional information was provided via email on March 19, 2014.

A request to use extraction wells PW-10 and PW-16A in place of PW-11 and PW-14B as part of the GWES at the South Pile was submitted by Golder on April 4, 2014. USEPA approved the change via email on April 22, 2014, a copy of which is included in Appendix A. The GWES was constructed such that wells PW-10 and PW-16A are being used as part of the hydraulic control system and wells PW-11 and PW-14B are being used as monitoring wells to assess the performance of the hydraulic control system.

Other wells associated with monitoring the GWES were installed under direction from WRS throughout the year including: GW-HBW1 on January 16, 2014; GW-HBW18 on September 4, 2014; and GW-HBW20 on December 2, 2014. Well construction logs will be provided by the ESRC Team as part of the ESRC Construction Completion Report.

Golder coordinated the installation of monitoring GW-HBW19 in the northeastern portion of the Site (replacing abandoned well GD-2S), Unit 1 well GW-U102, and Unit 4 well GW U405 in the southern area of the Site near the headwaters of South Creek (replacing wells removed by the construction of the South inland wetlands). The wells were installed between September 29, 2014 and October 10, 2014. Copies of the well construction logs are provided in Appendix B-1.

During the third quarter of 2014, WRS restored the disturbed area in the western portion of the Site associated with the HBW and the north and south groundwater collection trenches. The interim cover over the west side of the site was repaired by placing a combination of new asphalt paving, pavement millings, and topsoil over the disturbed areas to minimize the potential for direct contact with the underlying impacted soils.

Installation of permanent conveyance piping, electrical power, enclosures to house the wellhead equipment and controls along with the associated concrete pads, continued throughout the year and was completed during the fourth quarter of 2014.

Installation of the communication and control system that allows operation of the GWES from the GWTF building control room was completed in late December 2014, which allowed primary responsibility for operation of the GWES to be transferred from the ESRC Team to Woodard & Curran during the week of December 22, 2014.

Sediment Removal

The remediation of sediment in Tidal Flat 1 and a portion of South Creek was completed in 2013. Due to

the difficulty with achieving sufficient isolation of the work area from the river using an Aqua-Barrier®


January 2015 19 033-6231-002

cofferdam system alone, following the design presented in the ESRC CMDR, Brown and Caldwell

provided construction alternatives for isolating Tidal Flat 2 from the Quinnipiac River to the CTDEEP

OLISP. OLISP provided a de minimis change authorization dated November 8, 2013 to allow the

installation of a Port-a-Dam cover over the inflatable bladders in the Aqua-Barrier® cofferdam and clean-

soil berms on the interior of the Aqua-Barrier®. Due to schedule delays caused primarily by weather

conditions, WRS was not able to complete the Tidal Flat 2 remediation during 2013. During January and

early February 2014, the CMI Team communicated with CTDEEP OLISP and USACE concerning

potential timing restrictions to protect diadromous fish due to the changes in the schedule for the Tidal

Flat 2 sediment removal activities. CTDEEP OLISP confirmed that the OLISP permit did not include

seasonal restrictions due to the planned use of the cofferdams. USACE coordinated with NOAA, who

concurred with the request to perform the sediment removal activities in April 2014, as long as all in-water

activities were complete by April 25, 2014.

Tidal Flat 2 Sediment Remediation


January 2015 20 033-6231-002

Preparation for the sediment removal within Tidal Flat 2 began at the end of March 2014 with the

deployment of the Aqua-Barrier® cofferdam system augmented with a Port-a-Dam cover. A delegation of

CTDEEP staff members visited the Site on April 10, 2014 to observe the Tidal Flat 2 sediment removal

activities. In total, approximately 1,800 cubic yards of sediments were removed from Tidal Flat 2. The

sediment was amended with Portland cement as a drying agent prior to being placed on the South Pile.

Two feet of clean sand backfill was placed in the excavations, consistent with the CTDEEP and USACE

permits. On April 24, 2014, CTDEEP OLISP and USACE were notified via email that the sediment

removal work at Tidal Flat 2 was completed and the cofferdams had been removed, satisfying the

requirements to have the work finished by April 25, 2014.

CMS Area E-4 (North Pile) Cover System

The geosynthetic components (i.e., the gas venting layer, geomembrane, and drainage layer) and cover

soil had been placed over the top, southern and western sides of the North Pile by the end of the fourth

quarter 2013. A small area on the eastern edge of the North Pile was left with a temporary cover to

permit access through this area to transport the stabilized sediments from Tidal Flat 2 to the South Pile.

The remaining portions of the North Pile were covered by the cover system in May 2014 after completion

of the sediment removal activities. WRS constructed the final drainage features (mid-slope swales,

berms, etc), placed the final 6-inch topsoil layer, and seeded the North Pile during the third quarter of

2014. WRS completed planting the shrubs and other ecological enhancements, and constructing the final

access roads on and around the North Pile in the fourth quarter of 2014.

CMS Area E-3 Former Aeration Lagoon (FAL) Consolidation and Cover System

During the first quarter of 2014 the FAL was temporarily stabilized using a stabilization product consisting

of a mixture of annual rye, winter rye, wood fiber mulch and fertilizer. The ESRC team continued

monitoring the progress of consolidation during the first quarter of 2014 and in April 2014 determined that

the consolidation of the WWTR was sufficiently complete to allow construction of the low permeability

cover system. The gas vents were installed and the geosynthetic components of the cover system were

placed in May 2014, followed by placement of 18 inches of cover soil and the final 6-inch topsoil layer in

June and July 2014. Once all of the soil was placed, the FAL was seeded and planted with shrub islands,

native vegetation and other ecological enhancements as specified in the ESRC CMDR. Similar plugs and

shrubs were also planted on the adjacent Former Enclosed Aeration Lagoon (FEAL) during the third

quarter of 2014.

CMS Area E-5 (South Pile) Consolidation and Cover System

At the end of 2013, approximately 46,000 cubic yards of soil had been placed on the South Pile, which

correlates to approximately 75% of the consolidation fill specified in the ESRC CMDR, and the WWTR


January 2015 21 033-6231-002

consolidation had been estimated to be approximately 40% complete. Approximately 6,000 cubic yards

of soil and debris were placed on the top of the South Pile during the first quarter of 2014. During the

second quarter of 2014, 18,000 cubic yards of soil were placed on the top of the South Pile. An additional

4,400 cubic yards of soil and debris from various finish-grading activities were placed on the South Pile

during the third and fourth quarters. In total, approximately 74,400 cubic yards of soil and debris were

placed in the South Pile.

Following placement of the soil, WRS monitored the progress of consolidation of the South Pile WWTR

through the surveying of settlement plates. By August 2014, WWTR consolidation and grading of the

South Pile slopes were sufficiently advanced to permit installation of the low permeability cover system.

The geosynthetic components of the cover system were installed between August 25, 2014 and October

24, 2014. The cover system construction progressed in sections, first installing the geosynthetics then

placing 18 inches of cover soil and 6 inches of topsoil. By the end fourth quarter, the stormwater

drainage features and roads on the South Pile had been installed, and erosion control matting and

seeding to provide erosion control had been completed. The ecological enhancements on the South Pile,

including the planting of shrubs and other species, will be completed in the spring of 2015.

Constructed Inland Wetlands and Stormwater BMP in CMS Areas E-1, E-2 and E-3

During the first half of 2014, ESRC construction focused on completing the covers in the northern portions

of the Site. The northern wetland excavations were completed in June 2014. The geocomposite clay liner

(GCL) to retain and isolate the clean stormwater from the underlying impacted groundwater was placed in

July 2014, followed immediately by the placement of 24-inches of wetland soil. During the third quarter,

the GCL and cover soils were also placed in the North BMP. By the end of the year, all the northern

wetland areas had been seeded and planted with shrubs and plugs.

Placement of GCL in the South Inland Wetlands. The geosynthetic components of the South Pile Low Permeability Cover System are also visible.


January 2015 22 033-6231-002

The majority of the excavation to shape the subgrade of the southern inland wetlands (CMS Area E-2)

was completed during the second quarter and third quarters of 2014. Placement of the GCL and wetland

soil in the southern inland wetland, was started late in the third quarter and completed in the fourth

quarter of 2014.

The GCL and sufficient cover soil has been placed in the South BMP during 2014 such that impacted

soils are no longer exposed. The final grading of the cover soil, seeding and planting of the South BMP is

planned for the spring of 2015.

CMS Areas E-1, E-2 and E-3 Cover System

The majority of the cover system in CMS Areas E-1, E-2 and E-3 is formed by the constructed wetlands,

stormwater BMPs and the cover systems for the FAL and the FEAL. As specified by the ESRC CMDR,

protective barrier cover systems were installed between these major features to prevent future contact

with underlying impacted soils. In order for the final grades to integrate with the existing infrastructure

and to promote final stormwater drainage, small amounts of soil were excavated from CMS Areas E-1,

E-2, and E-3 and placed in the South Pile during the second and third quarters of 2014. The areas were

graded, then WRS placed an orange demarcation layer, 18 inches of protective cover soil, and 6 inches

of topsoil as described in the CTDEEP-approved EC Fact Sheet. Seeding of the protective barrier cover

system in most areas was completed October 2014, with the remainder (primarily in the southern portion

of the Site) to be completed in 2015. WRS also installed the base of the new gravel access roads and

pathways (mainly on the northern areas of the ESRC) with the remainder to be finished in 2015.

The protective barrier cover system was modified in several small areas, particularly areas around the

GWTF and the main electrical switchgear, to avoid disruption of the active utilities. These areas were

finished with a black plastic demarcation layer covered by gravel, which removed the need to excavate

below the existing grade prior to placement of the protective materials. These changes to the ECs were

approved by CTDEEP in June 2014 and August 2014 and will be documented in the construction

completion report. These areas are too small to be effectively shown on Figure 2.

After submission of the ESRC CMDR, it was decided to use a small additional area to the north of the

GWTF and east of the Former Polishing Lagoon as part of the support zone for full-scale ISTR

operations. Therefore, installation of a protective barrier cover in this area was deferred to the west side

corrective measures construction, which will be implemented after completion of ISTR. The change to the

EC was approved by CTDEEP, with concurrence from USEPA. The approximate ESRC cover system

boundaries shown on Figure 2 reflect the change.


January 2015 23 033-6231-002

Tidal Wetlands Mitigation

During the third quarter of 2014, WRS completed the final grading to create the micro-topography in Tidal

Wetlands Enhancement Areas A and B per the USACE and CTDEEP OLISP permit tidal wetland

mitigation plan. Representatives of the USACE conducted a site visit and compliance inspection on

Wednesday, July 30, 2014 related to the work being performed under the USACE Section 404

Connecticut General Permit and approved Tidal Wetlands Mitigation Plan. On August 28, 2014, Pfizer

sent an email with photographs of the improved E&S controls around the North and South Piles that were

highlighted by USACE as needing repair during their site visit on July 30, 2014.

Excavation of the southern tidal wetland, which is located outside the HBW adjacent to South Creek and

referred to as Enhancement/Creation Area C to in the USACE and CTDEEP OLISP permits, was

advanced in parallel with the excavation of the southern inland wetlands. Excavation of the southern tidal

wetland was also mostly complete during the third quarter of 2014, with some limited excavation along

the northern edge completed during the fourth quarter. Placement of wetland cover soil in the southern

tidal wetlands was completed in December 2014.

A portion of the eastern stream bank of South Creek was damaged during significant summer rainstorms.

In response, the ESRC Team revised the design for the wetland mitigation area adjacent to South Creek

and communicated the proposed modifications to representatives of CTDEEP OLISP on September 29,

2014. On October 7, 2014, representatives of CTDEEP OLISP and the CMI Team met on-site to review

the conditions of the damaged portion of South Creek and the proposed modifications and stream bank

protection measures. Subsequent to the meeting, on October 28, 2014, the ESRC Team submitted a

Certificate of Permission (COP) application package for the proposed South Creek bank restoration and

protection measures to CTDEEP OLISP and USACE. Additional information and revised drawings related

to the COP application package were provided between November 4, 2014 and November 6, 2014 in

response to requests from CTDEEP OLISP. CTDEEP OLISP approved the COP on November 14, 2014

(See Appendix A). Copies of the approved COP were provided to USACE on November 17, 2014. On

November 25, 2014 the CMI Team received the USACE approval of the de minimis modification to the

existing permit (permit number NAE-2012-1039) to incorporate the additional South Creek bank

restoration and protection activities into the permitted work within wetlands under USACE jurisdiction via

email. A copy of the USACE approval is provided in Appendix A.

The work to restore and protect the eastern bank of South Creek began in December 2014, and will be

completed, as winter weather permits, by the second quarter of 2015. Maintenance and monitoring of all

of the tidal wetland mitigation areas is anticipated in 2015 as the new plantings become established.


January 2015 24 033-6231-002

2.6 In-Situ Thermal Remediation

2.6.1 In-Situ Thermal Remediation Pilot Study Final drafts of the ISTR Pilot Study Report and the Full-Scale ISTR Preliminary Design Proposal (ISTR

Pilot Study Report and Full-Scale PDP) were submitted to USEPA and CTDEEP on August 30, 2013.

Fundamental design components for full-scale ISTR treatment of Subareas A and B are summarized in

the full-scale ISTR PDP, including metrics such as the proposed target treatment temperature and

duration, system specifications, treatment system monitoring requirements, and shut-down criteria.

Representatives of USEPA, CTDEEP, Pfizer and their respective consultants participated in a

teleconference on December 10, 2013 to discuss USEPA’s preliminary review, following which USEPA

issued technical review comments concerning the ISTR Pilot Study Report and Full-Scale PDP on

January 13, 2014. Based on the discussions during the December 10, 2013 teleconference and verbal

concurrence with the proposed treatment temperature for the full-scale ISTR system during the January

15, 2014 progress teleconference, TerraTherm began preliminary activities toward designing a Full-Scale

ISTR system to treat DNAPL Subareas A and B at a subsurface temperature of 100 oC in parallel with the

activities to address USEPA’s comments on the ISTR Pilot Study Report and Full-Scale PDP.

TerraTherm and Golder prepared a Response to Comments and revised portions of the ISTR Pilot Study

Report and Full-Scale PDP which were submitted to USEPA and CTDEEP on March 28, 2014.

On August 21, 2014, USEPA completed their review and issued an approval for the Revised ISTR Pilot

Study Report and Full Scale PDP. USEPA, CTDEEP, Pfizer and their respective consultants participated

in a teleconference on August 28, 2014 to discuss the outstanding comments concerning the design of

the full-scale ISTR system. The responses to USEPA’s comments were incorporated into the Full Scale

In Situ Thermal Remediation Draft Final Design Report (ISTR DFD), which was submitted to USEPA and

CTDEEP, as described in Section 2.6.2 below. Hard copies and/or CD-ROM containing the Revised

ISTR Pilot Study Report and Full Scale PDP were provided to USEPA and CTDEEP on November 21,

2014, which completes the review and revision cycle for the documents associated with the Order Major

Milestone “Submit Pilot-Study Report and Preliminary Design Proposal for Full-Scale ISTR System”.

2.6.2 In-Situ Thermal Remediation Draft Final Design One of USEPA’s comments on the ISTR Pilot Study Report and Full-Scale PDP addressed the proposed

schedule for implementation of full-scale ISTR. In response to USEPA’s concerns that it was not feasible

to effectively construct the full-scale ISTR system during the winter months, the CMI Team sought ways

to accelerate the design and construction schedule. In addition to progressing the design of the full-scale

ISTR concurrently with addressing USEPA’s comments on the ISTR Pilot Study Report and Full-Scale

PDP, the ISTR DFD was submitted to USEPA and CTDEEP in several stages to facilitate completion of

the below-ground components of the full-scale ISTR system prior to the start of inclement weather.


January 2015 25 033-6231-002

The ISTR Community Air Monitoring Plan (CAMP) and Health and Safety Plan (HASP) were submitted to

USEPA and CTDEEP for review on July 25, 2014. On August 21, 2014 USEPA provided notice that they

would not provide comment on the HASP but provided comments on the CAMP on August 27, 2014.

Responses to the comments on the CAMP were provided via email on August 29, 2014. USEPA

provided verbal approval for TerraTherm to begin intrusive activities while the responses to the comments

concerning the CAMP were being reviewed. On September 17, 2014, Pfizer received an email

communication from USEPA stating that the CAMP response to comments was adequate and requesting

that the responses be incorporated into the CAMP and resubmitted to USEPA. The revised CAMP,

which incorporated responses to USEPA’s August 27, 2014 comments, was provided via email on

October 14, 2014 and approved on October 21, 2014. Copies of these email messages are included in

Appendix A.

The majority of the ISTR DFD, including the basis of design (main text), engineering drawings (Appendix

A) and air regulatory compliance demonstration (Appendix B), was submitted to USEPA and CTDEEP on

October 31, 2014. The remaining portions of the ISTR DFD, namely the Sampling and Analysis Plan

(Appendix D), the Quality Assurance Project Plan (Appendix F), and the ISTR Unit 3 Groundwater

Monitoring Plan (Appendix G), were submitted to USEPA and CTDEEP on December 11, 2014. The

submission of the final appendices to the ISTR DFD on December 11, 2014 achieved the Order Progress

Goal “Submit Full-Scale ISTR Draft Final Design” in advance of the Master Plan Schedule (Progress Goal

date: September 25, 2015). Hard copies and/or CD-ROM containing the complete ISTR DFD, including

the previously approved HASP (Appendix C) and CAMP (Appendix E), were provided to USEPA,

CTDEEP and the other recipients on December 23, 2014. As discussed in Section 2.6.4 below,

construction of the full-scale ISTR system in DNAPL Subareas A and B is progressing in parallel with the

Agency review of the full-scale ISTR DFD based on USEPA’s previous concurrence with the fundamental

design concepts for full-scale ISTR treatment of Subareas A and B presented in the ISTR Pilot Study

Report and Full-Scale PDP.

2.6.3 Town of North Haven Approvals for Full-Scale ISTR On behalf of Pharmacia & Upjohn, the CMI Team submitted applications for Site Plan Approval to the

Town of North Haven Inland Wetlands Commission (IWC) and Planning and Zoning Commission (P&ZC)

along with material for Coastal Area Management review on May 22, 2014. A presentation was made to

the IWC on June 25, 2014, following which the members of the IWC provided a positive referral to the

P&ZC. Site plan approval was received from the P&ZC during their July 7, 2014 meeting after a brief

presentation about the ISTR project. On July 21, 2014 and July 30, 2014, the Town of North of North

Haven sent letters documenting the approval of permit application #P14-15 for full-scale ISTR system

construction contingent on receiving revised drawings that incorporate the items requested in the

approval letter. Copies of these letters are provided in Appendix A. Revised drawings were provided to


January 2015 26 033-6231-002

the Town of North Haven Engineer and Town of North Haven Land Use Administrator for review on

August 27, 2014. The counter-signed drawings were received from the Town of North Haven on

November 18, 2014, which completes the Town of North Haven site plan approval process.

Other local permits (building, electrical etc.) were and are being obtained as necessary. As required by

the conditions of the Town approvals, the Erosion and Sedimentation controls were inspected by Town

personnel prior to the initiation of soil disturbing construction activities.

2.6.4 Utility Upgrades Woodard & Curran and URS coordinated with local utility providers to implement upgrades to the Site

utilities in preparation for full-Scale ISTR. These activities included:

During the third quarter of 2014, a portion of the existing primary natural gas feed to the GWTF was relocated to outside the DNAPL Subarea A footprint. A conduit sleeve was also installed to allow for installation of the secondary gas feed to the ISTR equipment pad. The secondary gas feed, which will provide natural gas to the ISTR air emissions control equipment, was completed in the fourth quarter of 2014.

During the third quarter of 2014, a portion of the main electrical supply to the GWTF was relocated so that it was far enough from DNAPL Subarea A to reduce the risk of thermal damage to it during ISTR operations.

The existing emergency generator for the GWTF, which was located within the footprint of DNAPL Subarea B, was removed in November 2014 and replaced with a newer unit located in an area that would not interfere with the operation of full-scale ISTR.

New electrical transformers and switchgear were installed at the Site during the fourth quarter of 2014 to upgrade the site electrical system to support ISTR. The site electrical upgrade will be complete the first quarter of 2015.

2.6.5 Full-Scale In-Situ Thermal Remediation System Construction TerraTherm mobilized to the site on August 18, 2014, installed the perimeter photoionization detector

(PID) stations associated with the ISTR CAMP and began setting up their support staging areas, support

zone, exclusion zone demarcation, trailers, and equipment storage. TerraTherm collected background

data prior to beginning subsurface disturbance activities and then began collection of continuous

monitoring data as the wellfield construction activities commenced. On September 16, 2014, TerraTherm

personnel collected the first monthly CAMP compliance TO-15 air samples for VOCs. The initial data

indicates the presence of various VOCs at concentrations consistent with background conditions.

Subsequent samples collected in 2014 also contained various VOCs at concentrations consistent with

background conditions.

During late-August and September 2014, a trench was excavated around Subarea A to identify any

utilities installed into Subarea A. A number of inactive utilities were identified at the wellfield perimeter

during the trenching activities and these utilities were sealed with grout. Various old building foundations


January 2015 27 033-6231-002

were also identified. TerraTherm also re-routed an active storm drainage pipe on the eastern edge of the

wellfield and installed protection on a storm water basin directly adjacent to Subarea A.

In September 2014, TerraTherm completed the grinding of the existing asphalt surface, followed by the

placement of a minimum of 18 inches of clean gravel and additional dense graded aggregate fill to

construct a vadose zone above the Subarea A TTZ which was completed in early October 2014. After

the GWTF emergency generator relocation was completed, the Subarea B TTZ was cleared of active

utilities, the existing asphalt surface was ground and the imported fill layer was constructed in November

2014. TerraTherm and its subcontractors completed the installation of the ISTD heater wells, multi-phase

extraction wells, groundwater control wells, temperature monitoring points, pressure monitoring points,

and the horizontal vapor extraction wells in both Subareas A and B between October 14, 2014 and

December 10, 2014. TerraTherm and its subcontractors also completed construction of the concrete

equipment pads for the process equipment pad and the air emissions stack in November 2014. In

December 2014, TerraTherm completed the placement of the lightweight concrete vapor cover system in

both Subareas A and B.

DNAPL Subarea A Well-field

The remaining above-ground components of the full-scale ISTR well-field, such as piping and control

wiring, along with the assembly of the above-ground vapor and liquid process treatment components are

targeted to be completed in the first and second quarters of 2015. The CMI Team is coordinating an


January 2015 28 033-6231-002

inspection of the ISTR system prior to the start of operation with USEPA and CTDEEP, to fulfill the Order

requirement for a Pre-construction Inspection and Meeting. After discussion with USEPA and CTDEEP

during the progress teleconferences, the meeting was tentatively scheduled for April 14, 2015. Pending

USEPA and CTDEEP approval of the Full-Scale ISTR DFD, shakedown of the full-scale ISTR system is

scheduled for May 2015 with sub-surface heating targeted to begin in June 2015.

2.7 Community Outreach Pfizer and the CMI Team have conducted a number of meetings and presentations as part of

implementing the Community Relations Plan (Appendix H of the CMI Work Plan). Key community

outreach activities during 2014 included:

Meetings with the North Haven First Selectman were held on February 26, 2014 and November 9, 2014 to provide progress updates to town leadership.

Representatives of the CMI Team attended the Quinnipiac River Watershed Association’s (QRWA) library dedication ceremony on Tuesday, February 25, 2014 in Meriden, CT. The QRWA library was named in honor of Annette and Rico Gattilia, two founding members of the North Haven Citizens’ Advisory Panel (CAP) for the Pharmacia & Upjohn Site. Sadly, Annette Gattilia passed away in April 2014. The CMI team added a tribute to Annette and her contributions to North Haven and the entire Quinnipiac River region to the project website7.

The CMI Team met with the Town Land Use Administrator and Town Engineer on March 4, 2014 to discuss local permitting requirements for full-scale ISTR and to provide a progress update on recent activities in relation to the ISTR Site Plan Approval process.

The CMI Team convened a meeting of the North Haven Emergency Response leaders on March 26, 2014 to review safety procedures and plans for the 2014 construction year.

The CMI Team participated in the North Haven Community Earth Day celebration on April 5, 2014. The team displayed graphics depicting the site, answered questions, and handed out fact sheets about the project.

A representative of the CMI Team attended the biannual North Haven Economic Development Breakfasts on April 10, 2014 and October 29, 2014. Business leaders asked questions about progress at the site and CMI Team members addressed those questions.

Meetings with the North Haven Citizens’ Advisory Panel were held on June 10, 2014 and October 20, 2014 to provide progress updates and obtain input from the members. Juan Perez, project manager for USEPA, and Craig Bobrowiecki, project manager for CTDEEP, attended the June 2014 meeting.

Immediately following the October 20, 2014 CAP meeting, representatives of the North Haven Trail Association and the North Haven Land Trust joined the CAP for a presentation on ecological restoration activities and the planned interpretive trail. This presentation was a follow-up to the previous ecological workshop held in April 2013.

7 www.UpjohnNorthHaven.com



January 2015 29 033-6231-002

Ceremonial Planting on October 6, 2014

The CMI Team hosted a stakeholder event at the Site on October 6, 2014 showcasing the ESRC progress and celebrating initiation of ecological restoration efforts. Representatives of USEPA, CTDEEP, the North Haven Citizens Advisory Panel (CAP), and the Town of North Haven attended, as did U.S. Senator Richard Blumenthal.

A number of articles appeared in local papers throughout the year including:

An article appeared in the weekly North Haven Citizen on Friday, April 11, 2014 reporting on the Earth Day program and specifically calling attention to the Pharmacia & Upjohn Company LLC Site display.

Following the June 2014 CAP meeting, an article entitled, “North Haven panel pleased with progress at former Upjohn site”, appeared on the New Haven Register website on June 10, 2014 and in print on June 11, 2014. An article entitled, “Pfizer cleanup of Upjohn site moving ahead”, appeared in the weekly North Haven Citizen on June 20, 2014. The same article also appeared in June 22 edition of the Meriden Record Journal, a daily paper serving the five surrounding towns in the central Quinnipiac River region.

Following the October 2014 ecological restoration showcase, an article entitled, “Pfizer holds ‘eco restoration’ at Upjohn Site”, appeared on the North Haven Citizen website on October 6, 2014 and appeared in print the following Friday. An article entitled, “Cleanup Progressing on Pfizer Site,” appeared in the New Haven Register on October 7, 2014.


January 2015 30 033-6231-002

The USEPA Project Manager presented the CMI progress at the Site to the USEPA

Region 1 office directors in February 2014 and a profile of the green remediation efforts at the Site was posted on the CLU-IN website on September 1, 20148.

As part of the Community Outreach activities being conducted in accordance with the Community

Relations Plan, Pharmacia & Upjohn has also updated the www.upjohnnorthhaven.com website and

maintained a digital information repository that can be accessed from the North Haven Memorial Library,

where selected Site reports are being made available..

8 http://www.clu-in.org/greenremediation/subtab_d37.cfm



http://www.clu-in.org/greenremediation/subtab_d37.cfm

January 2015 31 033-6231-002

3.0 DATA SUMMARY AND CONCLUSIONS The following Section summarizes the data collected to monitor operations of the GWES and GWTF,

groundwater monitoring data collected in accordance with the CMI Groundwater Monitoring Plan, and the

other data collected in 2014 and as described in Section 2.0.

3.1 Assessment of Performance of the Groundwater Extraction Systems and Groundwater Treatment System

During the ESRC construction in 2014, the GWES functioned in several transitional configurations to

provide hydraulic control over Unit 1 groundwater in conjunction with the HBW. The two main

configurations of the GWES during 2014 are as follows9:

From January 2014 through approximately August 2014, extraction wells PW-1R, PW-2, PW-4R, PW-5R, PW-9, PW-17, PW-10, PW-11, PW-16A, PW-14-B, TPW-1N, TPW-2N, and extraction sumps S1S, and S2S within the south groundwater collection trench were operated to extract groundwater from Unit 1, though all wells did not operate at all times.

From approximately August 2014 through December 2014, the extraction well network included PW-1R, PW-2RA, PW-4R, PW-5R, PW-9, PW-10, PW-16A, TPW-1N, and the extraction sumps within both the north and the south groundwater collection trenches (S1S, S2S, S2N, and S1N). Infiltration of precipitation to Unit 1 was greatly reduced through installation of the low permeability cover systems in the northern part of the Site (completed in August 2014) and the southern part of the Site (completed in October 2014).

3.1.1 Summary of GWES Operations, Monitoring and Maintenance During ESRC construction, the GWES extraction wells and temporary extraction wells were initially fitted

with inline totalizer flowmeters which were gradually replaced with magnetic flowmeters as the extraction

wells controls were upgraded over the course of 2014. Flow rates from each extraction well were

recorded on an approximately daily basis and these data are summarized in Table C-1 included in

Appendix C. Table C-1 also indicates which extraction locations were operating at any given point during

the ESRC construction activities.

The extraction wells were redeveloped, or otherwise maintained on an as-needed basis as part of the

preventative maintenance program to help achieve consistent performance. If needed, redevelopment

was typically performed in 1 or 2-day periods to minimize downtime of the extraction well and was

intended to maintain an adequate specific capacity until the subsequent redevelopment event. During the

2014 reporting period there were several redevelopment activities conducted at the Site. The duration

and method of redevelopment activities at each location are summarized in Table C-2 of Appendix C.

9 Compared to the GWES FD, these transitional steps can be best summarized as activities related to CMI Steps 4 and 5.


January 2015 32 033-6231-002

Pharmacia & Upjohn maintains an emergency spare parts inventory on-site. Inventory items include

pump heads and motors, flow sensors and meters, and electrical leads for the extraction well system. In

addition, spare electrical conduit and power lines to the extraction wells have been installed as part of

Site improvements. Appendix C summarizes the maintenance activities performed and significant events

occurring during the 2014 monitoring period. As detailed in Appendix C, during two time periods in 2014,

the SCADA system located in monitoring well MP-22S, which records continuous water levels that have

been correlated with Quinnipiac River elevations, ceased to operate due to ESRC-related construction

activities. During the second downtime period of the SCADA system a portable datalogger was placed in

monitoring well GD-5S to provide data correlated with Quinnipiac River elevations until final repairs could

be made. The portable datalogger was used from mid-September 2014 through the end of the year.

3.1.2 Treatment System Monitoring The GWTF at the Site consists of a Fluidized Bed Reactor (FBR) Unit (installed in 1995), a Solids

Removal System (SRS) (installed in 2001), and an Ultraviolet Light/Hydrogen Peroxide (UV/Oxidation)

System (installed in 2001). The FBR Unit degrades organic compounds with activated biological growth

attached to suspended carbon media. The SRS removes suspended solids, metals, and some organics

adhered to the solids from the FBR effluent. The UV/Oxidation System further degrades the organic

compounds by using ultraviolet light in conjunction with hydrogen peroxide to oxidize and destroy the

compounds. Granulated Activated Carbon (GAC) and multi-media filters were added in 2013 to pre-treat

certain waste streams generated by CMI. The GWTF operates under a NPDES permit (CT0001341)

issued by CTDEEP that regulates the treatment of contaminated groundwater and stormwater and the

subsequent discharge of the treated water to the Quinnipiac River.

A summary of the performance of the GWTF is provided in Table C-3 (Appendix C). The data include

average influent and effluent chemical concentrations, percent removal and mass removal during 2014.

The total mass of volatile and semivolatile organic chemicals listed in Table C-3 that was removed during

the 2014 reporting period is estimated to be approximately 4,800 pounds. The total volume treated by the

GWTF during the 2014 reporting period is estimated to be approximately 58,100,000 gallons, and

included not only groundwater extracted by the GWES, but also stormwater that may have contacted

impacted soils and other waters generated by ESRC construction.

3.1.3 GWES Hydraulic Control Monitoring During 2014, GWES monitoring included the collection of groundwater elevation data in accordance with

the CMI Work Plan during low-mid tide and high tide on March 22, 2014 and August 5, 2014 (See Tables

D-1-3 and D-1-7 in Appendix D-1). Unit 1 groundwater piezometric surface maps were developed based

on the March and August groundwater monitoring events for each tide level, as shown on Figures 4, 5, 6

and 7. Historically, groundwater elevations measured at low-mid-tide are used to evaluate the


January 2015 33 033-6231-002

effectiveness of the GWES hydraulic control. Groundwater elevation measurements were conducted at

low-mid-tide10 to allow for Site groundwater levels to be influenced by an approximately one hour slack

high tide followed by four hours of ebbing tide prior to water level collection. Groundwater elevation

measurements were also conducted on the same day at high tide11. Until completion of ESRC cover

construction activities it was deemed necessary to continue to monitoring groundwater elevation during

low-mid tide and high tide respectively to assess any residual tidal changes in groundwater elevation

following completion of the HBW. Variation of groundwater elevation in wells along the eastern perimeter

(MP-21S, GD-6SR, DM-9SR, OH-13, OH-14, etc.) showed average groundwater elevation changes of

approximately 1.4 feet prior to HBW installation (Appendix C, 2013 Annual Report). Installation of the

HBW has greatly muted any variation in groundwater elevation, in wells along the eastern perimeter

(MP-21S, GD-6SR, DM-9SR, OH-13, OH-14, etc.) only showed average groundwater elevation changes

of approximately 0.2 feet following HBW installation (Appendix D-1).

In general, Unit 1 groundwater flows from west to east, toward the GWES as shown on Figures 4, 5, 6,

and 7, from a high elevation of approximately 10 to 12 feet above the National Geodetic Vertical Datum of

1929 (NGVD29) on the west side of the Site to less than 0 feet NGVD29 (equivalent to MSL) on the east

side of the Site where groundwater is intercepted by the GWES. Unit 1 groundwater capture is shown on

Figures 4, 5, 6 and 7 by the depressions in the groundwater surface depicted between the Site and the

Quinnipiac River. In conclusion, these manual readings indicated that the GWES provided hydraulic

capture of Unit 1 groundwater. This conclusion is consistent with the findings of previous hydraulic

capture analyses (see previous Annual Reports).

In addition to the requirements set forth in the CMI Work Plan, the GWES FD required: periodic

groundwater elevation measurements; the interpretation of groundwater contour maps; and continuous

groundwater elevation monitoring. These requirements were included in the GWES FD to evaluate

instantaneous changes in groundwater elevation as a result of CMI and recommend adjustment to

groundwater extraction rates, if needed. The wells/piezometers that were included in the Transition

GWES monitoring plan are noted in Table 1 and their locations are shown on Figure D-2-1 in Appendix

D-2.

Groundwater contour maps interpreted for low-mid tide cycle as required by the GWES FD are included in

Appendix D-1 for the following survey dates:

10 Low tide is defined to be five hours after high groundwater elevation occurs at MP-22S One hour is added to the high groundwater elevation in MP-22 to approximate the time frame required for the high tide conditions to extend into the entire Site. 11 High tide is defined as one hour following the time at which high groundwater elevation occurs at monitoring well MP-22S.


January 2015 34 033-6231-002

January 8, 2014;

February 11, 2014;

May 1, 2014;

May 19, 2014;

July 2, 2014;

September 4, 2014;

September 29, 2014;

October 30, 2014;

December 3, 2014; and

December 23, 2014

All measurements were targeted toward low-mid tide for consistency with previous manual water level

measurements; however, correlation with tides is no longer required following installation of the HBW.

The continuous water level monitoring included in Appendix D-2, generally indicated consistent inward

hydraulic gradients (i.e., from exterior surface water or groundwater towards the HBW and the GWES) in

the area adjacent to the Quinnipiac River. As explained in Appendix D, only brief periods of outward

gradients were noted at few locations as a result of CMI construction activities and extraction system

upgrades including, but not limited to, piping connection installation, electrical wiring, control system

installation, and enclosure set up. These brief periods of outward gradients were overcome by longer

durations of inward (away from surface water/exterior to HBW groundwater) movement of groundwater

resulting in net inward groundwater flow towards the Site and ultimately groundwater capture by the

GWES. Appendix D-2 presents the magnitude and duration of any periods of outward gradients and

presents a generalized calculation indicating no breakthrough of Site groundwater through the HBW. The

analysis approach was based on similar analyses conducted in 2011 and discussed in previous Annual

Reports.

Over the 2014 monitoring period, the large depression in groundwater elevations located in the northeast

corner of the Site extended to the southern end of the Site extending across the North Pile, FAL, and the

eastern portion(s) of the South Pile. The groundwater elevations within this depression are consistently

lower than the Quinnipiac River elevation of groundwater elevations monitored in wells located outside

(downgradient) of the HBW. The depression in the northeast corner of the Site, first identified in 2013,

resulted from the simultaneous operation of extraction wells coupled with installation of low permeable

cover systems in the northern portions of the Site cutting off infiltration to Unit 1, and reduced inflow of

surface water following installation of the HBW. A similar depression in the South Inland wetland area

(west of the South Pile) occurred later 2014 following installation of low permeability covers in the wetland

basin. In conclusion, the GWES, HBW, and low permeability cover systems created an area of

depressed groundwater along the eastern side of the Site that provided hydraulic capture of Unit 1

groundwater, preventing discharges to the Quinnipiac River and North Creek, and a similar area west of

the South Pile prevented discharges to South Creek.


January 2015 35 033-6231-002

3.2 Groundwater Quality Monitoring

3.2.1 Groundwater Data Collection and Review Activities The Order includes a requirement to conduct groundwater monitoring both during corrective measures

implementation (CMI groundwater monitoring) and during long-term post-construction OM&M (post-CMI

groundwater monitoring). The objectives and scope for the CMI groundwater monitoring are described in

the CMI Groundwater Monitoring Plan (Appendix A of the CMI Work Plan). Table A-3 of Appendix A of

the CMI Work Plan summarizes the locations to be sampled along with the rationale for monitoring each

location. The CMI Groundwater Monitoring Plan made provisions to adapt the CMI monitoring to changes

in Site conditions and linked the process of communicating the modifications to the CMI monitoring

program to USEPA and CTDEEP via the Annual Reports. Accordingly, the intended groundwater

monitoring to be implemented in 2014 was described in Section 6.1 of the 2013 Annual Progress Report.

USEPA reviewed Section 6.1 of the 2013 Annual Report and on July 8, 2014 confirmed that they had no

comments on the proposed 2014 monitoring program (see Appendix A). The CMI groundwater

monitoring that was conducted in 2014 is the focus of Section 3.2. Non-routine groundwater monitoring

that was conducted in support of several objectives during 2014 is described in Section 3.3.

CMI Groundwater Sampling and Analyses

The CMI Groundwater Monitoring Program (including modifications proposed in the 2013 Annual

Progress Report) was conducted in September 2014. Samples were collected by Golder from a total of

12 distinct wells as part of the CMI Groundwater Monitoring Program. One well that was not accessible

during the September 2014 sampling event (MW-35D) was sampled in October 2014. The samples were

submitted to Alpha Analytical, who utilized both their Mansfield and Westborough, MA facilities to perform

the requested analyses. The following groundwater sampling and analyses, which are also summarized

in Table 2, were conducted during these events.

Two Unit 1 wells were sampled during September 2014 to assess groundwater conditions downgradient of the former RCRA Units including the Former Polishing Lagoon, the North Pile, and the Former Enclosed Aeration Basin. In addition, as requested by USEPA in their comments on the CMI Groundwater Monitoring Plan, samples were also collected from two Unit 1 wells downgradient of the South Pile. The Unit 1 groundwater samples from Wells PW-4R (replacing PW-4), PW-5R (replacing PW-5), PW-11 and MW-35SR were submitted for analysis of VOCs, SVOCs and total lead.

Seven Unit 3 wells were sampled during September 2014 to assess whether chemical concentrations in Unit 3 groundwater at the Site perimeter remain below the comparative criteria. Samples from Unit 3 wells DM-5D, DM-7D, DM-9D, GD-3D, GD-4D, MP-20DR, and MP-28DR were submitted for analysis of VOCs, SVOCs and lead. In addition, a sample from Unit 3 well MW-28DR was also submitted for analysis of dissolved lead. Well MW-35D was not accessible in September 2014 due to ESRC construction and the presence of a yellow-jacket nest in the well casing. A sample was collected from well MW-35D in October 2014.


January 2015 36 033-6231-002

The samples from Unit 3 wells GD-3D and GD-4D were also used for the dual purpose of monitoring

groundwater conditions downgradient from Unit 3 well SEC-7D. Additional sampling efforts related to

assessing groundwater conditions in the vicinity of SEC-7D along with non-routine sampling in the vicinity

of full-scale ISTR are discussed in Section 3.3.

Comparative Criteria

This Annual Report evaluates the analytical data from the groundwater samples in relation to two sets of

comparative criteria. The first set of comparative criteria is the groundwater Media Protection Standards

(MPS) defined in Attachment 2, Tables 3 and 4, of the Order. As explained in the footnotes to Tables 3

and 4 (Order Attachment 2) and as further clarified in Appendix J of the CMS, the criteria used to develop

the MPS were based on 1) provisional (draft) RSR values which were advanced by CTDEEP in 2007

(CTDEEP, 2007) and subsequently withdrawn in May 2009, as well as 2) RSR values for Additional

Polluting Substances (APS) proposed by Pharmacia & Upjohn in June 2007 (Golder, 2007). As noted in

the footnotes on Tables 3 and 4 of the Order, “The criteria provided as MPS are subject to change based

on revisions to the RSRs, among other factors. The promulgated RSRs or approved Site-specific RSRs

for APS at the time of remedy implementation are the applicable MPS.”

The second set of comparative criterion that has historically been used include 1) the Surface Water

Protection Criteria (SWPC) RSR criteria promulgated by CTDEEP for state-wide use (CTDEEP, 1996 &

2005), 2) the Industrial Commercial Volatilization Criteria (ICVC) from the CTDEEP Remedial Standard

Regulations Volatilization Criteria, Proposed Revisions, (CTDEEP, 2003), and 3) the RSRs for APS

criteria approved by CTDEEP for Site-specific use in December 200812, (CTDEEP, 2008). As part of the

ongoing process of reviewing and revising the RSRs, on March 16, 2011, CTDEEP withdrew blanket

approval to utilize the 2005 Criteria for APS and the 2003 Proposed Revisions to the ICVC. In June

2013, CTDEEP promulgated revised RSRs, however with the exception of revisions to the criteria for

Total Petroleum Hydrocarbons (TPH) and lead, did not revise the SWPC and the ICVC from those

originally published in 1996. The June 2013 revisions to the RSRs also formalized the withdrawal of the

2005 Criteria for APS and the 2003 ICVC (CTDEEP, 2013b). While the Site has not formally petitioned to

continue using these interim criteria, they are being presented in this 2014 Annual Report for comparative

purposes and for consistency with previous reports.

The above MPS and RSR comparison criteria, along with the target compounds for each analysis, are

summarized on Table 3 of this Annual Report. The SWPC MPS and RSRs apply to all water bearing

units at the Site, while the ICVC MPS and RSRs only apply to Unit 1 groundwater, in particular that

portion of Unit 1 groundwater within 15 feet of the ground surface or a building.

12 The Site-specific ICVC for naphthalene of 12 ug/l was revised to 3,099 ug/L by CTDEEP in March 2012.


January 2015 37 033-6231-002

Data Quality Review

In accordance with the CMI Groundwater Monitoring Plan, the data generated by the CMI Groundwater

Monitoring Program underwent a data quality assessment to identify quality issues which could affect the

use of the data. After completion of the data quality review, 99.7 percent of the groundwater sample data

reported by Alpha associated with the CMI monitoring program were found to be acceptable for project

use, which met the project completeness goal of 85 percent. The data quality review and the detailed

findings of the data quality assessment are presented in Appendix E along with tables summarizing the

laboratory results with the qualifiers applied. Laboratory data reports, which include the Chains-of-

Custody, are provided on CD-ROM in Appendix F. In many cases, the samples from the routine CMI

Groundwater Monitoring were collected concurrently with samples to monitor conditions in the vicinity of

Unit 3 well SEC-7D. Therefore, Appendices E and F address the data collected for both these purposes.

3.2.2 Unit 1 Groundwater Sample Results The compounds detected in the Unit 1 CMI monitoring groundwater samples are summarized in Table 4,

and have been compared to the criteria discussed above (SWPC and ICVC MPS along with the SWPC

and ICVC RSRs). Concentrations exceeding one or more of the comparative criteria are indicated.

Complete results for the Unit 1 sample analyses (which include non-detected compounds) are provided in

Appendix E.

As shown in the results summarized in Table 4, the following compounds were detected above the

comparative criteria in one or more Unit 1 monitoring locations:

Benzene

Aniline

Benzidine

2-Chloroaniline

4-Chloroaniline

3,3’-Dimethylbenzidine

1,4-Dioxane

All of the Unit 1 wells sampled as part of the CMI Groundwater Monitoring are located inside the HBW

and within the hydraulic capture zone of the GWES and thus these exceedances are being contained and

removed via the groundwater extraction and treatment system.

The five primary organic compounds identified in Unit 1 groundwater at the Site, based on frequency

and/or magnitude of detection, are benzene, chlorobenzene, 1,4-dioxane, 2-chloroaniline, and


January 2015 38 033-6231-002

3,3’-dichlorobenzidine13. The concentration of these five compounds in Unit 1 groundwater is summarized

on Figure 8.

Time versus concentration graphs covering the last ten years of data are presented in Appendix G for

select Unit 1 wells. The data from replacement well PW-4R was integrated into the graph showing the

historical data from adjacent well PW-4 and the data from new well PW-5R was integrated into the graph

showing the historical data from PW-5. While well PW-4R is located in close proximity to the former

location of PW-4, groundwater concentrations are noticeably higher in PW-4R than they were in PW-4.

The groundwater sample analyses from 2014 continue to document that groundwater extracted

downgradient of the RCRA Units and other Site features such as the South Pile exceed the comparative

criteria prior to treatment in the GWTF.

3.2.3 Unit 3 Groundwater Sample Results As described above, samples were collected from eight Unit 3 wells to monitor conditions at the

downgradient perimeter during September and October 2014. The chemicals detected in Unit 3 in these

routine CMI monitoring samples are summarized in Table 5, where they are compared to the criteria

described above (SWPC MPS along with the SWPC RSRs). As shown on Figure 9 and discussed below,

all results from the Unit 3 perimeter monitoring samples collected as part of the routine CMI monitoring

were below the comparative criteria. Complete results for the Unit 3 sample analyses (which include non-

detected results) are provided in Appendix E. Additional Unit 3 groundwater monitoring was conducted in

2014 in the vicinity of well SEC-7D as discussed in Section 3.3.

Perimeter Unit 3 Wells

As shown in the results summarized in Table 5, there were no exceedances of the comparative criteria for

VOCs and SVOCs in Unit 3 downgradient perimeter wells (GD-3D, GD-4D, DM-5D, DM-7D, DM-9D,

MP-20DR, MP-28DR and MW-35D). Consistent with the evaluation of Unit 3 groundwater presented in

Appendix L of the CMS, provisions of the June 27, 2013 CTDEEP RSRs promulgated under 22a-133k-

3(g)(2)(c) were considered to evaluate compliance with the SWPC (the only groundwater protection

criteria applicable to Unit 3 and 4 groundwater). Specifically, compliance with the SWPC for a substance

in groundwater is achieved when the sampling locations are representative of the subject groundwater

plume and:

(i) the ninety-five percent upper confidence level of the arithmetic mean of all sample results representative of the subject groundwater plume is equal to or less than such criterion; or (ii) the concentration of a substance in the portion of the plume which is immediately upgradient of the point of discharge to groundwater is less than or equal to the SWPC.

13 These five compounds were previously identified as compounds of concern (COCs).


January 2015 39 033-6231-002

The chemistry results for organic compounds in the downgradient perimeter wells sampled as part of the

2014 CMI Groundwater Monitoring are all below the MPS and the promulgated, RSR-based SWPC

criteria.

3.3 Other Data Generated As discussed in Section 2, a number of non-routine groundwater samples and Construction Quality

Assurance/Construction Quality Control (CQA/CQC) samples were collected in support of various CMI

activities. The results from the analysis of these samples are summarized below and are provided in

appendices to this Annual Report.

3.3.1 SEC-7D PDI/PDP As described in the revised SEC-7D PDI/PDP, new wells were installed and additional data was collected

in the vicinity of Unit 3 well SEC-7D and deep unconfined well GW-HBW17 to monitor conditions in the

area of identified impacts and to address the remaining USEPA comments concerning groundwater

conditions in the northern portion of the Site. In summary, the following actions were taken:

Deep well GW-U309 was installed on the northern border of the Site near North Creek on June 4, 2014. This well was screened in the unconsolidated materials immediately above the Unit 4 bedrock. Approximately 4 feet of Unit 2 were observed at the GW-U309 location, which is consistent with the thinned/absent Unit 2 expected in that area.

Groundwater samples were collected from 12 wells located in the vicinity of SEC-7D in June 2014.

Based on additional discussions with USEPA, Unit 1 well GW-U103 was installed to create a deep shallow pair with well GW-U309 and two additional Unit 3 wells, GW-U310 and GW-U311 were installed upgradient of well SEC-7D between September 29, 2014 and October 10, 2014 to better define hydraulic and chemical gradients in the vicinity of the area of thinned/absent Unit 2.

A comprehensive round of groundwater sampling was conducted in October 2014, including collection of additional analytical parameters and samples from selected Unit 4 wells.

Additional samples were collected from wells GW-U305 and GW-U402A on December 22, 2014; however, the data from these samples was not received in time to incorporate the results into this report.

The proposed datalogger study was initiated in December 2014 to assess the effectiveness of extraction well TPW-1N and determine if alternative pumping rates or alternative extraction wells should be used. The data collection phase of the datalogger study is anticipated to be complete in February 2015.

Construction completion reports for the new monitoring wells GW-U103, GW-U309, GW-U310, and

GW-U311 are provided in Appendix B-1.

A summary of the groundwater samples collected in the vicinity of SEC-7D, along with tables

summarizing the chemicals detected in the samples results are provided in Appendix H-1. The data


January 2015 40 033-6231-002

quality assessment for this data was integrated with the data quality assessment for the CMI monitoring

data and is provided in Appendix E. The laboratory data packages are provided in Appendix F.

The data collected in the vicinity of SEC-7D in 2014 are provided in Appendix H-1 with minimal

interpretation. A more complete interpretation of this data will be presented to USEPA and CTDEEP after

the completion of the datalogger study as part of the response to comments. However, a

recommendation for locations and frequency of groundwater monitoring in 2015 are provided in Section

6.2 of this 2014 Annual Report.

3.3.2 ISTR Thermal Treatment Zone Monitoring As discussed in Section 2.6, DNAPL and groundwater samples were collected in the vicinity of DNAPL

Subarea A and B to provide data in support of the design of the full-scale ISTR system and the pre-

treatment system to be installed at the GWTF to manage the water generated during full-scale ISTR

operations. A sampling summary along with the sample results are provided in Appendix H-2. The

laboratory data package is provided in Appendix E-3.

3.3.3 ESRC Construction Quality Assurance Sampling During ESRC construction, Golder performed CQA in accordance with the Construction Quality

Assurance Plan (CQAP) which was provided in Appendix N of the CMDR. Specific CQA activities

included part time and full time monitoring of ESRC construction and was dependent on the specific

construction activity, as outlined in the CQAP. During ESRC 2014 construction, a majority of the CQA

oversight, including all full time monitoring and CQA sampling performed was associated with the final

cover systems. This included conformance and destructive testing of the geosynthetics as well as

geotechnical sampling for the various cover soils and aggregates used as components of the final cover

systems. Test results of the final components of the cover system all met the project requirements

outlined in the Technical Specifications. Appendix H-3 provides results of the sampling as well as

additional details on the CQA sampling activities.

3.3.4 ISTR Construction Quality Assurance CQA monitoring was also performed by Golder during the full-scale ISTR construction. Golder provided

full time oversight during installation of the multi-phase extraction (MPE) and groundwater extraction

(GWE) wells, which included verification of the depth of Unit 2, as well as part time oversight during

installation of the heater wells, temperature and pressure monitoring points. Appendix H-4 consists of a

brief summary of the CQA activities including a table providing the depths of Unit 2 as observed by

Golder during the installation of the MPE and GWE wells.


January 2015 41 033-6231-002

4.0 ASSESSMENT OF PERFORMANCE OF CORRECTIVE MEASURE The Order requires the Annual Report provide an assessment of the performance of the Corrective

Measure during the previous year. Final “Corrective Measures” as defined by Order, are in process of

design and installation and while substantial progress was made on certain Corrective Measure

components in 2014, the final Site-wide Corrective Measures have not as yet been fully installed.

Therefore, this Section of the 2014 Annual Report discusses the effectiveness of existing IRMs and

interim covers remaining in place at the Site as well as the Corrective Measure components that have

been installed to date, namely the Unit 1 Groundwater hydraulic controls and construction of the majority

of the ESRC cover systems. Subsequent Annual Reports will provide specific assessments of the

performance of the final Corrective Measures once they are fully constructed at the Site and when

appropriate, will discuss progress toward achievement of the Order Performance Standards. The

groundwater migration controls and direct exposure controls described below, along with the ongoing Site

management procedures and institutional controls (as discussed in Section 5.0) will continue to mitigate

and provide protection of human and environmental exposures to impacted media throughout the CMI

period until final Corrective Measures are fully implemented at Site

Groundwater Migration Controls

Pharmacia and Upjohn installed, operates, and maintains a Site perimeter GWES and state-of-the-art

GWTF that controls potential threats to human health and the environment from releases of groundwater

to surface waters (i.e., Quinnipiac River, North Creek and South Creek) by providing effective capture and

treatment of impacted groundwater. Prior to June 2013, groundwater hydraulic control was provided by

the interim GWES, which in 1999 allowed USEPA to approve stabilization measures under the

Environmental Indicators Migration of Contaminated Groundwater Under Control (CA-750), and provided

the necessary hydraulic controls over impacted Unit 1 groundwater for over 15 years.

In November 2013, the ESRC Team completed the installation of the HBW, providing physical isolation of

impacted Unit 1 groundwater from the adjacent surface water. As described in Section 2.5.3, the GWES

was operated in several transitional configurations and expanded throughout 2014 and by the end of the

year had reached close to the post-ESRC configuration. The performance of the GWES during 2014 is

discussed in Section 3.1 of this Annual Report. Consistent with the findings of previous hydraulic control

analyses, the GWES operation in 2014 in conjunction with the HBW provided effective hydraulic control

of Unit 1 groundwater prior to its reaching the Quinnipiac River.

Direct Exposure Controls

Pharmacia & Upjohn has also previously installed IRMs and various RCRA and non-RCRA covers to

mitigate human and ecological direct contact with impacted soil and WWTR. Based on these IRMs and


January 2015 42 033-6231-002

covers, USEPA approved stabilization measures under the Environmental Indicators for Current Human

Exposures Under Control (CA-725) in 1999. In essence, this means that there are no unacceptable

human exposures to soil/WWTR at the Site, based on current use.

After decontaminating, decommissioning and removing former manufacturing buildings and storage tanks

in 1993, Pharmacia & Upjohn paved the majority of the western portion of the Site (including the Former

Production Area) to mitigate direct exposures. Pharmacia & Upjohn installed a chain-link fence and

locking gates around the north, west, and south property boundaries, installed warning signs, and

provides 24-hour per day Site security to minimize unauthorized entry to impacted areas of the Site. Also

in the western portion of the Site, Pharmacia & Upjohn constructed an IRM for the Relic Firewater Pond,

which provides a geosynthetic membrane and soil cover to prevent human and ecological exposures.

These IRMs continue to effectively protect against direct contact exposures to contaminated media on the

western side of the site in 2014.

As discussed in Section 2.6.5, the interim asphalt cover over DNAPL Subareas A and B in a portion of the

Former Production Area was disturbed as part of constructing the full-scale ISTR system in August 2014.

The clean fill and concrete thermal covers placed over the DNAPL Subareas A and B during construction

of the TTZ will prevent direct contact to underlying contaminated media during the ISTR operations.

Interim covers on the eastern side of the Site effectively provided protection against direct contact

exposures to contaminated media on the eastern side of the Site through the start of ESRC construction

in June 2013. Following disruption of these interim covers, and prior to and during construction of the

ESRC cover systems, exposure to contaminated media were controlled through the implementation of the

following measures:

Controlled access to the exclusion zone designated on the east side of the Site

Implementation of a rigorous health and safety plan for Site workers

Physical control to deter unwanted trespasser access

Dust control and perimeter air monitoring to protect the surrounding community

Adherence to the soil, sediment, and debris management plan

Implementation of equipment and personnel decontamination procedures

Installation and maintenance of soil erosion and sedimentation control structures

As described in Section 2, during 2014, construction of the low permeability and protective barrier covers

on the eastern side of the Site was substantially completed, such that at the end of the year all areas of

the east side of the Site and impacted media were covered by one of the approved cover systems or one

or more components of the approved cover system. While work remains to complete the ecological

enhancements, that will among other purposes provide long-term stabilization of the cover systems


January 2015 43 033-6231-002

against erosion, the existing conditions prevent both human and ecological direct contact exposures. In

addition, the low permeability geosynthetic cover systems placed over the North Pile, FAL and South Pile

in 2014 will reduce infiltration of precipitation through WWTR.


January 2015 44 033-6231-002

5.0 INSTITUTIONAL CONTROL MONITORING ACTIVITIES The Order defines institutional controls as “(a) the prohibitions of various land and water use activities set

forth by Section VII.B.5.d and e of this Order to limit human exposure to the contaminants at the Facility

and ensure the protectiveness of the Corrective Measures as well as (b) the Environmental Land Use

Restrictions (ELURs) that Respondent shall put into place pursuant to Section VII.B.5.b of this Order.”

Section V.B.5.c of the Order requires that as part of the Annual Report, the Respondent shall confirm that

it has conducted long-term institutional control monitoring activities.

The majority of the institutional controls identified in the Order, in particular the ELURs, will not be

implemented until after completion of Corrective Measure construction. However, several institutional

controls have been implemented at the Site, are incorporated into Site OM&M, and have been monitored

during the 2014 CMI reporting period as summarized below. As described in Section 4.0, ISTR

construction activities began in August 2014 and ESRC construction activities continued throughout 2014

and as a result, the type of institutional controls monitoring transitioned from the previous IRM institutional

control monitoring to construction controls monitoring being implemented.

Site-Wide Controls

Unauthorized entry into the accessible portions of the Site is restricted by a chain link fence with signage

(24 inches by 36 inches reading "Warning, No Trespassing, Environmental Contamination Beyond This

Point") installed around the perimeter of the Site at approximately 200-foot intervals. Additional “Warning"

and "No Trespassing" signs are posted in the least accessible areas of the Site, which are not fenced.

Access to these portions of the Site is controlled by the following:

Eastern Portions of the North Side: The Highway 40 corridor’s steep embankment, North Creek waterway, dense vegetation, and tidal marsh;

Eastern Portion of the South Side: Neighboring industrial/commercial facilities, South Creek Waterway, and tidal marsh, and;

East Side: Quinnipiac River and tidal marsh.

CTDEEP OLISP extended the Certificate of Permission to allow the signs to remain in wetland areas until

CMI activities are complete. Woodard & Curran is the contractor hired by Pharmacia & Upjohn to

maintain a 24-hour per day on-site presence, control the automatic locking Site entrance gate, and to

operate and maintain the groundwater extraction and treatment system. Access through the fenced area

is controlled by three gates which are locked 24 hours a day when not in use. A key card entry lock

system and a surveillance camera is installed at the front gate (41 Stiles Lane). All Site visitors are

required to sign in upon entry to the Site and to obey Site health and safety requirements. The primary

visitor sign-in area is located in the GWTF entrance and managed by Woodard & Curran. URS and WRS

also maintained sign-in sheets for the consultants, contractors, and visitors associated with Corrective


January 2015 45 033-6231-002

Measure implementation. Until all such areas were covered during ESRC construction, a map of the Site

was posted in the Site visitors sign-in areas (GWTF entrance managed by Woodard and Curran, URS

office trailer, WRS office trailer) that showed visitors where significant environmental hazards may exist in

accordance with CTDEEP requirements.

All fences, gates, and security measures are checked periodically for vandalism or other evidence of

trespassing. Woodard & Curran staff is present on-site 24 hours per day and security checks of

controlled areas are made several times a day. On February 4, 2014, an unauthorized visitor entered the

Site, however he was stopped by Site personnel shortly after entry and prior to exposure to impacted

media. The trespasser was cited by the Town of North Haven Police. This is the first documented

trespassing incident since the Order was issued in 2011.

Woodard & Curran staff performs a weekly perimeter sign inspection and maintenance program to

confirm that warning signs are present and remain clear of obstructions. The perimeter fencing is

inspected for damage and the gates are checked to ensure they are locked and locks are in working

order. Institutional control inspection checklists (for such items as signs, fences, and gates) are

maintained on-site. During 2014, Woodard & Curran staff would also periodically inspect the interim

covers on the west side of the Site to assess damage, thereby fulfilling the requirement to at least

annually verify that cover systems and engineered controls are in good order. Pharmacia & Upjohn began

removing warning signs as direct exposure hazards were eliminated during the installation of final cover

systems on the east side of the Site. It is anticipated that the majority of the remaining warning signs will

be removed in 2015 upon completion of the ESRC.

East Side Controls

As discussed in Section 4.0, the transition from the previous IRM/Institutional Controls monitoring

(described above) to the post-CMI Site-Wide Corrective Measure monitoring described in the Order

began in May 2013 with the commencement of the ESRC construction activities. The ESRC Team is

implementing the ESRC Corrective Measure activities (HBW, GWES upgrades, final cover systems and

other CMs) and is responsible for managing and regularly inspecting and monitoring the east side areas

under construction.

Consequently, the regular inspections of east side IRMs and the GWES previously performed by

Woodard and Curran (described above) are no longer necessary and will no longer be performed. The

ESRC Team regularly inspects (at least monthly) the east side construction areas and controls they have

implemented (see Section 4.0). Golder Associates performs regular monitoring (on an approximately

monthly basis) of the GWES water levels and performance. Woodard & Curran staff continue to perform a

Site-wide perimeter sign inspections and maintenance program (including on the east side of the Site) to


January 2015 46 033-6231-002

confirm that remaining perimeter warning signs are present and remain clear of obstructions. Altogether,

these east side inspections and monitoring fulfill the requirement to at least annually verify that cover

systems and engineered controls for the east side are in good order and the requirement to verify that

monitoring wellheads are in good repair.

Current Land Use Restrictions

While the Environmental Land Use Restrictions (ELUR) described in the Order will not be implemented

until final CMs are installed, Site use restrictions are currently recorded on the existing property deed,

stating that the Site shall not be used in any manner that the USEPA determines would adversely affect

the integrity of any containment system, treatment system, or monitoring system. It is likely that at least

two separate ELURs will be implemented: (1) an ELUR allowing passive recreational use on the East

Side where ecological habitat will be restored, created and/or maintained, and (2) an ELUR allowing

commercial or light industrial use on the West Side. Pharmacia & Upjohn has verified that through its

oversight that current Site use is consistent with the conditions of the existing deed restriction.

Summary

As Site Owner, Pharmacia & Upjohn remains in control and maintains the Site in accordance with current

land use requirements, therefore institutional control provisions related to site ownership/property deed

transfer are not relevant. The Site continues to be used for remediation activities in accordance with

USEPA and CTDEEP approved work plans. While CMI activities, in particular the ESRC construction,

have disturbed previously existing RCRA covers and IRMs, these activities are being performed with the

knowledge and consent of USEPA and CTDEEP and in accordance with the CMI Work Plan, and no

uncontrolled exposure to Site contaminants has occurred or is currently present (i.e. the existing covers

and ESRC construction controls described in Section 4.0 are currently serving the purpose to prevent

direct contact exposure). Prohibited uses of the Site, such as the potable use of groundwater and the use

for residential activities, are not occurring.


January 2015 47 033-6231-002

6.0 PROJECTED 2015 MONITORING ACTIVITIES AND MASTER PLAN

SCHEDULE The following Sections fulfill the Order requirement for the Annual Report to provide a schedule of

sampling and field activities to be performed and reported in the following year, along with any proposed

modifications to the OM&M activities. This Section also summarizes milestones and progress goals that

Pharmacia & Upjohn anticipates will be fulfilled in the upcoming year. There are no proposed changes to

the Master Plan Schedule.

6.1 Schedule of OM&M Sampling This Section summarizes the groundwater monitoring activities to be conducted in 2015. It includes

monitoring activities that have been described in previous technical submittals to USEPA and CTDEEP

and presents proposed monitoring activities where consensus is yet to be reached with USEPA and

CTDEEP. The CMI Groundwater Monitoring Plan, described in the CMI Work Plan, was designed to

monitor Site groundwater during construction of the ESRC and other Corrective Measures. The

Transition GWES monitoring program, described in the GWES FD, was designed to supplement the CMI

groundwater monitoring and monitor Unit 1 hydraulic control during the transition to the upgraded

post-ESRC GWES14. The approved Post-CMI Groundwater Monitoring Plan, included as Appendix D of

the ESRC CMDR, described the intended monitoring network, procedures for groundwater monitoring,

and associated QA protocols for groundwater sampling and analyses at the Site during the first two years

following completion of ESRC construction, and concurrent with the implementation of the remaining

Corrective Measure. Since the post-ESRC GWES was not fully functioning until late 2014 and final

shakedown of the GWES operation and controls will not likely be completed until early 2015, the

groundwater monitoring in 2015 is proposed to be a hybrid of the programs from the CMI Groundwater

Monitoring Plan, the Transition GWES monitoring plan, and the Post-CMI Groundwater Monitoring Plan. It

is anticipated that the transition to the post-ESRC monitoring described in the Post-CMI Groundwater

Monitoring Plan will begin in mid-2015, once the ESRC Team demobilizes from the Site. The Full-Scale

ISTR DFD and the SEC-7D PDI/PDP also describe other proposed groundwater monitoring activities. As

has been discussed on the progress teleconferences, a holistic view is valuable when considering

groundwater monitoring efforts and therefore these groundwater monitoring activities are also discussed

below.

The CMI Groundwater Monitoring Plan included an objective related to the routine collection of Unit 1

groundwater samples to monitor Unit 1 groundwater downgradient of the RCRA units (Former Polishing

Lagoon, Former Enclosed Aeration Lagoon, and North Pile) and downgradient of the South Pile. This

14 While the ESRC CMDR used the term “post-CMI GWES,” and no additional changes to the GWES are anticipated, as the post-CMI period will formally begin after approval of the overall Site Construction Completion Report (coinciding with issuance of the CTDEEP Stewardship Permit and termination of the USEPA Order), the term post-ESRC GWES will be used during the remainder of this discussion and during the period between completion of the updated GWES and the official start of the post-CMI period.


January 2015 48 033-6231-002

objective was achieved by the collection of groundwater monitoring samples from Unit 1 Monitoring Wells

PW-4R, PW 5R, PW-11 and MW-35SR in September 2014. The groundwater sample analyses from 2014

continue to document that groundwater extracted downgradient of the RCRA Units and other Site

features such as the South Pile exceed the comparative criteria prior to treatment in the GWTF. As

discussed in the 2013 Annual Report, it is proposed that this monitoring be phased out since it is based

on a relic objective for pre-ESRC RCRA Unit and IRM monitoring and is not included in the post-ESRC

monitoring. Pharmacia & Upjohn will not collect these samples in 2015 or beyond for purposes of RCRA

Unit or IRM monitoring since the newly designed groundwater monitoring program is comprehensive to

include Site-wide RCRA Corrective Action program monitoring.

As described in Section 3.1, the 2014 hydraulic control monitoring and groundwater sampling events

were conducted in a dynamic fashion to accommodate the ESRC construction activities and field

conditions. With the continuation of ESRC and full-scale ISTR construction activities in 2015, Pharmacia

& Upjohn anticipates that groundwater monitoring in 2015 will continue to be a dynamic process as the

Site moves towards post-CMI conditions. The scope and the schedule of the groundwater monitoring

activities discussed below may be adjusted to accommodate the methods, locations and schedule of

specific construction activities planned for 2015 (e.g. Full-Scale ISTR construction schedule, well

installation dates, Health and Safety, and access limitations). USEPA and CTDEEP will be kept informed

of the progress of these activities via the quarterly progress reports and teleconferences, or by less formal

means, such as email, as these activities develop throughout the course of the year.

The objectives, scope and schedule of the planned 2015 monitoring activities are described in the

sections that follow.

6.1.1 Objective 1: Unit 1 Groundwater Hydraulic Control Monitoring Objective

Verify hydraulic control of Unit 1 groundwater, evaluate changes in Unit 1 groundwater elevations as a

result of CMI and equilibration of the Site to post-ESRC conditions, and recommend adjustment to

groundwater extraction rates, if needed.

Scope

To achieve this objective, Unit 1 groundwater elevation measurements will be taken along the Site

perimeter and the HBW alignment on a continuous basis using portable electronic datalogger devices.

As described in both the GWES FD and the Post-CMI Groundwater Monitoring Plan, periodic manual

water level measurements will also be taken at the locations where the dataloggers are installed that will

be used to verify the accuracy of the datalogger devices and allow for correction, if necessary.


January 2015 49 033-6231-002

During 2015, the portable dataloggers will be deployed at the locations indicated in Table 6 and shown on

Figure 10. This configuration is similar to the configuration described in the Post-CMI Groundwater

Monitoring Plan; however, it incorporates changes in response to ESRC as-built conditions (e.g. the use

of replacement wells when those referenced in the Post-CMI Groundwater Monitoring Plan were

damaged by construction, and the changes to which wells will be used for extraction on the South Pile).

The datalogger configuration will be similar to that used during the 4th Quarter of 2014 with the exception

that the datalogger placed in well GW-HBW11 will be removed and not used during 2015. The

groundwater elevations in GW-HBW11 will be compared to the elevation of the Quinnipiac River, as

recorded by the SCADA system in well MP-22S, since groundwater in the area near monitoring well

GW-HBW15 has been consistently below the river during the second half of 2014. The locations used for

continuous water level monitoring will be evaluated near the end of 2015 and based on the data collected,

the monitoring network for 2016 may be revised, including the elimination of redundant monitoring

locations.

Schedule

As described in Section 5.3 of the GWES FD, the dataloggers will be downloaded and the data evaluated

on an approximately monthly basis until completion of the ESRC construction (anticipated to be

completed June 2015). As specified in the Post-CMI Groundwater Monitoring Plan, the information

collected by the dataloggers will continue to be evaluated approximately monthly during the first six

months following the completion of the ESRC construction (anticipated to be June through December).

After six months of post-ESRC construction monitoring, the frequency will be evaluated and likely

reduced. The exact frequency of manual verification of the water levels will be evaluated following the

initial 6-month period, but is anticipated to be performed semiannually for the first two years following

ESRC completion. The revised schedule will be provided in the 2015 Annual Report.

While, the manual verification of datalogger readings will be performed approximately monthly during

2015, the data collected in 2013 and 2014 have verified the reliability of the datalogger measurements;

therefore, piezometric contour figures will no longer be presented for the monthly verification of hydraulic

control. At the end of 2015, after approximately six months of post-ESRC construction monitoring, the

frequency of the manual verifications will be evaluated and likely reduced. The exact frequency of

manual verification of the water levels will be evaluated following the initial 6-month period, but is

anticipated to be performed semiannually for the first two years following ESRC CMI completion. The

revised schedule will be provided in the 2015 Annual Report.


January 2015 50 033-6231-002

6.1.2 Objective 2: Evaluation of Post-ESRC Groundwater Flow Directions Objective

Assess post-ESRC Units 1, 3 and 4 groundwater flow patterns, elevations, and vertical gradients.

Scope

This objective will be achieved by the collection of periodic manual water level measurements at wells

screened in Units 1, 3 and 4. The perimeter and interior Unit 1 wells to be included as part of the manual

water level monitoring program in 2015 are shown on Figure 10. Figure 11 shows the Unit 3 and 4

monitoring locations that will be incorporated into the groundwater level program for the deeper water

bearing units. The water level monitoring locations are also listed on Table 6, which also includes an

indication of the changes between the 2014 and 2015 monitoring locations.

Starting with the 2015 monitoring, manual measurements will target low-mid tide only. High tide

measurements will be discontinued since, as discussed in Section 3.1, the average tidal fluctuation in

wells along the eastern perimeter (MP-21S, GD-6SR, DM-9SR, OH-13, OH-14, etc.) has been greatly

muted by installation of the HBW and was approximately 0.2 feet in 2014.

Schedule

To fulfill the objective to evaluate and assess groundwater flow directions, manual water level

measurements will be collected approximately quarterly. Synoptic water level monitoring events are

anticipated in March, June or July, and either September or October15 2015. The March 2015 event is

anticipated to be the last semiannual synoptic round conducted under the CMI Groundwater Monitoring

Plan. The proposed frequency for manual water level measurements for the remainder of the year is

consistent with the Post-CMI Groundwater Monitoring Plan, which specified that verification of interior

water level measurements in Unit 1 and evaluation of water levels in Units 3 and 4 would be performed

quarterly during the first six months following the completion of the ESRC construction. The locations,

durations, and frequency of water level measurements will be determined by a variety of factors,

including, but not limited to, weather, safe access to the monitoring locations during construction

activities, and variability of datalogger readings. The exact frequency of interior water level

measurements will be evaluated following the initial 6-month period but is anticipated to be performed

semiannually for the first two years following construction completion. The revised schedule will be

provided in the 2015 Annual Report.

15 The date for the summer and the fall monitoring events will be picked based on a number of factors including, ESRC construction completion date, when low river stage is anticipated in the Quinnipiac River and the ISTR start-up date such that a consolidated Annual Monitoring event can be conducted in either September or October 2015, and the summer event will be held approximately 3 month previously..


January 2015 51 033-6231-002

6.1.3 Objective 3: Unit 1 Groundwater Quality Outside HBW Objective

Establish baseline Unit 1 groundwater quality outside the HBW to allow the future assessment of

attenuation of potential residual Unit 1 groundwater impacts outside the HBW.

Scope

This objective will be achieved by the collection of baseline samples for VOCs and SVOCs from 10 Unit 1

monitoring wells located outside the HBW (GW-NFPA07, GW-HBW03, GW-HBW11, GD-5S, DM-5S,

DM-7S, GW-HBW12, GW-HBW06, GW-HBW13 and GW-HBW07). The wells are listed in Table 7 and

shown on Figure 10.

Schedule

As described in the Post-CMI Groundwater Monitoring Plan, baseline samples will be collected

approximately quarterly for a period of six months following completion of the ESRC. It is anticipated that

samples will be collected in June or July and September or October 2015. The schedule for sample

collection will be decided based on when ESRC construction is completed and when the full-scale ISTR

system begins operation such that a consolidated monitoring event can be conducted in the fall of 2015.

Per the Post-CMI Groundwater Monitoring Plan, based on the review of the water level and groundwater

temperature data collected from wells DM-5S, DM-7S, GD-5S, GW-HBW03, GW-HBW06, GW-HBW07,

GWHBW11, GW-HBW12, and GW-HBW13 in fall 2013 and winter 2014, for winter groundwater sampling,

it is proposed that groundwater samples be collected at low tide, or within three hours of low tide and for

summer groundwater sampling, it is proposed that groundwater samples be collected between two and

six hours following low tide. The impact of the inflow of river water on the groundwater temperature was

seen to vary between wells monitored during the survey, and at some locations, there appeared to be

little temperature variability. At these locations, it is proposed that groundwater samples be collected

during the four hour period following low tide. Prior to collection of the 2015 groundwater quality samples

from the wells located outside the HBW, electronic dataloggers will be used to record temperature and

water level data from a selection of these wells for a two week period to verify the relationships between

water level and temperature in the well and the tidal cycle to confirm the timeframes to collect

representative Unit 1 groundwater samples from the wells outside the HBW. It is anticipated that the

continuous verification of Unit 1 hydraulic control may be temporarily suspended at selected locations to

allow the dataloggers to be used for this program.

It is anticipated that groundwater sampling will be conducted to generally coincide with the low river stage

once the groundwater monitoring program moves to an annual sampling event after the initial baseline.


January 2015 52 033-6231-002

Low river stage typically occurs between mid-September and early October. Therefore, one of the events

in 2015 will target this low river stage timeframe. In addition, to the extent practical, the groundwater

sampling events will be scheduled to avoid periods of abnormally high river discharge (e.g., due to

significant storm events). The schedule for sample collection in 2015 will also consider when ESRC

construction is completed and when the full-scale ISTR system begins operation such that a consolidated

monitoring event can be conducted in the fall of 2015.

6.1.4 Objective 4: Demonstrate Compliance with Unit 3 Performance Standards at Downgradient Property Boundary

Objective

Demonstrate compliance with the Unit 3 Performance Standards established in the Order at wells along

the downgradient property boundary.

Scope and Schedule

This objective will be achieved by the collection Unit 3 groundwater samples for VOC and SVOC analysis

from seven Unit 3 monitoring locations (DM 5D, DM-7D, DM-9D, MP-20DR, MW-35D, GD-3D, and

GD-4D). The Unit 3 wells that will be sampled are listed in Table 7 and shown on Figure 11. The data

from several of these wells will also be used to evaluate conditions in the vicinity of Unit 3 well SEC-7D.

Collection of samples from interior Unit 3 well MP-28DR, located on the southern slope of the North Pile

will be discontinued. This well was included in the CMI Monitoring, but as it is not located at the Site

perimeter, it was not included in the post-ESRC monitoring described in the Post-CMI Groundwater

Monitoring Plan.

Collection of samples from downgradient Unit 3 monitoring wells on an annual basis is a common

element of both the CMI Groundwater Monitoring Plan and the Post-CMI Groundwater Monitoring Plan. It

is anticipated that these samples will be collected during the consolidated Annual Monitoring event in

either September or October 2015.

6.1.5 Objective 5: Groundwater Chemistry and Hydraulic Gradients in the Vicinity of Unit 3 Well SEC-7D

Objective

Refine understanding of groundwater chemistry and hydraulic gradients in the vicinity of Unit 3 well

SEC-7D.


January 2015 53 033-6231-002

Scope and Schedule

The SEC-7D PDI/PDP indicated that the monitoring wells to be sampled in 2015 would be selected based

on the results of the 2014 monitoring. As shown on Table 7, samples will be collected from five Unit 3

(GD-3D, GD-4D, SEC-7D, GW-U311 and GW-U305) and two deep unconfined wells (GW-HBW17 and

GW-U309) in March 2015. Samples will be collected from four shallow Unit 1 wells (GW-HBW16,

GW-HBW19, GW-U103, and TPW-1N), three deep unconfined wells (GW-HBW17, GW-U303, and

GW-U309), and five Unit 3 wells (GD-2D, GW-U310, SEC-7D, GW-U305, and GW-U311) in September

or October 2015. The data collected from Unit 1 well GW-NFPA07 and Unit 3 wells GD-3D, GD-4D and

MP-20DR as part of the post-ESRC monitoring, and from proposed Unit 3 well GW-U312 as part of the

full-scale ISTR monitoring, will also be evaluated as part of this data set. This preliminary selection of

wells to monitor may be refined based on the results of the datalogger study.

Hydraulic gradients in the vicinity of Unit 3 well SEC-7D will be evaluated following completion of the

datalogger study in January 2015. The data from this study will be available in the first quarter of 2015

and will be used to provide input into the response to USEPA comments dated July 8, 2014, which is

projected to be submitted to USEPA and CTDEEP no later than March 2015.

Newly installed wells in the vicinity of SEC-7D have been added to the synoptic groundwater

measurement program, described previously in Section 6.1.2. Manual water level measurements will be

collected in March, July and either September or October 2015.

6.1.6 Objective 6: Confirm Groundwater Quality Data Collected at Unit 4 Well GW-U402A Objective

Confirm or refute groundwater quality data collected in October 2014 at Unit 4 well GW-U402A, as

discussed in Appendix H-1 of the 2014 Annual Report.

Scope and Schedule

Collect one sample from GW-U402A in January 2015 for VOC and SVOC analysis to confirm or refute

data collected during the October and December 2014 sampling events. In addition, collect samples from

GW-U402A for VOC and SVOC analysis in March and September or October 2015.

A groundwater sample will also be collected from adjacent Unit 3 well GW-U305 in January 2015 for

comparison to the previous results. Additional sampling that is scheduled at Unit 3 well GW-U305 during

2015 is described in Section 6.1.5.


January 2015 54 033-6231-002

6.1.7 Objective 7: Monitor Changes in Unit 3 Groundwater Quality During Full-Scale

ISTR Objective

Establish baseline groundwater conditions downgradient of DNAPL Subareas A and B, monitor changes,

if any, to groundwater quality and groundwater elevations during and immediately after the full-scale ISTR

operation and provide a warning system for potential adverse changes to Unit 3 groundwater quality

downgradient of DNAPL Subareas A and B as it relates to the full-scale ISTR operations.

Scope and Schedule

As described in the Unit 3 Groundwater Monitoring Plan for Full-Scale ISTR (Appendix G of the ISTR

DFD), samples will be collected from proposed Unit 3 wells GW-U312 and GW-U313, or alternate wells

as approved by USEPA and CTDEEP, approximately every 60 days. The first sample will be collected

approximately 2 months prior to the initiation of ISTR heating to provide baseline data. The schedule

shown on Table 7, assumes that well installation will be completed in March 2015 and that ISTR heating

will be initiated in June 2015. The schedule of the ISTR monitoring may be modified to permit the

collection of samples concurrently with the consolidated post-ESRC and SEC-7D area monitoring event

in September or October 2015.

All Unit 3 groundwater samples will be analyzed for VOCs and SVOCs. Additionally, groundwater

samples will also be analyzed for PCBs approximately every 120 days (see Unit 3 Groundwater

Monitoring Plan for Full-Scale ISTR for additional details).

6.2 Proposed Modifications To The Annual OM&M Activities Woodard & Curran will continue to operate the GWTF in accordance with the Site NPDES Permit and will

continue the NPDES permit renewal process with CTDEEP. Woodard & Curran will continue to operate,

monitor and maintain the post-ESRC GWES, and institutional controls at the Site. Golder Associates will

continue to monitor water levels, assess the performance of the Unit 1 hydraulic controls, and collect the

groundwater quality monitoring samples. No changes to routine OM&M activities, such as redevelopment

of extraction wells (as needed) and inspection of the fences and signs at the Site are anticipated. While

daily operating parameters may be adjusted to accommodate the CMI wastewater streams, including

those generated by ISTR construction and operation, these changes will be implemented in accordance

with the NPDES permit and CTDEEP approvals for the ISTR waste streams.

6.3 Master Plan Schedule As shown on Figure 3 and discussed in Section 1.5, Pharmacia & Upjohn had previously met all of the

Major Milestones or Progress Goals included on the Master Plan Schedule for 2014, including:


January 2015 55 033-6231-002

Complete ISTR Pilot Study

Submit ISTR Pilot Study Report and PDP

Submit Unit 1 Hydraulic Controls Draft Final Design Package

Submit GWTF NPDES Request for Determination of Permit Modification related to the ESRC construction to CTDEEP, as necessary

The CMI Team achieved the June 5, 2015 Major Milestone associated with “Submit Draft Final Design for

Remaining ESRCs (including EC Variance Application Part 2) in 2013. During 2014, the CMI Team also

achieved the 2015 Progress Goal Submit Full-Scale ISTR Draft Final Design.

A number of Progress Goals remain for 2015 including:

Activity Milestone Type Milestone Date Target

Completion Date

Submit GWTF NPDES Request for Determination of Permit Modification to

CTDEEP related to Operation of the Full-Scale ISTR, as necessary

Progress Goal 10/30/2015 1st Quarter 201516

Submit Draft Final Design of West Side Remedial Components Progress Goal 8/28/2015 TBD

To date, the CMI Team has not encountered any delays or technical difficulties that would negatively

impact the ability to meet the Master Plan Schedule. The CMI Team, on behalf of Pharmacia & Upjohn,

is striving to accelerate the design and construction schedule to efficiently implement the Corrective

Measure and efficiently complete the CMI period.

As described in Section VII of the Order, Pharmacia & Upjohn may propose updates to the Master Plan

Schedule to USEPA. Achieving the progress goal for “Submit Draft Final Design of the West Side

Remedial Components (WSRC)” is dependent on assessing future development needs in the Town of

North Haven through discussions with potential developers and Town officials, and the selection of a

West Side redevelopment concept that will be compatible with WSRC remedial action objectives. While

initial talks with potential developers are in progress and potential redevelopment concepts are being

considered, a redevelopment concept has not been selected. Pharmacia & Upjohn is currently evaluating

whether it will be able to prepare and submit the WSRC Draft Final Design by the August 28, 2015

Progress Goal date. Pharmacia & Upjohn does not request any modification to the Master Plan Schedule

at this time, but anticipates that they will be discussing this Progress Goal with USEPA and CTDEEP as

2015 progresses and will likely request an extension. Proposed revisions to the Master Plan Schedule

16 Based on the timing of the proposed full-scale ISTR operation, the information related to NPDES approval of treatment of the full-scale ISTR waste waters was included in the NPDES permit renewal application submitted to CTDEEP in July 2014. After discussion with CTDEEP, a request for approval to manage water generated during ISTR treatment under RSCA Section 22a-430-3(i) is being prepared.


January 2015 56 033-6231-002

will be provided to USEPA and CTDEEP in the Quarterly Reports, as specified by the Order. Revising the

Progress Goal date associated with the submittal of the draft final design of the WSRC is not anticipated

to impact the ability to achieve the May 29, 2020 Major Milestone associated with Submit the

Construction Completion Report for West Side Areas.

Section IV of the quarterly progress reports describes and provides more detail on specific CMI activities

planned for 2015, including details of Corrective Measure implementation that lead to the Order Major

Milestones and Progress Goals highlighted above. USEPA and CTDEEP will be kept informed of any

schedule changes through the quarterly progress reports and routinely scheduled teleconferences.

USEPA and CTDEEP will also continue to be consulted, regarding technical and regulatory matters (e.g.

to solicit input on the ISTR Full-Scale Design, SEC-7D remedy, and ESRC implementation), as necessary

during 2015.


January 2015 57 033-6231-002

7.0 REFERENCES CTDEEP, 1996. Remediation Standard, RCSA 22a-133k-1 through 22a-133k-1, January 1996.

CTDEEP, 2003. Connecticut’s Remediation Standard Regulations Volatilization Criteria, Proposed Revisions. March 2003.

CTDEEP, 2005. Comprehensive List of Approved Additional and Alternative Criteria, October 2005.

CTDEEP, 2007. Draft Proposed Revisions to the Remediation Standard Regulations, October 2007.

CTDEEP, 2008. Letter from Patrick F. Bowe (CTDEEP) to Russ Downey (Pharmacia & Upjohn) “Request for Criteria for Additional Polluting Substances” dated December 22, 2008.

CTDEEP, 2010. NPDES Permit Issued to Pharmacia & Upjohn Company LLC (Permit ID CT0001341), January 2010.

CTDEEP, 2011, Ms. Kim Hudak, “Approval of Facility Modification Treatment System Modification Approval”. Letter to Mr. Russell Downey, June 11, 2011.

CTDEEP, 2012. Letter from Patrick F. Bowe (CTDEEP) to Tim Carr (GeoDesign) “Request for Criteria for Additional Polluting Substances” dated March 23, 2012

CTDEEP, 2013a, Ms. Kim Hudak, “Approval of Facility Modification Treatment System Modification Approval”. Letter to Mr. Russell Downey, March 19, 2013.

CTDEEP 2013b, Remediation Standard, RCSA 22a-133k-1 through 22a-133k-1, July 2013.

Golder Associates Inc., 2006. Final Investigation Report, Pharmacia & Upjohn Company LLC Site, North Haven, Connecticut, August 2006.

Golder Associates Inc. (Golder), 2007. Proposed RSR Criteria for Additional Polluting Substances (Revision 1), June 2007.

Golder Associates Inc., 2010. Final Revised Corrective Measures Study, Pharmacia & Upjohn Company LLC Site and Lake A LLC Site, North Haven, Connecticut, Golder Associates Inc., June 2010.

Golder Associates, 2012a. 2011 Annual Progress Report, Pharmacia & Upjohn Company LLC Site, North Haven, Connecticut, February 2012.

Golder Associates, 2012b. Corrective Measures Implementation Work Plan, Pharmacia & Upjohn Company LLC Site, North Haven, Connecticut, February 2012.

Golder Associates, 2013a. 2012 Annual Progress Report, Pharmacia & Upjohn Company LLC Site, North Haven, Connecticut, January 2013.

Golder Associates, 2013b. Groundwater Extraction System Hydrogeologic Draft Final Design (Appendix H of the Draft Final East Side Remedial Components Design Report) Pharmacia & Upjohn Company LLC Site, North Haven, Connecticut, May 2013.

Golder Associates, 2014a. 2013 Annual Progress Report, Pharmacia & Upjohn Company LLC Site, North Haven, Connecticut, January 2014.


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Golder Associates, 2014b. SEC-7D Pre-Design Investigation Report and Preliminary Design Proposal,

Pharmacia & Upjohn Company LLC Site, North Haven, Connecticut, revised February 2014.

Golder Associates, 2014c. Groundwater Extraction System Hydrogeologic Final Design (Appendix H of the East Side Remedial Components Design Report) Pharmacia & Upjohn Company LLC Site, North Haven, Connecticut, July 2014.

Golder Associates, 2014d. Post-CMI Groundwater Monitoring Plan (Attachment A to Appendix D of the East Side Remedial Components Design Report) Pharmacia & Upjohn Company LLC Site, North Haven, Connecticut, July 2014

Hydrodata, Inc, 2014. Effluent Mixing Zone Dye Study Report, November 2014

TerraTherm and Golder Associates, 2013. Draft In-Situ Thermal Remediation Pilot Study Final Report and Full-Scale Preliminary Design Proposal, Pharmacia and Upjohn Company LLC, North Haven, Connecticut, August 2013.

TerraTherm and Golder Associates, 2014. Full Scale In Situ Thermal Remediation Draft Final Design Report, Pharmacia and Upjohn Company LLC, North Haven, Connecticut, December 2014.

USEPA, 2010a. Statement of Basis for Pharmacia & Upjohn Company LLC Site, North Haven, Connecticut, June 2010.

USEPA, 2010b. Final Decision and Response to Comments for Pharmacia & Upjohn Company LLC Site, North Haven, Connecticut, September 2010.

USEPA, 2011. Administrative Order on Consent in the Matter of the Pharmacia & Upjohn Company LLC, 41 Stiles Lane, North Haven, CT, (USEPA Docket Number RCRA-01-2011-0027), March 2011.

WRS and Brown and Caldwell, 2013a. Final Draft Corrective Measures Design Report East Side Remedial Components, Pharmacia & Upjohn Company LLC Site, North Haven, Connecticut, March 2013.

WRS, Brown and Caldwell and Golder, 2013b. Engineered Control Fact Sheets for the Remaining ESRC, Pharmacia & Upjohn Company LLC Site, North Haven, Connecticut, October 2013. Revised March 2014.

WRS, Brown and Caldwell and Golder, 2014. Corrective Measures Design Report East Side Remedial Components, Pharmacia & Upjohn Company LLC Site, North Haven, Connecticut. August 2014.


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